A-22992, MAY 15, 1928, 7 COMP. GEN. 724

A-22992: May 15, 1928

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TRANSPORTATION RATES - SHIPMENTS IN FULLY LOADED CARS THE ALLOWANCE FOR TRANSPORTATION OF A CARLOAD SHIPMENT WHERE THE CAR IS FULLY LOADED WILL BE DETERMINED FROM THE CARLOAD RATE AND MINIMUM WEIGHT. THE CHARGE THUS ARRIVED AT MUST NOT EXCEED THE CHARGE FOR THE SAME LOT OF FREIGHT IF TAKEN AS A LESS-THAN-CARLOAD SHIPMENT AND THE PENALTIES PROVIDED BY RULE 5 OF THE CONSOLIDATED FREIGHT CLASSIFICATION FOR NONCOMPLIANCE WITH THE PACKING REQUIREMENTS OF LESS-THAN-CARLOAD SHIPMENTS WILL NOT BE APPLIED WHEN DETERMINING THE CHARGES APPLICABLE UNDER RULE 15 OF THE CLASSIFICATION. WHEREIN $300 WAS DEDUCTED ON ACCOUNT OF DAMAGE IN TRANSIT OF AIRPLANE NO. $58.01 WAS DISALLOWED ON ACCOUNT OF CHARGES FOR TRANSPORTATION OF AIRPLANE NO.

A-22992, MAY 15, 1928, 7 COMP. GEN. 724

TRANSPORTATION RATES - SHIPMENTS IN FULLY LOADED CARS THE ALLOWANCE FOR TRANSPORTATION OF A CARLOAD SHIPMENT WHERE THE CAR IS FULLY LOADED WILL BE DETERMINED FROM THE CARLOAD RATE AND MINIMUM WEIGHT, OR ACTUAL WEIGHT WHEN IN EXCESS OF THE MINIMUM, BUT THE CHARGE THUS ARRIVED AT MUST NOT EXCEED THE CHARGE FOR THE SAME LOT OF FREIGHT IF TAKEN AS A LESS-THAN-CARLOAD SHIPMENT AND THE PENALTIES PROVIDED BY RULE 5 OF THE CONSOLIDATED FREIGHT CLASSIFICATION FOR NONCOMPLIANCE WITH THE PACKING REQUIREMENTS OF LESS-THAN-CARLOAD SHIPMENTS WILL NOT BE APPLIED WHEN DETERMINING THE CHARGES APPLICABLE UNDER RULE 15 OF THE CLASSIFICATION.

DECISION BY ASSISTANT COMPTROLLER GENERAL GINN, MAY 15, 1928:

SAN DIEGO AND ARIZONA RAILROAD CO. REQUESTED REVIEW OF SETTLEMENT T 55195, JANUARY 24, 1928, WHEREIN $300 WAS DEDUCTED ON ACCOUNT OF DAMAGE IN TRANSIT OF AIRPLANE NO. A-7266 PER BILL OF LADING N-434651, AUGUST 1, 1927, AND $58.01 WAS DISALLOWED ON ACCOUNT OF CHARGES FOR TRANSPORTATION OF AIRPLANE NO. A-7286, PER BILL OF LADING N-434665, AUGUST 31, 1927, BOTH SHIPMENTS FROM CLEVELAND, OHIO, TO NAVAL AIR STATION, NORTH ISLAND, CALIF.

THE CARRIER IN ITS APPLICATION FOR REVIEW CLAIMS THE AMOUNT DEDUCTED ON ACCOUNT OF DAMAGE IN TRANSIT TO AIRPLANE NO. A-7266 AND FILES A LETTER DATED FEBRUARY 7, 1928, FROM THE SUPPLY OFFICER, NAVAL AIR STATION AT SAN DIEGO, CALIF., STATING THAT THE RESPONSIBILITY FOR THE DAMAGE HAS BEEN PLACED ON THE MANUFACTURER AT CLEVELAND, OHIO, BECAUSE OF IMPROPER PREPARATION OF SHIPMENT. THE NAVY DEPARTMENT REPORTED APRIL 19, 1928, THAT THE MANUFACTURING COMPANY HAD BEEN HELD RESPONSIBLE FOR THIS DAMAGE AND THAT THE COST OF THE REPAIRS HAD BEEN REFUNDED BY DEDUCTION FROM ANOTHER BILL OF SAID COMPANY. THE CARRIER IS THEREFORE ENTITLED TO CREDIT FOR THE $300 DEDUCTED IN SETTLEMENT.

