[Federal Register Volume 80, Number 37 (Wednesday, February 25, 2015)]
[Notices]
[Pages 10053-10058]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-03898]
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DEPARTMENT OF COMMERCE
International Trade Administration
Trade Mission to South Africa, Kenya and Mozambique
AGENCY: International Trade Administration, Department of Commerce.
ACTION: Replacement of Trade Mission Statement.
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SUMMARY: The United States Department of Commerce, International Trade
Administration is replacing a notice published June 14, 2014, at 79 FR
36290, for the Trade Mission to South Africa and Mozambique, With an
Optional Stop in Kenya; February 23-27, 2015.
SUPPLEMENTARY INFORMATION: Replacement of Trade Mission Statement.
Background
The United States Department of Commerce, International Trade
Administration is replacing its Trade Mission to South Africa and
[[Page 10054]]
Mozambique, With an Optional Stop in Kenya; February 23-27, 2015 with a
new trade mission as notified herein. Replacement.
Trade Mission to Mozambique, Kenya and South Africa
June 18-26, 2015
Mission Description
The U. S. Department of Commerce, International Trade
Administration, is organizing a Trade Mission to Mozambique, Kenya and
South Africa, June 18-26, 2015, which will be led by a senior executive
of the U.S. Department of Transportation. The mission is designed to
help U.S. firms find business partners and sell equipment and services.
Target sectors holding high potential for U.S exporters include:
Transportation Infrastructure and Equipment, such as: road, bridge
and dam construction and reconstruction; automatic fare collection
systems, new and refurbished railroad locomotives, new bulk car and
other dedicated rolling freight fleets, smart signaling and rail
operation automation, rolling stock depot design, strategic route
design and network planning, port mobile, weighbridges and quayside
systems and upgrading of existing port equipment and oil and gas
development infrastructure.
Energy Equipment and Services, such as: power generation (including
renewable energy); transmission and distribution (including smart
grid), energy efficiency, oil and gas exploration and production and
project development.
Agricultural Equipment, such as: crop production equipment and
machinery, irrigation equipment and technology, crop storage and
handling, precision farming technologies and fertilizers.
Although focused on the sectors above, the mission also will
consider participation from companies in other appropriate sectors as
space permits.
This trade mission will include one-on-one business appointments
with pre-screened potential buyers, agents, distributors and joint
venture partners; meetings with national and regional government
officials, chambers of commerce, and business groups; and networking
receptions. The mission will help participating firms and trade
associations gain market insights, make industry contacts, solidify
business strategies, and advance specific projects, with the goal of
increasing U.S. exports to Mozambique, Kenya and South Africa.
Commercial Setting
Mozambique, with a population of 23 million, grew its economy from
1994 to 2009 at an average rate of eight percent per year--one of the
fastest rates of growth of any sub-Saharan African economy over this
period. In 2013, GDP reached $15 billion. While the country was
devastated after the civil war ended in 1992, it has since benefited
from macroeconomic reforms and large foreign investment projects.
Though infrastructure remains weak and the population is still
largely rural, the government is committed to building a strong
commercial environment. The United States has traditionally been a
relatively minor trading partner, but U.S. investment in the energy
sector, particularly off-shore natural gas, is expected to grow
tremendously in the next several years. External competition, local
labor quotas, periodic flooding, and an often-contentious political
situation present some challenges to doing business in Mozambique.
Kenya, with a population of 43 million, is the dominant economy in
the East African Community. Given its position as the economic,
commercial, and logistical hub of East Africa, more U.S. companies are
investing in Kenya and setting up local and regional operations there.
Kenya's first election under a new constitution with a devolved
government structure was held in April 2013, and should position it for
further growth. Investor confidence is high, as demonstrated by Kenya's
record-breaking $2 billion debut sovereign bond offering in 2014.
Kenya also boasts a large number of well-educated English-speaking
and multi-lingual professionals, and a strong entrepreneurial
tradition. Doing business in Kenya includes a number of challenges,
such as crime, unemployment, limited infrastructure, and corruption.
South Africa, a country of 52 million people, has the most
advanced, broad-based industrial economy in Africa, enjoys relative
macroeconomic stability and boasts sound financial, legal and
accounting institutions; not to mention an English-speaking workforce.
