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stead, virulent pests in foreign countries that have a potential to attack Nortn 

 American trees should be studied to obtain informadon to prevent or delay introduc- 

 tion to this continent. Potenual pests can be evaluated by planting North American 

 species in infested areas of foreign countries to measure suscepnbility. Alternately, 

 pests can be imported into a USDA-approved quarantine facility and evaluated under 

 controlled conditions. 



While APHIS has not yet adopted a comprehensive policy, as above, it is willing to 

 increase the effectiveness of its pest exclusion efforts through new regulations. In 

 September 1992, APHIS announced an intent to propose general reguladons that 

 would govern "unprocessed wood" products that could transport nonindigenous or 

 not previously introduced pests (see 57 Federal Regisler, No. 184, pp. 43628-43631). 

 The agency sought input on mitigation measures for different "unmanufactured 

 wood products' exported from different coimtries. APHIS also invited suggestions as 

 to whether the agency should have considerable flexibility in the future to revise 

 import requirements, or whether it should be required to seek public comment 

 before adopdng any fumre revisions. 



Twenty-eight wood importers and trade associations responded to the APHIS nodce. 

 Many of the importers and trade associations recognized the risk of pest introduc- 

 tion, but all argued that any regulation must be a reasonable response to "real* rather 

 than "imaginary" risks, economically feasible, and in compliance with free-trade prin- 

 ciples. The association of Northwest Independent Forest Manufacturers argued that 

 such high-value wood products as Siberian larch should be imported under less strin- 

 gent regulations as part of balancing risk against benefit 



Many companies and associations supported adoption of a "universal' rule, but then 

 argued that their particular import, e.g., wood chips from Canada or Mexico, should 

 be subject to less resuiciive regulation or exempted completely. Several asserted that 

 tropical woods posed no dircat as pests would be killed by winter freezes. However, 

 some firms plan to import chips from pine and other species from planutions in the 

 tropics to Gulf Coast or California ports which are near native pine forests and plan- 

 tations where freezing temperatures are relatively infrequent 



The assertion that importation of logs from neighboring countries belonging to 

 species native to the United States should cause less concern was expanded by the Amer- 

 ican Forest Council to include Monterey pine plantations in distant countries. Argu- 

 ing that Monterey pine planutions "may not be subject to the same insects and pests 

 as exotic [tree] species[,l" the Council concluded that Monterey pine imports should 

 be subject to less stringent phyiosaniury regulation than imporu of species not 

 native to North America. The American Forest Council has failed to recognize that 

 imporuiions of North American tree species grown in another country should be 

 more stringendy regulated than nonnaiive species. A greater probability of successful 

 infestation exists when the imported host species is native to the area of introduction. 



Recommendations Re: Raw Wood Imports 



The authors of this paper firmly believe that quarantine procedures should be devel- 

 oped for all categories of raw wood imports, including logs and wood chips. However, 

 we are not suflicienUy expert to determine the most effective quaranune measures to 

 ensure exclusion of forest pests. The reports by the three risk assessment teams and 

 the Siberian midgation advisory team are good examples of the interdisciplinary 

 cooperauve effort needed to analyze a specific importation situation with a potential 

 to cause pest problems, and then to develop reasonable protocols to insure against 



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