THE DISALLOWANCE OF $58.01 WAS FOR THE TRANSPORTATION OF AN AIRPLANE WITH ENGINE INSTALLED, 6,300 POUNDS, IN CAR C AND NW-125236. THE CARRIER CLAIMED $896.60 FOR THE SERVICE, BASED ON 16,200 POUNDS AT ONE AND ONE- HALF TIMES FIRST-CLASS RATE AND ALLOWANCE WAS MADE FOR $838.59 BASED ON ACTUAL WEIGHT AT THREE AND ONE-HALF TIMES FIRST-CLASS RATE ARRIVED AT BY THE APPLICATION OF RULE 5, SECTION 3 (D) AND RULE 15 OF THE CONSOLIDATED FREIGHT CLASSIFICATION.

THE CARRIER CLAIMS THE AMOUNT THUS DISALLOWED, CONTENDING THAT THE CITED RULES OF THE CLASSIFICATION DO NOT APPLY BECAUSE IT IS IMPOSSIBLE TO LOAD SHIPMENTS OF AIRPLANES AND AIRPLANE PARTS SO AS TO OCCUPY THE FULL CUBICAL CAPACITY OR THE EIGHT-CARRYING CAPACITY OF CARS AND ITS RECORDS INDICATE THAT THE SHIPMENT WAS NOT BOXED OR CRATED AND THEREFORE COULD NOT HAVE BEEN ACCEPTED AS AN L.C.L. SHIPMENT UNDER THE PROVISIONS OF RULE 5, C.F.C. NO. 4.

IN THE GOVERNING WESTERN CLASSIFICATION THE CARLOAD RATING FOR AIRPLANES, WITH OR WITHOUT POWER INSTALLED AND WHETHER LOOSE OR IN PACKAGES, IS ONE AND ONE-HALF TIMES FIRST CLASS, MINIMUM WEIGHT 10,000 POUNDS, SUBJECT TO RULE 34; AND THE LESS-THAN-CARLOAD RATING IS DOUBLE FIRST CLASS IN BOXES OR CRATES WHEN SHIPPED WITH POWER INSTALLED AND TWO AND ONE-HALF TIMES FIRST CLASS IN BOXES OR CRATES WHEN SHIPPED WITH POWER INSTALLED AND TWO AND ONE-HALF TIMES FIRST CLASS IN BOXES OR CRATES WHEN SHIPPED WITHOUT POWER; THE RATING FOR AIRPLANE PARTS CONSISTING OF PROPELLERS, WING PANELS OR SECTIONS, COWLS, ELEVATORS, RUDDERS OR STABILIZERS, ETC., IS ONE AND ONE-HALF TIMES FIRST CLASS, IN CARLOADS WITH A MINIMUM WEIGHT OF 10,000 POUNDS, SUBJECT TO RULE 34, AND DOUBLE FIRST CLASS IN LESS-THAN-CARLOAD LOTS WHEN SHIPPED IN BOXES OR CRATES.

IN VIEW OF THE BULK AND LIGHT WEIGHT OF THESE AIRPLANES, THE CHARGE WOULD BE SUBSTANTIALLY LESS THAN UPON A CARLOAD BASIS IF COMPUTED AT THE LESS- THAN-CARLOAD RATING APPLIED ON THE ACTUAL WEIGHT OF THE SHIPMENT, BUT IT HAS BEEN CONTENDED THAT THE AIRPLANES WERE SHIPPED "LOOSE," THAT IS, THEY WERE RACKED AND BLOCKED IN THE CAR AS REQUIRED FOR CARLOAD SHIPMENT, AND THAT THE LESS-THAN-CARLOAD RATINGS ARE APPLICABLE ONLY WHEN THE ARTICLE IS IN BOXES OR CRATES AND SECTION 3 (D) OF RULE 5 OF THE CLASSIFICATION PROVIDES THE RATINGS ON ARTICLES WHICH ARE SHIPPED LOOSE WILL BE THREE CLASSES HIGHER THAN THAT PROVIDED FOR THE SAME ARTICLE IN BOXES; THE RATING THREE CLASSES HIGHER THAN DOUBLE FIRST CLASS IS THREE AND ONE-HALF TIMES FIRST CLASS; THEREFORE, IN ORDER TO DETERMINE THE CHARGE UNDER THE SECOND CLAUSE OF SECTION 1, RULE 15 OF THE CLASSIFICATION, THE PENALTY RATING OF THREE AND ONE-HALF TIMES FIRST CLASS WAS USED.

