66 



Oregon 



State 

 University 



Mr. Jack Edmundson 

 April 26, 1994 

 Page 2 



The interim regulations that were put into place by APHIS on New Zealcind and 

 Chilean log importations were flawed and generally ignored the recommendations 

 of the 1992 US Forest Service Saence Team that was formed to develop the protocol 

 for such actions (see attached memos dated January 4, 1994, and April 19, 1994). 

 Your priorities are reversed-your charge is to protect American natural resources 

 first and then assist in trade. 



Your section on historical perspectives provides an eloquent statement on the risks 

 and consequences of pest introductions. This is especially true for the portion on 

 white pine blister rust that clearly demonstrates the dramatic impact even a single 

 spedes may have on an ecosystem. When these impacts are associated with a 

 species of interest, i.e., white pine, the consequences are more visible. One can not 

 help but wonder how many other examples of this occur that have more subtle 

 impacts on ecosystems whose consequences may take years to surface. It seems 

 more than a little ironic that two of your examples were identified as serious risks 

 by the Siberian Log Team - e.g. The Eurasian poplar rust fungus and the Asian 

 Gypsy Moth. Certainly, the Siberian report was far more comprehensive and better 

 documented than either of the reports on New Zealand or Chile. When we have 

 scientific expertise it seems fooUsh to fail to utilize it and instead use far smaller 

 groups to conduct the analyses. The lack of credibility of the latter reports was 

 reflected by the attitudes of the scientific community. 



The inclusion of the pine shoot beetle, of course, makes a strong case for your 

 inclusion of green dunnage into the regulations. That is a most appropriate 

 inclusion indeed. One might add that the concern over this baik beetle exactly 

 paralleb the case of another bark beetle ■ Hylaster ater - considered a four-star pest 

 in Europe but virtually ignored by the New Zealand and Chilean teams - both 

 considering the species of no importance! (It does not now occur in the United 

 States). 



Finally, the reliance on methyl bromide as a major component of the regulations 

 certainly flies in the face of the virtual certainty that its use will be terminated 

 shortly because of its impact on the ozone-layer. Merely "satisfying" the 

 requirement of E.O. 12114 is hardly enough. 



2. Purpose and Need. 



It is true that inspections of all items is virtually impossible, especially when the 



sampling procedure is to remove a subsample. It is also true that increased 



importation activity increases the likelihood of accidental introduction. Extra care 



is required to craft regulations to assure that in fact these introductions do not 



occur. 



3. Alternatives 



Alternative 1 - No Action 



Unacceptable. Your outline of likely consequences of no action is precisely what 



should be the basis for an adequate protocol. 



