USE OF PESTICIDES

We are well aware that chemical pesticides are no cure-all and that there are risks involved in their use. We do not advocate indiscriminate use of pesticides and recognize the need for controlling the use of more hazardous ones. However, in setting up these controls, we ask that the benefits from pesticide usage in the forest be considered along with the risks. Today we do have tools to combat forest pests and weed trees. Various groups within the forest industry have long supported research aimed at developing alternatives that could be employed instead of chemical controls.

Research to develop effective silvicultural or biological controls for forest pests in tedious and costly but research efforts such as those of the U.S. Forest Service forestry schools and others continue to make progress. The outlook is promising. We heartily endorse an accelerated research program to develop alternative controls, but meanwhile we think it is important not to abandon our present technology while seeking a better alternative.

Use of pesticides in forest management differs somewhat from their use in agriculture. Although we have tree nurseries, seed orchards and tree breeding programs where extremely high values dictate regular preventive treatments, most forest applications of these materials are quite small. Few trees receive more than one treatment during their lifetime and many never require being treated. Herbicides are used somewhat more frequently but still only a small portion of the forest is treated in a given year. A survey made by Dr. Norman Johnson of the Weyerhaeuser Co. revealed that of 28 million acres managed by 43 industrial owners in the South, 186 thousand acres were treated with herbicides in 1969. This is only 0.7 percent of the acreage surveyed.

The most common method of applying herbicides is with a tree injector which permits a controlled dosage to be applied directly into the cull tree. There is no run-off and no known danger to the environment with this technique. Since many people have been concerned over possible harmful effects from 2,4.5-T, I might add that we are not aware of harmful effects to men or animals where this material has been used on commercial forests. We understand there is now evidence that the danger attributed to 2,4,5-T in Vietnam was caused by a contaminent known as dioxin and that all but a very small amount of this can be removed in the manufacturing process. As a forest management tool 2,4,5-T is neither injected into the flesh as in the case with mice under study in the laboratory nor is it sprayed in large quantities or in high concentrations over human populations. At this point I should like to comment briefly on contents of three bills—S. 745, 232 and 272.

8. 745

The provision in this Act for designating pesticides for "general use", "restricted use" or for "use by permit only" seems a logical and reasonable approach to a very difficult problem. The Act places a considerable burden on the Administrator and we feel that it would be improved by adding:

(1) further guidelines or criteria for classifying pesticides;

(2) specific guidelines outlining the responsibilities and qualifications for licensing operators and consultants. We suggest that the bill provide that standards for licensing applicators and consultants be determined with the aid of an advisory committee made up of research scientists, manufacturers, users including farm use, home use and forest use, entomologists, state administrators and others concerned. If the American Pulpwood Association can assist in this, we will be glad to do so;

(3) protection for users. The bill gives the manufacturer of a pesticide certain protection through appeals. We suggest that protection also be provided to the user. Sudden withdrawal of use of a pesticide, when no substitute is available, is unwarranted unless of course strong factual information is presented proving that the risks outweigh the benefits for a particular use.

To be effective pesticides usually must be applied rather precisely as to timing. For this reason, we feel that administrative procedures must be sufficiently streamlined to permit prompt use of pesticides when needed. If state regulatory agencies are to function effectively there must be a clear understanding with the Federal Administrator regarding usage of the various materials. Unless this understanding exists, an unwieldy and ineffective procedure will result, and requests to use pesticides may get bogged down.

S. 232 AND S. 272

These bills which would prohibit the sale and shipment of certain pesticides, seem inconsistent with the intent of $ 745. They would, in effect, eliminate all use of certain other pesticides. We feel that this step is unwarranted, since adequate alternatives are not available.

FOREST USE OF DDT

Although use of DT is controversial, its use on the Gypsy Moth does present an example of what can happen when use of a pesticide is discontinued before an adequate substitute is developed. The Gypsy Moth is a defoliator found primarily in Northeastern United States although in recent years it has been found in most states east of the Mississippi River. In describing a State-Federal cooperative program initiated in 1956 using DDT to control the Gypsy Moth, a Pennsylvania Department of Agriculture bulletin says ". . . this program was progressing well until 1963 when the use of DDT was discontinued . . .". Since that time the damage done by larvae of the Gypsy Moth was increased dramatically. The U.S. Department of Agriculture reports that the forest area defoliated increased from 80,000 acres in 1968 to 260,000 acres in 1969 to 800,000 acres in 1970.

ENDRIN

One pesticide mentioned in S 232 is endrin. This pesticide has a very specific use in forest management and there is no known substitute for it. It is used to treat seed to be direct-seeded-seed that are to be broadcast over an area in the forest where the ground has been specially prepared to receive it. Species most commonly direct-seeded are Slash Pine, Longleaf Pine, Loblolly Pine and Douglas Fir. The seeds are coated with 50% endrin and a latex sticked at the rate of about one pound of endrin for 100 pounds of seed. The seeds are broadcast over the land at a rate of 0.5 to 1.0 pounds of seed per acre, depending on the species.