THE SECOND CLAUSE OF RULE 15 OF THE CLASSIFICATION PROVIDES THAT "THE CHARGE FOR A CAR FULLY LOADED MUST NOT EXCEED THE CHARGE FOR THE SAME LOT OF FREIGHT IF TAKEN AS A LESS-THAN-CARLOAD SHIPMENT" AND RELATES TO THE CHARGE OR REVENUE ON A CARLOAD SHIPMENT AND NOT TO ITS MOVEMENT AND IT IS OBVIOUS THAT ITS PURPOSE IS TO PREVENT CARRIERS FROM ESTABLISHING A CARLOAD RATING WITH SUCH HIGH MINIMUM WEIGHT THAT IT WOULD BE IMPOSSIBLE TO LOAD SUCH MINIMUM WEIGHT INTO A CAR.

THE CARRIER'S CONTENTION THAT THE SHIPMENT COULD NOT HAVE BEEN ACCEPTED AS A LESS THAN CARLOAD HAS NO BEARING ON THE APPLICATION OF THIS PROVISION OF RULE 15, AS THE RULE DOES NOT REQUIRE THE SHIPMENT TO BE MADE AS A LESS CARLOAD BUT PROVIDES FOR THE DETERMINATION OF THE CHARGE FOR A FULLY LOADED CAR; THE CARRIER'S CONTENTION THAT IT IS IMPOSSIBLE TO LOAD THIS CLASS OF SHIPMENTS SO AS TO OCCUPY THE FULL CUBICAL OR WEIGHT-CARRYING CAPACITY OF CARS IS ALSO OUT OF ORDER, AS RULE 15 OF THE CLASSIFICATION MAKES NO REFERENCE TO "CUBICAL CAPACITY" OR "WEIGHT-CARRYING CAPACITY" OF CARS, BUT SIMPLY APPLIES WHEN THE CAR IS FULLY LOADED WHICH IS QUITE DIFFERENT FROM THE "CUBICAL CAPACITY.' AIRPLANES ARE LIGHT AND BULKY AND THE PARTS LIABLE TO DAMAGE IF ONE PART TOUCHES ANOTHER IN A CAR IN TRANSIT. THE LOADING OF SUCH ARTICLES AND THE SPACE OCCUPIED IN THE CAR MUST NECESSARILY BE ENTIRELY DIFFERENT FROM A FULLY LOADED CAR OF GRAIN, COAL, ETC. IN OTHER WORDS, AIRPLANES ARE OF SUCH PHYSICAL CHARACTER THAT ALTHOUGH NOT IN FACT OCCUPYING THE ENTIRE CAR SPACE THEY PRECLUDE ANYTHING ELSE BEING LOADED INTO THE CAR WHICH MIGHT SUBJECT THEM TO DAMAGE WHILE BEING TRANSPORTED.

THE INTERSTATE COMMERCE COMMISSION HAS FREQUENTLY HELD THAT ORDINARY MINIMUM CAR LOADINGS SHOULD BE ESTABLISHED WITH REFERENCE TO THE LOADING CAPACITY OF THE CAR, AND IF CARRIERS DESIRE TO PROTECT THEMSELVES FROM UNDULY LOW REVENUES THEY SHOULD DO SO BY REGULATING THE RATE RATHER THAN BY PRESCRIBING ARBITRARY MINIMA. IT IS NOTED THAT THE ORDINARY LOADED WEIGHT OF AIRPLANES IS BETWEEN 6,000 AND 8,000 POUNDS, AND THAT SELDOM CAN THE PRESCRIBED MINIMUM BE LOADED. RULE 15 OF THE CLASSIFICATION DOES NOT REQUIRE THE LOADING TO BE IN SUCH A MANNER THAT THE ARTICLES INCLUDED IN THE SHIPMENT MAY BE DAMAGED WHILE IN TRANSIT AND CONTEMPLATES CASES WHERE A CAR IS AS FULLY LOADED AS IS CONSISTENT WITH THE SAFE TRANSPORTATION OF THE SHIPMENT. THE RULE PROVIDES A METHOD FOR DETERMINING THE CHARGE FOR THE TRANSPORTATION OF A FULLY LOADED CAR, NOT FOR LOADING A CAR.

