Attached Comment

Dear Mr. Betts, I am respectfully submitting comments on the recent Notice of Proposed Rulemaking (NPRM) published by the Pipeline and Hazardous Materials Safety Administration (PHMSA) on July 31, 2008 entitled "Hazardous Materials: Revision to Requirements for the Transportation of Batteries and Battery -Powered Devices" (HM-215J). In this NPRM, a new provision for transporting "portable electronic devices" containing fuel cell systems is being proposed in 49 CFR 175.10(a) (18). Examples of such "portable electronic devices" listed in this proposed rule include: "cameras, cellular phones, laptop computers, and camcorders". Examples of allowed "portable electronic devices" included in the proposed list in 49 CFR 175.10(a)(18) are identical to those devices containing lithium cells or batteries currently listed and allowed in 49 CFR 175.10(a)(17). However, in 49 CFR 175.10(a)(17), the term "consumer electronic and medical devices" is used to describe these identical devices. For purpose of clarity in the regulations, I am requesting that the identical term "portable electronic devices" be used to describe these identical devices containing lithium cells or batteries. I am requesting that the term "portable electronic devices" be incorporated into 49 CFR 175.10(a)(17) to replace the existing term "consumer electronic and medical devices". If this comment is outside of the scope of public comments received on the proposed rule (HM-215J), then I would like to submit the comment as a request for a regulatory change. Thank you for your consideration of this request. Sincerely, Andrew Romach Regulatory Manager URS Corporation