ML20057B924
| ML20057B924 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1993 |
| From: | De Planque E NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR50859 AE83-1-007, AE83-1-7, COMSECY-93-043, COMSECY-93-43, NUDOCS 9309240152 | |
| Download: ML20057B924 (1) | |
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e August 19, 1993 OFFICE OF THE COMMISSIONER MEMORANDUM FOR:
Samuel J.
Chilk Secretary of the Commission FROM:
E.
Gail de Planque hgdL
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SUBJECT:
PETITION FOR RECONSIDERATION OF ANNUAL FEE RULE (COMSECY-93-043)
I would grant the petition for reconsideration of the FY 1993 annual fee rule because I believe the Commission erred in deciding to revoke the generic exemption for educational institutions rather than to pursue basing the exemption on the
" externalized benefit" rationale suggested by the Allied-Sicmal Court.
I agree with Commissioner Remick that, despite the further confusion granting the petition will entail, failure to grant it will only compound the error and ensnare the Commission as well as licensees in a large expenditure of resources and in litigation which will most likely accompany the effort to determine individual exemptions.
cc:
Chairman Commissioner Rogers Commissioner Remick OGC EDO OC 9309240152 930819 PDR COMMS NRCC nf g CDRRESPONDENCE PDR.
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