| |

Phytosanitary
Protection and the Forest Industry: Policy Issues on Quarantine
Pests

M.
Dubensky, R.
Scott Cameron, and R.
Kellison
Exotic, invasive pests are
affecting everyone, everywhere in the world. Movement of species
from one place to another in the world has always followed the paths
of human travel and commerce. However, due to the confluence of a
series of factors, we are experiencing a massive wave of exotic
species introductions never experienced before. These factors
include: rapidly expanding global economy, relaxed trade barriers,
efficient and rapid means of transport, widespread movement of large
volumes of all kinds of raw materials and manufactured goods, the
use of large enclosed containers containing infested organic
materials, and restricted use of pest control chemicals.
We all share concerns for
protecting our valuable forest resources from catastrophic losses
caused by invasive forest pests, and, at the same time, we are
concerned about the potential significant limitations to trade and
added costs that protecting against invasive species might bring to
our businesses.
Our objective is to provide a brief
overview of forest resources in the United States, the importance of
exotic forest pests, forest industry’s approach to phytosanitary
protection, and how the quarantine pest protection system works at
the state and federal levels in the United States.
Key Points
Forest industry companies in the
United States are strongly committed to the protection of the
valuable renewable natural resources that they manage and use in
their businesses.
The United States has a good set of
laws and well-established government agencies that have done a
commendable job of minimizing the spread of exotic pests.
Forest industry is supportive of a
consistent process that accurately assesses the risk of introducing
exotic pests associated with the importation of unprocessed logs,
chips, lumber, solid wood packing material, and other wood products,
as well as a reasonable set of barriers to prevent such
introductions.
At the same time, forest industry
is strongly committed to the principles of free trade and opposes
artificial or unnecessary barriers imposed upon businesses.
Cooperation among governments,
agencies, industry, and private citizens; new innovative and
integrated approaches; improved regulatory and suppression
procedures; and, additional funding will be needed to curtail the
movement and limit the negative effects of exotic pests around the
world.
Forest Resources in the United
States
One-third of the United States is covered with forests. There are
about 200 million hectares of commercial timberland in the United
States. Of this total, 59% is in the hands of 10 million independent
landowners (Fig. 1). Forest industry has 14% of the forest land
ownership in the United States, and national forests and other
public lands account for 27% (mostly in the West). Yet only 8% of
the timber is harvested from public lands, while 50% is from
non-industrial ownership and 42% from forest industry land. This
reflects the fact that timber harvest on national forest land has
been curtailed dramatically in recent years and public lands are now
being managed mostly for other non-timber commodities (preservation,
ecosystem management, recreation, watershed protection). A shrinking
land base and environmental restrictions on harvest are further
reducing the supply of timber in the United States, especially in
the West.
 |
| Figure 1 |
Thus, many forest industries are
looking at ways to increase yields on less land, development of new
technologies and products, and offshore opportunities. Fast-growing
high-yield forest plantations are becoming key components in the
strategic positioning of many leading companies in the international
pulp and paper business. Fiber and other forest resources have
become global commodities. These factors have led to the potential
for importing large volumes of logs, chips and other unprocessed
wood products to manufacturing facilities in the United States,
which in turn increases the potential for introducing destructive
exotic pests.
The United States is a net importer
of softwood lumber. In 1999, the United States imported 18 billion
board feet of softwood lumber or 35% of consumption. While the vast
majority of lumber imports are from Canada, other suppliers are also
increasing market penetration. Imports from countries other than
Canada jumped by over 41%. Other suppliers include Brazil, Mexico
and Chile. The only significant importation of chips from countries
other than Canada is currently from Chile. Chips are primarily
imported and consumed in the Pacific Northwest and account for less
than 1% of U.S. consumption. Some industry analysts speculate that
U.S. companies will begin importing pulpwood and/or chips from other
countries in Latin America if U.S. supply becomes more constrained.
That scenario has a high probability and, for that reason,
phytosanitary requirements have become an increasingly important
concern to the industry.
