HFO-1234yf SNAP Workshop Meeting

November 20, 2009

Washington, DC

Meeting Summary

Prepared by ICF International

December 8, 2009TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc246911295"  Background
PAGEREF _Toc246911295 \h  4

  HYPERLINK \l "_Toc246911296"  1.	HFO-1234yf SAE Standards	  PAGEREF
_Toc246911296 \h  4

  HYPERLINK \l "_Toc246911297"  1.1	Systems Design	  PAGEREF
_Toc246911297 \h  4

  HYPERLINK \l "_Toc246911298"  1.2	Refrigerant	  PAGEREF _Toc246911298
\h  5

  HYPERLINK \l "_Toc246911299"  1.3	Service Equipment	  PAGEREF
_Toc246911299 \h  5

  HYPERLINK \l "_Toc246911300"  1.4	Technician Requirements:	  PAGEREF
_Toc246911300 \h  5

  HYPERLINK \l "_Toc246911301"  1.5	SAE Certification	  PAGEREF
_Toc246911301 \h  5

  HYPERLINK \l "_Toc246911302"  2.	CRP Risk Assessment of HFO-1234yf
PAGEREF _Toc246911302 \h  6

  HYPERLINK \l "_Toc246911303"  2.1	Corrosive Leaks	  PAGEREF
_Toc246911303 \h  6

  HYPERLINK \l "_Toc246911304"  2.3	Flammability	  PAGEREF _Toc246911304
\h  6

  HYPERLINK \l "_Toc246911305"  2.4	HF Generation	  PAGEREF
_Toc246911305 \h  7

  HYPERLINK \l "_Toc246911306"  2.5	Input Service Scenarios	  PAGEREF
_Toc246911306 \h  7

  HYPERLINK \l "_Toc246911307"  3.	Atmospheric Impacts	  PAGEREF
_Toc246911307 \h  8

  HYPERLINK \l "_Toc246911308"  4.	Vehicle Makers’ Suggested Rule
Modifications	  PAGEREF _Toc246911308 \h  9

ATTACHMENT 1- SAE/OEM HFO-1234yf SNAP Workshop
Presentation………………………………...……..11

Background

The Environmental Protection Agency (EPA) has issued a proposed rule for
the chemical HFO-1234yf in motor vehicle air conditioning under EPA’s
SNAP Program. Representatives of the automotive industry, including the
SAE International, have requested to meet with the EPA to update the SAE
standards relevant to HFO-1234yf, present SAE's research on the health
and safety risks of HFO-1234yf, and to offer comments on the proposed
use conditions in EPA's proposed rule. The following is a summary of the
meeting that took place between automotive industry representatives and
EPA on November 20th, 2009.

HFO-1234yf SAE Standards

Ward Atkinson, SAE Climate Chairman

There are currently thirteen HFO-1234yf -related documents to be
published in the first quarter of 2010 by the SAE International
Technical Standards Board. The documents are related to automotive
system design, refrigerant purity, automotive servicing equipment,
automotive technician requirements and SAE certification. Among these,
SAE would like the EPA to incorporate relevant standards into the final
HFO-1234yf rulemaking. Industry will also refer to HFO-1234yf as
R-1234yf when it is utilized as a production refrigerant.

Automotive Systems Design

The five SAE standards related to automotive systems design using
HFO-1234yf are:

J639 Safety Standards for Motor Vehicle Refrigerant Vapor Compression
Systems,

J2772 Measurement of Passenger Compartment Refrigerant Concentrations
Under System Refrigerant Leakage Conditions,

J2773 R-744 and HFO-1234yf Refrigerant Standard for Safety and Risk
Analysis for use in Mobile Air Conditioning Systems,

J2842 HFO-1234yf and R-744 Design Criteria and Certification for OEM
Mobile Air Conditioning Evaporator and Service Replacements

J2064 R-134a and HFO-1234yf Refrigerant Automotive Air-Conditioning Hose
and Assemblies.

Together, these standards establish safety requirements, a method of
testing and verification for use in risk assessment, and a procedure to
evaluate the refrigerant concentration for mobile air conditioning (MAC)
systems. The standards also minimize exposure to personnel during normal
use or servicing of a MAC system utilizing toxic or flammable
refrigerants and establish hose design requirements to minimize
permeation of the refrigerant and to maintain functionality in the -30°
to 125°C range.

Further, service equipment requirements and design requirements such as
in J639 reference the standard J1739, “Potential Failure Mode and
Effects Analysis in Design (Design FMEA), Potential Failure Mode and
Effects Analysis in Manufacturing and Assembly Processes (Process FMEA),
and Potential Failure Mode and Effects Analysis for Machinery (Machinery
FMEA).”

Refrigerant Purity

The J2844 standard - “Refrigerant Purity and Container Requirements
for New HFO-1234yf Refrigerant Used in Mobile Air-Conditioning
Systems” - establishes container specifications and minimum purity
levels required for use of HFO-1234yf in MAC systems.

Service Equipment

The five SAE standards related to service equipment for HFO-1234yf are:

J2843 HFO-1234yf Recovery/Recycling/Recharging Equipment for Flammable
Refrigerants for Mobile Air-Conditioning Systems,

J2851 HFO-1234yf Refrigerant Recovery Equipment for Mobile Automotive
Air-Conditioning Systems,

J2888 HFO-1234yf Service Hose, Fittings and Couplers for Mobile
Refrigerant Systems Service Equipment,

J2912 HFO-1234yf Refrigerant Identification Equipment for Use with
Mobile Air Conditioning Systems, and

J2913: HFO-1234yf Refrigerant Electronic Leak Detectors, Minimum
Performance Criteria.

Collectively, these standards establish minimum equipment (including
those used for refrigerant identification purposes) requirements for the
recovery/recycling/reclaiming and recharging of HFO-1234yf and detail
specific service equipment to be used in the service and maintenance of
HFO-1234yf systems.  The standards also establish minimum performance
criteria for electronic probe- type leak detectors intended for use in
automotive air conditioning systems utilizing HFO-1234yf as well as
performance and operating feature requirements for the
recovery/recycling/reclaiming and recharging of HFO-1234yf.

