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/