BAYPORT AND THE SCOPING SESSION: PART 2

Many of you have read the initial summary of issues for the scoping session that GBCPA prepared in July 1999. The intent of this Scoping Issues: Part 2 document is to supplement what we wrote at an earlier time in the hope of providing more details for those of you wishing to make comments to the Corps of Engineers. The Corps is taking comments from the public regarding the issues they believe should be analyzed in detail in the Environmental Impact Statement (EIS) being prepared on the Port of Houston Authority's proposed Bayport container port. It is important to note that a permit application has already been filed on this proposed project and that public comment is part of an administrative law process that could lead to the issuance of a permit to construct this project. A formal record will be made of the public's comments at this scoping session, both oral and written. You may submit written comments to the Corps up until Sept. 17, 1999.

The goal of Galveston Bay Conservation and Preservation Association (GBCPA) is to ensure that the Corps conducts a full and fair analysis of this project. The purpose of an EIS is to inform the decision-maker -- the District Commander of the Corps Galveston District -- of the impacts of the proposed Bayport container port as well as the impacts of alternatives to the Bayport proposal. The National Environmental Policy Act (NEPA) -- the act that requires the preparation of an EIS -- requires that a decision-maker be told the truth about the impacts to the environment and surrounding community and that a fair and unbiased evaluation of alternatives be required. It is from this perspective that this scoping supplement is written.

There are several issues that are both detailed and complicated.

I. NEED TO ANALYZE 50-FOOT DEEP CHANNEL

In the earlier document, we urged that all persons and groups concerned about the future of Galveston Bay request that the EIS include an analysis of the deepening of the Houston Ship Channel and the Bayport Channel to 50 feet of depth. This is an extremely important issue. Galveston Bay is one of the most productive estuarine areas in the United States. The production and maintenance of oysters, shrimp, crabs and juvenile finfish such as speckled trout and redfish is directly related to the balance between salt and freshwater inflows within the bay system. If this balance is disrupted, then the production can be lost.

The deepening of the Houston Ship Channel and the Bayport Channel to 50 feet would bring additional salt water into Galveston Bay from the Gulf of Mexico. The Bayport channel is located in the fresher portion of Galveston Bay; here, additional salt water threatens to increase the overall salinity of the bay, thereby altering the balance. When these increases are combined with reductions in freshwater inflows due to drinking water diversions from the Trinity, the net result is a saltier bay that will be less productive.

At this time, the 50-foot channel is not proposed by the Port of Houston Authority, who is arguing that such a channel should not be analyzed because it is not being proposed at this time. However, this 50-foot channel is a reasonably foreseeable future action and should be included in the EIS as a cumulative impact of the proposed Bay development. Additionally, the diversion of freshwater from the Trinity River and the reduction of Trinity River inflows also should be classified as a reasonably foreseeable future action that should be analyzed in combination with the 50-foot channel. These are the actions that will determine the future environmental quality of our Bay system. These are the actions that should be analyzed.

In order to fairly and fully analyze these cumulative impacts, a computer model of bay salinity must be developed and utilized to predict salinity levels resulting from this increase in salt inflows due to the 50-foot channel and decreases in freshwater inflow due diversions. This computer model should be selected and developed in consultation with the U.S. Fish and Wildlife Service, the National Marine Fisheries Service, the Texas Parks and Wildlife Department, the Texas General Land Office and the Texas Natural Resource Conservation Commission.

The importance of this analysis being included in the EIS cannot be overstated. The future of the Galveston Bay system is dependent upon the balance of salt and fresh inflows. The Port of Houston Bayport project, if constructed as proposed and designed, will require a 50-foot channel. This issue must be analyzed now -- at the beginning of the evaluation -- rather than being raised at a later time after the investment of more than $350 million in taxpayer’s money.

Air pollution is a major issue associated with the Port of Houston Bayport facility. In the earlier document, three types of air pollution arising from Bayport were identified. These were: (1) ozone, (2) fine particulate matter and (3) hazardous air pollutants. Each of these pollutants is discussed in sequence.

The Houston area is violating the national standard for ozone. If we do not develop a plan in the near future for reaching the ozone standard by the year 2007, our region may lose federal transportation funds. In fact, we may begin to lose federal transportation funds as early as 2001 if our region does not get a program together to solve our ozone air pollution. Additionally, there are major health consequences every day that we violate this national ozone standard, particular for young people and the elderly.