Technician Requirements

The J2845 standard - “Technician Training for Safe Service and
Containment of Refrigerants Used in Mobile A/C Systems (R-744 and
HFO-1234yf)” - requires that technicians be trained to recognize which
refrigerant is being handled and how to handle both refrigerants safely.

SAE Certification

The SAE J2911 standard - “Procedure For Certification That
Requirements For Mobile Air Conditioning System Components, Service
Equipment and Service Technicians Meet SAE J Standards” - establishes
a procedure for certifying that the requirements in SAE J Standards for
MAC system components, service equipment and service technicians are
met.

Closing Remarks:

More standards have been established for HFO-1234yf than for R-134a.
SAE has developed standards for HFO-1234yf similar to those for R-134a,
and has added a few additional standards which enable the industry to
address design and service requirements of HFO-1234yf (summary slide #24
in presentation).  All HFO-1234yf standards are to be published in the
first quarter of 2010.

CRP Risk Assessment of HFO-1234yf

William Hill, MAC Expert Consultant and Dr. Tom Lewandowski, Gradient
LLC

The Cooperative Research Program (CRP) is sponsored by vehicle makers
(e.g., BMW, Daimler, Chrysler, Ford, General Motors, Toyota, Hyundai,
Jaguar-Land Rover, etc.) and Tier One/Two Suppliers (e.g., DuPont,
Honeywell, Delphi, Goodyear, etc.). This study evaluated HFO-1234yf
material compatibility, air-conditioning system efficiency and
performance, and safety and risk assessments. The CRP Risk Assessments
found no significant risks associated with the use of HFO-1234yf in
mobile air-conditioning systems.

CRP’s methodology utilized Fault Tree Analysis (FTA) methods for key
exposure scenarios including vehicle exposures and repair exposures, and
qualitatively evaluated other limited impact scenarios. These results
were compared to non- air conditioning (AC) related automotive risks. In
this last phase of the CRP risk assessment, new experimental data
replaced modeling assumptions, fault trees were expanded, and results
were presented for the global vehicle fleet. This provided more reliable
numbers relating to refrigerant concentrations in vehicles and potential
HF generation and a more comprehensive conceptualization of the chain of
events that could lead to exposure (e.g., by including a break-down of
factors that are speed-dependent in the FTA).  For example, four vehicle
makers obtained refrigerant concentration measurements in the passenger
cabin after simulated refrigerant release.  The refrigerant
concentrations did not exceed the health-based exposure limit of 115,000
ppm, but did exceed the lower flammability limit (LFL) in a few severe
collision instances.  It was noted that for either the refrigerant to
ignite or for HF exposure to rise above a health-based limit, a series
of events or conditions had to occur in addition to an accidental
release of the refrigerant.

Corrosion Leaks

During evaluation of risks associated with evaporator leaks due to
corrosion (for example, due to water, road salt, aging, etc.), it was
found that the specified type of leak grew slowly, and the slow release
of refrigerant as the leak grew larger created cabin concentrations of
HFO-1234yf below 2%. This concentration is significantly below the LFL
of 6.2%, and thus poses no significant risk.  The previous assessment
had indicated that large corrosion leaks could produce HFO-1234yf
concentrations in the cabin above the LFL but further consideration
shows that the charge will be lost long before leak holes reach this
size (i.e., within several hours).  Corrosion leaks of the evaporator
were therefore not addressed by the FTA, which focuses on
collision-related leaks as well as leaks related to parts fatigue (e.g.,
abraded hoses).

Chemical Toxicity

Chemical toxicity was also found to pose an insignificant exposure risk.
Toxicity testing was performed by TNO, WIL, and Hamner Institutes.  This
analysis was conducted in the first two phases of the CRP and was not
repeated in this most recent, third phase, as exposures were not of
concern from the standpoint of refrigerant toxicity.

Flammability

The risk posed by flammability was also concluded to be low, as
evaluated by considering the possibility and effect of a flame
occurring. HFO-1234yf has a low burning velocity (1.5
centimeters/second) as compared to 152a and propane (both greater than
20 centimeters/second), meaning that it would have a limited effect if
ignited. HFO-1234yf is also difficult to ignite due to its high minimum
ignition energy (( 5000 milliJoules) as compared to methane and gasoline
(both less than 1 milliJoule). Furthermore, possible ignition sources
for HFO-1234yf are limited. The only sources considered to be credible
were a match, a failure or short of a positive temperature coefficient
(PTC) heater, and hot surfaces in the engine compartment under extreme
vehicle use. Although the flammability risk posed was concluded to be
very low, the risk was still addressed in the FTA.

HF Generation

HF generation testing was conducted in both an actual vehicle and in
bench-top studies. In a passenger cabin scenario with refrigerant
release and exposure to flame source, HF concentration due to HFO-1234yf
thermal decomposition below the LFL was significantly below the AEGL-2
limit (95 ppm over 10 minutes) inside the passenger cabin.  Moreover,
there was no direct ignition of the refrigerant HFO-1234yf; instead, a
strong spark was used to produce a butane flame, which was then used to
light the HFO-1234yf.  In an engine compartment scenario, where
HFO-1234yf was released onto the hot surface, the highest HF breath
level concentration measured in the vehicle cabin (with the cabin air
intake fan running at maximum) was also well below the AEGL-2 limit.
This is a conservative estimate given that the data were based on
extreme engine operation (700ºC) with the hood seals removed allowing
for a direct path to the cabin air intake and full suction from the
engine.  The presenter also noted that individuals can perceive
irritation from HF at concentrations of 3 to 5 ppm, and that those
exposed would quickly move to avoid further exposure.

EPA staff asked if the analysis considered exposure to first responders.
 Dr. Lewandowski explained that the fault tree analysis assumed that
professional first responders would be using appropriate protection.
However, the FTA did include scenarios for exposure to a “good
Samaritan,” such as a member of the general public or a volunteer
first responder, who might not have appropriate protective equipment. In
these scenarios, the fault tree analysis determined limited exposure
risks.

