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Absurdity # 1. Published research discussed in the Draft Environmental Impact Statement and 

 more recent studies suggest that all imported wood articles should be heated throughout to a 

 minimum of 160°F for 75 minutes. The Proposed Rules, however, call for wood articles to be 

 heated only to 133"? for 30 minutes. 



Absurdity # 2. Except for those wood articles that come from Siberia, imported logs and other 

 articles will not be required by APHTS to be heat treated until 1 to 2 months after their arrival at 

 U.S. ports. During these two months, the logs can be stored uncovered in ports or in exposed 

 mill yards and transported in open trucks throughout the region, including through valuable 

 forests. Throughout this two-month period, spores of fungi can be released into the air, insects 

 can emerge and fly to neighboring trees, and pieces of bark and branches can blow off in the 

 wind. As a result, all trees near the ports, mills, and along transportation routes are in danger of 

 being infected by virulent diseases. 



Absurdity # 3. Although many experts emphasize that complete debarking is necessary for 

 fumigants to reach and kill all surface-dwelling insects, the new rules allow the imported logs to 

 retain 2% of their bark. Even with 98% of the bark removed, a substantial numbers of insects can 

 be transported from the export country to the United States. 



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At>surdity # 4. Methyl bromide was recommended in the Proposed Rules to be the main 

 fumigant applied to logs and other wood products to kill pests, although 



(1) Methyl bromide is known to be a serious dcplctcr of the stratospheric ozone layer and 

 is scheduled to be banned from all production and use in the U.S. by the year 2001 by the 

 Montreal Protocol, to which the U.S. is a signatory; 



(2) It is due to be banned by the Environmental Protection Agency since its use is 

 inconsistent with the Qean Air Act; 



(3) It is an acutely toxic agent that causes human birth defects and neurological damage; 



(4) It penetrates only an inch into wood and cannot therefore kill disease organisms in the 

 center of logs; 