It remains the primary choice for U.S. companies wishing to develop the
promising markets of sub-Saharan Africa, although it suffers from large
disparities in income distribution and over 25 percent unemployment. In
2014 South Africa's GDP grew by less than two percent to $357 billion.
Doing business in South Africa includes a number of challenges
including corruption and power shortages, as well as a series of
protectionist policies that has precipitated a series of downgrades by
the major credit agencies.
Best Prospects in Targeted Sectors
Transportation Infrastructure and Equipment
Mozambique
Transport networks and infrastructure will be instrumental to
developing Mozambique's growth potential in the near and long term. The
recently concluded $500 million Millennium Challenge Corporation
compact funded extensive rehabilitation of key roads, a dam, and a
water supply project in two northern provinces. The Government of
Mozambique is investing heavily in expanding rail and port capacity to
manage the rising production of mineral resources. A rail line to the
deepest natural port on the East Coast of Africa should significantly
lower coal transport costs, and two foreign companies have recently
been contracted to begin work on a new rail line ending at Macuze port.
As total coal exports are projected to reach 40 million tons per year
by 2015 and long term estimates are in the range of 100 million tons
per year, infrastructure around this sector remains a priority. In
addition, rapid investment in infrastructure to support planned
liquefied natural gas (LNG) projects in northern Mozambique, one of its
least developed regions, could bring vast opportunities to U.S. firms.
Kenya
Kenya enjoys an extensive, but uneven, infrastructure that is still
superior in many cases to that of its neighbors. Nairobi is the
undisputed transportation hub of Eastern and Central Africa and the
largest city between Cairo and Johannesburg. The Port of Mombasa is the
most important deep-water port in the region, supplying the shipping
needs of more than a dozen countries despite persistent deficiencies in
equipment, inefficiency and corruption. As a result of these
deficiencies, the Port of Mombasa has been earmarked for major
expansion and re-habilitation.
Kenya's ``Vision 2030'' infrastructure development plans call for
significant improvements to the provision of water, renewable energy,
ICT, housing, roads, bridges, railways, seaports and airports over the
next 20 years. The construction industry in Kenya is driven primarily
by two key infrastructure sectors: Transportation and housing, given
the large housing deficit that exists in Kenya. Construction and
infrastructure development will also present new opportunities,
especially with the
[[Page 10055]]
passage of the new public-private partnership (PPP) law which will make
government procurements more transparent and less risky.
South Africa
South Africa's Transnet, the largest State Owned Enterprise (SOE)
within the Department of Public Enterprises (DPE) has announced and
allocated funding for significant transportation infrastructure capital
investments. In 2012, the government announced the allocation of
funding for investments estimated at over $90 billion over 15 years.
Though there have been complaints of slow implementation, leading some
contractors to re-focus business elsewhere in the continent, in late
2013 and early 2014 commitments were made to procure passenger rolling
stock, locomotives, signaling and track upgrades. Also, the development
of the significant Durban phase 2 port extension (in the old Durban
International Airport precinct) has been initiated.
The Passenger Rail Agency of South Africa (Prasa) of the SA
Department of Transport (SADOT) in March 2012 announced a 20-year rail
improvement program estimated at more than $13.6 billion. Of this, $1.3
billion will be invested in signaling, new depots, modern stations and
integrated ticketing, while $1.1 billion is being spent on new
locomotives.
SOE Transnet Freight Rail (TFR) and others are expanding logistics
projects such as upgrading the Sishen-Saldanha Bay ore line, the
Richard Bay coal line and other new coal line networks in the
northwest. Transnet's rail and port projects are reportedly set to cost
around $30 billion over seven years and include augmenting the tractive
and bulk car fleet, signaling, maintenance, advanced train management
systems and network expansion/concession models. For the second large
diesel locomotive program of 465 units, one U.S. and one Chinese
manufacturer were selected as preferred bidders in February 2014.
Transnet Port Terminals (TPT), the port operating SOE is set to
invest $3.3 billion over the next seven years for the expansion and
improvement of its bulk and container terminals. Significant capacity-
creating projects included the expansion of the Durban Container
Terminal's (DCT's) Pier 1 that would increase its capacity from 700,000
twenty-foot equivalent units (TEUs) to 820,000 TEUs by 2013 and 1.2
million TEUs by 2016/17. Other expansion projects include the Ngqura
Container Terminal, Durban Ro-Ro and Maydon Wharf terminal, the iron-
ore bulk terminal at the Port of Saldanha and the ageing Richards Bay
Terminal where $370 million is set aside for mobile and quayside
equipment, as well as weighbridges.