According to the experts, our region must reduce emissions of nitrogen oxides (NOx) by as much as 85 percent to come into compliance with the national standard for ozone. To date, our plan to achieve an 85 percent reduction is unacceptable. While industrial controls will help, there are no serious controls proposed in either the on-road or off-road mobile source categories. Together, these last two source categories contribute about 45 percent of our NOx. With regard to these two sources, two separate analytical issues exist. These are called general conformity analysis and transportation conformity analysis. These comments will focus upon general conformity requirements.

Bayport must be analyzed with regard to its effect on ozone air pollution specifically by identifying the production of NOx from the proposed Bayport container port construction and operation. GBCPA has estimated, utilizing a ratio methodology derived from an EIS for the Port of Long Beach, the NOx emissions from the proposed Bayport facility could range from 5 to 10 tons per day. This level of emissions is extremely high. The entire off-road mobile source category for the Houston region -- to which Bayport belongs -- produces approximately 220 tons per day of NOx.

According to modeling completed by the Texas Natural Resource Conservation Commission (TNRCC), this existing level of 220 tons per day of NOx must be reduced by at least 50 percent. Unfortunately, the Houston region currently lacks a plan to achieve such reductions. Therefore, Bayport will add off-road mobile source pollution to a category for which no plan exists to generate a reduction. If we add NOx from Bayport and do not otherwise reduce NOx in this category, we will worsen existing ozone levels, increase health problems and lose our federal transportation money.

The specific analysis that must be undertaken regarding the off-road mobile source contribution of the proposed Bayport port is called general conformity analysis. The scope of the general conformity analysis is triggered by the "but for" concept (cause-and-effect relationship). In comments about ozone air pollution and NOx generated by the facility, citizens should state that "but for" the issuance of a permit by the Corps of Engineers under §10 of the River and Harbor Act, no navigation facility could be constructed at Bayport. "But for" the §10 permit, no containers would be brought in by diesel powered vessels and tugs at Bayport, no diesel trains would be present at the site, no containers would be unloaded and moved about by diesel cranes and heisters, and no diesel trucks would be present on the site, lined up with their engines idling and belching pollutants. Your comments should also state that you are requesting that the Corps undertake general conformity analysis on all sources within the proposed Bayport container facility, including trucks, trains, cranes, heisters, ships and tugs.

This "but for" concept is extremely important in determining the "scope" of the air pollution analysis. While the above may seem to be common sense, it needs to be stated and presented to the Corps to enhance the effectiveness of your comments. "But for" your comments, the Corps might not complete this analysis correctly.

Fine particle matter is the most dangerous pollutant that will be generated by the Bayport facility. Again, your comments should be prefaced by the statement "but for" the issuance of the §10 permit by the Corps, fine particle air emissions would not be occurring at this site. Therefore, the impact of the port development and the associated diesel tugs, vessels, trains, cranes, heisters and trucks must be analyzed.

Diesel vehicles are a major source of fine particle air pollution. They are not regulated to any significant extent under current Texas law. Diesel engines generate fine particle emissions directly. Diesel engines generate NOx and sulfur dioxide (SO2) that form aerosols that are also considered to be fine particle air pollution.

Fine particle air pollution is deadly. The City of Houston Sonoma Technology Report identified that in the future, approximately 435 premature deaths per year would occur within the Houston region (primarily Harris County) associated with exposure to fine particle air pollution. Additionally, fine particle air pollution causes severe cardio-pulmonary problems and worsens existing lung problems.

In order to accurately assess fine particle air pollution from Bayport, five steps must be followed. First, the existing levels of fine particle air pollution in and around Bayport must be determined. This is no small task. At this time, a comprehensive monitoring system for fine particle air pollution does not exist in the Houston region or the Bayport area. In the Houston region, only "spot" studies have been completed to date. It is essential that serious fine particle-monitoring program be conducted as part of this environmental impact statement. The levels of fine particles that the residents of Shoreacres, Seabrook, La Porte, Pasadena, Deer Park, El Lago and Taylor Lake Village will be subjected to after completion of Bayport are impossible to determine without an excellent baseline monitoring system. This monitoring system must be established throughout the affected area and must provide representative samples throughout the affected area over the period of twelve consecutive months.

