Comment on FR Doc # E9-85

The District is strongly opposed to this rule. The cost of additional manpower to plan and implement this rule would be costly. It would take many hours of planning, software re-writes, and finally additional manpower to implement and track. This is coming at a time when we are all facing drastic staff cuts due to the economy and budget cuts. Vendors who fall into this category will most likely be required to increase their fees/prices to cover their operating costs in order to track withholding amounts paid on their behalf by the governmental entity and also cover the cost of cash flow reduction. If prices/fees cannot be raised, they may forego doing business with the government entity. Many small businesses may go out of business as their profit margins may not allow for the 3% withholding on the gross sale. Overall, this is an unnecessary burden on both the governmental entity and the vendor. It will only add costs and increase inflation. It is a very bad idea at a very bad time.