DEPARTMENT OF 

 •ENTOMOLOGY 



65 



April 26, 1994 



Oregon 



State 

 University 



MEMO TO: Mr. Jack Edmundson 



Branch Chief, Environmental Analysis aind Documentation 



Biotechnology, Biological, and Environmental Protection, 



APfflS, USDA 



Room 543, Federal Building 



6505 Belcrest Road 



Hyattsville MD 20782 



FROM; JohnD. Lattin ///>>-./(-/• 



Systematic Entomology Laboratory 

 Department of Entouiology 

 Oregon State University 

 Cordley Hall 2046 

 Corvallis OR 97331-2907 



SUBJECT: Comment on Draft Environmental Impact Statement (DEIS) on the 

 Importation of Logs, Lumber, and Other Unmanufactured Wood 

 Articles. 



^zc: 



Cordlev Hall 20-l« 

 Corvallis. Oreson 



S733I-2907 



Telephone 

 J03-737-4733 



Fu 



S03T37-3643 



latemci: 

 office9bcc.orsi.edu 



I am responding to a request for comment on the draft EIS on the Importation of 

 Logs, Lumber, and Other Unmanufactured Wood Articles. Since I have responded 

 in detail on all previous requests for comments, I am attaching copies of two 

 previous memos that deal with much that is contained in the draft EIS. These 

 memos-dated January 5, 1994, covering Docket No. 91-074-5 and April 19, 1994, 

 covering Docket No. 91-074-3 should be attached to this memo for inclusion jn the 

 .public record. -Further, I am including a copy of Arthropod Diversity and 

 Conservation in Old-Growth Northwest Forests, American Zoologist 33:576-587. 

 1993. Lattin, John D. Please note page 584. 



The comments below will follow the outline of the Draft EIS. 



1. Introduction 



The shortage of logs in the Northwest is not due to greater demand as you indicate 

 but rather on the fact that harvest rates have exceeded replacement rates for a 

 number of years (Beuter Report and Sessions Report). It was the final recognition 

 of this fact that led to the current controversy and ultimately to the Presidential 

 Timber Conference in the Spring of 1993. 



While the chjirge of APHIS is to protect our country's agricultural and forest 

 resources fit)m plant pests, your basic policy certainly hampers your success-"that 

 is, its willingness to allow many types of imports that pose unanalyzed, or 

 incompletely analyzed, risks." (Office of Technology. 1993. Harmful Non- 

 Indigenous Species in the United States p. 115) It is time that your operating policy 

 truly reflected your official charge. 



The "test shipments^ of logs fi-om the Soviet Far East were infested with insects, 

 nematodes, and diseases— that is far more than "...demonstrated the potential for 

 the introduction of pest species of insects, nematodes, and plant diseases." (p. 1). 

 Contrary to your statement, the maiin reasons the Siberian Logs were banned fi-om 

 importation resulted from the intervention of the Oregon House Delegation in 1990 

 (OTA 1993 p. 118) that was then followed by the formation of the Siberian Raw Log 

 Risk Assessment Team in 1991. 



