Historic, Archive Document Do not assume content reflects current scientific knowledge, policies, or practices. United States Department of Agriculture Marketing and Regulatory Programs Animal and Plant Health Inspection Service & ism Importation of Logs Lumber, and Other Unmanufactured Wood Articles Final Supplement to the Environmental Impact Statement, May 1998 Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Final Supplement to the Environmental Impact Statement, May 1998 Agency Contact: Richard Orr, Senior Entomologist Risk Analysis Systems Policy and Program Development Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 117 Riverdale, MD 20737-1238 Telephone: 301-734-8939 The U S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an equal opportunity provider and employer. Mention of companies or commercial products in this report does not imply recommendation or endorsement by the U.S. Department of Agriculture over others not mentioned. USDA neither guarantees nor warrants the standard of any product mentioned. Product names are mentioned solely to report factually on available data and to provide specific information. This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State and/or Federal agencies before they can be recommended. CAUTION: Pesticides can be injurious to humans, domestic animals, desirable plants, and fish or other wildlife — if they are not handled or applied properly. Use all pesticides selectively and carefully. Follow recommended practices for the disposal of surplus pesticides and pesticide containers. Table of Contents Summary of Supplement to the Environmental Impact Statement iii I. Introduction 1 A. Background 1 B. Historical Perspective 4 C. Relationship to the Environmental Impact Statement 6 D. Relationship to the Rulemaking Process 7 E. Summary of the Environmental Impact Statement 8 F. Summary of the Economic Analysis 10 II. Purpose and Need 13 III. Court Orders 15 A. Introduction 15 B. Point 1 — Uncertainty of Efficacy of Combinations of Methods 15 C. Point 2 — Omission of Important Information 16 1. Risk Assessments and Control Measures 16 2. Compliance by Exporting Countries 17 3. Human Health Effects of Control Efforts 17 D. Point 3 — Comparison of the Alternatives 17 IV. Environmental Analysis 19 A. Point 1 — Efficacy of Combinations of Methods 19 1. Introduction 19 2 Potential Future Imports 20 3 Risk Assessments and Combinations of Methods 21 B. Point 2 — Important Additional Information 28 1. Risk Assessment and Control Measures 28 2. Compliance by Exporting Countries 33 3. Human Health Effects of Control and Eradication Efforts 44 C. Point 3 — Comparison of the Alternatives 55 1. Introduction 55 2. Summary of Pest Prevention Methods 62 3. Example Shipment of Wood Products 65 4. Summary of Environmental Consequences of Alternatives 67 5. Individual Ranking of Environmental Consequences of Alternatives ... 69 D. Additional Updated Information 79 1. GAO Audit of Agricultural Inspection 81 2. Suppression/Eradication Strategies 82 3. Methyl Bromide Use 86 4. New Methods and Techniques 87 5. Summary of Pest Risk Assessment for Logs From Mexico 90 6. Information on Effectiveness of the Wood Import Regulation 92 V. Preparers and Reviewers 95 Table of Contents i VI. References Cited 97 VII. Appendices A Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-1 B. Court Documents B-1 C. Documents Related to Compliance C-1 D. Acronyms D-1 E. Glossary E-1 F. Final Rule on Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-1 Tables 1 Estimated First Year Welfare Impact on U.S. Society 11 4-1 Efficacy of Mitigation Measures Available for Pests and Pathogens Associated With Russian Timber Imported to the United States 23 4-2 Regulatory Requirements for Imported Logs From Chile or New Zealand 25 4-3 Raw Logs — Pathogens and Pests vs. Mitigation 26 4^4 Raw Logs — Pathogens and Pests vs. Mitigation 26 4-5 Universal Permit Regulatory Requirements for Wood Imports 27 4-6 Ability to Import Various Types of Wood Commodities Under Each of the Six Alternatives 55 4-7 Alternative 2: Key Aspects of Subpart 40 Definition of Regulated Articles 58 4-8 Requirements for Specified Articles 58 4-9 Universal Importation Requirements 60 4-10 Requirements for General Permits 61 4-1 1 Example Shipment of Wood Products Under Each Alternative 66 4-12 Alternatives and Methyl Bromide Use 72 4-13 Amount (in Metric Tons) of Methyl Bromide Used to Fumigate Imports of Logs, Lumber, and Other Unmanufactured Wood Products 87 Figures 1 Timeline for the EIS, Regulation, and SEIS 4 2 Relative Ranking of Alternatives With Regard to Their Ability to Exclude Pests and Their Environmental Consequences 68 ii Table of Contents Summary of Supplement to the Environmental Impact Statement The U S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), is charged with preventing the introduction and dissemination of exotic animal and plant pests and pathogens in the United States for the purpose of protecting its agricultural, aquacultural, and forest resources. One of the ways APHIS accomplishes its mission is through regulating imports, such as agricultural items and plant-related materials, that may harbor plant pests. In early 1990, APHIS began to receive inquiries from the wood products industry regarding the possibility of importing large quantities of logs, lumber, and other unmanufactured wood articles from sources other than Canada (the traditional source of imported wood articles). The initial requests were from Siberia. This was soon followed by inquiries for log imports from New Zealand and Chile. In order to determine the potential of such imports to introduce exotic plant pests, APHIS requested the U.S. Forest Service to conduct pest risk assessments. APHIS’ wood import regulation was based, in part, upon the results of the risk assessments, careful analysis of available mitigation measures, consideration of comments from the public and industry, and the results of an environmental impact statement (EIS) that was completed in 1994 pursuant to the National Environmental Policy Act (NEPA). The regulation became effective in August 1995 and was subsequently challenged in Federal court, in part, on grounds that the NEPA component of the rulemaking was deficient. The U.S. District Court for the Northern District of California agreed that the EIS was lacking in certain respects and, on June 5, 1997, enjoined the issuance of new import permits for the importation of certain unfinished nontropical wood articles under the 1995 regulation, pending, in part, the correction of deficiencies in the EIS that were cited in the court’s order. The primary purpose of this Supplement to the EIS (SEIS) is to fulfill this court ruling. The court found the EIS to be deficient in three areas: • the EIS assumes without examination that individually ineffective control measures will be effective collectively; • the EIS omits significant information concerning uncertainties in the risk assessments and control measures, compliance by exporting countries, and human health effects of control measures; and • the EIS lacked an adequate comparison of the alternatives considered. This SEIS specifically addresses the court’s areas of concern and provides additional updated information that has become available since the EIS was published in 1994. /// The SEIS explains in much greater detail the process that was used in developing the requirements of the wood import regulation. This included evaluating pest risk through the use of pest risk assessments and evaluating the various mitigation measures available to arrive at a series of measures that, when used in sequence, are effective in reducing pest risk to a negligible level. The SEIS discusses the uncertainties in the pest risk assessments and control measures. It discusses the Agricultural Quarantine Inspection (AQI) program, of which the wood import regulation is a part, and discusses how noncompliance is handled by the AQI program. It also discusses, in general terms, the potential human health effects of pest mitigation actions. Specific pest management programs, as they are developed and planned, will be subject to site specific analyses to ensure that potential impacts to human health are known prior to implementation. The six alternatives are compared through a ranking of each alternative relative to its potential effects on each of the seven areas of potential impact that were discussed in the EIS. These seven areas are human health, forest resources, biodiversity, methyl bromide use (impact to the ozone layer), global climate change, cultural resources, and endangered and threatened species. In addition to addressing the court-identified deficiencies, the SEIS provides updated information. This includes a discussion of a recent U.S. General Accounting Office (GAO) review of the AQI program. The thrust of the GAO review is that port inspection, as a sole line of defense against the introduction of exotic plant pests, has weaknesses that are difficult to overcome. Because inspection was the sole mitigation measure prior to the wood import regulation, this is precisely the reason that the regulation was developed. The SEIS includes a general discussion of suppression and eradication control strategies that may be applied to forest plant pests. In addition, it provides information discussing that APHIS has experienced no discernible increase in the use of methyl bromide since promulgation of the wood import regulation. The SEIS concludes that two new potential treatment methods, irradiation and shipboard heat treatment, may hold promise, but are as yet unproven. The SEIS also provides information on the newly completed pest risk assessment for logs from Mexico, information on quarantine pest interceptions since the wood import regulation was implemented, and includes an appendix devoted to public comments received on the draff SEIS. IV I. Introduction A. Background North America is rich in forest resources. Because of its abundant forest resources, the United States historically had imported relatively small quantities of logs and lumber. However, the United States has now become the world’s leading importer of wood and wood products (Stairs and Salinger, 1988). In 1990, for example, the United States imported more than $5 billion in logs, lumber, and other unmanufactured wood articles (USDA, FAS, 1992). Historically, large U S. imports of softwood logs and lumber have been limited to those from the forests of Canada. In recent years, the quantity of softwood logs available in the United States for harvest and milling has declined, particularly in the Northwest, where Washington and Oregon alone produce about 16 percent of the total U S. tree harvest. Commercial forest lands available for logging in the United States are projected to decrease by 4 percent between 1990 and 2040 (USDA, APHIS, 1995). Concerns over wildlife habitats, such as the spotted owl in the Northwest, are likely further to limit future U.S. tree harvest. Meanwhile, demand for timber is increasing. For example, it is estimated that demand for timber imports to the United States from the former Soviet bloc alone could be between 265 and 425 million board feet per year (USDA, FS, 1995a, and USDA, FS, 1991a). This trend of lower domestic harvest combined with higher consumer demand increases the demand for imports (USDA, APHIS, 1995). Therefore, the industry has expressed interest in importing large volumes of logs over an extended period. The focus has been on softwoods from northeastern Asia’s boreal forests and plantation- grown pine from countries in the Southern Hemisphere. The U.S Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), is charged with preventing the introduction and dissemination of exotic animal and plant pests and pathogens in the United States to protect its agricultural, aquacultural, and forest resources. One way APHIS accomplishes its mission is through regulating imports, such as agricultural items and plant-related materials, that may harbor plant pests. Recent trade agreements, such as the North American Free Trade Agreement (NAFTA) and the General Agreement on Tariffs and Trade (GATT), have opened trade by removing barriers (other than phytosanitary barriers), which directly affect APHIS’ inspection activities. Because the United States historically has not imported appreciable quantities of logs and lumber (except from contiguous Canadian forests), APHIS did not have quarantine regulations in place specifically for logs, lumber, and other unmanufactured wood articles. The Organic Act (7 U.S.C. 147a), the Federal I. Introduction 1 Plant Pest Act, as amended (7 United States Code (U.S.C.) 1 5 Oaa— 1 5 Ojj ), and the Plant Quarantine Act, as amended (7 U.S.C. 151-167), provide the Secretary of Agriculture with the authority to inspect a commodity entering the United States, require treatment or refuse entry if it is found to be infested with specific pests, and to act either independently or in cooperation with States or local governments to carry out operations or measures to detect, eradicate, suppress, control, or prevent the spread of plant pests. However, inspection alone is insufficient to address the plant pest risk associated with the increase in the quantity, size, and diversity of shipments of logs, lumber, and other unmanufactured wood articles. In early 1990, APHIS received the first requests from the wood products industry to import logs from Siberia. These requests covered the importation of several ship containers of logs in order to test import procedures and the market qualities of Siberian larch and pine. These shipments demonstrated a potential for the introduction of pest species of insects, nematodes, and plant pathogens. This experience prompted APHIS to request the U.S. Forest Service (FS) to conduct a detailed pest risk assessment of Siberian larch (USDA, FS, 1991a). The pest risk assessment estimated that the introduction of a single pest, the larch canker, could cause direct timber losses of $129 million annually and that a worst-case scenario involving heavy establishment of exotic defoliators in the United States could cost $58 billion. Meanwhile, APHIS analyzed the efficacy of control measures that could be used against plant pests associated with Siberian timber (USDA, APHIS, 1991a). APHIS concluded that damage could be limited by control programs, but once a pest such as a defoliator is established, eradication would be unlikely. Because of the clear indication of potential plant pest problems, APHIS stopped the importation of logs from Siberia in September 1990. To improve on regulating the entry of these articles, APHIS also indicated its intention to promulgate a comprehensive regulation governing the importation of logs, lumber, and other unmanufactured wood articles. An advance notice of proposed rulemaking was published in the Federal Register on September 22, 1992 (57 FR 43628) (see fig. 1). After this, APHIS received letters of concern from Congress and citizens. Prompted by other import requests and growing public concern, APHIS requested the U.S. Forest Service to conduct two additional pest risk assessments. The first risk assessment, for Monterey pine ( Finns radiata) and Douglas-fir ( Pseudotsuga menziesii ) logs from New Zealand, screened the 30-year computerized list of insects and pathogens for these two tree species and focused on seven organisms having the greatest potential risk (USDA, FS, 1992a). The second risk assessment, for Monterey pine, coigiie ( Nothofagus dombeyi), and tepa (Laurelia philippicina) from Chile, similarly compiled lists 2 /. Introduction of insects and pathogens known to be associated with these tree species. Those ten insects and four pathogens posing the greatest risk potential were then identified and analyzed in detail (USDA, FS, 1993a). Both risk assessments also identified gaps in available biological information on insects or pathogens. One insect and one pathogen were identified as having high risk potential. Seven insects and two pathogens were identified as having moderate risk potential (USDA, FS, 1993a). APHIS, utilizing these two pest risk assessments to develop mitigation measures to address the identified levels of risk and minimize the potential for plant pest introduction, published an interim regulation for the importation of Monterey pine logs from Chile and Monterey pine and Douglas-fir logs from New Zealand (58 FR 59348, November 9, 1993). The comprehensive regulation (see appendix F) promulgated by APHIS (60 FR 27665, May 25, 1995), which became effective on August 23, 1995, supersede this interim rule. The scoping comment period for the “Importation of Logs, Lumber, and Other Unmanufactured Wood Articles, Draft Environmental Impact Statement” (DEIS) was open for 30 days, from July 26 to August 25, 1993 (58 FR 39726). On January 20, 1994, APHIS published the accompanying proposed regulation in the Federal Register (59 FR 3002). The DEIS was published in February 1994 and the final EIS (EIS) was published in July 1994. The Final Economic Analysis of the proposed regulation was completed by APHIS on May 1, 1995, and the regulation was promulgated on May 25, 1995 (60 FR 27665). On November 14, 1995, a complaint was filed in the U S. District Court for the Northern District of California, alleging, in part, that the EIS prepared in conjunction with the regulation violates the National Environmental Policy Act (NEPA) and the Council on Environmental Quality (CEQ) NEPA implementing regulation. The Oregon Natural Resources Council (ONRC), the Pacific Environment and Resources Center, and the Northcoast Environmental Center brought this suit On April 25, 1996, a related complaint against APHIS, also in the Northern District of California, was filed by Californians for Alternatives to Toxics and the Mendocino Environmental Center The two complaints were consolidated On February 27, 1997, the court ruled on plaintiffs’ and APHIS’ motions for summary judgment, finding the EIS inadequate in three areas. On June 5, 1997, the court ruled on the plaintiffs’ motions for injunctive and declaratory relief, enjoining APHIS from issuing any new permits for the importation of certain nontropical wood articles until APHIS prepares a Supplement to the EIS (SEIS) and promulgates regulations in light of the SEIS A Notice of Intent to prepare an SEIS was published in the Federal Register in August 1997 (62 FR 45217, August 26, 1997). Work was initiated on the /. Introduction 3 SEIS in July 1997; the draft SEIS was published in December 1997; and the final SEIS was available for public review in May 1998. Advance Economic Analysis Notice of Proposed DEIS Completed & Complaint Filed by Rulemaking Published Regulation Promulgated ONRC.ef a/. Septem ber 1992 February 1994 May 1995 Novem ber 1995 A A A A V V V DEIS EIS Regulation Scoping Published Became Effective July-August 1 993 July 1994 August 1995 Court Rules on Motions Notice of Intent to Prepare an Publication for Summary Judgment SEIS Published of Final SEIS February 1997 August 1997 May 1998 A A A V V V Complaint Filed by Court Rules on Motions Draft SEIS CATS, et a/ for injunction & Published April 1996 Declaratory Relief December 1997 June 1997 Fig. 1 . Timeline for the EIS, Regulation, and SEIS. It may appear as though the promulgation of the regulation placing restrictions and requirements on imported logs, lumber, and other unmanufactured wood articles is an impediment to free trade and, thus, might be construed as contrary to other U.S. public policy interests. However, this is not the case. The sole function of the proposed regulation is to protect U.S. natural resources from the potentially devastating effects of introduced plant pests. The regulation is structured to allow importers a degree of flexibility in their approach to the issue. This strategy results in import restrictions that obstruct trade as little as possible while still fulfilling their purpose of protecting U.S. natural resources from the risk of plant pest introductions. B. Historical Perspective Forest ecosystem diversity, function, and productivity have been dramatically altered by the introduction of exotic insects and pathogens. More than 20 exotic fungal pathogens and 360 exotic insects now attack woody trees and shrubs in North America (Haack and Byler, 1993). Following are examples of the consequences of exotic plant pests to our Nation’s forests: • Chestnut blight, which is caused by a fungus, was first discovered in 1904 and was probably introduced from Asia. Within 50 years, it had killed 4 I. Introduction nearly all of the chestnut trees in the United States. At the turn of the century, chestnut trees comprised a quarter of all hardwood trees in the United States and numbered in the billions (Newhouse, 1990). Despite extensive research efforts, no solution has been found to save the species, and mature American chestnut trees are no longer found in the United States. • Dutch elm disease was introduced in North America in the 1920's from Europe. It is caused by a fungus that is spread by the European (and later American) elm bark beetle. It is now found in every State in the continental United States (USDA, FS, 1991a). Cook (1987) estimated that 100 million elm trees have succumbed to the disease. • White pine rust fungus attacks all species of five-needle pines and other host plants, such as the currant and gooseberry. Introduced around 1900, it has spread throughout most of North America. Eastern and western white pine and sugar pine are the most valuable timber species affected by the rust. Between 80 and 95 percent of these trees have been killed or damaged in affected stands, including 9 million acres in the Northwest (USDA, FS, 1991a). • European gypsy moths were brought into the United States in the 1860's by an entomologist. Currently, the infestation area includes much of the northeastern United States and portions of the Midwest and Canada. The gypsy moth, which feeds voraciously on new leaf growth, is considered the most destructive insect that attacks hardwood forests, shrubs, and urban shade trees. More than 12 million acres in the northeastern United States alone were defoliated in 1981, causing weakened trees, reduced growth, and aesthetic losses. Several million dollars are spent annually to monitor, suppress, and control the gypsy moth in the United States and Canada, but the European gypsy moth continues to spread (USDA, FS, 1991a). The more aggressive Asian gypsy moth, introduced from Siberia on grain ships, was discovered in 1991 in Oregon, Washington, and British Columbia. After a $27 million effort in 1992, the infestation was eradicated (Bridges, 1993). There also have been recent reports of Asian gypsy moths in both North Carolina and South Carolina, which were addressed in the environmental assessment for the 1995 gypsy moth eradication program in North Carolina and South Carolina (USDA, FS and APHIS, 1995b). A successful eradication program was approved and undertaken in 1995. I. Introduction 5 C. RelationsSiip to the Environmental Impact Statement The Council on Environmental Quality’s (CEQ) implementing regulations for the National Environmental Policy Act of 1969 (NEPA), as amended (42 U.S C 4321 et seq.), state — (c) Agencies: ( 1 ) Shall prepare supplements to either draft or final environmental impact statements if: (i) The agency makes substantial changes in the proposed action that are relevant to environmental concerns; or (ii) There are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts. (2) May also prepare supplements when the agency determines that the purposes of the Act will be furthered by doing so. (40 Code of Federal Regulations (CFR) 1502.9) Supplements also may be prepared to address significant concerns or data or informational gaps identified by the preparing agency or other reviewers (such as the U.S. Environmental Protection Agency (EPA) or the courts). In this case, APHIS is preparing a Supplement to the EIS because of the U.S. District Court for the Northern District of California’s order regarding the need to address uncertainty and improve clarity in the following three areas: • The efficacy of combinations of treatment methods; • The omission of important information concerning uncertainties in risk assessments and control measures, compliance in other countries, and human health effects of pesticide applications; and • Comparison of the alternatives. The CEQ directs agencies to “prepare, circulate, and file a supplement to a statement in the same fashion (exclusive of scoping) as a draft and final statement unless alternative procedures are approved by the Council” (40 CFR 1502.9(c)(4)). The process formally began when APHIS published a Notice of Intent in the Federal Register on August 26, 1997, and requested comments from interested parties (62 FR 45217) This notice outlined the three areas to be addressed in the SEIS and requested comments on the proposed scope of the SEIS. The request for comments on scope is not required, but was included to demonstrate adherence to the spirit and intent of NEPA. In response to this notice, 33 comment letters were received. They were considered in the preparation of the draft SEIS. Notice of the availability of the 6 /. Introduction draft SEIS appeared in the Federal Register on December 10, 1997 (62 FR 65426). Because an SEIS is prepared in the same fashion as an EIS, an SEIS is subject to a minimum of a 45-day comment period on the draft and 30 days on the final before the issuance of a Record of Decision (40 CFR 1 506. 10(b), (c)). A 60-day comment period on the draft SEIS closed on February 10, 1998. Comments received were used to help complete this SEIS. In addition, the comments have been included in appendix A. APHIS intends to issue a Record of Decision at the conclusion of the 30-day period after the Notice of Availability of the SEIS is published D. Relationship to the Rulemaking Process As required by section 102(2)(c) ofNEPA (42 U S.C. 4321 et seq.) and outlined in the CEQ regulations (40 CFR sections 1 502.3, 1 502.4, and 1508.18), an EIS is required on “major Federal actions” which significantly affect the quality of the human environment Included in the category of “major Federal actions” are “new or revised agency rules [or] regulations” (40 CFR 1508.18). Both the rulemaking and NEPA processes provide considerable opportunities for public comment. APHIS notified the public that it was considering regulating the importation of logs, lumber, and unmanufactured wood articles in an advance notice of proposed rulemaking (57 FR 43628, September 22, 1992). In accordance with the NEPA process, APHIS published in the Federal Register (58 FR 39726) on July 26, 1993, a combined notice of intent to prepare an EIS and scoping notice requesting comments from interested parties. Comments also were received on the proposed rule (59 FR 3002, January 20, 1994). APHIS held public hearings on February 10, 1994, in Portland, Oregon, and on February 23, 1994, in Washington, DC, to receive comments. The comments from the public hearings and the written comments received on the draft and final ElS’s were considered by APHIS. Responses to comments on the draft EIS were published in the final EIS. As required by the CEQ regulations (40 CFR 1502.9 (c)(4) and 1506.10(c)), APHIS provided a public comment period (of 60 days, 15 days more than the minimum required) after the notification of availability of the draft SEIS. Upon completion of this SEIS, APHIS will publish a Record of Decision (ROD), as required by 40 CFR 1505.2. The ROD will state all of the alternatives considered and discuss means to avoid or minimize environmental harm from the selected alternative. I. Introduction 7 E. Summary of the Environmental Impact Statement APHIS is responsible for preventing the introduction and dissemination of exotic plant pests and diseases in the United States, thus protecting U.S. agricultural, aquacultural, and forest resources from plant pests. As part of its mission, APHIS proposed a regulation regarding the importation of logs, lumber, and other unmanufactured wood articles. The regulation was intended to minimize the risk of plant pest introductions associated with the importation of logs, lumber, and other unmanufactured wood articles into the United States. The need for a comprehensive regulation was prompted by the request of the wood articles industry to permit entry of larger volumes of logs into the United States from other countries. Shipments of logs from some localities provide a greater potential for introduction of plant pests than shipments from other localities. Unfortunately, both accidental and intentional plant pest introductions have wreaked havoc on the forest and agricultural resources of the United States. Among these, chestnut blight and Dutch elm disease are recognized as two of the most devastating plant diseases to North American trees. More recently, the United States and Canada have invested millions of dollars in ongoing control and eradication efforts to stem invasions of European and Asian gypsy moths. As required by NEPA, APHIS prepared the E1S because of the potential for impact to the environment from implementation of the proposed regulation. APHIS considered the following six alternatives in the EIS: Alternative 1 — No Action Alternative 2 — Proposed Regulation (Preferred Alternative) Alternative 3 — Prohibit Untreated Wood Except Packing Material Alternative 4 — Prohibit Untreated Wood Alternative 5 — Prohibit Unmanufactured Wood Except Packing Material Alternative 6 — Prohibit Unmanufactured Wood The no action alternative would allow importation of logs, lumber, and other unmanufactured wood articles to continue as in the past, before the wood import regulation. Under the no action alternative, APHIS’ authority was limited to inspect, require treatment, and refuse entry of any article believed to be a plant pest risk. Importers were not required to treat logs, lumber, or other unmanufactured goods. If importers treated wood articles, they had no restrictions regarding the type of pesticides that could be used, and pesticides 8 I. Introduction banned in the United States could be used to treat wood articles. Under the no action alternative, APHIS would continue to discourage importation of wood articles from Siberia, but countries could pressure APHIS to allow entry of wood articles contingent on inspection. The remaining five alternatives considered in the EIS all restrict, to varying degrees, importation of logs, lumber, and other unmanufactured wood articles. AJternatives 2, 4, and 6 require treatment of wood articles and packing materials. These alternatives are more protective in preventing plant pest introduction than other alternatives. Alternative 6, which is the most restrictive of imports, prohibits the importation of any unmanufactured wood articles. Alternative 4 allows the importation of unmanufactured wood articles, but requires pretreatment of all imports. Alternative 2, the preferred alternative, allows importation of unmanufactured wood articles and untreated wood articles that meet certain conditions, as described below. Alternatives 3 and 5 restrict the importation of unmanufactured or untreated logs and lumber, but do not require the treatment of packing materials Because these alternatives exempt packing materials from regulation, they are considered less protective than alternatives 2, 4, and 6. Alternative 2, the preferred alternative, requires plant pest treatments in all cases in which APHIS has identified a risk of plant pest introduction. Of the alternatives, alternative 2 presents, what APHIS believes, is the set of actions that will best accomplish the goal of minimizing pest introduction. The regulation under alternative 2 imposes three basic requirements for the entry of regulated articles into the United States as follows: 1. A permit either must be issued by APHIS for the importation of a regulated article before to its arrival at a U S. port, or must meet the requirements of a general permit as outlined in the wood import regulation. 2. An importer document or certificate must accompany every shipment of regulated articles verifying that the conditions of the APHIS regulation have been met. The only exceptions to this requirement are set forth in sections 319.40-2(c) and 319.40-3 of the wood import regulation. 3. At the time of arrival, all regulated articles are subject to inspection to ensure that shipments comply with requirements and plant pests of concern are not present. If upon inspection any signs of plant pests are found or if the inspector finds that the requirements for importation and entry have not been met, the inspector has the option of refusing entry of the regulated article into the United States or requiring safeguards or pest mitigation measures, such as treatment, that would minimize the risk of plant pest introductions. I. Introduction 9 Under this regulation, APHIS may issue a permit if the applicant has not had a permit revoked for noncompliance within the previous 12 months and can meet any of the following three options: ( 1 ) the importer document or certificate verifies that the requirements for a general permit are met, (2) requirements for specified articles from specified countries are met, or (3) universal importation requirements are met. The EIS addressed the potential impacts to the environment for each of the six alternatives. These included possible risks to — • human health, • forest resources, • ozone depletion from the use of methyl bromide, • biodiversity, • global climate change, • cultural resources, and • endangered and threatened species. A detailed analysis of potential impacts from the use of methyl bromide was prepared because of the classification of methyl bromide as an ozone depletor. In addition, an economic analysis was prepared to determine the economic effects of the proposed regulation on free trade. A draft of that analysis was available for the EIS. It has since been completed and is summarized in the next section F. Summary of the Economic Analysis The Final Economic Analysis of Proposed 7 CFR Part 319, Quarantine 40 Regulations (Q^40), was completed on May 1, 1995, by the Policy Analysis and Development Staff of APHIS. Because it was unavailable when the EIS was published, APHIS is including the following summary of the economic analysis. As shown in table 1, the economic analysis estimates that, during the initial year of implementation of the wood import regulation, domestic producers of regulated articles would benefit from a welfare gain of about $35.2 million, while domestic consumers could incur a welfare loss of about $171.9 million. About 78.6 percent of the total estimated consumer welfare loss is attributable to treatment costs for dunnage (including scrap lumber) used to pack various nonbulk commodities imported into the United States. APHIS anticipates that this potential welfare loss will be reduced as shipping companies switch to bark-free dunnage materials to avoid Q-40 treatment costs. The net consumer loss for regulated imported wood articles occurs because additional regulatory restrictions would raise prices and decrease the availability of imported 10 /. Introduction unmanufactured wood articles. Therefore, the demand and price for less costly domestic wood would likely rise because higher import prices will encourage U S. consumers to change their purchasing practices. Table 1 — Estimated First Year Welfare Impact on U.S. Society (in thousands of dollars) Commodities impacted by proposed rule U.S. consumer welfare losses U.S. producer welfare gains Net welfare impact Wood articles1 (29,768) 29,736 (32) Dunnage as cargo2 (7,060) 5,460 (1,601) Dunnage used in shipping3 (135,122) 0 (135,122) Estimated total impact (171,950) 35,196 (136,754) Note: Columns and rows may not sum due to rounding 1 Includes logs, wood chips and particles, rough lumber, and untreated railroad ties, posts, piles, and poles 2 Includes newly manufactured wood packing boxes and cases; containers for fruit/vegetable harvests; and crates and pallets made from untreated rough lumber. These articles are produced/imported for first time use. 3 Includes all dunnage materials with bark (including scrap lumber) used as packing material for imported commodities. This estimate assumes that this rule will not affect domestic production of wood dunnage or articles that use this debarked dunnage. Table 1 estimates that compliance with the requirements of the rule may cost U.S. society up to $136.7 million, representing the cost of plant pest exclusion. This cost figure does not consider either the benefits that would be accrued by excluding pests or the probability that businesses would be able to reduce this cost by choosing among the rule’s requirement options in ways that minimize their costs. If the United States does not expend resources to exclude plant pests through regulation or other means, such pests could become established and cause significant damage to domestic agriculture For example, in the past few years plant pests, including the Asian gypsy moth and pine shoot beetle, have been introduced into the United States, and several million dollars have been spent on efforts to eradicate, control, or prevent further spread to noninfested areas of the country. A recent U.S. Forest Service pest risk assessment concerning potential Siberian timber imports evaluated the potential costs to U.S. society of several nonindigenous plant pests (USD A, FS, 1991). The risk assessment estimated that introduction of a single pest, larch canker, could cause direct timber losses of $129 million annually. The same study estimated that a worst-case scenario involving heavy establishment of exotic defoliators in the United States could cost $58 billion. This is a damage estimate of resources that would be lost to established defoliators. While it is possible that damage could be limited (at additional cost) by instituting an eradication program, I. Introduction 11 eradication is deemed unlikely based on the fact that no known established forest pest defoliators have ever been eradicated The initial estimated losses of complying with the rule’s requirements will be offset over time as businesses adapt to new international sources of wood supply. If resource constraints remain constant after this rule is implemented, consumers will purchase a slightly higher volume of domestic wood articles at prices that are slightly higher than those that currently prevail in the U S. market. However, domestic consumers will continue to supplement their wood and wood product purchases with imports whenever the imported price is lower than the domestic price. About 98.8 percent of the total estimated losses displayed in table 1 are attributable to one-time treatment costs for dunnage (including scrap lumber) used to pack various commodities imported into the United States. APHIS anticipates that this loss will be reduced as shipping companies switch to bark-free dunnage materials to avoid Q-40 related treatment costs. Shippers will take precautions to ensure that dunnage is bark-free before commodities are loaded at the foreign port of origin. APHIS maintains that bark-free dunnage material is readily available throughout the world and can be substituted at little or no cost. Therefore, APHIS estimates that the required use of bark-free dunnage will result in a negligible long-term cost increase to shippers in the long term. The Regulatory Flexibility Act (5 U.S.C. 601 et secj.) requires that APHIS specifically consider the economic impact of proposed Q-40 regulations on small entities. The Small Business Administration (SBA) data indicate that about 25,998 domestic entities could be impacted by the proposed restrictions on regulated articles. About 25,769 (99 percent) of these entities are classified as small according to SBA criteria. The estimated $35.2 million gain in producer welfare represents less than 1 percent of combined average annual sales for impacted small entities Therefore, the net impact of proposed Q-40 regulation on small businesses is expected to be minor. 12 /. Introduction II. Purpose and Need The Animal and Plant Health Inspection Service (APHIS) regulates imports under the Federal Plant Pest Act, as amended (7 U.S.C. 1 50aa— 1 50jj), and the Plant Quarantine Act, as amended (7 U.S.C. 151-167), which, among other things, authorize the Secretary of Agriculture to prevent the introduction and dissemination of new plant pests or those not widely distributed throughout the United States. APHIS has been delegated authority to administer these two statutes and has promulgated Foreign Quarantine Regulations (7 CFR 319) that regulate the import of commodities. Until August 23, 1995, there was no regulation specifically governing imported logs, lumber, and other unmanufactured wood articles other than an interim rule covering imports of Monterey pine logs from Chile and Monterey pine and Douglas-fir logs from New Zealand Instead, APHIS relied upon general import procedures that provide for the inspection of imports (including logs, lumber, and unmanufactured wood articles) at the port of entry and for the imposition of quarantine measures and treatment or refusal of the shipment if plant pest species are found. Inspection of logs, lumber, and unmanufactured wood shipments at the port of entry is labor intensive. For large shipments, examining carefully every wood article for potential plant pests is virtually impossible. Consequently, an inspection program alone is inadequate to protect against the introduction of plant pests that may be associated with large shipments of imported wood. Furthermore, the possibility of pest introduction increases if wood imports were to increase. Although there is growing interest in the importation of logs for use in U.S. mills, an actual increase in imports has not yet been fully realized. Because of the damage exotic plant pests have caused U.S. forests and other plant resources in the past and the potential for damage in the future, APHIS believed that the regulation needed to be promulgated. The August 1995 regulation was designed to address improvements needed in the existing system to prevent plant pest risks associated with increased importation of unmanufactured wood articles into the United States. Since August 23, 1995, APHIS has had a regulation in place that specifically governs the importation of logs, lumber, and other unmanufactured wood articles. On June 5, 1997, however, the U.S. District Court for the Northern District of California enjoined the issuance of new permits for the importation of some unfinished nontropical wood articles under the 1995 regulation, pending the correction of deficiencies the court noted in the EIS and the promulgation of the regulation in light of the SEIS. II. Purpose and Need 13 The primary purpose of this SEIS is to fulfill the 1997 ruling of the U.S. District Court for the Northern District of California (see appendix B) relative to the requirements of NEPA. This document provides the public and decisionmaker additional important information, including a better comparison of the alternatives, and responses to issues raised through the public comment process. 14 II. Purpose and Need III. Court Orders A. Introduction In its February 27, 1997, order the U S. District Court for the Northern District of California ruled on the motions for summary judgment (see appendix B). It found that the EIS prepared for the APHIS regulation governing the importation of unmanufactured wood articles did not comply, in part, with NEPA or with the CEQ regulations. This SEIS addresses the court’s specific concerns regarding the inadequacy of the EIS under NEPA. On June 5, 1997, the court ruled on the plaintiffs’ motions for injunctive and declaratory relief (see appendix B). The court’s analysis of the EIS did not establish that the regulation is arbitrary and capricious or contrary to law (see appendix B, p. B-36). However, the court found that the plaintiffs had demonstrated “sufficient likelihood of environmental harm to justify an injunction against the issuance of new permits for the import of non-tropical unfinished wood products” (see appendix B, p. B-38). However, the court allowed “imports to continue under permits that have already been issued” (see appendix B, p. B-39). The court specifically enjoined APHIS from issuing any new permits for importation of unfinished, nontropical wood articles such as — • Monterey pine logs and lumber from Chile and New Zealand, • Douglas-fir logs and lumber from New Zealand, • Temperate hardwoods, and • Logs and lumber imported under the universal options. The injunction is in effect until “APHIS prepares a new Environmental Impact Statement and promulgates regulations governing the importation of unmanufactured wood products” (see appendix B, p. B-39). The June 5, 1997, order also directed the parties to appear before the court on May 15, 1998, to “report the progress in issuing a new EIS” (see appendix B, p. B-39). The following sections explain the three specific areas of the EIS that the court found to be inadequate in its February 27, 1997, order. Chapter IV, Environmental Analysis, addresses the court’s concerns in detail. B. Point 1 — Uncertainty of Efficacy of Combinations of Methods In its February 27, 1997, order the court found that the EIS “assumes without examination that individually ineffective control measures will be effective collectively” (see appendix B, p. B-28). Although the court did not accept the III. Court Orders 15 plaintiffs’ assertion that the “regulations of wood products must entirely prevent the importation of pests,” it did determine that APHIS “may not gloss over the considerable uncertainty about the effectiveness of different mitigation measures. The EIS and the regulations are based on the assumption that the combination of different mitigation measures will compensate for the inadequacies of each” (see appendix B, p. B-17). The court appeared to agree with the plaintiffs that APHIS had failed to cite any studies or documentation for its belief that the combination of sufficient mitigation measures will successfully mitigate the introduction of pests. This documentation was deemed important since APHIS used this belief to justify its selection of its preferred alternative. The court ruled that given the purposes of the EIS are “to foster informed decision-making and promote public participation. Defendant’s [APHIS’] failure to point out the considerable uncertainty surrounding its belief that a combination of measures will be effective renders this portion of the EIS inadequate” (see appendix B, p. B-18). C. Point 2— Omission of Important Information The court found the EIS omits significant information concerning uncertainties expressed in the following areas: • Risk assessments and control measures, • Compliance by exporting countries, and • Human health effects of control efforts. Following is a summary of these specific concerns of the court. 1. Risk Assessments and Control Measures The court found that the “failure of the EIS to discuss in a significant manner the uncertainties about the risks of infestation and the adequacy of control measures skews its portrayal of the risks associated with the preferred alternative. This skewed portrayal limits the usefulness of the EIS to public participation and informed decision-making” (see appendix B, p. B-20). The court found the adequacy of the risk assessments underlying the EIS and regulation was relevant to the adequacy of control measures. The court stated that it is “difficult for the public to assess the regulatory framework proposed in the EIS if it is not informed of the significant uncertainty about the scope of the risk that the regulations seek to contain” (see appendix B, p. B-20). The court cited some of APHIS’ studies, which called for “additional research to fill in significant gaps in knowledge about the efficacy of various control measures” (see appendix B, p. B-20). 16 III. Court Orders 2. Compliance by Exporting Countries 3. Human Health Effects of Control Efforts The court stated that “[t]o a great extent, the preferred alternative depends upon self-certification by importers or upon certification by the national governments of exporters” and that APHIS “may not dismiss compliance problems as a simple problem of human honesty lying beyond the scope of the EIS” (see appendix B, p B-20). The court ruled that APHIS’ response in the final EIS to comments about this issue “does not constitute an adequate evaluation of how compliance problems abroad may limit the effectiveness of the preferred alternative” (see appendix B, p B-21). The court agreed with APHIS that “detailed discussion of the human health consequences of eradication efforts can only be conducted in the context of a particular eradication effort” (see appendix B, pp. B-21-B-22). However, the court faulted APHIS for not discussing “the health implications of eradication efforts at all” (see appendix B, p. B-22). The court called for a discussion of the range of human health consequences of pesticide applications comparable to the discussion in the EIS of the range of environmental consequences that can accompany application of pesticides to forests. The court found that this omission “minimizes the potential consequences of looser import restrictions [and] biases the EIS in favor of the preferred alternative” (see appendix B, p. B-22). D. Point 3 — Comparison of the Alternatives The court, in its decision, twice quoted a section of the CEQ regulations to emphasize the importance of a clear comparison of alternatives — • The EIS “should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public” (40 CFR 1502.14) (see appendix B, p. B-27); and • The comparison of the environmental effects of the various alternatives is supposed to be “the heart of the environmental impact statement” (40 CFR 1502.14) (see appendix B, p B-28). The court found that the EIS failed to discuss adequately “the different environmental impacts of the various alternatives” (see appendix B, p. B-28). The court pointed out that differences exist in the — (1) extent to which alternatives rely on the use of methyl bromide, (2) use of different treatments for different kinds of wood from various parts of the world, and (3) effectiveness of different treatment methods against different kinds of threats (see appendix B, pp. B-27-B-28). III. Court Orders 17 The court found that “[rjather than sharply defining the issues and providing a clear basis for choice among the alternatives, the EIS obscures the differences by labeling them all a matter of degree. By downplaying these differences, the EIS minimizes both the environmental drawbacks of the more lenient alternatives and the environmental benefits of some of the stricter alternatives. This distortion impedes both public participation and agency decision-making. The comparison of the environmental impacts of the various alternatives is therefore inadequate” (see appendix B, p. B-28). The following chapter. Environmental Analysis, addresses the three primary concerns of the court: (1) the efficacy of combinations of methods; (2) the important additional information concerning the risk assessment and control measures, the compliance in other countries, and the human health effects of control measures; and (3) the comparison of the alternatives. 18 III. Court Orders 1. Introduction IV. Environmental Analysis A. Point 1 — Efficacy of Combinations of Methods The importation of logs, lumber, and other unmanufactured wood articles presents a risk of inadvertently importing plant pests that may be associated with the imported commodity. Wood and wood articles are subject to infestation by insects, fungi, nematodes, and other plant pests at any time from preharvest through final manufacturing. Measures can be taken to reduce the probability of pest infestation to a negligible level and, thus, maintain the value of the wood product. For example, wood can be grown in plantations where silvicultural techniques and pesticides can be used to increase harvest and reduce pest infestation. Upon harvest, there are many treatments and handling procedures that can be used alone or in combination to rid wood of pests and prevent reinfestation of the wood. Such treatments can include debarking logs to remove surface pests, using pesticides to kill surface pests or wood-boring pests as they emerge, fumigating the logs with a chemical to kill surface and shallow wood pests, and using heat to kill pests on and in the wood. Handling procedures include segregating logs from potential sources of pests and shipping them within a short time of harvest and treatment in order to avoid infestation or reinfestation. Also, by limiting exports to saw quality logs only (that is, logs with no discernible pests associated with them), the probability of having an infested log to begin with is greatly reduced. Each treatment and procedure has its limitations — it may negatively affect certain qualities or the value of the wood, it may not be totally effective against all pests, it may be economically infeasible, or the technology may not exist to apply the treatment practically. Heat treatment (either to raise and maintain the internal temperature of the wood to 71.1 °C for a minimum of 75 minutes or to kiln dry in accordance with the Dry Kiln Operators Manual (USD A, FS, 1991c) is the only treatment acknowledged to be effective against all pests (USDA, APHIS, 1991a and USDA, FS, FPM, 1992b). Even after this treatment is applied, the wood must be segregated from all potential sources of pests to ensure that it is not reinfested. Choosing a set of procedures and treatments that maximize the likelihood of successful exclusion of plant pests is a difficult and complicated decision because it must be effective, practical, and economically feasible. Until recently, the procedure for excluding plant pests associated with imported logs, lumber, and wood articles consisted of inspection at the port of entry by Plant Protection and Quarantine (PPQ) inspectors. The disposition of the commodity was determined by the inspection results. The inspection process IV. Environmental Analysis 19 included verifying the paperwork on the commodity and visually and physically checking the commodity at the port of first arrival for signs of pest infestations. Visual and physical inspection generally required the opening of shipping containers or holds to look for signs of pest infestations. This included looking for signs of bore holes and rot, checking bark that may be present, taking samples, and carrying out any other actions that the inspector deemed as appropriate to confirm the presence or absence of plant pests. Disposition of the commodity included one of four options — (1) if no plant pests were found, the commodity was permitted entry; (2) if plant pests were found, the inspector required treatment as deemed appropriate to eliminate the pest and then the commodity was permitted entry; (3) if the risk of pest introduction could not be mitigated, the inspector refused entry of the wood commodity into the country; or (4) if the risk of pest introduction could not be mitigated, the inspector could have the infested articles destroyed onsite. Historically, the inspection process was considered by most plant pest experts in USDA to be sufficient to minimize plant pests that may have been associated with wood imports. Besides manufactured articles and the Canadian imports, most wood was imported in small shipments. These shipments were primarily tropical hardwoods or lots of specialty woods that posed little threat of pest introduction. The small shipments made it relatively easy to conduct thorough inspections either to confirm or to deny with confidence the presence of plant pests so that the inspectors could take appropriate action. 2. Potential Future As mentioned in chapter 1, the U S. forest products industry has expressed an Imports interest in increasing the amount of logs, lumber, and other unmanufactured wood articles that are imported into the United States. The source of such imports could be from anywhere, but specific interest has been expressed in importing large quantities of larch wood from Siberia, Monterey pine (also known as radiata pine) from Chile, and Monterey pine and Douglas-fir from New Zealand. Exporters from Russia and, especially, Chile and New Zealand are anxious to expand their export markets into the United States. Both Chile and New Zealand have large plantations of Monterey pine, and New Zealand also has large plantings of Douglas-fir that are maturing and ready for harvest. In Russia, the trees available for export are from natural forests rather than plantations. Importation of large quantities of logs, lumber, and other wood articles from trading partners other than Canada would be a major departure from historical import patterns. The magnitude of large individual shipments of logs presents the port inspector with a much more difficult task. In the past, the inspector would have to inspect small shipments of logs or wood articles that could be moved relatively easily and closely observed. Even if the shipment consisted of 20 IV. Environmental Analysis up to 15 or 20 large logs, a comprehensive inspection was possible. The new scenario of potentially large shipments could include individual shipments of hundreds of logs and even shipholds full of logs. The inspector is presented with a formidable task when conducting a physical inspection on a large shipment. No longer does the inspector have relatively easy access to all logs in a shipment. Now the inspector must coordinate the inspection with the heavy equipment operators who are moving and unloading the logs. The time an inspector can spend looking at individual logs will be reduced because of the sheer volume of logs that must be inspected and because logistical problems become much more of an issue. Confidence that the inspection process by itself will be able to either confirm or deny the presence of plant pests is reduced, thus requiring that additional safeguards be implemented. Therefore, APHIS began to study the situation with the purpose of ultimately defining a set of mitigation requirements that would reduce the risk associated with plant pest introductions to a negligible level, without depending solely on the efficacy of inspections of large shipments of logs, lumber, and other wood articles. 3. Risk Assessments and Combinations of Methods The U.S. Forest Service conducted such pest risk assessments for larch logs from Siberia and the Soviet Far East (USD A, FS, 1991a), Monterey pine and Douglas-fir from New Zealand (USDA, FS, 1992a), and Monterey pine, coigue, and tepa from Chile (USDA, FS, 1993a). To conduct each pest risk assessment, the U.S. Forest Service established a team of forest pest specialists. Team members and those advising the team by providing technical information and additional expertise to the team included USDA employees, as well as individuals from academia, private industry, and other government organizations. The team also traveled to the country where it was evaluating pest risk to confer with experts in the country and to verify pest conditions through site visits. In the pest risk assessments conducted, determining the risk posed by pests that might be associated with the importation of wood consisted of two tasks: (1) determining the likelihood that exotic pests could become established in the United States and (2) determining the consequences of any such establishment. Each task was then subdivided into components, and each component was addressed. In systematically approaching the problem of developing effective mitigation measures, APHIS arranged for the U.S. Forest Service to — • conduct pest risk assessments to identify potential pests on imported logs; • estimate their likelihood of establishing self-sustaining, reproductive populations; and • estimate the consequences of their establishment in the United States. IV. Environmental Analysis 21 Four components were evaluated under the first task (to determine the likelihood of an exotic pest becoming established) — (1) the likelihood of a pest organism being on, with, or in the logs at the time of importation; (2) the likelihood of pests surviving in transit and not being detected at the port of entry under then-current quarantine procedures (inspection only); (3) the likelihood of pests encountering environmental conditions in which they could survive and reproduce; and (4) the likelihood of a pest expanding its range beyond the colonized area. The components of the second task (the consequences of establishment) include — (1) the economic impact of pest establishment; (2) the environmental impact of pest establishment; and (3) the social and political influences that could be associated with pest establishment.1 Every component of the pest risk assessment process contains varying degrees of uncertainty because of gaps in the available information. The process, however, includes the extensive use of subject matter experts and, thus, makes every attempt to overcome gaps in scientific information by seeking and using the best professional judgment of experts. Concurrent with the efforts of the team of experts assembled for the U.S. Forest Service-led pest risk assessment for Siberia and the Soviet Far East, APHIS assigned its Methods Development Center in Hoboken, New Jersey, with the task of providing an inventory and analysis of mitigation methods available to be used in developing an import regulation for logs, lumber, and other unmanufactured wood articles (USDA, APHIS, 1991a). The methods identified in the inventory were evaluated for technical efficacy against the organisms found in the pest risk assessment for Siberia and the Soviet Far East (USDA, FS, 1991a). The results of this analysis were used to help define the requirements for the safe import of Russian timber. The analysis noted that seldom were literature citations available that provided scientific evidence that a particular mitigation method was effective against a 1 The social and political impacts were not included in the pest risk assessment for Siberian larch (USDA, FS, 1 991a), but since have been included as a standard portion of the pest risk assessment process. Thus, they were included in the pest risk assessments for New Zealand (USDA, FS, 1992a) and Chile (USDA, FS, 1993a). 22 IV. Environmental Analysis specific pest identified as a potential problem. This is not surprising because worldwide there are literally thousands of potential pest species and it is unreasonable to expect that scientific studies would be conducted on all of them. To obtain such information at this time would entail exorbitant costs in both time and money. Nevertheless, this lack of scientific data results in uncertainty. The degree of Uncertainty, however, can be reduced to a negligible level if the preponderance of evidence indicates that a measure would be effective against similar organisms or has demonstrated effectiveness over a wide variety of organisms. When APHIS experts found that this was the case, the measure was determined to be effective. APHIS then monitors the mitigation methods to ensure they work as expected. Often, the lack of species-specific data in the literature requires the extrapolation of existing data to similar species. Assessments of the efficacy of methods were done according to the site locations that may be occupied by pests, as described by the U S. Forest Service risk assessment team, i.e., efficacy against pests on the outer surface of the log, pests in or under the bark, and pests in the wood. The results of the analysis are summarized in table 4-1. Table 4-1. Efficacy of Mitigation Measures Available for Pests and Pathogens Associated With Russian Timber Imported to the United States1 Pest/Location Methyl bromide Kiln drying Stea m heat Irradiation Debarking Pests on the outer surface Asian gypsy moth/nun moth E E E R E Root/stump insects E E E E E Scale insects E E E R E Flat bugs E E E R E Aphids/wooly adelgids/ Siberian silk moth E E E R E Pathogens R E E R E Pests in or under bark Engraver beetles/weevils E E E R E Pests in the wood Monochamus, Xylotrechus E E E N N Siricidae E E E N N Pathogens R E E N N Wood nematodes R E E N N Legend: E = Effective, N = Not effective, R = Requires research 1 Source: Abstracted from USDA, APHIS, 1991a. IV. Environmental Analysis 23 A similar process to that described for Siberian logs was followed for imported logs from both New Zealand (Orr, 1992) and Chile (Reeves, 1993). That is, organisms that demonstrated the potential for risk in the pest risk assessment were matched with potential mitigation measures that would be effective in developing a safe importation scheme. The three mitigation assessments (USDA, FS, 1991a; Orr, 1992; Reeves, 1993) represent the most current and comprehensive review of the scientific information that is available for forest pests from the respective countries. Those assessments acknowledge that, while the information they contain is believed to be as accurate as possible, gaps in scientific information remain for some organisms known to be, or could potentially become, forest pests. The mitigation measures that resulted from the information in those assessments are believed to be effective against not only pests that were the actual subject of scientific experimentation, but pests similar in biology and habitat preferences to those tested. Because the consequences of introducing a pest or pathogen can be severe, APHIS was cautious in developing the mitigation requirements. Several examples of the deleterious effects that pest or pathogen introductions can have on the forest resources in the United States are provided in the EIS. It is because of experiences with pests, such as the gypsy moth, that APHIS has exercised caution regarding imports proportional to the risk that they pose. In general, when there is a higher level of risk, APHIS adopts more stringent entry requirements for import commodities. The adopted regulation has several requirements that must be met if importing Monterey pine logs from Chile or New Zealand or Douglas-fir logs from New Zealand. The requirements are divided into two stages — (1) requirements to be met prior to entry into the United States, and (2) requirements to be met after entry into the United States. The requirements are summarized in table 4-2. 24 IV. Environmental Analysis Table 4-2. Regulatory Requirements for Imported Logs From Chile or New Zealand Requirements Level of pest risk reduction1 Before shipment for U.S. entry: la Provide heat treatment of logs. (Steps 2 and 3 are not required if this step is taken; move directly to step 4.) Total -OR- l.b. Acquire saw log quality trees. Some or extensive2 -AND- 2. Debark logs within 45 days of timbering. Some or extensive 3. Fumigate logs after debarking and before 45 days. Extensive or total 4. Segregate logs from all other pest sources. Extensive or total Upon U.S. entry: 5 Conduct comprehensive inspection of logs. Some 6 Move logs directly to processing facility, maintaining the segregation from pest sources (initiated in requirement 4, above); heat treat and process logs, and destroy any waste within 60 days of entry Total 1 Some = Some reduction of pest risk expected; Extensive = Extensive reduction (95 percent or more) of pest risk expected; and Total = Total (100 percent or nearly 100 percent) reduction of pest risk expected. 2 Dependent upon any identified pest Before entering the United States, the first requirement is that the wood either must be heat treated or be from saw log quality trees (live, healthy, and apparently free from disease and pests). At the very outset of the importation process, this requirement provides some or extensive pest risk reduction, depending upon the identified pest (see tables 4-3 and 4-4). In other words, by requiring trees that are apparently pest- and disease-free, APHIS has reduced the risk of previously unnoticed pests appearing in the shipments later in the process. The next requirement is that within 45 days, the logs must be debarked (resulting in some or extensive reduction in pest risk against bark beetles, for example) and then fumigated either on board in the ship’s hold or in sealed containers (extensive risk reduction or total reduction against hitchhikers, for example). After fumigation, logs must be segregated from all other pest sources until they have entered the United States and are processed. The segregation of treated logs protects against reinfestation by pests. IV. Environmental Analysis 25 Table 4-3. Raw Logs — Pathogens and Pests vs. Mitigation1 New Zealand United States Pest 45-day limit Saw log quality only Debarking Methyl bromide fumigation PPQ entry requirements Heat process (sawmill) Bark beetles S S E T S T Platypus spp. S S S T S T S/rex/fungus S E S E S T Leptographium S E s E S T Kalotermes S E s T S T Huhu beetles S E s E S T Hitchhikers S S E T S T Unknown pests S S s E S T Legend: S = Some reduction of pest risk expected. E = Extensive reduction (95 percent or more) of pest risk expected. T = Total (1 00 percent or nearly 1 00 percent) reduction of pest risk expected. 