Exchange Comments to the Proposed AQI Fee Increases
This letter is to express concerns and oppose certain of the fees outlined in the above-referenced proposed rulemaking. As information, the Maritime Exchange for the Delaware River and Bay is a nonprofit trade association representing the interests of commercial port stakeholders in the tristate Delaware Valley.
The Maritime Exchange strongly supports APHIS and the Agricultural Quarantine Program. Exchange members join APHIS in its commitment to preventing the introduction of foreign pests into the U.S. ecosystem. We also recognize the severe financial constraints that have plagued the AQI program for the last several years, and our members have invested significant time and energy to work with APHIS personnel to identify innovative solutions to address the issue. Further, the Exchange and its members agree that reasonable fee increases are necessary from time to time.
We appreciate this opportunity to provide comment to the proposed rulemaking and look forward to working with APHIS to identify a rate structure that is both equitable and helps meet program needs. Following are key considerations we would ask program managers to evaluate prior to finalizing the new rate structure.