I have a few issues with the following charges:
1. There should be no charge to discuss with an importer about the
obligations pertaining to a cash bond. If you do decide to go forward with this
charge, does this mean you would send the importer a bill for this even if he
decides not to pursue a cash bond?
2. The NHTSA can e-mail this agreement at no charge.
3. The formal agreement has already been prepared. The RI is required to
full in the required information. (no charge)
4. When do you charge for receiving mail?
5. Does it take 6 different employees for the ?prepared agreement approval
to the prepared importer approval letter?? 70 minutes??
6. Why does the importer need a new letter of approval when you can
send them a copy of the CBP approval letter?
7. Has the NHTSA charged any form? The cash agreement is a standard
form that is already on someones computer at the NHTSA, and can be stored on
the RIs? computer as well.
8. I don?t think it takes 60 minutes to write a check to send to the RI.
The following should be a one time only charge if you decide to charge for them at
all:
1. Information about a cash bond
2. The agreement for the cash bond. This is a form that lets the RI change
the required information when needed.
I feel that there will be unnecessary charges and double billing ever time the RI
gets a cash bond if this proposed rulemaking of schedule fees is allowed to go
through the way it is setup at this time. I propose that the NHTSA provides a
revised chart as to the disposition for the fees.
Carl D. Brinegar - Comments
This is comment on Rule
Schedule of Fees Authorized by 49 U.S.C. 30141 Offer of Cash Deposits or Obligations of the United States in Lieu of Sureties on DOT Conformance Bonds
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Related Comments
Public Submission Posted: 01/09/2008 ID: NHTSA-2007-0037-0002
Jan 07,2008 11:59 PM ET