1 Source: Orr, 1992 Table 4-4. Raw Logs — Pathogens and Pest vs. Mitigation1 Chile United States Pest 45-day limit Saw log quality only Debarking Methyl bromide fumigation PPQ entry requirements Heat process sawmill Bark insects S S E T S T Siricid wasp S E S T S T Wood-boring insects S E S T S T Hitchhikers S N/A E T S T Termites E E S T S T Diplodia shoot blight N/A S S E S T Needle diseases N/A S E E S T Stains & vascular wilt S s S E N/A T Root & stem rot N/A E S E N/A T Legend: S = Some reduction of pest risk expected. E = Extensive reduction (95 percent or more) of pest risk expected N/A = Not applicable. T = Total (1 (30 percent or nearly 100 percent) reduction of pest risk expected 1 Source: Reeves, 1 993. 26 IV. Environmental Analysis Upon entering the United States, the logs are subject to inspection and then must move directly to a processing facility where they must be heat treated and processed. Any waste from the processing of logs must be destroyed within 60 days of entry. The heat treatment process results in total reduction of pest risk. The requirement that logs be segregated from pest sources is maintained until final processing of the logs is complete. Tables 4-3 and 4-4 demonstrate that the combination of requirements imposed before a shipment of logs from New Zealand or Chile enters the United States will result in a range of extensive to total reduction of the risk that a live exotic pest will remain with the imported logs. By the time all steps are completed (including those to be accomplished in the United States), although some uncertainty remains, the probability of a live pest being present, escaping, and establishing a reproducing population in the United States is negligible because of the complementary mitigation measures and the sequence in which they are applied. The requirements for a universal import permit also include combinations of treatments and/or handling procedures, as identified in table 4-5. The treatments all result in a negligible risk of pest introduction and establishment, and the handling procedures ensure that infestation or reinfestation does not occur after the commodity has been treated. In addition, raw lumber and wood or bark chips from places in Asia that are east of 60° East Longitude and north of the Tropic of Cancer are ineligible for importation. This is because logs, lumber, and other wood articles from this area have been found to be severely infested with numerous pests and reinfestation is highly likely to occur. Table 4-5. Universal Permit Regulatory Requirements for Wood Imports Commodity Requirement Level of pest risk reduction Logs 1. Prior to importation, logs must be debarked. Some or extensive 2. Prior to importation, logs must be heat treated. Total 3. During entire interval between treatment and export, logs must be handled and stored to exclude pest access to logs. Extensive or total Lumber (heat treated or heat treated with 1. Heat treat prior to import. Total moisture reduction) 2. During shipping, lumber must be segregated from other regulated articles. Extensive or total Table 4-5 — continued IV. Environmental Analysis 27 Table 4-5 — continued 1. Risk Assessment and Control Measures Commodity Requirement Level of pest risk reduction Lumber (raw) 1. Lumber must be segregated from other regulated articles. Extensive or total 2. Lumber must be heat treated within 30 days of import and prior to processing. Total Wood chips/bark chips 1. Prior to import, wood chips and bark chips must be fumigated, OR Extensive or total heat treated. Total 2. Wood chips and bark chips must be segregated Extensive or total Legend: Some = Some reduction of pest risk expected Extensive = Extensive reduction (95 percent or more) of pest risk expected Total = Total (100 percent or nearly 100 percent) reduction of pest risk expected APHIS recognizes that uncertainties are inherent when dealing with biological resources. In the face of this uncertainty, APHIS must, and does, make biological decisions based on the best available scientific data while attempting to reduce uncertainty by continually reviewing new information and evaluating the efficacy of new mitigation measures. The wood import regulation will be adjusted to include new or improved methods and strategies for pest exclusion as they become available. B. Point 2— Important Additional Information a. Introduction Many forest pests that occur in other countries do not occur in the United States. APHIS is charged with preventing the introduction and dissemination of exotic plant pests, thereby protecting U S. agricultural and forest resources. In order to protect these resources effectively, it is necessary for APHIS to regulate imports that may harbor pests. APHIS relies on the best available scientific information when developing both regulations and pest exclusion methods. This information comes from many sources, including published information in the scientific literature and the opinion of recognized forest pest experts. Risk assessment is one of the approaches used to summarize the existing knowledge and predict the potential for pests to enter and become established in the United States. Risk assessments systematically identify and characterize the risk associated with the occurrence of an adverse event. As part of this process, risk assessments use 28 IV. Environmental Analysis existing information. Risk assessments were conducted by the U S. Forest Service on the importation of logs from Siberia (USD A, FS, 1991a), New Zealand (USDA, FS, 1992a), and Chile (USDA, FS, 1993a). In developing the regulation governing the importation of logs, lumber, and other unmanufactured wood articles, APHIS relied upon those risk assessments and evaluations of available control measures for forest pests from Siberia (USDA, APHIS, 1991a), New Zealand (Orr, 1992), and Chile (Reeves, 1993). Equally important as summarizing existing knowledge, risk assessments identify information gaps and capture and record uncertainty. Identifying uncertainties associated with any investigation helps define the degree of confidence that accompanies decisions based upon the risk assessment. Uncertainty is a fundamental part of scientific investigation often with more questions being raised by a scientific study than are answered. Because scientific research is based upon probabilities rather than absolutes, uncertainties are inherent to any investigation (Silbergeld, 1991). Throughout the risk assessments (USDA, FS, 1991a, 1992a, and 1993a), as well as the review of control measures for potential pests (USDA, APHIS, 1991a; Orr, 1992; Reeves, 1993), are numerous statements concerning uncertainties and the paucity of information on many potential pests. The EIS (USDA, APHIS, 1994) relied upon the results of the risk assessments, especially information on known forest pests. Less implicit in the EIS was a summary about the uncertainties and data gaps expressed in the risk assessments and the review of the control measures. This section further explains uncertainties regarding the risks of infestation and the adequacy of control measures. b. Uncertainties Regarding Pests Many nonindigenous organisms have the potential to cause damage to U.S. forest resources. The pest risk assessments (USDA, FS, 1991a, 1992a, 1993a) emphasized the known forest pests that occur — or suspected to occur — in the exporting countries. Assessment of the threat that those pests pose to forest resources in the United States was based on the biological information available for each pest. A greater degree of confidence can be given to predicting the likelihood and consequences of establishment for familiar and well-known pests. The pests that can most readily be assessed for their potential to become established in the United States are frequently those pests that have the most information known about them. Knowledge regarding life cycles, interactions with other organisms, and habitat requirements are examples of the kind of information used for assessing whether or not a given organism could become a forest pest in the United States. IV. Environmental Analysis 29 Often, an assessment of pest potential is based on incomplete information. The ability of some pests to damage forest resources may be well documented, but biological information may be lacking. For those organisms, information obtained on similar species can be used to infer the pest potential. If a species has a history of being a forest pest outside the United States, it can be assumed that the species also would be a pest should it be introduced and become established in the United States. Examples of potential forest pathogens for which there is a high degree of uncertainty due to a lack of information are the various species and strains of the fungal genus Ophiostoma. These fungi have been included as potential pathogenic pests on imported logs from New Zealand (USDA, FS, 1992a) and Chile (USDA, FS, 1993a), but there is uncertainty about whether these exotic organisms would be pathogenic if introduced into North America. It is suspected that the vectors for these fungi in Chile are bark beetles and possibly other insects found in beetle galleries (Flarrington, 1988), yet the exact vectors have not been proved (Cielsa, 1988). While the exact fungal vectors are not known, the risk assessment assigns a high probability of establishment for these fungi in the United States. This example shows that the lack of information on a given insect or microorganism and how it could become established does not mean that these pests will be designated as low risk. In fact, lack of knowledge and a less cautious approach may increase the possibility of introducing an unknown virulent pathogen that could become successfully established in the United States and cause unacceptable losses (USDA, FS, 1993a). Other organisms, such as bark beetles (order Coleoptera, family Scolytidae), are known to cause damage to forest resources, but little else may be known about them. Many bark beetles in Asia have yet to be described and classified, and little is known about the life histories and survival requirements for some of these destructive forest pests. Therefore, risk assessments associated with Asian bark beetles must necessarily be made with a high degree of uncertainty. The most difficult organisms to assess for pest potential are those that are not known to be pests in their native habitats, but may become pests if introduced and established in the United States. Because of different ecological relationships in new environments, an introduced species may not behave in the same way as it did in its native habitat. Some pests cause minor damage in their native habitats, but cause devastating effects when introduced outside their native range. Two examples of pest species invading North America include two fungi that have virtually eliminated the American chestnut and drastically reduced the American elm. The fungus, Cryphonectria parasitica , causes chestnut blight. This fungus causes little damage to chestnuts in Asia. However, 50 years after being 30 IV. Environmental Analysis introduced into the eastern United States, the fungus had devastated what was once the dominant tree in eastern North America, the American chestnut. Despite extensive research, no solution has been found that would allow the recovery of chestnuts in North America. Another fungus, Ophiostoma ulmi , is responsible for the drastic reduction in American elm trees and five other elm species that are native to States east of the Great Plains. Native to Europe, this fungus is spread by the European elm bark beetle. Since it was introduced in the United States in the 1 920's, native American bark beetles also have become carriers of the fungus. O. ulmi infestations have spread through the United States and are now found in all 48 contiguous States. Further complicating attempts to combat this pest was a change in O. ulmi virulence once it entered the United States. This indicates the complex and unforseen aspects that can be associated with predicting the risk posed by a given organism. Distinctive life history traits also may influence the damage caused by a forest pest. Unforseen changes in those traits complicate any prediction of how much damage a pest can cause. An example is the gypsy moth ( Lymantra dispar) invasion into the United States. It is believed that the Asian gypsy moth strain poses a greater threat than the European strain because, unlike the European strain female, Asian strain females can fly. This may very well increase the rate at which Asian gypsy moths can spread to forest resources in the United States. In its native range, the Asian strain has a wider plant host range than the European strain. It could be that the Asian strain will also have a wider plant host range than the European strain in the United States. The pest risk assessments conducted for Siberia, Chile, and New Zealand attempted to systematically identify organisms that could potentially become forest pests in the United States. Taken into account was the considerable amount of uncertainty surrounding each organism. For many potential pests, biological information is lacking that would help determine the probability and consequences of establishment. Assessing the risk potential that a given organism could become a forest pest in the United States is then based on known facts, as inferences from the best available information, and on the best professional judgment of recognized experts. c. Uncertainties Regarding Control Method Efficacy Many methods have been developed to eliminate pests from wood. The only treatments acknowledged as effective against all pests are (1) the standard kiln drying schedules for lumber used in the United States (this has not been confirmed for use on logs (USD A, APHIS, 1991a)) and (2) raising and maintaining the internal temperature of all wood articles to at least 71.1 °C for a IV. Environmental Analysis 31 minimum of 75 minutes (USD A, FS, FPM, 1992b). Other treatment methods such as debarking, spraying pesticides, and fumigation are effective against certain pests, but are of limited effectiveness against others. Testing a particular control method for effectiveness against every known or potential pest organism would not be feasible or necessary. Control methods have often first been tested, under controlled conditions, for efficacy against specific pests as well as a wide variety of other organisms. Once it has been accepted that a method is effective against a certain group of pest organisms, those results are widely considered to be applicable against species with similar biologies and habitat requirements. Heat treatment is an example of how a control method is developed and leads to broader application. The early use of heat to treat wood for pests was reported by Snyder (1923), and Snyder and St. George (1924), who found that a kiln- drying schedule was effective against powderpost beetles ( Lyctus spp., family Lyctidae) in lumber. Since then, Ostaff and Cech (1978) have demonstrated that kiln drying effectively controls larvae of the pine sawyer beetle ( Monochamus spp., family Cerambycidae), a beetle that penetrates wood deeper than powderpost beetles. Based on results of limited tests such as these, Ostaff and Shields (1978) broadly concluded that commercial kiln drying would be effective in killing all stages of insect life in wood. Most recently, after reviewing available information, it was determined that heat treatment at 71.1 °C for 75 minutes would effectively eliminate pests from all wood articles (USDA, FS, FPM, 1992b). New control methods are also being developed and tested for effectiveness against a variety of pests. An alternative to kiln drying heat treatment is to treat wood with microwaves, which are ultrahigh frequency waves that elevate the temperature of any material containing moisture. In wood with a low moisture content, resident insects would have a higher moisture content than the surrounding wood and be more susceptible to microwaves. Thomas and White (1959), Hightower et al. (1974), and Burdette (1976) have all reported on various insects that could be controlled by using microwaves to sterilize wood. However, there is uncertainty whether microwaves have a significant effect on eliminating fungi from wood (USDA, APHIS, 1991a). Thus, while proven to be effective against certain pests, the limitations of this method are still being investigated. Because methods are not tested against every pest, there are gaps in scientific data on the efficacy of various mitigation techniques (USDA, APHIS, 1991a). To estimate method efficacy, it is necessary to extrapolate existing data to related species. To obtain information on the efficacy of every method against every potential pest would entail exorbitant costs in both time and money. Decisions 32 IV. Environmental Analysis regarding treatment methods are based on the professional judgment of recognized experts using the best available scientific information. Reliance upon professional judgment is generally recognized as the preferred method to overcome data gaps when it is not possible to obtain the missing data. As forest pest risks and potential mitigative measures are considered, the lack of data in both areas is taken into account (USD A, APHIS, 1991a). The ability to develop strategies to manage, control, or even eradicate those pests becomes more likely as data gaps are filled and knowledge regarding forest pests increases. Generally, when there is a high level of risk, APHIS adopts more stringent entry requirements for commodities. d. Summary Our knowledge of forest pests and the effectiveness of pest control methods used to control pest movement contains data gaps. Some organisms that are known to be forest pests have been investigated to a great extent while much less is known about the biology of others. In addition, some organisms that are not pests in their native habitats may become pests if they are introduced and become established in the United States. In addition, no combination of methods or single method has been tested for effectiveness against all known or potential pests. Because of these uncertainties, developing a definitive list of potential pests and determining the absolute efficacy of pest exclusion methods is impossible. Yet, it is valid to rely upon professional judgment to identify pest organisms and to assume that once a given method effectively controls a given organism, that similar organisms would also be susceptible to that method. The regulation for importing nursery stock, plants, roots, and bulbs in growing media (7 CFR 3 1 9.37—0) is an example of an overlapping combination of pest control methods considered effective against known potential pests. 2. Compliance a. Introduction by Exporting Countries APHIS is the Federal agency responsible for minimizing the risks of plant pest and pathogen introduction and thereby protecting U S. agriculture and forests. Under the authority of the Federal Plant Pest Act, the Plant Quarantine Act, and the Federal Noxious Weed Act, APHIS regulates the importation of plants and plant products to prevent the introduction and spread of plant pests that are new to or not widely distributed within the United States. The regulations, contained in the Code of Federal Regulations, Title 7, chapter III, are critical to the agency’s mission to protect U.S. agriculture. APHIS accomplishes its mission through inspection of cargo and passengers; prevention, monitoring, and control IV. Environmental Analysis 33 programs; cooperative efforts at the international, Federal, State, and local levels; scientific research; and education. The rapid growth in international trade and travel and the reduction of unwarranted trade restrictions in recent years, coupled with the vast geographic areas covered, have resulted in a proportionate expansion of APHIS’ responsibilities. For example, overall exports and imports rose nearly 50 percent and agricultural exports and imports by nearly 30 percent between 1990 and 1995 (GAO, 1997). To meet the challenges presented by such growth, APHIS has increased its number of inspectors by 44 percent, from about 1,800 in 1990 to about 2,600 in 1996 (GAO, 1997). APHIS’ Plant Protection and Quarantine (PPQ) unit has the regulatory authority to inspect both agricultural and nonagricultural products that may carry plant pests. This is done primarily through its Agricultural Quarantine Inspection (AQI) activities. In fiscal year 1996, APHIS spent an estimated $152 million on AQI activities. Recent multilateral trade agreements, such as the North American Free Trade Agreement (NAFTA) and the General Agreement on Tariffs and Trade (GATT), have provisions that have opened trade by dismantling artificial trade barriers, and directly affected APHIS’ inspection activities. For example, both agreements contain provisions on the use of sanitary and phytosanitary (related to animal and plant health) measures to limit the introduction of foreign plant pests and pathogens. Consequently, APHIS is developing science-based pest-risk standards to comply with the agreements. APHIS also is actively involved in developing international pest-risk standards to comply with GATT and NAFTA. These standards form the foundation for changing inspection program procedures, including the frequency and intensity of inspections. These standards will help determine a level of protection appropriate to the risk and will not unnecessarily restrict trade. b. United States Programs APHIS’ approximately 2,600 inspectors with a budget of about $152 million work cooperatively with three other Federal Inspection Services (FIS) agencies — the U.S. Department of Justice’s Immigration and Naturalization Service (INS), the U.S. Treasury Department’s Customs Service (Customs), and the U.S. Department of the Interior’s Fish and Wildlife Service (FWS) — to monitor the entry of cargo and passengers into 172 land and sea ports. Besides cargo inspections, APHIS’ AQI inspectors also are involved in, but not limited to, the review and issuance of certificates for agricultural exports; temporary work assignments away from their normal work location (for more efficient allocation of inspectors on an as needed basis); inspection and approval of 34 IV. Environmental Analysis treatment facilities; cargo fumigation; anti-smuggling activities; investigations, monitoring, and preclearance activities; and training. Because of recent trade agreements and the importance of trade to the U.S. economy, APHIS and its inspectors are working to facilitate the flow of cargo and people into the United States while protecting U.S. public health, agricultural, and biological interests. To help meet its increasing regulatory responsibilities without needless disruption of trade, APHIS has taken the following actions: • Shifting staff and funds away from other programs to the inspection program. While the budget for inspections activities rose by 78 percent and staffing by 44 percent, APHIS’ overall funding has increased by only 20 percent since 1990. • Broadening the range of inspection techniques to more efficiently use its inspection resources. APHIS is increasing the use of detector dogs and x-ray equipment. APHIS is funding research on new x-ray technologies and studying improved sampling techniques and the use of roving inspectors at land borders. Inspectors also are using periodic inspection blitzes — highly intensive inspections of baggage or cargo — in addition to their usual inspections of selected items. For example, if imports arrive from a country where quarantine pests have been detected on cargo in the past, APHIS may conduct inspections on 100 percent of the cargo. This type of inspection may involve notifying the country of origin of increased inspections; charging additional costs to the exporter and importer for inspection; and fumigating the cargo, thereby causing more delay and possibly fines and revocation of permits. The economic ramifications of these actions usually result in more diligent adherence to the import regulation. • Initiating more inspections in the country of origin and using preclearance programs to reduce and focus workloads at entry ports APHIS staff oversees or conducts inspections in the country of origin so that inspectors at U.S. receiving ports only need monitor these cargoes. APHIS’ International Services (IS) unit now has preclearance programs for various commodities in 29 countries. APHIS also has a cargo release program with Mexico to reduce inspections of high- volume, low-risk commodities. • Improving coordination with other FIS agencies (Customs, FWS, and INS). The FIS agencies use Port Quality Improvement Committees to improve port of entry operations and cross-train FIS staff relative to IV. Environmental Analysis 35 APHIS’ inspection needs. APHIS has begun providing computer equipment to 33 maritime ports and 26 airports to link to Customs’ cargo databases, which identify people and vehicles with prior violations. Similarly, APHIS is working to improve linkages with cargo manifest databases to obtain cargo information that identifies shipments for inspections. • Implementing an AQI Results Monitoring Program This program measures the effectiveness of inspections nationwide and identifies those ports of entry with the highest risk relative to pests and diseases entering the United States. The program also identifies pest and disease risks associated with various commodities, their country of origin, and their means of entry. This program will allow APHIS to determine if the number of inspections performed at a given location for a given commodity adequately addresses the risk posed. • Working to improve the reliability of its data systems, such as its Workload Accomplishment Data System. APHIS is consolidating its four PPQ regions into two regions to achieve improved national consistency. APHIS also is conducting program analysis and risk assessments to provide operational assistance to the AQI inspection programs to make improved inspection level and staffing decisions. This will allow APHIS to improve its focus on its more than 50 different inspection methods and technologies in high risk areas. Congress authorizes APHIS to inspect commodities that enter the United States. As mentioned above, certain countries or commodities receive extensive monitoring and inspection before or upon arrival at a U.S. port. During an inspection, any organism found is immediately sent for identification. If APHIS cannot identify the organism at the port of arrival, it is sent immediately to taxonomic specialists, located in various areas of the United States, for identification. This request is considered an urgent interception for immediate classification. Identification is accompanied by an enhanced hazard risk assessment. All cargo is quarantined until the status of the organism can be determined. This risk assessment process (Enhanced Risk Assessment for Determining the Quarantine Status of Exotic Organisms) uses three criteria with weighted risk factors (high, medium, low, unknown) for the amount of information available for each criterion. The first criterion is taxonomy; complete species or subspecies identification is preferred. The second criterion is hazard identification/distribution of the organism, such as whether the organism is known in the United States or is capable of establishment in the United States. The third criterion is agricultural concern: (1) whether or not it is known as an 36 IV. Environmental Analysis agricultural pest or a vector of an agricultural pest) and (2) whether or not the organism potentially is capable of establishment in the United States. This information is used to determine the quarantine status of the organism and quarantine action for the commodity on which it was found. A detailed description of this risk assessment and quarantine status decision table can be found in appendix C. If the organism is found on the quarantine list, an Emergency Action Notification document (PPQ Form 523) is prepared and is sent to the shipper, consignee, and sometimes the country of origin’s agricultural official. This document describes, in part, the organism, type of cargo, shipper, consignee or owner, country of origin, foreign phytosanitary permit number, and remedial action taken. This document is used to notify importers and/or shippers of the options available to them for commodities that are in quarantine status. The options available for the quarantined cargo are (1) destroy (by appropriate means), (2) fumigate (or use other treatment methods appropriate to kill the organism), or (3) refuse entry and return to the country of origin. The consequences of receiving a PPQ Form 523 are additional costs to the shipper, importer, and/or consignee because of delays, added treatment costs, and new shipping charges. Often, these costs exceed the profit margin of the commodity for the shipper or importer. From an economic standpoint, therefore, it is very undesirable to be cited with a PPQ Form 523. Besides the inspection of regulated foreign logs, lumber, and other wood articles at the U S. port of entry, APHIS requires Compliance Agreements with all wood processing facilities in the United States that process regulated foreign wood articles. The Compliance Agreement is a document among APHIS, the affected State agricultural or forestry official (State cooperators), and the appropriate facility official. The types of foreign wood processing facilities are as follows: dry kiln mill, sawmill, veneer mill, paper mill, particle board mill, and power plant. Certain requirements in the Compliance Agreement are common to all regulated foreign logs, lumber, and other unmanufactured wood articles processing facilities. Specific requirements to each type of regulated foreign wood processing facility are found in appendix C. Requirements common to all regulated foreign wood processing facilities are as follows: 1 . Imported wood will remain segregated from other wood articles until processing is completed. 2. Imported wood will move to the facility in the most direct route as soon as reasonably possible with no diversions. 3. The facility will notify the PPQ work unit office, specified in the agreement, of the arrival of shipments at the processing facility. IV. Environmental Analysis 37 4. Any pallets, dunnage, or other solid wood packing material used in the shipment of regulated wood must be mitigated, at least to the degree required for the regulated article, in addition to meeting the entry requirements for solid wood packing material. 5. Foreign lumber must be treated appropriately according to the wood type and end-product use. This action will be specific to the lumber processing facility. See appendix C for details. 6. The processing facility will keep a record or log book listing imported wood type (genus and species), quantity, origin (country), the importer of record or facility from which it was received, and a treatment completion date. This record will be made available upon request by APHIS and/or State cooperators. 7. APHIS inspectors and/or State cooperators will be permitted access to the lumber processing facility premises to monitor compliance. 8. The PPQ work unit office specified in the agreement shall be notified as soon as possible, but within 24 hours, when conditions exist that violate or compromise the conditions of this agreement. 9. The facility must request changes to the agreement in writing and submit the request to APHIS. 10. The agreement may be canceled, orally or in writing, by the APHIS inspector supervising its enforcement whenever the inspector finds that the facility, its employees, or agents have failed to comply with its conditions. The elements in the Compliance Agreement are additional safeguards to prevent an exotic pest from escaping and establishing itself in the United States. The checks and notification system in place give the operators of the processing facility a local APHIS and/or State cooperator contact in the event of unexpected conditions. This safeguard, therefore, permits feedback at the Federal and State agricultural/forestry level. c. Programs in Exporting Countries As mentioned in the introduction of this section, APHIS certifies preclearance programs for some commodities in certain countries. These preclearance programs allow for more efficient use of port inspectors at the U S. port of entry. Training for these programs is conducted by APHIS, PPQ personnel. All certifications are revokable if problems are observed Preclearance of a 38 IV. Environmental Analysis commodity does not mean that there is no inspection at the U S. port of entry. Preclearance means that a less rigorous inspection may be possible, but does not require that a less rigorous inspection be conducted. APHIS has inspected the treatment facilities and inspection infrastructure in each country and determined that they are capable of preventing the introduction of exotic pests into the United States. Regulated foreign logs, lumber, and other unmanufactured wood articles are inspected at the U S. port of entry for compliance with the treatment methods and other requirements of the Foreign Quarantine Regulations. As needed, APHIS port inspectors may be temporarily detailed to a foreign country to facilitate inspection and compliance. APHIS has procedures and guidelines to ensure that treatment facilities in other countries meet our requirements for importation of regulated articles to prevent the dissemination or establishment of plant pests not known to exist in the United States. The following information is from a bulletin on APHIS Requirements for Treatment Facilities for Log Importation into the United States. It is an example of the heat treatment facility requirements. Countries and/or foreign companies must apply to APHIS for approval of facilities for heat treatment, fumigation, and cold treatment. Required information that must be submitted to the agency for approval of a heat treatment facility is as follows: 1 . Detailed construction plans (including dimensions) and/or blueprints. 2. Detailed description of safeguards to be applied at the facility to maintain segregation between the treated and untreated logs. It is the responsibility of the facility to ensure that the treated articles are stored, handled, or safeguarded in a manner that prevents any infestation by plant pests after treatment, during storage and shipping. 3. Information on the make and model of the temperature recorder that will be used along with its accuracy and the number of sensors it monitors. The size of the heat treatment facility will determine the minimum number of temperature sensors needed. The recording system must meet the following specifications. a. The recording system (platinum resistance temperature sensors and recorder) shall have an overall accuracy of +/-1.0 °F in the range of 155 °F to 170 °F with a resolution of 0.2 °F. b. The recording system shall be capable of repeatability in the range of 155 °F to 170 °F. The temperature for each sensor shall be recorded at least once every 2 minutes during the 75-minute process to monitor potential temperature fluctuations and cold spots. IV. Environmental Analysis 39 c. An automatic temperature recording and controlling system shall record the temperature and duration of the treatment and generate a status report on the temperature settings throughout the treatment process. d. If a strip chart recorder is used, the chart scale on the recorder shall be graduated with the minor scale marks every 0.1 of a degree in the range of 155 °F to 162 °F. The chart shall be of sufficient length to display the entire treatment. e. Platinum resistance temperature sensors shall be such that the conditions of the environment will not affect their performance. The sensing unit shall be located within the first inch of the sensor. The size of the log will determine the appropriate length of the sensor sheath, which shall be 0.25 inches (6.4 mm) diameter or less. f. The recording system shall be capable of individual channel calibration and continuous automatic monitoring of time and temperatures throughout the treatment process. g. Each recorder shall be connected to a commercial line conditioner to provide protection from voltage irregularity, noise reduction, and harmonic distortion. 4. Electrical wiring throughout the facility must meet local and international safety code requirements. Earth grounding of all electrical wiring is required. Wires located near machinery or in a high traffic area must be shielded in a metal conduit to prevent damage. 5. The treatment chamber must be designed to allow for the installation of numerous portable probes throughout the load. These probes will be positioned at the direction of APHIS personnel during the certification or precertification process. APHIS evaluates each proposal separately and informs the applicant of any modifications needed. When the plans and blueprints are finally approved, the applicant can initiate construction or renovation. When construction is 50 percent to 70 percent completed, the applicant may (at his or her option) request an onsite inspection by USDA. Upon completion, each facility must submit a proposed operating plan and photographs. The results of two successful trial runs (consisting of the printouts of internal log temperatures during treatment) must also be submitted. 40 IV. Environmental Analysis At this time, APHIS sends an inspector to physically inspect the facility and officially monitor two additional test runs using debarked logs. The internal temperature of the logs is monitored during the treatment using thermocouples or thermistor probes drilled to the center of several logs. The minimum treatment temperature of 160 °F (71. 1 °C) must be reached in the centers of the logs before the 75-minute treatment is considered to have begun. If the two complete test runs meet APHIS’ requirements, a Certificate of Approval is issued. At that point, the inspectors from the Ministry of Agriculture/Forestry of the respective country will be responsible for monitoring treatments and issuing a Phytosanitary Certificate or other mutually agreed upon document to accompany each individual shipment of logs. In addition, a Cooperative Service Agreement (CSA) is required between APHIS and the treatment facility in the exporting country (cooperator). The CSA is a written document that describes the commodity-specific work plan and the responsibilities of the cooperator and APHIS. Under the CSA, the APHIS inspector(s) has free access to inspect and examine the physical records, observe facility operations, and provide training as needed. Under the CSA, the cooperator will (1) deposit sufficient monies to cover salaries and other expenses for all APHIS personnel needed to perform work as described in the work plan under this agreement; (2) obtain host country permits or licenses, as required, so that APHIS personnel can have free access to facility locations; and (3) will not certify for shipment to the United States infested shipments if quarantine pests are found. A detailed CSA form can be found in appendix C. Post-entry inspection of logs is still conducted at the U S. port of entry by PPQ port inspectors. Failure to comply with required treatment conditions will result in loss of importation license for at least 1 year and/or civil penalties. No new permit will be issued to an applicant who has had a permit withdrawn in the last 12 months. CSA’s are not granted to applicants in countries that do not have the physical infrastructure to ensure compliance under these requirements. In the interest of facilitating trade with the United States, two countries (New Zealand and Chile) have incorporated APHIS’ unmanufactured wood article importation requirements, 7 CFR 319, into their governmental protocols and procedures. The New Zealand Ministry of Forestry has incorporated into its procedural manuals used by the New Zealand forest industry specific processing requirements related to logs, raw lumber, and heat-treated lumber as set by the APHIS regulation in 7 CFR 3 19.40-5. The New Zealand Ministry of Forestry ensures United States importation requirements are met through preshipment port inspections (leading to an import certificate) and by training industry site IV. Environmental Analysis 41 inspectors on U S. procedures for products not requiring an import certificate, eg., kiln-dried lumber. The New Zealand Ministry of Forestry regularly audits New Zealand companies on their compliance with U.S. unmanu-factured wood production requirements. These audits include examination of records maintained by exporters relating to the age of logs, debarking operations, the concentration of anti-sap stain chemicals applied, and the fumigation of each consignment. The Chilean Agricultural and Livestock Service (“SAG”) has world-wide recognition in pest management programs that affect exported wood products. Chile has developed a coordinated program with the private sector to deal with phytosanitary problems in an efficient way. The cooperation is with the Controladora de Plagas Forestales S.A., a corporation created by the forestry industry to prevent pest outbreaks in forest resources. Most wood products from Chile that are imported into the United States are in the form of sawn kiln-dried lumber. This lumber is processed under the requirements stipulated by APHIS. A small percentage of Chilean wood is imported into the United States as logs. However, as of late 1997, Chilean exporters of unmanufactured wood products are heat treating logs, as described in 7 CFR 3 1 9, destined for the United States. d. Risk of Noncompliance Risks associated with noncompliance with the Federal Quarantine Regulations have been addressed by APHIS (60 FR 27669-27670, May 25, 1995). It is APHIS’ position that noncompliance with these or other regulations increases the risk of importing a potentially damaging pest to the United States. It is also the agency’s position that the risks or costs of getting caught must be sufficiently high to provide a strong deterrent for noncompliance. Therefore, APHIS continues to enforce its regulatory activities with great diligence and scrutiny. In Fiscal Year (FY) 1996, APHIS handled 632 cases involving violations of the Plant Protection and Quarantine (PPQ) regulations promulgated under the authority of the Federal Plant Pest Act (FPPA), as amended, and the Plant Quarantine Act, as amended (USDA, APHIS, M&B, 1996). Of this total, 598 cases were closed during FY 1996. Most of the alleged violations (72 percent) were resolved through payment of civil penalties by stipulation agreement between APHIS and the violators. Resolution of the cases also was achieved, in part, either by APHIS’ issuance of a Letter of Warning to the alleged violator, by issuance of a Decision and Order by an Administrative Law Judge (ALJ) (after the filing of a formal administrative complaint by the Administrator of APHIS), by criminal prosecutions, or by closure with no penalty. 42 IV. Environmental Analysis In FY 1996, Investigative and Enforcement Services (IES) collected $71,490 in civil penalties from stipulation agreements, and ALJ’s assessed $48,512 in civil penalties in their Decisions and Orders. From FY 1994 through FY 1996, IES offered stipulations to resolve approximately 1,600 cases and ALJ’s issued approximately 250 Decisions and Orders. In cases involving cargo violations, it is more time-efficient to issue a stipulation than to pursue formal administrative action. When the case is not flagrant and when the pest risk is contained, IES issues stipulations to first-time violators. For second-time or flagrant violations, the case is referred to USDA’s Office of the General Counsel to file an administrative complaint or to refer to the appropriate U S. attorney’s office for criminal prosecution (USDA, APHIS, M&B, 1996). Therefore, APHIS keeps importers and shippers informed of the penalties for filing inaccurate or fraudulent documents or failure to meet the regulatory requirements of 7 CFR Part 319. The importer or shipper could be subject to civil penalties, criminal fines, jail sentences, and loss of revenue due to APHIS’ rejection of commodities, permit applications, and/or compliance agreements. A major tool for APHIS concerning noncompliance of unmanufactured wood articles is the agency’s authority either to refuse the wood articles, require that the wood articles be treated by fumigation or heat, or require that the entire cargo be destroyed. The logistics of destroying a shipment of logs is immense and impractical. The more realistic action would be to deny off-loading of the cargo or in situ treatment of the cargo before off-loading. Either of these options is costly to the shipping line and exporter, who must assume all costs for delays and treatments. The daily cost of having a ship delayed in port because of noncompliance would soon exceed the value of the wood article cargo itself. Revocation of a permit or compliance agreement is for a minimum of 1 year — a length of time that would be very costly for an importer or shipper not to be allowed to import wood articles into the U S. market. In addition to these penalties brought by APHIS, the importer or shipper may be liable for other legal actions brought by individuals or groups. Self-certification or preclearance programs, such as the one for Chilean fruits and vegetables, have been successful in the past when it is clear to all parties that their best interests are served by accurate and reliable certification. Accuracy of these programs is tested at the U S. port of entry. Fraudulent documents or certifications may conflict with the stated requirement on the APHIS import permit or other supporting documents at the port of entry. Spot inspections for plant pests or evidence of required treatment will aid in document verification. As mentioned above, the consequences to the importer or shipper are substantial. IV. Environmental Analysis 43 APHIS is determined to demonstrate that the use of fraudulent documents is not worth the risk (USDA, APHIS, M&B, 1996). APHIS is aware that certain countries are considered high crime in areas of international trade because of fraudulent activities outside of official channels (60 FR 27669-37670, May 25, 1995). The reason for this high crime label varies for each country. Regardless, APHIS takes particular care in enforcing regulatory requirements with regard to importation of regulated articles from these high crime countries. APHIS, along with other Federal agencies and international governments, is actively participating in an effort to identify and reduce the level of high crime in international trade. APHIS believes that the requirements for the importation of logs, lumber, and other unmanufactured wood articles, under 7 CFR Part 319, protect the United States from the importation of plant pests. APHIS also believes that the agency’s strict and vigorous enforcement of the regulation and the subsequent penalties will deter noncompliance of 7 CFR Part 3 19 by importers or shippers (USDA, APHIS, M&B, 1996). 3. Human Health Effects of Control and Eradication Efforts a. Introduction This section discusses how the efforts to control or eradicate an introduced plant pest may impact human health. It explains the planning and environmental processes that APHIS follows when an exotic plant pest is detected in the United States and how human health issues are considered. The possible actions (types of programs and program treatments) that APHIS can take against plant pests and how they may impact human health are discussed. Also, potential impacts that could occur because of actions taken or not taken, as well as documented cases of plant pest introductions and their possible human health impacts are reviewed. The potential impacts to human health that may result from treatments required by the wood import regulation were discussed in detail in the EIS (USDA, APHIS, 1994) and will not be repeated here. Effects on human health that may result from control or eradication efforts or no action following an exotic plant pest introduction occur from several sources — • chemicals or biologicals that may be used as control agents or disinfectants for control programs, • actions inherent in programs that require mechanical removal and destruction of trees or fruits, or • the various environmental impacts or behavioral effects of the invading pests themselves. In addition, having an exotic pest present in the United States may lead countries importing our products to require additional treatment (usually fumigations) of 44 IV. Environmental Analysis products being exported from the United States, often resulting in increased use of methyl bromide or other pesticides, which could have direct or indirect human health impacts. Factors that may influence the impact or the extent of effect to human health from control efforts include — • the specific pest that is introduced and its potential for movement and establishment, • the pesticide or treatment required to control the pest, • the type of application or treatment that would be appropriate, • the extent of the infestation, • the location of the infestation, • the type of program delivery available, and • the degree of success of the program. Because it would be impossible to predict the specific programs and treatments that APHIS may implement, this discussion must be of a general nature. Each program would be dependent upon many factors, including the specific pest and risk potential, the location, and available treatment options. There are thousands of plant pests, some known and others unknown, that could potentially be introduced through importation of wood articles. Some may be benign, while others may pose grave risks. Because eradication programs would have to be tailored to specific conditions, it is extremely difficult, if not impossible, to predict precise impacts to human health. Site-specific analyses are provided on potential impacts to human health and environmental resources for eradication programs through environmental assessments. However, general impacts to human health can be determined based on pest eradication effects and likely future treatment methods, as discussed below. b. Human Health Effects From Past Plant Pest Introductions in the United States To understand the potential for human health impacts following a plant pest introduction, two examples are provided of exotic plant pest introductions into the United States that have resulted in control or eradication efforts that had the potential to impact human health. The first example is the introduction and establishment of the gypsy moth in some regions of the United States. Although the European strain was introduced intentionally by an entomologist in the 1860's, the Asian strain has been introduced inadvertently from transport ships. While introductions of the Asian strain are believed to have been successfully eradicated thus far, both strains have the potential to become established. Indeed, the European strain has become established in much of the northeastern United States. Therefore, APHIS and its IV. Environmental Analysis 45 State cooperators have undertaken control or eradication efforts when either strain is detected outside the generally infested northeastern United States. As indicated in the Human Health Risk Assessment (USD A, FS and APHIS, 1995b) that supports the environmental impact statement for gypsy moth management (USDA, FS and APHIS, 1995a), effects on humans, either the public or workers, may result from treatments to control or eradicate the various life stages of the moth, or from the moth itself. Insecticides that may be used include Bacillus thuringiensis var. kurstaki ( Btk ), diflubenzuron, Gypchek® (gypsy moth nucleopolyhedrosis virus), DDVP (dichlorvos), or the mating disruptor disparlure. Possible effects on humans that may occur due to the use of the biological insecticides Btk or Gypchek® include irritation of the skin, eyes, or respiratory tract. Exposure to DDVP, while unlikely because of its use in traps, may cause enzyme inhibition. Exposure to high levels of diflubenzuron is known to have effects on the blood and may induce methemoglobinemia, which reduces transport of oxygen in the blood. Disparlure, a pheromone that causes mating disruption, while not causing any direct human health effects, is suspected to persist for extremely long periods in the human body, all the while acting as an attractant to adult male moths. This is reported to be a considerable nuisance (personal communication from Abbott and Rubin, 1997). On the other hand, human exposure to the larval stages of gypsy moths has resulted in rashes and other skin reactions, especially in children or other individuals who spend a substantial amount of time outside (USD A, FS and APHIS, 1995a and 1995b). Another example of an introduced exotic plant pest is the Asian long-homed beetle, which most likely entered the United States (New York) before 1995 in a shipment that contained dunnage. The program to control this pest requires cutting and destroying all infested trees; pesticide applications generally are not a part of the program. Therefore, the potential impacts to human health from control efforts would result more from incidents occurring during the mechanical removal and destruction of the trees, which in this case involved chipping and burning of the cut trees. Potential impacts to people from an operation to remove trees could include accidents involving the vehicles used in transport of the workers, downed trees, or chips. In addition, workers could be at risk of injury from the machinery used to chip the wood. Both workers and the general public, if the operation is not properly supervised, may incur injury from falling trees or limbs. Although burning of trees or the chips normally would be a consideration in an assessment of human health due to exposure to the combustion products, in this case the facility was an electric generating plant, which produces a clean burn (personal communication from Goodman, 1997). Open burning did not occur. Should open burning be necessary, then both workers and the general public may be exposed to the resulting combustion products, as well as potential risks from a controlled fire that somehow may get out of control. The only other impacts to human health may be from the damage 46 IV. Environmental Analysis caused by the insect itself. In this case, any damage caused by the beetle that predisposed the trees or tree limbs to falling could be considered to have a possible impact on human health. c. Planning Process and Environmental Analysis In the case of an inadvertent plant pest introduction, APHIS determines if eradication or containment of the pest is feasible. When eradication or containment is feasible, APHIS develops a management plan designed specifically to respond to the individual case. Because the type of program implemented by the agency or its cooperators may influence the degree of impact to human health, an integral part of the planning process includes a NEPA analysis that, among other considerations, analyzes site-specific human health issues. The NEPA analysis, including any risk assessments that support the environmental impact statement or the environmental assessment, provides information to assist APHIS in determining the best approach to respond to the pest introduction while protecting human health. If human health impacts are a concern, and sufficient control can be achieved with a less ambitious or less environmentally damaging alternative with less impact to human health, APHIS may elect to address an infestation with a less aggressive suppression program rather than an eradication program. The level of effort and degree of intervention for a suppression program may be less than that for an eradication program in the short term. The level of trapping may be lower, and the amount of pesticide applied over a specified area within a certain timeframe may be less, thereby lessening the amount of pesticide available in the environment for contact by humans. On the other hand, it may be necessary for a suppression program to continue indefinitely, resulting in possibly greater cumulative effects. Although human health issues are always taken into consideration before implementing a program, APHIS analyzes and evaluates many issues that must be weighed in balance. An exotic plant pest introduction into the United States imposes a responsibility on APHIS to eradicate or control the pest, if possible, to prevent harm to or destruction of agricultural products. Under these circumstances, it is not only human health issues, but the specific requirements dictated by legal authorities and the type of pest that affects many aspects of program delivery. Depending on the pest, the threat of establishment, the potential for agricultural and economic harm, and the feasibility of treatment, APHIS may respond to an infestation in one of several ways, ranging from no action, to suppression, to eradication. If the pest is not causing immediate damage or is causing damage in a discrete area that can be contained, and is highly unlikely to become established (that is, the pest is introduced in a region that is inhospitable to its continuing life cycle, and it is not likely to be transported to a hospitable area), or if treatment is infeasible, APHIS may determine that treatments are unnecessary and respond with no action. If, on the IV. Environmental Analysis 47 other hand, there is the potential to cause immediate or long-term harm, (that is, there is some risk of the pest adapting, reproducing, and becoming environmentally or economically damaging), APHIS may attempt to prevent its spread or relocation in a suppression program or to eliminate it in an eradication program. Within each of these programs, a variety of treatments and methods are available to eradicate or control plant pests, with varying degrees of potential impact on human health. These include trapping and monitoring, regulatory quarantines, pesticide applications, biological controls, sterile insect releases, physical controls (such as cut, chip, and bum), silvicultural practices, and combinations of these treatments and methods. For the most part, programs conducted by APHIS to eradicate exotic plant pest species require some application of pesticides. Although it is generally the chemical pesticides that elicit concern from the public, some minor health effects also have been attributed to biological pesticides (e g., skin, eye, and respiratory tract irritation from Btk). For some pests, removal and destruction of the host plants are necessary. This treatment carries with it the risks inherent in using mechanical equipment and moving large loads. Trapping and monitoring require program workers to travel over great distances and sometimes in rough terrain, and also to handle traps containing pesticides. In addition, pesticides in the traps contribute to the chance for exposure to the public. Programs geared toward suppression of an infestation may be able to rely more on the options that do not require pesticides. Regulatory quarantines, biological control organisms, sterile insect releases, and silvicultural practices generally do not result in substantial human health impacts. Unfortunately, not all treatment options are effective against or applicable to every pest species. For infestations that are treated with pesticides, applications are generally made using one or more of the following methods — • ground equipment for broadcast spraying, directed spot spraying, or soil drenches; • aerial broadcast or spot application; or • fumigation of soil or the affected commodity. The application method affects not only the number and type of individuals (workers or the public) who may be exposed, but also the possible routes of exposure. Aerial broadcast applications generally provide a greater opportunity for direct human exposure via dermal or inhalation routes. However, the concentration of the pesticide at any one place may be less than an exposure to, for example, a soil drench, which would likely result in a more limited dermal exposure (except, perhaps, in children), but at a higher concentration. Using ground rather than aerial equipment generally permits a more accurate 48 IV. Environmental Analysis application and generally avoids contamination of crops (unless they are the targets), backyard gardens, and water resources. d. Potential Pesticide Use A pest eradication or control program could involve the use of a variety of pesticides, which have varying degrees of toxicity to humans. Chemical insecticides, fungicides, herbicides, and miticides, as well as biological pesticides or attractants and biological control organisms, are included in the arsenal of agents available for use. The type of program, location of infestation, and biology of the specific pest dictate the most effective control agent, as well as the type of application that is likely to be used. Before program implementation, an analysis of human health (and other) impacts would be performed to determine if and how the program would proceed, and what, if any, mitigation measures should be taken to lessen impacts. Individuals who may be inadvertently exposed to pesticides that are used to control or eradicate an introduced plant pest, will likely demonstrate a range of sensitivities to the effects of exposure. For the most part, public or worker exposures that are likely to occur from pesticide applications used to control or eradicate plant pests will result in negligible, or at least very low, risks of adverse effects. This is reasonable since pesticide registrations are granted based upon studies that determine mitigable risk to workers and the public. The information on application methods, rates, target plants or organisms, and potential hazards to avoid is included in the label for the product. However, APHIS does not rely on the assumption that every application in every program will proceed as expected and, therefore, prepares or uses currently available human health risk assessments to define risks under typical and extreme circumstances, including accidental. Even so, some individuals with multiple chemical sensitivity are uncharacteristically sensitive to many foreign substances, including some pesticides, and may respond with a variety of adverse effects (respiratory, neurologic, digestive, allergic) to even extremely low levels of exposure. Generally speaking, the risk values that are derived cannot quantitatively consider this extreme circumstance, but the factors applied to risk values attempt to accommodate this uncertainty. A number of risk assessments have been prepared for programs that use pesticides that also might be used for forest protection programs. Therefore, APHIS is aware of any potential human health risks from these pesticides. Some risk assessments were prepared specifically for programs that could be implemented as a result of a pest introduction from logs, lumber, or other unmanufactured wood articles (i.e., gypsy moth). Other risk assessments, even though they were prepared for other programs, include human health risk information for pesticides that could be used in programs against forest pests. IV. Environmental Analysis 49 For example, insecticides for which human health risk assessments are available include — • Btk, diflubenzuron, Gypchek®, disparlure (technically, disparlure is not an insecticide, but is a chemical used to disrupt mating of gypsy moths), and dichlorvos for the gypsy moth management program (USDA, FS and APHIS, 1995b); • malathion (and malathion bait), diazinon, chlorpyrifos, fenthion, and methyl bromide for the Medfly eradication program (USDA, APHIS, 1993); • malathion, azinphos-methyl, diflubenzuron, methyl parathion, chlorpyrifos, and propoxur for the boll weevil cooperative control program (USDA, APHIS, 1991b); • diflubenzuron, malathion, carbaryl, and acephate for the grasshopper cooperative management program (USDA, APHIS, 1996); • acephate, Bacillus thuringiensis , carbaryl, and malathion (plus diesel oil and kerosene carriers) for the western spruce budworm management program in Washington and Oregon (USDA, FS, 1989a); • chlorpyrifos and lindane for a southern pine beetle suppression program (USDA, FS, 1987b); • acephate, carbaryl, chlorpyrifos, diazinon, dimethoate, dormant oil, fenvalerate, malathion, potassium salts of fatty acids, for nursery pest management programs for the U S. Forest Service (USDA, FS, 1989b, 1992c, 1993b, 1993d, 1994a); and • acephate, azinphos-methyl, Bacillus thuringiensis, bifenthrin, chlorpyrifos, esfenvalerate, lindane, and permethrin for seed orchard management programs for the U S. Forest Service (USDA, FS, 1995a, 1995b). Furthermore, the U S. Forest Service has prepared many documents that provide comprehensive toxicology and environmental fate information on many of the pesticides that would likely be used in a forest pest management program (USDA, FS, 1984, 1986a, 1986b, 1987b, 1989c). 