Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
CUCURBITS
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
cucurbits,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
nomination,
includes
general
background
information
that
the
U.
S.
believes
is
critical
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
cucurbits
follows.

2.
Background
In
1997,
the
Parties
to
the
Montreal
Protocol
adjusted
Article
2H
of
the
Protocol,
and
agreed
to
accelerate
the
reduction
in
the
controlled
production
and
consumption
of
methyl
bromide.
This
adjustment
included
a
provision
calling
for
a
phaseout
of
methyl
bromide
by
the
year
2005
"
save
to
the
extent
that
the
Parties
decide
to
permit
the
level
of
production
or
consumption
that
is
necessary
to
satisfy
uses
agreed
by
them
to
be
critical
uses."
At
the
same
time,
the
Parties
adopted
decision
IX/
6,
the
critical
use
exemption
decision,
which
laid
out
the
terms
under
which
critical
use
exemptions
under
Article
2H
would
be
granted.

3.
Criteria
for
Critical
Uses
Under
the
Montreal
Protocol
In
crafting
Decision
IX/
6
outlining
the
criteria
for
a
critical
use
exemption,
the
Parties
recognized
the
significant
differences
between
methyl
bromide
uses
and
uses
of
other
ozone­
depleting
chemicals
previously
given
scrutiny
under
the
Protocol's
distinct
and
separate
Essential
Use
exemption
process.
The
United
States
believes
that
it
is
vitally
important
for
the
MBTOC
to
take
into
account
the
significant
differences
between
the
critical
use
exemption
and
the
essential
use
exemption
in
the
review
of
all
methyl
bromide
critical
use
nominations.

During
the
debate
leading
up
to
the
adoption
of
the
critical
use
exemption
Decision
IX/
6,
an
underlying
theme
voiced
by
many
countries
was
that
the
Parties
wanted
to
phase
out
methyl
bromide,
and
not
agriculture.
This
theme
was
given
life
in
various
provisions
of
the
critical
use
exemption,
and
in
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption.
Those
differences
are
outlined
below.

The
Protocol's
negotiated
criteria
for
the
critical
use
exemptions
for
methyl
bromide
are
much
different
from
the
criteria
negotiated
for
"
essential
uses"
for
other
chemicals.
Page
2
Under
the
Essential
Use
provisions,
in
order
to
even
be
considered
for
an
exemption,
it
was
necessary
for
each
proposed
use
to
be
"
critical
for
health,
safety
or
the
functioning
of
society."
This
high
threshold
differs
significantly
from
the
criteria
established
for
the
methyl
bromide
Critical
Use
exemption.
Indeed,
for
methyl
bromide,
the
Parties
left
it
solely
to
the
nominating
governments
to
find
that
the
absence
of
methyl
bromide
would
create
a
significant
market
disruption.

For
the
U.
S.
nomination
for
cucurbits,
following
detailed
technical
and
economic
review,
the
U.
S.
has
determined
that
the
level
of
methyl
bromide
being
requested
is
critical
to
ensuring
that
there
is
no
significant
market
disruption.
The
detailed
analysis
of
technical
and
economic
viability
of
the
alternatives
listed
by
MBTOC
for
use
in
growing
cucurbits
is
discussed
later
in
this
nomination.

In
the
case
of
methyl
bromide,
the
Parties
recognized
many
agricultural
fumigants
were
inherently
toxic,
and
therefore
there
was
a
strong
desire
not
to
replace
one
environmentally
problematic
chemical
with
another
even
more
damaging.

The
critical
use
exemption
language
explicitly
requires
that
an
alternative
should
not
only
be
technically
and
economically
feasible,
it
must
also
be
acceptable
from
the
standpoint
of
health
and
environment.
This
is
particularly
important
given
the
fact
that
most
chemical
alternatives
to
methyl
bromide
are
toxic,
and
some
pay
pose
risks
to
human
health
or
the
environment
that
are
even
greater
than
the
threats
posed
by
methyl
bromide.

In
the
case
of
methyl
bromide,
the
Parties
recognized
that
evaluating,
commercializing
and
securing
national
approval
of
alternatives
and
substitutes
is
a
lengthy
process.

