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departures. Chips can also be loaded directly onto barges rather than stockpiled on the 

 ground awaiting a freighter. This has obvious advantages in terms of avoiding the 

 opportunity for insects and other decay organisms to infest the chips. 



The better approach would be to specify that logs be chipped and loaded onto barges 

 or ships in the minimum amount of time possible. If the bark is removed shortly after harvest 

 and the logs are chipped and loaded and transported quickly, insects and disease have little 

 opportunity to infest the chips. 



8. The Requirement to Process Chips Within 30 Days is Not Practical or Reasonable. 



There are situations where chips may be stored at manufacturing facilities in the U.S. 

 for more than 30 days before processing. Mill shutdowns and the rotation of chip piles may 

 cause delays that are not anticipated or planned. And, if the chips are transported to the U.S. 

 without long storage times in the country of origin, the potential for pest infestations is 

 minimized. 



Larger inventories of wood chips offer foresters the advantage of being more selective 

 in how and under what conditions trees are harvested and transported to the mill. Wet 

 periods during the winter, particularly in the Southern United States swamps and wetlands, 

 limit access to domestic supplies due to environmental restrictions and other logistical 

 constraints. More flexibility in wood storage times would allow foresters the options they 

 need to be more sensitive to resource protection concerns. 