50 IV. Environmental Analysis Fungicides for which human health risks have been analyzed include • banrot, benomyl, captan, chlorothalonil, copper sulfate, DCNA, dodine, ethazol, maneb, metalaxyl, thiram, and triadimefon for nursery pest management programs for the U S. Forest Service (USDA, FS, 1989b, 1992c, 1993b, 1993d, 1994a, 1994b); • boron compounds, chlorothalonil, and propiconazole for seed orchard management programs for the U S. Forest Service (USDA, FS, 1995a, 1995b); and • iprodione, mancozeb with thiophanate-methyl, propiconazole, and thiophanate-methyl to supplement the multiregional final environmental impact statement for nursery pest management (USDA, FS, 1994c). In addition, risk assessments have been prepared for a number of herbicides. Some examples of available risk assessments on herbicides include — • Vanquish (USDA, FS, 1995c); • triclopyr (USDA, FS, 1996a); • glyphosate (USDA, FS, 1996b); • hexazinone (USDA, FS, 1997); • amitrole, atrazine, 2,4-D, dicamba, glyphosate, hexazinone, picloram, and tebuthiuron for controlling noxious weeds and poisonous plants (USDA, FS, 1988a); • bifenox, 2,4-D, DCPA, dicamba, diphenamid, glyphosate, napropamide, oxyfluorfen, sethoxydim, and simazine for nursery pest management (USDA, FS, 1989b, 1992c, 1993b, 1993d, 1994b); • asulam, atrazine, 2,4-D, dalapon, dicamba, fosamine ammonium, glyphosate, hexazinone, picloram, simazine, and triclopyr, plus the contaminants 2-butoxyethanol and 1,4-dioxane, for vegetation management for reforestation (USDA, FS, 1988b, 1991b); and • many of those previously mentioned plus bromacil, 2,4-DP, diuron, and possible carriers diesel oil and kerosene for an EIS for managing competing and unwanted vegetation (USDA, FS, 1988c). IV. Environmental Analysis 51 The likelihood of these herbicides being used for pest control is minimal because of the low probability of viable plant material being introduced on imported logs, lumber, and other unmanufactured wood articles. Although human health risk assessments have been prepared for this vast array of pesticides, including insecticides, fungicides, and herbicides, these all have been prepared in association with a specific program describing treatment methods and program delivery, as well as possible deviations from standard operating procedures. The human health risks that were determined for workers and the general public resulted from analyses of typical applications, and also from extreme circumstances, including imprudent handling or accidents. The potential risk to human health ranged from negligible to highly unlikely; the possible effects ranged from none or minor effects, such as skin irritation, to adverse or frank effects, such as kidney damage or cancer. However, both the degree of risk and the extent of effects are so highly dependent on the specifics of the program that foretelling these details prior to defining a program is not possible. Despite this extensive list of pesticide risk assessments, if an introduced plant pest is one that is not known to APHIS or the U S. plant protection community, information may be insufficient to develop a management plan. Under these circumstances, it may be necessary to engage in new research to develop a strategy, pesticide, or control agent that is capable of controlling the plant pest. This could result in efforts ranging from experimental applications of known or newly developed pesticides, to release of biological control agents, to methods development for new pesticides or biological control agents that could affect human health. If the initial eradication program is not successful and the pest either establishes itself or translocates to other areas, it may lead to continuing program activities with increases in pesticide applications, as well as potential involvement of the public or agricultural community in treatment efforts. This could lead to uncontrolled pesticide applications or applications that are duplicated because of lack of communication between individuals. Either of these situations has the potential to increase the level of pesticides in the environment and affect human health. e. Pest Characteristics That Potentially Affect Human Health A plant pest’s ability to move and become established may affect the type of program and the aggressiveness of the program delivery, and thereby potentially affect human health. An exotic pest accompanying wood or wood articles entering the United States is likely to be detected at the port of entry, at which point action would be taken. Either the shipment is returned, or the ship and/or its contents are treated, generally by fumigation using methyl bromide. Under 52 IV. Environmental Analysis these circumstances, it generally would be workers (such as inspectors, applicators, dockworkers, and truckers) who may be directly affected. If care is not taken to contain the fumigant, other individuals immediately surrounding the treatment area may be exposed. Indirect global effects from methyl bromide use have been previously discussed (USD A, APHIS, 1994). Should preentry mitigation and inspection at the port of entry fail to detect or eliminate a plant pest, it is possible that the pest could be released locally. Local infestations generally can be treated and contained with the implementation of regulatory quarantines, although this is always dependent on the specific plant pest. Pesticides may be used, sometimes along with sterile insect releases. However, if the pest still persists, it could move or be transferred from its release site to other areas, States, or regions, possibly leading to other pockets of infestation. If the small infestations are not controlled, an extensive infestation could occur, possibly leading to the establishment of the plant pest. Human health impacts could result from program actions, or may come from the plant pest itself. As mentioned previously, some life stages of the gypsy moth have been shown to produce skin irritation in humans, particularly in children (USDA, FS and APHIS, 1995b). Another factor that affects the degree of impact to human health is the location and extent of the infestation of the introduced plant pest. Treatments may occur in very localized areas where fewer people may be exposed or over a broad area where greater numbers of people may be exposed. Treatments may be conducted at the port of entry, in remote areas, or in highly populated residential or recreational areas. Although residents and recreationists are notified when treatments are scheduled to occur, there is still the opportunity for exposure. It may be necessary to apply treatments over schools, hospitals, or other sensitive areas, or in areas occupied by sensitive individuals. In addition, applications may be on crops, near backyard gardens, water resources, or recreational areas, whereby individuals may be exposed through ingestion of contaminated food articles or water or through skin contact with contaminated surfaces. Applications may occur at night or during the day, which could affect different groups of individuals. f. Potential Pest Introductions From Imported Logs, Lumber, and Other Unmanufactured Wood Articles According to the pest risk assessments for Siberia and the Soviet Far East (USDA, FS, 1991a), New Zealand (USDA, FS, 1992a), and Chile (USDA, FS, 1993a), the plant pests that may present the most risk of introduction from imports of logs, lumber, and other unmanufactured wood articles include Asian gypsy moth and nun moth, pine wood nematodes, larch canker, spruce bark beetle, and Annosus root disease from Siberia, and drywood termite, root disease IV. Environmental Analysis 53 fungus, pinhole borers, huhu beetle, and a woodwasp/wood decay fungus from New Zealand. Prior to implementation of the wood import regulation, numerous types of insects and several species of fungi had been found on shipments of Monterey pine logs from New Zealand (USDA, FS, 1992a). Although most of the organisms from New Zealand were detected on logs that had not been treated, some organisms (an aphid, a spider, and mites) were found on logs that had been fumigated. (These may have been domestic organisms that were attracted to the wood after it arrived in the United States, but that is not certain.) Because the regulatory requirements are so stringent for wood articles imported from Siberia and the Soviet Far East, the largest volume of imports is likely to come from New Zealand and Chile. It may be possible to treat some plant pests, such as termites, with pesticides in soil drenches, if the infestations are small and localized. Other plant pests could be treated with aerial or ground applications of pesticides. For the most part, public health would not be affected by small operations unless the treatments were required in residential or recreational areas. Even under these circumstances, program workers provide notification of treatment schedules to individuals, such as residents or recreationists who may be impacted by pesticide applications. Health of workers applying the pesticides or the fumigant could be affected if proper procedures are not followed. However, program workers are required to adhere to standard operating procedures and follow all label directions, which serve to mitigate potential impact to themselves, as well as to the potentially exposed public. Overall use of methyl bromide will not be increased because its production and importation are limited by the Montreal Protocol and the Clean Air Act, which identify methyl bromide as an ozone depletor. Any increase in AQI use of methyl bromide would result in a decrease of other uses. For the most part, it is not feasible to control wood-boring pests (e g., wood wasps, long-horned beetles, and deep wood fungi) using pesticides. For a large portion of its life, the woodborer is deep inside the wood where pesticides cannot reach. Unfortunately, many beetles, besides causing physical damage to trees by boring or egg laying, also act as vectors for tree diseases, such as fungi, bacteria, or viruses. If these diseases were to become dispersed over large areas, the options for controlling them with pesticides are severely limited. The appropriate treatment, in a number of these situations, would be removal and destruction of the trees. The methods used to destroy the trees after they were cut would likely be chipping and/or burning. The impacts to humans from the cutting, removal, and destruction of the infested trees would be similar to those discussed above in the Asian long-horned beetle example. It is possible that an exotic plant pest may be introduced on imported logs, lumber, or other unmanufactured wood articles. Consideration of the human 54 IV. Environmental Analysis 1. Introduction health impacts from control or eradication efforts, or the lack of such efforts in response to a plant pest introduction, is an important component of a thorough evaluation of risks to human health. Because many factors enter into the determination of impacts to workers or the general public from control programs that may be required due to an inadvertent plant pest introduction, it is impossible to predict exact human health consequences. However, as an integral part of any program, a NEPA analysis is prepared that describes potential risks to human health and other resources. C. Point 3 — Comparison of the Alternatives The U S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), is charged with preventing the introduction and dissemination of exotic animal and plant pests and pathogens in the United States for the purpose of protecting its agricultural, aquacultural, and forest resources. One of the ways APHIS accomplishes its mission is through regulating imports, such as agricultural items and plant-related materials, that may harbor plant pests. In response to increasing concern regarding the introduction of exotic plant pests, APHIS promulgated a regulation to eliminate any significant plant pest risks presented by the importation of logs, lumber, and other unmanufactured wood articles into the United States. As part of the NEPA process and as a result of the scoping process, APHIS identified and considered six alternatives to decrease the probability of the pest establishment in U.S. forests: Alternative 1 — No Action Alternative 2 — Proposed Regulation Alternative 3 — Prohibit Untreated Wood Except Packing Material Alternative 4 — Prohibit Untreated Wood Alternative 5 — Prohibit Unmanufactured Wood Except Packing Material Alternative 6 — Prohibit Unmanufactured Wood These six alternatives represent a full range of reasonable alternatives, as required by NEPA. Table 4-6 provides an overview of the types of wood articles that would be regulated under each of the six alternatives. The alternatives are then explained in more detail in the subsections of this introduction. Table 4-6. Ability to import Various Types of Wood Commodities Under Each of the Six Alternatives Type of commodity 1 2 Alternative 3 4 5 6 Untreated wood Yes Conditionally No No Yes No Unmanufactured wood Yes Conditionally No No No No Packing material Yes Conditionally Yes Conditionally Yes No IV. Environmental Analysis 55 a. Alternative 1 — No Action The no action alternative allows importation of logs, lumber, and other unmanufactured wood articles to continue as it did prior to the regulation published on May 25, 1995. Under these conditions, APHIS has the authority to inspect, require treatment, or refuse entry (or destroy) any wood article shown by inspection to be harboring plant pests. Under this alternative, importers are not required to treat wood articles. However, if an importer decides to treat wood articles, there are no restrictions regarding the types of pesticides that can be used. Therefore, if the importer chooses, pesticides that are banned in the United States could be used to treat wood articles. Under the no action alternative, APHIS would continue to discourage the importation of wood articles from Siberia, based on the results of a recent risk assessment (USDA, FS, 1991a), but APHIS would allow entry of these articles contingent on inspection. The remaining five alternatives considered in the EIS all restrict, to varying degrees, the importation of logs, lumber, and other unmanufactured wood articles except from Canada and the Mexican states that border the United States. Alternatives 2 through 6 allow imports from these areas with an accompanying importer document or certificate that verifies the origin of the articles and certifies that they have not moved outside these areas. Alternatives 2, 4, and 6 restrict importation of unmanufactured wood articles and wood packing materials. Because these alternatives cover all wood articles, including packing materials, they would best prevent plant pest introduction. Alternatives 3 and 5 restrict the importation of unmanufactured and/or untreated wood articles, but do not require treatment of wood packing materials. Because these alternatives exempt packing materials from regulation, they are less protective than alternatives 2, 4, and 6. b. Alternative 2 — Proposed Regulation (Preferred Alternative) Alternative 2, the preferred alternative, allows importation of unmanufactured wood articles (as defined in table 4-7) that meet certain conditions, as described below: • A permit must either be issued by Plant Protection and Quarantine, APHIS, for the importation of a regulated article prior to its arrival at a U.S. port, as specified in tables 4-8 or 4-9, or must meet the requirements of a general permit as outlined in the wood import regulation and summarized in table 4-10. • An import document or certificate must accompany every shipment of regulated articles verifying that the conditions of the APHIS wood import regulation have been met. The only exceptions to this 56 IV. Environmental Analysis requirement are set forth in sections 319.40-2 and 319.40-3 of the regulation. • At the time of arrival, all regulated articles are subject to inspection to ensure that the shipments comply with the requirements and that no plant pests of concern are present. If upon inspection any signs of plant pests are found or if the inspector finds that the requirements for importation and entry have not been met, the inspector has two options. The inspector either can refuse entry of the regulated article into the United States or can require safeguards or pest mitigation measures, such as treatment or destruction of the commodity (usually by incineration), that would minimize the risk of plant pest introductions. c. Alternative 3 — Prohibit Untreated Wood Except Packing Material There are only two differences between this alternative and the preferred alternative. The first difference is that this alternative would not permit importation of any untreated logs, lumber, or other unmanufactured wood articles (except from Canada and Mexican states that border the United States). The second difference is that, under this alternative, all packing materials would be exempted from treatments. This would include loose wood packing materials, such as excelsior, sawdust, and wood shavings, as well as solid wood packing materials including, but not limited to, dunnage, crating, pallets, blocks, drums, cases, and skids. See tables 4-8, 4-9, and 4-10 for more specific permit requirements for alternative 3. d. Alternative 4 — Prohibit Untreated Wood Alternative 4, like alternative 3, prohibits the importation of any untreated logs, lumber, and other unmanufactured wood articles (except from Canada and Mexican states that border the United States). Unlike alternative 3, this alternative requires the treatment of wood packing materials. These treatments would consist of heat treatment and application of insecticides and fungicides registered by the U S. EPA. See tables 4-8, 4-9, and 4-10 for more specific permit requirements for alternative 4. e. Alternative 5 — Prohibit Unmanufactured Wood Excep-t Packing Material Alternative 5 prohibits the importation of any unmanufactured wood articles (except from Canada and Mexican states that border the United States). This alternative, however, does not regulate packing materials. IV. Environmental Analysis 57 f. Alternative 6 — Prohibit Unmanufactured Wood Alternative 6, which is the most restrictive of imports, prohibits the importation of any unmanufactured wood articles (except from Canada and Mexican states that border the United States). It is similar to alternative 5 except that all wooden packing materials also would be prohibited. Table 4-7. Alternative 2: Key Aspects of Subpart 40 Definition of Regulated Articles Regulated articles include — • Logs • Lumber • Whole trees (nonpropagative) • Bark • Cork • Pickets • Stakes • Shingles • Laths • Any cut tree or portion of a tree not solely consisting of leaves, flowers, fruit, buds, or seeds • Solid wood packing materials • Humus • Wood for composting • Litter • Painted raw wood products • Hog fuel • Sawdust • Excelsior • Wood chips • Wood mulch • Wood shavings The above articles must be unprocessed or have received primary processing only. Primary processing includes — • Cleaning (removal of • Spraying with fungicide or insecticide soil, limbs, foliage) • Fumigation • Debarking • Rough sawing • Rough shaping Table 4-8. Requirements for Specified Articles Applicable alternative Article Requirement 2 Bamboo timber • Timber, if completely dry, is eligible for import. • Timber may be imported into Guam and Northern Mariana Islands. 2, 3, 4 Radiata pine logs and/or lumber from Chile or New Zealand and Douglas-fir logs and/or lumber from New Zealand • Wood must be from live, healthy trees which are apparently free from pests. • Logs must be debarked and fumigated within 45 days of felling and prior to arrival in the United States, and logs must be in the same sealed container or hold on a ship as fumigation occurred. Table 4-8 — continued 58 IV. Environmental Analysis Table 4-8 — continued Applicable alternative Article Requirement • During shipment, no other regulated articles (except solid wood packing materials for raw lumber) are permitted in the same holds or sealed containers with logs/raw lumber, unless the other regulated articles have been heat treated or fumigated. • Upon arrival, logs must be kept segregated from other regulated articles and moved to a processing facility operating under an APHIS compliance agreement as swiftly and directly as reasonably possible after arrival. • All logs or products from logs must be heat treated or heat treated with moisture reduction within 60 days of their release from the port of first arrival; raw lumber from imported logs must be treated within 30 days of release from port of first arrival. • All products and waste from processed logs must be burned or heat treated or receive other processing that will destroy any plant pest that may be associated with it. • Sawdust, wood chips, and waste are prohibited for composting or use as mulch unless articles are fumigated or heat treated. Prior to treatment, such items may be moved only in an enclosed truck and only to another facility operating under a compliance agreement. 2 Tropical hardwood • Eligible for importation, logs and lumber (debarked) 2, 3, 4 Tropical hardwood • Must be fumigated prior to importation, logs (not debarked) 2 Tropical hardwood • Eligible for importation if in lots of 15 or fewer logs logs (not debarked, (except not into Hawaii, Puerto Rico, or the Virgin small lots) Islands). 2, 3, 4 Temperate • Must be fumigated. However, wood from places in hardwood logs and Asia east of 60° East Longitude and north of the lumber T ropic of Cancer is ineligible for import unless permitted under universal importation requirements. 2 Articles associated • Can only be imported to continental United States, with only tropical climate pests • Must not be imported to any tropical or subtropical areas of the United States as specified on permit. IV. Environmental Analysis 59 Table 4-9. Universal Importation Requirements Applicable alternative Article Requirement 2, 3, 4 2, 3, 4 2, 3, 4 2, 3, 4 Logs (softwood) • Prior to importation, they must be debarked and heat treated. Lumber (heat treated or heat treated with moisture reduction) Lumber (raw) Wood chips/ bark chips • During the entire interval between treatment and export, logs must be handled and stored to exclude pest access to them. • During shipment, lumber must be segregated from all other regulated articles (except solid wood packing materials) in separate holds or separate sealed containers unless all regulated articles also have been heat treated (either with or without moisture reduction). • Lumber on a vessel's deck must be in a sealed container unless it has been heat treated with moisture reduction. • The treatment used must be stated in the importer document or permanently marked on each piece of lumber. • Any raw lumber (including associated solid wood packing material) from those places in Asia that are east of 60° East Longitude and north of the T ropic of Cancer is ineligible for import. • No other regulated article other than packing materials may be on the same means of conveyance with raw lumber unless the raw lumber and other regulated articles are in separate holds or separate sealed containers. • Raw lumber on a vessel's deck must be in sealed containers. • All raw lumber imported must be consigned to a facility operating under an APHIS compliance agreement, must be heat treated (either with or without moisture reduction) within 30 days of import, and must be heat treated prior to any processing. • Wood or bark chips from Asian countries that are wholly or partially east of 60° East Longitude and north of the T ropic of Cancer are ineligible for import. • The importer document must certify that the chips are from live, healthy tropical species of plantation-grown trees grown in the tropics or have been fumigated with methyl bromide or have been heat treated. • Must be free from rot or accompanied by importer document certifying fumigation with methyl bromide or heat treatment. Table 4-9 — continued 60 IV. Environmental Analysis Table 4-9 — continued Applicable alternative Article Requirement • During shipment, no other regulated articles other than solid wood packing materials are permitted in holds or sealed containers with chips. • Chips on a vessel's deck must be in a sealed container (certain specified exceptions are permitted). • All imported chips must be consigned to a facility operating under an APHIS compliance agreement and must be burned, heat treated, or processed within 30 days of arrival at the facility. 2, 3, 4 Wood imported for mulch, humus, compost, and litter • Prior to importation, must be fumigated or heat treated. 2 Cork bark • Must be free of rot. 3,4 Cork bark • Must be fumigated or heat treated. Table 4-10. Requirements for General Permits Applicable alternative Article Requirement 2, 3, 4 Articles from Canada and Mexico • If from Mexico, they must be from a state adjacent to the United States. • Must be accompanied by importer document stating the origin of the articles is Canada or border states of Mexico and the articles have not been moved outside of this area. • Cannot be from subfamily Aurantioideae, Rutoideae, or Toddalioideae of family Rutaceae. 2, 4 Solid wood packing materials (free of bark, used with nonregulated articles) • Must be totally free of bark. • Must be apparently free of live plant pests. 2, 4 Solid wood packing materials (free of bark, used with regulated articles) • Must be totally free of bark. • Must be apparently free of live plant pests. 2, 4 Solid wood packing materials (not free of bark) • Must be certified as heat treated, fumigated, or treated with preservatives. Table 4-10— continued IV. Environmental Analysis 61 Table 4-10 — continued 2. Summary of Pest Prevention Methods Applicable alternative Article Requirement 2,4 Loose wood • Must be dry. packing materials (in use or imported as cargo) 2 Bamboo timber • Must be free of leaves and seeds. • Must be sawn or split lengthwise. • Must be dried. 2 Articles previously • Must present negligible pest risk (e g., sea drift issued wood). specific permits APHIS has identified a number of methods that could be used either alone or in combination to prevent the introduction of plant pests to the United States. These prevention methods are briefly explained and then discussed relative to a hypothetical example to demonstrate how they could be applied under the various alternatives. A more complete discussion of these methods, their application, and risks is contained in this SEIS in chapter IV, sections A and B, and in the EIS in chapter III, section G. a. Permitting and Certification Establishing a comprehensive yet workable permitting system is an effective step to prevent pest introductions. A permitting system is used to identify, track, and follow up on imported items. It informs inspectors of the contents of the shipments, the origin and destination of the items in the shipments, the parties responsible for the shipments, and the treatment and handling of the items in the shipments. Treatment facilities can also be certified to ensure they meet APHIS standards. b. Handling Procedures Upon harvesting and during shipment, numerous handling procedures are available that can be used alone or in combination to minimize plant infestation and reinfestation of wood. These procedures include — • limiting exports to saw quality logs only, which greatly reduces the probability of having infested logs in the first place, • segregating logs from potential sources of pests to prevent the opportunity for an infestation or reinfestation, • shipping wood within a short time of harvest so as to reduce the postharvest time during which wood could become infested, and • treating wood products in order to avoid infestation or reinfestation. 62 IV. Environmental Analysis c. Inspection In addition to verifying the permitting and certification paperwork and checking the paperwork against the shipment to help assure compliance, inspection is the process of visually and physically checking regulated articles for signs of obvious pest infestation at the port of first arrival. The level of inspection can vary from a small sample to 100 percent of a shipment depending upon the articles, country of origin, and other parameters. At least three benefits are gained by the inspection process — • It provides information regarding the success of the permit process. • It provides an opportunity to verify the efficacy of any treatments required prior to entry of the regulated article. • It allows an opportunity to prevent entry of plant pest species into the United States (by treating, destroying, or refusing entry of infested articles) should pests be discovered. Inspection is an effective monitoring tool while also providing some level of pest mitigation. d. Cooperative Efforts APHIS maintains cooperative efforts at the international. Federal, State, and local levels, which involve permitting, compliance, enforcement, and monitoring, as well as scientific research and education. Recent multilateral trade agreements (such as the North American Free Trade Agreement and the General Agreement on Tariffs and Trade) provide for the use of sanitary and phytosanitary (related to animal and plant health) measures and the development of international pest-risk standards in order to limit the introduction of foreign pests and pathogens. e. Debarking Plant pests or indications of their presence are often found in or immediately under the bark of trees. Debarking is the process of removal of bark from logs and other regulated wood articles, such as dunnage. Debarking is usually a mechanical process; however, less sophisticated methods might be used in less- developed countries. f. Fumigation Fumigation is a treatment method that involves using the gaseous phase of a chemical to kill a variety of plant pests found on and within wood and wood articles. While methyl bromide is the most commonly used fumigant, phosphine IV. Environmental Analysis 63 and sulfiiryl fluoride are chemicals that also are approved for fumigation. The process requires the introduction of the fumigant in a gaseous form into a chamber, under a tarp, or in the hold of a ship under controlled conditions. g. Heat Treatment Heat treatment consists of either raising and maintaining the internal temperature of the wood to 71.1 °C for a minimum of 75 minutes or kiln drying in accordance with the Dry Kiln Operators Manual. The methods used involve monitoring core temperatures and may or may not involve moisture reduction in the wood article. h. Pesticide and Preservative Treatments Pesticide and preservative treatments of logs, lumber, and other unmanufactured wood articles involve the application of chemicals to regulated articles to prevent plant pest infestation or reinfestation after other treatments. In some quarantine cases, the treatments are done to eliminate pests that are present. The chemicals may be applied as surface chemical treatments, penetrating dips, or fumigants. i. Enforcement and Monitoring Beyond cooperative and educational efforts, the risks and costs of not complying must be sufficiently high to strongly discourage potential violations of the law and its requirements. APHIS resolved approximately 600 enforcement actions in 1996. APHIS informs importers and shippers of the potential for civil penalties, criminal fines, jail sentences, and loss of revenue associated with filing inaccurate or fraudulent documents or failing to comply with the regulation. Importers and shippers also may be liable for other legal actions brought by other individuals or groups if they fail to comply with the law. Finally, APHIS monitors more closely those commodities which come from countries that are less likely to meet U S. import requirements. Yet, it is realized that even the most strict enforcement cannot completely prevent attempts to violate the law or otherwise circumvent requirements. j. Other Potential Prevention Methods Following are two prevention methods that may have potential future application. Although at this time, because of limitation of equipment, costs, logistics, or damage to wood, they do not currently appear to be practical methods. 64 IV. Environmental Analysis (1) Shipboard Heat Treatment This method involves heat treating logs in the holds aboard ships during their voyage to the United States. The patented design for this method has not yet been built and is therefore not available for further testing. (2) Irradiation Irradiation, either by microwave, gamma, or electron beam irradiation, could be used to kill pests either directly or indirectly by raising the temperature of wood. Further research is being conducted to determine effectiveness, cost, and safety of these irradiation measures. 3. Example Shipment of Wood Products Unmanufactured items: temperate hardwood logs (debarked) softwood lumber wooden pallets (free of bark and used with the lumber) Manufactured items: wooden chairs The following table demonstrates how this particular shipment would be handled under each of the alternatives. Keep in mind that this is only one example and is intended to be neither a comprehensive discussion of each of the prevention methods and its effectiveness nor the exact combination of applications. In order to help the reader better understand how the previous ten pest prevention methods might be used in combinations under each of our six alternatives, the SEIS presents a hypothetical example. A ship from a temperate South American country is arriving at a U.S. port. It has a combination of manufactured and unmanufactured wood articles as follows: IV. Environmental Analysis 65 Table 4-11. Example Shipment of Wood Products Under Each Alternative Alternative Action 1 All of the wood articles in this shipment would be allowed entry into the United States. None of the wood products would require treatment. If, prior to shipping, the importer voluntarily treated the logs, lumber, and/or packing materials, there would be no restrictions on the types of pesticides used, and the importer could use pesticides that are banned in the United States Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests. 2 A permit must be issued by APHIS for the lumber and wooden pallets that are 100% free of bark and the logs prior to their arrival at the U S. port, unless they meet the requirement of a general permit, as outlined in table 4-9. The chairs, as manufactured wood products, would not require a permit. If the logs, lumber, and packing materials have been heat treated, there would be no restrictions on their entry into the United States, providing the importer has an import document or certificate accompanying them that verifies that the conditions of the APHIS regulation have been met. The logs, if segregated during shipment, would be allowed if fumigated. Lumber must be heat treated and kept segregated from other wood products prior to arrival in the United States; in this case no sawmill compliance is needed. Or, if lumber is not heat treated prior to arrival, the lumber must go to a saw mill, having a compliance agreement, within 30 days of arrival and be heat treated. The wooden pallets must be 100% free of bark or heat treated, fumigated, or treated with preservatives. Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests. If plant pests were found by inspectors, APHIS could either refuse entry, require treatment of the entire shipment, or destroy infested articles. 3 All of the logs and lumber would have to be treated. The wooden pallets would not be regulated or require treatment; they could be in the same holds with the treated logs and/or lumber. The chairs would not be regulated Because the packing materials do not require treatment, it is possible that the logs and/or lumber could become infested with plant pests if those plant pests were present on the wooden pallets. Lumber and wood pallets need not be 1 00% free of bark. Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests. If plant pests were found by inspectors, APHIS could either refuse entry, require treatment of the entire shipment, or destroy infested articles. 4 All the articles except the chairs would have to be treated Treatments would probably include heat treatment or fumigation. Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests If plant pests were found by inspectors, APHIS could either refuse entry, require treatment of the entire shipment, or destroy infested articles. 5 The logs and lumber in this shipment would be refused entry because they are unmanufactured wood products. The chairs would be allowed entry, as would the packing materials, which are unregulated. Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests. If plant pests were found by inspectors, APHIS could either refuse entry, require treatment of the entire shipment, or destroy infested articles. Table 4-11 — continued IV. Environmental Analysis 66 Table 4-1 1 — continued Alternative Action 6 All of the wood products, except the chairs, would be refused entry. Upon arrival, the shipment would be subject to inspection to verify the paperwork and search for quarantine pests. If plant pests were found by inspectors, APHIS could either refuse entry, require treatment of the entire shipment, or destroy infested articles. 4. Summary of Environmental Consequences of Alternatives The CEQ regulations implementing NEPA state that alternatives are the heart of an EIS (40 CFR 1502. 14). In order for the public and an agency to make informed decisions regarding the environmental consequences of various alternatives, the alternatives must be distinct and comparable. One of the deficiencies identified by the court in the EIS was an inadequate comparison of alternatives. The court found that APHIS oversimplified the discussion of the environmental consequences of the alternatives and consequently obscured the differences among the environmental impacts of the various alternatives. In order to address this deficiency, the SEIS presents a matrix (fig. 2), which provides a relative ranking of the six alternatives with regard to both their ability to exclude pests and their environmental consequences. The alternative that most effectively excludes pests is ranked as a “1” while the alternative that is least effective at pest exclusion is ranked as a “6.” Similarly, the alternative that causes the least impact within a resource category (such as Human Health) is ranked as a “1” and the alternative with the largest impact in a category is ranked as a “6.” This matrix allows the reader to contrast the alternatives relative to their ability to exclude pests and their environmental consequences. This matrix is not intended to be a quantitative measurement of risk. Uncertain- ties are identified in the matrix and further explained in the following section (5). They can affect, to varying degrees, both the effectiveness and impact severity of the alternatives. Therefore, the rankings are relative and subject to professional judgment. For example, because international trade is dynamic, visualizing or predicting the impacts of new regulatory requirements is not clear-cut. Because the matrix reflects the results of a relative ranking of alternatives and not a numerical measurement, the columns cannot be averaged to provide an overall ranking of the alternatives. The categories are not on equal scales, and the degree of differences among the alternatives within those scales are not equal. IV. Environmental Analysis 67 in y c re o i/i i/> 03 3 CL O 03 -o X CD v! O CD X Q. 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To i o) QJ \ E | E V3 S C/3 S QJ S ! ° C/3 j C/3 j \ >•> re ! $ o J TO i .9 - 1 { H — l LU o s \ i j[^N> Alternative 6 Prohibit Importation of Unmanufactured Wood - Alternative 5 Prohibit Importation of Unmanufactured Wood Except Packing Materials Alternative 4 Prohibit Importation of Untreated Wood CN Alternative 3 Prohibit Importation j of Untreated Wood j Except Packing j Materials „ ... .. _ A in Alternative 2 Wood Import Regulation (Preferred Alternative) CO Alternative 1 No Action CO 3 O 0 c CO Z) 42 in ID 2» >, "O -P* 3 1 g < LU Alternative 6 - - - - v- - - Alternative 5 CN O- Alternative 4 CM CN CN - CN CN CN Alternative 3 CO in in in in in in Alternative 2 CO CO CO CO CO CO Alternative 1 in CD CO CO CD CO CO £ re a) X c re E 3 X to CJ N o w (D re 3 o V) & m 3 CD •*-* re E ID cm in k_ 0) S o re *-> in 03 hmm > ID C o "re o 03 c re o N si u. in o o O in o> o 3 o in ID cm 3 o CL CO ofl LU 68 IV. Environmental Analysis 1 Alternative 2 relies on pest risk assessments to set treatment requirements for imported wood products. Plantation-grown trees present lower plant pest risks, and the adoption of this alternative might encourage the use of plantations, which might decrease the logging of wild forests. If this assumption is true, this matrix, therefore, might understate the protectiveness of alternative 2 for biodiversity. This is discussed further in section 3 of this chapter. 2 There are only five values in this comparison because neither alternative 4 nor 6 uses methyl bromide (MB) for treatment of wood products. 5. Individual Ranking of Environmental Consequences of Alternatives For instance, in any category, an alternative with a ranking of “1” merely indicates that it is the alternative likely to have the smallest environmental impact on that resource area, and the alternative with a ranking of “6” is the one likely to have the largest environmental impact. In addition, not all categories are based on measurable harm (e g., defoliation of X acres of trees or use of Y tons of chemicals), and therefore require the use of best professional judgment. The key value of these comparisons of alternatives is to demonstrate the highest, lowest, and moderate levels of impacts. Whether an alternative that is ranked a “3” for a resource area is in fact superior to an alternative ranked a “4” is subject to interpretation. However, the matrix helps to compare and contrast the alternatives and focus on their relative effectiveness and impacts. Should exotic plant pests be inadvertently introduced into the United States, any programs that APHIS may initiate to eradicate them would include environmental analyses specific to the contemplated program. Those analyses would identify mitigation measures that could be incorporated into the specific program to lessen the impacts on human health and the environment. a. Sources of Uncertainty Some of the major sources of uncertainty surrounding the wood import regulation and the NEPA analysis include — • efficacy of mitigation methods, • source of wood, • size of shipments, • number of shipments, • wood market conditions, • accuracy of risk assessments, • human error, • compliance, • smuggling, and • biological and ecological information. It is important to keep in mind that all predictions of future actions and their potential implications and impacts contain a degree of uncertainty. The uncertainty can be reduced as more information and experience are available. One way to obtain more information regarding the effectiveness of the wood import regulation to exclude pests from the United States would be to monitor the movement of unmanufactured wood articles into the country and assess whether any pests become established as a result of those actions. Such monitoring would be appropriate in light of section 1505.3 of the NEPA implementing regulations. A monitoring system which makes maximum use of IV. Environmental Analysis 69 existing procedures, mechanisms, and protocols would help assess the effectiveness of the regulation. For example, in trying to determine how international markets might respond to regulatory restrictions imposed by alternative 2, we may be confronted with the following questions: Will this lead to less cutting of natural forests? Or more cutting from plantations? Or merely an increase in the price for plantation- grown trees? If the plantations are expanded to meet increased demand, will their expansion involve the cutting of more forests thereby lowering biodiversity or the planting of trees on previously deforested land thereby increasing biodiversity? All of these possibilities are real, but their probabilities are difficult to predict. b. Ability to Exclude Pests It is impossible to precisely predict potential plant pest introduction and establishment from the importation of wood articles into the United States or the consequences of a pest infestation. However, based on past experiences, establishment of exotic plant pests can have devastating consequences on U S. forest health, which in turn affects biodiversity, species composition and survival, and other resources such as recreation areas and historic properties (see chapter 1, B. Historical Perspectives). Pest eradication is costly, both in monetary terms and in potential human and ecological health impacts from the use of some control measures, such as pesticides. While providing a measure of pest control, eradication activities, if even attempted, rarely have been effective either in reversing the damage caused by the establishment of an exotic forest pest or in eradicating an established exotic forest pest. The no action alternative (alternative 1) presents a greater potential for the introduction and establishment of plant pests than the other alternatives. Under alternative 1, importers are not required to treat wood articles, and, if they do treat wood products, they could use pesticides that are banned in the United States. Also, under alternative 1, APHIS could not prohibit timber shipments from countries with a high risk of pest infestation. In fact, these problems prompted the promulgation of the regulation to exclude potential plant pests on wood articles. The other alternatives are ranked based on the comprehensiveness of their restrictions on importation of wood articles. For example, alternative 6, which excludes importation of any unmanufactured wood articles, is the most restrictive and, therefore, appears to be the most protective alternative analyzed in the EIS. Alternatives 4 and 2 are the next most protective because both include restrictions on all types of wood articles. Alternative 4 is more protective than alternative 2 because it prohibits the importation of all untreated wood. Alternative 5 prohibits the importation of all unmanufactured wood products (e g., logs and lumber) but allows unregulated 70 IV. Environmental Analysis entry of wood packing materials, which is a more likely pathway for the introduction of plant pests. Therefore, it is less protective than alternatives 2, 4, and 6. Alternative 3 allows the importation of packing materials and treated wood. It was deemed less effective at excluding pests than alternatives 2, 4, 5, and 6 because of the threat from unregulated packing materials. c. Human Health The potential impacts to human health resulting from each of the alternatives are related to the use of and exposure to pesticides, preservatives, chemicals, and fumigants used to treat wood articles before they are allowed to enter the United States. Human health also could be impacted by control strategies that result in exposure to pesticides (and dangers associated with their application) used to control introduced pests. See the section on Human Health Effects From Past Pest Introductions in the United States (chapter 4, B.3 .b.) for additional discussion. The rankings relative to human health displayed in figure 2 represent two factors that are potential indicators of human health impacts as follows: • First, the use of methyl bromide in metric tons and percent changes in ozone depletion, which were estimated in the EIS and are displayed in table 4-12 below. The estimates ranged from 0 for alternatives 4 and 6, to 8.5 metric tons of methyl bromide for alternative 3. Similarly, the percent change in ozone depletion ranged from -0.000042 for alternatives 4 and 6, to +0.000096 for alternative 3. Methyl bromide use was used as an indicator of potential applications of other treatment chemicals used, such as pesticides and preservatives as well as other chemicals that may be used instead of methyl bromide. Methyl bromide is currently the most commonly used fumigant, and information is available regarding methyl bromide usage. • Second, the “Ability to Exclude Pests” was assumed to be directly correlated with the need to initiate pest control programs in the United States. Associated potential risks are to the public and workers as a result of exposures to pesticides that may be used in any control, management, or eradication programs for introduced pests. IV. Environmental Analysis 71 Table 4-12. Alternatives and Methyl Bromide Use Alternative Ranking Total methyl bromide use (in metric tons)8 Percent change in ozone depletion6 1 3 2.6 0 2 4 5.4 +0.000042 3 5 8.5 +0.000096 4 1 0 -0.000042 5 2 1.7 -0.000012 6 1 0 -0.000042 “ Based on 1990 imports from all sources except Canada and Mexico and imports from New Zealand and Chile. Data for actual methyl bromide use is for alternative 1 (the no action alternative). b Assuming that anthropogenic methyl bromide emissions account for 10 percent of the yearly global ozone loss. Alternatives, such as 6 and 4, that were considered to be the best at excluding pests were assumed to have reduced risks of exposing the U.S. public and applicators to pesticides and their potential associated health risks. Whereas, alternatives 1 and 3, which were considered less effective at excluding pests, were deemed to have higher associated human health risks. The Human Health rankings of the alternatives are the result of using professional judgment to integrate the data on methyl bromide use and ozone depletion with the rankings of each alternative relative to their effectiveness at excluding pests from the United States. For example, alternatives 6 and 4, which were the best at excluding pests (with rankings of 1 and 2 respectively) and used no methyl bromide, were viewed as presenting the least human health risk. Alternative 3, which was determined to be the second worst alternative (with a ranking of 5) relative to pest exclusion and used the most methyl bromide, was judged to have the highest potential risk to human health. Alternative 1 was considered the least effective at excluding pests (ranking of 6) but had a moderate level of methyl bromide use. It was deemed to have the second greatest potential risk to human health because it was so ineffective at excluding pests, and therefore would require the greatest use of pesticides for associated potential control programs in the United States. Alternatives 2 and 5 were judged to be more effective at excluding pests (with relative rankings of 3 and 4 respectively) and used 5.4 and 1.7 tons of methyl bromide respectively. Although alternative 2 used over 3 times the amount of methyl bromide as alternative 5, it was judged to pose slightly less overall risk to human health than alternative 5 because of its greater effectiveness at pest exclusion and lower use of pesticides. 72 IV. Environmental Analysis d. Forest Resources Total forested areas in the United States encompass over 740 million acres or about one-third of the Nation’s total land area. Forested areas within the United States also continue their ranges in Canada and northern Mexico. Approximately 480 million acres of the forested areas are classified as timberland, i.e., it is capable of producing timber and has not been withdrawn from utilization by law. Forest resources are important for many reasons, such as — • water quality and quantity, • air quality, • biodiversity, • timber and wood products, • erosion control, • fish and wildlife habitat, • recreation, • agriculture (fruits and nuts), • medicinal and spiritual use, and • overall quality of life. While it is impossible to say how many plant pests have been or could be imported across national boundaries without becoming established in their new habitat, sufficient historic examples of exotic pests becoming major pests provide information to conclude that introduction of only a few organisms carries considerable risk. Chestnut blight, Dutch elm disease, white pine blister rust, and gypsy moths (see chapter 1, B. Historical Perspective) are a few of the introduced plant pests that have caused ecological and economic disruption in U S. forests. As can be seen in figure 2, the six alternatives considered in the EIS vary in their predicted effectiveness at excluding potential plant pests. The rankings of the effectiveness of each alternative and the discussion above in section b. (Ability to Exclude Pests) provide the basis for the rankings for each alternative relative to its potential impact to forest resources. Therefore, the ranking for each alternative is the same for forest resources as it is for its ability to exclude pests. Potential impacts to forest resources are discussed in detail in the EIS (chapter 4, pages 52-60). Ecological effects of pest introductions could include changes in species composition, deforestation, habitat destruction, degradation of riparian and montane communities, enhanced fire potential due to increased fuel loading, alteration of biogeochemical cycles, and loss of biodiversity. In addition, there likely would be economic impacts from the loss or degradation IV. Environmental Analysis 73 of forest resources due to pest introduction and establishment. These impacts include loss of timber resources, decreased tourism to forests and parks, damage to the fisheries industry from degraded water quality, cost of eradication of the introduced pest, control of forest fires, reforestation costs, and loss of property value. e. Biodiversity Biodiversity could be affected under the alternatives presented in the EIS in two principal ways: through the establishment of an exotic organism in North America and through harvesting of native forests overseas. The rankings presented in the matrix correspond to the ability to exclude pests. Historically, the establishment of nonindigenous organisms has been shown in some cases to clearly reduce biodiversity in the affected ecosystem (OTA, 1993). Alternatives with the most stringent requirements on timber importation are the alternatives that afford the best protection against the establishment of exotic organisms and, therefore, better protect North American biodiversity. The impact to native forests overseas are based on more complicated factors and therefore are more difficult to evaluate. AJtematives that restrict importation of wood articles will decrease the demand for foreign logs and lumber in the United States. This may lead to a decrease in wood harvesting in overseas forests in favor of increased logging ofU.S. forests (USDA, APHIS, 1995). This situation may or may not have a lasting effect on logging in foreign forests since international markets fluctuate for a number of reasons, and the United States is only one of many markets for international timber. As discussed in the EIS (pages 60-62) and noted in figure 2, the alternatives with the most restrictions on timber importation afford the best protection against the establishment of exotic pests and therefore better protect U S. biodiversity. Based on risk assessments conducted by the U.S. Forest Service (USDA, FS, 1991a, 1992a, 1993a), there appears to be a trend indicating that professionally managed plantations provide timber that is usually of a lower plant pest risk than timber harvested from unmanaged stands. If this trend continues, and alternative 2 (which bases importation on pest risk analysis) is adopted, then there would be a tendency to import more timber from plantation-grown trees than from trees harvested from wild forests. Harvesting plantation-grown trees would, under most circumstances, be expected to have less of an effect on biodiversity than the harvesting of forests, unless the naturally occurring forests are routinely cleared to be converted into plantations. Timber harvesting damages forest ecosystems by causing increases in erosion, fire susceptibility, 74 IV. Environmental Analysis and access for farming, for example (TFW, 1990). Plantations generally would not contribute to this problem. Edward Wilson (1992) maintained that in addition to protecting sensitive regions from ecologically unsound exploitation, we must promote sustainable development. Thomas Lovejoy, as chairman of the Tropical Forestry Workshop (TFW, 1990), promoted the philosophy of balancing economic and ecological issues when dealing with tropical forests. Sustainable forestry has the potential to maintain biodiversity, whereas exploitation of timber resources through such measures as slash and bum agriculture is extremely damaging to biodiversity in tropical forests. While none of the alternatives presented in the EIS will require either sustainable forestry or timber exploitation harvest methods, alternative 2 would encourage the use of plantation-grown trees and thus encourage sustainable forestry. f. Ozone (Methyl Bromide Use) Impacts to the ozone layer from the alternatives are directly related to the amounts of methyl bromide used. Methyl bromide is a chemical whose uses include fumigation of wood. It has been demonstrated to contribute to the depletion of the ozone layer, which protects the Earth’s surface from the damaging effects of ultraviolet radiation from the sun. As such, methyl bromide production is regulated by EPA under the Clean Air Act. The United States is currently responsible for approximately 43 percent of the global use and 50 percent of the global production of methyl bromide (FOE, 1992). Table 4-12 displays a rough estimate of the maximum use of methyl bromide for each of the alternatives and the estimated percent change in ozone depletion. As shown in table 4-12, alternatives 4 and 6 use no methyl bromide. Therefore, they would reduce the current baseline. Alternative 5 would also involve methyl bromide reductions relative to the baseline and, therefore, will reduce the percent change in ozone depletion. Alternative 1 (the baseline alternative) would maintain the current baseline, thus resulting in no change in ozone depletion. Alternatives 2 and 3 both are estimated to use more methyl bromide (5.4 and 8.5 metric tons, respectively) than the baseline and will increase the percent change in ozone depletion. Methyl bromide would be used under alternatives 1, 2, 3, and 5 not only to fumigate wood imports but also to fumigate wooden structures in the United States that might be infested by introduced pests. It is important to remember that logs coming from different geographic areas will require different IV. Environmental Analysis 75 treatments and that those treatments will vary depending on the type of wood product under consideration. It is important to note that, under current law, production and importation of methyl bromide into the United States will be terminated on January 1, 2001. Therefore, once existing stocks of methyl bromide in the United States are used, they will not be replenished and methyl bromide use for wood in the United States will eventually cease. Under the Montreal Protocol, the use and production of methyl bromide, however, can continue in those countries that are not considered to be developed. Therefore, methyl bromide use on wood is unlikely to cease, but will be reduced after January 1, 2001, if for no other reason than the fact that it will no longer be available for use domestically. However, even though methyl bromide use may continue overseas, it is unclear if currently available methyl bromide treatments that occur overseas still will be permitted under the wood import regulation. g. Global Climate Change The deforestation of large areas of timberland is thought by many scientists to contribute to increased levels of carbon dioxide (C02), a greenhouse gas, which may result in increased global warming. Deforestation would lead to fewer trees being available to take up C02 during the process of photosynthesis, resulting in higher C02 levels in the atmosphere. Deforestation of large areas may contribute to global climate change, but the extent of logging for the purpose of importation into the United States is unlikely to be a significant factor. In the foreseeable future, the bulk of logs likely to be imported into this country under the wood import regulation will come from plantations, which are then replanted with trees. Logging of forests in Siberia (with 1.6 billion acres of forest (Cheater, 1991)) and Asia would have a great potential for contributing to global climate change because timber operations in these areas usually do not include reforestation. Importation of large quantities of logs and wood articles from these areas is expected to be minimal because of import requirements under the regulation, the high transportation costs associated with their location, and current lack of infrastructure to support massive harvest and treatment of logs. The impacts to global climate change are inversely related to the restrictions on importation of logs. Therefore, those alternatives that are the most restrictive are least likely to cause deforestation of foreign forests in favor of harvest from tree plantations. Alternative 1, therefore, has the greatest potential to cause impacts, and alternative 6 has the least potential to cause impacts. However, none of the alternatives that impose restrictions (alternatives 2 through 6) have a high likelihood of affecting global climate change. 76 IV. Environmental Analysis h. Cultural Resources In promulgating the regulation on importation of logs, lumber, and unmanufactured wood products, APHIS considered the potential effects to cultural resources, as required by the National Historic Preservation Act and other laws and regulations. Protected cultural resources include historic properties, archeological sites, and sites of cultural significance. Effects on cultural resources are tied to the potential for the introduction and establishment of plant pests. Historic buildings can be affected by the removal of plant pests and their droppings. Buildings could require repainting, and landscaping associated with the buildings could have to be removed or replaced after an infestation. Archeological sites could be indirectly affected by a pest infestation. Archeological sites could be exposed by erosion, increased water runoff, or fire. Depending on the type of infestation and its specific effects, all of these might be possible. Sites of cultural significance to Native Americans could also be affected by an infestation. The presence of pests could damage or decrease the aesthetic value of such places. The EIS also looked at the potential for alternatives to affect recreational resources and landscaping. Impacts to these resources also are tied to the introduction and establishment of exotic plant pests, which affect plant foliage and vegetation selection. Areas infested with plant pests are less likely to attract recreational visitors, and those that continue to use areas infested by plant pests are likely to experience diminished recreational satisfaction. This effect is observed each year in areas affected by gypsy moth defoliation. Landscaping is done to achieve a number of goals, including to provide visual, noise, or wind barriers; to provide shade; or create pleasant surroundings. The introduction of exotic plant pests can cause defoliation and reduction in plant health, which diminishes all of these goals as evidenced by the loss of elm trees throughout U S. cities to Dutch elm disease. Whether the potential losses are to recreational or landscaping resources or to historic properties or archeological resources, insect damage or erosion has associated economic and social costs to both the public and private sectors. The alternatives considered in the EIS vary in their predicted effectiveness at excluding potential plant pests. The discussion on pest exclusion, above, provides the basis for the rankings of environmental impacts for cultural resources. IV. Environmental Analysis 77 i. Endangered and Threatened Species The Endangered Species Act requires Federal agencies to determine if their actions are likely to have adverse effects on federally listed threatened or endangered species. APHIS, in consultation with the U.S. Fish and Wildlife Service, determined that the preferred alternative would not have an adverse effect on threatened or endangered species. In fact, the U.S. Fish and Wildlife Service agreed with APHIS that the greatest threat to listed species comes from no action, as the increased importation of wood articles from diverse countries presents a significant risk of plant pest introduction. One of the factors facing native species is the introduction of exotic species, which may outcompete native species. As indicated by their status, listed species are particularly vulnerable. Actions that result in the prevention of the introduction of exotic species in the natural environment protect the listed species. The U.S. Fish and Wildlife Service concluded that the treatment methods outlined in the proposed regulation (alternative 2) do not pose a threat to listed species. In a letter to APHIS (March 15, 1993), the U.S. Fish and Wildlife Service gave four reasons, quoted below, for their concurrence with APHIS’ conclusion that threatened and/or endangered plants or animals would not be adversely affected by the preferred alternative: “1. All chemical treatments will be required to be applied in accordance with established Environmental Protection Agency (EPA) label directions and guidelines. This requirement will apply to such treatments applied overseas as well as in this country. 2. Only compounds registered by EPA for the intended use will be employed for fumigation, topical treatment, or other methods of application. The proposed rule does not offer or specify new compounds or untested procedures. 3. Disposal of unused treatment compounds in the U.S. will be conducted in accordance with established and approved EPA guidelines. 