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shipment California's regulations were stringent enough to identify the pests; APHIS'S were 

 not. 



The surest test of the adequacy of any regulation is whether or not it actually fulfills its 

 goals. Our short history of importing logs from Chile and New Zealand under Interim Rules 

 similar to the new Proposed Rules has produced strong evidence that these rules do not work. 

 For example, an importer recently brought western red cedar into the Pon of Coos Bay, Oregon, 

 without a permit No risk assessment had been developed for this tree species, so the inspectors 

 had no information about the pests that might be harbored in the wood. APHIS attempted to have 

 the logs burned, but the Oregon Department of Environmental Quality would not permit it 

 Finally, APHIS allowed the logs to enter the U.S. after fumigation, but the inspectors did not 

 know whether fumigation would be adequate to kill all the pests. 



Another requirement of the Interim and new Proposed Rules is that only healthy trees be 

 exported to the U.S. However, a recent load of logs arriving in California was found to be 

 diseased. This is yet another example of lack of compliance by exporters. And I have received 

 word that sawdust and chips from logs imported from New Zealand and Chile into California are 

 being combined, without sterilization, with waste from native trees and being spread as mulch in 

 California's forests. 



c- 



These plus several other examples of negligence and illegal activities by foreign exporters 

 and American mill owners illustrate the potential for virulent diseases and exotic insects to be 

 introduced into the forests «f the United States. These risks far outweigh the benefits derived by 

 a few lumber mills. The loss of even one important timber species such as Douglas fir, Loblolly 

 pine, or Northern red oak would wipe out large segments of the timber industry of the United 

 States. 



At the Forest Summit in Portland last year. President Clinton stated that the new Forest 

 Plan must be "scientifically sound, ecologically credible, and legally responsible." APHIS'S 

 Proposed Rules for importing logs and other unmanufactured wood articles into the United States 

 do not meet any of these criteria. 