THE SHIPMENT ON THIS BILL OF LADING WAS ONE COMPLETE AIRPLANE WITH ENGINE INSTALLED, WEIGHING 6,300 POUNDS; THE AIRPLANE WAS IN 11 PIECES AND THE PARTS AND PIECES WERE RACKED AND BLOCKED IN THE CAR AS PROVIDED FOR CARLOAD SHIPMENTS AND A 50-FOOT CAR WAS ORDERED AND FURNISHED FOR CARLOAD SERVICE. THE BILL OF LADING CONTAINED A STATEMENT ON ITS FACE THAT THE CAR WAS FULLY LOADED AND THE BILL OF LADING WAS SIGNED BY J. B. MCCORKLE, D.F.A., PENNSYLVANIA RAILROAD CO.

THE RATING PROVIDED FOR CARLOAD SHIPMENTS SUCH AS THIS IS ONE AND ONE- HALF TIMES THE FIRST-CLASS RATE ON A MINIMUM WEIGHT OF 16,200 POUNDS, BUT THE BILL OF LADING WHICH IS THE CONTRACT FOR CARRIAGE FURNISHES THE INFORMATION THAT THE CAR IN WHICH THE SHIPMENT WAS MADE WAS ,FULLY LOADED," AND RULE 15 OF THE CLASSIFICATION PROVIDES THAT IN SUCH EVENT THE CHARGE FOR THE SHIPMENT MUST NOT EXCEED THE CHARGE FOR THE SAME LOT OF FREIGHT AS THE LESS-THAN-CARLOAD RATE; BUT THE SHIPMENT WAS NOT BOXED OR CRATED AS IS REQUIRED FOR LESS CARLOAD SHIPMENTS, AND THE APPLICATION OF SECTION 3 (D) OF RULE 5 OF THE CLASSIFICATION INCREASES THE RATING TO THREE AND ONE-HALF TIMES THE FIRST-CLASS RATE AND THE DISALLOWANCE OF $58.01 WAS SO DETERMINED.

A SIMILAR SITUATION WAS BEFORE THE INTERSTATE COMMERCE COMMISSION IN ITS DECISION OF NOVEMBER 14, 1927, IN CASE OF BROWNELL AND FIELD COMPANY V. NEW YORK, NEW HAVEN AND HARTFORD RAILROAD COMPANY ET. AL., 132 I.C.C. 599. THERE THE QUESTION WAS ONE OF CHARGES ON SHIPMENTS OF PAPER CANS IN BAGS WHICH FILLED THE CARS TO CAPACITY AND UPON WHICH A CARLOAD RATING WAS APPLICABLE, WHETHER SHIPPED LOOSE OR IN ANY KIND OF PACKAGE, AND A LESS- THAN-CARLOAD RATING WHEN THE ARTICLES WERE BOXED OR CRATED; BY APPLYING THE PENALTY PROVIDED BY RULE 5 OF THE CLASSIFICATION TO THE SHIPMENT IN BAGS, THAT FORM OF SHIPPING CONTAINER NOT BEING AUTHORIZED, THE RATING WOULD HAVE BEEN THREE CLASSES HIGHER. THE COMMISSION HELD THAT THE SHIPMENTS WERE NOT MADE AS LESS THAN CARLOADS BUT AS CARLOADS IN CARS FULLY LOADED AND THE BAGS USED AS CONTAINERS MIGHT HAVE BEEN DISPENSED WITH AS THE CARLOAD RATINGS WOULD HAVE BEEN APPLICABLE IF THE CANS HAD BEEN LOADED LOOSE IN THE CARS; WHILE THE SHIPPER DID NOT BOX OR CRATE THE PAPER CANS AS REQUIRED IN THE TARIFFS FOR LESS-THAN-CARLOAD SHIPMENTS, THE SHIPMENTS BEING CARLOADS, THE CARRIERS WERE RELIEVED OF THE EXPENSE OF LOADING, UNLOADING, ETC. THE COMMISSION AWARDED REPARATION TO THE EXTENT THE CARLOAD CHARGES COLLECTED EXCEEDED THE CHARGES BASED UPON ACTUAL WEIGHT AT THE LESS-THAN-CARLOAD RATE WITHOUT THE APPLICATION OF THE PENALTY PROVIDED BY RULE 5 OF THE CLASSIFICATION FOR ARTICLES WHICH DO NOT COMPLY WITH THE PACKING REQUIREMENTS WHEN SHIPPED IN LESS-THAN CARLOAD LOTS. IN OTHER WORDS, THE COMMISSION FOUND THAT UNDER THE CIRCUMSTANCES THE NORMAL LESS-THAN-CARLOAD BASIS SHOULD ALTERNATE WITH THE CARLOAD BASIS IN APPLYING RULE 15 OF THE CLASSIFICATION AND THAT TO INCREASE THE LESS- THAN-CARLOAD BASIS IN ACCORDANCE WITH RULE 5 AS A PURELY TECHNICAL PENALTY FOR FAILING TO COMPLY WITH THE LESS-THAN CARLOAD PACKING REQUIREMENTS IS UNREASONABLE AND RESULTS IN PRACTICALLY NULLIFYING RULE 15 AND THEREFORE THE PENALTIES PROVIDED BY RULE 5 FOR NONCOMPLIANCE WITH THE PACKING REQUIREMENTS OF LESS-THAN CARLOAD SHIPMENTS WOULD NOT BE APPLIED WHEN DETERMINING THE CHARGES APPLICABLE UNDER RULE 15 ON A CAR WHICH IS FULLY LOADED. THIS HOLDING IS APPLICABLE HERE.