4. Any new compound proposed to be used for wood treatment would be reviewed for environmental risk (including possible impact on listed and proposed species) prior to registration. This office would be allowed the opportunity to comment prior to any such registration ” 78 IV. Environmental Analysis 1. GAO Audit of Agricultural Inspection It should be noted that other countries must follow import requirements under the regulation, and APHIS cannot enforce treatment application restrictions in foreign countries. While APHIS can request that other countries follow its standards, APHIS has no authority to enforce restrictions in foreign countries. The alternatives considered in the EIS vary in their predicted effectiveness at excluding plant pests. The preceding discussion on plant pest exclusion provides the basis for the rankings of environmental impacts for threatened and endangered species. D. Additional Updated Information The U S. General Accounting Office (GAO) conducted a review to assess APHIS’ effectiveness in minimizing the risks to agriculture from pests and diseases entering the United States (GAO, 1997). GAO identified recent developments that could challenge the ability of APHIS’ Agricultural Quarantine Inspection (AQI) program to carry out its mission, reviewed APHIS’ efforts to cope with these developments, and reviewed the effectiveness of the inspection program in keeping pace with workload changes. The report is based on work conducted at APHIS’ headquarters in Washington, DC, two regional offices, and 12 of the 172 ports of entry where APHIS inspectors regularly inspect individuals and goods entering the United States. The Nation’s three busiest ports of entry were included in the 12 examined by GAO. The GAO report cited areas of concern regarding APHIS’ need to (1) maintain minimum inspection standards in terms of the methods used to select samples from shipments chosen for inspection; (2) improve reliable workload data; (3) integrate a risk assessment factor into staffing allocation models; and (4) evaluate and assign inspection resources on a national basis as opposed to a regional basis. APHIS concurred with the recommendations and defined ongoing efforts to ensure inspection consistency and policy compliance by (1) targeting resources on higher-risk cargo, (2) establishing AQI specialist positions and port risk management teams to improve data quality, and (3) enhancing risk assessments, customer service, and the processing of passenger and cargo inspections. APHIS’ inspection workload has increased dramatically since 1990 because of growth in imports and exports, increased travel, and increased smuggling. Policy changes have exacerbated workload demands by increasing pressure to expedite the processing of passengers and cargo into the United States. APHIS has made a number of changes to its inspection program to respond to the demands of its growing workload. The agency shifted funds and staff away from other programs to the inspection program, broadened the range of IV. Environmental Analysis 79 inspection techniques, and stepped up efforts to coordinate with the other Federal Inspection Service (FIS) agencies. APHIS’ funding and staffing levels for AQI activities have increased substantially by approximately 78 percent and 44 percent, respectively, from fiscal year 1990 to fiscal year 1996, strengthening the Nation’s “first line of defense” against exotic pests and diseases. At the same time, according to USDA’s Assistant Secretary for Marketing and Regulatory Programs, APHIS’ effectiveness in the rapid detection of and response to new pest invasions has been compromised due to reduced funding and staffing allocations for domestic plant protection programs. The viability of U.S. agriculture, the Assistant Secretary observed, can only be preserved by maintaining an integrated safeguarding system that maintains an optimal balance of authorities, resources, and technologies (USDA, MRP, 1997). Based on its own needs survey, which corresponded largely with findings contained in the GAO report, APHIS has taken several steps to make better use of its inspection resources. For example, to supplement the normal practice of performing visual inspections of selected cargo and baggage, APHIS has significantly expanded the use of alternative inspection practices, such as detector dogs and x-ray equipment. In addition, inspectors are periodically using inspection blitzes — highly intensive inspections of baggage or cargo — to augment their visual inspection of selected items. APHIS also is working with other FIS agencies to maximize inspection activities. AQI is an important, but not the sole, component of APHIS’ system for safeguarding plant and animal resources from exotic pests and diseases. Maximum effectiveness is achieved only when program components such as foreign source intervention, smuggling intervention, exotic plant pest detection, exotic pest incursion management, preclearance inspection, permit decisions, quarantine treatment, detection survey and eradication, and point of entry inspection (AQI) are combined into a comprehensive safeguarding system. This integration is essential to the reduction of pest risk to a negligible level. As such, AQI policies and procedures are best understood and implemented within this context. AQI is the cornerstone to preventing the establishment of exotic pests and diseases in the United States. This program consists of more than 50 different inspection methods and technologies designed to prevent exotic plant and animal pests and diseases from entering and becoming established in the United States. The very nature of the program, which requires performing AQI inspections at more than 100 different ports of entry located throughout the United States and in foreign countries, considers national, regional, and local resources. Conditions such as climate, local agricultural production and host 80 IV. Environmental Analysis susceptibility, secondary movement of international travelers, and continuously changing international trade and travel priorities have serious impacts on resources. National allocations of workforce to regions are based on qualitative assessments of risk. The Workload Accomplishment Data System (WADS) and AQI Results Monitoring Program will increase APHIS’ ability to quantify those risks. APHIS is currently developing science-based pest-risk standards to comply with international trade agreements. These standards, based on risk assessments, form the foundation for changing inspection program procedures, including the frequency and intensity of inspections. In addition, APHIS has identified points of entry requiring additional staffing and is committed to staffing new points of entry as they arise. In view of APHIS’ role in preventing the introduction of plant pests, an ongoing need for a comprehensive inspection program is evident. APHIS continues to conduct risk analyses on both commodities and pathways that could provide a means for harmful pests and diseases to enter the country. Expansion of the AQI Results Monitoring Program will provide information on the relative risk associated with the entry of passengers and commodities into the United States. Additionally, as commodity entry is facilitated, improved inspection levels on higher risk commodities will be assessed. APHIS also will evaluate GAO’s premise that smaller numbers of reliable inspections are preferable to a larger number of inspections that do not comply with inspection guidelines. APHIS is committed to continuing to improve its AQI program to reduce the threat of harmful pests while not unduly restricting trade. Field personnel on local risk management teams, with input and guidance from regional and headquarters staff, will evaluate current inspection protocols to ensure that inspections performed in ports of entry are consistent with risk determinations and APHIS’ national policy. To improve the data in WADS, APHIS plans to ensure that inspection program policies are consistently applied nationwide and that the data used in decisionmaking are accurate and reliable. The PPQ regions recently established AQI specialist positions to conduct program analysis and risk assessment. These AQI specialists are part of the National AQI Team, which assures that AQI policies are consistently applied nationwide and that the data used in decisionmaking are accurate and reliable. Quality control of the data is also necessary at ports of entry. Ports are beginning to establish local risk management teams. These teams will conduct local risk assessments and recommend options to manage identified risks. By using these data to make risk-based decisions at the port, all field personnel will be involved in improving the accuracy of WADS. APHIS is consolidating its four PPQ regions into two regions and believes that this will contribute significantly to achieving national consistency in the AQI program. IV. Environmental Analysis 81 2. Suppression/ Eradication Strategies APHIS will continue to provide guidance to emphasize and reinforce the importance of using the best possible procedures for preventing pests from becoming established, and will ensure that the inspection standards are consistent with the risk determinations conducted through the AQI Results Monitoring Program. The thrust of the GAO report was that port inspection as a sole line of defense has weaknesses that are difficult to overcome. This was precisely the reason that the wood import regulation was developed. The regulation has resulted in shifting our protection of native forests from exotic pests away from a single inspection at the port of arrival to a comprehensive approach where pest mitigation is ensured before entry into the United States. The use of a combination of complementary mitigation measures has been required, thus reducing reliance upon inspection from the sole method of protection to a partial role that also serves as a monitoring tool to evaluate the effectiveness of the regulation. The regulatory approach used for wood imports was developed because APHIS was aware of the limitations of port-of-arrival inspection as later pointed out in the GAO report. The primary intent of the wood import regulation is to exclude exotic pests of forests and wood articles. Exclusion is the most effective technique for preventing new infestations of plant pests. There is, however, always the possibility that forest pests may be inadvertently established despite agency actions designed to prevent this. APHIS has prepared descriptions of “Pests not known to occur in the United States.” If any of these pests or other pests are detected in the United States, APHIS organizes a New Pest Advisory Group to assess the pest risks and to prepare an action plan that sets out control options for dealing with the new pest. The group may be responding to a new species (e g., Asian long-homed beetle) or to a new subspecies (e g., Asian gypsy moth). The participants in the advisory group usually include experts from the U.S. Forest Service, various interested State agencies, and academia. Agency actions in response to the introduction of new pest species include no action, suppression, and eradication. No action is generally taken for conditions where pest risk is insignificant or where agency actions could not contribute to elimination of the pest risk. Suppression is selected when eradication is infeasible and taking no action is inappropriate. Eradication is selected for conditions where feasible and where the pest risk justifies the expenses of eradication. Agency actions against introduced pest species may take the form of suppression or eradication strategies. While it is preferable to exclude pest species from introduction, as APHIS regulations are intended to do, no strategy can be designed to completely eliminate the risk of inadvertent plant pest introductions. When establishments have occurred and control activities are desirable, there are general approaches 82 IV. Environmental Analysis that can be taken. The selection of a suppression or eradication strategy depends upon the tools available to control and eliminate the introduced pest. The specific methods used against each pest must be designed for maximum effectiveness against that pest species. Because each species is unique in habits, habitat, and vulnerability, the particular problems and issues that relate to each species of forest pest are too varied and numerous to describe in detail. There are, however, some general strategies that pertain to certain types of forest pests. Once it is determined that a control program is needed, documentation of the environmental consequences of the larger control programs may be achieved through the preparation of an environmental impact statement (e g., Programmatic Gypsy Moth Management). Analysis and documentation of environmental consequences of smaller programs or site-specific agency actions for larger programs is generally presented in an environmental assessment (EA). The site-specific EA prepared for most programs provides the rationale used to select specific actions to achieve the desired control level with minimal adverse impacts. The rest of this section will address the general control strategies applicable to specific forest pest groups and the effectiveness of these control methods when used for suppression and eradication efforts. a. Insect Pests The strategies to control insect pests depend primarily on the insect species, their habitat requirements, their potential to damage trees and forests, their ability to spread, and their geographic distribution. The different combinations of biological and environmental factors make it necessary to take different approaches for control of each new and established pest species. Agency control programs are considered on a case-by-case basis with a comprehensive review of environmental impacts before selecting a specific control strategy. Efforts by APHIS and the U.S. Forest Service may determine that the insect has not become established (e g., the spruce beetle, Ips typographus ) and that no further action is necessary. If a pest has become established and has spread throughout its potential host range or no feasible control methods are available, then it may be decided that no agency action is the most appropriate approach. If there are feasible alternatives available to the agency, then each will be considered from the standpoint of effectiveness and environmental impacts. If the agency decides to take action against an insect pest, then an effort would be made to trace the source of the introduced insect pest. If it were imported via a wood commodity pathway, then a reevaluation of that pathway would be undertaken. Species with potential to damage forests (e g., gypsy moth in oak forests) may be controlled through eradication or suppression strategies. The eradication IV. Environmental Analysis 83 efforts are often chosen for small isolated infestations. The suppression efforts generally are chosen for sites where the pest is well established, the pest population is expected to cause substantial damage, and eradication is not feasible. A modification of the suppression strategy which was developed for use against gypsy moth, but that may be applicable to other forest insects, is the slow-the-spread strategy. Slow-the-spread programs occur on the geographic edges of an expanding infestation with the intent of minimizing damage as the pest’s distribution expands. All control programs that are developed depend upon an integrated pest management approach. For example, a site-specific gypsy moth program may use trapping, biological control agents, chemical control agents, mating disruption, sterile insect technique, regulatory controls, and physical controls (USDA, FS and APHIS, 1995a). Mechanical and silvicultural practices may be effective in some suppression programs. Selective removal of infested trees, trapping, weeding, thinning, pruning, and prescribed burning have been shown to effectively control some insect pests (Graham, 1979). The control of some wood insects may be difficult because control actions may not be feasible for all life stages. For example, small infestations of wood- boring insects may be controlled by cutting and destroying all infested trees (e g., Asian long-horned beetle in New York). Chemical control for these woodborers is only effective during a short period of time when the adults are active. Systemic chemicals may be used for some wood-boring species, but the environmental impacts of more persistent chemicals would have to be considered carefully in an environmental assessment before their use. Planting of genetically resistant strains of the host plant is one option that may be considered when eradication of the pest is not a feasible option (Speight and Wainhouse, 1989). Some forest insect pests are known to “hitchhike” on common carriers such as public transportation (e.g., Japanese beetle). Treatment of the public airlines with a knockdown agent and contact insecticide prior to flights has been shown to effectively prevent this. Some insect pests spread slowly and may be best contained by a limited control program where the trapping has detected the insect pest (e g., pine shoot beetle). These programs require adherence to trapping and treatment schedules if the wood articles are to be moved outside the regulated areas. The use of repellants and anti-feedant compounds may be applicable to some of these pest situations (Speight and Wainhouse, 1989). 84 IV. Environmental Analysis b. Fungal Pests Agency programs for suppression or eradication of fungal pathogens may be implemented when infestations are detected. The suppression or eradication of introduced pathogenic fungi can be difficult and cumbersome. The suppression program of Dutch elm disease conducted by the U.S. Forest Service was intended to reduce damage and prevent spread of the pathogenic fungus. The ability of the U.S. Forest Service to control this fungus was limited to treatments for the insect vector and elimination of infested trees. The vector and fungus were already well established before the program began. Early detection of fungal pests may allow an agency the opportunity to identify, cut, and destroy all infected trees, but this only would be effective for small infestations. The biology of the fungus determines its rate of spread. Insecticide treatment of trees may be effective for suppression or eradication if the introduced pathogenic fungi are transmitted to other hosts primarily by an insect vector. Fungicide treatment of trees may be effective for suppression or eradication if the introduced pathogenic fungi are not readily dispersed by wind or other means. Some efforts could require use of both fungicides and insecticides. Epidemiologic tracing of the source of the pathogenic fungus inoculum would be necessary to ensure that additional infestation would not occur. Detection of a newly introduced pathogenic fungus must be followed by an effort to delimit the geographical extent of the infestation. The agency must ensure that the fungal pathogens are not too widespread for an effective program. If the distribution at the time of detection is determined to be too broad for a successful program, then the agency may choose to attempt no regulatory actions (e g., the introduction of Eurasian poplar leaf rust). If the introduced fungus is highly pathogenic and the spores are readily dispersed by wind, suppression by containment or eradication may not be effective actions. Selection of an agency action must be based upon the nature and distribution of the fungal pathogens. c. Other Wood Pathogens Other wood pathogens include some nematodes, bacteria, and viruses. Agency programs or actions will depend upon the specific pathogenic organism. The infested area must be delimited to determine the appropriate response. Some small or site-specific infestations could be handled through the cutting and destruction of the infested wood (e g., Florida citrus canker infestations). Equipment used in these programs against bacterial pathogens is disinfected after use. Other infestations could be treated or contained through the use of pesticides. Fumigation may be required for eradication of site-specific infestations of nematodes. It may not be feasible to have program actions for IV. Environmental Analysis 85 large or widespread infestations. As with other pest species, determining the initial source of introduction of the pathogens would be required, as well as treatment or destruction of the wood that was determined to be the source of infestation. 3. Methyl The Montreal Protocol is an international agreement that governs the Bromide Use production and use of ozone-depleting chemicals. It was developed in response to evidence that manmade substances, particularly chlorofluorocarbons (CFC’s), were damaging the ozone layer. The ozone layer is a concentration of ozone in the earth’s stratosphere (the layer of the atmosphere that extends from 7 to 30 miles above the Earth’s surface). Its presence protects the Earth’s surface from excessive ultraviolet radiation. Under the Montreal Protocol, developed countries have agreed to limit and ultimately phase out production and use of ozone-depleting substances. Methyl bromide is listed as an ozone-depleting substance under the Montreal Protocol Accordingly, a reduction and phaseout schedule for methyl bromide production in industrial countries has been established, and production in developing countries will be frozen. The Montreal Protocol, however, maintains an exemption to the restrictions on methyl bromide for quarantine use. It also allows for a critical agricultural-use exemption. These exemptions are intended to be used when no alternative to methyl bromide is available to maintain phytosanitary standards and agricultural production. In the United States, methyl bromide is regulated under the Clean Air Act (CAA), which is administered by the U.S. Environmental Protection Agency (EPA). In 1993, EPA finalized a rule that classified methyl bromide as a Class I substance (one having a high potential for destroying stratospheric ozone). The CAA classifies ozone-depleting substances into two classes. Production and use of Class I substances (such as methyl bromide) are scheduled to be phased out over a 7-year period, and Class II substances are scheduled to be phased out over a 30-year period. According to the CAA regulations, production and importation of methyl bromide will be terminated by January 1, 2001 . Unlike the Montreal Protocol, there are no phytosanitary exemptions under the CAA. Therefore, methyl bromide use in the United States for any purpose will be reduced to zero as supplies dwindle after January 1, 2001. Methyl bromide currently is the only fumigant approved for use in meeting the wood import requirements. Despite the fact that international treaty (the Montreal Protocol) allows for exemptions for quarantine uses to the phaseout schedule of methyl bromide, the Clean Air Act prohibits the production and 86 IV. Environmental Analysis importation of methyl bromide into the United States after January 1, 2001. Soon after that date the existing stocks of methyl bromide in the United States are likely to be exhausted and methyl bromide will no longer be available for quarantine uses in the United States. Domestic production of methyl bromide for any use after January 1, 2001, will require an administrative decision and/or a statutory change. At this time, it is unclear if currently available methyl bromide treatments that occur overseas still will be permitted under the wood import regulation. If methyl bromide is not available, importers will have two options: import wood articles under the universal import requirements (primarily heat treatment) or find another fumigant that can replace methyl bromide. Other fumigants that may be efficacious could be used, but only after they have been accepted by APHIS and the regulation has changed to accept their use. APHIS records indicate that since the APHIS wood import regulation went into effect, there has been little change in the use of methyl bromide on such articles. Table 4-13 compares the amount of methyl bromide (in metric tons) used by APHIS during the 2 years before implementation of the wood import regulation in August 1995 and during the 2 years after adoption of the regulation. The lack of change in methyl bromide use may be surprising to some, but it may be explained by the reluctance of shippers and importers to invest time and energies in the face of the legal challenge to the regulation. Based on the interest shown by Chile, New Zealand, and the forest products industry, it is anticipated that the importation of logs, lumber, and other unmanufactured wood will escalate when the legal challenge is resolved. Table 4-13. Amount (in Metric Tons) of Methyl Bromide Used to Fumigate Imports of Logs, Lumber, and Other Unmanufactured Wood Articles Date Fumigation of logs, lumber, and wood articles Dunnage Total Before regulation: 8/93-8/94 0.39 1.72 2.11 8/94-8/95 0.86 1.35 2.21 After regulation: 8/95-8/96 0 81 1.46 2.27 8/96-8/97 1.09 0.82 1.91 4. New Methods and Techniques a. Shipboard Heat Treatment The technology for the heat treatment of logs has expanded since the original EIS was prepared. On the forefront of this technology is a proposal to heat treat logs in the holds aboard ships during the voyage to the United States. IV. Environmental Analysis 87 APHIS has examined the engineering designs of the proposed treatment and has approved, in principle, this treatment method. This design is patented in the United States. However, at the current time, no prototype equipment has been constructed and no ocean vessel is equipped to test the feasibility of this design. When it is available, APHIS will examine and test any equipment constructed to heat treat logs in this manner. b. Irradiation as a Potential Treatment Method Irradiation is one of the methods discussed in the EIS for which APHIS continues to explore the possibility of further development. This section provides additional and updated information on irradiation as an alternative method of treating imported wood articles and addresses the potential human health impacts of using irradiation as a mitigation measure. In the EIS for the importation of logs, lumber, and other unmanufactured wood articles (USDA, APHIS, 1994), gamma irradiation was mentioned as a potential treatment to prevent the introduction of exotic plant pest species on imported wood articles. However, because of its possible deleterious effect on wood articles, the cost involved in constructing gamma irradiation treatment facilities, and the need for efficacy data, it was noted that the method did not appear to be a feasible alternative for treating imported timber. Likewise, a similar treatment option, electron beam irradiation, was discussed as having the potential to be an effective treatment against a wide range of plant pests. Electron beam irradiation has been examined by Agriculture Canada for its feasibility as a possible treatment against New World pinewood nematode and wood-stain fungi. Unfortunately, similar obstacles — that is, limited information on the cost and logistics of setting up treatment facilities, and very little documentation of efficacy against insect pests and pathogens — prevented its practical employment for this purpose. In the EIS (USDA, APHIS, 1994), it was noted that “[t]o date, gamma irradiation has been applied only to disinfect or disinfest such items as food products, pharmaceuticals, and medical devices.” Even so, previous programs considered irradiation treatment only on a case-by-case basis for each facility or commodity use pattern. Because it is advantageous to find alternative plant pest quarantine treatments due to the phaseout of methyl bromide use, the North American Plant Protection Organization (NAPPO) convened a colloquium to review the suitability of irradiation technology as an alternative quarantine treatment (NAPPO, 1995). In fact, guidelines developed for the use of irradiation as a phytosanitary treatment are available to provide information on policies, procedures, and requirements for the proper conduct of treatments and to maintain consistency of operations between agencies and countries (NAPPO, 1997). 88 IV. Environmental Analysis Recently, APHIS proposed the use of irradiation as an additional regulatory treatment method for phytosanitary certification of some agricultural commodities (61 FR 24433, May 15, 1996) and prepared an environmental assessment (EA) (USD A, APHIS, 1997) to analyze the potential environmental impacts of using this option. The EA analyzed the human health and environmental impacts that may result from implementation of the proposed use of irradiation on agricultural commodities. Under this proposed use, the intended treated products are generally foodstuffs, and the required dosages are lower than those considered for wood. Therefore, it is inappropriate to infer efficacy data for logs and wood articles from available efficacy data on foodstuffs. However, because the processes would be similar, albeit with a lower dose, it may be reasonable to speculate from the EA the potential human health effects of using irradiation to treat wood articles. Under the circumstances where the commodities are food sources and therefore ingested, the human health issues relate to the potential exposure to not only radiation, but also the unique radiolytic products formed in the foodstuff from the process. For the purpose of this SEIS, wherein the radiation treatment would be applied to wood articles, only the potential exposure to radiation from the treatment facility is considered. An EA prepared by the US. Department of Health and Human Services’ Food and Drug Administration (FDA) determined that no adverse environmental effects are anticipated at food processing plants that are designed to irradiate fruits and vegetables (FDA, 1982). The Nuclear Regulatory Commission (NRC) has set stringent environmental protection requirements for any facilities that use radionuclide sources (10 CFR Parts 20, 30, 51, and 71). In addition, there are special carrier requirements for transport of hazardous materials (such as the radionuclides used at these facilities) set by the U S. Department of Transportation (DOT). Any extraneous radiation from radionuclides are to be contained in industrial plants by shielding, as required by the NRC and the Bureau of Radiological Health at FDA. The risk of radiation exposure to workers would be expected to be very low with adherence to the required safety regulations. The irradiation facilities should pose no routine risks to the general public, and public health concerns would occur only in the unlikely event of a major accident at a facility. Many safeguards prevent such incidents. Proper design and operating procedures of commercial irradiators have been shown to operate without significant radiation risk to workers or the public (CH2M Hill, 1987). Since the publication of the EIS in 1994, APHIS has been receptive to discussing any new data that would provide conclusive evidence that specific radiation dosages were effective against potential pests of wood articles, and that the process could be implemented successfully in a cost-effective manner. Although no new efficacy data have been published, Russian scientists have IV. Environmental Analysis 89 5. Summary of Pest Risk Assessment for Logs From Mexico conducted research and provided data in support of adopting a generic dose for treating raw logs. This information indicates that a dose of 7 kiloGrays (kGy) is sufficient to cause 100 percent mortality in insects, fungi, and nematodes in logs (Huettel, 1996). In addition, APHIS’ PPQ has formed a science panel consisting of scientists from APHIS, the Agricultural Research Service, and the U S. Forest Service to establish a research protocol, review data, and oversee the research effort toward a generic dose providing probit 9 mortality for all organisms of concern in logs from Russia. (Probit 9 mortality is a statistical estimation of 99.99683 percent mortality in a population of live organisms, corresponding to a survival rate of 32 individuals per million.) If approved, APHIS may propose that the treatment be included in the wood import regulation. There have been no further advances in developing treatment facilities that would be logistically and economically feasible for treating large shipments of logs, lumber, and other unmanufactured wood articles. Therefore, even though the irradiation process presents negligible human health concerns and has been acknowledged to achieve plant pest mortality, because of the lack of definitive information on feasibility, APHIS is not prepared to alter the assessment of its potential for use from that which is in the previous EIS. In 1996, APHIS asked the U.S. Forest Service to determine the pest risk of importing pine and Douglas-fir logs into the United States from Mexico. APHIS made this request because of an increased interest in importing Mexican pine and fir logs. In response to the APHIS request, the U.S. Forest Service established a team of forest experts and scientists to evaluate the risk of importing these softwood logs into the United States. The final document “Pest Risk Assessment of the Importation into the United States of Unprocessed Pinus and Abies Logs from Mexico” became available in February 1998. APHIS has appointed a Mexican Log Risk Management Team to evaluate the new information supplied by the risk assessment. Part of this team’s mission is to reevaluate the Mexican border exemption that is currently in the wood import regulation. The conclusions from the pest risk assessment for logs from Mexico are excerpted in the following paragraphs. “Several U.S. forest industries propose to import logs of Pinus and Abies for processing in various localities in the United States. Current regulations require that unprocessed logs from Mexican states that do not border the contiguous United States be debarked and heat treated to eliminate all pests (Title 7, CFR Part 3 19.40-6). However, a general permit was issued to import logs and other wood articles from Mexican states adjacent to the U.S. border (Title 7, CFR Part 3 19.40-3). There is little biological support for such a regulation because plant pests are not confined to political boundaries. Therefore, APHIS requested that 90 IV. Environmental Analysis the Forest Service prepare a risk assessment that identifies the potential pine and fir pests throughout Mexico, estimates the probability of their entry on logs of these species into the U.S., and estimates the potential for these pests to establish and spread within the U S. The pest risk assessment also evaluates the economic, environmental, social, and political consequences of the introduction. The assessment and conclusions are expected to be applicable to the entire United States.” “There are numerous potential pest organisms found on both Pinus and Abies spp. in Mexico that have a high probability of being inadvertently introduced into the U S. on unprocessed logs. Some of these organisms are attracted to recently harvested logs while others are affiliated with logs in a peripheral fashion but nonetheless pose serious threats to forest or agricultural hosts in the U S. Thus, the potential mechanisms of log infestation by nonindigenous pests are complex. Further complicating the issue is the presence of many of the pests of potential concern in Mexican states immediately adjoining the U S. For example, the following organisms with a moderate or high pest risk potential occur in one or several border states: the adelgids ( Pineus spp ), La Grilleta ( Pterophylla beltrani), pine bark beetle {Dendroctonus mexicanus), pine engraver beetle ( Ips bonanseai), pitch moth ( Synanthedon cardinalis), ambrosia beetle ( Gnathotrichus perniciosus), organisms that cause assorted diseases, (e g. Sphaeropsis sapinea and Cronartium spp ), and pine wood nematode (Bursaphelenchus xylophilus). Due to their size, and spatial configuration in some cases, these adjoining Mexican states have ecological and geographic features that do not resemble the bordering U S. states. The shared border regions where the features are similar can be quite small. Current import regulations provide a general permit for unprocessed wood products from these border states. The issue of pests of concern in adjacent states of Mexico should be considered in any review of log import regulations.” “The situation in Mexico has some important differences that distinguish it from the situations in New Zealand and Chile, where previous risk assessments have been done (USDA, FS, 1992a, 1993a). Plantation grown Monterey pine ( Pinus radiata) is an exotic species in both Chile and New Zealand and is relatively free of insects and pathogens. In both Chile and New Zealand, there have been relatively few organisms that have demonstrated a capability of adapting to their new potential pine host, and many of the insects and pathogens associated with Monterey pine are ones introduced from the northern hemisphere. In Mexico, the heart of diversity for Pinus spp. in the world, the number of native organisms associated with pine is far IV. Environmental Analysis 91 6. Information on Effectiveness of the Wood Import Regulation greater than that associated with pine in Chile and New Zealand. This inherent complexity of native pine forests in Mexico leads to more organisms with higher risk potentials than in Chile and New Zealand. Furthermore, an additional source of concern is that Mexico could have generic variants of species that already occur in both Mexico and the United States.” “For those organisms of concern that are associated with Mexican pines and firs, specific phytosanitary measures may be required to ensure the quarantine safety of proposed importations.” For the most part, records of quarantine pest interceptions are based on pest interceptions found at the ports of entry by visual inspection by Plant Protection and Quarantine (PPQ) officers and should not be interpreted as the actual numbers of infested wood commodities which have entered the continental United States since the wood import regulation took effect in August 1995. Because solid wood packing material such as crating and dunnage are so ubiquitous, only a small number of shipments are actually physically examined at the port of entry. Log imports, on the other hand, are always examined in detail and the data more closely reflect the actual pest risk. Lumber and other wood products are also normally examined in detail, but usually not to the degree as log imports. Hundreds of thousands of shipments of commodities containing wood products have entered the United States since the wood import regulation went into effect. Based on Plant Protection and Quarantine’s interception database, of the shipments that received physical inspection, approximately 500 were found to be infested with significant forest pests; however, none of the log shipments were found to be infested with significant exotic forest pests. Of the infested shipments, 97 percent were due to infested wood packing material. All infested shipments were either treated or refused entry. APHIS believes that the interception records indicate where the greatest risk of plant pest introduction occurs and thus point out portions of the wood import regulation that may need to be revisited. Log importations under the current regulation present a negligible plant pest risk. According to APHIS’ pest data base, no log shipments have been found infested with exotic forest pests since the wood import regulation went into effect on August 23, 1995. Lumber imports also present a negligible plant pest risk, with the possible exception of lumber from the adjacent states in Mexico (as determined in the pest risk assessment for Mexico, discussed in previous section). 92 IV. Environmental Analysis The interception records identify two pathways with the greatest likelihood of pests entering the country. They are the pathways for solid wood packing material and the movement of wood products across the Mexican-U.S. border. By far, the greatest current pathway of exotic forest pests into the United States is through use in international trade of untreated solid wood packing materials. Although the current wood import regulation has reduced the risk of pest introduction compared to the preregulatory period by requiring the removal of 100 percent of the bark on solid wood packing materials, it is apparent that this pest pathway is still of concern. APHIS and its sister plant protection agencies in Canada and Mexico, through the North American Plant Protection Organization (NAPPO), are developing an international standard on solid wood packing material. The first draft of the NAPPO Standards for Phytosanitary Measures on the “Import requirements for wooden dunnage and packing materials from sources outside of North America” was released on October 9, 1997. Currently, APHIS is evaluating and continuing development of the draft along with the plant protection agencies of Canada and Mexico. The intent of the NAPPO document is to determine the best approach to regulating solid wood packing materials and to try to adopt consistent regulatory actions throughout North America. If a change is thought to be necessary, APHIS will propose new import requirements to the wood import regulation. In response to the pest risk assessment for Mexico (summarized in the preceding section, chapter IV, section D.5.), a review is underway on the Mexican border exemption. APHIS has appointed a Mexican Log Risk Management Team to evaluate the new information supplied by the risk assessment. Part of this team’s charge is to reevaluate the Mexican border exemption currently in the wood import regulation. Examining imported commodities in order to identify plant pest pathways and, if pathways are identified, identifying ways to reduce the probability of entry is a standard practice of APHIS. This standard practice identified the pathways and prompted APHIS to initiate the actions discussed above. IV. Environmental Analysis 93 [This page is intentionally left blank.] 94 IV. Environmental Analysis V. Preparers and Reviewers Environmental Analysis and Documentation Policy and Program Development Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 149 Riverdale, MD 20737-1238 Carl Bausch Deputy Director Jack Edmundson Environmental Protection Officer David Bergsten Toxicologist Mary Biddlecome Secretary Charles Brown Ecologist Charles Divan Microbial Ecologist Margaret Huggins Program Analyst Leslie Rubin Toxicologist Vicki Wickheiser Writer/Editor Risk Analysis Systems Policy and Program Development Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 1 1 7 Riverdale, MD 20737-1238 Richard On- Senior Entomologist Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road Riverdale, MD 20737 Mary Neal Assistant Director Operational Support, Unit 131 Deborah Knott Supervisory Agriculturist Biological Assessment and Taxonomic Support Unit 133 Jane Levy Operations Officer Program Support, Unit 134 Ronald Campbell Import Specialist Phytosanitary Issues Management, Unit 140 Environmental Innovations Consulting Firm V. Preparers and Reviewers 95 [This page is intentionally left blank ] 96 V. Preparers and Reviewers VI. References Cited Abbott, L., and Rubin, L. Personal communication October 1997 regarding the effects of disparlure used for Asian gypsy moth control. USDA, APHIS, Policy and Program Development, 4700 River Road, Unit 149, Riverdale, MD 20737-1238. APHIS — See U.S. Department of Agriculture, Animal and Plant Health Inspection Service. Bridges, J.R., 1993. Two more bad bugs. American Forests, July/ Aug., p. 54. Burdette, E.C., 1976. Effects of microwave treatment of Anobiidae infested wood blocks. Atlanta, GA. Georgia Institute of Technology, Engineering Experiment Station. CH2M Hill, 1987. Feasibility study for a commodities irradiation facility in the State of Hawaii (final report and attachments). State of Hawaii, April 1987. Cheater, M., 1991. Save that taiga. Worldwatch, July/ Aug., Vol. 4, No. 4. Ciesla, W.M., 1988. Pine bark beetles: a new pest management challenge for Chilean foresters. Journal of Forestry 86:27-31. Cook, J., 1987. Elm Street revisited. Country Journal, Oct., p. 52-56. EPA — See U.S. Environmental Protection Agency. FDA — See U.S. Department of Health and Human Services, Food and Drug Administration. GAO — See U.S. General Accounting Office. Graham, D.A., 1979. Orientation and general summary. In Rudinsky, J A., ed.. Forest insect survey and control, 4th edition. Oregon State University, Corvallis, OR. Haack, R.A., and Byler, J.W., 1993. Insects and pathogens. J. of Forestry, Sept., p. 32-37. Harrington, T.C., 1988. Leptogt'aphium species, their distribution, hosts, and insect vectors. In Harrington, T.C.; Cobb, F.W., Jr., (eds ), Leptographium root diseases of conifers. St. Paul, MN. American Phytopathological Society Press: 1-39. Hightower, N.C., Burdette, E.C., and Burns, CP., 1974. Investigation of the use of microwave energy for weed seed and wood products insect control. Tech. Rep., Project E-230-901. Atlanta, GA. Georgia Institute of Technology, 53 p. VI References 97 Huettel, R.N., 1996. Letter dated July 1 1, 1996, from USDA, APHIS, PPQ, Oxford Plant Protection Center, Oxford, NC, to review participants regarding irradiation data. Newhouse, J.R., 1990. Chestnut blight. Scientific American, July, p. 106. North American Plant Protection Organization, 1995. The application of irradiation technology as a quarantine treatment. Proceedings of the NAPPO colloquium on the application of irradiation technology as a quarantine treatment. Orlando, FL. Oct. 19-20, 1994. Bulletin No. 13, January 1995. North American Plant Protection Organization, 1997. NAPPO standards for phytosanitary measures, guidelines for the use of irradiation as a phytosanitary treatment. The Secretariat of the North American Plant Protection Organization, Nepean, Ontario, Canada, Jan. 1, 1997. Orr, R., 1992. Plant Protection and Quarantine requirements for the importation of Pinus radiala and Douglas-fir logs, lumber, and wood chips from New Zealand. Administrative Record 8685-8695. OstafT, D.P., and Cech, M.Y., 1978. Heat-sterilization of spruce-pine-fir lumber containing sawyer beetle larvae (Coleoptera:Cerambycidae), Monochamus sp. Rev. OPX200E. Ottowa, ON. Canadian Forestry Service. 9 p. Ostaff, D.P., and Shields, J.K., 1978. Reduction of losses to logs and lumber caused by wood- boring insects. Rep. OPX218E. Ottawa, ON. Canadian Forest Service, Eastern Forestry Products Laboratory. 15 p. OTA — See U S. Congress, Office of Technology Assessment. Reeves, D , 1993. Plant Protection and Quarantine requirements for the importation of Pinus radiata logs from Chile. Administrative Record 8238-8246. SBA, 1996 — See Small Business Administration Silbergeld, E.K., 1991. Risk Assessment and Risk Management: An Uneasy Divorce. In Mayo, D.G, and Hollander, R.D. eds. Acceptable Evidence: Science and Values in Risk Management. Oxford Univ. Press. New York. Snyder, T.E., 1923. High temperatures as a remedy for Lyctus powder-post beetles. Journal of Forestry 21:810-814. Snyder, T.E., and St. George, R.A., 1924. Determination of temperature fatal to the powderpost beetle, Lyctus planicollis LeConte, steaming infested ash and oak lumber in a kiln. Journal of Agricultural Research. 28( 10): 1033-1038. 98 VI. References Speight, M R., and Wainhouse, D., 1989. Ecology and management of forest insects. Clarendon Press, Oxford, England. Stairs, G., and Salinger, M. (eds ), 1988. Canada and U.S. Forest Products. Duke University Press. Durham, NC. TFW — See Tropical Forestry Workshop. Thomas, A M., and White, M.G., 1959. The sterilization of insect infested wood by high frequency heating. Wood 24:407-410, ff. Tropical Forestry Workshop, 1990. Consensus statement on commercial forestry sustained yield management and tropical forests, 10 p. Co-sponsored by the Smithsonian Institution and International Hardwood Products Association. USDA — See U.S. Department of Agriculture. USDA, APHIS — See U.S. Department of Agriculture, Animal and Plant Health Inspection Service. USDA, FAS — See U.S. Department of Agriculture, Foreign Agricultural Service. USDA, FS — See U.S. Department of Agriculture, Forest Service. USDA, MRP — See U.S. Department of Agriculture, Marketing and Regulatory Program. U.S. Congress, Office of Technology Assessment, Harmful non-indigenous species in the United States, OTA-F-565. Washington, DC, U.S. Government Printing Office, September 1993. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1991a. An efficacy review of control measures for potential pests of imported soviet timber. Misc. Pub. 1496, Sept. 1991. Riverdale, MD. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1991b. National boll weevil cooperative control program, final environmental impact statement — 1991. Vol. 1. Riverdale, MD. U.S Department of Agriculture, Animal and Plant Health Inspection Service, 1993. Medfly cooperative eradication program, final environmental impact statement — 1993. Riverdale, MD. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1994. Importation of logs, lumber, and other unmanufactured wood articles, final environmental impact statement, July 1994 Riverdale, MD. VI. References 99 U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1995. Final economic analysis of proposed 7 CFR part 319, quarantine 40 regulations. Importation of logs, lumber, and other raw or processed wood products. Riverdale, MD. May 1, 1995. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1996. Human health risk assessment for the APHIS 1996 rangeland grasshopper cooperative management program. Prepared by Syracuse Environmental Research Associates under USDA Forest Service Contract No. 53-3 187-5-12, Task Order No. 43-3187-6-0260, May 10, 1996. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1997. Irradiation for phytosanitary regulatory treatment, environmental assessment, October 1997. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Management and Budget, 1996. Investigative and Enforcement Services, Plant Protection and Quarantine, 1996 annual report. lOp. Riverdale, MD. U.S. Department of Agriculture, Foreign Agricultural Service, 1992. Wood products: international trade and foreign markets. Washington, DC. June 1992. U.S. Department of Agriculture, Forest Service, 1984. Agriculture Handbook Number 633, Pesticide Background Statements, Vol. I. Herbicides. August 1984. U.S. Department of Agriculture, Forest Service, 1986a. Agriculture Handbook 633, Pesticide Background Statements, Vol. I. Herbicides (Supplement). October 1986. U.S. Department of Agriculture, Forest Service, 1986b. Agriculture Handbook Number 661, Pesticide Background Statements, Vol. II. Fungicides and Fumigants. U.S. Department of Agriculture, Forest Service, 1987a. Final environmental impact statement: suppression of the southern pine beetle. Region 8. U.S. Department of Agriculture, Forest Service, 1987b. Agriculture Handbook Number 670, Pesticide Background Statements, Vol. III. Nursery Pesticides. October 1987. U.S. Department of Agriculture, Forest Service, 1988a. Human health risk assessment for herbicide applications to control noxious weeds and poisonous plants. Report 88-9. Region 1. U.S. Department of Agriculture, Forest Service, 1988b. Final environmental impact statement: vegetation management for reforestation. Region 5. U.S. Department of Agriculture, Forest Service, 1988c. Final environmental impact statement: managing competing and unwanted vegetation. Region 6. 100 VI. References U.S. Department of Agriculture, Forest Service, 1989a. Final environmental impact statement: management of western spruce budworm in Oregon and Washington. Region 6. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. U.S. Department of Agriculture, Forest Service, 1989b. Final environmental impact statement: nursery pest management. Region 6. Department of Agriculture, Forest Service, 1989c. Agriculture Handbook 685, Pesticide Background Statements, Vol. Insecticides. Department of Agriculture, Forest Service, 1991a. Pest risk assessment of the importation of larch from Siberia and the Soviet Far East. Misc. Pub. 1495, Sept. 1991. Department of Agriculture, Forest Service, 1991b. Risk assessment: 2-butoxyethanol and 1,4-dioxane. Region 5. Department of Agriculture, Forest Service, 1991c. Dry Kiln Operators Manual. Forest Products Laboratory. Agriculture Handbook No. 188. Madison, WI. Department of Agriculture, Forest Service, 1992a. Pest risk assessment of the importation of Pinus radiatci and Douglas-fir logs from New Zealand. Misc. Pub. 1 508, Oct. 1992. Department of Agriculture, Forest Service, Forest Pest Management, 1992b. Final report: scientific panel review of January 10, 1992. Proposed test shipment protocol for importing Siberian larch logs. Adm. Rec. 9435-9457. April 15, 1992. Department of Agriculture, Forest Service, 1992c. Final environmental impact statement: nursery pest management. Region 2. (Republished draft environmental impact statement with errata sheet). Department of Agriculture, Forest Service, 1993a. Pest risk assessment of the importation of Pinus radiata, Nothofagus dombeyi and Laure/ia philippiana logs from Chile. Misc. Pub. 1517, Sept. 1993. Department of Agriculture, Forest Service, 1993b. Final environmental impact statement, nursery pest management. Department of Agriculture, Forest Service, 1993c. Nursery fungicide background statements. Department of Agriculture, Forest Service, 1993d. Final environmental impact statement: nursery pest management. Region 8. Department of Agriculture, Forest Service, 1994a. Final environmental impact statement: nursery pest management. Region 9. VI. References 101 U.S. Department of Agriculture, Forest Service, 1994b. Final environmental impact statement: nursery pest management. Region 4. U.S. Department of Agriculture, Forest Service, 1994c. Supplement to the final environmental impact statement: nursery pest management. Regions 1, 2, 4, 5, 6, 8, 9. U.S. Department of Agriculture, Forest Service and Animal and Plant Health Inspection Service, 1995a. Gypsy moth management in the United States: a cooperative approach, final environmental impact statement. Vol. II of V, chapters 1-9 and app. A-E. Washington, DC. U.S. Department of Agriculture, Forest Service, 1995a. Risk assessment: seed orchard management. Region 6. U.S. Department of Agriculture, Forest Service, 1995b. Final environmental impact statement: pesticide use in seed orchard management. Region 6. U.S. Department of Agriculture, Forest Service, 1995c. Vanquish risk assessment, final. Prepared by Syracuse Environmental Research Associates under USDA Forest Service Contract No. 53-3187-5-12, Task Order No. 43-3187-5-0787, October 16, 1995. U.S. Department of Agriculture, Forest Service, 1996a. Selected commercial formulations of triclopyr - Garlon 3A and Garlon 4, risk assessment final report. Prepared by Syracuse Environmental Research Associates under USDA Forest Service Contract No. 53-31 87-5- 12, Task Order No. 43-3187-6-0085, March 1996. U.S. Department of Agriculture, Forest Service, 1996b. Selected commercial formulations of glyphosate — Accord, Rodeo, and Roundup, risk assessment final report. Prepared by Syracuse Environmental Research Associates under USDA Forest Service Contract No. 53- 3187-5-12, Task Order No. 43-3187-6-0085, March 20, 1996. U.S. Department of Agriculture, Forest Service, 1997. Selected commercial formulations of hexazinone — human health and ecological risk assessment, final. Prepared for USDA, Forest Service by Syracuse Environmental Research Associates under USDA Forest Service Contract No. 53-3187-5-12, Task Order No. 43-3187-6-0296, March 4, 1997. U.S. Department of Agriculture, Marketing and Regulatory Programs, 1997. Statement of Action of GAO Final Report RCED-97-102, dated May 5, 1997, entitled agricultural inspection: improvements needed to minimize threat of foreign pests and diseases. U.S. Department of Health and Human Services, Food and Drug Administration, 1982. Proposed regulation for the use of irradiation for the treatment of food Environmental assessment, September 1982. 102 VI. References U S. General Accounting Office, 1997. Report to Congressional Committees, agricultural inspection, improvements needed to minimize threat of foreign pests and diseases. GAO/RCED-97- 1 02. May 1997. Wilson, E.O., 1992. The diversity of life, 424 p. W.W. Norton & Co. VI. References 103 [This page is intentionally left blank.] 104 VI. References VII. Appendices A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement B. Court Documents C. Documents Related to Compliance D. Acronyms E. Glossary F. Final Rule on Importation of Logs, Lumber, and Other Unmanufactured Wood Articles [This page is intentionally left blank ] Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement APHIS received 42 comment letters prior to the close of the comment period on February 10, 1998. In addition, 19 comment letters were received after the close of the comment period but in time to be analyzed. Copies of these 61 letters are included in this appendix. Several additional comment letters were received, but were not received in time to include in this appendix. These additional letters did not provide any new information that was not included in previous comment letters. In fact, all of the additional letters were similar to others that were received in that they expressed concern over the possibility of exotic pest species being introduced and becoming established in the United States, and requested a ban on the importation of raw logs. Many of the comment letters provided technical corrections that were incorporated into the final supplement to the environmental impact statement (SEIS). The comments also pointed out areas where the draft SEIS was unclear. All of the comments that were received were carefully considered, and the draft SEIS has been revised and finalized accordingly. While considering the comments, the Animal and Plant Health Inspection Service (APHIS) identified 16 primary issues that were themes in many comment letters. The issues are addressed in no particular order. The numbers appearing in the margins of the comment letters contained in this appendix correspond with the numbered issues identified below. ISSUE 1: Many commenters maintain that only the heat treatment of virtually all unmanufactured wood imports can ensure that they would be relatively pest-free, although some commenters believe that there are shortcomings with heat treatment that were not disclosed in the draft document. RESPONSE: Heat treatment is the most effective way to guarantee that wood is free from all plant pests. When coupled with safeguards to protect from reinfestation and with an effective monitoring system in place to ensure compliance, heat treatment is currently the best protective measure known. The heat treatment requirements of the wood import regulation were determined after careful consideration of the scientific literature, years of industry experience, and comments received from numerous experts. In fact, as pointed out in the environmental impact statement (EIS), the current heat treatment requirements were accepted at the urging of numerous commenters during the comment period prior to finalizing the Appendix A. Summary of Public Comments on the Draft Supplement A-1 to the Environmental Impact Statement wood import regulation. It is acknowledged that when the requirements are met, heat treatment is effective against pests. However, it has not been demonstrated that facilities exist to economically heat treat large shipments of logs. The universal entry requirements in the wood import regulation rely primarily upon heat treatment (see table 4-9). Any wood product, from anywhere in the world, can enter the United States if the heat treatment requirements, as outlined in the universal entry requirements, are met. However, the heat treatment requirements can be difficult or impossible to meet without altering the characteristics of the wood article, depending upon the type of imported wood product. Often, heat treatment is not the only mitigation method that can be justified by the pest risk. The Minimal Impact Principle of the General Agreement on Tariffs and Trade (GATT) (Sanitary and Phytosanitary article 5, paragraph 6), specifies that plant protection measures should not be more restrictive of trade than required to achieve the appropriate level of protection. If heat treatment at the point of origin is the only mitigation measure justified by the pest risk, then APHIS should require it. The mitigation requirements that APHIS places on international trade must be consistent with the pest risk involved and not be more restrictive than necessary to meet our phytosanitary goals. For example, heat treatment is not a required mitigation measure for importing logs and lumber from Canada because the pest complex is nearly identical to that of the United States. Another example is the carefully managed plantation-grown Pinus radiata from Chile and New Zealand. The minimal number of forest pests associated with these log imports can be successfully mitigated without resorting to heat treatment at the point of origin. APHIS will continue to abide by the Minimal Impact Principle of GATT when examining future requests for the importation of wood products. APHIS will not compromise its goal of protecting the Nation’s forests from the establishment of exotic pests, but will continue to achieve this goal consistent with international obligations. ISSUE 2: Some commenters contend that the potential for noncompliance with APHIS rules by exporting countries has not been adequately analyzed, that the potential for noncompliance indicates the need for independent certifications, that stronger penalties for noncompliance are needed, and that the environmental consequences of noncompliance are not addressed. RESPONSE: Noncompliance means that mitigation measures are not being applied as required by the wood import regulation. When this A-2 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement occurs, the effectiveness of the regulation is reduced and the potential for environmental impacts increases. The threat of a pest infestation resulting from noncompliance has not been precisely determined; however, the overall threat is probably not of a large magnitude. Regardless of the overall magnitude of risk, it is realized that only one infested shipment can result in the introduction of a foreign pest that could become established and cause severe environmental damage in the United States. Not only would a pest damage forest resources, but efforts to control, manage, or eradicate (if possible) the pest would likely involve the use of pesticides and other measures that would have adverse environmental impacts. Unintentional noncompliance by exporters in foreign countries may occur because the regulation is new, but unintentional noncompliance is expected to rapidly decline as foreign exporters and U S. importers become more familiar with the regulation and its enforcement. While APHIS has published the rule in the Federal Register and it has been publicized in the foreign trade community, one of the most effective ways to achieve compliance is through enforcement at the port of entry. As shipments are delayed or refused entry, steep financial costs, relative to potential profit margins, are incurred and a noncompliance situation is rapidly reversed. There is less probability for intentional noncompliance. Although, as regulations become more stringent, the potential for smuggling also increases. Any smuggling activity would be in criminal violation of laws and regulations of the United States. In addition, it is a costly process to surreptitiously transship commodities in bulk from the country of origin into the United States. It becomes even less enticing financially when compared to the consequences of detection. The harm that could be suffered should pest-infested unmanufactured wood products be illegally imported, either intentionally or unintentionally, into this country is as severe as any harm associated with other pest exclusion system failures considered in the SEIS. For this reason, the movement of unmanufactured wood articles into this country is monitored closely. Section 1505.3 of the Council on Environmental Quality’s (CEQ) implementing regulations under the National Environmental Policy Act (NEPA) states in part that “[a]gencies may provide for monitoring to assure that their decisions are carried out and should do so in important cases.” Where, as here, implementation of a proposed action involves some uncertainty concerning risks to the quality of the human environment, monitoring is especially appropriate. Accordingly, a monitoring system, which makes maximum use of existing procedures, mechanisms, and protocols already in place with APHIS and the U.S. Customs Service, is Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-3 used to track imports of unmanufactured wood articles to ensure, insofar as possible, that noncompliance does not occur. Several commenters believe that the penalties assessed because of noncompliance are insufficient to act as a deterrent. The current penalties are prescribed by Congress. A violator of the wood import regulation is subject to civil penalties, criminal fines, and jail sentences. APHIS also has the authority to revoke permits and compliance agreements, refuse entry of wood products into the United States, and delay wood product unloading. Refusal of entry of wood product cargo and the subsequent departure of the loaded ship, or delay of wood product unloading at U.S. ports, is extremely costly to the shipper and the ship owner. The possibility of revocation of a wood import permit and the subsequent loss of the U.S. market are economically damaging consequences of noncompliance. Many countries go to great lengths to protect their export business, and the loss of markets in the United States could be a major setback. In order to assist their exporters in meeting U.S. requirements, at least two countries, Chile and New Zealand, have included APHIS wood import requirements in their procedures for export. Chapter IV, section B .2.c. of the SEIS contains a discussion of how APHIS regulates the certification program for unmanufactured wood products. APHIS is responsible for protecting this country’s agricultural resources and its forest resources from exotic plant pests and will only accept certificates from an official foreign government agency. In a sense, the role of APHIS, as an agency of the U.S. Department of Agriculture (USDA) and as mandated by Congress, is to serve as a third party between the exporter and importer to protect the United States from plant pest infestations. APHIS and its inspectors have no financial interests in the potential importation process and have clear legislative mandates to protect U.S. interests. APHIS requires that the “Phytosanitary Certificate or other mutually agreed upon document” be issued by the Ministry of Agriculture/Forestry of the exporting country. A nongovernment entity cannot issue such documents. APHIS does not accept certification from other than official, designated government agencies. At this time, APHIS does not have a preclearance program for unmanufactured wood products. If APHIS does introduce such a program, the public will be notified by a Federal Register notice. In the notice, APHIS will describe the preclearance program and solicit comments from the public. ISSUE 3: Some commenters were concerned over the impact of the methyl bromide phaseout required by the Clean Air Act. Others expressed A-4 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement concern about whether it is even effective to use methyl bromide fumigations at all. RESPONSE: According to the wood import regulation, an importer must satisfy one of three sets of requirements to import wood products into the United States: the requirements for specified articles (see table 4-8), the universal importation requirements (see table 4-9), or the requirements for a general permit (see table 4-10). The general permit is reserved for wood products from Canada and the border states of Mexico, packing materials that have met certain standards, and for semi-processed wood articles that previously were issued specific permits but that have been found to present an insignificant pest risk (see table 4-8). The universal import requirements (see table 4-9), for most products, require heat treatment of articles either prior to arrival at a port of entry or within 30 days of import (for raw lumber from areas other than east Asia, Chile, or New Zealand). Any wood article can be imported if it meets the universal requirements. Specified articles are allowed entry under conditions other than those provided under the universal import requirements if alternative mitigation requirements can be demonstrated to ensure a safe importation. This standard often includes fumigation. Methyl bromide currently is the only fumigant approved for use in meeting the wood import requirements. Despite the fact that international treaty (the Montreal Protocol) allows for exemptions for quarantine uses to the phaseout schedule of methyl bromide, the Clean Air Act prohibits the production and importation of methyl bromide into the United States after January 1, 2001. Soon after that date the existing stocks of methyl bromide in the United States are likely to be exhausted and methyl bromide will no longer be available for quarantine uses in the United States. Domestic production of methyl bromide for any use after January 1, 2001, will require an administrative decision and/or a statutory change. At this time, it is unclear if currently available methyl bromide treatments that occur overseas still will be permitted under the wood import regulation. If methyl bromide is not available, importers will have two options to choose from: import wood articles under the universal import requirements (primarily heat treatment) or find another fumigant that can replace methyl bromide. Other fumigants that may be efficacious could be used, but only after they have been accepted by APHIS and the regulation is or has been changed to accept their use. One commenter stated that while table 4-1 indicated a need for research into the efficacy of methyl bromide against pathogens, the problem was not a lack of toxicity data, but the inability of a fumigant to penetrate to the core of a log or wood article in sufficient concentration to kill pathogens. Pathogens can be difficult to kill and, generally speaking, the exposure time Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-5 to a fumigant must be increased to ensure total kill of pathogens. The fumigation time necessary to kill all pathogens (surface as well as deep wood pathogens) with methyl bromide is uncertain. The physical problem of fumigant penetration at a sufficient concentration and for a sufficient length of time to kill pathogens may prove to be impractical to overcome in all cases. Another commenter was concerned about other uncertainties associated with the methyl bromide control method. Specifically, the commenter noted that methyl bromide schedule T-3 12 was developed for oak wilt fungus infecting oak logs and schedule T-404 was developed to address bark beetles and “efficacy of these two schedules against other pests is unknown.” As described in chapter IV, section B.l.(c) (Uncertainties Regarding Control Method Efficacy) of the SEIS, it is infeasible to test a particular control method against every known or potential pest species. Normally, once a method is accepted as efficacious against a pest, the results are considered applicable to other similar species. This was illustrated in the text with the example of heat treatment. Methyl bromide is widely accepted as efficacious against most, if not all, organisms. However, the specifics about exposure time and fumigant penetration of physical barriers that must sometimes be overcome to reach the pest have not all been resolved. Where it has been shown not to be efficacious, methyl bromide is not required. The information known about methyl bromide efficacy against wood pests and pathogens is summarized in tables 4-1, 4-3, and 4-4. These tables indicate that methyl bromide will provide extensive to total reduction of pest risk but that additional research is needed for determining the most effective schedules for use against specific pathogens. ISSUE 4: Some comment ers believe that the draft SEIS did not adequately address endangered species/biodiversity issues. RESPONSE: The sections, “Biodiversity” and “Endangered and Threatened Species,” of the Comparison of Alternatives (chapter IV, sections C.3 .e. and i.) have been expanded. The relative ranking of the impact each of the alternatives would have on endangered species and biodiversity is presented in figure 2 of the SEIS. These impacts range from not affecting biodiversity or endangered species in the United States (by prohibiting unmanufactured wood imports, alternative 6) to greater relative impacts to endangered species and the existing biodiversity in the United States (alternatives 4, 2, 5, 3, and 6). There is substantial evidence to support the belief that the loss of biodiversity is a serious and accelerating world-wide problem and that the introduction of nonindigenous organisms may contribute to the problem. The purpose of the wood import A-6 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement regulation is to reduce the risk of introduction of exotic plant pests to a negligible level. ISSUE 5: Wood “smuggling” into the United States through Mexico and Canada has not been adequately addressed, in the view of some commenters. RESPONSE: Title 7, Code of Federal Regulations (CFR), Parts 300 and 319, authorize USDA, APHIS, to issue a general permit for importation of wood articles from Canada and the Mexican border states without restriction. This practice would remain unchanged under each of the alternatives in the SEIS, exept for alternative 1. Because wood articles from Canada and the Mexican border states are subject to fewer restrictions than wood articles from other export countries, commenters have suggested that attempts may be made to circumvent the regulation and illegally pass wooden articles from outside Canada or Mexican border states, through those regions, into the United States. Commenters basically seek consideration of the potential risks to environmental quality that could be caused by criminal acts of third parties. The harm that could be suffered should pest-infested unmanufactured wood products illegally be imported through Mexico or Canada into this country is as severe as any associated with other pest-exclusion system failures considered in this document. Smuggling would violate the U S. laws and regulations. Add to that the cumbersome and costly process of surreptitiously shipping commodities in bulk from the country of origin, through one or more additional countries, into the United States, and the scheme becomes quite difficult to manage. Deterrents to noncompliance with Federal Quarantine Regulations include civil penalties; criminal fines; jail sentences; and loss of revenue due to rejection of commodities, permit applications, and/or compliance agreements. Still, the risk of harm from such a low-probability event is far from inconsequential. For this reason, consistent with prevailing laws and with treaty obligations, the movement of unmanufactured wood products from Mexico and Canada into this country is closely coordinated In accordance with section 1505.3 of the CEQ implementing regulations under NEPA , a monitoring system, which makes maximum use of existing procedures, mechanisms, and protocols is used to track imports of unmanufactured wood articles from Mexico and Canada. The monitoring system assures, insofar as possible, that wood smuggling through those countries does not occur. The issue of imports from Mexico also is addressed in issue 14. Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-7 ISSUE 6: Mitigation measures that are ineffective individually cannot, according to several commenters, prevent severe pest infestations, nor can they be assumed to be effective collectively because no risk assessment was prepared on this issue, although some commenters disagree that individual measures cannot be effective collectively. RESPONSE: When developing the risk mitigation requirements for the importation of Pinus radiata logs from New Zealand and Chile and Douglas-fir logs from New Zealand, great care was taken to match the available mitigation measures with the potential forest pests identified in the risk assessments. The individual mitigation measures were selected because they were effective in reducing the pest risk and they conformed to the requirements of the GATT SPS agreement. Methods that are effective against some pests but not others have been combined to complement each other and reduce pest risk to a negligible level. Mitigation requirements which are ineffective have not been required. Each of the individual mitigation steps was carefully screened to ensure that it would reduce the chance of one (or more) of the identified exotic forest pests from becoming established in North America as demonstrated in tables 4-3 and 4-4. Although no single mitigation measure (until the final heat treatment) is effective against all types of pests, each mitigation measure demonstrates either extensive reduction (95%+ mortality) or total reduction (approximately 100% mortality) to one (or more) of the identified pests. The two exceptions to this are (1) the 45-day limit from harvest to shipping and (2) APHIS’ port-of-entry inspection and in-country processing requirements. These measures do not treat infested wood articles, per se. They are designed to reduce the risk of postharvest woodborer infestations and to provide additional monitoring for failures in the system so that any failures may be corrected. As demonstrated in tables 4-3 and 4-4, the pest risk from all of the groups of pests is totally or extensively reduced prior to entry into the United States. Then, within 30 days of entry into the United States, the mitigation measures totally reduce the expected pest risk from every identified group of pests. The combination of complementary mitigation requirements results in a total package which effectively reduces the total pest risk to a negligible level. The effectiveness of these measures is thought to be high, since no plant pest or pathogen of quarantine significance has yet been found on logs meeting the above import requirements — in spite of extensive examination by Federal and State regulatory agencies. A-8 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement ISSUE 7: Some commenters indicated that trade was given preference in the draft SEIS over environmental protection, and other commenters indicated the opposite. RESPONSE: A number of commenters stated that APHIS is either (1) being overprotective and not meeting the minimal impact obligations as outlined in the GATT SPS agreement, or (2) compromising its plant protection function by attempting to minimize the impact on international trade. APHIS is fully committed to protecting the Nation’s agricultural resources and its forest resources from exotic plant pests, but it also has the obligation not to unduly and unjustly impact international trade. Attempts are continually being made to ensure that when mitigation measures are required by the wood import regulation that they impact international commerce only to the degree needed to meet APHIS’ plant protection goal of reducing plant pest risk to a negligible level. To go beyond this protective standard would be considered unfair trade restrictions under GATT and subject to challenge by other trading partners in the World Trade Organization. ISSUE 8: Data, including details about economic, social, and health care costs associated with pest eradication programs, are not adequately developed, according to several commenters. RESPONSE: A summary of the Final Economic Analysis of the proposed wood import regulation was included in the draft SEIS; copies of the complete Economic Analysis are available by request from APHIS. The Council on Environmental Quality (CEQ) implementing regulations under NEPA do not require that an economic analysis be prepared on the alternatives; only that if an analysis is prepared, then the information shall be incorporated by reference (40 CFR 1502.23). Specifically, the CEQ implementing regulations state that the “weighing of the merits and drawbacks of the various alternatives need not be displayed in a monetary cost-benefit analysis and should not be when there are important qualitative considerations.” Any further economic analysis of each alternative in the final SEIS would be speculative and would distract from the important qualitative considerations of the decisions. Both the EIS and SEIS discuss the losses to U S. forest ecosystems from historical pest infestations (see chapter I, section B of both the EIS and SEIS). These costs or losses extend beyond economics into important qualitative considerations. For example (as discussed in both documents), Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-9 chestnut blight virtually eliminated the American chestnut tree, which at one time was a substantial component of our hardwood forests. An estimated economic loss from another devastating forest pest could be in the billions of dollars. The qualitative and aesthetic losses to our hardwood forest ecosystems are at least as significant. The final EIS discusses the significance of these types of losses and provides numerous examples of the high costs of pest control efforts and their often limited success. The wood import regulation and the five alternatives currently being considered in this SEIS were in fact developed in an effort to prevent such pest introductions and subsequent economic and environmental losses. Attempting to assign a dollar value to all of the commercial (quantitative) and noncommercial (qualitative) values of these losses could prove to be interesting. However, it also would be highly speculative information and would not assist the reader and the responsible officials in their decisions. By reducing all such losses to dollar values, such an analysis could underestimate the importance of some species that could be or have been impacted. By assigning greater value to commercially important timber species over noncommercial species — which may have significant biological or aesthetic characteristics, but whose qualitative values cannot be translated into dollar values — such an economic analysis would confuse rather than clarify the issues. The SEIS (chapter I, section A) also characterizes the potential losses from future infestations, and states that “once a defoliator is established, eradication would be unlikely.” Similarly, the document presents examples of both cost and effectiveness for control programs related to the eradication of the European and Asian gypsy moths. As pointed out in the CEQ regulations — Most important, NEPA documents must concentrate on the issues that are truly significant to the action in question, rather than amassing needless detail. Ultimately, of course, it is not better documents but better decisions that count. NEPA’s purpose is not to generate paperwork — even excellent paperwork — but to foster excellent action. The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and enhance the environment. (40 CFR 1500. 1(b), (c)). Our forest ecosystems and agricultural production certainly represent valuable resources. The question at hand, as presented in this EIS process, A-10 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement is how best to realistically achieve the protection of those resources given what we do know and what is reasonably foreseeable from a scientific, technical, historical, environmental, and operational perspective. In accordance with the NEPA regulations, the EIS (chapter IV, section B. 1.) discusses the human health effects from the six alternatives that are “reasonably foreseeable” (40 CFR 1508.8). The draft SEIS discusses the reasonably foreseeable health effects of control and eradication efforts. This is a programmatic document which is required for “broad Federal actions such as the adoption of new agency programs or regulations” (40 CFR 1502.4(b)). APHIS will tier additional environmental analyses to this broad programmatic EIS as required by the CEQ regulations (40 CFR 1502.20). Thus, APHIS will be “tiering” from this programmatic EIS “of broad scope to those of narrower scope” (40 CFR 1500.4(i)). If a pest infestation does occur, an environmental analysis will be prepared before action to control or eradicate the pest is undertaken. It would address the specific health effects that could be associated with the particular control measures being considered for an infested area. To speculate what infestations could occur under the six alternatives being considered in this programmatic EIS, as well as where they could occur, what control measures might be available and appropriate, and what the affected biological and human populations could be, would be endless and highly speculative and would neither be helpful to the decisions at hand nor appropriate for a programmatic EIS. ISSUE 9: Some commenters have expressed the view that definitions of terms should be included in the SEIS to provide clearer guidance to the reader. RESPONSE: A glossary is provided in this SEIS and additional terms have been added or revised. For the purposes of the final SEIS, the definition for the term “saw log quality trees” has been expanded in the glossary (chapter VII, appendix E) to read “ Pinus radiata trees from Chile and P. radiata or Douglas-fir trees from New Zealand that are plantation- grown and are living, healthy, and have no apparent signs of disease or pest infestation.” Heat treatment is defined in the glossary as “A process of using heat or heat with moisture reduction to raise and maintain the internal temperature of the wood to 71.1 °C for a minimum of 75 minutes or adherence to the procedures outlined in Dry Kiln Operator’s Manual.” The procedures contained in the Dry Kiln Operator’s Manual are too lengthy to be reproduced in the final SEIS; however, that document has been added to chapter VI, References Cited. Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-1 1 Certain terms do not appear in the glossary of the final SEIS, and are best handled through examples. The terms “manufactured wood” and “unmanufactured wood” are not defined. However, examples of wood articles that are regulated under the wood import regulation are specified in tables 4-6, 4-7, 4-8, and 4-9. Furthermore, a hypothetical example of how various wood products destined for import into the United States would be classified and treated under each alternative is contained in chapter IV, section C.3. Rather than relying on a rigid definition of “unmanufactured” versus “manufactured” in determining semi-processed wood commodity entry status, APHIS considers on a case-by-case basis the effectiveness in reducing the pest risk of the individual manufacturing processes used in creating the wood commodity. Characterizing the many various and diverse types of wood products as unmanufactured or manufactured would be an enormous task, would be subject to debate, and would not alone determine the risk of forest pest entry. ISSUE 10: A number of commenters contend that inspections conducted within the integrated program are unlikely to be able to prevent pest introductions and that this risk is not adequately developed in the draft document. RESPONSE: The SEIS does not claim that inspections, by themselves, can prevent all or most pest infestations. In fact, the acknowledgment that they cannot was the initial impetus for promulgating the wood import regulation. Prior to the regulation, inspection was the only mitigation measure available to APHIS for wood imports, and the need for more effective mitigation measures was recognized. It is stated in the SEIS that inspection alone is insufficient to protect against pests which could be associated with wood imports. Inspections, however, are a valuable part of an integrated program designed to prevent the establishment of exotic plant pests. Inspections help ensure compliance with the requirements of the regulation. They provide a mechanism for verification that the permitting and certification requirements have been met. They also provide some measure of mitigation, but because of the difficulties involved with physically inspecting large shipments of commodities such as logs, inspection certainly cannot stand alone as a mitigation measure. Inspection also serves as a tool for monitoring the success of the wood import regulation. ISSUE 11: Several commenters stated that experience with the rules to date demonstrates their efficacy, although some commenters maintain that the rules have not been in place long enough to support that contention. A-1 2 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement RESPONSE: Several commenters stated that the rule needs to be strengthened, while others believe it fulfills its intent to protect against exotic pests. One commenter suggested the rule was overly stringent and should be relaxed. A number of commenters, however, pointed out a misleading statement on page 42 of the draft SEIS (chapter IV, section B.2.d ): “APHIS’ experience, during the short period that the wood import regulations have been in effect, indicates that they have successfully prevented quarantined pests from entering the United States.” This statement has been withdrawn from the final SEIS and a new section added (chapter IV. section D.6.). This new section discusses interception records since the wood import regulation took effect. The reader is referred to that section. Several commenters also pointed out that pests, such as the pine shoot beetle and Asian long-horned beetle, recently have been introduced into the country. While these pests were introduced prior to the effective date of the wood import regulation, commenters believe the regulation would not have prevented their introduction. While this is theoretical in nature, we do know that pest interception data gathered since the regulation took effect indicates that the portions of the regulation that address dunnage and the Mexican border state exemption should be revisited (see issue 14 and chapter IV, section D.6.), which APHIS is doing at this time. ISSUE 12: The degree of uncertainty surrounding the risk of pest introduction has not been adequately addressed in the draft SEIS and there has been no valid risk assessment that includes uncertainty. RESPONSE: Uncertainty is inherent to scientific research, and the evaluation of invasive organisms and pest infestations is no exception. It is acknowledged that there are pests which are hidden on their native hosts and have, therefore, not been identified as pests. These organisms have the potential to become pests should they enter and become established in the United States. It is also acknowledged that if the United States is to participate in international trade, some degree of risk will always be present. This is true for all types of exotic pests and pathogens, not just those that impact native forests. The individual pest risk assessments, which form the basis of the SEIS, used the best available scientific information and included the expert opinions of scientific authorities. In both the pest risk assessments and the SEIS (e g., chapter IV, section B), uncertainty surrounding pest risks and the corresponding mitigation requirements are addressed. The scientific knowledge regarding known forest pests and the risk they pose to forest resources in the United States has been summarized in the pest risk Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-13 assessments. Those documents also specify that while a certain amount of knowledge exists regarding forest pests, there are gaps in scientific information, and uncertainties exist regarding the potential for pest movement into the United States. The identification of these gaps initiates a cautious approach in developing mitigation measures (the less information, the greater the caution). The wood import regulation, while directly focused on existing scientific information regarding forest pests, also attempts to provide some reasonable protection against unknown forest pests — especially pests from forest ecosystems which currently have little forest pest data. The wood import regulation is not intended to reduce the pest risk to zero, but to lower the pest risk to a negligible level without imposing unnecessary regulatory constraints. When new information fills in the gaps in scientific knowledge, this data will be incorporated into the decisionmaking process to determine if any modifications to the regulation are justified. ISSUE 13: Some commenters contend that the impact of the rule on cultural resources of Native Americans has been overlooked. RESPONSE: Additional information, specific to Native Americans, has been added to chapter IV, section C.5.h. The current wood import regulation greatly strengthens APHIS’ ability to protect the Nation’s forests from the establishment of exotic forest pests. This benefits all segments of the American people who value our forests, including Native Americans. All segments of the American public were encouraged to comment upon the wood import regulation, the accompanying EIS, and the draft SEIS. Comments were received and considered from Native Americans. ISSUE 14: According to some commenters, the draft SEIS does not adequately develop the issue of risks associated with dunnage, and a pest risk assessment on that issue is needed. They also contend that the agency has not acknowledged a pending new risk assessment on wood products from Mexico. RESPONSE: APHIS is currently collecting information on the risk associated with dunnage, crating, and other solid wood packing materials moving with international commerce. The recent findings of the Asian long-horned beetle and the pine shoot beetle in North America, along with specific interception information from the ports of entry on solid wood A-14 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement packing materials, have demonstrated that the international movement of solid wood packing material is a plant pest pathway of concern.1 Although the current wood import regulation has reduced the risk of pest introduction compared to the preregulatory period by requiring the removal of 100 percent of the bark on solid wood packing materials, it is apparent that this pest pathway needs to be reexamined in greater depth. APHIS and its sister plant protection agencies in Canada and Mexico, through the North American Plant Protection Organization (NAPPO), are developing an international standard for solid wood packing material. The first draft of the NAPPO Standards for Phytosanitary Measures on the “Import requirements for wooden dunnage and packing materials from sources outside of North America” was released on October 9, 1997. Currently, APHIS is evaluating and continuing development of the draft along with its sister agencies in Canada and Mexico. The intent of this document is to determine the best approach for regulating solid wood packing materials and to try to adopt consistent regulatory actions throughout North America. If a change is appropriate, APHIS will propose new import requirements to the wood import regulation. This will include meeting in full the requirements of the Administrative Procedures Act and the National Environmental Policy Act. In 1996, APHIS asked the U.S. Forest Service to look into the pest risk of importing pine and fir logs into the United States from Mexico. APHIS made this request because of an increased interest in importing Mexican pine and fir logs. The U.S. Forest Service responded by establishing a team of forest experts and scientists to evaluate the risk of importing these softwood logs into the United States. The final document “Pest Risk Assessment of the Importation into the United States of Unprocessed Pinus and Abies Logs from Mexico” became available in February 1998. The pest risk assessment is summarized in chapter IV, section D.5. of the final SEIS. This risk assessment contains new, detailed information on a number of potential forest pests which could be found on unprocessed hardwood and softwood logs and lumber. APHIS has appointed a Mexican Log Risk Management Team to evaluate the new information contained in the risk assessment. Part of this team’s charge is to reevaluate the Mexican border exemption. If a change is appropriate, APHIS will propose a change to the wood import regulation. 1 Dawson, J.L.M., Bell, J.O., Allen, E.A., and Humble, L.M., 1997. Exotic insect interceptions from wooden dunnage and packing material. Presented at the North American Plant Pest Organization, November 1997. Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-1 5 APHIS will continue to request that the U.S. Forest Service conduct specific wood import risk assessments to ensure that the wood import regulation is based on the best scientific information available. For example, APHIS has requested that the U.S. Forest Service look into the pest risk associated with importing South American plantation-grown and managed Eucalyptus logs. As with the pest risk assessment for logs from Mexico, APHIS will reevaluate its regulation in light of any new scientific information. ISSUE 15: Some commenters maintain that alternatives developed in the draft document are inadequate and have not been adequately compared. RESPONSE: As required by NEPA and the CEQ regulations, the EIS and SEIS fully consider, at a programmatic level, a broad range of reasonable alternatives. While other alternatives or variations on alternatives considered in the EIS could be developed, the six alternatives (ranging from no Federal action to prohibition of all unmanufactured wood articles) that have been presented for consideration by the public and decisionmakers are representative of the full range of alternatives. The Comparison of Alternatives, chapter IV, section C of the SEIS, has been expanded to better explain how the relative rankings of the alternatives were derived regarding both their effectiveness at pest exclusion and their environmental consequences. In the SEIS, we have made a concerted effort to display, compare, and contrast the alternatives’ strengths and weaknesses given the information that is currently available. The final SEIS (chapter IV, section C.3.) also presents an expanded discussion of the treatment methods that could be applied and provides an example to walk the reader through the treatment of a hypothetical shipment of wood products. This is a programmatic document that is using the best information currently available. Regardless of the pest exclusion method used or the alternative considered, uncertainties, risk, and data gaps do exist. Similarly, speculation beyond a historical and general nature of the possible consequences of pest infestations, changes in international markets, compliance possibilities, potential new treatment methods or chemicals is endless and speculative. We believe that historical examples best demonstrate what is at stake. ISSUE 16: A frequent comment, often the sole comment in the correspondence, was that banning log imports is the only way to protect forest resources in the United States. A-16 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement RESPONSE: The current entry requirements contained in the regulation for log imports attempts to match the pest risk with the degree of phytosanitary protection by allowing entry of all logs, from anywhere in the world, if they meet the universal requirements for heat treatment. The heat treatment requirements have been demonstrated to be effective against all known forest pests and pathogens. Coupled with adequate safeguards to insure compliance and to prevent accidental reinfestation, importation of these logs represents a negligible pest risk. For specific types of log imports which demonstrate less of a pest risk, other less demanding mitigation requirements are provided. For example, log imports from Canada, because the country shares a nearly identical forest pest complex with the United States, are allowed entry requiring only a proof of origin. Some other examples, each with its own specific set of mitigation requirements matched to the pest risk, include small shipments of tropical hardwood logs moving into temperate climates, plantation-grown Pirns radiata logs from New Zealand and Chile, and small shipments of (non-Asian) temperate hardwood logs. All requirements were carefully considered and designed to reduce pest risk to a negligible level. The function of the regulation is to protect the Nation’s forests from the establishment of exotic pests. In accordance with the Minimal Impact Principle under GATT (SPS article 5, paragraph 6), the mitigation requirements that APHIS places on international trade must be consistent with the pest risk involved and not be more restrictive than necessary to meet our phytosanitary goals. In addition, APHIS must accept other mitigation measures, which are equal in protection to, but not necessarily identical to, our own, as stated in the Equivalence Principle under GATT (SPS article 4). When prohibiting or restricting the importation of unmanufactured wood products, APHIS must consider pest risk and all available mitigation measures. Even if APHIS placed a complete ban on log imports, this action alone would not provide much additional exotic forest pest protection over existing entry requirements. Except for logs imported from Canada, foreign log imports generally have been small, intermittent, and carefully monitored for quality and plant pests both by industry and State/Federal regulatory agencies. However, as noted in the EIS and SEIS, there is the potential for large shipments of logs from New Zealand and Chile. Compared to the movement of lumber, wood chips, solid wood packing material, and numerous other types of wood products entering the United States, log imports are currently only a small part of the exotic forest pest risk equation. To be effective, the regulation has to address all major pathways that exotic forest pests can enter and become established. A Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-17 simple ban of all log imports will address only one relatively small pathway for the introduction of exotic pests. A-18 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement List of Commenters The following is a list of the commenters by the order in which their comments were received. Their comments follow this list. 1 . Stephen L. Wood, Professor Emeritus Brigham Young University Provo, UT 2. Charlotte Shoemaker Berkeley, CA 3. Jeffrey J. Morrell Oregon State University Corvallis, OR 4. Patricia Clary, Executive Director Californians for Alternatives to Toxics (and affiliated groups) Areata, CA 5. David Gordon, Acting Executive Director Pacific Environment & Resources Center Sausalito, CA 6. Charlotte Shoemaker Berkeley, CA 7. David Pilz Corvallis, OR 8. Jeffrey K. Stone Oregon State University Corvallis, OR 9. Mark Fleming, International Procurement Forester Crown Pacific Bend, OR 10. Bayard H. McConnaughey, Professor Emeritus University of Oregon Eugene, OR 11. and 12. John D. Lattin, Professor Emeritus Oregon State University Corvallis, OR Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-19 13. Ruth Niswander Davis, CA 14. Lynell Fay Oceanside, CA 15. Ron Huber, Director Coastal Waters Project Rockland, ME 16. Denny Miles, Executive Director Oregon Small Woodlands Association Salem, OR 17. Bill Welsch, President Safe Alternatives for Our Forest Environment Hayfork, CA 18. Gwen Marshall Protect Biodiversity in Public Forest Network Cincinnati, OH Victor G. Soukup, President Ohio Native Plant Society Wyoming, OH 19. Dave Overhulser, Entomologist State of Oregon Salem, OR 20. Tim McKay, Executive Director The Northcoast Environmental Center Areata, CA 21. James V. Griffiths Chief Executive New Zealand Forest Industries Council Wellington, New Zealand A-20 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement 22. Danna Smith, Network Coordinator Ron Huber, Steering Committee Dogwood Alliance Cedar Mountain, NC 23. Kenneth R Munson, Manager Forest Productivity & Research International Paper Dallas, TX 24. Dorthea Zadig, Senior Agricultural Biologist State of California Sacramento, CA 25. Marc A. Seidner, President Fibreform Wood Products, Inc. Los Angeles, CA 26. David L. Wood, Professor University of California, Berkeley Berkeley, CA 27. Gregory H. Aplet, Forest Ecologist, and Robert M. Freimark, Assistant Director The Wilderness Society Seattle, WA 28. John P. McMahon, Vice President Weyerhaeuser Company Tacoma, WA 29. Craig J. Regelbrugge, Director of Regulatory Affairs American Nursery and Landscape Association Washington, DC 30. Daniel. J. Hilburn, Administrator Kathleen JR. Johnson, Supervisor John Griesbach, Plant Pathologist State of Oregon Salem, OR 3 1 . John Wood, Ambassador New Zealand Embassy Washington, DC Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-21 32. Michael Axline, Counsel Jenna App, Legal Intern Jennifer Frozena, Legal Intern Western Environmental Law Center Eugene, OR 33. Irene Ringwood Ball Junk LLP Washington, DC (on behalf of McPhillips Manufacturing Company, Inc., Mobile, AL) 34. David Gordon, Acting Executive Director David Martin, Program Associate Pacific Environment & Resources Center Sausalito, CA 35. Scott Berg, Director American Forest & Paper Association Washington, DC 36. Patricia M. Clary, Executive Director Linda Perkins, Mendocino Environmental Center Cecilia Lanman, Envrionmental Protection Center David Drell, Willits Environmenal Center Californians for Alternatives to Toxics Areata, CA 37. Fields W. Cobb, Professor Emeritus University of California, Berkeley Sagle, ID 38. Dan Zimmerman Californians for Alternatives to Toxics Glen Ellen, CA 39. LeifJoslyn Kensington, CA 40. Daniel Carvallo, Deputy Chief of Mission Embassy of Chile Washington, DC A-22 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement 41. Dennis A. Ostgard Schwabe, Williamson & Wyatt, P C. Washington, DC (on behalf of Terranova Forest Products, Inc., Bellevue, WA) 42. Mark Anderson, Resource Procurement Schmidbauer Lumber, Inc. Eureka, CA 43. Terry Lamers, Forestry Consultant Dallas, OR 44. Adrienne Reed Storey Klamath Forest Alliance Etna, CA 45. George Wooten Winthrop, CA 46. William C. Denison, Associate Professor Emeritus Oregon State University Corvallis, OR 47. Callie Jordan Mosier, OR 48. Jean and Robert DeSpain Visor, OR 49. Faith Thompson Campbell Western Ancient Forest Campaign Washington, DC 50. Doug Heiken, Western Oregon Field Representative Oregon Natural Resources Council Eugene, OR 5 1 . Richard E. Sanderson U S. Environmental Protection Agency Washington, DC 52. Kevin Smith, Conservation Director Royal Forest and Bird Protection Society of New Zealand, Inc. Wellington, New Zealand Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-23 53. Craig J. Regelbrugge Director of Regulatory Affairs and Grower Services American Nursery and Landscape Association Washington, DC 54. Mary L. Petrofsky San Francisco, CA 55. Chad Michael and Eleanor Gerould San Francisco, CA 56 Dan Durmont San Francisco, CA 57 Karen Ashikeh Union City, CA 58. David Schneider Berkeley, CA 59. Carl Linkhart Oakland, CA 60. Dariel Heitkamp Martinez, CA 61. Larry Schmidt Oakland, CA A-24 Appendix A. 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S.C CO 5 |£ co 5 o o «^o— . 5 ° c c^ C 1> — o c c a “D w w W- G C O o o 7^3 « S’ X ■ : © re » E .2 o -0 ,_• D.= E E utrdu-.-'S-- ^ £ 0 Ef’xX C^j E 5 x « Z'X u c - r2 2X re ~ re ^ c c - ^ x O > Cl re — X x re CJ CL) Q- « 3 ^ O c/d' 00 w 3 c >> 5 o C 1/ rt a (j re 73 re X c D V 7 P 1 1 1 c 2 c ^ •- >.2^ c cz re ^ 'G W id 00 > X c 3J re *- **/ re ,0 x C £ ^3 ■ cz c 3 u re to o g O 'c x £ cz (l, r re 41 X “O re 1/5 to- Cl E OJ ' to ■to- O re re CL) C re = .S s.E > 2 < ■“ u 5 b3 re o a-ix j= > C7 “ « o C X C) U O to § - SO X £ 0 0 re T3 C E Z ci ^ c Jg to; -o "c ■o o u y E ^ £ 1 S E g x .2 E u 5 " 13 a ■5 5 u- c- « O p c c -a n O' “ ^ c <0-00 0 S' eb re C/3 (L) CJ "O 3) C c cz X3 C 00 2 re o re CL X X w u o re ° — X — x — _ re 3 c O o •- X 0 X a; 3J 5/5 « ^ V £ •- E — ^ 3 £ c a. > Cl F cj c. ■ E X c 00 a >».£ 1 1 ° £ > - c ^ 8 « x a « c « z c y — n CA ; p o £ p i o H Cl — C t/t Cl x re c — £E=2 TO J? C o fN 00 IT) Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-47 s ffi ° E K > E 5 u g 5 <3 v Ti >* C CJ3N ~ N « .5 Z 32 Q 5 e "S S W -a s ! f U d g -t % S s. 0 S D N • s?. ■5 £ 5 j> £ ■« t; _ n 5 1/1 . < -O « a/ c 60 2 ^ t ^ t c 0 ™ S£ 0 S S >, £ 0 g 5 •g * £ £ » F 5- 2 "§ 0 0 u s s — U u § * £ u V C 0 g- 0 £ X tT ^ i s > a" 7 O k, ^ u |S|5W * iu [« tj ■t T3 wo _ 5 -v 2 S 5 | w> "K E i - N £ 0 7 e c “ “2 c 5 ” - S £ (0 CL E 5 a >% *, x 0 c r w £ -T3 0 ai 1 ^ § £ 3 x 0“ 3 4, ^ > a c £ 0 -J c TJ <0 C if S X S o « u X < u a.s ~ £* K ^ CT' O' JU Tu N q 2 c 3 U ^ 9i a; o> C T3 T) CL 3 ^ 3 CL Q >. 1/ X c. D ^ * a 0 2 U C 3 0 U W3 01 •!■* iJ Cfi 3 D 2 < < w N w 2 2' O H 0 2 j w 5 cn 0) u 0 Uh T3 C >— i (TJ 01 N s 01 z x rJ O o' » ro 0 $ C- rt x X 0 & 1 2 t/> u £ x E < o; 1/ o cs C rf £ c ^ A-48 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement US industry and market links. The US is an important and expanding market for NZ • the precedent this court case may set for ongoing or future distortions of wood forest products, KiLn Dried Timber (KDT) and manufactured wooden products m products (or other primary based products) trade into the US (or other) markets particular fhe US is NZ's fourth largest forest products market, currently at around through this lype of injurious legal action by NGO's 7 Commpntfl on Draft Supplement to EIS s § ^ £ II (0 to £ £ . §■« 111 £ c 5 3! to to « X £ H C * CL L M. K 2 to LT) u t* to if> 3 C D 73 3 H 2 3 CL 0 £ 73 f >. 0 C 1 2L 6 N ~ cr y to w ■£ JC 73 ** c to ^ o to u «/> p VI p as x y E N Z 73 .5 1 in - P d c RJ 3 CL C E fo O c CL ^ p x c to if > X if) £ la (X W3 = S. £ 2 5 * g o E •- O £ S O Z CL c/) £ 3 a, 60-5 ■S p .2 0 to Jij J" to $ tb X to <*. ^ o g - E 2i £ 5 CL _ | 1 e 5 8J J to to , o II CL p C t N _ Z w C T? §1 O to c P 3 73 73 to O u ^ 3 t: s cL u 0 0 § § s? X 5 5 ^ f < £ X to 73 ■£ S S tr. 73 to 1 1 3 t/T 5 " d ra VI w = g - S § s 2 !i x N ~ Z E r ^ X , "ra § s C : O o X C 73 P to o a X 1/1 a § c 73 to 1 1 -3 I cfij £ T5 to r E ^ x 5 to * ^ 0 -O 0 ^ to 'T U. •> to u 0 > p jrc . § e - x >- fc»n > V 0 x X E CL r bj c £ 3 S Z 4 :“ C I £ £ 73 x b ^ £ >. ■S fu 2 H CJ3 O & ^ 0 X c ~ E 5 •5 5 _ 73 — c iu | fe-g • ^ O ni -> c O 3 ” j s 2 J " E « I ^ » S £ £ £ 5 5 5 E to C to X C £ C (/) P D U- T >, r4 A-49 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement transmission of plant pests into the forests of the Southeast the Dogwood Alliance firmly urges the adoption of Alternative 6 ’Prohibit importation of unmanufactured wood' A-50 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement i V &• •a 5 % II li - -a o u p f * ■* § £ *1 hli ITj Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-51 A-52 C o W ^ o u «3 ^ U. 0. b b H .9 .£■ o . 2 S u O a «j u 0 a -3 E $g isM C CL -D 9 *5 a u .1 & <-> 3 q ?1 i» > , X -a- ja 43 m o a 73 "O So s -g 2 s 9 9 JJ' n _ oo f3 | B 0 s to •a .9 ■3 c c ^ t: 7 S 2 ,o C o 9 43 g 13 -3 > i/i o * E '6 u C/i ■a SN-a . B ? a J ■a z s f .a t n _s « -3 z g ■a fc. n3 O 5 S3 S3 3 n3 nj >s 13 ti u 3 -C u 5 S3 t* U4 00 Q. *3 fN Appendix A. 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Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement 00 GN CA ■5 s .5 £ !i -i CJQ S ^ ° 1 e a « £ 2 - -S o 6 6 JJ >, 5 S’ ^ I 3 z * .3 _ ~o 3 § E -o "S J! « - X - Cl ,oj c/i . to wi e !: i/> •— '£ x c ^ 3 •“ 5 t-~ E & O <-A u ■ — 1 J= 22 S -5 ^ I S a" -a > u < ^ O0 O 00 ^ Q •Jj ° "a “cd ■ « o -S u O ^ QO ■a -a ^ c *— ~ C O % feb <2 co - 2 E r- — ^ g k- ~ > Jg | “ 53 ^ D O ^ 3 W O rx > ■p -a rj <0 O O of a c p V u -— u GX) c c CU p - - 2 5 1 ^5 o ■■s-S'i *> >, O - .2 all P on an ■a g E c c § $ 5 ° rt co X> L. 5 > to -a J3 S ,5 2? !3 £ 0> Q£ C O 3 to co Q. 2 3 ^ O ^ > £ c 0 01 c 3 E ■o LU CO CD CD CO SCO a. = E W $ O) •- ?« “ x * « 1/) i/> — c/> X to $2 .r-i «xi Ij r>j T3 to _V> o o 1> c to Q o u Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-55 A-56 2 £ _C ^ ■5 o 1 * O -2 M O “ -C jc ~a - "25 2 ™ w "S ^ X c 1! 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J ‘C P ‘h « OB s O — - A 03 U — *3 eg $ ?« J ^ «G O C ^ ■S .s 2 to .2? -5 5 cj « *=r H £ 4/ c» Ji *o o. ja _ ^ ex S r | ^ S D. 3 rn ON Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-57 *<6 P3 •c i? £ ■- £ £ s c P c £ ■ 2 1 3 £ ^ j -S -S3 I -a OT C .O^ " IU miStl . 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Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement <: • - li ■3" 3r m LU X H £ * s £ F < c o : O E > -a g- « O O 3 O' oo — 3 W u, > c - ™ - Qj tx ) — , ° < = £ I 0 ^ £ b, E 1 ™ . g S s ° - Hf I^S 111 I S « O O " Q =2 | ’ C ; < : c o I lu a. 00 O > E £ 1 E £■ C 3 => on u. 2 E U W T3 w 0 > O 2 T3 ^ C P £ - > o 1 1 1 f 1 1 1 la c £• I E rt ^ ~0 F § o c >1 s rs c >. © p c c 5 S i.M-i e * M n. O = J= £ ■£ u f u iE C O 1> U c w t O ■— on to -5 c — a . C n £ c =xj E E 1 2 c * 1 H E — O — > w a UJ ~~ £ £- a: § E Q = c < - ^ £ >, .c « 1^1 § a ~a ^2 £ «5§„- I § 1 1 = ^ .E n 3 on c c o c T3 : p = ?| 1 i § -Si g> c. - E s a — o. a- E M.-S 1 t*g> S £ = - CJ L? a O CIj [ « a _2 C- C E u "3 -5 _E ^ 3 — r "E “ n ^ C T3 iX> E G 2 2 E c -H v — — “3 "O ^ C c O "O o *a E ^ ^ E - E > O O o «2 3 “O E j= r; n A. r- P c coo - T3 eli o v- -a o a P C3 *33 -S r- q. 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Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-59 3 QJ d x i— cu JU e q O "2 k s.a< , : £ oo o Q 2 LU LU cu D tt oo o _) on — oo LU *Z u 2 r - < S "2 c O -2 I Cl > §■ "O 13 q,) GO U- 3 d d ^ -r-i C ~ 2 c 2 .2 £ <~ a m ra So -vc £ M 5/3 £ u JD S « °. C ^ I - E C aj a _o ^ d E - 3 E O OJ 2 o a tS r E OJ ■— o o >> * <2 2 d o» 2 £ V X >. t: ^ ° £ z E E ■a r? 5 3 00 N Cl Cl O- “ = « - S -a o \§ " E- -o c 2 < £ 3 d £ j= c LU — ■|jjS 'u 3 o a . < s •«■ S E E q. _a 03 CU d 3 © O c V3 > cn 'z: .. 3C u t7i ^ o o Jr Cl o Q !2 .2 S. 3 C 1 -O o E< I < % y u. - ~ < 5 5- °2| S jj 1 8 £ E •= o o o c XT i» E ■§ c o o 2 a © d 00 OJ -“E « .£ E ^ > o> o •- > x> * o — c E •- •- 1 1 ■5 g § < i_ 00 ° S ? 32 ii r. ^ r3 ■— O 3 r= u ^ fo E „ s > 3 - o ^ •2 | f- = = -O O ^ cj u- .tr ° 3 C r « ° « CJ °- E -S' •- S' 2 O rt ■ — 5 I - — O £ 2s o E •£. >- O Cl Q- co a -O _ o = « o = c ^ < “3 ' ^ § J = 1 tr . o c p 1J 3 ° .3 h c w -C u - E ■ “ C3 ^ o O “3 5 0- E. 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Z ir .E o -3 § C X x 2 C3 C CL r3 0 c/) O w O — X > ■3 ^ .E o OO -3 o_ I ? S : 1 :S 1 2 o- >> o «2"= ._ u ■; ij > .2 c l- c D 01 3 QJ c E E P -s -S E c ^ £" 2? & ■§ o K _ £ S "5 £ % co - g rt « ;= « X : ' L. 3 "O ^ oo c X "I< < E 3" 00 00 flj O x £ _ ^ LJ- C X _ X 1 - U - i* » .3 X 3 75 O. X o «fc E -S .5 •e i 00 UJ — c Cl .3 O 03 3. 3 Q-U- .Ji c •3 O O § S (3 00 3 rg £45 2. x ^ C a. > .E O L. o VL» _ c_ u a> v oj ^ £! - 5 « z ■- . ~ o w a> o u 3 £ ^ o !” i O-I "c > 5 E 3 00 J5 i 2 H3 E -o Cl OJ .2 ZZ "3 X 3 *5 ^ s 1 1 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-61 From Craig Regelbnjgge To Jack Edmundson Date 2/10/98 Time 8 01 38 AM C3 C/j | x c c- £ < Q o> ll c. o c x 0 u C/> G 1 2 2 e- E T3 - UJ £ • G C £ O 2 W 5/1 > '55 £ j>^0 ii bO c TO c ^ 3 $8 1— ZZ. tc — < 'P N ^ £ cp c ^ ^ p o Q £ ca ^ ,0 & "2 > — C G UJ cu 2 o c G G X O E ClXT e-; 5 o-° ^ n -o 3 C £ Q) D- - ■£ Cl. 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TO • — ■ P J- ^ d 3 TO X TO ^ G w X G P •* G o -p ~ > TO g G $ E ^ TO CJ 2j * ■£ x c! to ;-r Mj 01) p £ CL 3 £ G x 5 p > ^ ^ -2 o t 13 TO Cj C “••H § -o E P ^ to 3 § -5 I : * ^ G 3 TT , 5 £ d ^ 2 *J X -C - X G X ^ G — G B z P I E c TO -3 E J CL ^ 0 CL U S TO TO _ G O - = n « Z Z TO <0-0 ~ E oo i.l g E x ^ _ 3 *p« x - *1 'J 5 4 ^ s 1 !§1 ^fl E -r >, 2 U ^ G 7. G C E i_ X 3 _ 3 *• £ U ^ » £1 r § .1 3 2 3 u 5 £ > i 1 S § I? E = - £ S t § t l\ 1 1 ’ e s : „ t QO ^ A-62 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement ^ 13 >> G g x u ~ X O ra C X c o .2 -C E CL< ■ 3 — X s s P- u. n c T3 g c 5 ra o x -c -g g ° ° c x x 0) G II S i 3 ti £ C -0 .2 g c o -a q-j< £ G 3 G X > o C O c§£ O 73 0) X a> to P cl^ G o O 0 j -c ra 0 2 in £P C T3 E 3 i * .2 E 3 « E£ff rc *- tJO Cl co O ^ ^ to c £ P X O .52 13 ° _ G cd oi - si n. 52 c ^ ■"* n P-X - qj — s_j! ra Nr. u ■o C ¥ D oj F -° r. 13 QJ § jg o H X o o U r- j£> _g c E ^ -s -g x IS ££ ~ bf> J X) a» to c •£ s ^ £ In 60 cu • - oj S Bug D- - o E g O £ ; . £ § ra OI g X c 3 cl ^ cr co r, r3 C ° X X •- c .a g m E ^ ^ £ £ e 3 in O S2 * X u o V E o -£ ^ ■a " 3 ■= i c ns E: >ig g « g u o> 5 * .52 cn X X cl < 3 £ - co > co C 3 .2 - . g •- _ ^ > X 2 ^ — ; g SP S ^ C/) X) G on o 2 Q- . o < O -o ; d e o ™ E rc — *- O ^ (/) ^ £ | 2 S rC 3 E cl! g X Cl. 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O- ~ P ^ <-g sfsIsSl CL Cl ' >.— O O 60 S^Z G. r^* r* ’ — O 03 <£ u X _ n G C w § -E £ a. E 01 cO “03^ S.X 0 5^ rj c x fD co CO £ X = c £ ? £ G E C g X r uT“ — E *- O 73 r Cl g CO X L G Q >>r c G - - x 33 — 03 *- X C £ «' c ■ - -o Z ™ o E — ^ = 13 0 O P U L « a ~ £| g X a -S PS o X ra X X, Cl i3 " S E o 5 2 X 5 c: xs bo ^ « r _ ai 5 ra g E X o S -5 ra C X X « O^E CO -*-* " r- to CO ^ P s > .§ CLX — (N G 1/1 *— ' co G G 3 £ 'n O Pi N P- §.§ .£| II P c to1 .£ S 8 Cl E O CL G E £ G •" > C G ‘Z P X X X G X £ o c 8 - -P 5>> x: \ r x x to *- t ^ J-J u - ^ rn P X G X G 2 -SjE X G 3 — “E CO 03 2 m- u u X O 3 2 G co ”P 3 ■P co O pi G G £ 8 CL C CL u G ^ r- P x ■£ 3 X _ o o x: •r P C to qJ I ^ > to c ^ x 2i CO co £ X G E.- ■ c to . X c - o 2 G Z c X - u '■= u g > r 5 | z 2 ^ Cl O G c £ o G X u c — to E o G .yj a i C 2 X -o C G — Cl to a, p c o c Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-63 o» S ? 3 .*P Q. P P C 'X - .P c c P P T, — Q-X fC co cj /~, J 3 ClU = p co n.X-~ < *- ci >^u. u — = c £ u. 0- c .&> 5 5 5 llii T3Sgj £ ■“ c “ p ^ s o ^|s£ X 3 r — ' p p fc E - - o • S sc< t; ^ c- 3 < W ■g 9 g £ -* b • i TD ^ meg C rz S P ^ x - O P < o •- c u < p 03 X x o — CL p ;ux C dj *£ -a - - o E g=iSO. J £ — r- ^ ^ box c r 3 - £ g S ^ * £ X -±3 1) 6C_ “ » u : ^ £ 5 > "* ~ £ o £ j= 3 E ' x E3 2 cS f2 E > . '- ,2 CJj-O i — : — q -j U — 03 ,r. C .£ >x Cl <0 'q T3 P •- > X C 03 3 oi o JD .J2 — X n >~» h“ co X ^ C r-i C c o 3 p ^ c co >. 03 3 IL b© o, n 'c 2 3 E ■s C 3 5 « ° o £ co u. 03 C < -r ■a. 2 • uj c - p Z>-> p X ^ p £ “ m = S x p zz X .2 g ^ p < CT' — • ^ £ to *5 tE ^ 'x £ UL O P Cu>*_ £ 5-a ° E £ c co p c T3 x: .o O^i/i ° c _3 . ^ c u jp s " c ^ c rs O di k- 0» o r T3 0 .- E £ O 0» L c .£ c Cn] >> o *> (N g_ *- c ^0 rz 3 _ C O n • — E i ^ p P ^ ’3 _ T3 X) — _ C >. 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J2 C 3 ■“ Qj X X I g > be p 73 — _ co E 33 in » 5 X O E - = 60 03 0> X 3 ^ *x ■*- 5 g ~ * n 73 dj P 3 co p : X iz ^ £ c £ S I| 1 Cl Q Cj ■ E £ SlS ■2 -= c « P d> p H c 2 E 5 xP E X p p C ^ t: b© 3 £ 3 3 p .2 E p — x ■P .X -3 *" 3 -X ~ X 03 03 c P X u C Cu ■p .X CO X U _ L P P 73 r3-_ = £ cl^ ^ E a X o O - ^22 p p 1 J© S- 8* E £ X • 03 X 3 -5 X *- p: p 2- x o x c ^ . o Cu P >> dj zz c 03 C Cu •— p •§ E 2 -XX > 2 u c Cu E X u 1- X' 3 ^ E£ ES P 3 n c p P X, n — P P 03 o — 03 03 ■£ E X X P P co co X 3 nT3 X P dj CO P . P d) E ^ bC uL X 3 Cu P ■5 0^2 C E“ C P ^ x ^ £ J= c o p X o < c O o "§ s X _ ’5- ' D ^ c • o c c r~ CiJ h ^ p p p p 3 ^ol X o ^ X CL 3 c X C O - O X 3 bCc X c 2) d© 03 X »-* j! 3 0 ' -U C “ r' ■2 £ E 15- Cl p X - b©-- . .£ E x £ - 3 -o ; U — , C >> w •£ 1 p : : ^ E ■ C p P _ E 2 •- p re - UO p > ^ C- < T3 G 03 P <= E X 3 f- CO 3 C O 3 • O V bC -2 £ £ -n - x c p X "P X P G g ”3 r. 9- ° X - ~ E Cu , P ~ ,rs H X X To p < x 1: x G 3 Cu 3 S < 2 A-64 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement 3 cl < « P £ • — r-^ Ps © 73 S O UJ e c c- £ c o' H Z u u f— v. < f- 2 P LJ U u £ >, c x. s v? ■ — C . p Q. ■" r i £ .E w IT. E 2 < o - j .2 ci g « O' Cl a — =J ^ P . 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" 4> 2 c 3 £ o o E c u -9 s t * »-i] O' 41 GJ 1-1 ■£ a. 60 -B-r ^ j 4> c ^ ^ ra on I S c - H D- C >S 1- O X r3 X ra 3 5 5 ^ C ra x a cl ra Q_r a. . o ra a; ra x £ tx Q i u 1/5 "P 0) 01 c < x d-7 X c _ ra 4i .E E c > fa C X ra bO^ £ ra £ in O ll X N ^ > ra v*- c u E ° .9 13 £ O- Cu n "£ a» “ C3 3 £ 5 “ « c -O 4) — o x o E tn c o x S c o > c — p 2 *- 3 O c x J2 US ■- O) ra — . ra .. ra to ^ ^ ° 2 > p i- y) p x c ra? P c x r5 ra C i- P p O _ Cl. p _ a. p .2 IE = c £ 58 s P yj £ 3 p O X £ ■*" p c S u. M p ■ Q- Q 5 x^ C_ tJj c c- O p rT^ s: 4> o ,2 — Q Ci ^ ^ c ra ^ y: c- tc X Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-65 A-66 P 14 o .P w 04 2 c 3 04 OX) o o 0^ 14 1 £ c32 — E - u t- -3 o 3 3 3 '5j .2 & -3 -O GJ c 3 c 04 Sj "O 04 P w -3 3 2 Sol e :e e i| 3 r JU CL - P o' O '” 6. > *2 3 3 C ~ "P n U ii .2 14 — T3 p ' 3 ? 3 « & | > -g <£ !i 5.5 u o g>-° o 3. — , ■2 u- E 5. c O ._ S » o S 2 to U E 04 c_ — 2 2 C 04 b 3 o E 04 w 04 3 04 — t- o O Jg- E 5 .£? S3 .£? p t, 5 3 c = 5 04 E 3 O •- P 3 l 3 ZSi p P 04 E ~ 3 -* O o *3 •- ? « •3 2 .2 t p ^ So 3 — 04 r C_ ~ W ^ 2 ~F OX) CL 2 24 r*. o 3 rt 13 .2 !: e p< — oo 3 3 -O 14 o .-b l- ;£ c/5 P -O 5 T3 E Z' \s 2 c P 04 CL D. • = . o cl >< x 2 OX) o t: ° c — s ? < < " >, E _ c £ S § n L c « ■P 2 14 "3 C 1 I' 'or o To Cl cj 04 ,0 W p 3 -g o _2 3 "P -3 - — ; O 04 04 V5 Z VO iP) O' w - O 3 X z p. -£> 3 -5 E t w £ O -Z O = i < O p r c. c C- c. 3 • E £ CJ w — 3-3/0 •3 Z C P ”3 t/5 '— -P 01 04 L. 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S 3 .Q — \D Lfi .2 C£ m 2 a D c di .2 ■5 «j to 5 •S £ Is &• 8 cL o .£ .5 « Sr e s; « 5 -o « « ^ 'B -S - Si S s •= % z -O s ^ ±5 60 C ^ § J) .2 C ro P .2 d u o a 3 g n « 5 g w O - £ O Z “c 2 o- 5 3 o .5 Jl xi 2 ^ ^ cu ^ -2 p £ ^ ^ d» cn~ ^ ‘5 ^ £ •5 T3 E £ bo i C w '33 r re re -r 5 S « 2 u -2 ^ (0 W U E 'Z 0 — 1 c a c a O a. ■d ^ dO di w- C g & s a ° •§ i-2| 8 § | 2L 1 1 1-g* s 1 g U CU O (X X F, 5/3 M _ $ a> o “ • E 5 ^c£SS £- O 2 dl 01 3 ij C in 1/3 E 1/3 di 2 -a Si -S F « «1 IS S “ dl ^ S' re u s re 2 £ fS ^ q 2 E co £ In' E £ E ^ a ^ >,2 a ™ m.« R. i f ^ -S £ 2 I 3 _^-4-Cu.rr "2 -n C di di ai 2 ^ x x *a a & e f a «• y o c E E a §-E c' § 8 " •£ ^ re g g C dJ u. u 5 « ■S c 1 a 01 g, % -a I 2 [5 a S g-s c .2 ° S di re- u >> £ di Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement u O S v =P\« ■5 ra .2 73 0- o g £ 'tl o < & § a. e o s 5 5 3 0 .b 2 ^ 73 .2 2 o •- •- i-s & § g s O co CU W5 c QJ -S -5 >^73 C "3 73 T3 o» 1 5 x> c 3 •£ 5 « ^5 n C * •r 3 -a S I “II B> I - J2 o» P o »- '— CJ UO ■*^ {^ oj [Ti o U 73 cn D- 3 *- •*- c 73 O '-= .3 o c 2 T3 H-?3 ^ % V 5 ^ a) 5 nj " 3 JC s/> .a rt3 -J3 tn <-> 0> P <0 73 •5 | | •& c S 2 2 o 3 D . ^ -C VJ .3 ai n 3 »- ai a u *- 3 5 C 2 ^-73 «S 2 O vo jO c75 S 2 2 g wi £ Q> QJ u .a 0) 3 ci- Er QJ OJ •- .5 3 Ci- C !-• U O D- * ? .s - S> £ < £■ . 3 73 w 2 o •2 c s >. .a ^ ^ w ^ u- D w 73 ^ C - 2 | p ”5) > is 32 Appendix A. 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Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-93 o CD CL CD — ^ fl) C/) ^ CJ d) O to Q) 0 5 £ _ n Z E c * ® M r P Z E (jj fc 1/1 _QJ CJ _0 _>> _Q £ o o I c S S. o (D Jr 0 =5 p *- -C e 5 sq r o CD c ID C/} 0 0 Q O c n 3 0 Q. 0 C — - CO 0 CD O 0 0) E - ■g E o > -C 0 E Q. jz o 0 -Q D 0 1 9> O O. a) c 0 tc o CL _Q 0 CO 0 Q. O E Z - E .•= J=- ID JZ , CO Q_ CO £ x O 0- CL < _0 C^-g § I £ be E T3 LLl O CO LLl O’ ;> — 2 s 0 H L= O -C o E — Z r- r -1 ^ -=z CD 0 P 0 0 E c -o £ E 3 « o g £ E c 0 r- a) - >. ~ o — — 0 0 0 -C ^ O $ c E - ro I g 03 -O O ~a 0) c £ > ro 0 k_ Q >. ® ' = CD ^ « ^ o — cO CD 11 u to 0 E - to co £ CD CJ CO 0 CD O *- -94 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement As for the supplement, it appears to acknowledge some of the issues that have been presented to APHIS, but there is very little more solid documentation (or no more) than was included in the original EIS of 1994 It does not adequately address most of the questions brought forth in the public responses. But it does acknowledge 2 ■£ _c o 2 1 l “ o 2 ° £ ^ S £ — 0 0 2 — — CD — E y - C 1 I s i o 0 03 ^ ■o 5 1 «5 £ o CO t> I 2 X X < 03 . 0) Q_ to tO E .2 g. 03 0) o — 03 2 = 0-2 £ _ C «0 tT ™ x ~ jz ^ 2 c 2 .c 0) % E 5 — — 03 - c 03 E < ~ 0 2, 2 0 ■= O -C S ~ “2 ~ " (U W ^ H. — r~ O 2 — (D .2 cn o •= 0 O 2 ~ TO x - 0 £ JD o c b o 0-^-0 >■ 03 _>> Q_ — Q_ ,b 2 -o 0 0 _Q a> j? Q. 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P H XJ O a XJ i — i •H •H CO •H rH 0 G G — 1 H G — l 0 0 G XJ c cn G a •H 0 > >, G H 0 03 03 cn O 0 H XU XJ H TU 0 G 03 G CD 03 G rH B G 4-1 XU XU c C 0 CQ XU G > 0 0 XU H XU 03 C XU O H M 4-J Cx, cn 0 O XU ■H ■H O u XJ CQ 03 0 CO 4J *H 0 B G 0 G u H G CJ B TJ 5 CO = rH V VO Appendix A. Summary of Public Comments on the Draft Supplement A-1 OS to the Environmental Impact Statement Che harvest of the native forest has diminished. Currently A-106 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement directed toward a total opening of trade. United States has become the second largest destination Any major import restriction imposed by the U.S. government TJ 0 rH CO X (D JJ X 03 CO >1 X u 4J G C ■H JJ •H 0 X G 03 u U 0 03 P JJ rH O JJ 0 0 d) 03 •H 2 0 34 o c 03 CO T3 03 CO X CO 4-4 G X 0 r— 1 0 44 Jj 0 - c W •H c X 0 4-1 •H 03 G •H a O JJ O JJ o cn X TJ ■rl 4J 03 34 G X JJ O jj G •H c 03 E-* 03 X 03 0 •H >, CJ jj CO 34 a 0 X X •H X c o X CO 03 4J G 34 JJ 0 'O E 34 U X O •H C/] 03 ■H CO 03 0 O 34 a jj 03 jj O •H 03 X H 03 x JZ 10 (D X a 0 X 03 0 CO a 34 0 •H rH E X T3 c TJ C/3 Jj £ a 0 0 t — i 0 E X 34 Ci] c rH o JJ •H £ 34 > •H CO a > •H 0 03 -U X u 03 U c •H jj cn rH c 0 to H 03 X 0 ■H g G •H o c rH •H 34 CJ E X X G •H CD C/3 34 JJ rH 03 CO •H CO >1 34 D D OJ 34 03 JJ C/3 1 E T3 U CO 03 34 G 0 Ci] U 0 T3 O 0 G C/3 JJ c JJ JJ •H X O 44 X H CO >i X dj 03 u JJ G 0 c o JJ ■H (0 G CO G O H 0 4-1 u < •H G 4-4 •H r— 1 U 44 34 *H G 34 X G Cn 34 03 o 0 C u < X X Cn 4-4 -H d) 0 G G T3 JJ 0 G O X X TJ 44 0 •H S H 0 •H 0 0 x •r— » U D 0 JJ CO O 44 c O CJ E /H X X CO > u 0 CD 34 C 0 0 rH 03 X O CO O X < 0 0 •H 34 U 0 >, a 0 rH 34 G rH G 5 X >, c CJ Cl] 0 rH 4J 3-4 a G X X 34 •H a 0 •rl a 03 0 34 0 X X 34 JQ 03 O 03 JJ c 34 X X X G .X 03 u p O (d 03 i — 1 4-4 3 JJ G C/3 •H G 2 0 JJ JJ 34 34 03 34 X 0 2 Cl. 34 >H X 0 G •H 0 34 44 £ U rH JJ •H X 34 JJ 44 •H X C CO •H X E- •H X CO x ■H o •H G G U 34 E-* 0 03 o u 0 X 04 £ X a c ij £ TJ U 03 JJ X rH T> 0 •H 0 03 < O 03 0 O1 G 0 0 -H C/3 CO E 0 0 a G CO c X X cn a X X u c u O X 34 JJ G G •H rH 34 E 03 rH 0 03 X 0 U U c cd d) 03 •H JJ a 34 03 TJ co JJ •H G 0 03 c c O 03 u 05 > 4J 03 34 G c X JJ - c •H Ci] Ci] G •H CO 03 44 d) a JJ •H o T> u G G G CO o X cn X CD X a Ci] 0 03 03 G 0 34 •H 0 44 •H O •H •H CO c G H > x ’ — 1 G c C/3 JJ C 34 •H X 0 •H 0 Cl] 0 T3 03 - 05 CD JJ ►H C/3 34 U o o 0 0 X X u T5 c G X O X C x 3-1 X > C/3 G 0 JJ •H CO 44 X G U ►H •H 34 cr H 05 O 0 (D G 44 C CO 34 03 JJ •H G 34 34 0 0 • — i X 03 •H 0 JJ 0 rH T> X 0 U C0 0 rH U 34 (D U 34 CO 34 CO (0 CO 34 u O CO X G G C -H 0 03 x CD 0 G O 0 C O 0 34 0 X O o »-4 •H 2 CO £ 4J -Q 44 X 44 34 G D 44 T> a 34 O U u H4 a Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-107 A-108 Appendix A Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement x: XJ XJ xj 0 03 T) G C 03 •rH XJ U P G O O 03 0 3 O £ 03 •H 01 •H 0 u 1 — 1 0 G 4-J •H 4J r— | 03 m in 05 4J •H 03 03 XJ 0 05 5 03 QJ QJ *H T3 03 XJ - XJ XJ 0 XJ 0 G G 0 = •H •H U 03 - g 0 0 G G 3 XJ x: G C O 03 x: m G G QJ 4-1 i — 1 ■H 0 0 03 0 0 XJ O •H CP XJ 0 QJ QJ 04 G 0 0 03 U i — 1 4J G x: O4 0 XJ C 0 0 01 C/3 CO 03 > sz XJ 04 0 Cn XJ 4-4 03 x: 03 O G jp G g G i — 1 0 XJ £ £ ■H O G X) G E CP XJ XJ p G a r— 1 O T3 0 03 XJ 3 03 03 E 1 •rH z C 4-1 U 0 x: •H O G G 0 CP O rH in 03 0 i — 1 o 4-1 > XJ TJ O 0 0 XJ 03 > 0 u •H P T3 TJ Cn xj 03 O G U •H XJ •H G 0 0 i — i QJ QJ c XJ C XJ u - - G XJ 4-1 c 0 Q4 0 01 > CP N N ■H O c i — 1 CP 0 XJ « 03 u 0 03 CJ x: -H - •H •H i — 1 4-1 •H 0 XJ £ XJ x: G •H 03 rH 0 0 XJ G XJ r— | i — 1 TJ 0 4J £ U •rH •H cn O 1 — 1 G 03 Q4 G x: 0 03 0 03 03 QJ •H o 0 03 •H -H CP XJ C H - JP C X! 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H 03 G 03 0 £ U g G 04 u 4J x: •H T3 XJ O XJ O 0 G QJ 0 0 04 0 C £ XJ cn G c C 1 — l G 1 — 1 CJ •H QJ i — 1 tn 4J •H T3 03 0 0 •H XJ 03 03 a 03 •H O G > G QJ •H 4-> x: U i — 1 G 0 0 P XJ rH E iH 03 G O C 03 03 G 03 03 0 04 4-4 £ XJ C 03 04 0 Q4 XJ Q4 3 0 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-109 healthy and productive forest. A-110 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement of the growth of the forestry section, the Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-111 to biologically eradicate nearly all of the pest (it is now for a maximum of six months without suffering any deterioration. 03 TJ in c d) cn d) TJ •H •H c u 03 •rH 44 0 34 34 03 c c 03 u W u •H W 3 X o •iH cn dJ o 4-J 03 03 0 a 4-J >, 4-J 34 <4-1 U rH 4-J 0 03 34 c 44 3 TJ a <4-1 03 34 X T3 03 u TJ G o 4-J 0 4-J 4-J O i rH rH 0 0 OJ 0 CO in 4-J c 4-J C a rH c X 34 34 2 4-J 03 X 0 r—H < o E a = 03 0 TJ c 0 4-J u c ■H T3 cn •H 3 a rH 0 03 34 •rH 34 dJ O c 44 A tj 0 W <4-4 4-J rH 03 3 d> -X 0 •rH 03 0 X 34 •H a a 03 <44 3 34 cn 44 <4-1 34 CO o d) c cn cn 4-J O 3 -X 34 O •H r 4-1 X D i — i 0 TJ CN 34 44 u O W 03 4J 03 34 C T— | cn 4-J dJ U 3 a cn 0 34 34 0 •H 3 d> -rH c X 03 34 cn c TJ O 03 5 X 34 4-J o •H 4J c <44 44 c •H <4-1 a o 4-J 4-J 03 cn 4-J 4-J 0 o o 3 03 -X 0 0 rH cn 34 cn •H a •H C TJ 34 U x TJ W rH 0 3 d) 0 CTv E 4-J 05 d' 44 05 44 G 03 4-J TJ 04 u - d3 O 03 E c u 03 TJ C E 0 E in X 34 4-J d) ■rH cn CO c O 0 TJ •rH 0 34 0 34 4-J <44 34 34 rH c •rH C 73 0 4J 0 4-J a 34 rH >, 0 in < P T! 34 0 TJ 03 •H 34 (D a X 03 X •H T3 34 u 34 (D d) U 34 E -X 0 u u c 3 -X O T3 cn 03 03 44 X CRT) O 0 X O 03 -H •H cn O o •H c dJ 34 44 C ' 34 TJ E 34 c X 0 3 d) 4-J •rH O O •H C c G 3 a •H 3 34 cn X X T) .X TJ a 3 !— 1 •H 3-4 03 r— 1 TJ • H 0 4-J T3 O u O cn E m -h O cn 34 34 X dJ 0 03 0 c C CO iX c <4-4 TJ <4-4 c Q 0 c TJ 4-J <44 X 3 Qj 3 03 34 3 0 0 •H A rH 0 O cn 34 <4-1 03 tj -X >1 E -H 0 cn <44 TJ TJ 44 W 0 U in 34 3 -X 3 34 0 4-J T3 dJ dJ TJ G 03 34 TJ rH 3 3 (D 4-J •H TJ dJ x W •H 4J 0 i u 0 0 0 4-J 0 34 03 TJ 34 C 44 •rH 4-J W C rH X X X c 03 dJ TJ 03 03 W 05 r— H r—H H 4-J (U cn a 34 i o> TJ 0 in i — 1 •rH 03 4-J dJ (u 4-J C 0 dJ 0 tj •H .X - 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0 X C X X X O CD X 0 X 34 •rl 0 73 0 a »— i CO P G 0 03 U 03 0 a 03 u u Cn c rH < U X u JJ i — 1 > O X 0 X H Cd O •H 03 a •X X X < •X o •X •X G Qj 0 O 03 0 cd < Eh u JJ 0 03 0 0 rH X X x X X X 0 Cu 34 3 U 0 a 0 jj •X X X X > 03 C 0 73 03 O 2 C 03 a U XI w Cd 0 c C c > 0 Ui X •X •X 03 73 0 a 0J 44 0 C 0 D 2 £ si o o 03 rH X u X X >, C rH O 44 o E 0 34 Cn o 1 0 O X X 0 •r~> X 73 X -X c G JJ X) CO XI CO CO cn •rH 03 - — >, X X X X a 0 0 0 X X 0 O c 34 0 Ed D Cd >H c 73 N X a •X CD 0 O E 0 a C ■X 05 0 •X •H 0 0 0 0 si U Cn X3 CO o 03 •rH rH JJ G c •X •X c 0 'O G N X X JJ -H 73 si > jj U CO CQ E X c 03 c 44 D •X c 0 0 0 •X •X -X ■X 03 U Ui JJ 34 JJ 03 D CO < 2 03 JJ 03 JJ p o c •X X X 73 u X u S C X rH 0 JJ a o si 44 CO cd Eh O Cn 0 0 0 0 E X 0 3 u 03 o 3 •r-> X 0 o U Cd M 0 >, X U> u X X 73 73 X rH 0 X X 0 rH 0 CD 0 O 73 G X) >1 CO U o H ■X X O 0 G X 03 03 « X u X X 0 X O X 0 X a < X 0 0 D Cd U 03 > 0 0 O u O c H 3 Cd H U Eh X si Cn Cd CO > Cd 0 JJ 0 si E 73 U » < X 0 jj 03 XI a i — 1 •H c 03 jj X G X rH Cd p jj M Cd □ CO •H c -H 'X 0 03 03 0 i 1 si Ui 2 2 iz 2 x 03 JJ CD jj •X 34 U X 0 i 1 H 0 u H ►H u 0 G O u X 0 0 •X c r* X • • • 0 O 03 i — 1 0 X a X X 0 3 JJ 34 JJ X O jj 03 o X •X 0 0 05 0 >1 03 JJ o X 3h u rH 0 03 JJ > si P 03 X 0 3 p o X 0 CO 0 > a cr Cu a 0 Cd X a a E 0 X X x jj •X 3 73 0 -X U 03 Qj 0 •H 0 0 X m jj CO 73 0 JJ 0 X j— 1 X o X 73 0 G •H JJ 0 QJ 73 73 O O 5 0 x H 0 JJ X 0 E 0 i — I 0 E 3 E ■X G ■H E CD g •pi o o 44 73 0 JJ x o a Ui c 03 X a 0 03 CD < N s: Q, 0 s: H >1 X3 73 O O cd X o a X 0 73 C 03 Si Cli a a < 0 •X A 0 X 0 73 0 0 X 73 0 •X X G * 0 n 03 X O 0 • u 0 •X X o a 0 •X X 0 V 0 X 03 a < a -X E CD X 0 73 0 a Eh X m •X X C 0 03 0 0 0 C 03 3 >H O a 5 0 5 c O ui cr CD X E 3 •X U - Ui 0 C 03 03 X X 73 0 c 03 •x X O 0 73 0 73 73 o a 0 73 •X X G X X 0 0 -X X 3 C c c C 03 03 03 X rH X X X rH 03 0 o O 0 X 0 03 u o o U 0 c •X -x 73 X •X 0 0 c a c •X X X X X G 73 0 a • X rH E 03 03 03 03 0 0 0 c 03 0 U C O •h xj E 73 •H 34 rH 03 Cd U Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-113 A-114 C Ui UH o 4-1 o CO •X 4J to c 0 0 iJ co - QJ QJ J-i CO a to • •H co QJ x: Ui £ 0 4-1 >, 4-1 g x X < 4J rd QJ rH E m ^ W 2 O 0 5 a 4_i 4—1 •H (U cn QJ - O CO QJ rH cn G G 0 0 x: co 4-4 QJ SZ ^4 rd T3 c o C 14 c i— i u QJ 4-1 X 4-1 TJ r— 1 u cn 4J C * X 0 -r| 4_> •H 4-4 -H 0 sz O to QJ c C X) co G rd C rd J, 0 4J 0 *C 4-J 0 X X QJ sz QJ rd •X QJ CO rH QJ c w 4-J 4-1 c CO c TJ cn a 4—1 i — ( CO •H rd rH E - 0 o-o u •H 0 G O x - C rH - CO X Ui 4—1 rd rd CO 0 4-1 U CJ r— 1 c C o 4J G QJ .X o 4-1 TJ M ^4 T3 4-1 U u CO 4J — ' 0 0 rd £ CO •H U x a c X QJ C u 4-1 ^4 -rH •H p a rd QJ X o G rd T5 4-1 G G i-4 0 U u a1 0 X 4J QJ QJ 0 TJ C rd 4H T3 m ^ c ?°D O C TD •X QJ - o c 4-J TJ u C fd rH O 4-1 0 C - 4-1 co TJ 4-1 rd - QJ rd rd •H C U 0 D Ui O X) - C X C c E >1 4-1 - XI QJ a n, 0 0 J E X 4-1 I— I 0 p rd 4J X o c co c QJ 0 •H 4_i a 0 co CO rH c 0 •H co QJ rd •rH w XI 4-1 .L 0 4-i Xt X O 0 •H rd rd a 4J •H > E >s rd G CO rl ^h U u j-i u a> D QJ U £ •H Ui rd x a O Q) 0 :at f to 0 E cn 0 sz N •H •X TJ 0 sz o rd CO i-i > G E W4 G ■H x 1 •rl £ N TJ •rH U Ui TJ u C O 0 -Q ^ >H 0 C 0 O 4-J c QJ rd TJ •rH TJ 4-1 c QJ x; 0 4J a c 0 - •H in >, rd >, X 4_» c -Q O >, -H x: 3 rH ^ a 0 0 0 Z 4J cn X 1 — 1 rd co •rH rd rd X sz CO fd ° 01 t) V4 •r| m cn 4-1 rd rH E G •H a a •H - u ^ 0 cn CO D i — i rH G QJ rd C rd rd C rH V rH CO G .S . an V 0 0 U in P X U 0 X co 0 QJ 4J x: QJ XJ Vh 4-1 0 X CO C 4-J « O O •H •H CD 0 •H X to cn 4-1 rd QJ rH C 'tJ 4-1 • CO •rl m m U £ 4J 0 4J 4-1 0) •H -H 4J 4-1 G •rH 3 Cn C 4-1 0 a 0 rH 0 c X >, U tj X SZ c ui 4-1 U 4-1 C 0 4-4 -H u a c QJ sz c QJ a x: QJ QJ 0 D QJ rd •H c rd* 'H O G u -H O o OJ 4J 0 > a 4-1 N 4H sz £ U 0 2 X5 4J U 0 rH 4-1 2 u x G u QJ c QJ •X 4J QJ CO cn >-4 S ‘H h > g cn 4-j •H CO aj 4H 0 QJ X 0 QJ TJ c c •H x: rd >, rd 0 c r—i X C Q CO CU •rH rH cn rd 5 4-1 x: i-4 G c 0 V4 •H C 0 • a - 0 >1 o x XI 0 QJ rd c cr C 0 C 4-1 i CO •X > rH - G TJ rd rd QJ u rH m o 4-1 • rH 0 0 O 0 0 0 X aj 4H rd C U X C 0 •H 0) V < •rH rH 1/3 - m a rH •H X rH rH G rH T> c CO fd •H O •H X x: •rH c CO c 0 0 o -H 4J U -rl Qj rH 1 ■H QJ •rH rd TJ > 4-1 u >H rd rd TJ c 0 T3 0 2 0 rH X •H 0 x a o sz £ sz x: CO rd rd c >, 4-1 1 — 1 - CO 0 u 0 u TJ E CJ 0 co CJ u rH X 4-1 rd rH 4H c ^4 O >H 0 £ X -H X TJ 0 as QJ 0 QJ x rH 0 G QJ rH 4-1 4-1 4J M to x E- X < 0 < cn & qj «. rH X Ui rd rd 0 N V4 >, X •H u • CO CO c — - TJ CO co •H 4J G - P G c u 4-1 rd X O 0 rH 4-1 0 0 •rH rd QJ x: c rd QJ cn 0 0 -rH rH a 4J o XI X 0 • u • C — * 0 C u 0 sz i — l -H •rH cn 3 •rH - S 0 CO X SJ 4-> 0 ^4 CO 14 0 r- 4_i CO 0 cn o 0 u Q) •rH u 4J •H rH 4-1 4-1 G CO £ cn TJ CO co a CO rH X •rH rH a QJ sz rd rd rd •rH •rH c 0 rH cn 4-i cn 0 Cn rH 0 rH •H a CO X X o c G 4-1 T5 CO • rH 4-1 4-1 0 »*h e rH 0 rH ^ rH fO X X) sz •H P QJ o o X X G c U C c *X 'p o rd 73 4-1 •rH QJ O < — I rd QJ 0 0 a a •H U X u 4-1 4J a U a > •H u 0 QJ X x: QJ 0 QJ rd c x c fd 0 U 0 U a; 0 cu m XI U i c •rH QJ -rH u 0 Vh Jh in to cn to O **H c C CO 0 X C X TJ Du X o X sz • x 0 T3 c 0 0 0 < •M •rl 0 X CO u c X 0 0 cn c 0 U •rl 2 X X X CO 0 X CO •X X E E G 0 X X G Jh O 0 G G X 3 o sz CO 0 0 X 0 u X 0 U Jh CJ 0 Jh 0 X •rl X 3 - u i — 1 to CO E •H r~ CO 0 X 0 > X X X X U (N CO c •H 0 •rl 0 u ■- cn E X CJ >, X L) C G u 0 X - < • — • c o X X rH 0 M rH 0 0 X — o U 0 •X x c o CO 0 u u a X E \ u G m CO u •rl X X X G 00 •- •X >1 E c < G ID cn CO 0 TJ cn •r| X X 3 •X o cn cn CO CO 11 4H Jh O 0 O r- 0 G •r| 0 cn rH c cn CO u X c X •X X c 0 0 u G X •rl cn Jh i — 1 X G rH CO X 0 'C X C •X CO > O o X u •rl X Cn rH a •H U C 0 •rl O a O 0 C C 0 o •X 0 CO 0 E G 0 cn 0 •rH 0 £ X X TJ r* < ax •X X a X X X CO 4-1 •H O 0 o' 0 Jh X U •rH •rl u c 0 KD 2 CO X 0 a •X 0 X 0 X TJ u co O G G G X G 0 0 C cn O 0 TJ > X CO rH 0 4-1 G a, E 5 X 0 O •H Jh X 0 X u X Cn 0 o 0 — c G N cn CO 0 0 O p o X U CO X X 0 TJ ■ — c X cn E ro 0 cn •X X X u o - c X 0 0 G G •X u •X - — X 0 rH 0 •rl CO X X U X c CO 0 G u. 0 E •X rH O X 0 3 C X X •X x X c X G Ui 0 0 E U 0 Du 0 0 -X u c 0 0 ■ - X 4-1 X G 0 X 0 G G 0 C 0 0 >, u U X X 0 0 X CO TJ . — . X G 0 •rH 0 to E 0 •H X •rl Jh C X 0 0 < CO G X TJ 0 C -r 0 X O E X VD 3 X 0 rH X 0 0 X X co 0 X O - X C •X 0 — - X 0 X a 0 0 cn U CO E 0 CO G X X X X •X X r- 0 0 X X Cn 0 u < — 1 rH 0 •rl 3 0 >. •rH X •rl 0 TJ o X a in X 0 X TJ 4-J G rH •rl ■rl — ' Q rH >i ■Q X Jh 0 c CO X 0 Du CO in c X CO X CO C O 0 TJ X — - X X X X X 0 •rl •X X c TJ X 0 C X o X 0 0 Jh > 0 u 0 0 X CO G •rl CO X 0 X •X c E 0 G a CJ U X 0 U CO X - u 0 0 TJ 0 >iU 0 0 0 o 0 X G X G CO c X T3 0 E G i — i CO rH c •rl Jh E 0 X u X G c 2 TJ a 0 TJ 0 0 o *~H X 0 o 0 X O a Z >1 c 1 U O 0 Cn C cn O TJ 4-1 C X TJ u 3 Jh •H 2 X o X 0 1 •X C X3 G cn c - X •X Vh o c G X U TJ 0 X u r—t 0 Oj cn CM X U CO •X Du X G •X X a u O •H 0 0 *H C X G 0 CN C 0 X 0 in u 0 0 X Q •X c X •X a X X c 0 0 X 0 cn 0 > X rH O cn •X 2 0 0 c X o rH X £ U u i—H o X rH U cn 0 0 0 >•< X X « X CO 0 SZ X 0 a 0 u •H 0 0 o ■rl 0 CO rH rH TJ X G X Du 3 C o G 0 0 X 0 > E X 0 X a Jh X c > < — 1 • — • •rl O O 0 • — C '0 e'- cn U X u o X G CO 4H o E X 0 **H 0 0 0 X X •H X •X - •X en 0 X u c cn X G O u •rl c u 0 G u X X u C C X rl G o o X X G 0 x o 0 — 1 •X a 0 •rl 0 G O •rl X 0 0 0 CO O CO CO 0 Q — - u co SZ G 0 X u TJ X O •rl Cn o in 0 X •X C 0 •rl 0 kO X C - CO c X CJ X 0 >. O 0 JX Cn o E co X Jh X X a X X 0 •X cn 0 >, CO o •X O U u X U 0 0 0 cn X O 0 ni 0 0 0 X X a G X X CO c X cn X cn 0 CO CO 0 X of. 0 X rH a u X X TJ N o X TJ X o c o X c cn 0 Q) X 0 0 X X •rl O X E •rl jr. G rl X o o 0 X X X X •X 0 X 0 CO n •H •rl a 0 CO i X O E X •rH TJ X 0 c 0 2 u X O CO G 0 X — 1 X o G G u X 0 X X 0 •rl 0 CO 0 c 0 E 0 X X CJ G 0 > X 0 0 X X 0 TJ TJ CO Jh 3 X X ■3 0 0 cn cn 3 0 0 0 X rO G c tn > rH 0 m CO to O < C C X CO 0 •d X X X X 0 X X X 0 X 0 G 0 0 X SZ •H o — c 0 0 0 C 0 J- H 5 o CO X E- U ax CO CJ 4-4 X u CO X X X 0 CO 0 rH G 0 0 E 0 Jh 0 •H to C •H < •H > 0 X 0 0 U rH X 1-4 0 a CO X 0 •rl X a > — 1 X 0 X 0 •rl 0 X X H X X U Jh X 0 Jh H •rl r, • • • • G •rl 0 0 X •rl 0 U X X 0 G 0 CO E CO •rl TJ X 0 X a •rH > CO 0 G 0 CO X X o X •rl o G X U Vh 0 0 X G o 0 cn a •rH X X 0 CjJ TJ O O u TJ Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement 3 C >1 X 3 X O X a e < V 0 X CD < QJ X G QJ E QJ QJ X Cn < QJ > 03 X QJ CU O O U 03 03 O X >, x a u 3 X O X a u 3 X O X a cn QJ > X C 03 0 E 0 X O C jj 3-4 •H 4-1 04 C CO •H 3 CO 03 G cn JJ cd o 03 Cd M a X •H X X •a Eh 04 4-4 03 03 < o q X O 03 Eh < c "H X a 0 JJ Eh Cd ■H D, •H 2 D JJ *H 3 Cd 03 £ >r JJ "H TJ Cd X 34 X 0 X O a JJ Qj T> a 03 CU 0 E 03 ■H D C i — i ■H U Cd o M o u, H gg Q £ Cd Cd H rc < JJ 03 T3 •H G 0D 0 0 U >r Cd E G 0 U D 0 X X 2 CO 0 ■H 0 0 X -H X E 03 O Eh CO E 3-4 X a 0 3-4 c 0 u 0 0 34 X CO X O D X 34 CO Cd < (0 0 05 X a o X 0 fn Qj CO 3-4 U 4-4 X X 0 X 2 2 < cn O G O 0 X C CO O Cd i — i 03 0 03 X X o 0 X £ a CO i — i 0 •H <— 4 £ X CO cn >1 B a T3 rH O X X C o < •H C JJ 3-4 0 •H X 03 05 0 U Eh CL •H 0 04 X X 3-4 X •H 2 CO X r- 3-4 u CO 0 0 rH X Cd X < 2 U 2 »h O 2 Cd X m u > Cd 2 H Cd 3 O cn 03 x a o oj >, X a QJ x Eh X o X a «■ I x co g, 03 *M O X X § QJ a c QJ QJ XI & 0 X 03 U u 03 0 X CO O -H x § QJ X a >, X X a o x >, X a Cd 0 CO X CO o X G CO w rH - 0 o - T3 X 03 03 0 X 34 X X X X 0 G » X X X 04 o 03 G 03 i—l 03 03 •H 03 rH 03 < 3 X 0 X T3 04 •— 1 CO u c X 03 X 0 E Cd C 0 >X X 0 0 •H 0 03 03 •H Cd < CO Cn X CO 0 03 0 03 X X tn 3 1 — 1 i-4 C CO G u Q 0 0 G 0 0 T3 i — l CU 3 i — 1 •H G N X X •H O 03 0 TJ Cd •H > •H G 34 0 03 X tn 05 3 •H 0 03 3 a X U a 0 D U 0 0 •H tn x 0 0 c 03 0 X G X a >1 CO X G T3 rH •r~> a < -H NJ X 03 X X O C 0 0 0 03 X - •H TJ 0 G X a G X rH 03 X 0 > tn cd X Oj rH X G G Cn 03 03 34 •H 0 D 3 a CU X G £ 0 03 •H 0 D 03 03 U O r — 1 > 0 X C *H 0 X > G ■H G N X •H X •H •H 0 2 X X - 03 03 rH X 03 X •rH 03 N 0 O 0 •H rH X X X •H O 0 i — 1 0 T3 04 •H TJ U 03 X X X < 3 G a CO CU 03 X X 3 G rH CU X 0 E • 3 G •H cd (0 CQ X X Cd X 34 a 0 X X CO O •H 03 X •H T3 03 G X 34 X 03 TJ 0 0 O •H T 3 X •H X rH 0 i-4 T3 •H C c - O G >1 0 •H G X Qj X 3 0 u X u 03 0 X T3 0 0 X E 03 0 03 3 0 X X X X > O X O C G 0 03 C c G C -H G •H o 0 E C 0 X (0 X o •H O -H T3 tn 04 U - o o 0 03 X tn 3 Q 1 — 1 0 •H - 3 CO 0 •H 34 X X U 0 •H (0 •H 1 — 1 •H u ■H X •rH 0 X CO X CO - 34 3 04 03 0 0 X CO 03 X •H tn CO tn 0 CO X X X X G • X 0 0 X X tn X -- — ■ i — 1 0 ■ •H N 0 G 03 c c X u tn 0 CO G X u G >1 X •H G • *H X CO CO T3 X 03 c* X 3 •H -H CO X •H 03 tn x c QJ e QJ QJ X On < QJ > a) a o o u QJ x QJ E QJ QJ X tn < c QJ E 4 X Q. . X _ G „ 03 < X • CJ in • E D O — x U4 < Q co in x D 03 \ 0 O a < CO C 03 0 H X CO • X < X 0 4-) N O -H 3-1 >, O X X X X C 3 0 03 cn 0 co cn X 0 H Ll ^ C 0 0 a 03 CO 3-1 03 cn 5 0 i-J rH C X 0 03 E x 0 0 G X 05 cn 0 ,x x u 03 JJ 44 •H O c 0 >4 CO X O JJ JJ c >4 0 X a 0 X < JJ 03 03 3 O 3-i cnxi G cn 3-1 C 03 H JJ 3-4 *H X C D 44 - O X X U C E 03 3 4-1 X O 0 C C (0 U-H 3-1 -r- O . E X 0 0 D 34 s a 03 0 p < a: b1 - >, 03 x c a I rH £ 3-) 0 CQ 0 X X JJ * JJ D 0 O C X Cd •H 0 X -H 0 G 44 X 0 -H JJ cn jj 34 03 C < 3-) -H 44 X — • O G Cd 03 > CO < jj X cd C 0 O 0 E U 0 0 0 > >,x O 03 JJ cn 3 -h cn E 0 3 B x x o H D u CU JJ JJ rH O C O B 03 U O 3-4 O 3-1 03 jj a 3 o cr 3-4 4-1 O jj G >i0 03 3-4 CO rH 0 o a jj a. -H 3-4 0 c 3 x 03 d, JJ CO O 0 G JJ X H >i JJ X C D- 34 O O -H < 4-J JJ 03 3-4 • X 0 rH 03 Qj cn G O cn 03 O rH U U 03 03 CO 3 0 3-4 tJ)4H c ■H 4-1 X O C 03 CO JJ CO CO 0 3- 1 U 0 U X 03 c D 0 X 4- 4 JJ o 3-1 E O 3 4-( X c tn 03 C 3-i -H O X • 6 -H 0 0 > rH S O -H X X < 04 U 3 4-1 O JJ G C 0 O E *h 0 JJ 0 ITJ 3-4 Jj cn 3-i < o a >, E 3-4 -H 03 (0 3-4 O O JJ 4-4 >. x cn 04 c ■H TJ 3-1 • -H 0 m > X cn O fc 3-4 U 3j < 3 0 T3 X X JJ JJ O -H 0 T3 3-4 > 0 JJ O X CO X (0 0 03 -H 3-4 < — I O 0X4-1 X 03 O jj c c 0 -H O 0 •H X 0 jj T3 •h 0 03 n > u T3 03 JJ 05 X 3-4 C CO O JJ 3-4 03 0 B cu Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-115 mitigation measures required by USDA/APHIS (Table 4-7) are highly It should be noted that the pests liable to be A-116 Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement imported to the United States. Alternative 6: Prohibit importation of unmanufactured 0 O 4-) tr x: 0 CO JJ a) G c >1 jj x: JJ to 0 -H TJ 04 jj TJ o d ) •H •- Vh P g c 0 UH Q G JJ TJ T3 in (0 0 CO Vh CQ G o O vh O •rH E G jj 0 U CO 4-1 UH a) 0 03 x: u CO aj a X> co G JJ 03 AJ jj vh o O co > jj UH •H >, Vh 0 co O 0 0 G G u 03 4J dJ 0 - JJ jj o * 0 o rH > — 1 •rH (U u sz 0 P C co •H u - CO 03 •rH *4H CO rH 00 •H 0 TJ G in u JJ 0 - «— 1 0 JJ rH JJ .X co d) CT> jz 04 G P 03 •H N 0 > vh •rH 03 T J a co Q) 04 cn u 0 o jj x: JJ Jj vh X) O jj *4-4 o P CO G 0 •H U 04 r-H cr> 04 u c co CO G jj 0 co 0 JJ cr 0 e Vh P rH cn CP u jz a> x: r-H 0 CO jj d ) 0 r UH u TJ •rl X) •H G - Cn jj 2 U TJ r— 1 •H a u - •H C >i 03 jz •H 0 G rH o 0 CO C 0 03 JJ vh > 0 u •4-4 G 03 o x: JJ 04 d) 03 Cn sz rH U ) JJ CO >4H u «. G jj Cl] 0 03 UH u rH a C •H JJ ■» 03 d) co •rH O d) ro 0 *-) JJ •H d) 0 CO •H u p in •H TJ ■' 4J G 0 x: u CO VO i — 1 co 03 JJ o TJ JJ CO 0) in jj d) JJ Vh (U x: 3 G JJ -H 03 •H TJ c UH G •H jj Vh dJ 03 JJ G 0 CQ E jj 03 •H 04 x: o OJ •H u a > N 05 ■ JJ G (U (U a: < (D jj 0 0 X] G CO jj a oj G p O X] 03 03 u (D \ > OJ JJ a 05 OJ JJ oj > — 1 •H 03 Vh 0 G CP Vh CO O Vh U E TJ rH OJ .X x: •H Vh U a Vh Vh U >, CP CP (U (U •H OJ CO 03 .X Vh Vh jj x: P 0 0 0) O rH < w CO JJ CO JJ JJ jj Vh O 03 3 o JJ JD JZ x: JJ i — 1 (U Q G •H JJ 03 Vh CO 03 JJ E O U JJ JJ rH d ) 03 CO G \ 03 dJ >, CO Vh O (U E U Vh oj OJ CO •H 03 TJ G cu 0 H (U Vh Vh 0 JJ a Vh OJ C CP x: UH JJ 3 CO 03 O CO F 2 i — l jj E CO X O - CO o jj p Vh c - U •H •H O CO jj C OJ CO •H OJ G O CO o in H JJ dJ 0 TJ x: jj (U P o OJ JJ Vh o 03 a JJ •H V U jj — OJ 2 10 O OH (U 03 OJ VO 03 JJ G JJ • H 0 ■H •H iH O dj dJ 0-1 0 TJ JJ c cn JJ CO •H P CO CO E TJ JJ U JJ O-l (0 OZ M x: JZ o 0 cn cn OJ JJ UH JJ OJ TJ 0 c 03 0 O 0 JJ \ H jj m C CO CO JJ •H «H Vh CO •H JJ 0 Vh o G s c u CQ S ■H 03 •H 03 u TJ 0 OJ JJ UH 03 0 •H u O 04 p < - 3 d) CO 03 OJ UH TJ 03 OJ U 3 P 1 •H CO >, Vh 03 •H c JJ Vh OJ C 0 Vh • — 1 jj 03 u 04 M •H Vh x: JJ E Vh 0 JJ C 03 CO CP XJ T3 0 Vh 0 fH ta 0* CO CO in JJ u Vh O JJ a CO D OJ CL) OJ 0 JJ 0 m a 2 P m 0 C C X OJ rH CP OJ E JJ rH TJ •rH (D jj d) 04 JJ \ O «H P d) a O P Cl] Vh d) •H Vh > 0 •H •H O G in u CO H U U TJ x: X u 0 r 0 x: x: 03 03 Vh c x: O 0 dj & p 04 d) 2 G G H CJ ,H JZ UH D CJ 3 CO x: m 2 O •H jj 03 03 m < u U (U d) T) m 2 N «4H JJ E i — i G u M c Vh o G u 03 o Cl4 (H JJ • • O (U •H Q CO U in JJ 4J d) OH Appendix A. Summary of Public Comments on the Draft Supplement A-1 1 7 to the Environmental Impact Statement A-118 T3 C 3 I m o Q o “ s > “ * Is! £3~ 8°l X 5 2 ^ , < E ^ « E 3 rt „ ■ O _ &) C C3 ^ « o 2 o Q 1 CL | ^ 2 2 xj ca o E C Q. > ± c « iu ■ - pj -. Q _ .o . o 0> I CL D TT a: c ca o — - — • 0-> 22 is £ [ll (/) ca - s « t s C«-r ? O 5 S ^ ca •-- > o u ca u c_ (/) ca 5 | E E I I oo w £ £ 2 o.