A comparative of study of the provisions assignment of proceeds at the standby letter of credit and UCC.
Another form of transport is credit proceeds transfer. It happens when the seller is the manufacturer but there is a need to provide raw materials or he is responsible for part of production or he is assembling goods by providing sub-goods. In all other cases, it is not cost effective that the seller transfers all the credit to the third party but, after setting the assignment document, the seller gives the third party the profit commitment after the final production and supply as a guarantee. This commitment is a guarantee for the third party. Unlike the credit transfer, the mediator role is stronger in this method and the seller makes a profit far more than transfer credit by applying value added. So they both are transfer ways and should not be confused. The present paper tries to explain the differences, express their features and characteristics and finally compare existing regulations in guaranteed letters of credits and UCC. First, some important terms are defined which are needed throughout the study for understanding materials.
A Different Alteration & Assignment:
Alteration is a mechanism in which an individual transfers all of his obligations and interests to the third party under a contract. In the Alteration, the third party successfully replaces the original one (committed one) as a contracting party and the original one is no longer the commitment subject. Furthermore, when a contract is transferred, the parties must remain in the same situation before the transferor turns his commitment. But in the proceeds assignment, the parties do not change and the contract privacy still exists between the original parties, and the third-party consent is not necessary for assignment .Therefore assignment differs from Alteration in that the parties do not change.
A Different Subrogation & Assignment:
In Subrogation or proxy, an individual replaces with the other and undertakes his rights in a law suit for financial damage to the extent that the other can prove it. In contrast, assignment is the official transfer of property or proprietary rights . This means that in the Subrogation, the right principle is in charge of another person like a lawyer who will take over all the right the client possesses for his financial compensation. But in the assignment, the assignor reserves the right principle or credit, and the contract between the original parties do not change but its benefits are assigned.
A Different Transfer & Assignment:
Credit is considered as part of the creditor's property. In accordance with the principle of transmissibility of financial rights, credit is assignable to the other. However, according to the rule that "nobody can transfer to other people more than what he has ," upon assigning the credit, it is transferred with all the associated flaws and errors to transferee .Both transfer and assignment are usually used together for one thing. For example, (a) wants to transfer and assign all of his assets and responsibilities under a contract. Although the term transfer is the ordinary word for transferring something to the other, it is used in the law in conjunction with responsibilities, liabilities, amounts due, commitments and penalties. While the term assignment is used for assets, properties, receipts, interests, rights and benefits. So when it is said that someone wants to transfer and assign his/her assets and responsibilities, it really means that he/she wants to assign assets and transfer responsibilities . In other words, assignment is considered as the displacement of negative assets and transfer is considered as the displacement of positive assets.
Assignment and transfer of proprietary rights is the right or benefits under an agreement against certain persons. Whether a benefit transfer is considered assignment depends on the assignor's intent. So assignment is different from other forms of transfer such as commitment conversion or substitution . In the credit transfer, the transferee is the beneficiary's successor and he will not only own the beneficiary's rights but also the conditions for realizing those rights should be met by the transferee. For example, the transferee delivers the commercial cheque and list signed by him to the opener in order to implement the terms of a credit. However, the individual to whom the credit benefits are assigned is not responsible for the implementation of such terms and conditions and only acts to withdraw the credit amount upon presentation of documents in accordance with letters of credit by the beneficiary. Unlike the letter of credit assignment, in the proceeds assignment under credit, the third party is not allowed to request for payment under the credit .The proceeds assignment of the letter of credit is the transfer of future liabilities payable based on the letter of credit from the beneficiary to another person, i.e. assignee which enables him to receive the credit instead of the beneficiary according to the letter of credit. The proceeds assignment does not transfer the right to cheque issuance or implementation according to the letter of credit. The cheque must be issued in the name of the beneficiary. Although the right to receive proceeds is assigned to the assignee, when the letter of credit is transferred to the transferee, the right of cheque issuance or implementation is also transferred according to the letter of credit. The transfer of the letter of credit to the second beneficiary (i.e. transferee) allows presenting the following documents of the letter of credit and therefore its payment. Thus, the role of assignee under assignment is relatively passive (due to the beneficiary) because to the extent that payment of the letter of credit is important, the assignee must wait until the proceeds of the letter of credit appear. However, the transferee may have an active role in issuing the letter of credit .
