26 



The 110 logs were down there in the hold. No one knew they 

 were coming. They were on the manifest in fairness. It turned out 

 those logs had not been heat-treated. For reasons I am not person- 

 ally familiar with, these logs had to have been heat-treated at point 

 of origin before they were allowed in this country. They had not 

 been so treated. 



They were quarantined by APHIS at that time and the shippers 

 were given two choices, take them back or destroy them. They de- 

 cided to destroy them. They were going to bum them — they had 

 been sprayed with two types of insecticides and two types of fun- 

 gicides. Our Oregon Department of Environmental Quality came in 

 and said, you cannot do that, you cannot release those compounds 

 into the air. This touches on the burning of sawdust that has this 

 material on it. 



So the inspector, under proper jurisdiction, (he had the authority 

 to do so) released those logs without the proper treatment. They 

 were sent by truck from the coast to two inland cities. Mill City 

 and Lyons, in the western foothills of the Cascades. 



So they went to two mills directly from that port. So that is how 

 those logs got treated. So I have some problems. I spent two years 

 on the OTA panel on a Nonindigenous Species project and learned 

 more about this topic. And one of the things that emerged from 

 that particular activity was that if you look at the economics of it, 

 money is much better spent preventing the invasion of organisms 

 than treating them once they are here, and all you have to do is 

 look at the cost of the gypsy moth control and a number of other 

 species to document that very thoroughly. 



My comments today will concentrate on two things, proposed reg- 

 ulations and the mitigation protocols. Many of these have been dis- 

 cussed and I will not repeat them. 



I have very serious concerns and reservations about the proposed 

 regulations, and that is no secret, it is a matter of public record. 

 These regulations are based chiefly on the Pacific Northwest activi- 

 ties, as has been said again and again today. 



We had an original meeting of some 60 or more scientists, pa- 

 thologists and entomologists, that addressed the Siberian log im- 

 portation question in Portland in 1991. This was a very thorough 

 review. 



It is interesting that relatively little of the information from that 

 review shows up in these proposed regulations. These regulations, 

 are in fact based chiefly on the documents produced by risk assess- 

 ments from New Zealand and Chile. It is curious because they in- 

 spire some comments to the contrary. 



Both of these proposals that were risk assessments were per- 

 formed by a team of quite different composition than the first one. 

 The second one (New Zealand) had a very small group, as I recall 

 half a dozen people only from within the Forest Service. They re- 

 ceived most of their information from the New Zealand govern- 

 ment. And omitted — I had occasion to review both the draft and a 

 final copy — omitted information that was provided to them from 

 other sources, including the main reference on insects associated 

 with the pines they were talking about (Ohmart, 1982). 



And if one wants to go to Appendix J of that document, you will 

 find 85 pages of comments on it. Most of them not very — I should 