Input Service Scenarios

New CFD modeling applied to service-related refrigerant releases
suggests minimal ignition hazard. Service pits were not considered in
the FTA because they are assumed to be covered by existing OSHA
regulations on confined spaces that require ventilation for service
pits.  SAE assumes that EPA will require that only certified
professional technicians conduct AC service, which SAE standards will
also require.  Upon further clarification from the presenters, it was
determined that a “certified professional technician” is not written
intending to exclude certified non-professional technicians.  However,
it would require technicians, whether professional or not, to receive
certification before conducting AC service.

One automotive representative asked about the possible timing for a
follow-up rule for service technicians under §609 of the Clean Air Act.
 EPA staff stated that they could not answer that question.

Closing Remarks:

The FTA considered many scenarios for exposure to HFO-1234yf.  In the
analysis, it was found that:

Risk Comparison to Other Vehicle Events

Risk Scenario	Risk per vehicle per operating hour	Citation

Risk of being in a police reported vehicle collision	= 5 x 10-5	NHTSA,
2007

Risk of vehicle collision due to vehicle brake failure	= 3 x 10-7	New
York State DMV

Risk of highway vehicle fire (any cause)	= 1 x 10-7	Ahrens, 2008; BTS,
2004

Risk of an airbag-related fatality associated with a vehicle collision
=2 x 10-10	NHTSA, 2001

Risk of vehicle occupant/former occupant experiencing HF exposure above
health based limits associated with an HFO-1234yf ignition event	= 5 x
10-12	CRP, 2009

Risk of vehicle occupant being exposed to an open flame due to
HFO-1234yf ignition 	= 9 x 10-14	CRP, 2009

Risk Comparison to Other Workplace and Service Events

Risk Scenario	Risk per

working hour	Citation

Non-fatal recordable injury at work (all occupations)	=2 x 10-5	NSC,
2004

Risk among automotive repair tecnicians of being struck by object
resulting in lost work days	=2 x 10-6	BLS, 2007

Risk of service technician exposure to an open flame due to HFO-1234yf
ignition 	= 1 x 10-20	CRP, 2009

Risk of recordable incident involving repair technicians being struck
with high pressure HFO-1234yf equipment hose 	= 3 x 10-8	CRP, 2009

Based on these results, the presenter stated that use of HFO-1234yf in
MAC systems poses an extremely low level of risk for vehicle operators
and service workers.  In response to questions, Dr. Lewandowski
clarified that Phase III of the CRP study explicitly compares HFO-1234yf
to R-744 (CO2), but does not directly compare HFO-1234yf’s risks to
those for R-134a

Atmospheric Impacts

Dr. Tim Wallington, Ford Motor Company

The Ford Motor Company conducted a review of findings by scientific
studies and articles that evaluated atmospheric impacts caused by
HFO-1234yf. Section 3 summarizes the relevant findings and discrepancies
between the Company’s review and the Significant New Alternatives
Program’s (SNAP) evaluation.

Vehicle makers support the following SNAP findings:

 “HFO-1234yf has an ozone-depletion potential (ODP) of nearly zero,”

“The global warming potential (GWP) of HFO-1234yf is 4…” and

“TFA is produced from atmospheric oxidation of HFO-1234yf.”

TFA Accumulation

Vehicle makers also agree with the SNAP finding that the “…projected
maximum TFA concentration in rainwater should not result in a
significant risk of aquatic toxicity.” However, they disagree with a
statement in a report by ICF International (2009) that TFA is diluted in
fresh water bodies with the exception of “vernal pools and similar
seasonal water bodies that have no significant outflow capacity.”
Vehicle makers believe there is limited TFA accumulation in seasonal
water bodies based on Boutonnet et al. (1999).  Vehicle makers also
stated that no impacts were observed on vernal pool ecosystems in an
experimental study conducted by Benesch et al. (2002).

HFO-1234yf Emission Rate Estimates

Regarding the appropriateness of analyzing environmental impacts of
HFO-1234yf based on the current emission rate for HFC-134a, vehicle
makers recommend that EPA instead use 50 g per vehicle per total
lifecycle emission rate of HFO-1234yf in future environmental analyses.
This value was based on a 2009 study by Papasavva et al.

VOC Designation

In assessing the classification of HFO-1234yf as a volatile organic
compound (VOC), the vehicle makers suggest that ethane is more similar
to HFO-1234yf than ethylene based on their photochemical ozone creation
potential (POCP) values and maximum incremental reactivity. Vehicle
makers state that ethane is not classified as a VOC and HFO-1234yf has a
reactivity comparable to or less than that of ethane and therefore will
not contribute to a >1-4% increase in ground level ozone.  Vehicle
makers cited Wallington et al. (2009), Derwent et al. (1998) and Carter
(2009) in this assertion.

EPA staff asked if all documents cited in the presentation were
available.  Dr. Wallington clarified that all the documents are in the
public domain.  He said that Wallington et al., 2009 has recently been
submitted for publication and is available upon request.  EPA staff
indicated that they would like to see this paper if it is accepted for
publication by a peer-reviewed journal.

Closing Remarks:

The vehicle makers’ opinion is that there are sufficient environmental
data now available for HFO-1234yf SNAP approval and the chemical’s
exemption from VOC restrictions.

Vehicle Makers’ Suggested Rule Modifications

Jim Baker, MAC JAB Consulting

Jim Baker stated that strict interpretation of the proposed rule
effectively prevents the use of HFO-1234yf. As proposed, the rule
mitigates risk to zero and vehicle makers believe the proposed under
hood concentration limits are unachievable.

Summarizing results from the CRP, Jim Baker stated that when the vehicle
is off, HFO-1234yf concentrations do not reach levels of concern and
when the vehicle is on, the non-collision under hood risk is the same as
the risk associated with R-134a because of HF generation.  The exposure
frequency of the HFO-1234yf direct expansion system is also twenty times
lower than that of the R-152a secondary loop, which has been approved by
SNAP. However, HFO-1234yf would not be suitable for a secondary loop
because the loss of efficiency would be prohibitive for this
refrigerant. Exposure frequency of HFO-1234yf is less even if exposure
concentrations are not limited and HF generation is considered. Thus,
exposure to the refrigerant poses a near zero risk. Based on the CRP
risk assessment, no concentration limits are required.