Second, the direct and indirect emissions (e.g., emissions of NOx and SO2) of fine particle matter must be estimated. Although direct emissions of fine particle may be relatively straightforward to predict, the formation of secondary fine particles from aerosols is a much more difficult analysis. A mathematical model must be developed that will predict the occurrence of fine particle air pollution within the affected area.

Third, direct emissions of fine particles must be added to secondary fine particle levels associated with NOx and SO2 aerosol formation in order to accurately determine resulting fine particle levels. Here, a Gaussian dispersion model is necessary to predict the isolines of concentration of fine particles within adjacent neighborhoods.

Fourth, once these fine particle emissions have been converted into predicted concentrations within the affected area, these modeled levels must be added to the monitored background concentrations in order to determine the resulting levels to which the residents will be exposed.

Fifth, an analysis must be completed of the health effects that would be expected to occur to residents within this affected zone. This health analysis should be completed by a qualified toxicologist and the extent and occurrence of health effects should be specifically analyzed. In this manner, an honest and fair analysis of the "but for" air pollution consequences of the issuance of the Corps of Engineers §10 permit will result.

C. Hazardous Air Pollutants

Yet a third type of air pollution -- hazardous air pollutants -- will be released from the proposed Bayport container port. Again, "but for" the issuance of the §10 permit, no diesel emissions would occur from ships, tugs, trains, cranes, heisters and trucks within the container facility. And once again, diesel combustion is the source of concern.

There are 38 specific hazardous constituents in diesel emissions and the state of California has designated diesel emissions to be hazardous in their own right. Again, the questions are the same. First, what are the existing levels of hazardous air pollutants in the residential areas surrounding Bayport? Second, what are the emissions of the specific hazardous constituents -- the speciated hazardous constituents -- associated with Bayport's activity. Third, what is the modeled concentrations of these speciated hazardous constituents in the neighborhoods? Fourth, what are the resultant hazardous constituent levels when modeled concentrations are added to monitored concentrations? Fifth, what are the health effects to the residents who are exposed to the resulting hazardous constituent levels?

Again, the importance of toxicological expertise cannot be overstated. These pollutants are not classified as hazardous for no reason. Many of these hazardous constituents are cancer-causing. Others cause genetic problems and may lead to gene alterations in adults and children (e.g., they are mutagenic) or they may lead to alterations in developing fetuses (e.g., they are teratagenic). Others are simply toxic. We need to know the facts about these constituents and the health consequences to be expected from these pollutants.

These air pollution issues are serious threats to public health. Additionally, these air pollution issues are not limited to the immediately adjacent subdivisions but are instead true regional impacts. This threat extends at least into Pasadena, Deer Park and La Porte as well as into the City of Houston with regard to ozone if not fine particles. Computer models must be relied upon to establish the extent of this impact, which will be different for each of the three air pollutants. These threats to public health result directly from the proposed Bayport container port. "But for" the construction of the Bayport facility, these increased levels of air pollution and increased risk of health problems would not exist.

III. LAND-USE ANALYSIS

From a land-use perspective, there are several key issues that must be addressed. These were identified in some detail in the earlier write-up. Again, the important point here is that "but for" the issuance of the §10 permit by the Corps of Engineers, these land use impacts would not occur. There would be no additional noise or lighting impacts across this acreage. There would not be an additional 7,000 trucks per day at peak usage. There would not be an additional 2,000 cars per day at peak usage. There would not be an additional eight 8,000 foot long trains per day at peak usage. The channel and wharves cannot be constructed without a Corps' permit. Without a Corps' permit, the containers could not be unloaded. Without a Corps permit and its associated container movement, there would be no need for 7,000 trucks per day and 2,000 cars per day.

A. Transportation Impacts

The extent of the transportation disruptions associated with the proposed Bayport container facility is immense. It is essential that the EIS, being prepared by the Corps of Engineers, fully and fairly analyze this issue. Reasonable traffic flow is an important aspect of residential development and use and enjoyment of residential property. If you lack mobility, you lack an important ingredient of safety and quality of life.