Energy
Mozambique
Mozambique is set to become one of the world's largest new
suppliers of natural gas. The country's massive offshore discoveries
have launched a scramble among exploration and production companies to
develop these new-found resources. In early 2014, the Oil and Gas
Journal raised Mozambique's proven reserves to 100 trillion cubic feet
(Tcf), making it the third-largest proved natural gas holder in Africa.
Although much of the Mozambique's offshore acreage still remains
underexplored, one U.S. company already has announced recoverable finds
totaling some 45-65 Tcf. The country's rich resources could support up
to ten LNG trains in one province alone, and a floating LNG facility is
under consideration. Developers focusing on Mozambique's LNG
infrastructure expect to begin exporting as early as 2018.
Additionally, although the United States exported only $25 million of
oil and gas field equipment to Mozambique in 2013, this is up from $1
million only five years prior and comprises about 19 percent of the
country's relatively small total of $132 million for that year. More
than 80 percent of U.S. exports to Mozambique are in pipe products,
indicating the early stages of the industry.
Mozambique is a net exporter of energy. But in order to support its
growing economy the country requires significant investment to upgrade
old infrastructure and conclude new generation projects. The majority
of power produced in the country comes from the Cahora Bassa hydro-
power scheme in central Mozambique, where the government plans a multi-
million dollar ``North Bank'' expansion. It will add an additional
1,250 MW with transmission lines to South Africa, the South African
Power Pool, Maputo, and Northern Mozambique. Planning for a second
multi-billion dollar, 1,500-plus MW hydropower dam 35 miles downstream
at Mphanda Nkuwa is well underway, and the operators are expected to
finalize financing this year, with commercial operations due to start
as early as 2017. The government of Mozambique recently approved new
renewable feed-in tariffs as part of an ongoing strategy to promote
private investment in renewable energy sources.
Kenya
In response to strong economic growth and increasing demand for
electricity, Kenya is focused on developing its power generation and
transmission and distribution infrastructure. Today, Kenya is faced
with brownouts, blackouts, and power surges that damage equipment and
necessitate emergency power, driving up the cost of electricity. The
supply deficit and costly short-term solutions impede economic growth,
and reduce the competitiveness of Kenya's private sector in the region.
With only 25 percent of the population connected to the grid, the
Kenyan government is currently implementing a plan to connect an
additional 5,000MW to the grid to meet growing demand and help reduce
electricity tariffs by 40 percent by 2017, with a goal of achieving
universal access by 2030.
In ITA's Renewable Energy Top Markets for U.S.-Exports 2014-2015,
Kenya was ranked 13th most promising export market for U.S. renewable
energy companies, and first in the geothermal sector, which makes up
about 22 percent of Kenya's energy mix (about 583 MW). More than 40
wells per year currently are being drilled, with a target of developing
over 5,000 MW, approximately half of its capacity, in the next two
decades. Kenya has extensive plans to increase other renewables as
well. The country is gradually diversifying its energy mix and is keen
to wean off expensive thermal diesel power, whose supply is impacted by
recurring droughts; and thermal power, which is sensitive to global
fuel prices.
Kenya is also an increasingly promising player in the booming East
Africa oil and gas market. The multiple onshore discoveries announced
since 2012, largely in Turkana County, have led exploration and
production companies to sound optimistic notes about the country's
potential. The greatest enthusiasm surrounds offshore resources, where
drillers hope to replicate Mozambique and Tanzania's vast natural gas
discoveries. To date, Kenya's oil resources are estimated to be 600
million barrels, with at least one firm projecting that Kenya's
resource base could amount to as much as 10 billion barrels, though
exploration is still in the early stages. While movement on key planned
infrastructure projects, such as the $25 billion Lamu Port, South Sudan
Ethiopia, Transport (LAPSSET) Corridor, has been slow, if all goes
smoothly, a Uganda-Kenya pipeline could be completed by as early as
2019.
