Comment from Kathleen Johnson & Jim Labonte, Oregon Dept. of Agriculture

7 CFR part 319 (Docket No. APHIS-2006-0125) Importation of Emerald Ash Borer Host Material From Canada Proposed action: amends regulations to prohibit or restrict the importation of emerald ash borer host material from infested areas of Canada consistent with those imposed by Canada on the materials from infested areas of the United States. I support the prohibition of importation into the United States of all ash trees, regardless of size, that originate in regions regulated by the CFIA for emerald ash borer. A concern is that the regulations might not be updated frequently enough. It would be better to include infested areas of Canada. Wood or bark chips less than 1 inch in diameter are allowed since larval growth are apparently not supported by chips this size or smaller. However, adults could be within that size of wood and carry emerald ash borer to the U.S. I do not support this inclusion of wood chips greater than 1 inch as an allowable imports. Counties bordering ones quarantined for emerald ash borer may have populations not yet detected since it is difficult to survey reliably for this pest. Even in official surveys, reliable techniques are not available to detect early infestations in an area. I would not allow firewood or ash wood and logs in neighboring counties to be enterable with only an import permit; again official surveys are not reliable to detect early infestations. Stronger regulation and tracking of firewood would be helpful. Preventing long distance shipment of firewood would help to slow the spread of invasive wood borer and other wood associated insects. At the least even though importer documents may be required to accompany some shipments, prior notification of receiving states that shipments from infested states are on their way would be more helpful and should be required. Kathleen Johnson, Insect Pest Prevention & Management Program Supervisor I have concerns that debarking and cambium removal to only 1.27 cm would be inadequate to ensure absence of EAB larvae. The cambium in large logs can be quite thick. Josh said that he found larvae at the cambium/sapwood interface of some logs, at depths exceeding 1 inch (2.54 cm). Jim LaBonte, Entomolgist