The scope of the analysis of transportation impacts should be very broad. Consider the following information presented to the Citizens Advisory Panel (CAP) that has been established by the Port of Houston Authority. Two 8,000-foot-long trains will enter and two 8,000-foot-long trains will leave the proposed Bayport rail yard in the morning and two 8,000-foot-long trains will enter and two 8,000-foot-long trains will leave the rail yard in the afternoon. According to the plans associated with the pending permit application, these trains will cross Fairmont Parkway eight times per day. This crossing is an at-grade crossing. An 8,000-foot-long train requires approximately 20 minutes to pass a particular point. This means that Fairmont Parkway will be closed eight times a day for 20 minutes, meaning that it will be closed for two hours and 40 minutes per day. There may be several additional crossings such as the Fairmont Parkway example. The important point is -- the full impact of the rail system must be identified and evaluated, and what is the community being asked to give up in order to gain a container facility at Bayport.

Similarly, the impact of 7,000 trucks per day must be fully understood. According to the CAP presentation, although containers will be loaded and unloaded 24 hours a day, trucks will primarily enter and leave the facility during daylight hours. Assuming a 12-hour daylight period and a relatively even distribution, at peak usage, almost 10 trucks per minute will be entering and 10 trucks per minute will be leaving this facility. If the projected average usage of 5,000 trucks per day is assumed instead of the 7,000 trucks per day peak usage, approximately seven trucks per minute will enter and seven trucks per minute will leave this facility. Additionally, another 2,000 cars per day are projected to enter and leave this facility.

The impacts of this increased truck traffic will be felt through a very large area, including along SH146 and Red Bluff, to name two areas. Of particular concern is the fact that a left-hand turn is required from SH146 South to Port Road in order for the trucks to enter the facility. According to a report prepared by a transportation consultant, this left-hand turn will create a level of service "F" at this location, meaning that SH146 will cease to function as through street.

Traffic systems are interconnected paths. When certain paths become obstructed, cars and trucks seek out other paths. An initial review indicates major thoroughfares such as SH146, Red Bluff and Fairmont Parkway will be severely impacted, as will Port Road and Todville Road. In turn, commuter traffic will likely avoid these roads, thereby increasing traffic congestion on other roads such as Bay Area Boulevard and NASA Road 1.

These traffic consequences are not localized to the subdivisions surrounding Bayport but are instead true regional impacts. The EIS for the proposed Bayport container port must clearly and honestly evaluate the resulting traffic consequences associated with truck traffic, car traffic and train movement associated with the Bayport container port. Again, full disclosure of the consequences of the issuance of this §10 permit must be set out. The citizens of the Bay Area have the right to know the consequences of this proposed Bayport facility.

B. Noise and Lighting

From a land-use standpoint, noise and lighting at the proposed Bayport facility will generate significant impacts to adjacent neighborhoods. Here, quantification is a key element. Noise levels must be predicted quantitatively as should lighting levels. Noise and lighting levels should be established for baseline conditions using monitors throughout the affected subdivisions. Background noise and lighting should be measured during times of the year when there are differences in tree cover, thereby taking into account seasonal variations. All impact analysis should be based upon increases from existing levels and should be supported by defensible calculations. Again, "but for" the issuance of this §10 permit, no increases in noise or lighting levels would occur.

C. Loss of Residential Integrity

The most difficult analysis is to identify the scale and extent of the loss of residential land uses that would not occur "but for" the issuance of the §10 permit. Together, noise and lighting impacts plus the loss of mobility plus increased air pollution will decrease the residential viability of certain areas. The extent of this residential decline should be clearly understood and articulated. "But for" the issuance of this §10 permit, certain residential areas would have continued to be viable.

The issue for the EIS is to determine where this loss in residential land use will occur and the magnitude of this loss. It is essential that one or more qualified land use experts undertake this analysis. The residential usage of the western shoreline of Upper Galveston Bay is an important aspect of the overall integrity of the Galveston Bay system. If these existing residential land use patterns are altered because of the development of Bayport, what are the likely consequences of this change?

The loss of land value is directly related to this loss of residential integrity. Realtors are reporting difficulty selling homes near Bayport. Land values are beginning to decline on the basis of the potential issuance of the §10 permit by the Corps of Engineers. How much land value will be lost as a result of the issuance of this §10 permit by the Corps of Engineers?