In
fact,
even
after
an
alternative
is
tested
and
found
to
work
against
some
pests
in
a
controlled
setting,
adequate
testing
in
large­
scale
commercial
operations
can
take
many
cropping
seasons
before
the
viability
of
the
alternative
can
be
adequately
assessed
from
the
standpoint
of
the
climate
and
soil
for
various
potential
users.
In
addition,
the
process
of
securing
national
and
sub­
national
approval
of
alternatives
may
require
extensive
analysis
of
environmental
consequences
and
toxicology.
The
average
time
for
the
national
review
of
scientific
information
in
support
of
a
new
pesticide,
starting
from
the
date
of
submission
to
registration,
is
approximately
38
months.
In
most
cases,
the
company
submitting
the
information
has
spent
approximately
7­
10
years
developing
the
toxicity
and
other
environmental
data
necessary
to
support
the
registration
application.

The
Parties
to
the
Protocol
recognized
that
unlike
other
chemicals
controlled
under
the
Montreal
Protocol,
the
use
of
methyl
bromide
and
available
alternatives
could
be
site
specific
and
must
take
into
account
the
particular
needs
of
the
user.

The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
Page
3
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
understand
the
unique
nature
of
U.
S.
agriculture,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
methyl
bromide.

4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Cucurbits
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
initiated
open
meetings
with
stakeholders
both
to
inform
them
of
the
Protocol
requirements,
and
to
understand
the
issues
being
faced
in
researching
alternatives
to
methyl
bromide.
During
those
meetings,
which
were
attended
by
State
and
association
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
U.
S.
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11
which
calls
for
specific
information
to
be
presented
in
the
nomination.

Upon
return
from
the
Sri
Lanka
meeting
of
the
Parties,
the
U.
S.
took
a
three
track
approach
to
the
critical
use
process.
First,
we
worked
to
develop
a
national
application
form
that
would
ensure
that
we
had
the
information
necessary
to
answer
all
of
the
questions
posed
in
decision
XIII/
11.
At
the
same
time,
we
initiated
sector
specific
meetings.
This
included
meetings
with
representatives
of
cucurbit
growers
across
the
U.
S.
to
discuss
their
specific
issues,
and
to
enable
them
to
understand
the
newly
detailed
requirements
of
the
critical
use
application.
These
sector
meetings
allowed
us
to
fine
tune
the
application
so
we
could
submit
the
required
information
to
the
MBTOC
in
a
meaningful
fashion.

Finally,
and
concurrent
with
our
preparation
phase,
we
developed
a
plan
to
ensure
a
robust
and
timely
review
of
any
and
all
critical
use
applications
we
might
receive.
This
involved
the
assembly
of
more
than
45
PhDs
and
other
qualified
reviewers
with
expertise
in
both
biological
and
economic
issues.
These
experts
were
divided
into
interdisciplinary
teams
to
enable
primary
and
secondary
reviewers
for
each
application/
crop.
As
a
consequence,
each
nomination
received
by
the
U.
S.
was
reviewed
by
two
separate
teams.
In
addition,
the
review
of
these
interdisciplinary
teams
was
put
to
a
broader
review
of
experts
on
all
other
sector
teams
to
enable
a
third
look
at
the
information,
and
to
ensure
consistency
in
review
between
teams.
The
result
was
a
thorough
evaluation
of
the
merits
of
each
request.
A
substantial
portion
of
requests
did
not
meet
the
criteria
of
decision
IX/
6,
and
a
strong
case
for
those
that
did
meet
the
criteria
has
been
included.

Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.
Page
4
Page
5
5.
Overview
of
Agriculture
Production
5a.
U.
S.
Agriculture
The
U.
S.
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
agricultural
climates.
These
factors
allow
the
U.
S.
to
be
a
uniquely
large
and
productive
agricultural
producer.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farm
land
totaled
381
million
hectares,
a
land
area
larger
than
the
entire
size
of
many
entire
countries.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
the
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables
has
had
an
important
influence
on
the
way
agriculture
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

Other
factors
also
affected
the
general
development
of
agriculture
in
the
U.
S.
While
land
for
farming
is
widely
available,
labor
is
generally
more
expensive
and
less
plentiful.
As
a
result,
the
U.
S.
has
developed
a
unique
type
of
highly
mechanized
farming
practices
that
are
highly
reliant
on
pesticides
such
as
methyl
bromide
and
other
non­
labor
inputs.
The
extent
of
mechanization
and
reliance
on
nonlabor
inputs
can
be
best
demonstrated
by
noting
the
very
low
levels
of
labor
inputs
on
U.
S.
farms:
in
2001,
only
2.05
million
workers
operated
the
2.16
million
U.
S.
farms,
with
help
from
less
than
1
million
hired
workers.

