FRA Distills “Overregulation” Avalanche

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In response to concerns expressed at FRA’s September 11 Board of Directors meeting about the growth of federal regulations impacting wood supply management at various levels throughout the chain, FRA examined the regulatory threats obstructing wood supply management the most and characterized each threat in plain terms, including its impact on the supply chain and its current status (whether the regulatory threat is in place or pending and how FRA and other organizations are confronting it). The current version of this Overregulation Summary is posted on the FRA web site’s home page at http://www.forestresources.org/overregulation.html; a print-quality PDF version of the five-page document is also linked from there.

This Overregulation Summary will be a work in progress, updated frequently, since the status of regulatory initiatives changes and new regulations emerge or grow in their impacts. The Summary currently lists the following areas in which unreasonable regulatory burdens threaten the supply chain:

  • Foreign guestworkers employed by reforestation contractors
  • Forest road construction and maintenance
  • Independent contractor status determination
  • Emissions from industrial boilers
  • Uncompetitive truck weight rules
  • FMCSA’s “Compliance, Safety, Accountability” (CSA) program

During Executive Committee review of the version now posted, it was suggested that three additional regulatory programs may deserve treatment in a future revision:

  • The EPA Tier Four diesel engine requirements;
  • The definition of biomass in EPA’s Tailoring Rule;
  • The regulation of the credit industry through authorities created in the Dodd-Frank bill, and similar initiatives, as an obstruction both to housing recovery and to small businesses’ access to credit.

FRA members may wish to use the Overregulation Summary as a presentation item in contacts with policymakers or with others whose views shape our operating environment.