Comment Submitted by Brendan J. Davis, Forest Landowners Association

October 24, 2008 Mr. W. Ralph Basham Commissioner U.S. Customs and Border Protection 1300 Pennsylvania Avenue, N.W. (Mint Annex) Washington, DC 20229 Re: Softwood Lumber Act Implementing Regulation -- Docket No. USCBP- 2008-0052 Dear Commissioner Basham: This letter conveys the Forest Landowners Association’s comments on an interim rule published by Customs and Border Protection’s (CBP) to implement an importer declaration pro-gram under the Softwood Lumber Act of 2008. The regulation was published at 73 Fed. Reg. 49,934 (Aug. 25, 2008). The Forest Landowners Association is a national non-profit organization of private forest landowners, forestland investment companies, forestry consultants, state foresters, forest exten-sion agents, forest products professionals, and forestry industry professionals who own and oper-ate more than 37 million acres of timberland in 47 states. The Association and its members have a vital interest in the enforcement of the Softwood Lumber Act of 2008. United States international agreements regarding forest products are a critical means of combating unfair trade in forest products. But the value in those agreements can only be realized if the U.S. government enforcements them. And foreign countries’ noncompliance with the agreements harms U.S. forest landowners by undermining U.S. markets for forest products and timber. The Softwood Lumber Act of 2008 is key to ensuring compliance with them, and the public needs energetic enforcement of regulations that faithfully implement the Softwood Lum-ber Act. We believe that the interim rule properly reflects the requirement of the Softwood Lum-ber Act to establish an importer declaration program. Among other things, the interim rule com-ports with the statute’s mandate that information be provided for “each shipment,” thereby for-bidding any type of blanket declaration covering multiple entries. We urge CBP to finalize the interim rule without any changes that would undermine the Softwood Lumber Act of 2008 and to vigorously enforce the regulations. Doing so would be a major step toward stopping injurious noncompliance with international agreements covering trade in softwood lumber. Thank you for considering these comments. Sincerely, Scott Jones, Executive Vice President Forest Landowners Association cc: Trade and Commercial Regulations Branch Regulations and Rulings U.S. Customs and Border Protection 1300 Pennsylvania Avenue, NW (Mint Annex) Washington, DC 20229