Comment on FR Doc # N/A

STATEMENT BY DANIEL L. WILLETT ON PUBLIC APPROVAL GUIDANCE FOR TAX-EXEMPT BONDS, Docket IRS-2008-0095 I oppose changes to the TEFRA requirements for consideration of Private Activity Bonds. My experience with participating in consideration of these Bonds was in southeast Wisconsin in the 1980s after TEFRA requirements were legislated. A coalition of community and labor organizations utilized information on Industrial Revenue Bonds and 501c3 bonds for job retention and job creation. There are big problems with Private Activity Bonds that I will not go into in this statement. I oppose reducing the requirement for published notice of hearings from fourteen (14) days to seven (7) days. We were following initial notice of hearings on Industrial Revenue Bonds in southeast Wisconsin. Bonds were issued by the state, cities, villages, and towns -- a total of 141 different issuing bodies in an eleven-county area. There was no one source for public notices. Some newspapers in urban areas had a concentration of the notices but that did not help for proposals by companies to move from urban areas to the edge of metropolitan areas. Besides those legal notices we were forced by a lack of alternatives to monitor paper notices on bulletin boards in municipal buildings or make arrangements to have agendas sent to us via postage-paid envelopes that we supplied. I understand that the changes proposed by the IRS include options for internet-based communications by government. I think this would not have changed anything in my experience because some smaller municipalities will not offer internet-based options or may restrict access to internet-based communications and alternative telephonic communications to their own residents and not include a regional coalition like ours. In short, fourteen days was not enough time to stay on top of the notices so I know that seven days will not be enough time. I oppose the option for issuing bodies of canceling hearings if no outside interest is expressed before the hearing. Given the short time of public notice, it was a scramble for us to analyze the information and decide if we wanted to participate in a hearing. A deadline for registering interest in a hearing further decreases the time we would have had to decide whether we wanted to participate in a public hearing. I oppose allowing issuers to provide fewer details on projects. Our coalition followed Private Activity Bonds for both job retention and creation. We opposed Bonds that subsidized job piracy or displaced workers from their jobs by moving too far. We also wanted to draw a distinction between job retention and job creation, terms that are sometimes used interchangeably. Both are important but the unemployed need job creation. We needed as much information as possible on the projects to discern the anticipated job retention and job creation. Although information on the developer would have helped with understanding the resulting construction jobs, we needed to know the name of the employer for evaluating the permanent jobs. Although applications by new incorporations of general and limited partners can capture the legal relationship between parties, they would make it harder for community and labor organizations trying to determine who will be doing the hiring. In closing, I ask you to view the processes for issuance of Private Activity Bonds through the eyes of community and labor organizations with limited resources trying to get enough information in a short period of time to decide whether to support or oppose individual issuances. These proposed changes will hurt their efforts to include more people in the public purposes of these Bonds.