The presenter stated that the proposed rule, as written, creates a
mitigation dilemma. For example, ventilating the cabin or installing
refrigerant discharge devices is required to comply with interior
concentrations limits.  Cabin ventilation could draw in additional
hazardous fumes from non-cabin fires, etc., during and after collision
events in every collision with ventilation—resulting in higher risk
compared to if they do not add ventilation. Currently, not all
collisions release refrigerant. However, with the installation of
directed refrigerant discharge, HFO-1234yf would be released by every
collision—again, resulting in higher risk.

Passenger Compartment

Proposed Rule: Engineering strategies and/or devices must be
incorporated into the system such that leaks into the free space of the
passenger compartment do not result in HFO–1234yf concentrations of
6.2% v/v or above in any part of the free space inside the passenger
compartment for more than 15 seconds.

Comment: Unnecessary based on near zero risks identified in the SAE
Cooperative Research Program’s FTA risk assessment.

Proposal: Vehicle makers shall be responsible for conducting risk
assessments, and implementing appropriate risk mitigation as necessary,
to reduce risk of injury and/or property damage to an acceptable level.
Such risk assessments shall be based upon SAE J1739 (FMEA), or its
equivalent, and kept on file. Risk assessments shall cover all aspects
of vehicle use, including normal use, aging, service, and vehicle
collision.

One automotive representative clarified that “risk to an acceptable
level” can be informally interpreted as “okay to put onto the
market.” Mr. Baker suggested that EPA could consider that an
acceptable level of risk would be equivalent to the level of risk for
HFC-152a.  An acceptable risk can exist when exceeding the LFL for
HFO-1234yf when also considering additional factors.  Mr. Baker noted
that HFO-1234yf has unique flammability characteristics, since it
requires a two-stage ignition.  He stated that it takes approximately
5000 times more energy to ignite HFO-1234yf than for hydrocarbons or
gasoline. The cost to recharge after every collision if using a
refrigerant discharge device, e.g., squib valve, would also need to be
considered, even though this cost is not the main barrier.

Although further alternatives to the proposal were not presented,
automotive representatives suggested using wording that was similar to
wording used in the third use condition for hybrids—specific, but also
flexible. This would also be relevant to the following proposed use
conditions.

Engine Compartment and Vehicle Electric Power Source

Proposed Rule: Engineering strategies and/or devices must be
incorporated into the system such that leaks into the engine compartment
or vehicle electric power source storage areas do not result in
HFO–1234yf concentrations of 6.2% v/v or above for any period of time.

Comment: Unnecessary based on near zero risks identified in the SAE
Cooperative Research Program’s FTA risk assessment. This requirement
is not possible to meet and therefore prevents the use of HFO-1234yf.

Proposal: Vehicle makers shall be responsible for conducting risk
assessments, and implementing appropriate risk mitigation as necessary,
to reduce risk of injury and/or property damage to an acceptable level.
Such risk assessments shall be based upon SAE J1739 (FMEA), or its
equivalent, and kept on file. Risk assessments shall cover all aspects
of vehicle use, including normal use, aging, service, and vehicle
collision.

In response to a question from EPA staff, Mr. Baker also stated that
that engineering controls such as flame retardant on the interior of the
vehicle are not in consideration at the moment, since risks of fire
caused from the refrigerant are nominal.

Exhaust Manifold Surfaces and Hybrid/Electric Vehicle Electric Power
Sources

Proposed Rule: HFO–1234yf MVAC systems must incorporate protective
devices, isolation and/or ventilation techniques in areas where
processes, procedures or upset conditions such as leaks have the
potential to generate HFO–1234yf concentrations at or above 6.2% v/v
in proximity to exhaust manifold surfaces and hybrid/electric vehicle
electric power sources.

Comment: Unnecessary based on near zero risks identified in the SAE
Cooperative Research Program’s FTA risk assessment. This requirement
is not possible to meet and therefore prevents the use of HFO-1234yf.

Proposal: Vehicle makers shall be responsible for conducting risk
assessments, and implementing appropriate risk mitigation as necessary,
to reduce risk of injury and/or property damage to an acceptable level.
Such risk assessments shall be based upon SAE J1739 (FMEA), or its
equivalent, and kept on file. Risk assessments shall cover all aspects
of vehicle use, including normal use, aging, service, and vehicle
collision.

Closing Remarks:

In a response to a statement by one automotive representative about the
risks of gasoline, EPA staff clarified that the SNAP Program’s
statutory authority refers to the overall risks to human health and the
environment when comparing an alternative to ozone depleting substances
to the other available alternatives.

Vehicle makers agree with the proposed requirements for unique fittings,
labeling, high-pressure compressor cutoff switch, failure mode and
effect analysis, as well as the proposed requirement that the
refrigerant be used in new MAC systems only. Vehicle makers would like
to be able to choose HFO-1234yf as an option as soon as possible and
believe that the removal of HFO-1234yf concentration limits from the
rule is necessary for implementation of HFO-1234yf in vehicles.
Additionally, the automotive representatives would like the SAE
standards and CRP risk assessment to be considered in the final rule
making. However, both are not yet published and/or contain CBI
information.  EPA staff responded that they would check with EPA’s
Office of General Counsel for advice.

The acute exposure guideline (AEGL)-2 is the airborne concentration of a
substance above which it is predicted that the general population,
including susceptible individuals, could experience irreversible or
other serious, long-lasting adverse health effects or an impaired
ability to escape. (EPA, 2008)

HFO-1234yf Meeting Summary

Final

December 8, 2009

Page   PAGE  10


[Federal Register Volume 76, Number 145 (Thursday, July 28, 2011)]
[Notices]
[Pages 45303-45308]
[FR Doc No: 2011-19052]

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SECURITIES AND EXCHANGE COMMISSION

[Investment Company Act Release No. 29735; File No. 812-13909]

ING Asia Pacific High Dividend Equity Income Fund, et al.; Notice
of Application

July 21, 2011.
AGENCY: Securities and Exchange Commission (``Commission'').

ACTION: Notice of application under section 6(c) of the Investment
Company

Act of 1940 (``Act'') for an exemption from section 19(b) of the Act
and rule 19b-1 under the Act.