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South Africa
Electricity supply constraints are significant and are expected to
remain a feature of South Africa's social and economic landscape for
several years to come. ESKOM, the government owned power utility, with
a virtual monopoly on generation, transmission and distribution
(responsible for around 95 percent of local generation) is experiencing
budgetary and infrastructure challenges. As a result of these
challenges, the government has put a renewed focus on the increased
generation of power, increased energy efficiency and decreased
consumption. ESKOM's reserve of power has recently become so low that
it has been forced to utilize its contractual rights with large
industrial users to require them to reduce consumption at critical
times, and it has implemented scheduled brownouts or ``load-shedding''
outages for all users. It has also been forced to use expensive diesel
to power generators at peak load periods. Though there is current and
planned infrastructure investment to ensure future supply, there have
been significant delays in bringing these planned power generation
facilities on line.
ESKOM is currently investigating smart grid as an option to manage
peak load demand. Renewable energy programs have also been introduced
in order to facilitate clean renewable independent energy production.
The government's Renewable Energy Independent Power Producer
Procurement program (REIPPP) has been relatively successful and marks
the first time independent power producers have been allowed to sell
power back to the grid. In ITA's Renewable Energy Top Markets for U.S.-
Exports 2014-2015, South Africa was ranked 12th; however, local content
requirements, which have increased in recent months, may limit
potential U.S. exports.
Further capital expenditure is ongoing with the two large scale
coal-fired plants under construction--Medupi Power Station (4,800 MW)
and Kusile Power Station (4800 MW)--as well as a pumped storage project
(1,332 MW) and a wind energy facility (1,00MW). With on-going power
outages, the government of South Africa has also recently opened bids
to independent power producers for the provision of 2,500 MW of base-
load (coal) power.
South Africa boasts the world's eighth largest supply of
technically recoverable shale gas resources, according to the U.S.
Department of Energy's Energy Information Administration. In 2012, the
government lifted a moratorium on exploring the country's estimated 390
trillion cubic feet (tcf) of unconventional deposits. While licenses
have yet to be issued, President Zuma announced in June 2014 that the
government would proceed with shale gas development plans, indicating
the government's willingness to move forward with development in the
sector.
South Africa has announced plans to add 9,600 MW of nuclear power
over the next twenty years and the government is in talks with multiple
countries about resources to develop South Africa's civil nuclear
energy program. The country currently has two nuclear reactors that
generate 5 percent of its electricity.
Agricultural Equipment
Mozambique
Mozambique has vast needs and vast opportunities in the agriculture
sector. Boasting a landmass about the size of Texas and Louisiana
combined, a coastline longer than the eastern seaboard of the United
States, and a geographic location well-positioned to export to
burgeoning Asian markets, agriculture is still small-scale and
subsistence. Growth in agriculture has lagged in relation to GDP
growth, largely due to the lack of mechanization and irrigation.
Opportunities for U.S. companies vary from cold storage, irrigation and
food processing equipment.
Mozambique recognizes agriculture as the key to poverty reduction
and employment and is focused on policy reforms to attract more private
sector investment. The Government of Mozambique is committed to
promoting the use of technology, irrigation, and improved methods to
raise yields. This commitment has resulted in plans by U.S. and other
foreign agribusiness companies to establish commercial farms.
Kenya
Agriculture remains the backbone of Kenya's economy. It accounts
for about 24 percent of GDP directly and 75 percent of the labor force
indirectly. Cash crop (tea, coffee, and horticulture), food crops
(maize, wheat and rice), and livestock dominate the agricultural
sector. Kenyan agriculture faces many challenges. It is predominately
rainfall dependent and thus subject to wide production variances. It is
undercapitalized, implying low technological absorption resulting in
low productivity. Small-scale farmers contribute about 75 percent to
the country's total value of agricultural output and account for nearly
85 percent of total employment in the agricultural sector. These
attributes, coupled with challenges arising from limited institutional
capacity, poor infrastructure, and risks associated with liberalized
markets, explain the relative stagnation of agricultural productivity
and incomes.
Kenya's horticulture industry is a major export success in Africa.
It is almost entirely dominated by the private sector and provides many
opportunities for increased importation of fertilizers, pesticides and
equipment. Similar opportunities lie in the floriculture industry in
Kenya, which is the leading exporter of fresh cut flowers to the flower
auction in Holland. Other important commodities include maize, tea,
coffee, sugarcane and wheat, which will require additional use of
fertilizers as production grows. The government has embarked on a
mechanization program to increase use of more modern means of farming
to increase output. In addition, the government has set aside 1.2
million acres of land for irrigation that for growing maize and wheat,
and livestock farming. Agricultural equipment is tax exempt under the
VAT Act 2013 to provide support to the sector.