-a C -O BJ c © a I 3 to ** ZD x *o o o ca w — — c u U cfi T3 •£ S2 K ® £ o . ac c o o - E 5 3 — C ca c E 2 CJ w CO *- 1-i rt 2 — tz , cj _E « ■DyviSjjr, n-j- 2£ fi-Sg 5 -I — J- cn -— w — rr -— E “ sz o o E £ E — *5 -F„ ca >. _ o P « b £ s £ E « -5 2 ^ ± -2 c oo "3 . i) o ig.3 > 1(2 c -F ca © a> CLJ 7 . w aJ E u d-S 5 ~ _D § 2 < ar £- c _© c 5/1 2 -c 2 oo © »- CJ ^ o .<£ U - ^ ca — _z c < OT CL u — E E ca w “■ -c ca £ ■£= *a ca C_ *- — F t tr .V 2 “ 7= c k- © c >. IL> _c -j « u 7 p ta < E E co 5 rt E o ° .5= ^ E §• g 3 ^ E i =§ >. -g = g — ^ CO • c o (A -J. 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CJ1 C +J to c Ql C H L Qi V -d L U C 03 O Qj Ql H U L £ X 3 Qi Qi dJ U £ £ O ^ H -d T) O •• Qj . tQ *■> (N 0) TJ U 3 H 0 CO > CCU £1 (O 0 0 -H CO -d *h J2 H D] ^ h 0 CO X E CQ Qi < S Q f O -d N CO • < < L B 3 ^ VI Qi 3 . a Ql Qj Vi T) . T) 2 X O Qj tQ Qi Qj -d -d Qi -d -I C Q L U U jQ ■H O N O Qj Qi 0 -d -h a -h a c >. C CD E a CD H L -H H C -d •d -H C CD T3 a» Ql H o QJ Qj O L C L L +J H Qj IB li dJ O L * Oj 3 L. O -DO* a Qi CQ VI •HE O* Ql O 1) O O -H 0 U > C L Qj X 0 >» C Qj rl if) JZ -d L Qi > a . 0 ■d Qj 0 (N ~ JZ co a g M v -rl G >s D» C Q I) S H O O' -H > Oi » Qi H C H TO -d (N -d -H X 0 If) 0 ® X) Qj £ N E X C £ IQ -H H 0 0 V Ql -d >- X ~ -d 0 CD 'H O CQ E -H Ql Oj U CD L 0 -d a Qi Qj 1 v 0 a u v Vi 0 0 E 0 Qj C £Z -H ^ 3 u v x v a 0 . OU L C. 0 L Q) G 3 u l c a a g o 0 -d o a m n ■d E 0 c . □ •d H vD H 0 ~D . . Qi Qi OQ*i 0 3 U U d C HH £ U O Qi 3 -d 0 -H -Q O • G a 0 u N L G V L 0 cr> O Q • • h CO a o 3 ii h cn L cr V w cn -d 0 0 o ■< CN «h E L L -d •Q 0 •d U 0 V 0 T> C 0 0 £3 V O i 0 O 0 XZ -d L -d 0 -d > iZ C I -d 0 £3 T3 -H CJ1 -HOC > 0 H 0 0 -d a 0 >s c *H -H H St E 0 0 H U H *H 0 L 0 H -d L a 0 0 £ 3 T) 0 cr -H 0 0 E -D C 0 0 0 0 U 0 0 O ■O L -d «H 0 3 in O M y ca x -o a -d l < •H 0 T> 0 C C CD O (9 L H -d 3 -d Cl C 0 O E C H L >S -H H O U 0 ® X 0 Ql QJ C U 0 H H H £ X 3 0 X 0 X H 0 3 JZ X ■d-d O C . C 0 -d V O v« C C L 0 (j 3 cn E *0 U C i) 0 XL 0 0 L H 0 X d 3 CQ -d IQ or X 0 CD -d L O X X 0 . 0 0 0 -d JZ 0 ■d -d cn 0 t) •d 0 0 -d H H u c 0 3 L a 0 a xz 0 -d o 0 -d 3 C •H ■o C 0 0 -d 0 0 0 -d a c 0 X) e 0 E d o c U 0 y L C 3 3 0 0 U -O 0 3 TJ H H 0 0 X C 0 o o o d 0 a co 0 r- t 0 X h a a < u c 3 L - 0 >s 3 H C 0 £3 L TQ 0 X u E C £. H U CO CO \ d C 0 E 0 L 3 U o L a 0 u L 3 O 0 0 oz Appendix A. 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Z a;s g. a : u ' S) P, 03 03 t) W) cl C L c u L CJ If OJ - SZ 4/ n> ~ — Of) — E 03 Ills s a a E .2 £ a J= 5 o-cz “ — U. w ' 3 £ 3 VO 00 “ UJ _ u S c “ Sbl a - u ™ o 5 2 a -o ^ «-> . T3 O . OJ i_ 2 E c 03 O X > 4f 4f £ -a o 73 4f on 75 2 d ah w £ P *° £ C 3 4J C s s : CfO _ „ o£ is I g < >, aj 'D ^ E .2 .9*’f •o > 2 ^ 13 £ 75 -o cl 5 CJ ■o Of U- 3 •— 55 r i d u 2 73 75 «= £ o a -g if 4f 2 "O O •o c 03 •*- ca c 3 C ■— — §•§07 2o £ Q. S D ( C c £ 4J L- E £ 3 d a -8 X ' ■8 £2 LU ■ p o 5j oo C ^ -E ^ LU S Q 3 Os 3 On 3 2 >> u. 03 Of) ■*- < X) O D 2 7 03 o. r- "£ -2 1 2 > 13 > ^ ^ ° 5 "3 2 j* CJ 2 LL •• < £ y -g e ^ o "p c *n Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-127 M E 0 P - U CJ X •HOC X Q 0 0 X EM o tj a P coy C (0 H H O OP H W > U X X 0 X C O 10 Q M -H O 0 >1 CP C CO X X E < D TJ O 03 03 G H C H X % P Pu rtl CP O TJ 0 u 0 . 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( 3 P in TJ H E m Cr c c n X 1 P C a) TJ c > P -r4 rH H X n u rH C 0 -h a E c u c o O M to i-4 m E in (TJ a 0 TJ Li ■ P P i_i P r- P (TJ (TJ H TJ E : H TJ O (TJ < u X av Appendix A Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement I >S*l30', . £ C D^'D O D 73 P 73 3 Q) U 73 C 03 a 0 0)^^ p to e e to 73 73 0 0) X P p a p p c c - GJ f0 <— i > rH (T3 o> a p >1 - 5 to to c r a> o _h p o 5 •C H 73 c O' a; £ P 73 -h 73 10 a73 p o) to oj 73 03 >, £ C £ P O 4-1 03 P -H 03 O > c : oi u 73 *H O 10 C 73 0) X 3 73 C 10 73 73 U-h 73 3 03 0) 03 • 10 rH 3 01 73 ^-h a C 03 O 3 73 73 E 0£ 01 an 0 0 *h p C O O 10 CO O P 73 P C O “ 73 73 03 Qj -H H W - U P H -H C/3 3 0 10 03 73 0 c rH p P P CD to E u M tO •H 73 0) O > M P p 73 x: 3 p u O 73 P u 03 P 73 03 0) c W T3 73 73 0) w u P 0 P O 01 > O x: x: £2 03 C/1 O 73 «. — C 03 P C/l 73 to p c/i p >, rH •H p 0 a P O P Q x: P to _ p x: Q 4h 73 O' 0 w P p P 73 P 0 E CO c •H T3 CO p 03 0) P CO P ON Z W C 0) C E O' P 0) •H 03 03 x: p p •H 0) 0) > r C/3 73 C iH O P 73 *H 73 a > rH E 3 O P x: e P •H =- oi p x: P 73 C/l 0) H o 73 P C •H C o P 0 CO p O p 03 •H o c e M C x: 73 P P 73 P 0) p •H •H O ~ C (1£ O' i—l 73 O p — 0) c W •H P c p tr 0 73 £2 u P 0 N P CO c O' 0 to C T •H •h a> < £ g C/l •H 0 03 a u x: 03 to P 73 1 u •H C P p P > HOO- 03 G 73 P P 73 E *H p rH P p 73 O 03 C p •H p o 03 -f u •h m U p p 03 0 CO 73 •H p i— i P to 03 w a o 73 c c 03 P 0) £3 ^ 73 03 03 P P 03 C C 0 O *H 03 0) 73 SZ ' — to *H P P 0 P rH S C/l •H C p sz x: 03 SZ 0 •H >i X CO 3 a 0 P 73 P 0) 0 4H 73 CO 0 >itfl p p I-H P P •H rH 03 c 0 C 73 CO 0 03 C c •H 0 o a P P 73 03 CO to 73 p 3 73 0 03 E - c 4h 0) 0 3: 0 P c p 4H E 3 P 73 C E 4H 0) 0) c 03 •H E P < 0 0 SZ x: •H • a u 0) u 73 O O O 73 C 73 03 O p 0 P 73 73 P P O 0 cu 0 p p P C/l to 03 O' 73 C 0 O -C •H P 73 p 0 rH 0) 73 73 CO 4H w CO rH u 03 cn < a 73 0) P £5 « P c P 3 4-1 a p P E c 5 c 73 4H 0) « p E CO w P E C X 0 W 0 3 P x: •H 4h 0 0 0) 0 a 03 73 c w « 0 M u 73 0 0 0) •H CO 73 4H P CO O p 0 rH •H x: CO o p c 0 P aw •H C O •H p 73 03 03 0 o 73 4H •H rH 03 p c c c 3 73 •H rH 03 p p 3 P to 73 0) P 03 73 sz c 3 73 c -Q 73 c 0 M 03 O p 73 £J 3 rH p 0 4H 73 •H c P C c 4h M C o C 73 (0 > P u P E a 73 to 4h 0 E •H •H P 0 3 < to 0 •H 73 •H E •H sz < O JZ U 0) C 3 C •H P p E c CO 73 ••H C cu P c •H p 03 £2 3 p p in p < p 03 >i •H G P >1 0 •H 0) D 0) P 73 w c 0 P 73 £5 E x: 73 rH 0) CM •H 0 E p 4-t P 0 4h to P CO o E 0) •H •H c •H 0 a 73 u O 3 >. 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Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-131 ONRC comments on SDEIS A-132 p G p c G 0 c £Z CO 0 c P p C QJ H 0 C T3 0 P c <0 •H p> P 0 P CP CO <13 0 (0 0 •H p c (0 X p 0 0 p O' HH rH •H rH > 4-4 4-i <13 <13 CO <13 0) QJ p c P 03 3 w 0 •H P p <13 •H 0 CO 0 T3 P P a 0 a c 3 c 0 r~ 4 G P CO a P <13 0 <13 P >1 p M 0 P P 0 P Q) 0 0 w 2 ■ H 2 P C/1 <13 P P a C p <13 C a CO T3 p <13 p p •H •H -H T3 O 0 E > p ■H O > V£ -X 0 rr •H 0) JZ T3 0 P c P CO r T3 0 C Q' 10 rH c 0 CO p C rH p TJ TJ TJ TJ i— i •H rH (0 <13 0 T3 0 CO P CO <13 0 p 0 •H <13 0 a QJ TJ 3 rH P 03 (0 rH •H P P C 0 p •H rH 3 C 3 a O' p P TJ - E p > X CO 4-4 0 CO ap p <0 0) C c 0 P 0 > T3 •H •H P rH P p c •H P •H CO p CO 0 c •H a TJ 0 0 x: 03 P rH 0 c c T3 rH p P <13 P 0 0 0 a G 0) 0 C P T3 p c E •H P 0 •H C 3 <13 o 0 <13 0 P P O E •H T3 4H £ p ro 0 •H •H 3 C <0 P P •H rH 0 ap E O' 0 p p rH 0 0 P P a > 4H P M p P T3 < <13 O P a p 4h 3 P rH rH c 0 0 P 3 rH QJ 0 0 0 rH 0 a P c 3 0 O 0 <13 0 p 0 0 T3 >. 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E jC 3 03 rH 3 •H E 03 <0 0) in X TJ in P 03 c rH P in *> P CO O 03 CO P c P in p p E in 0) 0) 3 rH X ro 4h <0 CO 0 O T3 P 4h 4H ro 0) p p 0) 0) TJ ro p 0 p 03 03 M a 03 •o •H (0 0 03 rH x: u 0 T3 4H rH 03 3 03 0) c rH w XZ E 03 P O an 3 a •H 0 X rH XZ 4H 03 > in 0) •H ro p 03 O P V 0> c T3 E in 03 o p O P ro •H E x: «. rH c P 0) in (0 P O •H c 0) X >. c Its X 4-1 c in 10 4H 4H 0 CO S 03 3 p 0 P 0 in «0 •H 0 03 •H P 0 p c 0 0 XZ in c 03 aT3 u 3 >i a p in o 3 03 p c •H c rH in p 0) XI T3 c (0 03 3 03 O CO •H 03 4H C in •H >1 c -C 3 in •H in <0 0 0) a in X in P > E a 0 03 x: p 0 p in 03 E 03 p XZ 0) 03 0) a a c ro 3 *. •H 0 c p 03 p 0 O > C p c > c > X 0.4-1 •H 0) P O CO P c 0 03 O in O' T3 P •H 0 rH 0 ■H 0 •H p ro M 0) O' O M •H 03 •H £ c in 0) c X* p •H 3 03 •H P •H p p 0) O T3 w v 3 in 0 p in •H E ro P 4H 3 P ro in (0 03 0) P 3 xz P TJ O' in 4H o c in p f0 rH c 0 03 C ro C in c P 2 O in p a P p <0 03 3 O 0) 3 03 P >. P 3 in •H rH P 3 p O CO <0 0 03 p in O a O rH O'x: 03 TJ 3 P 3 0) O 03 E W P rH 5 0) XZ ro 0) c in 03 a in a 0 P P O c CPP in p O u C o 0 xz p P XZ 0 •H in 0 •H 03 p 03 rH P 03 0 0) rH •H rH P CO 0 c x: p 0 T5 p 0 T3 u T3 T3 a a ro ax 0 P ro TJ (0 a o u w cn Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-133 New Zealand has suffered grievously from the deliberate, accidental and illegal introduction of alien plant and animal species that have wrecked havoc with our indigenous ecosystem The combined assault of these alien species is the greatest ongoing threat to New Zealand's indigenous biodiversity. E- n cj o 7..E- S§ TO l/i U u 2 CJ U * II E a £ l I Cj o > j> u ”2 u c ?. 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CL < CO a; o ~a c D E ~o LU 03 0) D 5 (D !2 03 ? 25 2 ■D o 2 $ C O p £ *0 o « •p s P I vy^ & & 00 P a" d -p v_/l Appendix A. Summary of Public Comments on the Draft Supplement to the Environmental Impact Statement A-139 2 - - -■ mmmmlm ; > 1 M. y ->. » SPje. - ’S'*!*:- ,V> '• ■"’ ■ , „■» £ >S j& A ' 5< (5 | ,x:. ’"wS*- March 5, 1998 ;■ .'vj O'- , £ 5 ■■55 \ \ c V £ >■ ’i i V i * ,1 * f * i- 'S' 9- N V "5 V ~v ■$ v C,' ? ^ V v < s ^d 'J =Sj r'n IN IN Q V *> £ t 2 '1 * S I vy S i N^ >. > V V ^ ^ ns ; 'v ■>s' i >- ■V X - 1 < k i , V <* X i - ^ ■J K '4 S> 3 ^ > i ** s { i i ' 4 $ v ; ,3 S r ^ * i ■ NJ £j ■ -^ V . v< ? V J ^ i l *' - x 1 . J v, ^ Tn, ^ K1 $ 4 <* ^ tL s M J # rvvr \ ' f A' x ^ > 5 \ 1 P a ^ i ^ * ' V; CLAUDIA WILKEN UNITED STATES DISTRICT JUDGE Copies mailed to counsel as noted on the following page 32 Appendix B. Court Documents 5TH CASE of Level 1 printed in FULL format. OREGON NATURAL RESOURCES COUNCIL, et al . , Plaintiffs, v. ANIMAL AND PLANT HEALTH INSPECTION SERVICE, an agency of the United States Department of Agriculture; Defendant. CALIFORNIANS FOR ALTERNATIVES TO TOXICS, et al., Plaintiffs, v. ANIMAL AND PLANT HEALTH INSPECTION SERVICE, et al.. Defendants, and AMERICAN FOREST & PAPER ASSOCIATION; INDEPENDENT FOREST PROOUCTS ASSOCIATION, I ntervenor- Defendant s . No. C 95-04066 CU UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 1997 U.S. Dist. LEXIS 9521 June 5, 1997, Decided June 5, 1997, FILED DISPOSITION: [*1] Plaintiff ONRC'S motion for prelim- inary injunction GRANTED in part. Plaintiff CATS' motion for injunction and declaratory relief DENIED. COUNSEL: For OREGON NATURAL RESOURCES COUNCIL, PACIFIC ENVIRONMENTAL AND RESOURCES CENTER, NORTHCOAST ENVIRONMENTAL CENTER, Plaintiffs: Nathaniel S.U. Lawrence, Natural Resources Defense Council, San Francisco, CA. Michael D. Axline, Western Environmental Law Center, Eugene, OR. For ANIMAL AND PLANT HEALTH INSPECTION SERVICE, an agency of the United States Department of Agriculture, defendant: James A. Coda, U.S. Attorney's Office, San Francisco, CA. Robin Michael, U.S. Department of Justice, Environmental and Natural Resources Div., General Litigation Section, Washington, DC. For AMERICAN FOREST & PAPER ASSOCIATION, INDEPENDENT FOREST PROOUCTS ASSOCIATION, Intervenor-Defendants: Mark D. Plevin, Crowell & Moring, Irvine, CA. J. Michael Klise, Crowell & Moring, Washington, DC. JUDGES: CLAUDIA WILKEN, United States District Judge OPINIONBY: CLAUDIA WILKEN OPINION: ORDER GRANTING IN PART PLAINTIFF ONRC'S MOTION FOR PRELIMINARY INJUNCTION AND DENYING PLAINTIFF CATS' MOTION FOR INJUNCTION AND DECLARATORY RELIEF Plaintiff Oregon Natural Resources Council, et [*23 al. ("ONRC") move for a preliminary injunction. Plaintiffs Californians for Alternatives to Toxics, et al., ("CATS") move separately for an injunction and declaratory relief. Defendant Animal and Plant Health Inspection Service ("APHIS") and Intervenors American Forest and Paper Association and Independent Forest Products Association oppose both motions. The matter was heard on May 16, 1997. Having considered all of the papers filed by the parties and oral argu- ment on the motion, the Court GRANTS ONRC'S motion in part and DENIES CATS' motion. BACKGROUND In its February 27, 1997 Order, the Court found that the Environmental Inpact Statement ("EIS") prepared for the APHIS regulations governing the importation of unmanufactured wood products ("Regulations"), 7 C.F.R. pt. 319.40, did not comply with the National Environmental Policy Act ("NEPA"), 42 U.S.C. § 4321 et seq., or with Council on Environmental Quality ("CEQ") regulations, 40 C.F.R. pt. 1500 et seq. The Court, however, rejected Plaintiffs' argunent that APHIS had applied an incorrect legal standard when framing the Regulations. The Court ordered the parties to submit briefing on the appropriate form of relief. [*3] Plaintiff ONRC filed a motion for a preliminary in- junction, requesting that the Court enjoin APHIS from issuing any new import permits under the Regulations until the agency complied with its obligations un- der NEPA. ONRC'S proposed injunction would not pre- vent the import of wood products pursuant to the gen- eral permits granted in Title 7 C.F.R. § 319.40-3 nor would it rescind permits that have already been Appendix B. Court Documents B-35 1997 U.S. Dist. LEXIS 9521, *3 granted under the Regulations. At oral argument, ONRC expressed particular concern about the antici- pated commencement of large-scale imports of unfin- ished wood products from Mexican states that do not border the United States. Plaintiff CATS filed a separate motion for a per- manent injunction and declaratory relief. CATS seeks to enjoin APHIS from issuing new permits under the Regulations and to rescind the permits that have al- ready been issued. In its reply brief, CATS clar- ified that it is not seeking to enjoin the general permit for imports from Canada and from Mexican states that border the United States. See 7 C.F.R. § 319.40- 3(a). APHIS and Intervenors oppose any injunction that would enjoin the issuance of new permits or rescind current permits. DISCUSSION I. [*4] Validity of the Permitting Provisions of the Regulations CATS argues that the provisions of the Regulations which authorize APHIS to issue permits for the im- portation of unfinished wood products are invalid. CATS contends that the Regulations do not comply with APHIS1 own interpretation of the Federal Plant Pest Act ( "FPPA" ) , 7 U.S.C. § 150aa et seq., and the Plant Quarantine Act ("PQA"), 7 U.S.C. § 151 et seq., which is that the agency must ensure that inports pose only a "negligible risk" of introducing exotic pests into the United States. CATS maintains that the Court's findings concerning the inadequacy of the EIS establish that the permitting provisions of the Regulations will not reduce the risk of infestation from the importation of unfinished wood products to negligible levels. The Court's analysis of the EIS does not by it- self establish that the Regulations are arbitrary and capricious or contrary to law. The inadequacy of the EIS is a distinct issue from whether the ad- ministrative record demonstrates that the Regulations are substantively faulty. CATS has therefore failed to establish that the Regulations do not comply with APHIS' negligible risk standard. II. [*5] Injunctive Relief A. Equitable Discretion APHIS concedes that it is required to prepare an environmental impact statement prior to promulgat- ing regulations concerning the importation of unfin- ished wood products. As explained in the Court's Order of February 27, 1997, the EIS prepared for the Regulations did not comply with CEQ requirements. The Regulations are therefore unlawful because they were enacted "without observance of procedure re- quired by law." 5 U.S.C. § 706(2)(D). The typical remedy for NEPA violations is to en- join the unlawful federal action pending completion of a new EIS. In this case, that would mean enjoining enforcement of the Regulations published at Title 7 C.F.R. pt. 319.40. The Court, however, has consid- erable equitable discretion to determine the appro- priate form of injunctive relief. Unless Congress has intervened to control judicial discretion, in- junctive relief is "not a remedy which issues as of course." Weinberger v. Romero-Barcelo, 456 U.S. 305, 311-12, 72 L. Ed. 2d 91, 102 S. Ct. 1798 (1982). The courts should "not lightly assume that Congress has intended to depart from established principles" of equity. Id. at 313. NEPA does not limit the [*6] Court's equitable discretion, Save the Yaak Conn. v. Block, 840 F.2d 714, 722 (9th Cir. 1988), nor do any provisions of FPPA or PQA intimate a congressional in- tent to confine the exercise of equity jurisdiction. "'The essence of equity jurisdiction has been the power of the Chancellor to do equity and to mould each decree to the necessities of the particular case. Flexibility rather than rigidity has distinguished it.'" Weinberger, 456 U.S. at 312 (quoting Hecht Co. v. Bowles, 321 U.S. 321, 329, 88 L. Ed. 754, 64 S. Ct. 587 (1944)). "Although the district court has power to do so, it is not required to set aside every unlawful agency action. The court's decision to grant or deny injunctive or equitable relief un- der the [Administrative Procedure Act] is controlled by principles of equity." National Wildlife Fed'n v. Espy, 45 F .3d 1337, 1343 (9th Cir. 1995). When reg- ulations have been promulgated improperly, the Court may, if equity demands, leave the regulations in place while the agency follows the necessary procedures. Idaho Farm Bureau Fed'n v. Babbitt, 58 F.3d 1392, 1405 (9th Cir. 1995). To obtain an injunction, Plaintiffs must establish irreparable injury [*7] and the inadequacy of legal remedies. Weinberger, 456 U.S. at 312. The Court must balance the harms to the parties and the public in light of the substantive policies of the underly- ing statutes. Amoco Production Co. v. Village of Gambell, 480 U.S. 531, 544-45, 94 L. Ed. 2d 542, 107 S. Ct. 1396 (1987); Weinberger, 456 U.S. at 312. In other words, "the party seeking relief must show not merely a statutory violation, but a probability B-36 Appendix B. Court Documents 1997 U.S. Oist. LEXIS 9521, *7 of injury serious enough to outweigh any adverse ef- fects from the issuance of an injunction." Seattle Audubon Soc'y v. Evans, 771 F. Supp. 1081, 1088 (U.D . Wash.), aff'd, 952 F.2d 297 (9th Cir. 1991). B. Possible Forms of Injunctive Relief 1. Status Quo Ante An injunction returning regulation of the impor- tation of unfinished wood products to the status quo ante, i.e., reliance on visual inspection as the prin- cipal means of preventing the entry of infested wood into the United States, would clearly be inappro- priate and is not requested by any of the parties. The Court is required to shape equitable relief in light of the substantive policies of the underlying statutes. Gambell, 480 U.S. at 544. One of the purposes [*8] of NEPA is "to promote efforts which will prevent or eliminate damage to the environment." 42 U.S.C. § 4321. FPPA and PQA, similarly, are in- tended to prevent the introduction and spread of ex- otic pests. The parties agree that the current reg- ulations are an improvement over the status quo ante; they simply disagree about whether they are an ade- quate improvement. It would therefore be an abuse of discretion for the Court to issue an injunction which would result in less protection to the environ- ment and less protection against the entry of exotic pests into the United States than exist under the cur- rent Regulations. 2. Allow Current Regulations to Remain in Effect Until Completion of New EIS • APHIS maintains that the only appropriate action for the Court is to permit the current Regulations to remain in force in their entirety pending completion of a new EIS. Relying on cases discussing the doctrine of severability, the agency argues that the Court does not have the authority to pick and choose which pro- visions of the current Regulations to enforce. See North Carolina v. Federal Energy Regulatory Comm'n, 235 U.S. App. D.C. 28 , 730 F.2d 790 (O.C. Cir. 1984). Severability [*9] cases, however, are in- apposite. Severability is an issue when a partic- ular provision of a statute or regulation is invalid but the remainder is lawful. Here, the Regulations are unlawful in their entirety because the agency did not comply with the procedure required by law. The question before the Court, therefore, is not whether certain unlawful portions of the Regulations may be stricken in order to allow the remainder to continue in effect indefinitely. The question is what interim form of relief the Court should institute pending com- pletion of a new EIS and promulgation of regulations in light of the new EIS. As discussed above, the current Regulations are the baseline for appropriate injunctive relief. Additional injunctive relief may be appropriate, how- ever, if Plaintiffs satisfy the requirements for eq- uitable relief. a. Injunction Against Additional Permits ONRC argues that the most appropriate form of re- lief is an injunction preventing APHIS from issuing additional permits under the Regulations but allowing existing permits to continue in force. ONRC main- tains that this injunction will reduce the risk of entry of exotic pests into the United States while minimizing [*10] interference with established eco- nomic expectations and existing contracts. Based on the fact that the Court found that APHIS assuned when drafting the EIS that individually in- effective control measures would be effective collec- tively, ONRC maintains that the entry of exotic pests into the United States in wood imports continues to be a substantial threat. ONRC also points to APHIS1 own studies which found that non- tropical wood products from Chile, New Zealand, and Siberia pose a high risk of harboring pests that could be damaging to American forests. APHIS responds that ONRC's fear is too speculative to justify enjoining additional wood imports. APHIS is partially correct. ONRC requests that APHIS be enjoined from issuing any new permits under the ex- isting regulations. Some categories of wood products governed by the Regulations, however, do not pose a significant threat of infestation to forests in the continental United States. Bamboo and tropical hard- woods, for example, pose little threat to temperate forests in the United States. Pests from forests that are comparable to American forests pose a greater threat. A particular ex- otic pest may be well-adapted to the conditions [*111 that prevail in American forests, but may not be con- strained by resistances to it that developed in its region of origin. Indeed, some of the most devas- tating North American infestations in the past were caused by pests that were innocuous in their regions of origin. Denison Decl. P 20. Two catastrophic infestations affecting North American hardwood trees originated with the importation of infected logs from Europe and Asia: chestnut blight and Dutch elm disease. 7 Ackninistrative Record ("AR") 2163-64. APHIS' own studies demonstrate a high risk of infes- Appendix B. Court Documents B-37 1997 U.S. Dist. LEXIS 9521, *11 tation from non-tropical trees grown in Chile, New Zealand, and Siberia. 8 AR 2636, 9 AR 2951, 9 AR 3191. In addition, the administrative record con- tains criticisms of APHIS' risk studies for focusing on known rather than unknown risks. 9 AR 2783, 10 AR 3438-40. The record therefore indicates a significant threat of infestation from forests comparable to those in the United States, but does not indicate a significant threat from tropical hardwoods. APHIS does not deny that if exotic pests did establish them- selves in American forests, the consequences could be devastating and difficult to mitigate. When an injury to the environment [*121 is "suf- ficiently likely," the balance of harms will usually favor the issuance of an injunction to protect the en- vironment. Gambell, 480 U.S. at 545. Although APHIS provided estimates of the economic impact associated with enjoining the issuance of new permits, it did not provide an estimate of the costs of an injunction targeted at imports from regions which pose the great- est threat to the health of American forests. Given that an injunction would remain in effect only un- til APHIS completes a new EIS and promulgates regula- tions that comply with NEPA, the short-term economic consequences of an injunction against the issuance of new permits for the import of non-tropical unfinished wood prooucts are outweighed by the potential for ir- reparable harm to American forests by the importation of exotic pests. ONRC has therefore demonstrated sufficient like- lihood of environmental harm to justify an injunction against the issuance of new permits for the import of non-tropical unfinished wood products. b. Rescission of Permits Already Issued CATS argues that ONRC's proposed injunction is too limited because it allows those who already have permits to continue importing unfinished [*131 wood products despite the inadequacy of the current Regulations. Although CATS correctly points out that ONRC's proposed injunction does not address the threat cosed by wood being imported under existing permits, CATS' injunction would entail significantly greater economic costs. In addition, courts have been more reluctant to interfere with existing per- mits than to enjoin the issuance of new ones. See Forelaws on Board v. Johnson, 743 F.2d 677 , 686 ( 9th Cir. 1984), cert, denied, 478 U.S. 1004, 92 L. Ed. 2d 709, 106 S. Ct. 3293 (1986) (cited in Gambell, 480 U.S. at 541; Forest Conservation Council v. United States Forest Serv., 66 F.3d 1489, 1496 (9th Cir. 1995)). Given the interference with existing eco- nomic interests and contracts that would necessarily result from rescinding permits and given the greater cost that would result from enjoining all imoorts, the Court finds that CATS has failed to establish that the balance of harms tips in favor of issuing its proposed injunction. C. Compliance with GATT APHIS contends that enjoining the issuance of new permits is contrary to the General Agreement on Tariffs and Trade ("GATT") See WTO-SPS arts. 2.2- 2.3. Article [*141 2.2 of the agreement on sanitary and phytosani tary measures provides that "Members shall ensure that any sanitary or phytosani tary mea- sure is applied only to the extent necessary to pro- tect human, animal or plant life or health, is based on scientific principles and is not maintained with- out sufficient scientific evidence . . . ." When relevant scientific evidence is insufficient, "a Member may provisionally adopt sanitary or phytosani- tary measures on the basis of available pertinent in- formation .... Members shall seek to obtain the additional information necessary for a more objective assessment of risk . . . within a reasonable pe- riod of time." WTO-SPS art. 5.7. Phytosanitary mea- sures may not arbitrarily or unjustifiably discrimi- nate between member nations where similar conditions prevail and may not constitute disguised restrictions on international trade. UTO-SPS art. 2.3. By enjoining only the issuance of new permits for imports that pose a threat of infestation to North American forests, the injunction is not broader than necessary to protect plant life. The injunction will last only until APHIS conducts a new EIS and promul- gates regulations that comply with NEPA. By permit- ting [*151 imports to continue under existing per- mits, the impact on international trade is minimized. The injunction proposed by ONRC, as modified to al- low the importation of wood products that do not pose a threat to the health of North American forests, is therefore consistent with the United States' obliga- tions under GATT. D. Geographic Scope Intervenors contend that Plaintiffs do not have standing to request injunctive relief outside the Northern District of California or, in the alterna- tive, California, Oregon, and Washington. District courts, however, may grant nationwide injunctive re- lief when necessary to provide the plaintiff complete relief. Bresgal v. Brock, 843 F.2d 1163, 1170-71 (9th Cir. 1987); see also Califano v. Yamasaki, B-38 Appendix B. Court Documents 1997 U.S. Dist. LEXIS 9521, *15 442 U.S. 632, 702, 61 L. Ed. 2d 176 , 99 S. Ct. 2545 (1979) (in class action, “scope of injunctive relief is dictated by the extent of the violation established, not by the geographical extent of the plaintiff class"). In the previous Order, the Court held that Plaintiffs have standing to challenge the Regulations' compliance with NEPA. As Intervenors' own discussion of the introduction of the pitch canker into California demonstrates, pests in one [*16] re- gion of the country can spread to other regions of the country. West Coast forests, therefore, face a threat of infestation regardless of the port of en- try of the infested wood. Limiting the scope of in- junctive relief to northern California or to the West Coast would therefore deny Plaintiffs complete re- lief. The Court thus has the authority to issue a nationwide injunction. CONCLUSION The Court finds that ONRC has established a sub- stantial likelihood of irreparable harm resulting from the introduction of exotic pests into United States forests by means of imports of nontropical un- finished wood products. The balance of harms tips in favor of enjoining APHIS from issuing new permits for such products but allowing imports to continue under permits that have already been issued. For the foregoing reasons, Plaintiff ONRC's mo- tion for a preliminary injunction is GRANTED in part. Plaintiff CATS' motion for an injunction and declara- tory relief is DENIED. The Court therefore ENJOINS APHIS from issuing any; new permi ts for the importation of unfinished non-tropical wood products pursuant to Title 7 C.F.R. §§ 319.40-5(b) (Monterey pine logs and lirtoer from Chile and New Zealand, Doug l as- fi r [*17] logs and lim- ber from New Zealand), 319.40-5(d) (temperate hard- woods), 319.40-6(a) (universal importation, logs), and 319.40-6(b) (universal importation, limber) until APHIS prepares a new Environmental - Impact Statement and promulgates regulations governing the importa- tion of unmanufactured wood products. Except to the extent otherwise required by this Order, APHIS shall comply with the Regulations published at Title 7 C.F.R. pt. 319.40 until it has promulgated regula- tions that comply with NEPA. The parties shall appear before the Court on Friday, May 15, 1998, to report the progress in issu- ing a new EIS. IT IS SO ORDERED. Dated: JUN - 5 1997 CLAUDIA UILKEN United States Oistrict Judge Appendix B. Court Documents B-39 [This page is intentionally left blank ] B-40 Appendix B. Court Documents Appendix C. Documents Related to Compliance 1. Enhanced Hazard Risk Assessment for Determining the Quarantine Status of Exotic Organisms C-3 2. Compliance Agreement, PPQ Form 519 C-5 a. Attachment 1, Regulated Foreign Lumber Processing Facility - Dry Kiln Mill . C-7 b. Attachment 2, Foreign Logs Processing Facility - Sawmill C-9 c. Attachment 3, Regulated Foreign Logs Processing Facility - Veneer Mill ... C-l 1 d. Attachment 4, Foreign Logs and Lumber, Regulated Wood Waste Processing Facility - Paper Mill C-l 5 e. Attachment 5, Foreign Logs and Lumber, Regulated Wood Waste Processing Facility - Particleboard Mill C-l 7 f. Attachment 6, Foreign Logs and Lumber, Regulated Wood Waste Processing Facility - Power Plant C-l 9 3. Compliance Service Agreement Example C-21 Appendix C. Documents Related to Compliance C-1 [This page is intentionally left blank ] C-2 Appendix C. Documents Related to Compliance ENHANCED HAZARD RISK ASSESSMENT FOR DETERMINING THE QUARANTINE STATUS OF EXOTIC ORGANISMS This enhanced hazard risk assessment process is a toot used by APHIS-PPQ-BATS to quickly determine and document the quarantine status of exotic organisms, especially for taxa sent as "Urgent" interceptions. Taxa not formerly evaluated or in need of re-evaluation are assessed using the ciitena listed below. The taxon is determined as reportable or nonreportable using the attached risk table, and the taxon name is subsequently added to the appropriate pest or tally quarantine status list (dictionary). A record of the evaluation, including citations of references used, is maintained in an electronic file. Criterion 1: Taxonomy (H) Complete species or subspecies identification. (M) Generic or higher level identification only and assessor feels comfortable extrapolating information from similar organisms. (L) Generic or higher level identification only and assessor not comfortable extrapolating information from similar organisms. Criterion 2: Hazard Identification/Distribution of Taxon. (H) Non-indigenous and not present, but capable of establishment in the U.S.; or Non-indigenous with limited range in the U.S. and under official control (or will soon be evaluated by APHIS); or Non-indigsnous, present in the U.S., and reached probable limits of range, but genetically different enough to warrant concern and/or vector a foreign plant pest. (M) Native, but genetically different enough to warrant concern or to vector an exotic plant pest (that the original taxon could not), and is capable of further expansion or increased damage potential. (L) Non-indigenous or native in U.S. and reached probable limits of range and not genetically different enough to warrant concern and/or vector a foreign plant pest, or Has NOT reached probable limits of range, but no official control exists or is likely to be initiated. (U) Unknown, not enough information available to make a choice. Criterion 3: Agricultural Concern — Known Importance. (H) Known pest or capable of vectoring known pests of agriculture (crops, forests, animals, beneficial organisms, environment, etc.). (M) Not known as a pest of agriculture, but having characteristics that demonstrate a potential for becoming a pest in the U.S. (L) Not known as a pest of agriculture & not likely to become a pest if established in the U.S. (U) Unknown, not enough information available to make a choice. Appendix C. Documents Related to Compliance C-3 ENHANCED HAZARD RISK ASSESSMENT QUARANTINE STATUS DECISION TABLE RISK RATING RISK CATEGORY QUARANTINE DECISION HIGH RISK TO MEDIUM RISK HHH HHM HMH HMM HMU HUM MHH MHM MUM LHM LUM Quarantine Action Required LOW RISK HHL HHU HLH HLM HLU HUL HUU MHL MHU MLM MILL MLU MUL MUU LHL LHU LLH LLM ILL LLU LLU LUU No Action Required NOT APPLICABLE* (RE-ASSESS) HML HUH MMH MMM MMH MML MMU MLH MUM LHH LMH LMM LML LMU LUH invalid risk category combinations * NOTE: Some ranking combinations are invalid or very unlikely. For example, for taxa above the species level (M or L ranks. Criterion 1), It is not likely that an assessor would know the taxons genetic map (M rank. Criterion 2) or have knowledge that the taxon represents a •known pest" (H rank. Criterion 3). □ FOR URGENT INTERCEPTIONS: Use the Table to determine quarantine action on imported shipments infested with the rated organism. □ TO ADD THE ORGANISM TO EITHER THE PEST OR TALLY LIST: First re-assess all organisms with assigned risk categories: "L— ". The assessor should become comfortable with extrapolating information from similar organisms, before assigning a quarantine status to the taxon. "-U-.", "-U", or "-UU". Taxa will not be listed until their presence or absence in the U.S. is known and their potential impact on U.S. agriculture is estimated. rated as "not applicable" by the enhanced hazard process (see note, above). Add to the Pest List all organisms ranked high-to-medium risk, or to the Tally List all organisms ranked low risk by the enhanced hazard process. C-4 Appendix C. Documents Related to Compliance UNITED STATES DEPARTMENT OF AGRICULTURE ANIMAL. AND PLANT HEALTH INSPECTION SERVICE PLANT PROTECTION AND QUARANTINE COMPLIANCE AGREEMENT 1 NAME AND MAILING ADDRESS OF PERSON OR FIRM 2. LOCATION 3. REGULATED ARTICLE(S) 4. APPLICABLE FEDERAL QUARANTINE(S) OR REGULATIONS 6. //We agree to the following: [Note: See attachments 1-6/ any of which could be referred to here.] 7 SIGNATURE 8. TITLE 9 DATE SIGNEO The alfixing of the signatures below will validate this agreement which shall remain in citect until cancelled, but may be revised as necessary or revoked tor noncompiiance. 10. AGREEMENT NO. 1 1. DATE OF AGREEMENT 12 ppq official tXame and Title i 1 3. AOORESS 14 SIGNATURE is. STATE AGENCY o F Fi c i a l < Name ana Title l 16. ADDRESS 17. SIGNATURE PPQ FORM 519 Appendix C. Documents Related to Compliance C-5 [This page is intentionally left blank.] C-6 Appendix C Documents Related to Compliance Compliance Agreement - Attachment #1 Regulated Foreign Lumber Processing Facility - Dry Kiln Mill 1. The imported lumber will be kept segregated from other wood products from the time of discharge and release at the port of entry until the lumber is completely processed under the terms of the import permit and this compliance agreement. 2. The imported lumber will move to this facility in as direct a route as reasonably possible with no diversions. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 3. The facility will be responsible for notifying the USDA, APHIS Work Unit office (specified below) of the arrival of shipments at the processing facility. 4. This facility may receive raw lumber imported from all sources identified in 7 CFR 3 19.40 and specified on the importer’s permit. 5. Any pallets, dunnage or other solid wood packing material used in the shipment of the regulated wood must be processed as regulated wood under the terms of this agreement. 6. The raw lumber must be heat treated in accordance with the 319.40-7c or heat treated with moisture reduction in accordance with 3 19.40-7-d within thirty (30) days from the time the lumber is released from the port of first arrival into the United States. Heat treatment must be completed before any cutting, planing, or sawing of the raw lumber. (a) Kiln drying, conducted in accordance with the schedule prescribed for the regulated article in the Dry Kiln Operator’s Manual, Agriculture Handbook 188. (b) Dry heat, exposure that raises the temperature of the center of each regulated article to at least 71.1 °C (160 °F), and maintains the article at that temperature for at least 75 minutes and reduces the moisture content of the article to 20 percent or less. 7. A record or log book will be kept by this facility listing imported wood type (genus and species), quantity, origin (country), importer of record or facility received from, and treatment completion data. The record will be made available to APHIS officers or APHIS cooperators upon request. 8. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. Appendix C. Documents Related to Compliance C-7 9. The APHIS Work Unit office in shall be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or compromise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions, etc. The APHIS contact telephone number is , fax is . Office hours are to , Monday through Friday. 10. Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in 1 1. This agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that this facility, its’ employees, or agents have failed to comply with its conditions. If the cancellation is oral, the decision to cancel this agreement and the reason(s) for canceling shall be confirmed in writing as promptly as circumstances permit. Any cancellation may be appealed in writing to the Administrator within ten days after receiving written notification of the cancellation. The appeal shall state all the facts and reasons upon which the company replies to show that the compliance agreement was wrongfully canceled. The administrator shall grant or deny the appeal as promptly as circumstances permit. If there is a conflict as to any material fact, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. As of the (Title) (Name of company) facility, I have read and understood the conditions of this compliance agreement. Signature Date Title C-8 Appendix C. Documents Related to Compliance Compliance Agreement - Attachment #2 Foreign Logs Processing Facility - Sawmill 1. The imported logs and products derived from those logs will be kept segregated from other wood products from the time of discharge and release at port of entry until the regulated wood products are completely processed under the terms of the import permit and this compliance agreement. 2. The logs will be moved from the port of first arrival to the sawmill in as direct a route as reasonably possible with no diversions. Log trucks or containers may be used to transport the logs from the port of arrival to the mill. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 3. The facility will be responsible for notifying the USDA, APHIS Work Unit office (specified below) of the arrival of shipments at the processing facility. 4. At the destination mill, the logs will be unloaded and put directly into decks designated for the imported logs and apart from other logs. If brow logs are used, those logs must also be processed under the terms of this agreement. 5. Any pallets, dunnage or other solid wood packing material used in the shipment of the regulated wood must be processed as regulated wood under the terms of this agreement. 6. A record or log book will be kept by this facility listing imported wood type (genus and species), quantity, origin (country), importer of record, and treatment completion data. The record will be made available to APHIS officers or APHIS cooperators upon request. 7. Logs will be processed into lumber at the sawmill in accordance with the following procedures. a. Regulated logs will be processed separately from other logs, unless all logs processed at that time are processed under the terms of this agreement. b. Green lumber produced will be kiln dried at this facility or may be transported to another facility which is under compliance with USDA, APHIS to process regulated green lumber. The kiln drying process must raise the temperature of each article to at least 71.1 °C (160 °F) at its center and maintain that temperature for at least 75 minutes, reducing the moisture content of the treated article to 20 percent or less. c. The mill will be cleaned of all regulated chips, sawdust and wood waste before processing other non-regulated logs. Appendix C. Documents Related to Compliance C-9 8. All chips and sawdust produced from the bucking and trimming operations will be collected and handled as regulated wood waste. 9. Regulated wood waste must be collected for burning as fuel at the mill site, or collected into a closed container for transport to another facility which is under compliance with USDA, APHIS, to process regulated wood waste into paper, particle board or energy. 10. Transport of regulated wood waste shall be in closed trucks and trailers with tightly tarped tops and no open screen vents, by as direct a route as reasonably possible. Receiving facilities must be declared and approved by the monitoring official before shipments are allowed to proceed to that facility. 1 1 . The regulated logs and products generated from those logs (such as veneer, lumber, chips, sawdust, or other products) must be processed in accordance with this agreement within 60 days of the time the logs are released from the port of first arrival. 12. Only regulated articles covered by this agreement will be processed at any one time unless all articles processed are treated in accordance with the provisions of this agreement. Sanitary practices adequate to assure treatment of all or practically all of the products derived from the logs shall be used at regular intervals during the processing and at completion of all processing of each shipment under this agreement. Truck beds, containers, loaders, tarpaulins and other components of the transportation and loading system shall be thoroughly sept out before subsequent contact with non-regulated articles. Sweepings will be treated as a regulated wood waste. 13. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. 14. The APHIS Work Unit office in , be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or comprise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions and etc. The APHIS contact telephone number is , fax is . 15. Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in , to , Monday through Friday. C-10 Appendix C. Documents Related to Compliance Compliance Agreement - Attachment #3 Regulated Foreign Logs Processing Facility - Veneer Mill 1. The imported logs, veneer blocks, cants and the products derived from them will be kept separate from all other wood products from the time of discharge from the means of conveyance until the regulated wood products are completely processed under the terms of the import permit and this compliance agreement. 2. The regulated logs, veneer blocks and/or cants will be transported to the mill in as direct a route as reasonably possible with no diversions. Log trucks or containers may be used to transport the logs from the port of arrival to the mill. Regulated veneer blocks must be transported in a completely enclosed container or on a tightly tarped truck. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 3. The facility will be responsible for notifying the USDA, APHIS Work Unit office (specified below) of the arrival of shipments at the precessing facility. 4. At the destination mill, the logs, veneer blocks or cants will be unloaded and put directly into decks designated for the imported wood and apart from other logs. If brow logs are used, those logs must also be processed under the terms of this agreement. 5. Regulated logs, veneer blocks and cants will be processed in accordance with the following procedures. a The regulated logs, veneer blocks and cants will be processed separately from all other wood products unless all wood products are processed under the terms of this agreement. b. All regulated logs, veneer blocks and cants may be trimmed to size before steaming. c. Veneer blocks and cants will be heat treated in the steam vaults for 24 hours at 165-180 °F, or other appropriate schedule as is customary before slicing. d. Green veneer must be treated with dry heat in the veneer drier with exposure to temperatures of at least °C ( °F) for at least minutes which will result in a moisture content of 20 percent or less. This is considered to meet or exceed the requirements for heat treatment with moisture reduction as stipulated in 7 CFR 319.40. e. Regulated wood waste, including lily pads, veneer block cores and substandard veneer sheets may be processed into wood chips and sawdust or may be kiln dried utilizing a process which must raise the temperature of each article to at least 71.1 °C (160 °F) at its center and maintain that temperature for at least 75 minutes, reducing the moisture content Appendix C. Documents Related to Compliance C-11 of the treated article to 20 percent or less. The chips and sawdust generated during the processing of the regulated articles may be utilized immediately for fuel onsite, or alternatively, may be collected for transportation to an approved processing facility under compliance with USDA, APHIS. f. Transport of regulated wood waste shall be in closed trucks and trailers with tightly tarped tops and no open screen vents, by as direct a route as possible. Receiving facilities must be declared and approved by the monitoring official before shipments are allowed to proceed to that facility. g. The mill will be cleaned of all regulated chips, sawdust and wood waste before processing other non-regulated logs or blocks. 6. The regulated logs and products generated from those logs (such as veneer, lumber, chips, sawdust, or other products) must be processed in accordance with this agreement within 60 days of the time the logs are released from the port of first arrival. 7. Only regulated articles covered by this agreement will be processed at any one time unless all articles processed are treated in accordance with the provisions of this agreement. Sanitary practices adequate to assure treatment of all or practically all of the products derived from the logs shall be used at regular intervals during the processing and at completion of all processing of each shipment under this agreement. Truck beds, containers, loaders, tarpaulins and other components of the transportation and loading system shall be thoroughly sept out before subsequent contact with non-regulated articles. Sweepings will be treated as a regulated wood waste. 8. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. 9. The APHIS Work Unit office in , be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or comprise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions and etc. The APHIS contact telephone number is , fax is . 10. Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in 1 1 . This agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that this facility, its’ employees, or agents have failed to comply with its conditions. If the cancellation is oral, the decision to cancel this agreement and the reason(s) for canceling shall be confirmed in writing as promptly as circumstances permit. Any cancellation may be appealed in writing to the Administrator within ten days after receiving written notification of the cancellation. The appeal shall state all the facts and C-12 Appendix C. Documents Related to Compliance reasons upon which the company replies to show that the compliance agreement was wrongfully canceled. The administrator shall grant or deny the appeal as promptly as circumstances permit. If there is a conflict as to any material fact, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. As of the (Title) (Name of company) facility, I have read and understood the conditions of this compliance agreement. Signature Date Title Appendix C. Documents Related to Compliance C-13 [This page is intentionally left blank ] C-14 Appendix C. Documents Related to Compliance Compliance Agreement - Attachment #4 Foreign Logs and Lumber Regulated Wood Waste Processing Facility - Paper Mill 1 . Regulated sawdust, shavings and chips may be delivered to this mill from any source mill under compliance to process the regulated logs and wood products. 2. This facility will be responsible for notifying the USDA, APHIS Work Unit office (specified below) of the arrival of shipments at the processing facility. 3. The regulated wood waste must be moved from the source mill to this facility in as direct route as reasonably possible with no diversions. The wood waste (defined here as regulated sawdust, wood chips and/or shavings) must be received in closed trucks and trailers with tightly tarped tops ad no open screen vents. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 4. Upon delivery, the regulated material must be placed in a storage area which is separate from other nonregulated material unless all material processed from that storage area is handled in accordance with th eprovisins of this agreement. Alternatively, the regulated material must be placed at the front of the wood waste storage area to go directly int the digester. 5. The delivering trucks and trailers will be swept free of all wood waste to include the exterior surfaces of the vehicle such as bumpers and tailgates. Any wood waste obtained from this or any other cleaning process that is not of a quality to be utilized for pulp production may be utilized for fuel production onsite, with the provision that the material should be placed at the front of the fuel storage area for immediate consumption. 6. All regulated wood waste must be processed into pulp or consumed as fuel within 60 days of the tie that the regulated wood product was released at the port of entry. All other wood products “contaminated” by these deliveries will also be processed in the same time period. 7. The pulp manufacturing processed is considered to meet or exceed the requirements for heat treatment as stipulated in 7 CFR 319.40-7c. 8. A record or log book will be kept by this facility listing imported wood type (genus and species), quantity, origin (country), importer of record, and treatment completion data The record will be made available to APHIS officers or APHIS cooperators upon request. 9. Only regulated articles covered by this agreement will be processed at any one time unless all articles processed are treated in accordance with the provisions of this agreement. Sanitary practices adequate to assure treatment of all or practically all of the products derived from the logs shall be used at regular intervals during the processing and at completion of all processing of each shipment under this agreement Truck beds, containers, loaders, tarpaulins and other Appendix C. Documents Related to Compliance C-15 components of the transportation and loading system shall be thoroughly sept out before subsequent contact with non-regulated articles. Sweepings will be treated as a regulated wood waste. 10. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. 1 1 The APHIS Work Unit office in , be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or comprise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions and etc. The APHIS contact telephone number is , fax is . 12. Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in 13. This agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that this facility, its’ employees, or agents have failed to comply with its conditions. If the cancellation is oral, the decision to cancel this agreement and the reason(s) for canceling shall be confirmed in writing as promptly as circumstances permit. Any cancellation may be appealed in writing to the Administrator within ten days after receiving written notification of the cancellation. The appeal shall state all the facts and reasons upon which the company replies to show that the compliance agreement was wrongfully canceled. The administrator shall grant or deny the appeal as promptly as circumstances permit. If there is a conflict as to any material fact, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. As of the (Title) (Name of company) facility, I have read and understood the conditions of this compliance agreement. Signature Date Title C-16 Appendix C. Documents Related to Compliance Compliance Agreement - Attachment #5 Foreign Logs and Lumber Regulated Wood Waste Processing Facility - Particleboard Mill 1. Regulated sawdust, shavings and chips may be delivered to this mill from any source mill under compliance to process the regulated logs and wood products. 2. This facility will be responsible for notifying the USDA, APHIS, Work Unit office (specified below) of the arrival of shipments at the processing facility. 3. The required wood waste must be moved from the source mill to this facility in as direct a route as reasonably possible with no diversions. The wood waste (defined here as regulated sawdust, wood chips and/or shavings) must be received in closed trucks and trailers with tightly tarped tops and no open screen vents. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 4. Upon delivery, the regulated material must be placed in a storage area which is separate from other non-regulated material unless all material processed from that storage area is handled in accordance with the provisions of this agreement. Alternatively, the regulated material must be placed at the front of the wood waste storage area to go directly into the processor. 5. The delivering trucks and trailers will be swept free of all wood waste to include the exterior surfaces of the vehicle such as bumpers and tailgates. Any wood waste obtained from this or any other cleaning process that is not of a quality to be utilized for particleboard production may be utilized for fuel production onsite, with the provision that the material should be placed at the front of the fuel storage area for immediate consumption. 6. All regulated wood waste must be processed into particleboard or consumed as fuel within 60 days of the time that the regulated wood product was released at the port of entry. All other wood products “contaminated” by these deliveries will also be processed in the same time period 7. The particleboard manufacturing process is considered to meet or exceed the requirements for heat treatment as stipulated in 7 CFR 3 19-40-7c. 8. A record or log book will be kept by this facility listing imported wood type (genus and species), quantity, origin (country), importer of record, and treatment completion data. The record will be made available to APHIS officers or APHIS cooperators upon request. 9. Only regulated articles covered by this agreement will be processed at any one time unless all articles processed are treated in accordance with the provisions of this agreement. Sanitary practices adequate to assure treatment of all or practically all of the products derived from the logs shall be used at regular intervals during the processing and at completion of all processing Appendix C. Documents Related to Compliance C-17 of each shipment under this agreement. Truck beds, containers, loaders, tarpaulins and other components of the transportation and loading system shall be thoroughly sept out before subsequent contact with non-regulated articles. Sweepings will be treated as a regulated wood waste. 10. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. 1 1 . The APHIS Work Unit office in , be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or comprise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions and etc. The APHIS contact telephone number is , fax is . 12. Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in 13. This agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that this facility, its’ employees, or agents have failed to comply with its conditions. If the cancellation is oral, the decision to cancel this agreement and the reason(s) for canceling shall be confirmed in writing as promptly as circumstances permit. Any cancellation may be appealed in writing to the Administrator within ten days after receiving written notification of the cancellation. The appeal shall state all the facts and reasons upon which the company replies to show that the compliance agreement was wrongfully canceled The administrator shall grant or deny the appeal as promptly as circumstances permit. If there is a conflict as to any material fact, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. As of the (Title) (Name of company) facility, I have read and understood the conditions of this compliance agreement. Signature Date Title C-18 Appendix C. Documents Related to Compliance Compliance Agreement - Attachment #6 Foreign Logs and Lumber Regulated Wood Waste Processing Facility - Power Plant 1 . Regulated sawdust, shavings and chips may be delivered to this mill from any source mill under compliance to process the regulated logs and wood products. 2. This facility will be responsible for notifying the USDA, APHIS Work Unit (specified below) of the arrival of shipments at the processing facility. 3. The regulated wood waste must be moved from the source mill to this facility in as direct a route as reasonably possible with no diversions. The wood waste (defined here as regulated sawdust, wood chips and/or shavings) must be received in closed trucks and trailers with tightly tarped tops and no open screen vents. If rail transportation is used, then a letter of express shipment must be requested from the rail carrier to prevent delay in transit. 4. Upon delivery the material must be placed at the front of the chip storage area going into the furnace. 5. The delivering trucks and trailers will be swept free of all wood waste t include the exterior surfaces of the vehicle such as bumpers and tailgates. Any wood waste obtained from this or any other cleaning process will be consumed as fuel under the conditions of this agreement. 6. All regulated wood waste must be consumed as fuel within 60 days of the time that the regulated wood product was released at the port of entry. All other wood products “contaminated” by these deliveries will also be burned in the same time period. 7. The furnace will burn all the regulated wood waste to ash. 8. A record or log book will be kept by this facility listing imported wood type (genus and species), quantity, origin (country), importer of record or facility received from, and treatment completion data The record will be made available to APHIS officers or APHIS cooperators upon request. 9. APHIS inspectors and/or APHIS cooperators will be permitted access to the premises described to monitor compliance with this agreement. 10 The APHIS Work Unit office in , be notified as soon as possible (but not later than 24 hours) when conditions exist that violate or comprise the conditions of this agreement. These conditions could include, but are not limited to, spills, accidents, equipment malfunctions and etc. The APHIS contact telephone number is _, fax is _. Appendix C. Documents Related to Compliance C-19 1 1 . Requests for changes or revisions to this agreement must be made in writing and submitted to the APHIS office in , . 12. This agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that this facility, its employees, or agents have failed to comply with its conditions. If the cancellation is oral, the decision to cancel this agreement and the reason(s) for canceling shall be confirmed in writing as promptly as circumstances permit. Any cancellation may be appealed in writing to the Administrator within ten days after receiving written notification of the cancellation. The appeal shall state all the facts and reasons upon which the company replies to show that the compliance agreement was wrongfully canceled. The administrator shall grant or deny the appeal as promptly as circumstances permit. If there is a conflict as to any material fact, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. As of the (Title) (Name of company) facility, I have read and understood the conditions of this compliance agreement. Signature Date Title C-20 Appendix C. Documents Related to Compliance Agreement No . Accounting No. COOPERATIVE SERVICE AGREEMENT Between xxxxxxxxxxxxxxx And UNITED STATED DEPARTMENT OF AGRICULTURE (USDA) ANIMAL AND PLANT HEALTH INSPECTION SERVICE (APHIS) Article 1 - Purpose THIS AGREEMENT is made and entered into by and between XXXXXXXXXXXXXX. , hereafter referred to as the Cooperator, United Stated Department of Agriculture, Animal and Plant Inspection Service, hereafter referred to as APHIS. and the Health APHIS requires that certain agricultural produce imported XXXXXX , be inspected and/or treated by an AP^ °j;flC^ J"° the risk of introducing pests into the United States (US) eliminated; and from insure is The purpose of this agreement is to provide training for XXXXX Officers in order for them to initiate certain treatments o fruit offered for import at embarkation points outside the requested by the Cooperator. This inspection and/or treatment o the produce outside the US will aid in keeping undesirable pests and diseases from entering the US, thus giving addea protection to the agricultural areas of the US; and It is the intention of the parties hereto that such cooperation shall be for their mutual benefit and the benefit of the people of the US and XXXXXX. NOW, THEREFORE, for and in consideration of the promises and mutual covenants herein contained the parties hereto do mu ua y agree with each other as follows: Appendix C. Documents Related to Compliance C-21 Paae Z. Article 2 - Authority APHIS is authorized by 7 USC 147a (b) , as amended, to cooperate with the governments of foreign countries and with foreign or international organizations or associations to detect, eradicate, suppress, control, and prevent or retard the spread of plant pests . Furthermore, the Food, Agriculture, Conservation, and Trade Act of 1990, Pub. L. No. 101-624, Section (c) 2509, 1045 Stat . 