Christopher James Bradley - Comment on FR Doc # 2011-17994

1.) 88 hour loading limit....Extraneous and unesscary rule. The steamship lines have strict rules with financial penalties if the containers are kept by the shipper for a long period. This issue solves itself as their financial disincentives to load one booking over a long period of time. The rule will add more rules for a very minute percentage of the containers shipped. 2.)Grade Cert Can cover a max of 20 boxes...A barge is the equivalent of 65 containers and a vessel is much more than that. To limit container shipments to only 20boxes per grade cert is a disadvantage for the container shippers in both cost and competition.