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    Summary of Application: Applicants request an order (``Order'') to
permit certain registered closed-end management investment companies to
make periodic distributions of long-term capital gains with respect to
their outstanding common stock as frequently as monthly in any taxable
year, and as frequently as distributions are specified by or in
accordance with the terms of any outstanding preferred stock that such
investment companies may issue.
    Applicants: ING Asia Pacific High Dividend Equity Income Fund
(``IAE''), ING Emerging Markets High Dividend Equity Fund (``IHD'');
ING Global Advantage and Premium Opportunity Fund (``IGA''); ING Global
Equity Dividend and Premium Opportunity Fund (``IGD''); ING
Infrastructure, Industrials and Materials Fund (``IDE''); ING
International High Dividend Equity Income Fund (``IID''); ING Prime
Rate Trust (``PRT''); ING Risk Managed Natural Resources Fund (``IRR,''
together with IAE, IHD, IGA, IGD, IDE, IID and PRT, the ``Current
Funds''); ING Investments, LLC (``IIL''); ING Investment Management Co.
(``ING IM''); and Directed Services LLC (``DSL'', together with IIL and
ING IM, the ``Investment Advisers'').

DATES: Filing Dates: The application was filed on May 26, 2011, and
amended on July 21, 2011.
    Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on August 15, 2011, and should be accompanied by proof of
service on the applicants in the form of an affidavit or, for lawyers,
a certificate of service. Hearing requests should state the nature of
the writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.

ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090; Applicants, c/o Jeffrey S.
Puretz, Dechert LLP, 1775 I Street, NW., Washington, DC 20006.

FOR FURTHER INFORMATION CONTACT: Laura L. Solomon, Senior Counsel, at
(202) 551-6915, or Daniele Marchesani, Branch Chief, at<PHONE_NUMBER>
(Division of Investment Management, Office of Investment Company
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SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number or an applicant
using the Company name box, at http://www.sec.gov/search/search.htm or
by calling<PHONE_NUMBER>.

Applicants' Representations

    1. Each Current Fund is a registered closed-end management
investment company and is organized as a Delaware statutory trust, with
the exception of PRT (which is organized as a Massachusetts business
trust).\1\ The common shares of the Current Funds are listed on the New
York Stock Exchange. PRT has also issued preferred shares. Each Current
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Applicants believe that investors in the common shares of the Current
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    \1\ Applicants request that any Order issued granting the relief
requested in the application also apply to any registered closed-end
investment company currently advised or to be advised in the future
by IIL, ING IM or DSL (including any successor in interest) or by an
entity controlling, controlled by or under common control (within
the meaning of section 2(a)(9) of the Act) with IIL, ING IM or DSL
(such entities, together with IIL, ING IM and DSL, the ``Investment
Advisers'') that decides in the future to rely on the requested
relief. Any closed-end investment company that relies on the Order
in the future will comply with the terms and conditions of the
application (such investment companies together with the Current
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the Order have been named as Applicants. A successor in interest is
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    2. IIL, an Arizona limited liability company, acts as the Current
Funds' investment adviser. ING IM, a Connecticut corporation, acts as a
sub-adviser to certain of the Current Funds. DSL, a Delaware limited
liability company, is an investment adviser under common control with
IIL and ING IM. Each of IIL, ING IM and DSL is a registered investment
adviser under the Investment Advisers Act of 1940, as amended
(``Advisers Act'') and is an indirect, wholly-owned subsidiary of ING
Groep N.V. (``ING Groep''). ING Groep is a global financial institution
of Dutch origin.\2\ Each future Investment Adviser to a Fund will be
registered under the Advisers Act.
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    \2\ Prior to July 1, 2011, each applicant was able to rely on
the exemptive order granted in the Matter of ING Clarion Real Estate
Income Fund, et al., Investment Co. Act Release Nos. 28329 (Jul. 8,
2008) (notice) and 28352 (Aug. 5, 2008) (order) (``Existing Order'')
to make periodic distributions of long-term capital gains with
respect to the Current Funds' outstanding common stock as frequently
as twelve times each year and as frequently as distributions are
specified in the terms of any outstanding preferred stock. As of
July 1, 2011, due to a restructuring of ING Groep, applicants are no
longer able to rely on the Existing Order.
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    3. Applicants state that, prior to a Fund's implementing a
distribution plan in reliance on the Order, the Board of Trustees (the
``Board'') of the Fund, including a majority of the trustees who are
not ``interested persons,'' of such Fund as defined in section 2(a)(19)
of the Act (the ``Independent Trustees''), shall have requested, and
the Investment Advisers shall have provided, such information as is
reasonably necessary to make an informed determination on whether the
Board should adopt a proposed distribution policy. In particular, the
Board and the Independent Trustees shall have reviewed information
regarding the purpose and terms of a proposed distribution policy, the
likely effects of such policy on such Fund's long-term total return (in
relation to market price and its net asset value per common share
(``NAV'')) and the relationship between such Fund's distribution rate
on its common shares under the policy and such Fund's total return (in
relation to NAV); whether the rate of distribution would exceed such
Fund's expected total return in relation to its NAV; and any
foreseeable material effects of such policy on such Fund's long-term
total return (in relation to market price and NAV). The Independent
Trustees shall also have considered what conflicts of interest the
Investment Advisers and the affiliated persons of the Investment
Advisers and each such Fund might have with respect to the adoption or
implementation of such policy. Applicants state that, only after
considering such information shall the Board, including the Independent
Trustees, of a Fund approve a distribution policy with respect to such
Fund's common shares (the ``Plan'') and in connection with such
approval shall have determined that such Plan is consistent with a
Fund's investment objectives and in the best interests of a Fund's
common shareholders.
    4. Applicants state that the purpose of a Plan would be to permit a
Fund to distribute over the course of each year, through periodic
distributions as nearly equal as practicable and any required special
distributions, an amount closely approximating the total taxable income
of such Fund during such year and, if