This treatment of seeds prior to direct seeding effectively repells rodents. Before the use of endrin for this purpose, direct-seeding was usually a complete failure because rodents ate the seed.

We know of no substitutes that are available at the present time.

BENZENE HEXACHLORIDE (BHC)

Another pesticide that would be banned by S 232 is lindane. Since lindane is technically pure gamma isomer, benzene hexachloride (BHC) and since use of the latter had been questioned we feel we should comment on this pesticide.

BHC is used to combat bark beetles in all species of pine in the South and many species in the West. When timber stands are weakened-whatever the cause-pine bark beetles can increase their populations quickly and unless counter measures are instituted promptly, they may kill pine trees on hundreds or thousands of acres and are the South's most serious forest enemy.

In recent years both the forest industry and government agencies have undertaken a long range and costly program of tree breeding. Protecting valuable trees in seed orchards and progeny tests is absolutely essential. We can expect bark beetles to attack from time to time and must be prepared to protect our breeding stock for super-trees with the latest and best techniques.

BHC is effective for controlling bark beetles. The insecticide is applied either as an oil solution (.25% of the gamma isomer of BHC in number 2 fuel oil) or as an emulsifiable concentrate. These formulations may be applied as a preventive treatment to uninfested tree trunks and stumps near trees that have been attacked or to infested trees and stumps for direct control. The material is applied with small sprayers directly to selected trees. One gallon covers about 100 square feet of bark surface. No suitable substitute is available, although research is underway to provide non-chemical means of controlling bark beetles.

SUMMARY

We would like to stress the point that insecticides are largely used in the forest on an infrequent basis, and rarely are insecticides or herbicides applied to a given area more than once in 25 to 80 years. Regular spraying of the same area to eliminate cull hardwoods or endemic insect populations is neither feasible or necessary.

When pesticides are needed in insect or disease control the need is often immediate. Therefore administrative procedures governing the use of these materials must be structured to facilitate prompt decision making and action.

Pesticides are needed to protect and develop our Nation's forests which are vital both as a source of forest products and as means of improving our environment. We hope that these bills can be so written that they will provide for forest use of pesticides when needed.

Senator ALLEN. Mr. Moore, did you want to testify at this time? Mr. MOORE. NO. We collaborated on this. I am here to help answer questions if you have any to ask.

Senator ALLEN. We appreciate very much your attendance before the committee and giving us this testimony.

As to these two Senate bills completely banning DDT and certain other pesticides, Mr. Ruckelshaus stated that he was opposed to those bills on the very same theory that you outline there that they could be regulated under S. 745, and there is no need to ban them outright. Now, as to the American Pulpwood Association, this is a group of companies that own pulpwood lands or what is the association? Mr. LEE. The association is made up of pulpwood paper companies, also wood suppliers and people who provide timber to our mills. Senator ALLEN. By and large, the members of your association would own large acreage tracts, would they not?

Mr. LEE. Yes.

STATEMENT OF J. EDWIN MOORE, MANAGER, FORESTRY PROGRAM, AMERICAN PULPWOOD ASSOCIATION, NEW YORK, N.Y.

Mr. MOORE. Not all of them, Bob. It is an association of producers, consumers, and growers. Take any company, like Union Camp, for example. They manufacture pulp and paper, but they also own forest lands. And it is the forest land management people and the people who procure the wood for the mill that are our members. And we also have producer members who are mostly small contractors, and who buy small amounts of timber, cut it, and haul it to the mills.

Senator ALLEN. In other words, it covers several occupations and aspects of the pulpwood industry just like the Cotton Council embraces ginners and producers and mills and various other aspects of the cotton industry?

Mr. MOORE. Yes. Some of our members do not own any land, and some own a lot of land.

Mr. LEE. I might say that in the South, of the 190 million acres, 40 million acres are owned by the forest industry. This is not only pulp. and paper but lumber and other industries. And 141 million acres are in the hands of small private landowners.

Senator ALLEN. Union Camp has some land down in Alabama, does it not?

Mr. LEE. Yes, sir.

Senator ALLEN. I notice that they recently acquired some.

Now, actually the provisions of S. 745 would not impose the same degree of hardship on the pulpwood industry that it conceivably could on the small farmer who has to apply pesticides possibly several times a year, whereas in many cases your application is only a once-a-lifetime affair. And regulation might not be so burdensome on the forest owners and on the man who tills 40 acres of land; is that correct?

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Mr. LEE. That is true. I think when the need is here to apply these materials and Mr. McIntyre brought this out, I thought the need is now, and whether it be a large landowner or a small one, the procedure has to be so streamlined that you can employ them very quickly. Senator ALLEN. Hasn't the use of pesticides played an important part in saving our forest from destruction by pests?

