Bonnie Montgomery

TSA's proposed change in fee structures for STA applications is to be set at $13 - $21 per STA. IACs have been charged $28.00 per application since the beginning of the program, which means TSA has been overcharging in the amount of $8 - $15 per STA. This amounts to nearly $10,000.00 for my company. I feel we are owed a refund of the difference, since the proposed regulation states that TSA is not allowed to make a profit on STAs. This refund could be in the form of credits for free STAs until the difference is used up. Further, non-IACs who are entering the CCSP program have been given free STAs since there was no authority for charging them. Under no circumstances do I agree with this policy if there is not a similiar treatment for IACs, and other stakeholders, during the same time period. This is discrimination, and in violation of fair trade policies & practices. I believe all IACs and other stakeholders should be reimbursed for the STAs they paid for during the same time period that free STAs were given to one favored branch of the private sector. This could also be in the form of credits as above mentioned. TSA had the option of waiting to process those STAs after they were allowed to charge for them, and certifiying all shipper-CCSFs conditionally, until such time as their STA applications were paid for. TSA has the capacity to process many STA applications simultaneously, and could have done so in this instance.