so determined by its Board, all or a portion of the returns of capital
paid by portfolio companies to such Fund during such year. It is
anticipated that under the Plan of a Fund, such Fund would distribute
to its respective common shareholders a fixed monthly percentage of the
market price of such Fund's common shares at a particular point in time
or a fixed monthly percentage of NAV at a particular time or a fixed
monthly amount, any of which may be adjusted from time to time. It is
anticipated that under a Plan, the minimum annual distribution rate
with respect to such Fund's common shares would be independent of a
Fund's performance during any particular period but would be expected
to correlate with a Fund's performance over time. Except for
extraordinary distributions and potential increases or decreases in the
final dividend periods in light of a Fund's performance for an entire
calendar year and to enable a Fund to comply with the distribution
requirements of Subchapter M of the Internal Revenue Code (``Code'')
for the fiscal year, it is anticipated that each distribution on the
common shares would be at the stated rate then in effect.
    5. Applicants state that prior to the implementation of a Plan for
a Fund, the Board shall have adopted policies and procedures under rule
38a-1 under the Act that: (i) Are reasonably designed to ensure that
all notices required to be sent to the Fund's shareholders pursuant to
section 19(a) of the Act, rule 19a-1 thereunder and condition 4 below
(each a ``19(a) Notice'') include the disclosure required by rule 19a-1
under the Act and by condition 2(a) below, and that all other written
communications by the Fund or its agents regarding distributions under
the Plan include the disclosure required by condition 3(a) below; and
(ii) require the Fund to keep records that demonstrate its compliance
with all of the conditions of the Order and that are necessary for such
Fund to form the basis for, or demonstrate the calculation of, the
amounts disclosed in its 19(a) Notices.

Applicants' Legal Analysis

    1. Section 19(b) of the Act generally makes it unlawful for any
registered investment company to make long-term capital gains
distributions more than once every twelve months. Rule 19b-1 under the
Act limits the number of capital gains dividends, as defined in section
852(b)(3)(C) of the Code (``distributions''), that a fund may make with
respect to any one taxable year to one, plus a supplemental ``clean
up'' distribution made pursuant to section 855 of the Code not
exceeding 10% of the total amount distributed for the year, plus one
additional capital gain dividend made in whole or in part to avoid the
excise tax under section 4982 of the Code.
    2. Section 6(c) of the Act provides that the Commission may, by
order upon application, conditionally or unconditionally exempt any
person, security, or transaction, or any class or classes of persons,
securities or transactions, from any provision of the Act, if and to
the extent that the exemption is necessary or appropriate in the public
interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
    3. Applicants state that one of the concerns leading to the
enactment of section 19(b) and adoption of rule 19b-1 was that
shareholders might be unable to distinguish between frequent
distributions of capital gains and dividends from investment income.
Applicants state, however, that rule 19a-1 effectively addresses this
concern by requiring that distributions (or the confirmation of the
reinvestment thereof) estimated to be sourced in part from capital
gains or capital be accompanied by a separate statement showing the
sources of the distribution (e.g., estimated net income, net short-term
capital gains, net long-term capital gains and/or return of capital).
Applicants state that similar information is included in the Funds'
annual reports to shareholders and on the Internal Revenue Service Form
1099 DIV, which is sent to each common and preferred shareholder who
received distributions during a particular year.
    4. Applicants further state that each of the Funds will make the
additional disclosures required by the conditions set forth below, and
each of them has adopted compliance policies and procedures in
accordance with rule 38a-1 under the Act to ensure that all required
19(a) Notices and disclosures are sent to shareholders. Applicants
argue that by providing the information required by section 19(a) and
rule 19a-1, and by complying with the procedures adopted under the Plan
and the conditions listed below, each Fund's shareholders would be
provided sufficient information to understand that their periodic
distributions are not tied to a Fund's net investment income and
realized capital gains to date, and may not represent yield or
investment return. Accordingly, Applicants assert that continuing to
subject the Funds to section 19(b) and rule 19b-1 would afford
shareholders no extra protection.
    5. Applicants assert that section 19(b) and rule 19b-1 also were
intended to prevent certain improper sales practices, including, in
particular, the practice of urging an investor to purchase shares of a
fund on the basis of an upcoming capital gains dividend (``selling the
dividend''), where the dividend would result in an immediate
corresponding reduction in NAV and would be in effect a taxable return
of the investor's capital. Applicants assert that the ``selling the
dividend'' concern should not apply to closed-end investment companies,
such as the Funds, which do not continuously distribute shares.
According to the Applicants, if the underlying concern extends to
secondary market purchases of shares of closed-end funds that are
subject to a large upcoming capital gains dividend, adoption of a
periodic distribution plan actually helps minimize the concern by
avoiding, through periodic distributions, any buildup of large end-of-
the-year distributions.
    6. Applicants note that the common stock of closed-end funds
generally tends to trade in the marketplace at a discount to their
NAVs. Applicants believe that this discount may be reduced if the Funds
are permitted to pay relatively frequent dividends on their common
shares at a consistent rate, whether or not those dividends contain an
element of capital gain.
    7. Applicants assert that the application of rule 19b-1 to a Plan
actually gives rise to one of the concerns that rule 19b-1 was intended
to avoid: Inappropriate influence on portfolio management decisions.
Applicants state that, in the absence of an exemption from rule 19b-1,
the adoption of a periodic distribution plan imposes pressure on
management: (i) Not to realize any net long-term capital gains until
the point in the year that the fund can pay all of its remaining
distributions in accordance with rule 19b-1; and (ii) not to realize
any long-term capital gains during any particular year in excess of the
amount of the aggregate pay-out for the year (since as a practical
matter excess gains must be distributed and accordingly would not be
available to satisfy pay-out requirements in following years),
notwithstanding that purely investment considerations might favor
realization of long-term gains at different times or in different
amounts. Applicants assert that by limiting the number of capital gain
distributions that a fund may make with respect to any one year, rule
19b-1 may prevent the normal and efficient operation of a periodic
distribution plan whenever that fund's realized net long-term capital
gains in any year exceed the total

