99 



6 



to combat both endemic and introduced disease agents, either takes decades to develop or is 



not available to the forest pest manager at all. Once wc have made the mistake and 

 introduced a forest pest, there may be absolutely nothing that wc can do to sufficiently reduce 

 the impacts upon the forest ecosystems or upon our economy. The prospects are frightening. 

 We must cake whatever steps that we can to assure that pest introductions do not occiir in the 

 fust place. APHIS must understand the implications and address them with great inteUigence 

 and the best means possible. 



The next issue is that of the regulations proposed by APHIS. I firmly believe that the 

 alternative preferred in their EIS is totally inadequate at least wjth respect to disease-causing 

 agents (fungi, bacterin. nematodes and possible viruses) that can be deep within logs and large 

 dimension lumber. The so-called prefened alternative seems to have been designed more to 

 minimize restrictions on commerce than to protect North American forest resources. Since 

 this is almost the antithesis of Che mission of APHIS, I do not comprehend such action. Is it 

 possibly due to political pressures from Congress itself? 



I will briefly address below some of the cnticisms that 1 have: 



(1) Inspections simply cannot ensure that phini pests are not present" lo logs, 

 large timbers or even m sawn boards. 



(2) Sampling, to be effective in detection of microscopic disease agents in the 

 wood, needs to be relatively intensive, especially if the goal is to exclude 

 potentially devastating pests. Such sampling is labor intensive, so the proposed 

 level of sampling is dangerously low. 



(3) Once the samples are taken, they must go to a laboratory where they are 

 subjected to a variety of tests. If an organism is isolated, often it has to be 