Credit transfer has business objectives that are different from the assignment of credit proceeds. When a credit is transferred, the second beneficiary becomes the successor of the first beneficiary; so he will be entitled to and should perform the duties of the first beneficiary but he must do so using his shipping documents not the first beneficiary'. Such a credit is used when the seller (the first beneficiary) is not the manufacturer or supplier of goods. In fact, products are provided by someone other than the seller. In such cases, the transferable credit is set in a way that prevents from contract conclusion between the main supplier and the buyer. In other words, it prevents the buyer from making orders directly to the supplier and bypassing the seller as the intermediary. Moreover, the transferrable letter of credit is different from negotiable  letter of credit. Although the letter of credit is not inherently transferable, the cheques issued pursuant to it are transferable .
Assignment Of Proceeds In Standby Letter Of Credit (Isp98):
In international regulations of guarantee letters, provisions 6-06 to 6-10 are related to the review of proceeds assignment regulations. These regulations will enter into force when the designated person or issuer is requested to declare the acceptance of payment of all or part of proceeds to the transferee based on the beneficiary's request. This is achieved when no another law is applicable. The ISP regulations show that bank approval is required for the proceeds assignment, and without such confirmation, the bank is not committed to implement such an assignment. Approval requirements are conducted in order to clarify its legal position and this is particularly important where another bank is used as the place of payment and the difference now is that what is the governing law? The law of the place of the issuer bank or the law of residence? This relationship is included in provision 6-04 (b) of ISP  regulations .
It should be explained that as soon as the issuer bank or any other authorized bank acts to transfer proceeds to the third party, the bank will notify that the beneficiary issued an irreversible order and pursuant to this order, banks will allow the payment in part or whole. The transferee beneficiary may issue an proceeds assignment and request the bank to confirm the assignment.
The issuer bank, designated bank or any other authorized person who acts on the basis of the guarantee letter will not be committed to assign proceeds on behalf of the beneficiary and will be at liberty to accept or reject it (if accepted, it will be sent to the beneficiary in the form of letters, emails, telex or swift messages).The question here is that when the beneficiary accepts the proceeds assignment, is any right made for the transferee beneficiary on the guarantee letter? And that if the guarantee letter is revised or revoked, what effect it will have on this assignment. Clause 6-07 (b) (I) states in this context that such a right will be imaginable for the transferee beneficiary and the related rights can be affected by revising or revoking the guarantee letter. Therefore, these rights can be subject to change or cancellation, unless some conditions are included in the assignment or approval that predicts something else. Thus, the beneficiary orders for the designated bank or issuer, as the case may be reversible or irreversible. In current procedure, banks rarely approve reversible proceeds assignment and in most cases, they require the beneficiary to confirm the reversible proceeds. When the proceeds assignment is approved, the designated or issuer bank is obliged to do the obligation under the terms of the assignment or approval pursuant to the guarantee letter. Meanwhile, the rights for transferee beneficiary will depend on the net proceeds payable to the original beneficiary, the rights of the designated parties and transferee beneficiaries, the rights of other transferees and beneficiaries with priority .With regard to the operational risk of transactions; the designated person or issuer should think measures to mitigate such risks. In this regard, the acceptance of proceeds assignment is subject to the following actions:
1. Submission of the principle guarantee letter for investigation; with a consideration of existing guarantee letter, previous notices, specific orders, canceled items and any previous actions taken in connection with the guarantee letter are revealed.
2. The verification of the signature of the person signing on behalf of the beneficiary. This is important because the payment is made to the third party (transferee) who is unknown to the bank.
3. Setting restrictions for the person signing on behalf of the beneficiary.
4. The request for irreversibility of the acceptance of assignment which is usually provided for the transferee beneficiary in the form of a prepared form containing notices, guarantees, compensation method and other conditions that can be in a form preferred by the designated person or issuer .
Different claims may occur about each of the above items between the main beneficiary and the transferee beneficiary. In such a case, the beneficiary requests for a temporary order for prohibiting the payment of proceeds to the transferee, until the discrepancy is clarified and the final payment will be suspended .
The designated person or issuer who makes payments pursuant to the assignment of accepted proceeds, in line with verifying the signature of the person signing instead of the beneficiary and also approving the representation of the personating instead of the beneficiary is like the payment made to the beneficiary and will require him to compensate. So, the designated person or issuer is required to investigate and certify the guarantee letter and review the beneficiary's signature. Otherwise, if any money is paid to the beneficiary, he will be faced with the risk of repeated payment.
