Garry Bonelli — joined the Port Commission, seeing the world (or at least Israel) for free.

San Diego Unified Port District commissioner Garry Bonelli is looking to go on a spring junket to Israel and Jordan, but before making his reservations the retired two-star admiral checked in with the state’s Fair Political Practices Commission to make sure everything is kosher.

The tab for the two-week tour for retired U.S. generals and admirals “to meet the top echelon of the Israeli military and political leadership” is being footed by the Jewish Institute for National Security Affairs. It’s a Washington DC–based nonprofit group that bills itself on its website as an advocate of “a strong U.S. military, a robust national security policy, and a strong U.S. security relationship with Israel and other like-minded democracies.”

A February 25 letter to port lawyer William McMinn from commission counsel Zackery P. Morazzini says: “During the 2013 Program, the participants observed Israeli military exercises in the field, visited key Israel Defense Force and national intelligence installations, and were briefed on the latest Israeli war fighting doctrine, national security plans, and technological and cyber innovations. Public officials with whom they met include Minister of Defense Moshe ‘Bogie’ Ya’alon, IDF Chief of Staff Benny Gantz, Director General of the Ministry of Defense Udi Shani, and Head of the National Security Council Yaakov Amidror.” The program “was created in cooperation with the Israel National Police, the Israel Ministry of Internal Security, and the Israel Security Agency (Shin Bet) to support and strengthen American law enforcement counter terrorism practices.”

So, can Bonelli accept the freebie, well over the Port’s $440 gift limit, and does he have to tell the public how much the trip was worth? Says Morazzini’s letter: “Payments for travel, lodging and meals can be either a reportable gift to [Bonelli] or income if he provided consideration of equal or greater value. It appears from the facts that the payments are income rather than a gift.” The attorney then goes on to conclude that “income payments that are reimbursement for travel expenses…received from a bona fide nonprofit entity” are legal for Bonelli to accept and don’t have to be disclosed on his annual statement of economic interests.

A former Navy SEAL and San Diego chamber of commerce executive, Bonelli joined the port board last December as the representative of Coronado. “The SEALs are a very offensive force, but kicking in doors is just a small part of it,” he was quoted as saying at the time of his appointment.