of the periodic distributions that may include such capital gains under
the rule.
    8. In addition, Applicants assert that rule 19b-1 may cause fixed
regular periodic distributions to be funded with returns of capital \3\
(to the extent net investment income and realized short term capital
gains are insufficient to fund the distribution), even though
undistributed realized net long-term capital gains otherwise would be
available. To distribute all of a fund's long-term capital gains within
the limits in rule 19b-1, a fund may be required to make total
distributions in excess of the annual amount called for by its periodic
distribution plan or to retain and pay taxes on the excess amount.
Applicants thus assert that the requested Order would minimize these
anomalous effects of rule 19b-1 by enabling the Funds to realize long-
term capital gains as often as investment considerations dictate
without fear of violating rule 19b-1.
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    \3\ Returns of capital as used in the application means return
of capital for financial accounting purposes and not for tax
accounting purposes.
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    9. Applicants state that Revenue Ruling 89-81 under the Code
requires that a fund that has both common shares and preferred shares
outstanding designate the types of income, e.g., investment income and
capital gains, in the same proportion as the total distributions
distributed to each class for the tax year. To satisfy the
proportionate designation requirements of Revenue Ruling 89-81,
whenever a fund has realized a long-term capital gain with respect to a
given tax year, the fund must designate the required proportionate
share of such capital gain to be included in common and preferred share
dividends. Applicants state that although rule 19b-1 allows a fund some
flexibility with respect to the frequency of capital gains
distributions, a fund might use all of the exceptions available under
rule 19b-1 for a tax year and still need to distribute additional
capital gains allocated to the preferred shares to comply with Revenue
Ruling 89-81.
    10. Applicants assert the potential abuses addressed by section
19(b) and rule 19b-1 do not arise with respect to preferred shares
issued by a closed-end fund. Applicants assert that such distributions
are either fixed, determined in periodic auctions, or determined by
reference to short-term interest rates rather than by reference to
performance of the issuer, and Revenue Ruling 89-81 determines the
proportion of such distributions that are comprised of long-term
capital gains.
    11. Applicants also submit that the ``selling the dividend''
concern is not applicable to preferred shares, which entitles a holder
to no more than a periodic dividend at a fixed rate or the rate
determined by the market, and like a debt security, is priced based
upon its liquidation value, dividend rate, credit quality, and
frequency of payment. Applicants assert that investors buy preferred
shares for the purpose of receiving payments at the frequency bargained
for and do not expect the liquidation value of their shares to change.
    12. Applicants request an order pursuant to section 6(c) of the Act
granting an exemption from the provisions of section 19(b) of the Act
and rule 19b-1 thereunder to permit each Fund to make periodic capital
gain dividends (as defined in section 852(b)(3)(C) of the Code) as
often as monthly in any one taxable year in respect of its common
shares and as often as specified by or determined in accordance with
the terms thereof in respect of the Fund's preferred shares.

Applicants' Conditions

    Applicants agree that, with respect to each Fund seeking to rely on
the Order, the Order will be subject to the following conditions.

1. Compliance Review and Reporting

    The Fund's chief compliance officer will: (a) Report to the Fund's
Board, no less frequently than once every three months or at the next
regularly scheduled quarterly Board meeting, whether: (i) The Fund and
its Investment Adviser have complied with the conditions of the order;
and (ii) a material compliance matter (as defined in rule 38a-1(e)(2)
under the Act) has occurred with respect to such conditions; and (b)
review the adequacy of the policies and procedures adopted by the Board
no less frequently than annually.

2. Disclosures to Fund Shareholders

    (a) Each 19(a) Notice disseminated to the holders of the Fund's
common shares, in addition to the information required by section 19(a)
and rule 19a-1:
    (i) Will provide, in a tabular or graphical format:
    (1) The amount of the distribution, on a per common share basis,
together with the amounts of such distribution amount, on a per common
share basis and as a percentage of such distribution amount, from
estimated: (A) Net investment income; (B) net realized short-term
capital gains; (C) net realized long-term capital gains; and (D) return
of capital or other capital source;
    (2) The fiscal year-to-date cumulative amount of distributions, on
a per common share basis, together with the amounts of such cumulative
amount, on a per common share basis and as a percentage of such
cumulative amount of distributions, from estimated: (A) net investment
income; (B) net realized short-term capital gains; (C) net realized
long-term capital gains; and (D) return of capital or other capital
source;
    (3) The average annual total return in relation to the change in
NAV for the 5-year period (or, if the Fund's history of operations is
less than five years, the time period commencing immediately following
the Fund's first public offering) ending on the last day of the month
ended immediately prior to the most recent distribution record date
compared to the current fiscal period's annualized distribution rate
expressed as a percentage of NAV as of the last day of the month prior
to the most recent distribution record date; and
    (4) The cumulative total return in relation to the change in NAV
from the last completed fiscal year to the last day of the month prior
to the most recent distribution record date compared to the fiscal
year-to-date cumulative distribution rate expressed as a percentage of
NAV as of the last day of the month prior to the most recent
distribution record date.
    Such disclosure shall be made in a type size at least as large and
as prominent as the estimate of the sources of the current
distribution; and
    (ii) Will include the following disclosure:
    (1) ``You should not draw any conclusions about the Fund's
investment performance from the amount of this distribution or from the
terms of the Fund's Plan'';
    (2) ``The Fund estimates that it has distributed more than its
income and net realized capital gains; therefore, a portion of your
distribution may be a return of capital. A return of capital may occur,
for example, when some or all of the money that you invested in the
Fund is paid back to you. A return of capital distribution does not
necessarily reflect the Fund's investment performance and should not be
confused with `yield' or `income' ''; \4\ and
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    \4\ The disclosure in this condition 2(a)(ii)(2) will be
included only if the current distribution or the fiscal year-to-date
cumulative distributions are estimated to include a return of
capital.
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    (3) ``The amounts and sources of distributions reported in this
19(a) Notice are only estimates and are not

being provided for tax reporting purposes. The actual amounts and
sources of the amounts for tax reporting purposes will depend upon the
Fund's investment experience during the remainder of its fiscal year
and may be subject to changes based on tax regulations. The Fund will
send you a Form 1099 DIV for the calendar year that will tell you how
to report these distributions for Federal income tax purposes.''
    Such disclosure shall be made in a type size at least as large as
and as prominent as any other information in the 19(a) Notice and
placed on the same page in close proximity to the amount and the
sources of the distribution.
    (b) On the inside front cover of each report to shareholders under
rule 30e-1 under the Act, the Fund will:
    (i) Describe the terms of the Plan (including the fixed amount or
fixed percentage of the distributions and the frequency of the
distributions);
    (ii) Include the disclosure required by condition 2(a)(ii)(1)
above;
    (iii) State, if applicable, that the Plan provides that the Board
may amend or terminate the Plan at any time without prior notice to
Fund shareholders; and
    (iv) Describe any reasonably foreseeable circumstances that might
cause the Fund to terminate the Plan and any reasonably foreseeable
consequences of such termination; and
    (c) Each report provided to shareholders under rule 30e-1 under the
Act and each prospectus filed with the Commission on Form N-2 under the
Act, will provide the Fund's total return in relation to changes in NAV
in the financial highlights table and in any discussion about the
Fund's total return.

