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AF&PA also agrees with the proposal to exempt solid wood packing material used as 

 packing for regulated articles from the specific permit requirements that would otherwise 

 apply to imported solid wood packing materials. To separately permit solid wood packing 

 material would be a substantial economic burden without significantly reducing plant pest 

 risk. 



AF&PA supports additional general permits over time as APHIS gains experience with 

 the kinds of wood imports and their associated pest risks. In the interim, the permit process 

 proposed in the rule, including the opportunity for appealing the withdrawal of permits, will 

 be effective in reducing the risk of inadvertent pest introductions and efficient in terms of 

 minimizing costs and delays. 



3. The Forest Industry Agrees with the Objectives of Universal Requirements Followed by 

 Specific Procedures for Evaluating Other Imports 



Our member companies inform us that they are interested in and are exploring 

 importing substantially greater quantities of unmanufactured wood products in the near future. 

 Given the range of potential import situations, it makes sense to establish universal 

 importation requirements as a floor of protection for which any articles may be imported from 

 anywhere in the world. 