4069- 4073(1990), authorized APHIS to "collect fees to reimburse APHIS for the cost of carrying out the provision of the Federal Animal Quarantine Laws that relate to the importation, and exportation of animals, article, or means of conveyance." Article 3 - Mutual Responsibilities The looperator and APHIS mutually agree that; Commodity-Specific workplans will be elaborated by APHIS and the Cooperator or its representative and updated annually, in order to delineate technical parameters and to quantify the workload. Article 4 - The Cooperator' s Responsibilities The Cooperator agrees to/that; a. Designate in writing, to APHIS, an authorized representative who shall be responsible for administering the activities conducted under this Agreement. b. Deposit, upon execution of this Agreement, a certified or cashier's check for $X,XXXXXX with the US Treasury, through USDA, to be expended in accordance with USDA regulations , to cover salaries (including overtime), benefits, travel, subsistence, and other incidental expenses for APHIS Officers needed to perform the work herein described and administrative expenses . Whenever C-22 Appendix C. Documents Related to Compliance Page 3 the initial deposit is not sufficient to meet either the workload costs under this Agreement or its continuation, a further sum determined by APHIS shall be deposited, prior to completion of the work. All subsequent quarterly deposits shall be made by certified or cashier's check 30 days before the beginning of the quarter . c. Obtain form the Government of XXXXXX any necessary permits or licenses required for the APHIS Officers to have free access to locations necessary for performance of the planned work. d. Furnish facilities in XXXXXX for APHIS Officers and furnish personnel to be trained by APHIS Officers to inspect and/or treat produce offered for import into the US. e. If any pests of economic significance to the US are found, the infested shipments will not be certified for shipment to US markets . Article 5 - APHIS Responsibilities APHIS agrees. to; a. Designate in writing, to the Cooperator, its authorized representative who shall be responsible for administering the activities conducted under this Agreement. b. Furnish as requested by the Cooperator necessary training inspection personnel to: 1) provide training as necessary, 2) review and certify their inspection and treatment facilities, 3) provide supervision of the treatments, and 4) inspect and release the produce for shipment to the US when it meets plant quarantine requirements. The APHIS Officer/Officers will be furnished at the time or times agreed upon by the parties insofar as availabilities of personnel will permit. c. Make an accounting of the monies deposited by the Cooperator quarterly with a final accounting upon termination or expiration Appendix C. Documents Related to Compliance C-23 Page 4 of the Agreement. Any balance remaining unobligated at the conclusion of any fiscal year may be utilized during the ensuing fiscal year if a continuation of the inspection services is required. Any unobligated balance upon termination or expiration of this Agreement shall be returned to the Cooperator. Article 6 - Contingency Statement This Agreement is contingent upon the Cooperator depositing, with APHIS, funds needed to conduct covered activities and upon the availability of APHIS personnel to conduct services. Article 7 - Agreements with Other Entities That nothing in the Agreement shall prevent any other country, organization, or individuals from entering into separate Cooperative service Agreements with APHIS for the purpose of inspecting, certifying, and releasing produce for shipment into the US . Article 3 - Congressional Restriction Under 41 USC 22, no member of or delegate to Congress or resident commissioner shall be admitted to any share or part of this agreement or any benefit that may arise there from, unless it be made with corporation for its general benefit. C-24 Appendix C. Documents Related to Compliance Paae 5 Article 9 - Agreement Maintenance This Agreement Shall become effective upon date of final signature and shall continue indefinitely. This Agreement may be amended at any time by mutual agreement of the parties in writing and may be terminated by either party upon 60 days written notice to the other party and provided further, that in the event the Cooperator does not for any reason deposit necessary funds, APHIS is relieved of the obligation to continue any operation under this Cooperative Service Agreement. This Agreement shall not create any binding obligations under international law. FOR THE UNITED STATED DEPARTMENT XXXXXXXXXXXXXXXXX ANIMAL AND PLANT HEALTH XXXXXXXXXXXXXXXXXXXX INSPECTION SERVICE XXXXXXXXXXXX xxxxxxxxxxxxxxxx xxxxxxx Administrator xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxXx Date Date Appendix C. Documents Related to Compliance C-25 C-26 Appendix C. Documents Related to Compliance Appendix D. Acronyms APHIS Animal and Plant Health Inspection Service (an agency within the U S Department of Agriculture) AQI Agricultural Quarantine Inspection ARS Agricultural Research Service CAA Clean Air Act CATS Californians for Alternatives to Toxics CEQ Council on Environmental Quality CFR Code of Federal Regulations CSA Compliance Service Agreement DEIS Draft Environmental Impact Statement DOT United States Department of Transportation DSEIS Draft Supplement to the Environmental Impact Statement; Draft Supplemental Environmental Impact Statement EA Environmental Assessment EIS Environmental Impact Statement EPA United States Environmental Protection Agency FAS Foreign Agricultural Service FDA United States Food and Drug Administration FIS Federal Inspection Service (agencies) FPM Forest Pest Management FR Federal Register Appendix D. Glossary D-1 FS FSEIS GAO GATT IES INS M&B NAFTA NAPPO NEPA NRC ONRC PPQ Q-40 ROD SBA SEIS USDA USFS use. USDA D-2 U.S. Forest Service Final Supplement to the Environmental Impact Statement; Final Supplemental Environmental Impact Statement United States General Accounting Office General Agreement on Tariffs and Trade Investigative and Enforcement Services, APHIS Immigration and Naturalization Service Management and Budget, APHIS North American Free Trade Agreement North American Plant Protection Organization National Environmental Policy Act of 1969, as amended Nuclear Regulatory Commission Oregon Natural Resources Council Plant Protection and Quarantine, APHIS Quarantine 40 Regulations (under 7 CFR Part 3 19) Record of Decision Small Business Administration Supplement to the Environmental Impact Statement; Supplemental Environmental Impact Statement United States Department of Agriculture United States Department of Agriculture, Forest Service United States Code United States Department of Agriculture Appendix D. Glossary WADS WTO Workload Accomplishment Data System World Trade Organization Appendix D. Glossary 0-3 [This page is intentionally left blank ] D-4 Appendix D. Glossary Appendix E. Glossary The definitions of the terms in this glossary are provided specifically to define them as they apply to their use in this document. Adelgids A genus of aphids that feeds chiefly on spruce and balsam and causes damage and unsightly galls. Agricultural Quarantine Inspection Results Monitoring Program Measures the effectiveness of inspections nationwide and provides information on which ports of entry pose the highest risk of having harmful pests and diseases enter the country. Anti-feedant Any substance applied to a surface that either hinders or prevents a pest from feeding. Biodiversity The relative abundance and frequency of biological organisms within ecosystems. Biogeochemical cycles Earth chemical cycles, such as sulfur or nitrogen cycles, that are controlled by living organisms Civil penalty A cash fine imposed for noncriminal violations. Compliance Agreement (PPQ Form 519) A written agreement between APHIS and a person engaged in processing, handling, or moving regulated articles, in which the person agrees to comply with requirements contained in the agreement. Conifers (coniferous) A large order of trees and shrubs that are evergreen and all have cones. Cooperative Service Agreement A written agreement between APHIS, and a company or person not located in the United States. This foreign entity is referred to as the cooperator. This agreement defines the commodity-specific work plans and the responsibilities of the cooperator and APHIS. The purpose of this agreement is to provide training for inspectors and commodity inspection outside the United States to aid in keeping undesirable pests and diseases from entering the United States. Debarking A process, usually mechanical, of removing the bark from logs and other regulated wood articles. Removal of bark facilitates detection of Appendix E. Glossary E-1 plant pests and pathogens or indications of plant pests (such as bore holes). Defoliator A pest that, in its various life stages, feeds voraciously on leaves of trees or other plant life, thus, consuming and stripping the tree or plant of its foliage. Dermal Of or relating to the skin or an organism’s body surface. Diplodia shoot blight A large genus of fungi (family Sphaeropsidaceae, order Sphaeropsidales) that causes new plant stems and leaves to wither and die. Dunnage Loose materials used to support and protect cargo in a ship’s hold or used as padding in a shipping container, or used for packing. These materials can include scrap lumber, newly manufactured wood packing boxes and cases, containers for fruit or vegetable commodities, and crates and pallets made from rough lumber. Dunnage, imported as cargo, can be manufactured from rough untreated lumber that has not been stripped of all tree bark. Efficacy Effectiveness or the power to produce the desired result. Emergency Action Notification (PPQ Form 523) A form used by U.S. port of entry inspectors to notify exporting countries, importers, and consignees and document the interception of commodities that contain plant pests regulated under the Federal Plant Pest Act, the Plant Quarantine Act, and the Federal Noxious Weed Act of 1974. Entomologist A scientist specializing in the study of insects. Eradication The complete elimination of a pest species; for some agricultural pests, this may mean the reduction of the pest populations to nondetectable levels. Exotic pests Pests that are outside their native range. Exotic pest incursion management APHIS’ response to exotic pest introduction; usually a control strategy of eradication, suppression, or no action Flat bugs An insect of the family Aradidae, usually living under bark and including a South American species capable of inflicting severe bites. E-2 Appendix E. Glossary Foreign source intervention Exclusion of foreign pests and diseases by eliminating the pathway at the country of origin. Fumigation The process of using a chemical’s gaseous phase to kill plant pests. Used in an approved facility (enclosure or building) under strict supervision and guidelines. Fungi A major group of nonmobile, filamentous organisms that lack chlorophyll (i.e., are not photosynthetic) and get their nutrition from dead or living organisms. Examples of fungi are molds, mildews, yeasts, mushrooms, and puffballs. GATT General Agreement on Tariffs and Trade; a trade agreement that was implemented in 1995 and that applies to more than 100 countries. Gray (Gy) Unit of absorbed dose where 1 Gy is equivalent to the absorption of 1 joule per kilogram. (1 Gy = 1 J/kg) Heat treatment A process of using heat or heat with moisture reduction to raise and maintain the internal temperature of the wood to 71.1 °C for a minimum of 75 minutes or adherence to the procedures outlined in the Dry Kiln Operator’s Manual Indigenous Native; originating or developing or produced naturally in a particular land, region, or environment. Integrated pest management The selection, integration, and implementation of pest control actions on the basis of predicted economic, ecological, and sociological consequences; the process of integrating and applying practical methods of prevention and control to keep pest situations from reaching damaging levels while minimizing potentially harmful effects of pest control measures on humans, nontarget species, and the environment. Kalotermes The type genus of Kalotermitidae comprising many termites that are destructive pests of living trees or of dry timber. Kilogray (kGy) Measure of absorbed dose of radioactivity (1 kGy = 1,000 Gy). Leptographium A genus of fungi (class Hyphomycetes) that are root pathogens of conifers. Log The bole of a tree; trimmed timber that has not been sawn further than to form cants. Appendix E. Glossary E-3 Lumber Logs that have been sawn into boards, planks, or structural members such as beams. Mitigation Measures taken to avoid or reduce adverse impacts on the environment; or measures taken to avoid or reduce the likelihood of pest survival in a commodity. NAFTA North American Free Trade Agreement; a trade agreement among the United States, Mexico, and Canada, which was implemented in 1994. Nematodes Any of a class or phylum (Nematoda) of elongated cylindrical worms parasitic in animals or plants or free living in soil or water. Pathogens Microorganisms that can cause disease in humans, animals, and/or plants. They may be bacteria, viruses, fungi, or parasites. Pest risk assessment The qualitative and quantitative evaluation performed in an effort to define the risk of a pest species entering and becoming established in the country. Phytosanitary A term meaning that an object(s) is free of any plant-infecting or plant disease-causing agent. Plant pest Any living stage of any insects, mites, nematodes, slugs, snails, protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or reproductive parts of parasitic plants, noxious weeds, viruses, or any organism similar to or allied with any of the foregoing, or any infectious substances, which can injure or cause disease or damage in any plants, parts of plants, or products of plants. Platypus spp The type genus (family Platypodidae) comprising pinhole borers that usually attack freshly cut or seasoned wood. Port of entry The area (such as a seaport, airport, or land border station) where a person or cargo arrives in the United States and is inspected prior to entry into the country. Primary processing Any of the following processes: cleaning (removal of soil, limbs, and foliage), debarking, rough sawing (bucking or squaring), rough shaping, spraying with fungicide or insecticide sprays, and fumigation. Probit 9 (Mortality) A statistical estimation of 99.99683 percent mortality in a population of live organisms, corresponding to a survival rate of 32 individuals per million. E-4 Appendix E. Glossary Rad (rad or Radiation Absorbed Dose) Special unit for absorbed dose that is being superseded by the Gray (Gy). (1 rad = 0.01 J/kg = 0.01 Gy) Regulated article An article subject to APHIS (or agency) regulations; in this SEIS, the regulated articles are logs, lumber, and other unmanufactured wood articles. Risk A probabilistic term that attempts to quantify potential adverse effects associated with specific exposures to humans and their environment. Saw log quality trees Pimis radiata trees from Chile and P. radiata or Douglas-fir trees from New Zealand that are plantation-grown and are living, healthy, and have no apparent signs of disease or pest infestation. Silviculture The cultivation of trees; the practice of managing forest land for timber and dealing with the development and care of forests. Sirex The type genus of the family Siricidae including various horntails that are destructive pests of unseasoned lumber from coniferous trees. Stipulation An administrative civil penalty settlement between APHIS and an alleged violator Suppression Reduction of a pest population to a level below some predetermined economic threshold Taxonomic Of or relating to or having classification, especially of plants, animals, and microorganisms on the basis of differences and similarities among them Tropical hardwoods Hardwood timber species which grow only in tropical climates. Uncertainty May be due to missing information or gaps in scientific theory. Whenever uncertainty is encountered, a decision, based upon scientific knowledge and policy, must be made. The term “scientific judgment” is used to distinguish this decision from policy decisions made in risk management. Vector An organism, such as an insect, that transmits pathogens to plants or animals. Appendix E. Glossary E-5 Virulent Characterized by the capacity of a micro-organism to overcome the body defenses of the host. Welfare gain/loss The expected benefits and costs to consumers and producers. Welfare gains and losses described in the “Economic Analysis for the Wood Import Regulations” are partial, in the sense that societal gains for exotic plant pest exclusion are not included in the estimates. Workload Accomplishment Data System Compilation of workload statistics as reported by APHIS inspectors. Wood chips Wood fragments broken or shredded from any wood. E-6 Appendix E. Glossary Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles The final rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles, published in the Federal Register (60 FR 27665-27682, May 25, 1995), is provided in this appendix. Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-1 [This page is intentionally left blank ] F-2 Appendix F Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles 27665 Rules and Regulations Federal Register Vol. 60, No. 101 Thursday, May 25. 1995 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most of which are keyed to and codified in the Code of Federal Regulations, which is published under 50 titles pursuant to 44 U.S.C. 1510. The Code of Federal Regulations is sold by the Superintendent of Documents. Prices of new books are listed in the first FEDERAL REGISTER issue of each week. DEPARTMENT OF AGRICULTURE Animal and Plant Health Inspection Service 7 CFR Parts 300 and 319 [Docket No. 91-074-6] RIN 0579-AA47 Importation of Logs, Lumber, and Other Unmanufactured Wood Articles AGENCY: Animal and Plant Health Inspection Service, USDA. ACTION: Final rule. SUMMARY: We are establishing comprehensive regulations concerning imported unmanufactured wood articles. The new regulations will affect persons importing logs, lumber, bark chips, wood chips, certain wood packing materials, and other unmanufactured wood articles. We are also amending several existing regulations to remove provisions concerning the importation of certain wood articles, and to state that such articles will instead be covered under the new regulations. We are also incorporating by reference Agriculture Handbook 188. the "Dry Kiln Operator's Manual," which contains treatments authorized by this final rule. We are taking these actions because there is increased interest in importing large volumes of unmanufactured wood articles into the United States, and prohibitions and restrictions are necessary to eliminate any significant plant pest risk associated with importing these articles. DATES: Final rule effective August 23, 1995. The Director of the Office of the Federal Register approved the incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 on August 23, 1995. FOR FURTHER INFORMATION CONTACT: Mr. Richard L. Orr. Senior Entomologist, APHIS. Policy and Program Development, Planning and Risk Analysis Systems. 4700 River Road Unit 117, Riverdale, MD 20737-1238, 301- 734-8939. SUPPLEMENTARY INFORMATION: Background The Animal and Plant Health Inspection Service (APHIS) is establishing comprehensive regulations to eliminate any significant plant pest risks presented by the importation 1 of logs, lumber, and other unmanufactured wood articles. A changing national and world economy has recently increased the incentives to import wood that may present a significant increase in the risk of plant pest introduction into the United States. An example of this change is the interest of sawmills and other wood processors in utilizing foreign sources of wood to offset expected harvest reductions in the United States, or to provide raw materials for their facilities at prices competitive with or better than domestic prices. Trees produced in many foreign locations are attacked by a wide variety of exotic plant pests and pathogens that do not occur in this country. Logs and other unmanufactured wood articles imported into the United States could pose a significant hazard of introducing plant pests and pathogens detrimental to agriculture and to natural, cultivated, and urban forest resources. Plant pests and pathogens introduced into the United States in the past, such as the gypsy moth and the agents of Dutch elm disease and chestnut blight, have caused billions of dollars of damage to United States forest and plant resources. Until recently, the quantity and variety of unmanufactured wood imported were very limited, and there was little need to develop regulations specifically to address such imports. With few exceptions (see the discussion below of interim regulations allowing importation of certain logs from Chile and New Zealand). APHIS has been dealing with such imports only by detaining shipments at ports of first arrival for inspection, and ordering further action if warranted pursuant to 1 Throughout this document, the words "import" and "importation" are used to mean moving or bringing articles into the rerhroriaJ limics of [he United States. the Federal Plant Pest Act and regulations issued under that Act (7 CFR part 330). In addition. APHIS has prohibited the entry into the United States of logs from the former Soviet Far East and Siberia because a detailed plant pest risk assessment found that dangerous plant pests could occur in such logs and may be introduced with them. However, when large volumes of wood imports are involved, inspection at the port of first arrival without other conditions relating to the wood imports is not practical or adequate for preventing the introduction of plant pests associated with imported wood. Interest in importing logs and other unmanufactured wood articles from various countries is increasing rapidly toward a point where inspection and control activities solely at the port of first arrival will not be feasible. There is currently an intense commercial interest in developing a long-term industry in the Pacific Northwest for importing and processing logs from foreign countries. There is also potential for increased log and other unmanufactured wood article imports into other areas of the United States. Interim Rules Affecting Certain Logs From Chile and New Zealand An interim rule published in the Federal Register on February 16, 1993, and effective January 19, 1993 (58 FR 8524-8533. Docket No. 91-074-4), established importation requirements for Monterey pine and Douglas-fir logs from New Zealand. Plant pest risks associated with importing these articles, and import requirements that would reduce these risks to insignificant levels, were identified early in the course of developing comprehensive wood import regulations. Therefore, to reduce these plant pest risks as soon as possible, we established regulatory requirements in 7 CFR 319.40-1 through 319.40-8 for certain logs from New Zealand. A second interim rule published in the Federal Register on November 9, 1993 (58 FR 59348-59353, Docket No. 91-074-5), and effective November 2, 1993. established importation requirements for Monterey pine logs from Chile. This interim rule applied the same requirements to Monterey pine logs from Chile that the first interim rule applied to Monterey pine and Douglas- fir logs from New Zealand. Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-3 27666 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations This final rule replaces the regulations established by the interim rules with comprehensive regulations affecting importation of unmanufactured wood articles from all places, including Chile and New Zealand. The provisions contained in this rule for Monterey pine logs from Chile, and for Monterey pine and Douglas-fir logs from New Zealand are essentially the same as the requirements imposed by the interim rule, except that the interim rule used slightly different definitions due to its limited scope. Proposed Rule On January 20, 1994. we published a document in the Federal Register (59 FR 3002-3029, Docket No. 91-074-3) proposing to replace the interim regulations. "Subpart — Logs from Chile and New Zealand,” with a new "Subpart — Logs, Lumber, and Other Unmanufactured Wood Articles” containing prohibitions and restrictions concerning imported unmanufactured wood articles. The proposed rule, and this final rule, are based on an approach that gives importers three complementary options for importing regulated articles. These are: (1) If the regulations contain specific requirements for importing a specific article from a specific country or area, you may import the article by complying with those requirements. Examples of this option include the importation of Monterey pine logs and raw lumber from Chile and New Zealand in accordance with the requirements of § 319.40-5, "Importation and entry requirements for specified articles." We intend to add more articles, countries or areas from which articles may be imported, and importation requirements to this section as new requests to import various articles are evaluated and approved. (2) If the regulations do not contain specific requirements for importing the article you wish to import, or if you believe the article may be safely imported under less stringent conditions than the regulations require, you may submit an application for a permit to import the article, and describe in the application information about the article's origin, processing, treatment, and handling. We will evaluate the permit request, conducting plant pest risk assessments as necessary, and if we determine that the article may be safely imported under conditions not already in the regulations, we will institute rulemaking to add the appropriate articles and conditions to §319.40-5, "Importation and entry requirements for specified articles." (3) If the regulations do not contain specific requirements for importing the article you wish to import, you may wish to import the article before there is time to complete plant pest risk assessments and add the article and the necessary specific importation requirements to the regulations. In this case, you may import the article by complying with one of the universal importation options in § 319.40-6. These universal options employ heat treatment and other conditions for importing logs and lumber not otherwise enterable. These universal options are relatively stringent, because they must eliminate the spectrum of potential plant pests and address risks that have not been characterized. The universal options are designed to give importers a way to import articles that would otherwise be prohibited until detailed plant pest risk assessments are completed. Whenever feasible, importers may choose to employ universal options while plant pest risk assessments and rulemaking are underway to establish less stringent requirements for the articles they wish to import. Importers of some articles may find that complying with a universal option is the most feasible and cost-effective way to import their articles. Comments on the Proposed Rule We solicited comments concerning our proposal for a 90-day comment period ending April 20, 1994. We received 56 comments by that date. Eleven were from companies and industrial associations involved in the harvesting and importation of logs and other wood products, or the manufacturing of wood products that could be derived from such imports, or the sale of products or processes used in such manufacturing. Eleven comments were from environmental organizations. Six comments were from universities. Four comments were from State agencies involved in forestry or agriculture. Four comments were from agencies of the Canadian government, and one from the Delegation of the Commission of the European Communities. National associations representing Federal and State employees involved in forestry, American growers of nursery stock, and interested members of the public also submitted comments. We carefully evaluated these comments. While most supported implementing regulations addressing the importation of wood, many raised questions about how to do so in an optimally effective manner. These comments are discussed below in detail. In response to the comments, APHIS is making eight changes to the proposed requirements. These changes are: 1 . Change the standard for heat treatment and heat treatment with moisture reduction from 56 °C for 30 minutes to 71.1 °C for 75 minutes. This change is in response to several commenters who recommended that APHIS use 71.1 °C for 75 minutes as reported in the Forest Service's Scientific Panel Review of January 10, 1992 — Proposed Test Shipment Protocol for Importing Siberian Larch Logs. Upon reviewing this research and our data from the proposal supporting a lesser temperature-time combination, we believe we were in error in believing that the proposed heat treatment would effectively eliminate all plant pests of concern. Specifically, a heat treatment of 56 °C for 30 minutes could allow various harmful fungi to survive. Research reports show that various fungi in wood can survive 1 to several hours of heat treatment at temperatures ranging from 56 °C to 70 °C, but are destroyed by a treatment of 7 1 . 1 °C for 75 minutes. The heat treatment required by the regulations must be able to effectively destroy all potentially dangerous fungi. Therefore, we are changing the requirements for heat treatment and heat treatment with moisture reduction in §319.40-7 (c) and (d) to specify 71.1 °C for 75 minutes. We will allow heat treatment at lower temperatures only in specific kiln drying processes where the fungicidal action of the heat is extended over a long period of time and is complemented by moisture reduction (see below) . 2. Allow kiln drying conducted in accordance with acceptable industry practices to qualify as heat treatment with moisture reduction, in lieu of a specific temperature-time combination. As proposed, heat treatment with moisture reduction had to raise the temperature at the center of the treated article to 56 °C for 30 minutes. If we changed this provision consistent with the above change in the temperature and time of heat treatments (i.e., 71.1 °C for 75 minutes), then most articles kiln dried according to industry practices would not qualify as heat treated with moisture reduction, even though they meet the dryness standard of the regulations (a moisture content of 20 percent or less, as specified in §319.40- 7(d)). In fact, research shows that while some fungi survive temperatures between 56 °C and 70 °C for relatively short periods, all harmful fungi are destroyed by kiln drying that is conducted according to standard Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday. May 25, 1995 / Rules and Regulations 27667 industry practice, which often dries wood at lower temperatures over a period of 1 to many days, reducing the moisture content eventually to 20 percent or less. In summary, heat treatment with moisture reduction is an effective treatment if it is employed in either of two ways. It may reduce the moisture content of the article quickly, by employing a temperature of 7 1 . 1 °C for 75 minutes or more; or, it may reduce the moisture content more slowly by employing standard industrial dry kiln practices using a lower temperature. Several commenters suggested that to allow industry to use commonly employed kiln drying techniques to the extent they are effective, we should modify the requirement for heat treatment with moisture reduction. They cited a publication of the Forest Service which the wood industry relies on to specify acceptable kiln drying practices. This publication is the Dry Kiln Operator's Manual, Agriculture Handbook 188. We agree with these comments, and are changing the requirement for heat treatment with moisture reduction in §31 9.40—7 (d) to provide that heat treatment with moisture reduction may employ; 1. Kiln drying conducted in accordance with the schedules prescribed for the regulated article in the Dry Kiln Operator's Manual, Agriculture Handbook 188, which is incorporated by reference at §300.1 of this chapter; or. 2. Dry heat, exposure to microwave energy, or any other method that raises the temperature of the center of each treated regulated article to at least 71.1 °C, maintains the regulated articles at that center temperature for at least 75 minutes, and reduces the moisture content of the regulated article to 20 percent or less as measured by an electrical conductivity meter. We are also incorporating by reference, in 7 CFR 300.1, the Dry Kiln Operator's Manual. 3. Allow noncontainerized wood chips to be imported under certain conditions. Many industry commenters cited a substantial economic burden if they had to import wood chips only in sealed containers, rather than on deck or in open containers. Several suggested allowing some wood chips to be imported on barges or other vessels, covered by tarpaulins, if the wood chips come from a relatively low-risk source (live healthy trees from a managed tropical plantation) and are alone on a vessel (no other regulated articles) that is moved directly to the United States. We agree with this suggestion. Wood chips derived from live healthy trees from a managed tropical plantation are not likely to present plant pest risks that would not be controlled by the limits imposed by the regulations on the use of the chips. This is because there are few forest pests present in tropical climates that can survive winters in temperate climates. The few tropical plant pests that can survive temperate winters would likely be excluded from managed tropical plantations by the plant pest control practices employed at such plantations. If such chips are imported alone on a vessel and covered by a tarpaulin, there is little risk that the chips will be infested during transit by plant pests from higher-risk wood products. On the other hand, wood chips from unmanaged trees and trees in temperate areas are more likely to present serious plant pest risks. These chips should be subject to the full restrictions proposed for wood chips in the proposed rule. i.e.. they should be imported in sealed containers, and subject to fumigation or heat treatment, to prevent the introduction of plant pests they may harbor. Therefore, we are changing § 319.40- 6(c)(2), the universal importation requirement for wood chips and bark chips, by adding the following sentence: "If the wood chips or bark chips are derived from live, healthy, plantation- grown trees in tropical areas, they may be shipped on deck if no other regulated articles are present on the vessel, and the wood chips or bark chips are completely covered by a tarpaulin during the entire journey directly to the United States.” 4. Allow pallets to be imported in accordance with the requirements for solid wood packing materials, even if the pallets are imported as cargo. Several commenters noted that pallets should be allowed to be imported as cargo under no greater restrictions than if they are imported in actual use as packing. They pointed out that in normal shipping practice, large amounts of pallets are used to ship articles to a port, and then may be shipped as cargo from ports with a pallet surplus to ports with a pallet shortage. Commenters felt that pallets that have been in use. and have met the regulatory requirements for importation in use, do not present significant risks and should not have to meet additional requirements if they are subsequently moved as cargo. We agree. We are changing §319.40- 3(b) to allow pallets that are imported as cargo to be imported under the same requirements that apply to pallets that are in use as packing materials at the time of importation. Briefly, these requirements are that if the pallets are free from bark and are used for articles that are not regulated articles, they must be accompanied by an importer document stating that they are totally free from bark, and apparently free from live plant pests. If the pallets are free from bark and are used for regulated articles, they must be accompanied by an importer document stating that they are totally free from bark, apparently free from live plant pests, and have been heat treated, fumigated, or treated with preservatives in accordance with § 319.40-7, or meet all the importation and entry conditions required for the regulated article the solid wood packing material is used to move. If the pallets are not free from bark, they must be accompanied by an importer document stating that the pallets have been heat treated, fumigated, or treated with preservatives in accordance with §319.40-7. In all cases, the pallets are also subject to the inspection and other port of arrival requirements of §31 9.40— 9. 5. Exclude European Russia from the group of Asian countries to which more severe prohibitions and restrictions apply. Several commenters noted that the apparent intent to exclude European Russia from these more severe requirements was not carried out by the precise language, allowing many importations to occur from all places "except countries in Asia that are wholly or in part east of 60° East Longitude and north of the Tropic of Cancer.” Russia does extend east of 60° East Longitude. It was not our intent to include European Russia in this area, as can be seen from the context of the language in the preamble of the proposed rule. Therefore, we are changing this geographic description each time it appears to read "except places in Asia that are east of 60° East Longitude and north of the Tropic of Cancer.” 6. Continue to allow the ongoing importation of railroad ties from countries outside Asia, for subsequent pressure treatment and use in the United States, which APHIS has allowed to occur for some time. Commenters noted that these articles are normally treated within 30 days, and have been considered low risk. We agree that the regulations should continue to allow the importation of these railroad ties. We are adding the following new paragraph (f) to § 319.40-5, the section concerning importation requirements for specified articles: "Cross-ties (railroad ties) from all countries except places in Asia that are east of 60° East Longitude and north of the Tropic of Cancer may be imported if completely Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-5 27668 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations free of bark and accompanied by an importer document stating that the cross-ties will be pressure treated within 30 days following the date of importation." 7. Amend the definition of "Log" so that it includes cants sawn from logs. One commenter pointed out that by his reading of the regulations, it seemed likely that cants (partly trimmed logs) were subject to the same requirements as logs, but the regulations did not make this point absolutely clear. We did in fact intend that the regulations treat logs and cants the same. To make this clear, we are revising the proposed definition of "Log." which read "The bole of a tree; trimmed timber that has not been further sawn," to read "The bole of a tree; trimmed timber that has not been sawn further than to form cants." 8. Amend the requirements for completing an application for an import permit to require that the applicant specify not only any chemical treatments that will be employed prior to or after importation, but also the dosage of the chemicals that is employed. One commenter pointed out that the permit application procedure in proposed §319.40-4(a) required the applicant to provide, among other information, the names of any chemicals employed in treatments prior to or after importation (proposed §319.40-4(a) (4) and (5)). He suggested that the application should also include the dosage used for such treatments, so that APHIS and the public can judge whether the treatments are effectively applied. We agree, and are adding a requirement for dosage information to the affected sections. With the exception of the changes just discussed, and minor editorial changes, we are adopting the provisions of the proposed rule as a final rule. Additional comments are discussed below. Goals and Mission of APHIS as They Relate to the Proposed Rule Comment: APHIS should not consider the needs of international trade but should focus exclusively on pest exclusion as worded in the Federal Plant Pest Act of 1957 Response: It is important to recognize that APHIS has a number of responsibilities and legal mandates beyond the Federal Plant Pest Act. These include international trade agreements such as the General Agreement on Tariffs and Trade and the North American Free Trade Agreement, statutes such as the Regulatory Flexibility Act and the Paperwork Reduction Act, Executive Orders, and additional legal and policy guides. One of APHIS's basic responsibilities is plant pest exclusion, but this has to be conducted in balance with other national needs and goals. The majority of comments which specifically addressed the issue of balancing the needs of international commerce with prevention of pest introduction clearly favored such a balancing. However, some commenters believed that APHIS should reduce or terminate raw wood exports, so that wood could be used to meet domestic needs, removing the need for the importation of raw wood. APHIS does not have statutory authority to stop or reduce the export of raw logs by U.S. private land owners and companies so that the wood can be used for domestic needs. Opposition to the Importation of Unmanufactured Wood Comment: APHIS should restrict imports to manufactured and/or finished wood products only. Response: APHIS believes that this approach is too extreme. With proper mitigation and monitoring, the importation of some raw wood material from certain locations presents an insignificant plant pest risk. Limitations of the Pest Risk Assessment Process Comment: Some comments were directed toward the risk assessment process. A few were concerned that the process did not fully address the unknowns, did not address enough pests, or did not incorporate the full scope of experts needed. Response: The risk assessments conducted by the Forest Service were the most resource extensive risk assessments ever utilized by APHIS to determine the plant pest risk associated with an imported commodity. Great care was taken to choose which assessments needed to be completed before the rule was written. The first assessment focused on raw timber from Siberia, which was identified as extremely high risk. From this assessment, some universal requirements for the rule were derived. Two additional risk assessments were conducted on those timber commodities which were identified as lower risk (specific species of plantation grown trees from New Zealand and Chile). The specific requirements for these commodities were developed from these assessments. APHIS recognizes both the need for future assessments and the need to improve the risk assessment process. The risk assessment process used for the various assessments was derived from the National Research Council's section on ecological risk assessment as published in its 1993 "Issues in Risk Assessment” and represents the state of the art as it now stands for conducting ecological risk assessments. APHIS recognizes that the process is not perfect and that evolution will continue to be necessary. The risk assessment process is being, and will continue to be, modified and improved to make sure that it is the best that the science of ecological risk assessment can provide. One of the most difficult issues is how to assess the risk associated with unknown organisms, or with known organisms that do not have well- described characteristics or survival and spread capabilities. The regulations are designed to ensure that there is an insignificant risk that importing regulated articles will result in the entry and establishment of either known or unknown dangerous plant pests. Need for More Assessments of Additional Log Species Comment: APHIS needs to complete additional assessments for various timber products considered for importation. Response: APHIS agrees, and with the cooperation of the Forest Service, will continue to conduct risk assessments and amend regulations based on them, as appropriate. Packing Material Comment: The regulations proposed for solid wood packing materials are too restrictive. Response: We also received comments stating that the regulations proposed for solid wood packing materials are necessary and appropriate. We believe that the requirements in this final rulemaking document for the importation of solid wood packing materials are necessary to prevent the introduction of plant pests into the United States. Temperate Hardwoods, Tropical Hardwoods, and Chips Comment: Temperate and tropical hardwoods should be subject to entry requirements that are as strict as those for temperate softwoods. Response: The volume of imported temperate and tropical hardwoods has remained at a low sustained level. These small shipments of high priced logs and lumber can be monitored and controlled much more easily than the proposed large shipments of softwood logs. Comment: The proposed regulations for wood chip importations are too restrictive and it would not be feasible for importers to meet the requirements. The 30-day time limit for processing Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27669 wood chips after importation is too short, and the proposed requirement for containerized transportation of wood chips is unnecessary and costly. Response: APHIS believes that the 30- day limit for processing the chips is reasonable. The extension to 60 days requested by several commenters would present additional concerns with monitoring and increased plant pest risk. One commenter was under the incorrect assumption that the chips still had to be processed within the 30-day period if they had been subjected to an approved fumigation. This is not the case. The 30-day limitation is directed toward raw, untreated chips. The changes we are making to the proposed requirement for containerized transportation of wood chips are discussed above. Methyl Bromide Comment: In view of the negative effects of methyl bromide (MB) on the ozone layer, APHIS should not rely upon use of MB. Also, the regulations do not include plans for how APHIS will deal with articles requiring MB fumigation after MB is removed from regulatory use around the year 2001. Response: APHIS is concerned about the effects of MB on the ozone layer and will abide by the Environmental Protection Agency’s phase-out schedule. However, present reliance by commerce on MB is such that immediately terminating all regulatory use of MB is not realistic. The regulations were written with the phase out of MB in mind. All MB requirements presented in the regulations have alternative treatments. It is APHIS's hope that industry will develop and implement alternative mitigation schedules (e.g. irradiation, heat, borate, etc.) to replace its reliance on methyl bromide for the importation of regulated articles. Bark Removal on Temperate Softwood Logs Comment: Temperate softwood logs should be required to have 100 percent of the bark removed before importation, since even small patches of bark can harbor insect pests. Response: APHIS recognizes that 1 00 percent debarking of logs is not realistic. It is important to remember that APHIS requires either a heat treatment or fumigation to complement the debarking of temperate softwood logs. This combination of debarking with other mitigation requirements is sufficient to destroy plant pests of concern in the bark or directly under the bark. Other Comments and Responses Comment: APHIS should add other treatments, such as irradiation and borates, to the universal importation requirements. Response: APHIS recognizes the potential value of irradiation, borates, and other treatments for use as universal or specific treatments. Ongoing research into the use of irradiation and borates on timber products looks promising. However, the data is not yet complete to the extent necessary for APHIS to propose specific treatments. Irradiation treatments as well as other alternatives will be added to the regulations as they are developed and proven both effective and operationally feasible. Comment: For logs imported from Chile and New Zealand. APHIS should change the regulations to facilitate on- deck fumigation and transport of logs, and extend the time period for processing such imported logs after they are imported (currently 60 days). Response: The restrictions associated with the movement of logs from Chile and New Zealand prompted a number of responses from industry. Extending the time allowed to process the logs once they enter the United States and allowing the fumigation and movement of logs on the deck of ships were the two most stated requests. APHIS believes that allowing additional time beyond 60 days for processing the logs would make monitoring difficult and increase the plant pest risk. Therefore, APHIS will maintain the 60-day requirement. APHIS has prohibited the movement of logs on the open deck of ships because of the possibility of infestation of the logs while at the port of origin and/or other foreign ports visited while the ship is in transit. APHIS believes that until the issue of infestation during shipment to the United States is satisfactorily answered, the movement of logs on the open deck of ships must continue to be prohibited. Comment: The regulations should specify strong penalties that will be imposed on persons who do not comply with the regulations. The regulations should also make importers financially responsible for damages and control costs resulting from pests introduced through their shipments. Response: For an importer, the primary practical consequence for non- compliance is future ineligibility to import additional shipments. USDA has no authority to require importers to post bonds or otherwise stipulate their financial responsibility for costs that may result from introduced plant pests. However, individual shipments will be refused entry unless the shipments comply with regulatory requirements. APHIS can also respond to violations by canceling compliance agreements. Because domestic processing facilities must hold a current compliance agreement to import and process many types of regulated articles in the regulations, APHIS can stop violators from importing articles by canceling or refusing to sign a compliance agreement. In addition, statutory authority allows us to impose civil and criminal penalties on violators. Individuals also have recourse through the courts; persons who believe they suffered harm due to an importer who did not comply with regulatory requirements may file a civil suit against that importer. Comment: APHIS must allocate additional resources and personnel, especially inspectors at ports and sawmills processing imported wood, if the regulations are to be successfully enforced and monitored. Response: We agree that adequate resources and personnel, especially inspectors, must be devoted to prevent the introduction of plant pests into the United States. Adjustments in the level of personnel and resources devoted to APHIS programs are a normal part of management in the agency. Duties and staffing levels will be adjusted, at ports and elsewhere, to take the needs of the new wood import program into account. While APHIS will assign some personnel to major ports to work specifically with wood imports, and will assign some personnel to work specifically with monitoring compliance both overseas and in domestic processing facilities, we believe much of the resources needed for this program are already in place, in the form of existing APHIS port personnel and cooperating personnel from State plant protection agencies. Funding levels and agency personnel may vary from year to year. Import authorizations will not be provided if the level of resources decreases below the level needed to ensure that all imported regulated articles are subject to the level of inspection and monitoring necessary to prevent the introduction of plant pests into the United States. Regarding APHIS resources needed to ensure compliance with the regulations, commenters should be aware that user fees we collect for some program operations will help to ensure that the needed resources are available. Comment: The regulations would allow importers to self-certify. in the "importer document,” information Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-7 27670 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations about the type, quantity, and origin of imported articles and any treatments that have been applied to them. This self-certification is not an adequate substitute for a certificate issued by a plant protection organization recording the required information. You cannot rely on importers to honesdy and completely record the necessary information in an informal importer document. In particular, exports from the former Soviet Union are subject to rampant corruption, forgery of documents, and smuggling. Response: Questions about enforcement of regulations and how to deter violators who may present inaccurate information and documents opens up a complex nest of issues much larger than any single regulation. The general position of APHIS on these issues is as follows: 1 . Violations are most likely when the profit for the violator is high and the risk is low. APHIS plans its enforcement activities accordingly. We tend to scrutinize carefully large shipments of regulated articles, especially those of particularly valuable species. We employ various means to independently verify the accuracy of documents associated with these shipments — whether the documents are issued by an importer or by a government agency. We keep importers aware of the risks they face if they file inaccurate documents or fail to meet regulatory requirements. These risks include civil penalties, criminal fines and jail sentences, and loss of business due to APHIS rejection of permit applications and compliance agreement applications. Generally, wood commodities are not so lucrative that an importer would risk these penalties, especially long-term loss of business, for the sake of fraudulently importing any one shipment. We intend to vigorously publicize our enforcement activities related to this final rule during the initial implementation period, to make potential violators aware of the risks they face. 2. Self-certiTication has worked in other programs Many APHIS and other Federal agencies have programs that rely in part on regulated individuals providing accurate certifications to the agency. Experience has shown that these programs can work when the interests of both the regulated party and the agency are served by accurate self- certification. Examples of APHIS programs that have successfully employed self-certification include the domestic Gypsy Moth quarantine under 7 CFR 301.45 through 301.45-12 (in which businesses operating under compliance agreements may issue certificates), and the importation program for greenhouse-grown potted plants from Canada under 7 CFR 319.37-4(c) (in which greenhouse growers apply labels which certify that their plants meet certain growing requirements). Such programs work, in part, because our inspectors learn to evaluate the accuracy of self- certifications through visual examination of the materials and through independent sources of information. The programs also work because they are generally employed where the regulated parties have a financial reason to desire a continuing relationship of trust with the regulating agency, so they can continue to do business. This is the case with importer documents employed in this final rule. 3. The accuracy of self-certifications is often empirically tested at the port of hrst arrival. Much of the information in importer documents can be independently checked, sometimes by direct inspection and testing. Inspectors can discover a great deal about the accuracy of documents concerning a shipment by looking for plant pests and evidence of treatments in the articles. Moisture content can be directly measured at ports to determine whether kiln drying has occurred. Fraudulent importer documents will often conflict with waybills, valid importer documents from earlier shipments, and other records. We intend to use all of these opportunities to enhance enforcement and create a culture in which importers see that issuing inaccurate documents is not worth the risk. 4. Individual "high-crime” areas of international trade must be addressed in a larger forum than just the wood regulations. We agree that doing business in the former Soviet Union presents severe problems for honest businesspersons and the customs services of many countries. There is widespread smuggling, forgery of documents, and coercion of officials related to exports from this area. While we are not aware of significant criminal activities affecting unmanufactured wood exports from the former Soviet Union, this may be because such exports to the United States have not been allowed to occur in significant quantities until now. For these reasons, we will take particular care in enforcing regulatory requirements with regard to the importation of regulated articles from the former Soviet Union. As discussed above, there are numerous methods available to APHIS to confirm that the importation of regulated articles meets the regulatory requirements. We intend to employ them vigorously. There is an ongoing, international effort to reduce the level of smuggling, fraud, and other criminal activity associated with exports from the former Soviet Union. The State Department and the Federal Bureau of Investigation are working with their counterparts in other countries and in the former Soviet republics to try to stabilize the situation, and APHIS will monitor the results of these efforts to determine what level of enforcement activity needs to be directed toward shipments of regulated articles from the former Soviet Union. Comment: The regulations should minimize the costs associated with importing wood by imposing requirements that are both effective in pest control and cost efficient. To keep costs under control, the regulations should not include additional controls beyond those needed to control pest risk. Response: We agree, and believe we have designed the regulations to effectively exclude plant pests at minimal cost. Wherever we had two or more alternative, equally effective control methods, we wrote the regulations to allow importers to choose whichever method was less costly and disruptive to commerce in their particular cases. Whenever control methods with significant costs were necessary, such as heat treatment, we avoided using detailed "design standards” that can add to costs by requiring treatment facilities to be built and operated in particular ways. Instead, we have employed "performance standards" that allow maximum freedom for innovation and cost savings to regulated parties. Comment: In developing the proposed rule. APHIS failed to adequately communicate with the affected parties and the public. Only 10 representatives of environmental public interest organizations were on the distribution list for National Environmental Policy Act (NEPA) materials associated with the rule, and Indian Tribes with extensive forest holdings were not contacted. Response: We disagree. APHIS had numerous contacts with potentially affected groups prior to rulemaking. We actively sought information from academic, environmental, and industry organizations and encouraged them to involve their constituents in contributing to APHIS development of a proposed rule. We sent representatives to forestry conferences to explain APHIS perspectives early in the process. We developed a mailing list of persons and organizations interested in potential rulemaking for wood imports, which grew to over 500 members by the time Appendix F Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27671 the proposal was drafted. Persons on this list were informed of each significant step that preceded the proposal, for example, public meetings, plant pest risk analyses, and interim APHIS requirements at ports. We published an advance notice of proposed rulemaking prior to the proposed rule. We also established an electronic bulletin board, accessible by direct dial and through the Internet, to distribute copies of the proposed rule and associated documents and to accept public comments on the proposal. These activities resulted in far greater early public involvement than is usual for a Federal informal rulemaking proceeding. Also, publication of the proposed rule in the Federal Register meets the minimum procedural standard for adequate public notice. We believe our outreach activities far exceeded this minimum standard. Certainly, any individual or group that was interested in the wood imports issue and was involved with the media and forums where wood and forestry issues are normally discussed had ample notice of, and opportunity to participate in, APHIS decisionmaking prior to the issuance of the proposed rule. Comment: To ensure consistent nationwide requirements for importing wood, and to facilitate interstate and international commerce, the APHIS regulations should preempt all State and local requirements for wood imports. Officials in various States appear to have very different understandings of what authority they have over imports and how they are to interact with APHIS personnel. Response: Executive Order 12612, "Federalism.” instructs Federal agencies not to take actions that exceed the powers enumerated for the Federal government in the Constitution, and not to unnecessarily preempt State law or preclude States from developing policies and taking actions at their discretion. We do not believe the proposed changes to the regulations raise Federalism implications in terms of the Executive Order. The regulations address how a Federal agency will conduct operations of a Federal program, and do not preclude States from developing policies or exercising their authority to involve their employees in any plant protection programs developed by a State. States are free to pass laws or implement regulations for State plant protection programs. However, State programs may not add requirements for importing regulated articles that are inconsistent or in conflict with the requirements established by the Federal regulations. States may not cite their participation in the enforcement of the Federal regulations as the basis for also enforcing additional requirements that are not contained in the Federal regulations. In the “Executive Order 12778” section of the proposed rule, we stated "If this proposed rule is adopted: (1) All State and local laws and regulations that are inconsistent with this rule will be preempted* * We believe State and local laws and regulations would be inconsistent with our rule if they prohibit imports allowed by our regulations, or if they impose conditions on importation that are in addition to the conditions set forth in this final rule. States may impose requirements in accordance with State law that are not inconsistent with our regulations. Executive Order 12866 and Regulatory Flexibility Act We are issuing this final rule in conformance with Executive Order 12866. This rule has been determined to be significant and has been reviewed by the Office of Management and Budget under Executive Order 12866. We have prepared an economic analysis concerning this final rule. This analysis indicates that this rule will not have significant annual effects on the economy. Copies of the economic analysis may be obtained by sending a written request to APHIS, Policy and Program Development, Regulatory Analysis and Development. 4700 River Road Unit 1 18, Riverdale, MD 20737- 1238. Copies of the economic analysis are also available for inspection at USDA, room 1141, South Building, 14th Street and Independence Avenue SW., Washington, DC, between 8 a.m. and 4:30 p.m., Monday through Friday, except holidays. Persons wishing to inspect the analysis are requested to call ahead on (202) 690-2817 to facilitate entry at the reading room. The United States has become the world's leading importer of unmanufactured wood. In 1990, the United States imported the equivalent of 34.4 million cubic meters (CBM) of logs, lumber, and other unmanufactured wood valued at about $5.1 billion. Total imports nearly tripled between 1950 and 1990, with most of this increase occurring after 1970. Historically, Canada has supplied the United States with virtually all of its unmanufactured wood imports. Domestic production of logs, lumber, and other unmanufactured wood has increased steadily since 1950. In roundwood equivalents, production in 1990 was 1.6 times greater than in 1950. Most timber production occurs in southern and western States. In 1990, Oregon and Washington accounted for about 16 percent of the total U.S. tree harvest. Domestic logging companies are facing increasing challenges from conservation groups. Conservationists are opposed to many tree harvesting practices, especially clear cutting. In addition, concern over habitats for wildlife has raised questions about replacement of old growth/diversified forests with monoculture. Conservation issues are likely to limit future tree harvests in several northwestern States. Nationally, commercial forest lands are projected to decrease by about 4 percent over the next 50 years. Production is likely to decline in the Pacific Northwest and increase in the South and Rocky Mountain States.2 A slightly limited domestic harvest combined with higher consumer demand would likely result in an increased demand for imported wood and wood products. Alternative supplies of logs and other wood products have been located in the former Soviet Union, New Zealand. Chile, Brazil, and other countries. Wood imports from alternative sources have the potential to introduce and disseminate exotic plant pests and diseases throughout the United States. This final rule regulates the importation of logs and other unmanufactured wood products from all areas. There are exemptions from some requirements for imports from Canada and Mexican border states because most insects and other wood pests in these areas are also indigenous to the United States, or will become so through natural migration. Therefore, wood imports from Canada and Mexican border states do not pose a significant risk of exotic plant pest introduction. The regulations will reduce to an insignificant level the risk of entry and dissemination of plant pests associated with unmanufactured wood imports. Some regulated wood products are prohibited importation based on plant pest risk assessments that reveal more than an insignificant risk of the introduction of plant pests. Unrestricted trade in unmanufactured wood would likely result in losses to domestic agriculture from plant pest damage. Without governmental regulation, private entities might engage in trading activities that would result in the introduction of plant pests into the United States. 2 Over the next 50 years, new technologies may allow wood products companies to remove larger amounts of wood products from each tree. Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-9 27672 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations The following items are subject to the regulations: logs; wood chips: lumber; whole trees; portions of trees not consisting solely of leaves, flowers, fruits, buds, or seeds; bark; cork; laths; hog fuel; sawdust; painted raw wood products: excelsior: wood mulch; wood shavings; pickets; stakes; shingles: solid wood packing materials; humus; compost; and litter. Manufactured wood products are not regulated by the rule. The regulations require that certain specified imported unmanufactured wood products be treated prior to arrival in the United States. In 1990 the United States imported about 255,800 CBM of unmanufactured wood that would require treatment under the final regulations. These unmanufactured wood imports accounted for less than one percent of total 1990 domestic supplies. Imported shipments of kiln dried lumber are not required to be treated. About 4.1 million newly manufactured units of wood dunnage were imported as cargo from regulated areas in 1990. Dunnage imported as cargo can be manufactured from rough untreated lumber that has not been stripped of all tree bark.3 Imports comprised about 27 percent of the newly manufactured dunnage products available in the United States during 1990. Imports of regulated articles that will now require treatment totaled about $27.4 million in 1990. Total domestic supplies of these articles exceeded $80 billion during the same year. Therefore, the value of imports that will require treatment under the final regulations represented less than one percent of total domestic supplies in 1990. Our economic analysis estimates that this action would increase economic welfare for domestic producers of logs, lumber, and other regulated wood products by about $35.2 million. However. U S. consumers of these products will incur a welfare loss of about $171.9 million. About 98.8 percent of total estimated losses are attributable to treatment costs for dunnage (including scrap lumber) used to pack various commodities that are imported into the United States. APHIS anticipates that this loss will be mitigated as shipping companies switch to bark free dunnage materials to avoid Q-40 related treatment costs. Shippers will take precautions to ensure that dunnage is bark free before commodities are loaded at the foreign port of origin. 3 For the purpose of this economic analysis, dunnage imported as cargo includes dunnage produced for first time use. and does not include dunnage manufactured from used or scrap lumber. The Agency maintains that bark free dunnage material is readily available throughout the world and can be substituted at little or no cost. Therefore, APHIS estimates that the required use of bark free dunnage will result in a negligible cost increase to shippers in the long run. Complying with the rule’s requirements may cost U.S. society up to $136.7 million; this represents the cost of plant pest exclusion. This cost estimate does not include the opportunity cost associated with importation of timber products like Siberian larch that might be imported in the absence of this rule. Data are not available to make this estimate. Additionally, this cost figure does not take into account either the benefits that would be accrued by excluding pests, or the probability that businesses would be able to reduce cost by switching to less costly options such as bark free dunnage. If the United States does not expend resources to exclude plant pests through regulation or other means, such pests could become established and cause significant damage to domestic agriculture. For example, in the past few years plant pests including the Asian gypsy moth and pine shoot beetle have recently been introduced into the U.S., and several million dollars have been spent on efforts to control and prevent further spread to noninfested areas of the country. A recent USDA Forest Service pest risk assessment concerning potential Siberian timber imports evaluated the potential costs to U.S. society of several nonindigenous plant pests. The risk assessment estimated that introduction of a single pest, larch canker, could cause direct timber losses of $129.0 million annually. The same study estimated that a worst-case scenario involving heavy establishment of exotic defoliators in the United States could cost $58 billion (about $4.1 billion annually). This is a damage estimate of resources that would be lost to established defoliators. The benefits that would accrue from pest exclusion may be less because control efforts would be put in place to regulate the spread of exotic pests. Total benefits should be calculated as the avoided cost of such control efforts and avoided damages to agricultural and forest resources. However, past experiences with introduced exotic defoliators indicate that control measures would not likely prevent further spread and thus make eradication extremely unlikely. The initial estimated losses will be offset over time as businesses adapt to new international wood marketing channels. If resource constraints remain constant after this rule is implemented, consumers will purchase a slightly higher volume of domestic wood products at prices that are slighdy higher than those that currently prevail in the U.S. market. However, domestic consumers will continue to supplement their wood and wood product purchases with imports whenever the imported price is lower than the domestic price. Each year about 6 to 7.5 million non- bulk shipments of various commodities are imported into the United States. APHIS estimates that between 3.6 and 4.5 million (60 percent) of annual imported non-bulk shipments arrive in the United States packed in dunnage made of rough untreated wood with bark. The regulations will prohibit untreated dunnage with bark from entering the United States. APHIS does not expect the economic impact on U.S. producers of regulated articles to be uniform across the country. Producers in southern and Rocky Mountain States will likely gain more than producers in the Pacific Northwest. Conservation issues and resource constraints will likely limit the amount of welfare gain acquired by loggers and sawmills in Oregon and Washington. Pursuant to Title II of the Unfunded Mandates Reform Act of 1995 (“the Act"), which the President signed into law on March 22, 1995. USDA has assessed the effects of this rulemaking action on State, local, and tribal governments, and the private sector. This action does not compel the expenditure of $100 million or more by any State, local or tribal governments, or by anyone in the private sector, and therefore a statement under section 202 of the Act is not required. The Regulatory Flexibility Act requires that APHIS specifically consider the economic impact of regulations on small entities. Small Business Administration (SBA) data indicates that about 25,998 domestic entities could be impacted by the restrictions on regulated articles. About 25,769 (99 percent) of these entities are classified as small according to SBA criteria. These consist of approximately 14,662 small logging companies or sawmills that produce domestic wood articles, and approximately 15.642 entities that could import foreign wood for processing or resale. (These two figures total more than 25,769 because some firms process or resell both domestic and imported wood.) These small entities should experience most of the anticipated $35.2 million increase in domestic welfare. This increase will be a small average economic benefit for F-10 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27673 affected small entities, as it represents less than one percent of combined average annual sales for impacted small entities. A few small entities will undoubtedly accrue a disproportionate share of the domestic welfare increase due to their individual positions in their markets and variations in business strategies for dealing with new opportunities. The overall impact on small businesses is expected to be minor. Under these circumstances, the Acting Administrator of the Animal and Plant Health Inspection Service has determined that this action will not have a significant economic impact on a substantial number of small entities. Executive Order 12778 This rule has been reviewed under Executive Order 12778, Civil Justice Reform. This rule: (1) Preempts all State and local laws and regulations that are inconsistent with this rule; (2) has no retroactive effect; and (3) does not require administrative proceedings before parties may file suit in court challenging this rule. National Environmental Policy Act In accordance with the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 etseq), APHIS has prepared an environmental impact statement (EIS) addressing the importation of logs, lumber, and other unmanufactured wood in accordance with this rule. On August 12, 1994, a notice was published in the Federal Register (59 FR 41441) informing the public of the availability of the final EIS. The final EIS considered and evaluated the six following alternatives: Alternative 1 — No Action (No Regulations) Alternative 2 — Final Regulations (Preferred Alternative) Alternative 3 — Prohibit Untreated Wood Except Packing Material Alternative 4— Prohibit Untreated Wood Alternative 5 — Prohibit Unmanufactured Wood Except Packing Material Alternative 6 — Prohibit Unmanufactured Wood The final EIS addressed the potential impacts to the human environment, including possible risks to human health, impacts to forest resources, impacts to biodiversity, impacts from the use of methyl bromide, and impacts to global climate change, cultural resources, and endangered and threatened species. A detailed analysis of potential impacts from the use of methyl bromide was prepared because of the classification of methyl bromide as an ozone depletor. The analysis of the environmental impacts to all aspects of the human environment revealed that impacts attributable to the six alternatives are virtually identical, but are entirely dependent upon the degree to which plant pests are able to be excluded. Each alternative demonstrated a different likelihood of success. Alternative 6 is the most protective, that is, the most likely to minimize the risk of plant pest introduction. However, it is also the most restrictive with regard to importation of unmanufactured wood articles. Alternative 1, the No Action Alternative, is believed to be the least protective, and more likely than the other alternatives to result in inadvertent plant pest introductions. Alternative 4 is similar to Alternative 6 in that it is protective but may unnecessarily interfere with trade. The protective capacity of Alternatives 3 and 5 is diminished by the exclusion of packing materials from treatment requirements. Alternative 2, the Preferred Alternative, offers a balanced approach to the importation of logs, lumber, and other unmanufactured wood articles that requires plant pest treatments in all cases in which APHIS has identified a risk of plant pest introductions. This alternative was selected by the agency and is reflected by this final rule. Paperwork Reduction Act In accordance with the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 etseq.), the information collection or recordkeeping requirements included in this rule have been submitted for approval to the Office of Management and Budget. List of Subjects 7 CFR Part 300 Incorporation by reference, Plant diseases and pests. Quarantine. 