Hold on to your shirts folks! It doesn’t look like the U.S. Coalition and USTR Office are the only ones aimed at making free trade from Canada less free! Per Export and Import Permits Act Notice "Ser132 Monitoring Softwood Lumber Exports to the United States", your own government has put softwood lumber on their Export Controls List, even though, 1) the SLA (used as the scapegoat for implementing the expensive and cumbersome permit program in the first place) expires March 31^st and 2) the U.S. no longer requires the permit for entry purposes.

Acting as technical liaison to the B.C. Forest Sector Working Group in late 1995, and upon first meeting with the then Director General of the Export/Import Controls Bureau, our group was shocked, to say the least, when this department of Canada’s Foreign Affairs and Int’l Trade Office informed us of the way they, as opposed to our long thought out suggestions, intended to manage the pending SLA exports. At first we thought they were simply being unreasonable – that they were not even listening to our position that if the U.S. required these controls, the exporters, themselves, could report their exports and remit whatever assessments were levied. It became apparent that due to the sheer magnitude of the undertaking - their agency did not have the ability to manage this program. They had neither the staff nor infrastructure. However, because of the $9.00 permit fees collected from you over the past five years - they now have both, and, as is the usual case with any government agency with their hands in your pockets – they are more than comfortable with the status quo! Even if they can support why it is necessary to continue monitoring these exports, in that there are no longer allocation, transfer, and quarterly monitoring or fee base assessment considerations – why via permit? And, why via permit filers?

Prior to the CFTA and NAFTA, there was no fee associated with the filing of B-13 Export Declarations, which could be effected monthly and electronically. With the advent of the CFTA and NAFTA, with the exception of sensitive "Other Government Agency" controlled commodities, B-13’s were no longer required for exports to the U.S. Prior to the SLA and even during prior CVD investigations, softwood lumber was not captured. We are hard pressed to understand why the Governor General feels this costly interference in its own industry’s private business is necessary. And even if justified, why at this late date – one working day prior to expiration of the SLA – leaving the private sector no opportunity to comment or properly prepare.

If this Notice is not revoked, we, the U.S. Customs Broker, although not required by U.S. regulations, will be expected, by the Canadian government, to provide the same data, sans Quota Holder and EICB Number(s), to a permit filer - as we did throughout the SLA. Further monitoring, by permit, and via a program discouraging exporter-direct filings by the favoring of broker/permit filers with reduced costs, must be made subject to public comment and review.