U.
S.
agriculture
is
also
unique
in
terms
of
the
broad
range
of
crops
produced.
For
example,
the
fruit
and
vegetable
sector,
the
agricultural
sector
most
reliant
on
methyl
bromide,
is
diverse,
and
includes
production
of
107
separate
fruit
and
vegetable
commodities
or
groups
of
commodities.
With
this
diversity,
however,
has
come
a
large
number
of
pest
problems
that
methyl
bromide
has
proven
uniquely
able
to
address.

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
has
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices,
including
plastic
mulches,
row
covers,
high­
density
planting,
more
effective
pesticide
sprays,
and
drip
irrigation,
as
well
as
increased
water
irrigation
practices.
Optimization
of
yields
through
these
and
other
scientific
and
mechanized
practices
make
U.
S.
agricultural
output
very
sensitive
to
changes
in
inputs.
Therefore,
as
evidenced
by
the
U.
S.
nominations
for
critical
uses
of
methyl
bromide,
the
phase
out
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.
Page
6
5b.
U.
S.
Cucurbit
Production
U.
S.
cucurbit
production
(
specifically,
production
of
cucumbers,
melons,
cantaloupes,
honeydews,
watermelons,
and
various
squash
varieties)
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture
noted
above.
Cucurbits
are
grown
in
large
areas
of
many
of
the
vegetable
growing
areas
of
the
U.
S..
About
202,345
hectares
are
planted
annually.
As
a
consequence,
this
nomination
covers
use
in
a
variety
of
areas
with
differing
soil
and
climactic
characteristics,
including:
Georgia,
Michigan,
Alabama,
Arkansas,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia.
Cucurbits
covered
by
this
nomination
represent
about
one
third
of
the
U.
S.
land
planted
in
cucurbits.

The
value
of
the
cucurbit
crop
covered
in
this
nomination
is
also
significant.
Cucurbits
grown
by
the
eight
states
covered
in
this
critical
use
exemption
nomination
account
for
about
US
$
250
million,
or
about
one­
sixth
of
the
U.
S.
total.
Of
these,
cucumbers
account
for
about
half,
or
US
$
125
million.
Of
the
eight
states
in
this
nomination,
Georgia,
Michigan
and
North
Carolina
account
for
most
of
the
US
$
250
million
.

Cucurbits
grown
in
these
areas
are
generally
produced
using
mechanized,
scientific
practices
that
involve
deep
injection
of
methyl
bromide.
In
addition,
they
are
mostly
grown
using
multiple
row
transplants
placed
in
polyethylene
plastic­
mulch
raised
beds.
Cucurbits
generally
require
warm
temperatures
and
are
very
sensitive
to
cold.
Cucumbers,
for
example,
grow
optimally
at
temperatures
between
18
o
and
24
oC.
Having
deep
roots,
the
plants
are
best
suited
to
deep,
fertile,
well­
drained
soils.
Frequent
irrigation
of
cucurbit
crops
is
necessary,
as
insufficient
soil
moisture
can
distort
fruit
shape
(
Schrader
et
al.
2002).

Fresh
cucurbit
production
in
the
U.
S.
differs
most
significantly
from
international
methods
because
of
its
frequent
use
of
a
double
cropping
field
system
with
tomatoes,
eggplants,
or
bell
peppers.
Climatic
conditions,
with
heavy
rains
during
the
hottest
season
(
Georgia
for
example),
also
differentiate
the
U.
S.
from
other
cucurbit­
producing
countries.
These
conditions
lead
to
limited
success
of
methyl
bromide
alternatives,
particularly
in
the
Southeast,
as
compared
to
other
regions
that
have
implemented
alternatives.

A
typical
grower
in
the
regions
comprised
by
this
nomination
would
produce
cucurbits
on
about
1­
12
hectares
for
local
or
regional
markets,
while
a
grower
producing
cucurbits
for
wholesale
markets
would
typically
utilize
approximately
12­
200
hectares.
In
Georgia,
for
example,
a
representative
user
of
methyl
bromide
will
farm
a
total
average
of
162
hectares;
of
those
162
hectares,
81
hectares
would
be
treated
with
methyl
bromide
each
year,
due
to
high
pest
pressure.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Cucurbits
6a.
Target
Pests
Controlled
with
Methyl
Bromide
While
U.
S.
cucurbit
growers
use
methyl
bromide
as
one
of
many
options
against
a
range
of
fungal
pathogens,
nematodes,
insect
larvae,
and
weeds,
all
but
a
few
key
organisms
can
be
controlled
in
cucurbit
crops
with
other
pesticides
or
management
strategies.
Only
the
pests
for
which
critical
use
Page
7
exemption
requests
were
submitted
by
U.
S.
cucurbit
growers
are
described
in
detail
in
this
section.

