Comment on FR Doc # E7-11810

The basic problem is the lazy and indefensible "one size fits all" approach that the State Department has predictably used ... that there would be a "flat fee" applied to all programs regardless of size or nature. This stupid idea is merely a substitue for thinking. Perhaps the IRS will next adopt a personal income tax that taxes Warren Buffet and Bill Gates and all average citizens a flat amount each year regardless of their income or ability to pay! Only the government would treat a J-1 program run by volunteers (as in Rotary International) who issues 20 DS-2019 forms for high school students the same as a large F-1 University program like Harvard or Princeton with a budget of billions a year! Your cost accountants did an admirable job (it appears) in evaluating the direct and indirect costs ... but then the morons above them said "lets apply the costs evenly across the board." So should the post office charge the same amount for a post card and a large package?????? Volunteer programs have absolutely NO budget for SEVIS fees, but we will somehow pay our fair share ... but our share should be based on the government's actual costs of 20 high school exchange visitors annually versus a university which invites hundreds or perhaps thousands of students per year. Your proposal would in effect have small programs who are already short of funds subsidize large programs who have millions or even billions in the bank and ready revenue sources. Your flat fee idea is sloppy .. it must have been the product of an official who wants to kill off small J-1 programs. If that is the State Department's aim, keep it up, you'll get there! Signed, Harlow A. Hyde, Inbound Student Coordinator, Rotary District 5610-5630-5650. Lincoln, Nebraska USA