Another issue in proceeds transfer is the succession of the transferee beneficiary; thus heirs, legal representative, liquidator, trustee, proctor or similar persons become successors for the transferee beneficiary. If they present documents for the payment of proceeds to the designated person or issuer, the ISP regulations in clauses 611recognizethe right for these people to receive it. In such cases, courts order the bank to pay the money. Additionally, the payment order can be due to cases that the aforementioned parties such as the transferee beneficiary are authorized to withdraw the guarantee letter.
The designated person or issuer who receives quite consistent documents from the successor of the claimant can make payment subject to the submission of legal documents, including legal commenting, obtaining an additional document in case of withdrawal in the name of the successor from a public body, obtaining guarantee for compensation and the payment of outstanding costs associated with decision making.
Needless to mention that about the suspension of commitments upon submission of documents by the successor, above orders will apply regardless of the maturity of guarantee letter. So, even if the requested documents are asked after the expiration date, this submission will create no difference and the bank is obliged to accept it because such documents are not necessarily part of the original guarantee letter.
Assignability Of Letter Of Credit Proceeds In Ucc:
When the UCC was obligated, using letter of credit as a means of payment in commercial transactions was a reasonable assumption. Letter of credit was used for paying among good merchants in different cities in the past. According to the old usage of letter of credit as a means of payment in trading goods, there was no reason for the buyer to have the permission to control the seller's measures on revenues of letter of credit. But in recent decades, the use of letter of credit has expanded rapidly in all fields of commercial activity, because letter of credit is a simple solution for a common problem in all fields of commercial activity. Letter of credit is a solution for reduction in risks of commercial activities among people, especially risks associated with trusting each other in these activities in order to compel the beneficiary to perform the respective affairs. The Account party must provide an acceptable guarantee for the beneficiary to pay a certain sum to him/her in the occurrence of specific terms. The account party is willing to perform the payment operation, but the sum will be paid through the guarantee only in the occurrence of the respective terms. Bank is willing to be a shareholder in exchange for fee. However, if the bank is required to perform banking functions, the bank's role will be influenced by Principle of independence in performing the functions. A principle by which the issuing bank will be obligate to pay to the beneficiary, only if the terms of the letter of credit is provided . For example, in a sales transaction when letter of credit setting requires providing a specific waybill, (1) it makes sure the seller be paid immediately upon delivery; (2) it makes sure that the buyer will not pay until the goods delivery; and (3) it compels the bank to check the provided documents solely in order to approve their accordance with specific requirements, however it does not force them to inspect the goods or control the cargo.
1--Pursuant to section (2) 5-116 UCC  Regulation, letter of credit beneficiary can relegate his/her rights of Revenues obtained from letter of credit, even if this assignment is expressly prohibited in the letter of credit.
2--Assignment of revenues may be proper, if using letters of credit is for financing sales transactions, but the terms stipulated in section (2) 5-116 cannot be cited, because of generalizing letter of some applications credit to many fields of commercial activity. Considering applications of letter of credit, preventing from the assignment of revenues leads to valid and significant benefits for the account party. For example, revenues may actually have been considered for a specific purpose which could lead to the detriment of the other party, if it does not realize. The purpose of the principle of Assignment necessity is not to protect the parties against unfair or unequal rules. So making it changeable will not lead to permanent approaches. Moreover, due to the increasing of the transaction costs and their complexity, letter of credit may actually become Non-Transferable through modifying the terms of the contract. If we provide non-transferability, by changing the rule from an unchangeable principle to a deniable presumption, against the transferability, it also will lead to increasing the letter of credit efficiency, maintaining its ease and flexibility, and yet maintain its role in providing commercial investment.
3--Pursuant to section 5-116, the principle governing the assignment of transfer right of the letter of credit is called "transferability" and the principle governing the assignment of the right of receiving the revenues of letter of credit is called "assignability ". The right of transferring letter of credit may be transferred. (It means that the letter of credit is "transferable"), and it is only in the case of "a transferable document" is explicitly mentioned in the letter of credit, but the right of receiving the current revenues of letter of credit may be assigned (letter of credit is "assignable"), even if it is explicitly mentioned in the letter of credit that it is nontransferable or non-assignable, but letter of credit parties don't pay attention to the issue explicitly, former principle would be a deniable presumption against transferability, and the law assumes that they meant the letter of credit is non-transferable . Thus, the rule governing Assignment is not inconsistent with the rule governing the transferability, but it is located in the other side of the spectrum.
