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APHISRulemakingAPHIS-2006-0096

Agricultural Inspection and AQI User Fees Along the U.S./Canada Border

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American Forest & Paper Association filings
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American Forest & Paper Association filed 1 comment on this docket between Nov 21, 2006 and Nov 21, 2006. 65 other organizations filed here. The comment window closed 7186d ago.

What American Forest & Paper Association filed (1)

Nov 21, 2006· Comment from Patrick Rita, American Forest & Paper Association· APHIS-2006-0096-0063

SENT ELECTRONICALLY November 20, 2006 REFERENCE: Docket No. APHIS ? 2006-0096 Regulatory Analysis and Development, PPD Animal and Plant Health Inspection Service, U.S. Department of Agriculture Station 3A-03.8 4700 River Road, Unit 118 Riverdale, Maryland 20737-1238 The American Forest & Paper Association (AF&PA) appreciates this opportunity to provide comments with respect to the interim rule and request for comments on Agricultural Inspection and Agricultural Quarantine and Inspection (AQI) User Fees Along the U.S. / Canada Border pursuant to Federal Register Vol. 71, No. 165 (August 25, 2006). AF&PA is the national trade association of the forest, pulp, paper, paperboard and wood products industry. The forest and paper products industry accounts for more than 7 percent of total U.S. manufacturing output and ranks among the top ten manufacturing employers in 42 states. The more than 200 companies and related associations AF&PA represents have a strong interest in maintaining the competitiveness of the North American forest products industry and ensuring that unnecessary barriers to trade in goods are minimized, if not altogether eliminated. The U.S. forest products industry has a significant stake in any regulations that impact U.S. / Canada cross-border trade and as such, welcomes the opportunity to comment on this interim rule. Of utmost importance to the forest products industry is the adoption of measures that protect America?s healthy, productive and vitally important forest resource base. However, the industry is equally concerned that regulations imposed by APHIS? be commensurate with the identified risk so as not to have a negative economic impact on cross border trade. Based on review of the Federal Register notice, AF&PA insists that APHIS postpone implementation of the interim final rule. Until there is a better understanding of the risks associated with cross border trade and a clearer understanding of the findings of the Risk Assessment associated with this ruling, then AF&PA and its member companies cannot appropriately evaluate whether APHIS' response, as reflected in the interim final rule, is both an appropriate and practical solution. We are especially concerned that, according to our understanding, the Risk Assessment associated with this ruling is not available to the public. This makes it unreasonable to expect stakeholders to comment on the issue in a thoughtful and informed manner. Moreover, our understanding is that APHIS has been aware of the alleged risks for several years, thus undercutting any justification for satisfying the ?good cause? test under the Administrative Procedure Act, 5 U.S.C. ? 553(d)(3), which has no allowance of an ?interim? substantive rule without good cause. In addition, we do not believe that any ?good cause? exists to justify imposition of ?user fees? on every shipment crossing the Canadian border without an appropriate rulemaking process. The U.S. forest products industry will continue to be engaged in discussions to ensure our forest resources are protected while at the same time ensuring the continued flow of trade in our products. We again, strongly urge APHIS to postpone implementation of this rule on an ?emergency? basis, especially without providing proper justification for the planned broad-based inspection approach subjecting all cargo to user fees and potential inspection. A postponement will also allow stakeholders the opportunity to comment, and with the expectation that APHIS will take those comments under advisement before the ruling takes effect. Please do not hesitate to contact us for further information. Sincerely, Patrick Rita Vice President, Government Affairs

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