AIRPLANES, WITH POWER INSTALLED, IN LESS THAN CARLOADS, WHEN IN BOXES OR CRATES, ARE RATED AT DOUBLE FIRST CLASS AND THE RATE FROM CLEVELAND, OHIO, TO NORTH ISLAND, CALIF., VIA PORTLAND, REG., SOUTHERN PACIFIC CO., ATCHISON, TOPEKA AND SANTA FE RAILWAY AND SAN DIEGO AND ARIZONA RAILWAY, IS MADE ON A COMBINATION OF $1.70 TO MANITOWOC, WIS., $10.20 TO STOCKTON, CALIF., $1.69 TO SAN DIEGO, CALIF., AND 50 CENTS TO NORTH ISLAND, MAKING A THROUGH COMMERCIAL COMBINATION RATE OF $14.09 PER 100 POUNDS AS AUTHORIZED BY TARIFFS, AGENT JONES'S I.C.C. 940; AGENT TOLL'S I.C.C. 1187; ATCHISON, TOPEKA AND SANTA FE RAILWAY I.C.C. 9610 AND SAN DIEGO AND ARIZONA RAILWAY I.C.C. 90. DIVIDING THESE RATES AS PROVIDED BY AUTHORIZED DIVISION SHEETS AND DEDUCTING THE PROPER LAND-GRANT PERCENTAGE FROM THE VARIOUS PROPORTIONS RESULTS IN A NET CASH RATE OF $7.605 PER 100 POUNDS APPLICABLE ON GOVERNMENT SHIPMENTS. THE SHIPMENT ON BILL OF LADING N-434665 WEIGHED 6,300 POUNDS AND FULLY LOADED THE CAR AND THE CHARGE UNDER THE PROVISIONS OF THE SECOND CLAUSE OF RULE 15 IS FOR 6,300 POUNDS AT $7.605 PER 100 POUNDS AMOUNTING TO $479.12. THE ALLOWANCE BY SETTLEMENT T-55195 WAS $838.59 RESULTING IN AN OVERALLOWANCE OF $359.47.

