William Bray Smith - Comment

Companies that have already implemented Site Specific Security Plans as required in 49CFR172 should be required to maintain some level of security as opposed to completely dropping SSSP if the proposed rule becomes final with the current language and thresholds. Significant dollars have already been spent to secure sites that would become non-regulated under the propsed rule. The maintenance and upkeep of these SSSP's is a minor burden once the initial assessment is performed and the plan and related security control measures are put in place. In fact if the proposed rule goes in to effect the results could be a loss of jobs in certain instances where security personel have been hired as part of the SSSP and if the facility is no longer required to have an SSSP then there would be no need for those employees. Certainly over regulation is a burden as well but there needs to be common meeting ground some where between the "all or none" theory and the "selected few" theory. A basic simple plan should still be required for facilities producing hazardous materials in placarded quantities.