The new rule envisions imposing a filing fee of $350 on protesters. We respectfully request that an exception to the fee be created for small businesses, as defined under the Small Business Act, in order to mitigate against the burden of this requirement.
While we concur with the creation of a rule providing for a redaction process, we respectfully request that the rule allow the parties to opt out of creating redacted versions of protest documents should they wish to do so. Creating a redacted version of a protest filing can be a lengthy process involving a significant amount of attorney time spent not only reviewing and redacting the protest, but also in negotiating and reaching agreement with all of the parties. Because of these expenses, it is not uncommon for parties to jointly decide not to seek redacted versions of filings as a means of avoiding unnecessary legal costs.