Comment Submitted by James Clawson, Joint Industry Group

November 24, 2009 Department of Homeland Security Trade and Commercial Regulations Branch Regulations and Rulings Office of International Trade U.S. Customs and Border Protection 799 9th Street, NW. (Mint Annex) Washington, DC 20229–1179. Department of the Treasury Regulations and Rulings Division Alcohol and Tobacco Tax and Trade Bureau P.O. Box 14412 Washington, DC 20044–4412 Dear Secretary Geithner and Secretary Napolitano: The Joint Industry Group respectfully requests that you extend the public comment period for proposed rule numbers RIN 1505–AC18 and 1513–AB77, proposed by the Bureau of Customs and Border Protection (CBP) and the Alcohol and Tobacco Tax and Trade Bureau (TTB) respectively on October 15, 2009. These proposed rules, if implemented, will fundamentally change the existing administrative practice applied to the substitution drawback program. Many of our members rely on Title 19 of the U.S. Code, Section § 1313(J)(2), which provides for, as a matter of law the substitution drawback of any duty, tax or fee imposed under federal law upon importation. The Notices seek to reinterpret statutory right. As such, the members of the Joint Industry Group require additional time to fully evaluate the economic impact that these proposed rules will undoubtedly have on businesses and to submit thorough comments accordingly. The Joint Industry Group therefore requests that CBP and TTB extend the public comment period by 60 days. Thank you for your consideration. Sincerely, James B. Clawson Secretariat