text of comments to nrc re: fee exemption follows

["PAUL SKIERKOWSKI, UNIV. OF OKLAHOMA" <RADSAFE@aardvark.ucs.uoknor.edu>]

***** THE FOLLOWING IS THE TEXT OF THE REPLIED TO NRC ON FEE EXEMPT STATUS  PREPARED FOR SIGNATURE OF PROVOST OF UNIV. OF OKLAHOMA  ****

***** I HOPE WE'VE ADDRESSED THE "EXTERNALIZED BENEFITS" TERM ****
***** comments welcome *****






Secretary
U.S. Nuclear Regulatory Commission
ATTN: Docketing and Service Branch
Washington, DC  20555


SUBJECT: Proposed Revisions to 10 CFR Part 171 on Annual Fees, per
Federal Register Notice of 30 September 1993

Dear Sir:

This letter is in support of the Commission's proposed change to 10 CFR
Part 171 which would restore the generic exemption from annual fees for
nonprofit educational institutions.

The use of byproduct material in the teaching and research activities
at this institution produces significant externalized benefits to the
nation through medical and scientific advances.  Many of our science
departments have international reputations for their findings in
genetic research, much of which is made possible only through use of
byproduct material.  These research findings are shared with the
scientific community through publication in journals (usually at our
own expense), not through sale to commercial industries. In addition to
this advancement of the knowledge base,  future researchers learn the
basic techniques that they will utilize when they finish their courses
of study, and begin their independent research and teaching careers.  

The National Center for Groundwater Research is located at our insti-
tution.  A large amount of the research conducted by this Center
focuses on the fate of pollutants in our environment, and a majority of
these studies utilize byproduct material as a research tool to deter-
mine the transport and potential degradation of pollutants.  The re-
sults of this research have yielded significant advances in the areas
of environmental assessment and remediation.  Again, these "externali-
zed benefits" are shared with the scientific and regulatory community
without any profit motive.

The knowledge gained by our faculty and staff through these activities
has enhanced the advancement of technology through their participation
in various organizations, review panels, study commissions and govern-
mental advisory councils.  It is this knowledge, that they gain through
their work, that qualifies them to serve on such and this volunteer
service benefits both the scientific community and national agencies.


Secretary, USNRC
date
Page 2



It has been suggested that the costs associated with the fee assessed
to educational institutions can in fact be passed on in the form of
tuition etc.  At present, the cost of undergraduate and graduate educa-
tion is escalating at a phenomenal rate, while tuition, grants in aid
and other financial support seems to be decreasing.  When considering
the minimal stipends provided to graduate students, if the fee is
"passed on," the results easily could be to reduce the number of
potential scientists because of the economic hardship of paying an
additional fee to learn correct and safe handling methods needed for
their research.

The research, teaching and service missions performed by academic
institutions are the backbone of the scientific community in this
country.  The results of these missions translate as externalized
benefits to the nation as a whole in terms of advancement and progress
as well as improvements in the quality of life.  As such,  the Univer-
sity of Oklahoma strongly feels that such externalized benefits justify
the fee exemption proposed.


Sincerely,



 
University Provost