Kenya imports virtually all of its agricultural chemicals because
local production is insignificant. Kenya's fertilizer use has almost
doubled since the liberalization of the market in the 1990s and the
removal of government price controls and import licensing quotas. The
growth in use has been noted especially among the smallholder farmers
in growth of both food crops (maize, domestic horticulture) and export
crops (tea, coffee). Growth in the industry is largely due to huge
private investment in both importation and retailing of fertilizers.
Fertilizer is also tax exempted under the new VAT Act.
South Africa
South Africa has by far the most modern, productive and diverse
agricultural economy in Sub Saharan Africa. Agriculture in South Africa
remains an important sector despite its relatively small contribution
to the GDP. The sector plays an important role in terms of job
creation, especially in rural areas, but is also a foremost earner of
foreign exchange.
South Africa has a market-oriented agricultural economy that is
highly diversified, including production of all the major grains
(except rice), oilseeds, deciduous and subtropical fruits, sugar,
citrus, wine and most vegetables. Livestock production includes cattle,
dairy, pigs, sheep, and a well-developed broiler and egg industry.
Value-added
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sector activities include slaughtering, processing and preserving of
meat; processing and preserving of fruit and vegetables; dairy
products; grain mill products; crushing of oilseeds; prepared animal
feeds; and sugar refining amongst other food products. South Africa
also exports wine, corn, mohair, groundnuts, karakul pelts, sugar, and
wool.
South Africa offers U.S. exporters in the agricultural equipment
and technology sector a wide range of opportunities. Five percent of
all new agriculture equipment is being produced locally; 95 percent of
all agriculture equipment and parts are being sourced from
international markets, and at least 20 percent of new equipment and
technologies are currently being sourced from the U.S.
Mission Goals
The goal of this trade mission is to provide U.S. participants with
first-hand market information, and one-on-one meetings with business
contacts, including potential agents, distributors and partners so they
can position themselves to enter or expand their presence in these
markets.
Mission Scenario
This mission will visit Maputo, Mozambique, Nairobi, Kenya and
Johannesburg, South Africa allowing participants to access the largest
markets and business centers in these countries.
Proposed Mission Timetable
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Day of Week Location Activity
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Wednesday, June 17.................... Maputo................... Companies arrive Maputo.
Welcome Breakfast.
Thursday, June 18..................... Maputo................... Briefing by U.S. Embassy.
One-on-one business appointments.
Evening business reception.
Friday, June 19....................... Maputo................... One-on-one business appointments continue.
Saturday, June 20..................... Maputo/Nairobi........... Site visit or travel to Nairobi.
Sunday, June 21....................... Maputo/Nairobi........... Remain in or travel to Nairobi.
Welcome Breakfast.
Monday, June 22....................... Nairobi.................. Briefing by U.S. Embassy.
One-on-one business appointments.
Evening business reception.
Tuesday, June 23...................... Nairobi.................. One-on-one business appointments continue.
Wednesday, June 24.................... Nairobi/Johannesburg..... Travel to Johannesburg.
Welcome Breakfast.
Thursday, June 25..................... Johannesburg............. Briefing by U.S. Embassy.
One-on-one business appointments.
Evening business reception.
Friday, June 26....................... Johannesburg............. One-on-one business appointments continue.
Mission Ends.
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*Note: The final schedule and potential site visits will depend on the availability of local government and
business officials, specific goals of mission participants, and air travel schedules.
Participation Requirements
All parties interested in participating in the trade mission must
complete and submit an application package for consideration by the
U.S. Department of Commerce. All applicants will be evaluated on their
ability to meet certain conditions and best satisfy the selection
criteria as outlined below. A minimum of 15 and maximum of 20 firms
and/or trade associations or organizations will be selected from the
applicant pool to participate in the mission.
Fees and Expenses
After a company or trade association/organization has been selected
to participate on the mission, a payment to the U.S. Department of
Commerce in the form of a participation fee is required. The
participation fee for the mission is $4,600 for small or medium-sized
enterprises (SME),\1\ and $6,200 for large firms and trade
associations/organizations. The fee for each additional representative
(large firm, SME or trade association/organization) is $750.
