╨╧рб▒с>■  ■                                                                                                                                                                                                                                                                                                                                                                                                                                                   ¤    ■   ■    ■   ■                                                                                                                                                                                                                                                                                                                                                                                                                                                                           Root Entry        └F@Щ6цV>╛└MatOST        └.mхV>╛аaЦхV>╛MM            MN0    ╩■   ■                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       ND╨╧рб▒с>■  ■      └FMicrosoft Works MSWorksWPDocЇ9▓q╨╧рб▒с>■                                                                                                                                                                                                                                                                                                                                  ■'N а░TЫ╨        F╩ аар=╨/╨8d    ╨4ЦDDOGWOOD ALLIANCE Post Office Box 1598 Brevard NC 28712 January 12, 1999 Docket No. 98-088-1 Regulatory Analysis and Development PPQ, APHIS, Suite 3C03 4700 River Road Unit 118 Riverdale, MD 20737-1238. RE: Docket No. 98-088-1 Asian Longhorned Beetle We are writing with reference to the APHIS proposal laid out in Docket No. 98-088-1 Asian Longhorned Beetle; Addition to Quarantined Areas. Under this proposed new rule, three areas in and around Chicago Illinois will be quarantined, and the interstate movement of regulated wood products from the quarantine areas will be restricted. We understand that, to date, portions of New York City and Nassau and Suffolk Counties in the State of New York are already under quarantine. Because this beetle is known to attack healthy maple, horse chestnut, birch, Rose of Sharon, poplar, willow, elm, locust, mulberry, chinaberry, apple, cherry, pear, and citrus trees, as well as other hardwood species, the Asian Longhorned Beetle threatens to have severe and lasting impacts on the ecology and economy of the southeast, if it spreads to the southeast from infested northern states. We concur with the decision made by the administrator of APHIS that the rule be published without prior opportunity for public comment. Because of the potential for such adverse impacts, prompt action may be the best way to prevent the ALB from spreading to noninfested areas of the United States. While Dogwood Alliance strongly supports this extension of the quarantine as a way to minimize the spread of the Asian Longhorned Beetle (ALB) from those infested areas to uninfested areas of the United States, we also believe that the list of materials which are prohibited from leaving quarantined areas must specifically include woodchips in its language. We understand that the materials which are prohibited from leaving quarantined areas include logs, nursery stock, green lumber, firewood, stumps, branches and wood debris over 1/2 inch in diameter, all of which are subject to infestation by the Asian Longhorn Beetle at one or more of its life stages. RE: Docket No. 98-088-1 Asian Longhorned Beetle pg 2 of 2 We ask that the rule be amended to specifically include woodchips in the list of quarantined items. Elsewhere, APHIS describes the proscribed method of disposing of infested wood products as chipping followed by burning. In 7 CFR 319.40-5 -- "Importation and entry requirements for specified articles", APHIS states that "The means used to destroy solid wood packing material under this section must be incineration, or chipping followed by incineration." This language is echoed in APHIS' October 1998 fact sheet, "Questions and Answers: Interim Rule of Solid Wood Packing material From China", which states on page that "[i]nfested trees must be removed, chipped, and then burned to destroy all life stages of any beetles remaining inside". This implies that woodchips may themselves serve as movement of woodchips as feedstocks for both paper production and as biomass for power generation, it is likely that there will be confusion on the part of wood processors and shipping concerns as to whether woodchips are subject to the quarantine unless woodchips are specified in the rule. Sincerely Danna Smith, Executive Director Dogwood Alliance DF{w)>@TVlnФо╩чщ░▓  ЭЯ╦═668g i з й И К x z Ь Ю · № ■   .@BDFF6F ArialTimes New RomanrопnФz ^w'"│╨╧рб▒с>■  ■                                                                                                                                                                                                                                         CompObj            U