Target
pests
for
methyl
bromide
differ
between
the
northern
and
southeastern
regions
encompassed
in
this
nomination.
Specifically,
Michigan
cucumber,
squash,
pumpkin,
pepper,
eggplant
and
tomato
crops
all
experience
significant
damage
from
Phytophthora
blight,
a
result
of
infection
by
the
soil
fungus
Phytophthora
capsici..
Another
soil­
inhabiting
fungal
pathogen,
Fusarium
oxysporum,
is
also
of
great
concern
for
Michigan
cucurbit
growers
facing
the
loss
of
methyl
bromide.
Both
fungi
cause
root,
crown
and
fruit
rot
in
cucurbits,
greatly
decreasing
both
yield
and
quality
of
cucurbit
harvests.
Early
eradication
of
P.
capsici,
in
particular,
is
very
important
as
it
can
infect
plants
and
produce
additional
oospores
repeatedly
during
a
growing
season
and
result
in
an
epidemic.
Furthermore,
P.
capsici
has
developed
resistance
to
a
number
of
foliar­
applied
fungicides.
This
has
increased
the
importance
of
preventing
infestations
before
planting,
a
goal
currently
achieved
very
effectively
with
methyl
bromide.
Michigan's
cool
and
cloudy
climate
contribute
to
the
challenge
of
suppressing
fungal
pathogens
of
plants,
as
this
climate
is
optimum
for
the
growth
of
these
disease
organisms.

For
the
southern
and
southeastern
U.
S.
states,
the
main
pests
being
targeted
by
methyl
bromide
are
yellow
and
purple
nutsedge
(
Cyperus
esculentum
and
C.
rotundus,
respectively).
These
plants
are
perennial
species
in
the
Cyperaceae
family
that
are
widely
recognized
for
their
extremely
detrimental
economic
impact
on
agriculture.
Purple
nutsedge
is
considered
the
world's
worst
weed
due
to
its
widespread
distribution
and
the
difficulties
in
controlling
it
(
Holm
et
al.
1977).
Purple
nutsedge
is
considered
a
weed
in
at
least
92
countries
and
is
reported
infesting
at
least
52
different
crops.
Yellow
nutsedge
is
listed
among
the
top
fifteen
worst
weeds
(
Holm
et
al.
1977).
Yellow
nutsedge
is
found
throughout
the
continental
U.
S.
Purple
nutsedge
is
primarily
found
in
the
southern
coastal
U.
S.
and
along
the
Pacific
coast
in
California
and
Oregon.
A
survey
conducted
in
Georgia
ranked
the
nutsedges
as
the
most
troublesome
weeds
in
vegetable
crops,
and
among
the
top
five
most
troublesome
weeds
in
corn,
cotton,
peanut,
and
soybean
(
Webster
and
Macdonald
2001).

Nutsedges
have
an
allelopathic
(
inhibitory)
effect
on
the
growth
of
cucumbers
and
other
cucurbit
species,
among
a
variety
of
other
plants
(
Holm
et
al.
1977).
Like
other
weeds,
nutsedges
also
compete
vigorously
for
soil
nutrients,
light,
and
moisture.
Nutsedges
do
best
in
sunny,
warm
habitats
(
typical
of
southern
U.
S.
cucurbit
growing
regions),
and
are
intolerant
of
shady
conditions.
Thus,
nutsedges
are
frequently
problems
in
the
early
part
of
the
growing
season,
when
crop
plants
have
not
produced
many
leaves.
Later
in
the
season,
mature
crops
of
leafy
habit
(
as
are
most
cucurbits)
can
shade
out
new
nutsedge
infestations.
This
pattern
of
nutsedge
competition
with
cucurbit
seedlings
highlights
the
critical
need
for
effective
pre­
plant
control.

