67 



Oregon 



State 

 University 



Mr. Jack Ednmndson 

 April 26, 1994 

 Page 3 



Alternative 2 - Pronnsed RegTilations (Preferred Alternative) 



As stated, the regulations proposed are to expand the current interim regulations 

 on New Zealand and Chilean logs. However, I have seen no other analyses to cover, 

 in detail, such commodities as wood chips, or even logs frtjm other countries or 

 areas to be brought into the south, the southeast, east, or northeast. The conifers of 

 the south are especially vulnerable from pest organisms found in similar warm 

 climate pines - yet nothing has been done here. The same appUes to wood chips 

 from pine plantations in central and South America— prime contributors of pest 

 organisms. Work is needed to obtain new, effective modes of treatment for the wide 

 variety of articles, not extrapolations from a few, previous efforts (i.e. T312). 



My memos dated Janujiry 5, 1994, and April 19, 1994 (attached) cover the details of 

 the regulations outlined under alternative 2. As previously stated by me, there are 

 two maior flaws in these proposed regulations: (1) All heat treatments should be 

 made at point of origin and (2) the temperatures recommended are inadequate, it 

 should be 71°C for 45 minutes (center of log). Both of these details were included in 

 the protocol recommended to the US Forest Service by the Science Panel in March, 

 1992. Also included were recommendations that appropriate new information on 

 thermal death points for a variety of insects, diseases, and nematodes be obtained— 

 at point of origin. As stated in my memo dated April 19, 1994, your proposed 

 regulation to allow 60 days before heat treatment is applied after arrival in the 

 United States is nothing short of disastrous. You keep saying, "Finally, in order to 

 accomplish APHIS' mission (elimination of pest introductions)..." (p. 21), but you 

 provide pest organisms 60 days to escape! This fact, combined with the delay on 

 . receiviiig-ithe results of log samples (up to 3 months) that might^^O'w the 'entry iot ■' 

 1,560,000 Jogs before you knew there was a problem, makes your claim of ' 

 elimination of pest introductions a hollow one and a very dangerous one for the 

 protection of the Northwest forests (and other forests as well, especially the 

 southern conifer plantations). You must reconsider this aspect of your regulations. 

 Putting trade ahead of your very agency mission when the technology exists to 

 assure pest-free logs is simply wrong (OTA. 1993). With NAFTA and GATT 

 agreements being developed, we must have the proper regulations in olace to allow 

 the development of a sustainable forest resource in the United States. 



Alternative 3 - Prohibit Untreated Wood Except Packing Material 



Unacceptable so long as packmg materials are excepted. The pine shoot beetle 



almost certainly entered the US via green dunnage. 



Alternative 4 - Prohibit Untreated Wood 



This is the preferred alternative since it requires all wood to be treated regardless 

 of source. Exceptions simply ask for other exceptions that weaken the entire 

 process. It seems reasonable to encourage research to address what might be a 

 special case for some tropical hardwoods. Of course the answer might well be to 

 create added value to the wood before it leaves the country-processes that usually 

 includes proper drying in the first place. 



Alternative 5 - Prohibit Unmanufactured Wood Except Packing Material 

 Unacceptable on the grounds that packing material should be treated. This seems 

 lilf p a "manufactured" alternative. You clearly state the dangers of untreated 

 packing materials in this DEIS and in the proposed regxilations-then turn around 

 and offer its exclusion as a valid alternative! 



