FRA’s 2018 Policy Priorities

The U.S. wood supply system is the largest and most highly developed in the world, providing the raw material that furnishes our country’s seventh largest industrial sector:  forest products.  Overregulation threatens this system’s ability to continue to serve both its economic and environmental goals in a sustainable manner, especially in view of the large role small business plays in this system’s function and management.  FRA monitors and engages public policy processes that impose unreasonable costs and overly burdensome processes on the wood supply chain or that impede sensible reforms that might enhance competitiveness.

Paralysis by overregulation places in jeopardy the livelihoods of mills, employees, and dependent communities; harvesting and forest operations contractors and their employees; and the ten million private, institutional, and industrial forest landowners that support its resource base.  In the end, a dysfunctional wood supply system would not only be economically devastating but would expose the forest resource to wildfire and disease, leaving watersheds and wildlife habitat vulnerable and compromising the character of our country’s landscape.

What is overregulation?  The intrusion of government into the management of private business to an extent not justified by the duty to promote the general welfare or to achieve transparency in exercising that duty.

2018 Policy Priorities
Currently, the Department of Labor (DOL) classifies some forestry-related activities such as tree planting and herbicide application (including right of way application) in the H-2B non-agricultural guest worker program, while classifying other work such as logging in the H-2A agricultural program.  Most forestry work, however, is considered agriculture-related and is regulated as such by state and federal agencies.
Our nation’s federal vehicle weight limit is outdated and out of touch with today’s engineering advancements and consumer needs.  The 80,000-pound arbitrary truck weight restriction on Federal Interstate Highways has introduced unnecessary costs and inefficiencies to raw material suppliers and finished product shippers that depend on our roadways every day.
In comparison with most other countries with large forest products industries, U.S. wood supply systems are substantially de-integrated, and contracting among their various components is crucial to their operation.  The reasons lie in the historical configuration of our diverse forest resource, the many different types and sizes of landownerships, and our country’s tradition of enabling and fostering entrepreneurship at the local level.
Congress unveiled its so-called “unified plan” for overhauling the tax code in late September. FRA will be active as negotiations move forward in a number of areas of the tax reform debate, including the following:
Impact: This end-of-life tax assessment obstructs and discourages small business succession planning, weighing on the viability of loggers and other businesses supporting the wood supply chain, while also contributing to forest fragmentation and retention of land in forest.
Impact:  Federal carbon policy’s failure to acknowledge the principle of carbon neutrality in diverting woody biomass to energy production would obstruct U.S. energy policy’s potential for reducing total carbon emissions and make both established and emerging biomass energy conversion technologies uncompetitive.
Impact: The attempt to impose new definitions of water flows under federal regulation, with a corresponding permitting system, raises forest management operational expenses, increases uncertainty in planning, and potentially withdraws land from forest management.
Impact: The economic downturn and regulatory reforms of the financial industries have severely constricted small businesses’, and especially logging contractors’, access to credit.
Impact: The Fair Labor Standards Act’s prohibition on loggers employing their own children on family-run logging operations until the child reaches the age of 18 is discouraging the intergenerational transfer of logging businesses, since it prevents effective apprenticeships at a critical age. It is important to sustain existing businesses by facilitating the next generation’s entry into the profession as experienced operators and business managers. In addition, federal rules discourage employment of younger truck drivers, prohibiting drivers under 21 from driving trucks over state lines.
Impact: These provisions threaten to sideline good truck drivers and to make small carriers uncompetitive. To the extent that they reduce trucking capacity without significantly advancing safety, both CSA and HOS will impose large but unquantifiable new costs on the wood supply chain’s biggest cost component: transportation.
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