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\1\ An SME is defined as a firm with 500 or fewer employees or
that otherwise qualifies as a small business under SBA regulations
(see http://www.sba.gov/services/contractingopportunities/sizestandardstopics/index.html). Parent companies, affiliates, and
subsidiaries will be considered when determining business size. The
dual pricing reflects the Commercial Service's user fee schedule
that became effective May 1, 2008 (see http://www.export.gov/newsletter/march2008/initiatives.html for additional information).
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Exclusions
The mission fee does not include any personal travel expenses such
as lodging, most meals, local ground transportation and air
transportation. Delegate members will however, be able to take
advantage of U.S. Government rates for hotel rooms. Government fees and
processing expenses to obtain such visas are also not included in the
mission costs. However, the U.S. Department of Commerce will provide
instructions to each participant on the procedures required to obtain
necessary business visas.
Conditions for Participation
Applicants must submit a completed and signed mission application
and supplemental application materials, including adequate information
on the company's or association/organization's products and/or
services, primary market objectives, and goals for participation by
April 17, 2015. If the Department of Commerce receives an incomplete
application, the Department may either: reject the application, request
additional information/clarification, or take the lack of information
into account when evaluating the applications.
Each applicant must also certify that the products and services it
seeks to export through the mission are either produced in the U.S.,
or, if not, are marketed under the name of a U.S. firm and have at
least fifty-one percent U.S. content. In the case of a trade
association or organization, the applicant must certify that for each
company to be represented by the association/organization, the products
and/or services the represented
[[Page 10058]]
company seeks to export are either produced in the U.S. or, if not,
marketed under the name of a U.S. firm and have at least fifty-one
percent U.S. content.
In addition, each applicant must:
Certify that the products and services that it wishes to market
through the mission would be in compliance with U.S. export controls
and regulations;
Certify that it has identified to the Department of Commerce for
its evaluation any business pending before the Department that may
present the appearance of a conflict of interest;
Certify that it has identified any pending litigation (including
any administrative proceedings) to which it is a party that involves
the Department of Commerce; and
Sign and submit an agreement that it and its affiliates (1) have
not and will not engage in the bribery of foreign officials in
connection with a company's/participant's involvement in this mission,
and (2) maintain and enforce a policy that prohibits the bribery of
foreign officials.
Selection Criteria for Participation
Targeted mission participants are U.S. companies and trade
associations/organizations providing or promoting products and services
that have interest in entering or expanding their business in markets
of Mozambique, Kenya and South Africa. The following criteria will be
used in selecting participants:
Suitability of a company's (or in the case of a trade association/
organization, represented companies') products or services to these
markets.
Company's (or in the case of a trade association/organization,
represented companies') potential for business in the markets,
including likelihood of exports resulting from the mission.
Consistency of the applicant company's (or in the case of a trade
association/organization, represented companies') goals and objectives
with the stated scope of the mission.
Referrals from political organizations and any documents, including
the application, containing references to partisan political activities
(including political contributions) will be removed from an applicant's
submission and not considered during the selection process.
Timeframe for Recruitment and Application
Mission recruitment will be conducted in an open and public manner,
including publication in the Federal Register, posting on the Commerce
Department trade mission calendar (http://www.export.gov/trademissions/
) and other Internet Web sites, press releases to general and trade
media, notices by industry trade associations and other multiplier
groups, and publicity at industry meetings, symposia, conferences, and
trade shows.
Recruitment for this mission will begin immediately and conclude
April 17, 2015. We will inform applicants of selection decisions as
soon as possible after April 17, 2015. Applications received after
April 17, 2015 will be considered only if space and scheduling
constraints permit.
FOR FURTHER INFORMATION CONTACT:
U.S. Commercial Service, Johannesburg, South Africa, Brent Omdahl,
Deputy Senior Commercial Officer, Phone: 27-11-290-3227, Email:
[email protected].
Trade Missions Office, Washington, DC, Anne Novak, Phone: (202) 482-
8178, Email: [email protected].
Frank Spector,
International Trade Specialist.
[FR Doc. 2015-03898 Filed 2-24-15; 8:45 am]
BILLING CODE 3510-DR-P