Invasive, Exotic Species
Most organisms that reach
new locations as exotics are transported to those locations by human
activity. Many times, humans purposefully bring new species into an
area. Other times, people move organisms about without really
knowing it. For example, organisms may "hitch rides" on
cars or ships, or they may be found in fruits or wood or other cargo
that is moved from one location to another. It is estimated that at
least 4,500 exotic species are now established in the United States.
Many of these are very beneficial. However, exotic species also can
be very harmful. They can become serious pests in the new areas
where they have no natural enemies and native species have not
developed resistance to the exotics. With increased international
travel and commerce, the estimated numbers of exotic species
introduced into the United States have increased exponentially over
the last 200 years (Fig. 2).
 |
| Figure 2 |
In U.S. forests, some of our most
destructive pests are exotic insects and disease organisms,
including chestnut blight (Cryphonectria parasitica), Dutch
elm disease (Ophiostoma ulmi), white pine blister rust (Cronartium
ribicola), the European gypsy moth (Lymantria dispar),
the balsam woolly adelgid (Adelges piceae), Formosan termite
(Coptotermes formosanus), the pine shoot beetle (Tomicus
piniperda), and the Asian longhorned beetle (Anoplophora
glabripennis). Exotic plant species also compete with native
plant species and become noxious weeds.
Forest Pest Management in the
United States
The U. S. Department of
Agriculture Forest Service historically has been a model agency
providing support to all sectors of the forestry community. The work
of the Forest Service, Forest Insect and Disease Research (FIDR) and
Forest Health Protection (FHP) groups has been especially valuable.
In recent years, the Forest Service has undergone major policy and
personnel changes, that have changed their focus toward
biodiversity, ecosystem management, and preservation. U.S. Forest
Service support of research and development on production forestry
problems has been greatly reduced.
The commercial forests in the
United States include of a variety of indigenous conifer and
hardwood species, not a few exotic tree species as in many South
American countries. Some of the indigenous pests of greatest
significance to the forest are the bark beetles (Dendroctonus
and Ips spp.), weevils (Pissodes spp.), rust diseases
(Cronartium spp.), dwarf mistletoes, and several
lepidopterous defoliators (Choristoneura spp., Orgyia
psuedotsugata, etc.). Much research and applications work has
been directed toward these pests over the years.
Among the major forest pests in the
United States, exotic species have caused some of the most
devastating losses in productivity and species displacement, but few
exotics have obviously threatened forest industry’s
bread-and-butter coniferous species (Pinus and Pseudotsuga).
Outstanding support provided by the Forest Service and universities
in the past and the lack of an obvious vital threat to the major
commercial species has allowed the forestry community to benefit
from this protection.
APHIS
The USDA, Animal and Plant
Health Inspection Service (APHIS) regulates imports under the
Federal Plant Pest Act and the Plant Quarantine Act. The primary
mission of APHIS is to “protect the health of U.S. plant and
animal resources and facilitate their movement in the global
marketplace.” APHIS Plant Protection and Quarantine (PPQ) is
responsible for regulating the importation of agricultural items and
plant-related materials that might harbor unwanted pests at the
ports of entry and beyond. The agency also facilitates commodity
exports upon request by conducting inspections and providing
phytosanitary certificates required by other countries. The
requirements for specific goods and products for each country are
listed in the APHIS EXCERPT database. This database allows PPQ
officers, state and county officials, and others to access export
regulations for specific countries around the world.
State Agencies
Through cooperative
agreements, state agencies (for example - North Carolina Department
of Agriculture, Plant Protection Section) assist with the
enforcement of federal laws and regulations and set policy and
direction concerning plant protection and quarantine pests at the
state level. The state’s role generally increases with distance
from the port of entry in the state. They can also issue
phytosanitary certificates for goods and products exported from
their states.
Recent Quarantine
Pest Activities Concerning Logs, Lumber, and other Unmanufactured
Wood Products
Restrictions on Log Exports
The pine wood nematode (Bursaphelenchus
xylophilus) and oak wilt (Ceratocystis fagacearum)
are examples of two forest pathogens present in the United States
that have caused concerns that resulted in limited exports of pine
logs and chips to Japan and certain Scandinavian countries and oak
logs to European countries, respectively. APHIS and state inspectors
have issued phytosanitary certificates that specify that logs for
export are free of these diseases.