7 CFR Part 319 Bees, Coffee, Cotton, Fruits, Honey, Imports, Incorporation by reference, Nursery stock, Plant diseases and pests, Quarantine, Reporting and recordkeeping requirements. Rice, Vegetables. Accordingly, 7 CFR parts 300 and 319 are amended to read as follows: PART 300— INCORPORATION BY REFERENCE 1 . Part 300 is revised to read as follows: Authority: 7 U.S.C. 150ee. 154. 161, 162, and 167; 7 CFR 2.17, 2.51, and 371.2(c). § 300.1 Materials incorporated by reference; availability. (a) Plant Protection and Quarantine Treatment Manual. The Plant Protection and Quarantine Treatment Manual, which was reprinted on November 30, 1992, and includes all revisions through March 1995, has been approved for incorporation by reference in 7 CFR chapter III by the Director of the Office of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. (1) The treatments specified in the Plant Protection and Quarantine Treatment Manual and its revisions are required to authorize the movement of certain articles regulated by domestic quarantines (7 CFR parts 301 and 318) and foreign quarantines (7 CFR part 319). (2) Availability. Copies of the Plant Protection and Quarantine Treatment Manual: (i) Are available for inspection at the Office of the Federal Register Library, 800 North Capitol Street NW. Suite 700, Washington, DC; or. (ii) May be obtained by writing or calling the Animal and Plant Health Inspection Service, Documents Management Branch, Printing Distribution and Mail Section, 4700 River Road Unit 1, Riverdale, MD 20737-1229, (301) 734-5524; or (iii) May be obtained from field offices of the Animal and Plant Health Inspection Service. Plant Protection and Quarantine. Addresses of these offices may be found in local telephone directories. (b) Dry Kiln Operator's Manual. The Dry Kiln Operator's Manual, which was published in August 1991 as Agriculture Handbook No. 188 by the United States Department of Agriculture, Forest Service, has been approved for incorporation by reference in 7 CFR chapter III by the Director of the Office of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. (1) The kiln drying schedules specified in the Dry Kiln Operator’s Manual provide a method by which certain articles regulated by "Subpart— Logs, Lumber, and Other Unmanufactured Wood Articles" (7 CFR 319.40-1 through 319.40-1 1) may be imported into the United States. (2) Availability. Copies of the Dry Kiln Operator’s Manual are available for inspection at the Office of the Federal Register Library, 800 North Capitol Street NW, Suite 700, Washington, DC, or are for sale as ISBN 0- 1 6-0358 1 9- 1 by the U.S. Government Printing Office, Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402- 9328. Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-1 1 27674 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations PART 319— FOREIGN QUARANTINE NOTICES 2. The authority citation for part 319 is revised to read as follows: Authority: 7 U.S.C. 150dd. 150ee, 150ff. 151-167, 450. 2803, and 2809; 21 U.S.C. 136 and 136a; 7 CFR 2.17, 2.51, and 371.2(c). Subpart — Citrus Canker and Other Citrus Diseases 3. In §319.19. paragraphs (a), (b), (c), and (d) are revised to read as follows: §319.19 Notice of quarantine. (a) In order to prevent the introduction into the United States of the citrus canker disease (Xanthomonas citri (Hasse) Dowson) and other citrus diseases, the importation into the United States of plants or any plant part, except fruit and seeds, of all genera, species, and varieties of the subfamilies Aurantioideae, Rutoideae, and Toddalioideae of the botanical family Rutaceae is prohibited, except as provided in paragraphs (b), (c), and (d) of this section. (b) Plants or plant parts of all genera, species, and varieties of the subfamilies Aurantioideae, Rutoideae, and Toddalioideae of the botanical family Rutaceae may be imported into the United States for experimental or scientific purposes in accordance with conditions prescribed by the Administrator, Animal and Plant Health Inspection Service. United States Department of Agriculture. (c) Plants or plant parts of all genera, species, and varieties of the subfamilies Aurantioideae. Rutoideae, and Toddalioideae of the botanical family Rutaceae may be imported into Guam in accordance with § 319.37-6. (d) Plants or plant parts of all genera, species, and varieties of the subfamilies Aurantioideae, Rutoideae, and Toddalioideae of the botanical family Rutaceae that are regulated articles under §§319.40-1 through 319.40-1 1 may be imported into the United States in accordance with §§319.40-1 through 319.40-11 and without restriction by this subpart. ***** Subpart — Bamboo 4. The title "Subpart — Bamboo” is revised to read ' 'Subpart — Bamboo Capable of Propagation". 5. In §319.34, paragraphs (a) and (c) are removed; paragraphs (b) and (d) are redesignated as paragraphs (a) and (b); and newly designated paragraph (a) is revised to read as follows: §319.34 Notice of quarantine. (a) In order to prevent the introduction into the United States of dangerous plant diseases, including bamboo smut (Ustilago shiraiana), the importation into the United States of any variety of bamboo seed, bamboo plants, or bamboo cuttings capable of propagation,1 2 including all genera and species of Bambuseae, is prohibited unless imported: (1) For experimental or scientific purposes by the United States Department of Agriculture; (2) For export, or for transportation and exportation in bond, in accordance with §§ 352.2 through 352.15 of this chapter; or. (3) Into Guam in accordance with § 319.37—4 (b) . ***** Subpart — Nursery Stock, Plants, Roots, Bulbs, Seeds, and Other Plant Products 1 2 6. In §319.37-1, the definition of "Prohibited article" is revised to read as follows: §319.37-1 Definitions ***** Prohibited article. Any nursery stock, plant, root, bulb, seed, or other plant product designated in § 319.37-2 (a) or (b), except wood articles regulated under §§319.40-1 through 319.40-1 1, "Subpart — Logs. Lumber, and Other Unmanufactured Wood Articles." ***** 7. "Subpart — Logs from Chile and New Zealand" of this part is revised to read as follows: Subpart — Logs, Lumber, and Other Unmanufactured Wood Articles Sec. 319.40- 1 Definitions. 319.40- 2 General prohibitions and restrictions; relation to other regulations. 1 Regulations concerning the importation into the United States of bamboo not capable of propagation are set forth in §§ 319.40—1 through 3 1 9.40— 1 1 1 The Plant Protection and Quarantine Program also enforces regulations promulgated under the Endangered Species Act of 1973 (P.L. 93-205. as amended) which contains additional prohibitions and restrictions on importation into the United States of articles subject to this subpan (See 50 CFR parts 17 and 23). 2 One or more common names of articles are given in parentheses after most scientific names (when common names are known) for the purpose of helping to identify the articles represented by such scientific names; however, unless otherwise specified, a reference to a scientific name includes all articles within the category represented by the scientific name regardless of whether the common name or names are as comprehensive in scope as the scientific name. 319.40- 3 General permits: articles that may be imported without a specific permit; articles that may be imported without either a specific permit or an importer document. 319.40- 4 Application for a permit to import regulated articles; issuance and withdrawal of permits. 319.40- 5 Importation and entry requirements for specified articles. 319.40- 6 Universal importation options. 319.40- 7 Treatments and safeguards. 319.40- 8 Processing at facilities operating under compliance agreements. 319.40- 9 Inspection and other requirements at port of first arrival. 319.40- 10 Costs and charges. 3 1 9.40- 1 1 Plant pest risk assessment standards. Subpart — Logs, Lumber, and Other Unmanufactured Wood Articles §319.40-1 Definitions. Administrator. The Administrator of the Animal and Plant Health Inspection Service, United States Department of Agriculture, or any employee of the United States Department of Agriculture delegated to act in his or her stead. APHIS. The Animal and Plant Health Inspection Service, United States Department of Agriculture. Bark chips. Bark fragments broken or shredded from log or branch surfaces. CertiPicate A certificate of inspection relating to a regulated article, which is issued by an official authorized by the national government of the country in which the regulated article was produced or grown, which contains a description of the regulated article, which certifies that the regulated article has been inspected, is believed to be free of plant pests, and is believed to be eligible for importation pursuant to the laws and regulations of the United States, and which may contain any specific additional declarations required under this subpart. Compliance agreement. A written agreement between APHIS and a person engaged in processing, handling, or moving regulated articles, in which the person agrees to comply with requirements contained in the agreement. Departmental permit. A document issued by the Administrator authorizing the importation of a regulated article for experimental, scientific, or educational purposes. Free from rot. No more than two percent by weight of the regulated articles in a lot show visual evidence of fructification of fungi or growth of other microorganisms that cause decay and the breakdown of cell walls in the regulated articles. General permit. A written authorization contained in §319.40-3 F-1 2 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27675 for any person to import the articles named by the general permit, in accordance with the requirements specified by the general permit, without being issued a specific permit. Humus, compost, and litter. Partially or wholly decayed plant matter. Import (imported, importation). To bring or move into the territorial limits of the United States. Importer document. A written declaration signed by the importer of regulated articles, which must accompany the regulated articles at the time of importation, in which the importer accurately declares information about the regulated articles required to be disclosed by §319.40- 2(b). Inspector. Any individual authorized by the Administrator to enforce this subpart. Log. The bole of a tree; trimmed timber that has not been sawn further than to form cants. Loose wood packing material. Excelsior (wood wool), sawdust, and wood shavings, produced as a result of sawing or shaving wood into small, slender, and curved pieces. Lot. All the regulated articles on a single means of conveyance that are derived from the same species of tree and were subjected to the same treatments prior to importation, and that are consigned to the same person. Lumber Logs that have been sawn into boards, planks, or structural members such as beams. Permit. A specific permit to import a regulated article issued in accordance with §319.40-4, or a general permit promulgated in §319.40-3. Plant pest. Any living stage of any insects, mites, nematodes, slugs, snails, protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or reproductive parts of parasitic plants, noxious weeds, viruses, or any organism similar to or allied with any of the foregoing, or any infectious substances, which can injure or cause disease or damage in any plants, parts of plants, or any products of plants. Port of First arrival. The area (such as a seaport, airport, or land border station) where a person or a means of conveyance first arrives in the United States, and where inspection of regulated articles is carried out by inspectors. Primary processing. Any of the following processes: cleaning (removal of soil, limbs, and foliage), debarking, rough sawing (bucking or squaring), rough shaping, spraying with fungicide or insecticide sprays, and fumigation. Regulated article. The following articles, if they are unprocessed or have received only primary processing: logs: lumber; any whole tree; any cut tree or any portion of a tree, not solely consisting of leaves, flowers, fruits, buds, or seeds; bark; cork; laths; hog fuel; sawdust; painted raw wood products; excelsior (wood wool); wood chips; wood mulch; wood shavings; pickets; stakes; shingles; solid wood packing materials; humus; compost: and litter. Sealed container; sealable container. A completely enclosed container designed for the storage or transportation of cargo, and constructed of metal or fiberglass, or other rigid material, providing an enclosure which prevents the entrance or exit of plant pests and is accessed through doors that can be closed and secured with a lock or seal. Sealed (sealable) containers are distinct and separable from the means of conveyance carrying them. Solid wood packing material. Wood packing materials other than loose wood packing materials, used or for use with cargo to prevent damage, including, but not limited to, dunnage, crating, pallets, packing blocks, drums, cases, and skids. Specific permit. A written document issued by APHIS to the applicant in accordance with § 319.40-4 that authorizes importation of articles in accordance with this subpart and specifies or refers to the regulations applicable to the particular importation. Treatment Manual. The Plant Protection and Quarantine Treatment Manual, which is incorporated by reference at § 300.1 of this chapter in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. Tropical hardwoods. Hardwood timber species which grow only in tropical climates. United States. All of the States of the United States, the District of Columbia, Guam, the Northern Mariana Islands, Puerto Rico, the Virgin Islands of the United States, and all other territories and possessions of the United States. Wood chips. Wood fragments broken or shredded from any wood. Wood mulch. Bark chips, wood chips, wood shavings, or sawdust intended for use as a protective or decorative ground cover. § 319.40-2 General prohibitions and restrictions; relation to other regulations. (a) Permit required. Except for regulated articles exempted from this requirement by paragraph (c) of this section or §319.40-3, no regulated article may be imported unless a specific permit has been issued for importation of the regulated article in accordance with §319.40-4, and unless the regulated article meets all other applicable requirements of this subpart and any requirements specified by APHIS in the specific permit. (b) Importer document; documentation of type, quantity, and origin of regulated articles. Except for regulated articles exempted from this requirement by paragraph (c) of this section or §319.40-3, no regulated article may be imported unless it is accompanied by an importer document stating the following information. A certificate that contains this information may be used in lieu of an importer document at the option of the importer: (1) The genus and species of the tree from which the regulated article was derived; (2) The country, and locality if known, where the tree from which the regulated article was derived was harvested; (3) The quantity of the regulated article to be imported, (4) The use for which the regulated article is imported; and (5) Any treatments or handling of the regulated article required by this subpart that were performed prior to arrival at the port of first arrival. (c) Regulation of articles imported for propagation or human consumption. The requirements of this subpart do not apply to regulated articles that are allowed importation in accordance with §319.19, "Subpart— Citrus Canker and Other Citrus Diseases"; §319.34, "Subpart — Bamboo Capable of Propagation”; or §§319.37 through 3 1 9.37— 14 . “Subpart — Nursery Stock, Plants, Roots, Bulbs, Seeds, and Other Plant Products”; or to regulated articles imported for human consumption that are allowed importation in accordance with §§319.56 through 319.56-8, "Subpart — Fruits and Vegetables." (d) Regulated articles imported for experimental, scientific or educational purposes. Any regulated article may be imported without further restriction under this subpart if: (1) Imported by the United States Department of Agriculture for experimental, scientific, or educational purposes; (2) Imported pursuant to a Departmental permit issued by APHIS for the regulated article prior to its importation and kept on file at the port of first arrival; and (3) Imported under conditions specified on the Departmental permit and found by the Administrator to be adequate to prevent the introduction into the United States of plant pests. (e) Designation of additional regulated articles. An inspector may designate any article as a regulated article by giving written notice of the Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-13 27676 Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations designation to the owner or person in possession or control of the article. APHIS will implement rulemaking to add articles designated as regulated articles to the definition of regulated article in §319.40-1 if importation of the article appears to present a recurring significant risk of introducing plant pests. Inspectors may designate an article as a regulated article after determining that: (1) The article was imported in the same container or hold as a regulated article: (2) Other articles of the same type imported from the same country have been found to carry plant pests; or (3) The article appears to be contaminated with regulated articles or soil. § 31 9.40-3 General permits; articles that may be imported without a specific permit; articles that may be Imported without either a specific permit or an importer document. (a) Canada and Mexico. APHIS hereby issues a general permit to import articles authorized by this paragraph. Regulated articles from Canada and from states in Mexico adjacent to the United States border, other than regulated articles of the subfamilies Aurantioideae, Rutoideae, and Toddalioideae of the botanical family Rutaceae. may be imported without restriction under this subpart, except that they must be accompanied by an importer document stating that the regulated articles are derived from trees harvested in. and have never been moved outside, Canada or states in Mexico adjacent to the United States border, and except that they are subject to the inspection and other requirements in § 319.40-9. (b) Solid wood packing materials — (1) Free of bark; used with non-regulated articles. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Solid wood packing materials that are completely free of bark and are in actual use at the time of importation as packing materials for articles which are not regulated articles may be imported without restriction under this subpart, except that: (1) The solid wood packing materials are subject to the inspection and other requirements in §319.40-9; and (ii) The solid wood packing materials must be accompanied at the time of importation by an importer document, stating that the solid wood packing materials are totally free from bark, and apparently free from live plant pests. (2) Free of bark; used with regulated articles. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Solid wood packing materials that are completely free of bark and are in actual use at the time of importation as packing materials for regulated articles may be imported without restriction under this subpart, except that: (i) The solid wood packing materials are subject to the inspection and other reauirements in §319.40-9; (ii) The solid wood packing materials must be accompanied at the time of importation by an importer document, stating that the solid wood packing materials are totally free from bark, and apparently free from live plant pests; and (iii) The solid wood packing materials must be accompanied at the time of importation by an importer document, stating that the solid wood packing materials have been heat treated, fumigated, or treated with preservatives in accordance with § 319.40-7, or meet all the importation and entry conditions required for the regulated article the solid wood packing material is used to move. (3) Not free of bark; used with regulated or nonregulated articles. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Solid wood packing materials that are not completely free of bark and are in actual use as packing at the time of importation may be imported without restriction under this subpart, except that: (i) The solid wood packing materials are subject to the inspection and other requirements in §319.40-9; (ii) The solid wood packing materials must be accompanied at the time of importation by an importer document, stating that the solid wood packing materials have been heat treated, fumigated, or treated with preservatives in accordance with § 3 1 9.40-7. (4) Pallets moved as cargo. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Pallets that are completely free of bark and that are not in actual use as packing at the time of importation (i.e. . pallets moved as cargo) may be imported without restriction under this subpart, except that: (i) The pallets are subject to the inspection and other requirements in §319.40-9; and (ii) The pallets are accompanied by art importer document stating that the pallets were previously eligible for importation in accordance with paragraph (b) of this section and have not had wood added to them since that use. Solid wood packing materials other than pallets that are imported as cargo must be imported in accordance with the requirements of this subpart for raw lumber. (c) Loose wood packing materials. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Loose wood packing materials (whether in use as packing or imported as cargo) that are dry may be imported subject to the inspection and other requirements in §319.40-9 and without further restriction under this subpart. (d) Bamboo timber. APHIS hereby issues a general permit to import regulated articles authorized by this paragraph. Bamboo timber which is free of leaves and seeds and has been sawn or split lengthwise and dried may be imported subject to the inspection and other requirements in § 319.40-9 and without further restriction under this subpart. (e) Regulated articles the permit process has determined to present no plant pest risk. Regulated articles for which a specific permit has been issued in accordance with § 3 1 9.40—4 (b) (2) (i) may be imported without other restriction under this subpart, except that they are subject to the inspection and other requirements in §319.40-9. § 319.40-4 Application tor a permit to import regulated articles; issuance and withdrawal of permits. (a) Application procedure. A written application for a permit 1 must be submitted to the Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Port Operations Permit Unit, 4700 River Road Unit 136. Riverdale. MD 20737- 1236. The completed application must include the following information: (1) The specific type of regulated article to be imported, including the genus and species name of the tree from which the regulated article was derived; (2) Country, and locality if known, where the tree from which the regulated article was derived was harvested: (3) The quantity of the regulated article to be imported; (4) A description of any processing, treatment or handling of the regulated article to be performed prior to importation, including the location where any processing or treatment was or will be performed and the names and dosage of any chemicals employed in treatments; 1 Application forms for permits are available without charge from the Administrator, do the Permit Unit. Plant Protection and Quarantine. Animal and Plant Health Inspection Service. U.S. Department of Agriculture. 4700 River Road. Riverdale. MD 20737. or local offices of Plant Protection and Quarantine, which are listed in telephone directories F-1 4 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27677 (5) A description of any processing, treatment, or handling of the regulated article intended to be performed following importation, including the location where any processing or treatment will be performed and the names and dosage of any chemicals employed in treatments; (6) Whether the regulated article will or will not be imported in a sealed container or in a hold; (7) The means of conveyance to be used to import the regulated article; (8) The intended port of first arrival in the United States of the regulated article, and any subsequent ports in the United States at which regulated articles may be unloaded; (9) The destination and general intended use of the regulated article; (10) The name and address of the applicant and, if the applicant's address is not within the United States, the name and address of an agent in the United States whom the applicant names for acceptance of service of process; and (11) A statement certifying the applicant as the importer of record. (b) Review of application and issuance of permit. After receipt and review of the application. APHIS shall determine whether it appears that the regulated article at the time of importation will meet either the specific importation requirements in §319.40-5 or the universal importation requirements in § 319.40-6. (1) If it appears that the regulated article proposed for importation will meet the requirements of either §319.40-5 or §319.40-6, a permit stating the applicable conditions for importation under this subpart shall be issued for the importation of the regulated article identified in the application. (2) If it appears that the regulated article proposed for importation will not meet the requirements of either §319.40-5 or § 319.40-6 because these sections do not address the particular regulated article identified in the application, APHIS shall review the application by applying the plant pest risk assessment standards specified in §319.40-11. (i) If this review reveals that importation of the regulated article under a permit and subject to the inspection and other requirements in § 319.40-9, but without any further conditions, will not result in the introduction of plant pests into the United States, a permit for importation of the regulated article shall be issued. The permit may only be issued in unique and unforeseen circumstances when the importation of the regulated article is not expected to recur. (ii) If this review reveals that the regulated article may be imported under conditions that would reduce the plant pest risk to an insignificant level, APHIS may implement rulemaking to add the additional conditions to this subpart, and after the regulations are effective, may issue a permit for importation of the regulated article. (3) No permit will be issued to an applicant who has had a permit withdrawn under paragraph (d) of this section during the 12 months prior to receipt of the permit application by APHIS, unless the withdrawn permit has been reinstated upon appeal. (c) Permit does not guarantee eligibility for import Even if a permit has been issued for the importation of a regulated article, the regulated article may be imported only if all applicable requirements of this subpart are met and only if an inspector at the port of first arrival determines that no emergency measures pursuant to the Federal Plant Pest Act or other measures pursuant to the Plant Quarantine Act are necessary with respect to the regulated article.2 (d) Denial and withdrawal of permits. Any permit which has been issued may be withdrawn by an inspector or the Administrator if he or she determines that the person to whom the permit was issued has violated any requirement of this subpart. If the withdrawal is oral, the decision to withdraw the permit and the reasons for the withdrawal of the permit shall be confirmed in writing as promptly as circumstances permit. Any person whose permit has been denied or withdrawn may appeal the decision in writing to the Administrator within 10 days after receiving the written notification of the withdrawal. The appeal shall state all of the facts and reasons upon which the person relies to show that the permit was wrongfully 2 Section 105(a) of the Federal Plant Pest Act (7 U.S.C. 1 50dd(a)) provides, among other things, that the Secretary of Agriculture may. whenever he deems it necessary as an emergency measure in order to prevent the dissemination of any plant pest new to or not theretofore known to be widely prevalent or distributed within and throughout the United States, seize, quarantine, treat, apply other remedial measures to. destroy, or dispose of. in such manner as he deems appropriate, subject to section 105(d) of the Federal Plant Pest Act (7 U.S.C. 1 50dd(d)). any product or article, including any article subject to this subpart, which is moving into or through the United States, and which he has reason to believe is infested with any such plant pest at the time of the movement, or which has moved into the United States, and which he has reason to believe was infested with any such plant pest at the time of the movement. Section 10 of the Plant Quarantine Act (7 U.S.C. 164a) and section 107 of the Federal Plant Pest Act (7 U.S.C. 150ff) also authorize measures against regulated articles which are not in compliance with this subpart. denied or withdrawn. The Administrator shall grant or deny the appeal, in writing, stating the reasons for granting or denying the appeal as promptly as circumstances permit. If there is a conflict as to any material fact and the person from whom the permit is withdrawn requests a hearing, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing shall be adopted by the Administrator. §319.40-5 Importation and entry requirements for specified articles. (a) Bamboo timber Bamboo timber consisting of whole culms or canes may be imported into Guam or the Northern Mariana Islands subject to inspection and other requirements of § 319.40-9. Bamboo timber consisting of whole culms or canes that are completely dry as evidenced by lack of moisture in node tissue may be imported into any part of the United States subject to inspection and other requirements of §319.40-9. (b) Monterey pine logs and lumber from Chile and New Zealand; Douglas- fir logs and lumber from New Zealand— (1) Logs, (i) Requirements prior to importation. Monterey or Radiata pine ( Pinus radiata ) logs from Chile or New Zealand and Douglas-fir ( Pseudotsuga menziesii) logs from New Zealand that are accompanied by a certificate stating that the logs meet the requirements of paragraph (b)(l)(i) (A) through (D) of this section, and that are consigned to a facility in the United States that operates in accordance with § 319.40-8, may be imported in accordance with paragraphs (b) (l)(i) (A) through (b) (1) (iii) of this section. (A) The logs must be from live healthy trees which are apparently free of plant pests, plant pest damage, and decay organisms. (B) The logs must be debarked in accordance with § 3 19.40—7 (b) prior to fumigation. (C) The logs and any solid wood packing materials to be used with the logs during shipment to the United States must be fumigated in accordance with §319.40-7(f)(l), within 45 days following the date the trees are felled and prior to arrival of the logs in the United States, in the holds or in sealable containers. Fumigation must be conducted in the same sealable container or hold in which the logs and solid wood packing materials are exported to the United States. (D) During shipment to the United States, no other regulated article is permitted on the means of conveyance with the logs, unless the logs and the other regulated articles are in separate Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-1 5 27678 Federal Register / Vol. 60. No. 101 / Thursday, May 25, 1995 / Rules and Regulations holds or separate sealed containers, or. if the logs and other regulated articles are mixed in a hold or sealed container, the other regulated articles either have been heat treated with moisture reduction in accordance with §319.40- 7(d). or have been fumigated in the hold or sealable container in accordance with paragraph (b)(l)(i)(C) of this section. (ii) Requirements upon arrival in the United States. The following requirements apply upon arrival of the logs in the United States. (A) The logs must be kept segregated from other regulated articles from the time of discharge from the means of conveyance until the logs are completely processed at a facility in the United States that operates under a compliance agreement in accordance with § 319.40-8. (B) The logs must be moved from the port of first arrival to the facility that operates under a compliance agreement in accordance with §319.40-8 by as direct a route as reasonably possible. (iii) Requirements at the processing facility. The logs must be consigned to a facility operating under a compliance agreement in accordance with §319.40- 8 that includes the following requirements: (A) Logs or any products generated from logs, including lumber, must be heat treated in accordance with §319.40-7(c), or heat treated with moisture reduction in accordance with § 3 19.40—7 (d) . (B) The logs, including sawdust, wood chips, or other products generated from the logs in the United States, must be processed in accordance with paragraph (b) (1) (i ii) of this section within 60 days from the time the logs are released from the port of first arrival. (C) Sawdust, wood chips, and waste generated by sawing or processing the logs must be disposed of by burning, heat treatment in accordance with § 319.40-7(c), heat treatment with moisture reduction in accordance with § 3 19.40—7 (d) . or other processing that will destroy any plant pests associated with the sawdust, wood chips, and waste. Composting and use of the sawdust, wood chips, and waste as mulch are prohibited unless composting and use as mulch are preceded by fumigation in accordance with §319.40- 7(f)(3), heat treatment in accordance with §319.40-7(c). or heat treatment with moisture reduction in accordance with §31 9.40—7 (d) . Wood chips, sawdust, and waste may be moved in enclosed trucks for processing at another facility operating under a compliance agreement in accordance with §319.40-8. (2) Raw lumber. Raw lumber, including solid wood packing materials imported as cargo, from Chile or New Zealand derived from Monterey or Radiata pine (Pinus radiata) logs and raw lumber from New Zealand derived from Douglas-fir ( Pseudotsuga menziesii) logs may be imported in accordance with paragraphs (b)(2) (i) and (ii) of this section. (1) During shipment to the United States, no other regulated article (other than solid wood packing materials) is permitted on the means of conveyance with the raw lumber, unless the raw lumber and the other regulated articles are in separate holds or separate sealed containers: Except for mixed shipments of logs and raw lumber fumigated in accordance with § 3 1 9.40 — 7 (f) (2) and moved in accordance with paragraph (b)(1) (i)(D) of this section. Raw lumber on the vessel’s deck must be in a sealed container. (ii) The raw lumber must be consigned to a facility operating under a compliance agreement in accordance with § 319.40-8 that requires the raw lumber to be heat treated in accordance with §319.40-7(c) or heat treated with moisture reduction in accordance with § 3 1 9.40—7 (d) before any cutting, planing, or sawing of the raw lumber, and within 30 days from the time the lumber is released from the port of first arrival. (c) Tropical hardwoods. — (1) Debarked. Tropical hardwood logs and lumber that have been debarked in accordance with §319.40-7(b) may be imported subject to the inspection and other requirements of § 3 1 9.40-9. (2) Not debarked. Tropical hardwood logs that have not been debarked may be imported if fumigated in accordance with §319.40-7(0(1) prior to arrival in the United States. (3) Not debarked: small lots. Tropical hardwood logs that have not been debarked may be imported into the United States, other than into Hawaii, Puerto Rico, or the Virgin Islands of the United States, if imported in a lot of 15 or fewer logs and subject to the inspection and other requirements of §319.40-9. (d) Temperate hardwoods. Temperate hardwood logs and lumber (with or without bark) from all places except places in Asia that are east of 60° East Longitude and north of the Tropic of Cancer may be imported if fumigated in accordance with §31 9.40—7 (f) prior to arrival in the United States and subject to the inspection and other requirements of § 3 1 9.40-9. (e) Regulated articles associated with exclusively tropical climate pests. Regulated articles that have been identified by a plant pest risk assessment as associated solely with plant pests that can successfully become established only in tropical or subtropical climates may be imported if: (1) The regulated article is imported only to a destination in the continental United States: and, (2) the regulated article is not imported into any tropical or subtropical areas of the United States specified in the permit. (f) Cross-ties (railroad ties) from all places except places in Asia that are east of 60° East Longitude and north of the Tropic of Cancer may be imported if completely free of bark and accompanied by an importer document stating that the cross-ties will be pressure treated within 30 days following the date of importation. §319.40-6 Universal importation options. (a) Logs. Logs may be imported if prior to importation the logs have been debarked in accordance with § 319.40- 7 (b) and heat treated in accordance with § 319.40— 7(c). During the entire interval between treatment and export, the logs must be stored and handled in a manner which excludes any access to the logs by plant pests. (b) Lumber. — (1) Heat treated or heat treated with moisture reduction. Lumber that prior to importation has been heat treated in accordance with §319.40- 7 (c) , or heat treated with moisture reduction in accordance with §319.40- 7(d). may be imported in accordance with paragraphs (b)(1) (i) and (ii) of this section. (i) During shipment to the United States, no other regulated article (other than solid wood packing materials) is permitted on the means of conveyance with the lumber, unless the lumber and the other regulated articles are in separate holds or separate sealed containers, or, if the lumber and other regulated articles are mixed in a hold or sealed container, all the regulated articles have been heat treated in accordance with § 319.40-7(c), or heat treated with moisture reduction in accordance with §31 9.40—7 (d) . Lumber on the vessel’s deck must be in a sealed container, unless it has been heat treated with moisture reduction in accordance with § 319.40-7(d). (ii) If lumber has been heat treated in accordance with § 3 1 9.40-7 (c) . that fact must be stated on the importer document, or by a permanent marking on each piece of lumber in the form of the letters "HT" or the words "Heat Treated." If lumber has been heat treated with moisture reduction in accordance with § 319.40-7(d), that fact must be stated on the importer F-1 6 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday. May 25, 1995 / Rules and Regulations 27679 document, or by a permanent marking, on each piece of lumber or on the cover of bundles of lumber, in the form of the letters "KD” or the words “Kiln Dried." (2) Raw lumber. Raw lumber, including solid wood packing materials imported as cargo, from all places except places in Asia that are wholly east of 60° East Longitude and north of the Tropic of Cancer may be imported in accordance with paragraphs (b)(2) (i) and (ii) of this section. (i) During shipment to the United States, no other regulated article (other than solid wood packing materials) is permitted on the means of conveyance with the raw lumber, unless the raw lumber and the other regulated articles are in separate holds or separate sealed containers. Raw lumber on the vessel's deck must be in a sealed container. (ii) The raw lumber must be consigned to a facility operating under a compliance agreement in accordance with §319.40-8 that requires the raw lumber to be heat treated in accordance with §319.40-7(c) or heat treated with moisture reduction in accordance with §319.40-7(d), within 30 days from the time the lumber is released from the port of first arrival. Heat treatment must be completed before any cutting, planing, or sawing of the raw lumber. (c) Wood chips and bark chips. Wood chips and bark chips from any place except countries in Asia that are wholly east of 60° East Longitude and wholly or in part north of the Tropic of Cancer may be imported in accordance with this paragraph. (1) The wood chips or bark chips must be accompanied by an importer document stating that the wood chips or bark chips were either: (1) Derived from live, healthy, tropical species of plantation-grown trees grown in tropical areas: or (ii) Fumigated with methyl bromide in accordance with §319.40-7(0(3). heat treated in accordance with § 319.40- 7 (c) , or heat treated with moisture reduction in accordance with §319.40- 7(d). (2) During shipment to the United States, no other regulated articles (other than solid wood packing materials) are permitted in the holds or sealed containers carrying the wood chips or bark chips. Wood chips or bark chips on the vessel's deck must be in a sealed container: Except that; If the wood chips or bark chips are derived from live, healthy, plantation-grown trees in tropical areas, they may be shipped on deck if no other regulated articles are present on the vessel, and the wood chips or bark chips are completely covered by a tarpaulin during the entire journey directly to the United States. (3) The wood chips or bark chips must be free from rot at the time of importation, unless accompanied by an importer document stating that the entire lot was fumigated with methyl bromide in accordance with §319.40- 7(f)(3), heat treated in accordance with §319.40-7(c), or heat treated with moisture reduction in accordance with § 319.40— 7(d). (4) Wood chips or bark chips imported in accordance with this paragraph must be consigned to a facility operating under a compliance agreement in accordance with §319.40- 8. The wood chips or bark chips must be burned, heat treated in accordance with §31 9.40—7 (c) . heat treated with moisture reduction in accordance w ith §319.40-7(d), or otherwise processed in a manner that will destroy any plant pests associated with the wood chips or bark chips, within 30 days of arrival at the facility. If the wood chips or bark chips are to be used for mulching or composting, they must first be fumigated in accordance with §319.40- 7(f)(3). heat treated in accordance with §319.40-7(c), or heat treated with moisture reduction in accordance with § 3 1 9.40—7 (d) . (d) Wood mulch, humus, compost, and litter. Wood mulch, humus, compost, and litter may be imported if accompanied by an importer document stating that the wood mulch, humus, compost, or litter was fumigated in accordance with § 319.40-7(0(3), heat treated in accordance with §319.40- 7(c), or heat treated with moisture reduction in accordance with §319.40- 7(d). (e) Cork and bark Cork and cork bark, cinnamon bark, and other bark to be used for food, manufacture of medicine, or chemical extraction may be imported if free from rot at the time of importation and subject to the inspection and other requirements of §319.40-9. §319.40-7 Treatments and safeguards. (a) Certification of treatments or safeguards. If APHIS determines that a document required for the importation of regulated articles is inaccurate, the regulated articles which are the subject of the certificate or other document shall be refused entry into the United States. In addition. APHIS may determine not to accept any further certificates for the importation of regulated articles in accordance with this subpart from a country in which an inaccurate certificate is issued, and APHIS may determine not to allow the importation of any or all regulated articles from any such country, until corrective action acceptable to APHIS establishes that certificates issued in that country will be accurate. (b) Debarking. Except for raw lumber, no more than 2 percent of the surface of all regulated articles in a lot may retain bark, with no single regulated article retaining bark on more than 5 percent of its surface. For raw lumber, debarking must remove 100 percent of the bark. (c) Heat treatment. Heat treatment must be performed only at a facility where APHIS or an inspector authorized by the Administrator and the national government of the country in which the facility is located has inspected the facility and determined that its operation complies with the standards of this paragraph. Heat treatment procedures may employ steam, hot water, kilns, exposure to microwave energy, or any other method (e.g., the hot water and steam techniques used in veneer production) that raises the temperature of the center of each treated regulated article to at least 71.1 °C and maintains the regulated article at that center temperature for at least 75 minutes. For regulated articles heat treated prior to arrival in the United States, during the entire interval between treatment and export the regulated article must be stored, handled, or safeguarded in a manner which excludes any infestation of the regulated article by plant pests. (d) Heat treatment with moisture reduction. (1) Heat treatment with moisture reduction may employ: (1) Kiln drying conducted in accordance with the schedules prescribed for the regulated article in the Dry Kiln Operator's Manual, Agriculture Handbook 188, which is incorporated by reference at § 300. 1 of this chapter; or, (ii) Dry heat, exposure to microwave energy, or any other method that raises the temperature of the center of each treated regulated article to at least 71.1 °C. maintains the regulated articles at that center temperature for at least 75 minutes, and reduces the moisture content of the regulated article to 20 percent or less as measured by an electrical conductivity meter. (2) For regulated articles heat treated with moisture reduction prior to arrival in the United States, during the entire interval between treatment and export the regulated article must be stored, handled, or safeguarded in a manner which excludes any infestation of the regulated article by plant pests. (e) Surface pesticide treatments. All United States Environmental Protection Agency registered surface pesticide treatments are authorized for regulated articles imported in accordance with this subpart. Surface pesticide Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-17 27680 Federal Register / Vol. 60, No. 101 / Thursday. May 25. 1995 / Rules and Regulations treatments must be conducted in accordance with label directions approved by the United States Environmental Protection Agency. When used on heat treated logs, a surface pesticide treatment must be first applied within 48 hours following heat treatment. The surface pesticide treatment must be repeated at least every 30 days during storage of the regulated article, with the final treatment occurring no more than 30 days prior to departure of the means of conveyance that carries the regulated articles to the United States. (f) Methyl bromide fumigation. The following minimum standards for methyl bromide fumigation treatment are authorized for the regulated articles listed in paragraphs (f)(1) through (f)(3) of this section. Any method of fumigation that meets or exceeds the specified temperature/time/ concentration products is acceptable. (1) Logs, (i) T-312 schedule. The entire log and the ambient air must be at a temperature of 5 °C or above throughout fumigation. The fumigation must be conducted using schedule T- 312 contained in the Treatment Manual. In lieu of the schedule T-312 methyl bromide concentration, fumigation may be conducted with an initial methyl bromide concentration of at least 240 g/ m3 with exposure and concentration levels adequate to provide a concentration-time product of at least 17,280 gram-hours calculated on the initial methyl bromide concentration. (ii) T-404 schedule. The entire log and the ambient air must be at a temperature of 5 °C or above throughout fumigation. The fumigation must be conducted using schedule T-404 contained in the Treatment Manual. In lieu of the schedule T-404 methyl bromide concentration, fumigation may be conducted with an initial methyl bromide concentration of at least 120 g/ m3 with exposure and concentration levels adequate to provide a concentration-time product of at least 1920 gram-hours calculated on the initial methyl bromide concentration. (2) Lumber The lumber and the ambient air must be at a temperature of 5 °C or above throughout fumigation. The fumigation must be conducted using schedule T-404 contained in the Treatment Manual. In lieu of the schedule T-404 methyl bromide concentration, fumigation may be conducted with an initial methyl bromide concentration of at least 120 g/ m3 with exposure and concentration levels adequate to provide a concentration-time product of at least 1920 gram-hours calculated on the initial methyl bromide concentration. (3) Regulated articles other than logs or lumber, (i) If the ambient air and the regulated articles other than logs or lumber are at a temperature of 21 °C or above throughout fumigation, the fumigation must be conducted using schedule T-404 contained in the Treatment Manual. In lieu of the schedule T-404 methyl bromide concentration, fumigation may be conducted with an initial methyl bromide concentration of at least 48 g/ m3 with exposure and concentration levels adequate to provide a concentration-time product of at least 760 gram-hours calculated on the initial methyl bromide concentration. (ii) If the ambient air and the regulated articles other than logs or lumber are at a temperature of 4.5-20.5 °C throughout fumigation, the fumigation must be conducted using schedule T-404 contained in the Treatment Manual. In lieu of the schedule T-404 methyl bromide concentration, fumigation may be conducted with an initial methyl bromide concentration of at least 120 g/ m3 with exposure and concentration levels adequate to provide a concentration-time product of at least 1920 gram-hours calculated on the initial methyl bromide concentration. (g) Preservatives. All preservative treatments that use a preservative product that is registered by the United States Environmental Protection Agency are authorized for treatment of regulated articles imported in accordance with this subpart. Preservative treatments must be performed in accordance with label directions approved by the United States Environmental Protection Agency. §319.40-8 Processing at facilities operating under compliance agreements. (a) Any person who operates a facility in which imported regulated articles are processed may enter into a compliance agreement to facilitate the importation of regulated articles under this subpart. The compliance agreement shall specify the requirements necessary to prevent spread of plant pests from the facility, requirements to ensure the processing method effectively destroys plant pests, and the requirements for the application of chemical materials in accordance with the Treatment Manual. The compliance agreement shall also state that inspectors must be allowed access to the facility to monitor compliance with the requirements of the compliance agreement and of this subpart. Compliance agreement forms may be obtained from the Administrator or an inspector. (b) Any compliance agreement may be canceled by the inspector who is supervising its enforcement, orally or in writing, whenever the inspector finds that the person who entered into the compliance agreement has failed to comply with the conditions of the compliance agreement. If the cancellation is oral, the decision to cancel the compliance agreement and the reasons for cancellation of the compliance agreement shall be confirmed in writing, as promptly as circumstances permit. Any person whose compliance agreement has been canceled may appeal the decision in writing to the Administrator within 10 days after receiving written notification of the cancellation. The appeal shall state all of the facts and reasons upon which the person relies to show that the compliance agreement was wrongfully canceled. The Administrator shall grant or deny the appeal, in writing, stating the reasons for granting or denying the appeal, as promptly as circumstances permit. If there is a conflict as to any material fact and the person whose compliance agreement has been canceled requests a hearing, a hearing shall be held to resolve the conflict. Rules of practice concerning the hearing will be adopted by the Administrator. §319.40-9 Inspection and other requirements at port of first arrival. (a) Procedures for all regulated articles. (1) All imported regulated articles shall be inspected at the port of first arrival. If the inspector finds signs of plant pests on or in the regulated article, or finds that the regulated article may have been associated with other articles infested with plant pests, the regulated article shall be cleaned or treated as required by an inspector, and the regulated article and any products of the regulated article shall also be subject to reinspection, cleaning, and treatment at the option of an inspector at any time and place before all applicable requirements of this subpart have been accomplished. (2) Regulated articles shall be assembled for inspection at the port of first arrival, or at any other place prescribed by an inspector, at a place and time and in a manner designated by an inspector. (3) If an inspector finds that an imported regulated article is so infested with a plant pest that, in the judgment of the inspector, the regulated article cannot be cleaned or treated, or contains soil or other prohibited contaminants, the entire lot may be refused entry into the United States. (4) No person shall move any imponed regulated article from the port -1 8 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles Federal Register / Vol. 60, No. 101 / Thursday, May 25, 1995 / Rules and Regulations 27681 of first arrival unless and until an inspector notifies the person, in writing or through an electronic database, that the regulated article: (1) Is in compliance with all applicable regulations and has been inspected and found to be apparently free of plant pests; 3 or, (ii) Has been inspected and the inspector requires reinspection, cleaning, or treatment of the regulated article at a place other than the port of first arrival. (b) Notice of arrival; visual examination of regulated articles at port of First arrival. (1) At least 7 days prior to the expected date of arrival in the United States of a shipment of regulated articles imported in accordance with this subpart, the permittee or his or her agent must notify the APHIS Officer in Charge at the port of arrival of the date of expected arrival. The address and telephone number of the APHIS Officer in Charge will be specified in any specific permit issued by APHIS 4. This notice may be in writing or by telephone. The notice must include the number of any specific permit issued for the regulated articles: the name, if any, of the means of conveyance carrying the regulated articles; the type and quantity of the regulated articles; the expected date of arrival; the country of origin of the regulated articles; the name and the number, if any, of the dock or area where the regulated articles are to be unloaded: and the name of the importer or broker at the port of arrival. (2) Imported regulated articles which have been debarked in accordance with § 319.40— 7(b) and can be safely and practically inspected will be visually examined for plant pests by an inspector at the port of first arrival. If plant pests are found on or in the regulated articles or if the regulated article cannot be safely and practically inspected, the regulated articles must be treated in accordance with the Treatment Manual. (c) Marking and identity of regulated articles. Any regulated article, at the time of importation shall bear on the outer container (if in a container), on the regulated article (if not in a container), or on a document accompanying the regulated article the following information: ' Certain regulated articles may also be subject to §§ 319.56 through 319.56-8. "Subpart — Fruits and Vegetables." or to Noxious Weed Act regulations under part 360 of this chapter, or to Endangered Species Act regulations under parts 355 and 356 of this chapter and 50 CFR parts 17 and 23. 1 A list of APHIS Officers in Charge may be obtained from the Administrator. do Port Operations. Plant Protection and Quarantine. Animal and Plant Health Inspection Service. 4700 River Road, Riverdale. MD 20737. (1) General nature and quantity of the regulated articles: (2) Country and locality, if known, where the tree from which the regulated article was derived was harvested; (3) Name and address of the person importing the regulated article; (4) Name and address of consignee of the regulated article; (5) Identifying shipper's mark and number: and (6) Number of the permit (if one was issued) authorizing the importation of the regulated article into the United States. (d) Sampling for plant pests at port of first arrival. Any imported regulated article may be sampled for plant pests at the port of first arrival. If an inspector finds it necessary to order treatment of a regulated article at the port of first arrival, any sampling will be done prior to treatment. § 31 9.40-1 0 Costs and charges. The services of an inspector during regularly assigned hours of duty and at the usual places of duty shall be furnished without cost to the importer.5 The inspector may require the importer to furnish any labor, chemicals, packing materials, or other supplies required in handling regulated articles under this subpart. APHIS will not be responsible for any costs or charges, other than those identified in this section. § 319.40-1 1 Plant pest risk assessment standards. When evaluating a request to import a regulated article not allowed importation under this subpart, or a request to import a regulated article under conditions other than those prescribed by this subpart, APHIS will conduct the following analysis to determine the plant pest risks associated with each requested importation in order to determine whether or not to issue a permit under this subpart or to propose regulations establishing conditions for the importation into the United States of the regulated article. (a) Collecting commodity information (1) APHIS will evaluate the application for information describing the regulated article and the origin, processing, treatment, and handling of the regulated article; and (2) APHIS will evaluate history of past plant pest interceptions or introductions (including data from foreign countries) associated with the regulated article. (b) Cataloging quarantine pests. For the regulated article specified in an application, APHIS will determine what 5 Provisions relating to costs for other services of an inspector are contained in part 354 of this chapter. plant pests or potential plant pests are associated with the type of tree from which the regulated article was derived, in the country and locality from which the regulated article is to be exported. A plant pest that meets one of the following criteria is a quarantine pest and will be further evaluated in accordance with paragraph (c) of this section: (1) Non-indigenous plant pest not present in the United States: (2) Non-indigenous plant pest, present in the United States and capable of further dissemination in the United States; (3) Non-indigenous plant pest that is present in the United States and has reached probable limits of its ecological range, but differs genetically from the plant pest in the United States in a way that demonstrates a potential for greater damage potential in the United States; (4) Native species of the United States that has reached probable limits of its ecological range, but differs genetically from the plant pest in the United States in a way that demonstrates a potential for greater damage potential in the United States; or (5) Non-indigenous or native plant pest that may be able to vector another plant pest that meets one of the criteria in paragraphs (b)(1) through (4) of this section. (c) Determining which quarantine pests to assess. (1) APHIS will divide quarantine pests identified in paragraph (b) of this section into groups depending upon where the plant pest is most likely to be found. The plant pests would be grouped as follows: (1) Plant pests found on the bark; (ii) Plant pests found under the bark: and (iii) Plant pests found in the wood. (2) APHIS will subdivide each of the groups in paragraph (c)(1) of this section into associated taxa. (3) APHIS will rank the plant pests in each group in paragraph (c)(2) of this section according to plant pest risk, based on the available biological information and demonstrated plant pest importance. (4) APHIS will identify any plant pests ranked in paragraph (c)(3) of this section for which plant pest risk assessments have previously been performed in accordance with this section. APHIS will conduct individual plant pest risk assessments for the remaining plant pests, starting with the highest ranked plant pest(s) in each group. (5) The number of plant pests in each group to be evaluated through individual plant pest risk assessment will be based on biological similarities Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles F-19 27682 Federal Register / Vol. 60. No. 101 / Thursday, May 25. 1995 / Rules and Regulations of members of the group as they relate to measures taken in connection with the importation of the regulated article to mitigate the plant pest risk associated with the regulated article. For example, if the plant pest risk assessment for the highest ranked plant pest indicates a need for a mitigation measure that would result in the same reduction of risk for other plant pests ranked in the group, the other members need not be subjected to individual plant pest risk assessment. (d) Conducting individual plant pest risk assessments. APHIS will evaluate each of the plant pests identified in paragraph (c) (4) of this section by: (1) Estimation of the probability of the plant pest being on. with, or in the regulated article at the time of importation; (2) Estimation of the probability of the plant pest surviving in transit on the regulated article and entering the United States undetected; (3) Estimation of the probability of the plant pest colonizing once it has entered into the United States; (4) Estimation of the probability of the plant pest spreading beyond any colonized area; and (5) Estimation of the damage to plants that could be expected upon introduction and dissemination within the United States of the plant pest. (e) Estimating unmitigated overall plant pest risk. APHIS will develop an estimation of the overall plant pest risk associated with importing the regulated article based on compilation of individual plant pest risk assessments performed in accordance with paragraph (d) of this section. (f) Evaluating available requirements to determine whether they would allow safe importation of the regulated article. The requirements of this subpart, and any other requirements relevant to the regulated article and plant pests involved, will be compared with the individual plant pest risk assessments in order to determine whether particular conditions on the importation of the regulated article would reduce the plant pest risk to an insignificant level. If APHIS determines that the imposition of particular conditions on the importation of the regulated article could reduce the plant pest risk to an insignificant level, and determines that sufficient APHIS resources are available to implement or ensure implementation of the conditions, APHIS will implement rulemaking to allow importation of the requested regulated article under the conditions identified by the plant pest risk assessment process. Subpart — Packing Materials §319.69 [Amended] 8. The introductory text to §319.69 is removed. 9. In §319.69. paragraph (a), the phrase "On and after July 1 . 1 933, the” is removed and the word "The” is added in its place. 10. In §319.69, paragraph (b), the phrase "On and after June 8. 1953, the” is removed and the word "The” is added in its place. 11. In §319.69, paragraph (b)(3) is removed, and paragraphs (b)(4) and (b)(5) are redesignated as paragraphs (b)(3) and (b)(4). respectively. §31 9.69a [Amended] 12. In § 319.69a. paragraph (a) is amended by removing the reference "(b)(1), (3). and (4)” and adding the reference "(b)(1) and (3)” in its place. Done in Washington. DC, this 19th day of May 1995. Terry L. Medley, Acting Administrator. Animal and Plant Health Inspection Service. [FR Doc. 95-12789 Filed 5-24-95; 8:45 am] BILLING CODE 341CT-34-P -20 Appendix F. Final Rule for Importation of Logs, Lumber, and Other Unmanufactured Wood Articles 0224578 2