64 



Chief Regulatory Analysis and Development 



April 19, 1994 



Pages 



I was informed by the USDA/APfflS Portland ofGce that the standard 

 sampling procedure for logs was to select one log per flat for 

 increment boring to be examined for insect damage, nematode 

 presence, and disease organisms. Once the samples had been taken 

 8ind the logs visually inspected, the logs were released. I was also 

 informed that it may take as long as 3 months to get the results from 

 these samples. With that potential tum-around time schedule, 

 combined with the proposed 60 days for applying heat treatment (The 

 only sure way to assure low risks), one might be able to bring in 

 1,560,000 logs (one ship per day for 60 days) even before the sampUng 

 results of the first shipment had been received. Following your 

 standard practices, these logs would have been released for 

 processing. Do you really believe this is an appropriate path to 

 follow? 



Here we are, trying to develop a sustainable forest resource base in 

 the Pacific Northwest and ineffective regulations such as these are 

 being proposed-almost on the day the Forest Plan was presented for 

 legal reconsideration. When the disastrous consequences of non- 

 indigenous species on the forests of the Northeast can be seen today, 

 just why are we trying so hard to duplicate this in the Northwest? 

 Forcing the issue before we have adequate information and efifectively 

 proven regulations, properly applied, can only result in similar 

 disasters. Just who will be willing to take the blame for such actions? 



One final question—just why were the Revised Test Shipment 

 Protocol recommendations from the Forest Service Scientific Panel 

 ignored and replaced by weaker, altered recommendations? 



dmw 



c: R. E. Berry 



