62 



April 19, 1994 



C©FY 



MEMO TO: Chief Regulatory Analysis and Development 

 PPD, APHIS, USDA 

 Room 804, Federal Building 

 6505 Belcrest Road 

 Hyattsville MD 20782 



FROM: John D. Lattin 



Systematic Entomology Laboratory 

 Department of Entomology 

 Oregon State University 

 Cordley Hall 2046 

 CorvalHs OR 97331-2907 



SUBJECT: Comment on Docket No. 91-07^, Importation of Logs, 

 Lumber and Other Unmanufactured Wood Products 



I am responding to Docket No. 91-074-3 regarding the Importation of 

 Logs, Lumber, and Other Unmanufactured Wood Products. This item 

 attempts to draft broadly appUed regulations for the United States 

 rather than deal with these matters on a piece-meal basis. Besides 

 raw logs, other wood products are included. This makes good sense, 

 especially the inclusion of green dunnage, almost certainly the source 

 of the bark beetle recently introduced into the Great Lakes region. 



While I made extensive oral comments on this docket item at the 

 public hearing held in Portland, Oregon, the transcription of that 

 meeting was so poor that a written version is deemed essential. 

 Whoever transcribed that tape certainly lacked familiarity with ^^ 

 English. 



As I have commented previously (Memo dated 5 January, 1994 

 regarding Docket No. 91-074-5) it is encouraging to see USDA/APHIS 

 deal with the problems of wood importation on a broader scale but it 

 is unsettling to realize that virtually all of the material discussed is, 

 in reality, based upon the risk assessments of the Soviet Far East, 

 New Zealand, Chile reports. I have seen no similar analyses on any 

 other part of the United States - e.g., the risks likely to be present 

 with the importation of Caribbean Pine, now grown extensively in 

 plantations in South America amd elsewhere on the pines of southern 

 United States - risks that are certainly as great as the three already 

 examined. Further, I do not recall hearing of any risk assessments of 

 hardwood or conifer logs for the east coast or the Great Lakes region 

 or even anj^hing related to NAFTA. 