The aim of UCC rule in relation to assign ability is to guarantee this issue, so that merchants could take advantage of it as a pledge for providing their financial needs in business activities. On the other hand, UCC rules governing transferability and assign ability of the letter of credit acts in such a way that obtaining a letter of credit is like performing a contract, in which the other party takes considerable advantage by leaving the responsibility (of the implementation of required measures stipulated in the contract or their monitoring) to its main guarantor (like performance of a contract, in which one of the parties "trust" to the other party). Deniable legal presumption supports a bank against transferability, so that the bank will not have to trust and rely on others for performing a transaction, but it relies on a beneficiary party who trusts the bank. This is one of the matters of concerns in the common law which is stating that an exporter should not trust on anyone other than the person whose name is mentioned in the credit. Credit operations are typically contingent on submitting documents, and fabricating false documents are also easily done. Courts have assumed that an exporter who is obligated to pay for documents which are easy to counterfeit, has trust the mentioned beneficiary's honesty and veracity. Credit operations would be realized by restricting the transfer of documents which are easy to counterfeit. Section 5-116 of the Codex and Article 46 of the Uniform Regulation of letters of credit has restricted the transferring the right of letter of credit setting.  The aim of the regulators of UCC regulation draft was to establish a law by which they consider assignability in order to guarantee the beneficiary's ability of using letters of credit as a pledge, and also the ability of assignment of income facilitates the use of "reinsurance" letters of credit. In a way that, the beneficiary assigns the letter of credit to a bank as a pledge to issue a secondary letter of credit. When the seller is the beneficiary of the letter of credit, he/she can use it as a pledge to in favor of account party seller(for example the producer of raw materials of a product). This letter of credit, like the primary letter of credit, facilitates the sale of goods.
4--this point that "whether the assignment of income as a pledge for the issuance of another letter of credit for guaranteeing the feasibility of using letter of credit is enough or not?" is a questionable point. While cash or securities are used as a pledge, banks typically draw up the contract in a way that they have the right of receiving the value of that pledge for the payment of the debt, without the consent of the debtor. For example, if the loan is guaranteed by putting securities as a pledge, securities which don't have the name of the beneficiary could be executed easily. However if the beneficiary of the primary letter of credit, despite the assignment of revenues, has the right to withdraw the letter of credit, he/she may has incentives to refuse to withdraw letter of credit, such as a disagreement with the lender or an unwillingness to obligate the account party to repay the money to the bank. Moreover, the bank may also rely on the beneficiary for providing documents which are formed only after issuing the letter of credit, like the bill of lading. Therefore the bank must issue such a credit only for its reliable clients . Moreover the use of letter of credit as a pledge is beyond the UCC regulation, because bankruptcy can cause the use of primary letter of credit as a pledge is regarded as a doubtable issue, and put the main letter of credit under the question. In the case of Farmer vs. National Bank of crack (Crocker National Bank 70 Farmer (of Swift airlines) Court--according to the history of the legislation--believes that when the beneficiary is insolvent, letter of credit is virtually unenforceable as a recovery contract, and pursuant to section 365 of the Bankruptcy Act, it will be canceled and virtually out the benefit. The place of its letter of credit would be debatable. However until the explicit change in that aspect of bankruptcy law, a letter of credit which is under the support of another letter of credit can be converted to a letter of credit which is supported only by a claim with no pledge in bankruptcy. Finally, the law which says that the assignability is obligatory, cannot guarantees the assignability of the letter of credit as a pledge, because we are allowed to not to practice the regulation. As it will be discussed in the next section, parties in a transaction of the letter of credit can arrange a plan about this law. Due to the fact that regulating of a letter of credit is required to comply with the documentary terms requirements and not just contract execution, the parties can determine the documentary terms in a way that virtually prevent the assignment; although such a plan is likely to bring additional costs. Official comments of Legal Information Institute (Cornell, the Faculty of Law), in connection with the assignment of revenues in UCC, section (b), considers assignment of the revenues of the letter of credit explicitly reliable, if it is created after forming the credit. However, the revenues must be realized before forming the credit. This is adopted due to the large usage and the current approach in assignment of to the revenue to the assignee. Assignment of revenues contains no right related to the main letter of credit for the assignee, and assignee earns no benefit until the revenue is paid by the issuer.