According to the Port of Houston Authority, the Bayport facility will cost $1.2 billion to construct and will generate $1.8 billion in economic activity. If however, more than $600 million in residential value is lost as a result of this project, the negative costs outweigh the direct benefits. That, of course, does not include the dollar costs of increased air pollution, which could easily amount to a $100 million or the damage to Galveston Bay, which is a vast recreational and commercial fisheries resource. Additionally, the costs of increased air pollution should be calculated and added as a negative cost of the Bayport Project.

D. Land-Use Analysis Conclusion

In summary, a major analysis of the land use impacts of the Bayport facility must be undertaken in the EIS. Full and fair disclosure requires that the residential "shock waves" of this project be understood and revealed, honestly and intelligently, in the EIS. Again, "but for" the issuance of the §10 project, the residential land-use pattern of the upper west shoreline of Galveston Bay would be stable. With the issuance of the permit, the residential viability and desirability of the upper west side of Galveston Bay will be significantly affected in a negative manner. The key questions are: What is the extent of the negative effects? What is the dollar value of the loss? Can the residential use of this area survive this impact?

According to the regulations of the Council on Environmental Quality (CEQ) that are binding on the Corps of Engineers in the EIS process, the analysis of alternatives is the "heart" of the Environmental Impact Statement process (40 CFR 1502.14). According to these regulations:

Based on the information and analysis presented in the sections on the Affected Environment (1502.15) and Environmental Consequences (1502.16), it [the EIS] should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public. In this section agencies shall:

(a) Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives, which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.

(b) Devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits.

(c) Include reasonable alternatives not within the jurisdiction of the lead agency.

(d) Include the alternative of no action.

(e) Identify the agency's preferred alternative or alternatives, if one or more exists, in the draft statement and identify such alternative in the final statement unless another law prohibits the expression of a preference.

(f) Include appropriate mitigation measures not already included in the proposed action or alternatives.

40 CFR 1502.14 (emphasis added).

As can be seen from the above quoted section from the CEQ regulations, the analysis of alternatives is an extremely important part of the EIS process.

With regard to Bayport, the selection of alternatives to be evaluated in the EIS is a critical "scoping" issue. Bayport is not the only site for a major container facility on Galveston Bay. Several such sites exist, including Texas City, Galveston, Freeport and expansion of the existing Barbours Cut container facility, to name four.

However, the scope of the analysis should not be limited to the Galveston Bay system. According to the Booz-Allen feasibility study prepared for the Port of Houston Authority, Texas City and New Orleans are both competitors to the Bayport facility. Competitors equate to alternatives.

In the context of scoping, the proper question is: What is the proposed project? Given the magnitude of the proposed Bayport facility, it should not be surprising that the proposed project is to develop the major container facility in the western Gulf of Mexico. As such, New Orleans is certainly an alternative and should be considered as such in the EIS.

A. Galveston Bay Alternatives

First and foremost, container port development should be viewed from the perspective that the Galveston Bay system is a regional environmental resource and a regional economic resource. If there is to be a 21^st-century container facility in the Galveston Bay system, where should this facility be located? This analysis should start with an inquiry into existing infrastructure -- where within the Galveston Bay system are there deepwater channels that can accommodate current and future container vessels?

Forty-foot channels exist into Galveston, Texas City, Bayport and the Houston Ship Channel. The channel at Freeport is dredged to a 45-foot depth. The Houston Ship Channel is in the process of being widened and deepened to 45 feet of depth, although the Bayport channel will remain at a 40-foot depth, at least in the short term. A 50-foot channel is authorized at Texas City but is not under construction.

Texas City, Galveston and Freeport are viable alternatives to the Bayport container facility. Additionally, it appears that expansion of the Barbours Cut facility to the north is a viable alternative as well as are vacant land areas within the land cut portions of the Houston Ship Channel. At the least, documentation should be gathered regarding each of these areas, including the existing channel depths, the ability of the existing channels to be expanded to 50 feet of depth, existing rail and road access, the character of adjacent land uses, the presence of wetland areas, the existence of adequate wharf space and the existence of plans for container port development.

An initial screening is appropriate under the federal regulations. However, all reasonable alternatives must be analyzed in a comparative manner in order to sharply define the issues and providing a clear basis of choice among options by the decision-maker and public.