Log Imports
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 commodity specific pest
risk assessments (USDA Forest Service 1991, 1992, 1993, and 1998).
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 by the
Oregon Natural Resources Council (ONRC) and two California
environmental groups (CATS) in Federal court, in part, on grounds
that the NEPA component of the rulemaking was deficient. The U.S.
District Court of Northern 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 the correction of deficiencies in the EIS. APHIS challenged
the injunction and, in response, submitted a Supplemental EIS in May
1998. The judge ruled that the SEIS satisfied deficiencies in the
original EIS and lifted the injunction on log import permits in
January 1999. The plaintiffs appealed the ruling to the 9th Circuit
Court, which recently upheld the earlier decision (USDA, APHIS
1998a).
Industry’s Involvement in
Quarantine Pest Activities
Forest industry companies
seldom are involved in quarantine pest detection, eradication, and
suppression activities. However, they do occasionally participate in
the process of developing and modifying regulations by providing
input through their trade associations during the public comment
periods and through intervention in legal proceedings when
appropriate. A
brief overview of forest industry’s involvement in recent events
concerning quarantine pests follows.
Through the American Forest and
Paper Association (AF&PA), the national trade association of the
forest, pulp, paper, paperboard and wood products industry, member
companies have identified the following phytosanitary regulation
objectives:
The industry is first and
foremost concerned about and dedicated to protecting U.S. forests
from infestations of exotic pests.
Necessary rules and regulations
must be based on sound science and afford adequate protection,
while minimizing costs and avoiding unnecessary delays and
barriers to entry of imported wood products.
APHIS should strive to minimize
administrative and compliance costs to the extent appropriate.
APHIS should strive to establish
a predictable regulatory climate that is consistent with overall
trade policy objectives.
One area in which the industry has
expressed considerable concern would be an outright ban on the use
of solid wood packaging material (SWPM) in international shipping.
We believe that would have devastating consequences to forest
management and downstream manufacturing in the United States.
Another option, requiring heat treatment of SWPM, will undoubtedly
increase the cost of commodities. Given that 90% of all
international shipments use SWPM, there will inevitably be a
significant impact on global trade and commodity suppliers. For
example, if the U.S. packaging industry were subjected to similar
requirements, it would impact 96% of all pallets in use (Source:
Cahners Research Study). It would likely increase the use of methyl
bromide, especially for smaller, low-cost operations that don’t
have access or the financial means for installing equipment for heat
or preservative treatments. It will likely close many marginally
profitable operations in the United States and abroad because of
global commerce in SWPM. The ultimate outcome will likely be the
replacement SWPM with non-wood substitutes which could create even
more significant energy and waste disposal issues and problems.
DISCUSSION AND CONCLUSIONS
There
will always be a risk of moving unwanted organisms into new
environments or that intentional movement of organisms may have
undesirable effects on the environment (Zero risk does not exist).
Forest industry and APHIS walk a very fine line regarding exotic
(quarantine) pests, with “biological risks” on one side and “economic
risks” on the other. Our challenge, therefore, is to minimize the
movement of unwanted pests and reduce their negative effects without
adversely affecting free trade and a healthy world economy. To
accomplish this goal will require unprecedented cooperation among
governments, agencies, industry, research institutions, and private
citizens around the world. Significant research efforts are needed
to develop improved and innovative new approaches to regulatory and
suppression procedures.
AF&PA supports a proactive “systems”
approach being considered by NAPPO and endorsed by the European
Plant Protection Organization and New Zealand. This approach should
include a series of integrated barriers to the transport,
introduction, and successful establishment of exotic pests in the
United States. AF&PA advocates a proactive approach to
prevention of pest introductions by cooperating with foreign
governments to identify potentially serious forest pests with a high
risk for successful introduction into the United States, monitoring
populations in the host countries, and implementing measures to
block important routes of introduction.