5--The assignees right in performing the assignment of the revenue in front of the issuer, and the priority of the assignees right the in front of the designated person or the beneficiary of transferee has been addressed in Article 5. The right of assignment and priority are also discussed in paragraph (c), (d), and (e).it should also be noted that the Section 4-210 gives the first priority right in receiving revenue of the letter of credit to the bank receiving the payment.
6--Consent of the issuer or the designated person in assignment of revenues of the letter of credit in paragraphs (c) and (d) is of great importance in the domestic and international documentary credits. In many situations acquiring the issuers consent is always it is always recommended, in order to better guaranteeing the rights of the revenue for the assignee. The "Royal Council" in a research in Singapore voted that the satisfaction of bank "should be an explicit consent which is made after the request (transfer), and it should include both the limitations and the manner of transferring the request". This means that calling credit as a transferable credit during opening the credit, the banks consent is not enough. When notification of assignment is received, normally the issuer is required to sign a consent form. This is a reflection of a revision in the UCC, which is in paragraph "c" and "d" with designating the necessity of consent of the issuer, and the person designated to assign the revenue of the letter of credit, and it has some innovations in comparison with the previous regulations and national and international procedures. With unconditional consent of assignment, the issuer or the designated person is obligate to respect the rights of the parties. Paragraph "d" in this regard has stated that in such circumstances the issuer or the designated person cannot refuse the consent to the revenues assignment unreasonably. It has been said that if the assignee captures the letter of credit and submit it, the issuer have to bring reason for not identifying this assignment, otherwise he/she can refuse identifying the assignment of revenue even without any reason. The reason is that in section "D", paragraph 114-5, not providing the letter of credit by the assignee is an enough reason for not identifying this assignment as a valid assignment, and in the case of performing this provision, the necessity of having reason for the rejection of this assignment will be discussed .
7--Despite of performing requirements by the beneficiary, if the issuer of the credit refuses to identify transferring of the credit, or without considering any conditions that the beneficiary or the transferee does not attempt to perform it, and they refuse to accept the transfer request, according to paragraph 5-111 "g" " if ... the issuer violates the obligation which is included in section "A" or "B", the person who faces this obligation could receive compensation of damages caused from this violation, including direct damages, and not subordinate damages ...". If the section "A" and "B" of this paragraph was studied, acceptance of payment and refusal of the inadmissible payment is performed by the issuer; therefore failure to fulfill the obligation of transferring the credit is included in this section . It is also necessary to note that in the case of assignment of the revenue, if bank refused to accept it, it seems that it also would be included in the sentence above.
Counclutions & Suggestion:
This paper tries to review the proceeds assignment process in the banking regulations as well as the usual method, conditions and requirements of assignment. It also answers some common questions in this area. Finally, it presents banking regulations in UCC and ISP98, the assignment area and the effectiveness comparison. We conclude that assignment and transfer are two different concepts with different applications. There is criticism that the letter of credit related books overlook the proceeds assignment issue and mostly discuss it below the transfer issue. So, they do not make its place clear and confuse readers. Therefore, this paper attempts to explain it and leave no ambiguity. According to the newness of proceeds transfer issue, it is necessary to pay attention to it. Therefore, it is required to prepare books for interpreting these laws comprehensively considering the position and rules as soon as possible because there is no comprehensive book on the interpretation of the provisions of the letters of credit. Obviously, detailed knowledge of these rules can prevent fraud in letters of credit and business development. The simple form of credit transfer in international trade transactions is the letter of credit transfer. Since all suppliers or sellers are not manufacturer and are the mediate factor for most transactions, the credit transfer requests goods from the seller mediated by the seller as the main beneficiary following the request of the buyer or manufacturer or the main supplier or the related third party. But usually the third party requests for guaranteed purchasing. At this time, the seller may have not the time or power to establish a new account for the third party. So, the seller transfers to third party the credit requested from the buyer as guarantee, and the third party replaces the seller after delivery of goods. However, both the third party and the seller set a list for themselves and the seller sets a higher amount in his list and withdraws the difference between his list and the third party's list as profit.
