NRC-2012-0286, Comment (1) of Mark Sokolow on Notice of Consideration of Indirect Transfer and Conforming Amendment

Comment (1) of Mark Sokolow on Notice of Consideration of Indirect Transfer and Conforming Amendment

ML13017A407
Person / Time
Site:	Aerotest
Issue date:	01/07/2013
From:	Sokolow M Law Office of Mark Sokolow
To:	Rulemaking, Directives, and Editing Branch
References
77FR72889 00001, NRC-2012-0286
Download: ML13017A407 (2)

Text

Page 1 of 2 As of: January 16, 2013 Received: January 07, 2013 PUBLIC SUBMISSION Status: Pending_-ost PUBL C S BMIS IONTracking No. ljx-82z2-e7p Comments Due: January 0, Submission Type: Web Docket: NRC-2012-0286 Notice of Consideration of Indirect Transfer and Conforming Amendment Comment On: NRC-2012-0286-0001 Aerotest Operations, Inc., Consideration of Indirect Transfer and Conforming Amendment Document: NRC-2012-0286-DRAFT-0001 Comment on FR Doc # 2012-29523 U

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Submitter Information Name: Mark Sokolow i-T Address:

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338 Wedgerock Drive Fri Webster, TX, 77598 Organization: Law Office of Mark Sokolow General Comment The proposed agency action should be delayed until additional information is provided to the public.

On January 21, 2009, President Obama jump-started the development of federal government websites by issuing a Memorandum on Transparency and Open Government (Obama, 2009, p.

4685). This memorandum emphasized that government should be transparent, participatory and collaborative. In terms of transparency, President Obama indicated that "Executive departments and agencies should harness new technologies to put information about their operations and decisions online and readily available to the public" and the President instructed the Director of Management and Budget and the Administrator of General Services to coordinate the development of the agencies and departments implementing the principals of this Open Government Directive (4685). In response, Director Orszag of the Office of Management and Budget issued an Open Government Directive on December 8, 2009, which presented a 60-day timetable to "respect the presumption of openness by publishing information online" and Director Orszag reminded the agencies that the government has defined guidelines as to the objectivity of information (Orszag, 2009, p. 1-10). The federal guidelines focused on whether the "disseminated information is being presented in an accurate, clear, complete and unbiased manner. This involves whether the information is being presented within a proper context" (Guidelines, 2001, p. 8459).

You should be providing a summary as to why it is necessary for these intercompany transfers to take place. It really looks like Aerotest Operations is attempting to reduce its liability and assign it to a subsidiary. Is this subsidiary capitalized? Who are the principals or shareholders in the company? Are there any security concerns and have they been addressed?

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Page 2 of 2 MARK SOKOLOW ATTORNEY AT LAW 338 Wedgerock Webster, Texas 77598 http://mtsokolow-attorney.com mark@mtsokolow-attomey.com https ://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 01/16/2013