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timely. AF&PA requests prompt action by APHIS to evaluate the potential of irradiation as a 

 treatment technique and include it in the proposed rule as an option under the universal 

 importation requirements. 



Irradiation offers the potential to substantially increase timber imports and alleviate the 

 timber supply crisis in the Pacific Northwest while ensuring the protection of domestic forests 

 from introduced pests. The widespread implementation of irradiation technology to meet 

 phyto-sanitary requirements may offer the opportunity to expand markets for U.S. exports in 

 the future. 



7. AF&PA is Concerned that it is not Practical to Require Chips to be Transported in "Holds 

 or Sealed Containers." 



AF&PA believes that it is not practical or reasonable to require that all wood chips be 

 transported in the holds of ships or sealed containers. In many cases, there are not sufficient 

 volumes of wood chips or adequate loading facilities in developing countries to justify the use 

 of a large freighter or closed container vessels. Consequently, forest products companies have 

 been planning to barge chips on large platform barges, particularly along the Gulf of Mexico 

 coast, that would not be sealed. 



Barging of chips offers advantages over sealed containers in that the chip inventories 

 can be kept much smaller (10,000 tons per load) and fresher with proportionately more 