Mr. LEE. Yes, sir; it certainly has.

Senator ALLEN. If the use of pesticides is withdrawn from the forest, how long would it take for the pests to take over?

Mr. MOORE. It is hard to tell. But one serious attack of southern pine beetles, for example, will kill an acre of trees just as quickly as one attack of boll weevils will ruin an acre of cotton.

Senator ALLEN. I notice, Mr. Lee, that you suggest that these three classifications seem logical. The pulpwood forests and the large tracts are owned by the owners of these forest lands, they are more conducive to having applicators and having consultants. You have those in your own organization already, I am sure.

Mr. LEE. We would hope, as Mr. Hall brought out, that the professional forester or a forest entomologist on the staff of a corporation could serve in this capacity. We would also be concerned, of course, about the small private landowner. Of course, in the South there are 140 million acres of timberland that is owned by small private landowners. They have to have guidance and direction. And this is where a lot of the problem could be."

Senator ALLEN. I notice you suggest setting up an advisory committee to advise the agency on guidelines, qualifications for applicators and consultants, and things of that sort. Now, under the bill they are suggesting doing away with the Scientific Advisory Council, which is a necessary step in the banning of products. I am just wondering if they would take too well to the thought of adding another commission here or another council to advise with them, where they probably feel that they have sufficient competence inside the agency to handle this. I think it is certainly a suggestion that is worthy of consideration.

Mr. LEE. Sir, I would say one of the concerns here is that though our uses are small, yet they are very important. The example of Endrin that was brought out earlier is a very important use, but it could get obscured, and you could easily say, you do not need Endrin in this country, let us do away with it, it has no application to agriculture-I do not know if it does or does not-but this could be done, and forestry would be left without a very valuable tool. This is our concern, Mr. Chairman.

Mr. MOORE. Before Endrin was developed, direct seeding in the forest was just impossible, it just could not be done, because the seeds were eaten by rodents. And now we can do it. And in spite of the fact that we just use a very small amount, it is a very necessary small

amount.

Senator ALLEN. Now, with the demand for the wood and wood products and timber, pulpwood, ever increasing, isn't it going to be important for you to have the best growth possible in your forests if this demand is to be met?

Mr. LEE. Absolutely.

Senator ALLEN. And the use of pesticides does enable your forests to continue their growth in such a way as to come fairly close to meet

ing the demands. But even at best we are falling behind, are we not, in this country?

Mr. LEE. Right. We have got to really develop a program has been developed, and part of it is the better utilization of our lands, and a six or eight-pronged program to increase productivity in the future. One of the things that stands in the wings or stands in the background that has harassed us in the past, and is a threat over our head, is the uncertainty of the introduced forest pests. When a forest pest is introduced into this country it leaves behind often the native insects or parasites or whatever holds it in check, and then it is unrestrained and may blossom out very quickly. Here is a need immediately for a pesticide to hold it in check until we can go over and import the parasites or can develop through research techniques to hold it in balance.

The chestnut blight of course wiped out the chestnut trees.
Senator ALLEN. Yes.

Do you think there is any possibility through research and through biological and nontoxic means of eradicating pests in your forests? Mr. LEE. I do not think we can entirely eradicate them, Mr. Allen. There are some exciting things developing in research throughout the South, where I am most familiar with what is going on, and private industry, Government, and universities are involved in approaches that involve genetic control and tree breeding resistance to insects and diseases, and biological controls, for example, the introduction of a virus to control an insect with a disease.

Silvicultural controls, of course, is what we have undertaken to use before pesticides came along. This approach is largely preventive, and we sometimes do not move fast enough with this approach to avoid an insect build-up. If you have a hurricane, for instance, and a lot of timber has blown down and is subject to attack by insects, rapid salvage would be silviculture's role, but you might also need insecticides to go along with it.

Senator ALLEN. We cannot stop using pesticides and wait on these alternatives, can we?

Mr. LEE. No, sir.

Mr. MOORE. One of the most dramatic cases, I think, if an introduced insect that has gotten out of control is the gypsy moth. I do not know if anyone has mentioned that in the hearing before. But it has been in the country for some time. And it was kept under fairly good control up until about the mid-sixties. And then DDT was no longer used on it. And in 1968 the gypsy moth defoliated 80,000 acres in the Northeast. And in 1969 it was 235,000, I think. And last year it was 800,000, 10 times as much as just 2 years ago. And the gypsy moth is gradually spreading throughout the East. It has been found in almost every State east of the Mississippi. It has only been in serious numbers really in the Northeast.

Senator ALLEN. When was it observed for the first time, Mr. Moore? Mr. MOORE. It has been in the country for nearly a hundred years. It was introduced into Massachusetts.

Senator ALLEN. What do you mean introduced there? It just came in?

Mr. MOORE. No; I believe some researcher was trying to develop a new kind of industry using the gypsy moth to supply silk. This was