of the Secretary
Pennsylvania Avenue, NW
Mr. Neil Blickman
16 CFR Part 304 Comment--Hobby Protection Act Rule
name is Thomas Katonak and I am the president of the National Insulator
Association (NIA). This letter is
in response to the FTC's request for public comment on the Hobby Protection Act
of 1973 as advertised in the Federal Register, March 3, 2003.
NIA is a hobby organization involved with collecting electrical insulation
devices related to the communication and power industries.
We have over 1800 members in the United States, but speak for the much
larger insulator collector hobby estimated to number nearly ten thousand
the 35 years or so of organized insulator collecting, insulators have become
highly collectable and prices of the glass and porcelain artifacts have
escalated. Along with the price
increases, we have had increasing problems with forgeries and alterations.
With prices in insulator auctions commonly exceeding $5000 for a rare
piece, it is now quite profitable for parties to manufacture and distribute
imitation items. Many of these
artificial insulators defy the experts when it comes to authenticating the
NIA spends a major amount of its resources in conducting research on and
educating the insulator hobby about imitation and altered insulators.
However, with the dramatic increase in interest in the hobby, we are
unable to keep pace with those attempting to defraud the collector.
we have the authority to ban individuals from the NIA for unethical behavior
like making and/or selling fake items, we have little recourse under criminal
law to have people committing such fraud held accountable for their illegal
thereby strongly support modifications to the Hobby Protection Act of 1973 to
include other hobbies across the board, but in particular the insulator hobby.
attached statement provides the detailed support for this recommendation.
would be pleased to answer any questions you might have concerning this
statement and the NIA can provide experts to address the issues surrounding
forgeries and alterations as well as help in crafting any necessary