Dear Secretary Vilsack:

In the Fall 2010 Unified Agenda of Regulatory and Deregulatory Actions, the U.S. Forest Service indicated its intention to promulgate new regulations on the "Management of National Forest System Surface Resources with Privately Held Mineral Estates." We are concerned that this rulemaking will dramatically increase the regulatory burden on oil and natural gas exploration and production activities on millions of acres of private mineral estates on National Forest lands. We are especially concerned and alarmed that the Forest Service has claimed in the Unified Agenda statement that small business entities will not be adversely affected; that the rule is not major; that it is "[n]onsignificant;" and that a Regulatory Flexibility Analysis is not required by the agency. As explained below, we tind these claims by the Forest Service to be unsupported by publicly available information and recent legal developments.

Read the entire letter HERE.