38 



Another objective of ours is to minimize the administrative and 

 compliance costs for both APHIS and prospective importers in ad- 

 hering to these essential phytosanitary requirements, and also we 

 are very concerned about how this rulemaking may affect inter- 

 national trade, our trading partners, and that it be consistent with 

 overall trade policy objectives, either under bilateral trade agree- 

 ments or under the GATT process. 



Some of our primary concerns that are in more detail outlined in 

 our written statement are that we feel that APHIS has done a very 

 good job in developing and proposing these effective regulations to 

 protect our domestic forests from exotic pests and diseases. 



We share the concerns of APHIS regarding the risks of introduc- 

 ing exotic plant pests and diseases that may be associated with the 

 importation of unprocessed wood products. We believe APHIS has 

 the authority and the obligation to establish effective import in- 

 spection and control measures from manufactured wood products 

 and that these measures must be effective. 



And to address a question that came up earlier about heat treat- 

 ment in the country of origin, having served in the Peace Corps 

 and traveled internationally quite a bit, I am much more confident 

 in our APHIS in this country to make sure that quality control 

 standards are adhered to and the logs are sufficiently heat treated, 

 either not too hot to destroy the quality of the wood, and not too 

 cold to allow pests to be introduced, but to do it right. 



And I really do not have much confidence that some of the devel- 

 oping countries that may be 50 years behind us in terms of tech- 

 nology can really do it as well as APHIS can. 



We also agree with APHIS that pressures to increase importation 

 of wood products will most assuredly accelerate as artificial re- 

 source supply constraints occur as a result of timber set-asides and 

 environmental restrictions. 



Reducing the Federal harvest, as was pointed out earlier, by 8 

 billion board feet in 5 years as anyone would expect would increase 

 price pressures. We are seeing harvest levels accelerate in other re- 

 gions of the country. A lot of our member companies are locating 

 internationally to be able to bring wood into this country. In fact, 

 the reductions that we have seen in the Northwest exceed the total 

 harvest from several of the countries we are talking about here 

 today. New Zealand and Chile, that only produce 6.5 billion board 

 feet each year. 



We further agree that the current practice of inspection at point 

 of entry and prohibition of imports based on insufficient informa- 

 tion is not satisfactory, particularly in light of this significant new 

 interest in importing unmanufactured wood products. Importers 

 need to be able to plan their transactions in an orderly planner and 

 to meet credible and consistent regulatory requirements. 



We believe that the proposed rule offers effective and efficient 

 regulations to establish an organized system for importing un- 

 manufactured wood products. APHIS conducted extensive inves- 

 tigations and risk assessments involving experts from academia. 

 Government agencies, and the private sector, and APHIS has also 

 prepared an extensive environmental impact statement on the rule 

 that is well documented as far as we can tell. 