3. Disclosure to Shareholders, Prospective Shareholders and Third
Parties

    (a) The Fund will include the information contained in the relevant
19(a) Notice, including the disclosure required by condition 2(a)(ii)
above, in any written communication (other than a communication on Form
1099) about the Plan or distributions under the Plan by the Fund, or
agents that the Fund has authorized to make such communication on the
Fund's behalf, to any Fund common shareholder, prospective common
shareholder or third-party information provider;
    (b) The Fund will issue, contemporaneously with the issuance of any
19(a) Notice, a press release containing the information in the 19(a)
Notice and will file with the Commission the information contained in
such 19(a) Notice, including the disclosure required by condition
2(a)(ii) above, as an exhibit to its next filed Form N-CSR; and
    (c) The Fund will post prominently a statement on its (or the
Investment Advisers') Web site containing the information in each 19(a)
Notice, including the disclosure required by condition 2(a)(ii) above,
and will maintain such information on such Web site for at least 24
months.

4. Delivery of 19(a) Notices to Beneficial Owners

    If a broker, dealer, bank or other person (``financial
intermediary'') holds common shares issued by the Fund in nominee name,
or otherwise, on behalf of a beneficial owner, the Fund: (a) Will
request that the financial intermediary, or its agent, forward the
19(a) Notice to all beneficial owners of the Fund's shares held through
such financial intermediary; (b) will provide, in a timely manner, to
the financial intermediary, or its agent, enough copies of the 19(a)
Notice assembled in the form and at the place that the financial
intermediary, or its agent, reasonably requests to facilitate the
financial intermediary's sending of the 19(a) Notice to each beneficial
owner of the Fund's shares; and (c) upon the request of any financial
intermediary, or its agent, that receives copies of the 19(a) Notice,
will pay the financial intermediary, or its agent, the reasonable
expenses of sending the 19(a) Notice to such beneficial owners.

5. Additional Board Determinations for Funds Whose Shares Trade at a
Premium

    If:
    (a) The Fund's common shares have traded on the stock exchange that
they primarily trade on at the time in question at an average premium
to NAV equal to or greater than 10%, as determined on the basis of the
average of the discount or premium to NAV of the Fund's common shares
as of the close of each trading day over a 12-week rolling period (each
such 12-week rolling period ending on the last trading day of each
week); and
    (b) The Fund's annualized distribution rate for such 12-week
rolling period, expressed as a percentage of NAV as of the ending date
of such 12-week rolling period, is greater than the Fund's average
annual total return in relation to the change in NAV over the 2-year
period ending on the last day of such 12-week rolling period; then:
    (i) At the earlier of the next regularly scheduled meeting or
within four months of the last day of such 12-week rolling period, the
Board, including a majority of the Independent Trustees:
    (1) Will request and evaluate, and the Fund's Investment Advisers
will furnish, such information as may be reasonably necessary to make
an informed determination of whether the Plan should be continued or
continued after amendment;
    (2) Will determine whether continuation, or continuation after
amendment, of the Plan is consistent with the Fund's investment
objective(s) and policies and in the best interests of the Fund and its
shareholders, after considering the information in condition 5(b)(i)(1)
above, including, without limitation:
    (A) Whether the Plan is accomplishing its purpose(s);
    (B) The reasonably foreseeable material effects of the Plan on the
Fund's long-term total return in relation to the market price and NAV
of the Fund's common shares; and
    (C) The Fund's current distribution rate, as described in condition
5(b) above, compared with the Fund's average annual taxable income or
total return over the 2-year period, as described in condition 5(b), or
such longer period as the Board deems appropriate; and
    (3) Based upon that determination, will approve or disapprove the
continuation, or continuation after amendment, of the Plan; and
    (ii) The Board will record the information considered by it,
including its consideration of the factors listed in condition
5(b)(i)(2) above, and the basis for its approval or disapproval of the
continuation, or continuation after amendment, of the Plan in its
meeting minutes, which must be made and preserved for a period of not
less than six years from the date of such meeting, the first two years
in an easily accessible place.

6. Public Offerings

    The Fund will not make a public offering of the Fund's common
shares other than:
    (a) A rights offering below NAV to holders of the Fund's common
shares;
    (b) An offering in connection with a dividend reinvestment plan,
merger, consolidation, acquisition, spin-off or reorganization of the
Fund; or
    (c) An offering other than an offering described in conditions 6(a)
and 6(b) above, provided that, with respect to such other offering:
    (i) The Fund's annualized distribution rate for the six months
ending on the last day of the month ended immediately prior to the most
recent

distribution record date,\5\ expressed as a percentage of NAV as of
such date, is no more than 1 percentage point greater than the Fund's
average annual total return for the 5-year period ending on such
date,\6\ and
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    \5\ If the Fund has been in operation fewer than six months, the
measured period will begin immediately following the Fund's first
public offering.
    \6\ If the Fund has been in operation fewer than five years, the
measured period will begin immediately following the Fund's first
public offering.
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    (ii) The transmittal letter accompanying any registration statement
filed with the Commission in connection with such offering discloses
that the Fund has received an order under section 19(b) to permit it to
make periodic distributions of long-term capital gains with respect to
its common shares as frequently as twelve times each year, and as
frequently as distributions are specified by or determined in
accordance with the terms of any outstanding preferred shares as such
Fund may issue.

7. Amendments to Rule 19b-1

    The requested order will expire on the effective date of any
amendment to rule 19b-1 that provides relief permitting certain closed-
end investment companies to make periodic distributions of long-term
capital gains with respect to their outstanding common shares as
frequently as twelve times each year.

    For the Commission, by the Division of Investment Management,
under delegated authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011-19052 Filed 7-27-11; 8:45 am]
BILLING CODE 8011-01-P