STA does not support the Proposed Funding Model and we recommend the Commission deny the Filing and instruct the Operating Committee for CAT to address issues involving collaboration with Industry Members and transparency on costs, allocations and fees before re- submitting a revised funding proposal. STA believes the Proposed Funding Model lacks material information pertaining to costs associated with building, implementing, and maintaining CAT. The Proposed Funding Model applies fees to Industry Members to recoup such costs. Absent this information, Industry Members are unable to provide meaningful input that would ensure CAT achieves its intended goals on an efficient basis.

Read the full letter here.