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MEMO TO: Chief Regulatory Analysis and Development 

 January 5, 1994 

 Page 2 



The statement that the requirements for importing Monterey Pine and Douglas-fir 

 logs from New Zealand, if applied to importing Monterey pine logs from Chile, will 

 be sufBcient to prevent the introduction and dissemination of plant pests associated 

 with these logs from Chile is simply not true. Debarking is never really complete 

 and living larvae have been dug out of the wood under bark remnants m logs from 

 New Zealand, fvunigation vhl\ not penetrate far enough to kill organisms deeper 

 than 100 mm, and no heat treatment is being applied tieXaie shipment, as 

 recommended by the US. Forest Service Science Team - why then should it be 

 assumed that there are no risks? Talk about leaps of logic! It is my understandmg 

 that there is now a proposal to bring in green lumber and then dry it here Just 

 why is it so difficult to require kiln dried lumber in the first place - as Europe does. 

 And why is it that Chile and New Zealand will usii allow importation of any green 

 wood? They have lost most of their native forests. Until it is possible to bring m 

 pest free logs, they should not be allowed in at all. The statements made that there 

 are no risks is irresponsible and scientifically dishonest. Your unwillingness to 

 prohibit raw wood products from being imported into the US until both regulations 

 and mitigation protocols that are tested and proven effective is absolutely wrong. 

 Just why should we be so willing to put our forests at risk when even a modest 

 research effort combined with the requirement of drying at point of origin, would 

 virtually eliminate the risks? These proposed regulations are poorly crafted and 

 conceived and do a great disservice to those trying to develop sustainable forest 

 resources in western United States. Lest those more concerned with southern pine 

 forests feel they are protected from similar importations (wood chips, for example), 

 they should know that the chips from Honduras come from a species of pine 

 considered the SEine as long-leaf pine until only a few ye£irs ago. Pests of all types 

 are likely to find long-leaf pine and its near relatives appropriate alternate hosts, 

 Eind yet no one has even bothered to examine the chips at their point of origin for 

 possible organisms or to examine those pines from which the chips originate. 



The most distressing aspect of this entire exercise is the cavalier way in which our 

 natural resources are treated by APHIS. The original risk report on the 

 importation of raw logs from Siberia clesirly outlined the biological hazards of such 

 action. The report was prepared by a large number of well qualified speciahsts in 

 diseases and insects. The risks were well documented and the result was a 

 temporary ban on the importation of raw logs from the Soviet Far East until proper 

 mitigation protocols had been identified and developed. A parallel publication by 

 USDA/APHIS (USDA/APHIS, Misc. Publ. 1496) was pubhshed in 1991. This 

 document reviewed several procedures available for treating wood. Some of these 

 procedures were considered and deemed inadequate at the March, 1992, meeting of 

 the US Forest Service Science Panel that met in Sacramento, California, to consider 

 and draft mitigation protocol for raw log importations. Imagine our surprise when 

 we were given a draft of that protocol to consider and review - written by one of the 

 log importers! This draft was discarded and an entirely new document prepared. 

 All aspects of the problem were considered and recommendations drafted - 

 including areas where Uttle or no information was available and where research 

 was cleEirly needed. 



