On behalf of the National Industrial Transportation League (“NITL”), I am writing to you regarding significant concerns of our members regarding the new Container Excess Dwell fees recently adopted by the Ports of Los Angeles and Long Beach. These fees are intended to be assessed against ocean carriers, but some carriers intend to pass the fee through to their importer customers. The fee is designed to address the unprecedented congestion at the ports and to incentivize the prompt removal of loaded containers within the designated time-period.