PCU //\ Free Assembly Project /
26 April 2022
to: Dr. Homer Wilkes, Under Secretary:
– Natural Resources and Environment, USDA
cc: Meryl Harrell, Deputy Under Secretary
attn: Tom Vilsack, Secretary of Agriculture
Attached: “Status of the ‘Group Use’ Petition”
The above-titled letter is presented in critique of agency inaction on the “Petition to Amend” the Noncommercial Group Use regulations, as ‘Renewed’ in September 2021 – and in forthright appeal to proceed responsibly with this rulemaking.
The stated concerns are not new — the current stalemate was foretold in a prior email communique:
“Re: Meeting Request_Info Form #2 | pcu•FAP ” (12/13/21)
(Followup Meeting on CFR Petition & Process)
The ensuing 4 months have confirmed those foresights, and left an untenable situation.
The same remedies are called for now, in accord with admin law, agency rules, the public interest and common sense.
Also appended, for your reference: Memorandum presented to FS staff on request (cc: M.Harrell), answering their concerns on the grounds for moving this rulemaking — “The Plan for the Group Use Rule Proposal” (3/20/22)
Good ideas are on the table… your mindful response is requested.
respects_scott addison__(St.L: xxx.xxx.xxxx
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Attachments:
Wilkes_PetnStatus-25ap22.pdf (262 KB)
French-Plan_GUproposal-20mr22r.pdf (296 KB)