This EIS is being prepared for the Corps of Engineers to assist their decision-maker -- the District Commander -- and to assist the public in evaluating different courses of action. Here, citizens should note in public comments that it is not the desire of the Port of Houston Authority that is important here. Instead, the Commander and the public need to know if there are different locations that are available for this container facility and if there are differing environmental impacts associated with these alternative locations. The EIS is not to justify a pre-selected alternative but is instead to provide an honest and fair evaluation of alternatives in a comparative manner.

From this perspective, it is essential that the Texas City alternative be evaluated in a detailed, comparative manner by the Corps of Engineers. The City of Texas City has developed an excellent alternative container concept for Galveston Bay. Although this alternative is not as well defined as is the Bayport alternative, substantial detail exists and a basis exists for developing information associated with impacts of this alternative on the affected environment. Therefore, detailed information should be collected regarding the affected environment of the Texas City site on Shoal Point and the environmental consequences of the development of the Texas City container port alternative. In this manner, the issues can be sharply defined and will provide a clear basis of choice for the Commander and the public.

There are several noteworthy differences between the Port of Texas City alternative and the Bayport alternative. The Port of Texas City is better served by rail and will not rely on trucks to the extent that Bayport is relying on trucks. This difference should be clearly articulated and understood. Further, a 50-foot deepwater channel at Texas City will have less salinity impact to Galveston Bay than would be the case if the Houston Ship Channel and the Bayport channel were deepened to 50 feet. There is little or no residential land development around the Texas City site. There will be less air pollution produced if there is less usage of trucks. On the other hand, there will be transportation consequences associated with increased rail usage and truck movement in Texas City that must be evaluated. There is still a need to understand emission patterns, background air concentrations and modeled levels in the surrounding areas. There may be environmental consequences to the Swan Lake area of Galveston Bay.

The important point is that detailed analysis of the Texas City alternative must occur in order to sharply define the issues and to provide a clear basis of choice among the alternatives. Here, an important point to note is that the EIS is being prepared by consultants hired by the Port of Houston Authority. It is a basic conflict of interest for consultants hired by the Port of Houston Authority to evaluate the Texas City alternative. The potential for conflict of interest should be noted and the Corps should act to insure that another group of analysts is selected to work on the Texas City alternative.

Other alternatives may prove to be viable as well. Galveston has an existing container facility. Freeport may be an excellent alternative site, given its rail and road accessibility and deepwater channel. The important point is that these alternatives must be fairly evaluated. We -- the public -- are identified as the beneficiary of this analysis of alternatives in the federal regulations of the Council on Environmental Quality. We need to tell the Corps what we want to see in this analysis of alternatives.

B. New Orleans Alternative

A key issue for this scoping session is whether or not a container facility in New Orleans is a reasonable alternative to the Bayport site. Given that Booz-Allen identified New Orleans as a competitor to the Port of Houston's Bayport project, the strong argument exists that the Port of Houston's own documents establish New Orleans as a reasonable alternative for purposes of this EIS. Again, the goal of the EIS is to determine alternatives to the proposed action. As defined in the Booz-Allen report, the proposed action is the development of a container facility to serve the Western Gulf of Mexico. If the "spoils of victory" include dominance in the western Gulf market, then the scope of the analysis of alternatives should include that same area.

New Orleans is developing a serious megaport proposal at the Mouth of the Mississippi River. This New Orleans alternative is a combined action of several Louisiana ports and is in the early stages of development. Given that a port proposal is being developed for New Orleans and that dominance of the western Gulf is at stake in these competing proposals, the scope of the EIS should include New Orleans.

It is extremely important that citizens express which issues they wish to be included in the EIS. Several provisions of the regulations of the Council on Environmental Quality, which control the EIS process, clearly state that the intended audience for the EIS is the federal decision-maker and the public. You are the public. Do not hesitate to tell the Corps what you expect from this document.

Written comments can be submitted by e-mail or regular mail. The address is:

U.S. Army Corps of Engineers, ATTN: Mark King, CESWG-PE-R, P.O. Box 1229, Galveston, TX 77553-1229.

Mr. King's e-mail address is john.m.king@swg02.usace.army.mil.

Deadline for comments is Sept. 17, 1999.

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