“Invasive, exotic species” is
currently a very hot topic with high level political support in the
United States. In 1999, President Clinton authorized by Executive
Order the formation of the Invasive Species Advisory Council. This
council is an overarching group including the heads of many of the
government agencies that deal with plant protection and exotic
species, including the USDA, the Department of Interior and the
Department of Commerce. Many states in turn have formed their own
invasive species councils. This activity has served as a catalyst
for obtaining appropriations for increased budgets and staffing in
the area of exotic, invasive species in the United States. The
Department of Interior particularly has benefited from this process,
whereas the USDA Forest Service to date has received relatively
little, but millions of additional dollars are expected in the near
future. This initiative in the United States coupled with similar
efforts in other countries will provide research funds for
developing and implementing new systems that can prevent serious
damage to our natural resources at a cost the our global economy can
afford.
BIBLIOGRAPHY
Cameron, R. S. 1996. Plenary Panel:
Forest Protection - Paper Tiger or Evolving Science? - - An Industry
Perspective. North American Forest Insect Work Conference. San
Antonio, TX. April 8-12, 1996.
Stoyenoff, et al. 1998. Forest
Health in the North Central States. USDA Forest Service, University
of Michigan, School of Natural Resources and Environment.
USDA, APHIS. 1994. Importation of
Logs, Lumber, and Other Unmanufactured Wood Articles, Environmental
Impact Statement, July 1994.
USDA, APHIS. May 25, 1995.
Importation of Logs, Lumber, and Other Unmanufactured Wood Articles.
Federal Register 60(101):27665-27682.
USDA, APHIS. 1998a. Importation of
Logs, Lumber, and Other Unmanufactured Wood Articles, Final
Supplement to the Environmental Impact Statement, May 1998.
USDA, APHIS. 1998b. Solid Wood
Packing Material from China. Initial Pest Risk Assessment on Certain
Wood Boring Beetles Known to Associated with Cargo Shipments: Asian
Longhorned Beetle (Anoplophora glabripennis), Ceresium,
Monochamus and Hesperophanes. Aug. 1998.
USDA, APHIS. October 4, 1999.
International Sanitary and Phytosanitary Standard-Setting
Activities. Federal Register 64(191):53657-53661.
USDA, APHIS. April 20, 2000.
Importation of Wood Chips from Chile. Federal Register
65(77):21120-21128.
USDA, Forest Service. 1991. Pest
Risk Assessment of the Importation of Larch from Siberia and the
Soviet Far East. Misc. Pub. 1495, Sept. 1991.
USDA, Forest Service. 1992. Pest
Risk Assessment of the Importation of Pinus radiata and
Douglas-fir Logs from New Zealand. Misc. Pub. 1508, Oct. 1992.
USDA, Forest Service. 1993. Pest
Risk Assessment of the Importation of Pinus radiata, Nothofagus
dombeyi, and Laurelia philippiana Logs from Chile. Misc.
Pub. 1517, Sept. 1993.
USDA, Forest Service. 1998. Pest
Risk Assessment of the Importation into the United States of
Unprocessed Pinus and Abies Logs from Mexico. Gen.
Tech. Rep. FPL-GTR-104.
USDA, Forest Service. Pest Risk
Assessment of Importation into the United States of Unprocessed Eucalyptus
Logs and Chips from South America - In press.
INTERNET WEB SITES
http://www.afandpa.org/
http://www.agr.state.nc.us/plantind
http://www.aphis.usda.gov/
http://www.ceris.purdue.edu/napis/napis.html
http://www.exoticforestpests.org/
http://www.exoticforestpests.org/rppc/
http://www.exoticforestpests.org/rppc/ippra.html
http://www.exoticforestpests.org/rppc/NANIAD.html
http://www.exoticforestpests.org/rppc/NewInitiatives.html
http://www.ippc.int
http://www.itds.treas.gov/ITDS/ITTA/forestry.html
http://www.nappo.org
http://willow.ncfes.umn.edu/fhncs/
|