97 



4 



Theie are times when rhe poieniiaJ losses are so high that we must restnct commerce to 



provide the protection that we need. This is clearly one such case. I do not understand why 

 APHIS is so reluctant to acknowledge iL 



The regulations that APHIS has proposed as iheir preferred alternative in the recently 

 Jistributed Draft EIS are clearjy inadequate. I will now address some of the inadequacies and 

 possible reasons for them. 



First, the risi( assessment methods are oesiE.ned primarily for agricultural crop pests 

 and are not appropriate for assessing risks tc '.'c-Sit vegetation. The methods rely on access 

 to nearlv complete knowledge of both the pesi;> tiheir host range, environmental requirements, 

 life cycles, etc.) and of the hosts. In almost ali cases with forest pests, our knowledge is 

 deficient: in most cases, it could be descnbed as sketchy: and in many cases, it can probably 

 be described as non-existen: To illustrate the last point. I will use three e.xaraples: 



(T> Prior to its introduction into the U.S., the chestnut blight fungus had not been 

 disco\ered anywhere on the planet. It took more than a decade of detective 

 work after the introduction before discovering it.s igin in Asia. 



(2) The Port Orford Cedar root disease fungus that currently presents a threat to 

 the species almost assmedly was introduced. It was fust discovered in a tree 

 nursery near Seattle in 1923. but even today more than 60 years later we still 

 do not know from whence it came. 



(3) The dogwood anthracnose fungus that is currently devastating to the dogwoods 

 in the Ea,st and in the Northwest is also very likely an introduced pest. Yet. 

 we have no idea where it originated. 



