![](media/image1.wmf){width="1.6972222222222222in"
height="0.9041666666666667in"}**P.O. Box 91081**

**Los Angeles, CA 90009-1081**

**1125 W. Hillcrest Blvd.**

**Inglewood, CA 90301**

# Email: info @ dolphin-int.com

**Tel: (310) 645-2046, Fax: (310) 337-1393.**

November 14, 2023

U.S. Department Of Interior (Division of Policy and Directives
Management)

U.S. Fish & Wild Life Service

4401 N. Fairfax Drive, Suite 222

Arlington, VA. 22203

[REF: Proposed F&W inspection fees RIN 1018-AV31]{.underline}

To: Whom it May Concern

I write this letter in response to the new proposed import inspection
fee schedule for USFW. We have been Tropical Fish Importers here in Los
Angeles since 1976, and bring in about 800 shipments annually that clear
thru USFW inspection. Many of these shipments are small and thus high
inspections fees really add a lot to the cost of a small shipment. We
have a very good reputation with USFW here in Los Angeles, and we
appreciate their services very much, but such increased fees could put
us out of a business that we have been in over 30 years now.

We are presently paying a \$55.00 fee, plus the overtime fees for most
of our shipments. In our industry we are forced to bring in many weekend
shipments because our customers want fish on Mondays. Therefore we have
always incurred many weekend overtime fees which have been hard on us.
For example, in 2007 we paid \$132,590.00 in fees to USFW. 2007 was a
tough year for us; with all the fuel increases and air freight increases
we could barely break even. We employ about 40 persons, many of them for
over 25 years. We fear we could go out of business if fees keep going
up. Our customers are also hurting, so we find it very hard to raise the
price that we sell things for, or they will suffer... As I read the new
fees some of them could double our costs. [Really, a 10% overall fee
increase we could bear, but more than that could be the ruin of
us]{.underline}.

We have been paying now a \$55 fee plus vertime and inspecition fees. As
I read the proposal, that base fee would go to \$85.00 plus \$19.00 (Due
to it being Live Species) totalling \$104.00, which is about a 90%
increase for the first year. With further proposed increases over the
next few years and, of course, the high inspection fees and overtime
inspections fees on top of it all, we feel this would slowly if not
quickly [fee us to death in this small margin business.]{.underline}

We are really also concerned about the overtime fees for Saturday and
Sunday shipments under the proposal, which states that rates will go up
to a minimum of \$96 for the first hour + \$48 per each additional hour.
What is confusing is that if an importer has three or four shipments at
the same airline, all ready for inspection at the same time, is there
one fee of \$96.00 for this? What about if there are numerous shipments
from various importers at the same airline at the same time, do we all
share the costs? There is no standard stated for this, and tacking on
additional fees just seems unfair to us.

I understand that UFWS must recoup the costs of inspections, but I
believe the costs should be spread fairly across all the importers and
exporters, and you haven't done that in your proposal.

I thank you for consideration of our views on this matter. Please don't
make us another failed business which has to lay off people.

Thank you very much

Steven Lundblad

Pres. Dolphin International