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consistent regulatory requirements. AF&PA believes that the Proposed Rule offers generally 

 effective and efficient regulations to establish an organized system for importing 

 unmanufactured wood articles. 



2. AF&PA Supports the General Permit for Domestic Species Imported From Canada and 

 Mexico. 



AF&PA believes that there is ample justification for an exemption from the proposed 

 rules for imports from neighboring states of Mexico and Canada. There has been a long 

 history of forest products trade with Canada and Mexico in specific species and wood 

 products that are indigenous to both of our countries. These include logs, pulpwood and 

 wood chips now freely traded between the three North American trading partners. The 

 proximity of the three countries and the lack of historical evidence of infestations warrants an 

 exemption for imports of domestic and native species. 



Instead of an outright exemption, APHIS has proposed a General Permit that would 

 allow importation if the importer certifies that the wood originated from that neighboring 

 state. We believe that this will effectively eliminate the possibility of substituting wood from 

 non-neighboring countries with the least amount of paper-work and regulatory burden. 



