60-day Federal Register Notice Comment 1

Reiner Kahn - Comments

Document ID:

FMCSA-2010-0286-0002

This is comment on PROPOSED RULE: Agency Information Collection Activities; Proposals, Submissions, and Approvals: Request for Revocation of Authority Granted

Docket ID:

FMCSA-2010-0286

Topics:

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Name	Value
First Name		Fritz

Title	Fritz Reiner Kahn - Comments
Middle Name	Reiner

Last Name	Kahn
Mailing Address	1920 N Street, N.W. (8th floor)

City	Washington
Document Type	COMMENT

Country	United States
Document Sub-Type	Comment(s)

State or Province	DC
Postal Code	20036

Organization/ Org Unit	Fritz R. Kahn, P.C.
Submitter's Representative	Fritz R. Kahn, owner

Author/ Document Date	August 26 2010, at 12:00 AM Eastern Daylight Time
Received/Filing Date	August 25 2010, at 12:00 AM Eastern Daylight Time

Date Posted	August 26 2010, at 12:00 AM Eastern Daylight Time
Comment Start Date	August 24 2010, at 12:00 AM Eastern Daylight Time

Comment Due/Reply Date	October 25 2010, at 11:59 PM Eastern Daylight Time
Page Count	1

 

 

Attachments

FMCSA-2010-0286-0002.1

PUBLIC SUBMISSION

As of: November 09, 2010
Tracking No. 80b3a762
Comments Due: October 25, 2010
  Late comments are accepted

Docket: FMCSA-2010-0286
Notice of Request to Revise a Currently-Approved Information Collection: Request for Revocation of Authority Granted

Comment On: FMCSA-2010-0286-0001
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Request for Revocation of Authority Granted

Document: FMCSA-2010-0286-0002
Fritz Reiner Kahn - Comments

Submitter Information

Name: Fritz  Reiner  Kahn
Address:

1920 N Street, N.W. (8th floor)
Washington,  DC,  20036

Submitter's Representative: Fritz R. Kahn, owner
Organization: Fritz R. Kahn, P.C.

General Comment

Form OCE-46 fulfills an important need and by no means should be revoked. Affiliated motor carriers in order to effect corporate simplification may want to relinguish the operating authority of one of the motor carriers. The motor carrier can do so quickly and inexpensively by submiting Form OCE-46 to FMCSA, retaining a copy for its files. If there were no Form OCE-46, the motor carrier, of course, could cease paying the premium for its bodily injury and property damage insurance, whereupoon FMCSA eventually would suspend or revoke the motor carrier's authority to operate. That carries with it an undesireable connotation, suggesting that the company lacked sufficient funds to pay the insurance policy premiums. On the FMCSA's web page, the motor carrier would be shown as being inactive, whereas the motor carrier should be shown as having chosen to cease engaging in the for-hire transportatin business. Fifteen minutes to complete Form OCE-46 is not such a burden tht its revocation would have any real significance under the Paperwork Reductiion act of 1995.

CURRICULUM VITAE

OF

FRITZ R. KAHN

Fritz R. Kahn is a lawyer with offices at 1920 N Street, NW (8^th fl.), Washington, DC 20036, specializing in transportation regulatory matters. He represents shippers, governmental bodies, short line railroads and motor carriers before the Surface Transportation Board, the Federal Railroad Administration, Federal Motor Carrier Safety Administration and reviewing courts.

His work covers the entire gamut of STB’s jurisdiction, including mergers and acquisitions, line extensions and abandonments, rates and services, declaratory order and rule making proceedings and the like, and before the FRA and FMCSA he principally defends those accused of having violated the agency’s regulations.

Among his current clients are Natchez Railway, Potlatch Corporation, State of Illinois Department of Transportation, SMS Rail Services, Inc., V&S Railway. and BK Trucking Company.

Mr. Kahn has been identified and rendered reports as an expert witness in a variety of rail and motor carrier related cases. He is a Researcher for the Legal Knowledge Network and a Council Member of the Gerson Lehman Group.

Mr. Kahn is the founder and manager of Transportation Arbitration and Mediation, P.L.L.C., the body designated to arbitrate disputes of the Transportation Intermediaries Association and the Commodity Classification Standards Board of the National Motor Freight Association.

Now a solo practitioner, he was a partner for many years with Verner, Liipfert, Bernhard and McPherson, at the time Washington's foremost transportation law firm, subsequently merged into DLA Piper Rudnick & Gray Cary US LLP. Among other clients, he then represented were the Chicago and Northwestern Transportation Company, before its acquisition by Union Pacific Railroad Company, and Mobil Chemical Company, before its acquisition by Exxon Chemical Americas.

Mr. Kahn entered private practice after serving six years as the General Counsel of the Interstate Commerce Commission, predecessor of the Surface Transportation Board. In that capacity, among other things he argued two cases before the Supreme Court, Northern Lines Merger Cases, 396 U.S. 491 (1970), and Port of Portland v. United States, 408 U.S. 811 (1972).

Mr. Kahn is a member and a past President of the Association of Transportation Professionals, a member and a past General Counsel of the Transportation Research Forum, and a member of the American Society of Transportation Logistics and of the Transportation Lawyers Association.

He is a frequent contributor to transportation law journals, his most recent article being "Those Staid Stays", vol. 76, The Journal of Transportation Law, Logistics and Policy, no. 2, Second Quarter 2009.

Mr. Kahn is a Phi Beta Kappa and Omicron Delta Kappa graduate of the Columbian College of the George Washington University of Washington, DC, and an Order of the Coif and Law Review graduate of the University’s National Law Center.