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Proposed Ballot 2007-02 Comments
| Jurisdiction/Company |
Position |
Comments |
| Alabama |
Support |
Support. This proposed procedure is fair to the registrant and all affected jurisdictions without being overly punitive. |
| Washington |
Opposed |
Do not support the proposed ballot. Ballot tries to establish a uniform 20% penalty for not complying with the IRP recordkeeping provisions. Ballot conflicts with IRP Section 100, IRP Section 400, IRP Section 1060, etc. In summary, IRP cannot establish nor assess a fee, tax, penalty, or interest rate that is not in accordance with the statutes of each jurisdiction. |
| ATA |
Opposed |
This suggestion is hardly less arbitrary than the existing 100% fee assessment. Something better is needed. Opposed. |
| Oregon |
Opposed |
Do not support. Whether or not Oregon philosophically agrees with the notion of a 20% penalty for lack of records Washington has a point about the legality of IRP assessing a penalty that may not be supported by jurisdiction statutes. |
| Total supporting: |
1 |
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| Total opposed: |
3 |
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| Total undecided: |
0 |
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