69 



Oregon 

 State 



University 



Mr. Jack Edmundson 

 Apnl 26, 1994 

 Page 5 



Comparison of the En\nronmenta] Con sequences of the Alternatives 

 Your statement that there were no differences between the 6 alternatives when 

 evaluating impacts on human health, forest resources, ozone depletion, global 

 commons, and cultural resources is certainly wrong. Applications of pesticides on 

 wood products or to suppress pests once established ds. constitute an impact on 

 human health (e.g. burning pesticide treated logs releasing compounds into the air). 

 Inadequate treatment of raw wood that allows the introduction of pest organisms 

 will impact forest resources. You document that very clearly in this document. 



How then can you claim that there are no impacts? Use of methyl bromide is so 

 well documented as impacting the ozone layer that it is going to be eliminated and 

 you feel you can state there will be no impact? The contribution of movement of 

 wood materials around the world including whatever pest organisms might be 

 contained in this wood is most certainly going to impact the global commons. 

 Remember, too, that this movement of materials cuts both ways and the possibility 

 of shipping pest organisms back to the donor countries is a very real one and a point 

 not even considered. Finally, when you consider cultural resources, consider what 

 will happen if major new forest pests are introduced into the Pacific Northwest, for 

 example. The cultural resources are already severely stressed because of the 

 impacted forest resources. Major efforts are being made to develop these resources 

 into a sustainable resource— that does not include having to accommodate new 

 threats to an already stressed resource. To label Alternative 4 as "overly" 

 conservative is irresponsible. The purpose of this effort, by your own words, is to 

 eliminate the importation of pest organisms— that is the only driver. 



The statement that Alternative 2 might be somewhat protective of biodiversity 

 because it "could" tend to encourage sustainable forestry is simply not true. The 

 failure to demand heat treatment at the point of origin virtually assures the 

 introduction of pest organisms that will surely impact the sustainability of our 

 native forests. 



As stated earlier, you have used the green dunnage as a diversion, offering so-called 

 different alternatives based upon this commodity. The matter can be addressed 

 simply, it is a serious environmental threat indeed, require that it be heat treated 

 at point of origin. Not difBcult technically but very effective. 



Your final paragraph on page 41 is most distressing. You document the threats and 

 risks of these commodities very cjirefiilly and then conclude the consequences are 

 minimal! This is precisely what you did in both interim regulations on New 

 Zealand and Chilean logs. (1) We know the logs present a problem with likely pest 

 introduction, (2) we lack adequate technology to eliminate these pests from the logs 

 but, (3) we conclude there is no significant impact in allowing these logs to come in. 

 How can you reach such a conclusion? 



rv. Affected Environment and Environmental Consequences 

 This is a well-balanced presentation and description of the areas of concern. It 

 provides an excellent background for the entire DEIS. I leave the analysis of the 

 details of methyl bromide position to those more familiar with these details. The 

 evidence is clear, however, that the compound will be withdrawn from use in the 

 near future. Doesn't it make sense to be prepared for its removal by conducting 

 adequate research to validate other approaches, especially heat? 