THE SHIPMENT ON BILL OF LADING 434651, AUGUST 1, 1927, WAS ONE AIRPLANE NO. 7266, WITHOUT ENGINE INSTALLED. THIS SHIPMENT WAS A CARLOAD SHIPMENT WEIGHING 6,200 POUNDS AND A 50-FOOT CAR WAS ORDERED AND FURNISHED. THE AIRPLANE WAS IN 11 PIECES OR PARTS WHICH WERE PACKED AND BLOCKED IN THE CAR AS REQUIRED FOR CARLOADS AND THE BILL OF LADING CONTAINED A NOTATION THAT THE CAR WAS FULLY LOADED. THE RATING PROVIDED FOR THIS SHIPMENT WHEN IN CARLOADS IS ONE AND ONE-QUARTER TIMES FIRST CLASS IN OFFICIAL AND ONE AND ONE-HALF TIMES FIRST CLASS IN WESTERN CLASSIFICATION WITH A MINIMUM OF 16,200 POUNDS, BUT THE BILL OF LADING FURNISHES THE INFORMATION THAT THE CAR WAS FULLY LOADED AND RULE 15 OF THE CLASSIFICATION PROVIDES THAT THE CHARGE SHALL BE THE SAME AS ACCRUES ON THE SAME FREIGHT AT LESS-THAN- CARLOAD RATING. APPLYING THE PRINCIPLE IN THE CITED BROWNELL V. FIELD COMPANY CASE, THE RATE IS MADE ON A COMBINATION OF $2.55 TO MANITOWOC, WIS., $12.75 TO STOCKTON, CALIF., $2.11 1/2 TO SAN DIEGO, CALIF., AND $0.62 1/2 TO NORTH ISLAND AND DEDUCTING THE AUTHORIZED AMOUNT ON ACCOUNT OF LAND GRANT VIA THE ROUTE THROUGH PORTLAND, OREG., RESULTS IN A NET CASH RATE OF $9.852 PER 100 POUNDS APPLICABLE ON GOVERNMENT SHIPMENTS. SIX THOUSAND TWO HUNDRED POUNDS AT $9.852 PER 100 POUNDS IS $610.82. THE ALLOWANCE BY SETTLEMENT T-55195 WAS FOR $896.60, AND $300 WAS DEDUCTED ON ACCOUNT OF DAMAGE IN TRANSIT, MAKING A NET ALLOWANCE OF $596.60. THERE IS THEREFORE A BALANCE DUE THE CARRIER OF $14.22 ON THE PARTICULAR SHIPMENT.

INCLUDED IN THIS SETTLEMENT WERE FIVE OTHER SHIPMENTS OF AIRPLANES FROM CLEVELAND, OHIO, TO NORTH ISLAND, CALIF., UPON WHICH CHARGES WERE CLAIMED AND ALLOWED AS FOLLOWS:

CHART BILL OF LADING CONSIST WEIGHT CHARGE CHARGE

CLAIMED ALLOWED

POUNDS N-434664 AIRPLANE WITH ENGINE --- 8,000 $896.60 $896.60 N-434666 - -- DO ----------------- 7,500 896.60 896.60 N-434667 --- DO -------------- --- 7,000 896.60 896.60 N-434668 --- DO ----------------- 7,000 896.60 896.60 N-434669 --- DO ----------------- 8,300 896.60 896.60

4,483.00

THESE SHIPMENTS OF AIRPLANES WERE MADE AS CARLOADS AND IN EACH INSTANCE A 50-FOOT CAR WAS ORDERED AND FURNISHED; THE PARTS OR PIECES WERE RACKED AND BLOCKED IN THE CAR AS REQUIRED FOR CARLOADS, AND EACH INDIVIDUAL BILL OF LADING CONTAINS A NOTATION THAT THE CAR WAS FULLY LOADED. APPLYING THE PRINCIPLE LAID DOWN BY THE INTERSTATE COMMERCE COMMISSION IN THE CITED BROWNELL AND FIELD COMPANY CASE, THE CHARGE ON EACH SHIPMENT SHOULD BE DETERMINED FROM ITS ACTUAL WEIGHT AT A NET CASH RATE OF $7.605 PER 100 POUNDS ARRIVED AT AS EXPLAINED UNDER BILL OF LADING N-434665. THE SETTLEMENT IS REOPENED AND THE AMOUNTS CLAIMED, ALLOWED BY THE SETTLEMENT AND CHARGES DUE, APPEAR TO BE AS FOLLOWS:

CHART BILL OF LADING CHARGES CHARGES CHARGES

CLAIMED ALLOWED DUE 34651 $896.60 $596.60 $610.82 UNDERALLOWANCE - $14.22 N-434651 $896.60 $596.60 $610.82 UNDERALLOWANCE - $14.22 N-434665 896.60 838.59 479.12 OVERALLOWANCE -- 359.47 N-434666 896.60 896.60 570.38 OVERALLOWANCE -- 326.22 N-434667 896.60 896.60 532.35 OVERALLOWANCE -- 364.25 N-434668 896.60 896.60 532.35 OVERALLOWANCE -- 364.25 N-434669 896.60 896.60 631.22 OVERALLOWANCE -- 265.38

OVERALLOWANCE 1,967.77

UNDERALLOWANCE 14.22

NET OVERALLOWANCE 1,953.55

THE AMOUNT OF THE NET OVERALLOWANCE OF $1,953.55 WILL BE DEDUCTED FROM AN AMOUNT OTHERWISE DUE THE CARRIER UNLESS THE SAME IS PROMPTLY REFUNDED.