[3.] Nemo dat qui non habet
[4.] Nikbakht, H. Bana, Niyasar, Mashalah, 2011. A study on the concepts, terms, works, and legal nature of "credit transaction", Journal of Legal Studies, School of Law, Martyr Beheshti University, 5:380.
[5.] www.buray.net/2012/08/difference between transfer and assignment. html.
[7.] Reinhard Langrich, 2011. Translated by S. Hassani, Letter of Credit in International Trade Law, Tehran, Mizan Press, Second Edition, Spring, p: 300.
[8.] http://www.internationallawoffice.com/newslett ers/Detail.aspx?g=c5aa4918-15f2-4890-ba28 ff973fd570f4.
[9.] Heshmatallah Samavati, 2010. Law of international transactions, Tehran, Phoenix Publishing, Fourth Edition, p: 125.
[10.] In this type of credit, the beneficiary can issue the cheque to the opener, endorse it in the name of another person and deliver it along with documents required pursuant that credit, so that he/she can submit documents to the opener and receive funds.(Sarna-Lazar: "letter of credit, The Law And Current Practice",Carswall, 1989: 7-9.
[11.] arnsworth- E.allan, Honnold- john, 1975. "Commercial law, Cases And Materials", University Case Book Series, p:355.
[12.] www.standardbank.co.za,documentray credit, p: 2.
[13.] About the effect of transfer of the requested documents, Clause 2 in Article 6-04 reads: "The name of the transferee beneficiary can be used instead of the name of the transferor in each of the other documents requested.
[14.] The term transferee beneficiary is a term used in clause 1.11(c) (ii) of the ISP regulation which reads: "beneficiary includes a person to whom the right to withdraw is transferred by the designated beneficiary applicably (transferee beneficiary).
[15.] International standby practice (ISP98) Report of The Secretary-Genera, (A/CN.9/477.
[16.] Additional conditions often observed and set in forms are as follows:1. Reviewing the done withdrawals if the guarantee letter allows frequent withdrawals. 2. Full name, legal form, location and mailing address of the beneficiary and transferee. 3. Details of each request affecting the payment or delivery of the income of guarantee letter. 4. Making constraints for assignment by an amount less than the total amount and subsequent assignments. 5. Declaring comments related to the legal priority of assignment and 6.The right to recover any amount of income received by the transferee from the beneficiary which is receivable by the designated person or issuer.
[17.] Clause 6-09, ISP regulations.
[18.] Credits are essentially separated from sales contracts and other contracts on which they are based, and banks are not in any way related to them or do something along those contracts. Even if any reference to those contracts contains credits.
[19.] Unsolicited Commercial Communications
[20.] Therefore, this Act is similar to UCP rules, in the part of revocability of the contract, under which a letter of credit is revocable unless it is explicitly stipulated that it is irrevocable. See clause (C) 8 UCP. Act UCC monitors this crucial ingredient.
[21.] To verify the criticisms about the analogy upon the presenting documents for implementation, and also separating the right of Drawing Up from the right receiving revenue refer to the paper Ellinger; Eberth as "assigning and presenting documents of transfer and commercial-credit transactions", 1982. 24 Ariz. L. Rev., 285: 295-299.
[22.] Another problem upon reinsurance credit arrangements is that the bank issued the secondary letter of credit must guarantee that amendments related to primary letter of credit, which interfere the ability of its setting, will not be made.
[23.] Kashani Zadeh, Hoda, comparative study of obligations of beneficiary and issuer of documentary credit against each other in The Uniform Customs and Practice for Documentary Credits (UCP600) and Article 5 of the Uniform Commercial Code of the United States of America (UCC), Journal of International Law, the Journal of the affairs Centre of International Law, Legal Assistance of presidential parliamentary affairs 26th year, 40: 314-344.
(1) Ghafour Khoeini, (2) Hossein Ghorbanian
(1) Associate professor, Law Department, University of Kharazmi
(2) Ph.D. student, Jurisprudence & Private Law, University of Kharazmi
Hossein Ghorbanian, PhD student Award Islamic Jurisprudence And Private Law Kharazmi University
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|Title Annotation:||Original Article|
|Author:||Khoeini, Ghafour; Ghorbanian, Hossein|
|Publication:||Advances in Environmental Biology|
|Date:||Jun 1, 2013|
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