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2. Secretary Espy, 9 December 1993 



Technology Assessment (OTA) estimated that 15 of the most hannful imponed pest species 

 could eventually cost the U.S. $134 billion (1991 dollars). 



Importation of raw or inadequately processed logs into the U.S. is 

 highly dangerous. Valuable timber species such as Douglas-fir, western red 

 cedar, and ponderosa pine have little resistance to the pathogens and insects 

 that have evolved in Asia. The current loss of entire stands of the valuable timber 

 species, Port-Orford cedar, due to infestation by the lethal laxninatcd root-rot disease is an 

 example of the virulence of exotic diseases. 



Wc cannot overstress the importance of avoiding the introduction of exotic pests into 

 the United States. Techniques for totally eradicating pests and pathogens on the surface and 

 in the interior of logs are now available. However, we caution that the U.S. not rely on these 

 techniques until they have been thoroughly tested. ONRC recendy spoke with a member of 

 the Animal and Plant Health Inspection Service (APHIS) in Washington, D.C., who said that 

 different fumigarion techniques were being studied as part of the Environmental Impact 

 Statement (EIS) process for the importation of foreign logs, but that none were being 

 experimentally tested. In other words, if forest pest or pathogen species from any log- 

 exporting country have biological properties that make them more resistant to control 

 techniques than species studied previously, this will not be discovered undl after the pests 

 have been introduced into our country. 



We should follow the lead of the European Community (E.C), which has a strict 

 forest-protecdon program. The E.C. prohibits the importation of raw logs, and they require 

 that lumber be kiln-dSried in the country of origin. This ensures that forest pests will not be 

 inadvertendy transported and released into Europe during ship off-loading or during transit to 

 the wood's final destination. The E.C-standard should be displayed as an altemativc and 

 adopted as die preferred alternative by die Department of Agriculture in the EIS that the 

 Department is currendy preparing. 



As a second alternative (although we emphatically recommend the E.C. standard), 

 we urge the USDA to enact the following regulations, as a minimum, before allowing the 

 entrance of foreign timber into the U.S.: 



1. Only the most effective eradication techniques, such as heat treating wood to 

 160*F throughout, should be used. This treatment kills all insects and fungi in 

 the interior of logs, which simple debarking and fumigation techniques do not 



2. Pest eradication should take place in the country of origin; 



3. The holds of a^nsport ships should be fumigated before reaching U.S. ports 

 since foreign pests, such as the Asian gypsy moth, can be brought into the 

 United States in diis way. Fumigation of ships is especially critical for logs from 

 Asia, where "clean" ports are not yet available. 



4. Companies importing foreign logs or lumber should have to post boixls to 

 ensure diat the costs of inspection, research, and possible eradication after 

 release of pests be recovered. Since the cumulative potential losses from the 

 Asian gypsy modi and die nun modi have been estimated at between $35 billion 

 and $58 billion (1991 dollars), dus bond should be commensurably high. 



These steps should be taken for log imports from all foreign countries, 

 not just from Chile, New Zealand, and Russia. Because logs from any 



