Comment from Martin D Thomas, Arkema, Inc

Lifting the exemption from user fees for commercial trucks & commercial railroad cars results in the carriers passing on the fees to the importers who have already been hit hard with internally funding security measures after 9/11. Aside from C-TPAT, ACC's Responsible Care initiative and DOT's security regulations, our company as many others must comply with ISPM 15. All of the security measures mentioned are justified along with the cost to implement. However, concerning this docket, we import in bulk chemicals. The likelyhood of pests problems within a tank of chemicals is unlikely. Problems outside the railcars & bulk trucks should be easier to inspect as opposed to materials inside a passenger car, package truck & airlines. We believe that APHIS, in protecting our borders, may need to expand and strengthen their pest exclusion and smuggling interdiction. However, this system of targeted should not be accross the board and at the expensive of all industry. The times of 9/11 will be felt for decades to come. At this point in time user fees are not the answer to protect our borders. The answer is more government funding to hire an adequate number of permanent inspectors at our borders if APHIS and CBP are not adequately staffed to protect U.S. interests. If this is an impossible direction to take, targeting shipments of chemicals by commercial air, rail and truck should continue to be exempted based on APHIS's current ISPM 15 initiative and the nature of the imported product.