While
nutsedges
do
produce
seeds,
vegetative
reproduction
(
i.
e.
through
tuber
formation)
is
more
common
(
Thullen
and
Keeley
1979).
A
single
nutsedge
plant
is
capable
of
producing
140
shoots
(
yellow
nutsedge)
or
280
shoots
(
purple
nutsedge)
over
a
6
month
growing
season
(
Webster
2000).
Each
shoot
produces
a
single
tuber,
which
produces
plants
in
the
following
season.
At
least
one
study
(
William
and
Warren
1975)
reported
that
cucumber
yield
could
be
reduced
by
as
much
as
43
percent
due
to
an
infestation
of
nutsedge
at
a
density
of
1600
plants
per
square
meter.
To
interpret
this
figure
it
is
helpful
to
consider
that
uncontrolled
nutsedge
densities
can
exceed
7000
shoots
(
or
plants)
per
square
meter
(
Webster
2000).
In
extreme
infestations,
up
to
95
percent
losses
can
occur
due
to
Page
8
uncontrolled
nutsedge
infestations!
To
eliminate
yield
reductions,
cucumber
must
be
kept
weed­
free
from
24
to
36
days
after
crop
emergence
(
Friesen
1978).
Cucurbit
quality
is
also
reduced
by
the
presence
of
nutsedge
in
fields.
Nerson
(
1989)
found
that
keeping
fields
weed­
free
for
3
to
4
weeks
after
melon
emergence
resulted
in
significantly
better
fruit
quality.
Interestingly,
some
growers
claim
that
soil
fungi
(
such
as
those
mentioned
above)
can
also
reduce
the
quality
of
the
resulting
cucurbit
crop,
though
there
appear
to
be
no
formal
studies
quantifying
the
extent
of
loss.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Cucurbit
growers
generally
rely
on
fumigation
with
methyl
bromide/
chloropicrin
within
their
plastic
mulch
production
systems
to
control
soil
borne
diseases
and
pests.
There
has
been
extensive
research
on
alternatives
for
the
sector,
and
where
possible,
many
have
been
incorporated.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
in
a
preliminary
stage.
These
alternatives
have
not
been
shown
to
be
standalone
replacements
for
methyl
bromide.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex,
in
particular
Phytophthora
and
Fusarium
fungi,
affecting
cucurbit
production
in
key
growing
areas
of
the
U.
S.

We
begin
our
technical
and
economic
assessment
by
presenting
a
brief
discussion
of
in­
kind
(
chemical)
alternatives,
and
then
describe
the
attributes
of
the
not­
in­
kind
alternatives.

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Table
1
.
In­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Cucurbit
Crops.
Methyl
bromide
alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Metam­
sodium/
crop
rotation
Yes
*
No
1,3­
D,
Metam­
sodium,
Basamid
No
N/
A
Chloropicrin
No
N/
A
Nematicides
No
N/
A
Ozone
No
N/
A
Notes.
*
=
the
alternative
is
technically
feasible
for
some
target
pests
(
fungi)
but
not
others
(
nutsedges).
N/
A
=
Not
applicable.

Metam­
Sodium/
Crop
Rotation.
Metam­
sodium
is
a
technically
feasible
alternative
for
cucurbit
production
in
southern
U.
S.
states
in
areas
of
low
to
moderate
nutsedge
pressure.
However,
nutsedge
control
is
not
as
complete
as
with
methyl
bromide,
and
yield
losses,
particularly
in
high
pest
pressure
locations
may
cause
significant
economic
impacts.
The
current
estimates
of
typical
yield
losses
with
metam­
sodium
replacing
methyl
bromide
are
about
8
to10
percent
in
the
Southern
U.
S.,
with
losses
as
high
as
25
percent
being
possible
(
based
on
discussions
with
extension
specialists
in
Georgia).
The
financial
impact
of
this
loss
is
discussed
in
the
section
dealing
with
economic
feasibility.
While
metam­
sodium
has
good
efficacy
in
controlling
other
weedy
plants,
studies
thus
far
(
and
the
field
Page
9
experience
of
many
crop
experts
in
the
relevant
regions)
suggest
that
it
will
not
adequately
control
nutsedge
species
in
the
absence
of
methyl
bromide.
Though
no
studies
appear
to
have
been
performed
on
cucurbit
crops,
trials
of
metam­
sodium
in
tomatoes
and
bell
peppers
suggest
that
control
of
nutsedge
around
the
application
area
(
e.
g.
drip
irrigation
lines)
can
be
as
high
as
80
to
90
percent
with
metam­
sodium
(
Dowler
1999)
in
high
pest
pressure
areas.
However,
the
remaining
nutsedge
is
still
capable
of
causing
appreciable
yield
loss.

Metam­
sodium
is
not
a
technically
feasible
alternative
to
methyl
bromide
(
whether
used
in
continuous
cropping
or
in
conjunction
with
crop
rotations)
for
fungal
pathogens
cited
as
the
main
targets
by
Michigan
growers.
A
trial
is
currently
underway
in
Michigan
evaluating
the
efficacy
of
metamsodium
against
fungal
pathogens
in
zucchini.
Data
thus
far
indicate
that
it
does
not
provide
acceptable
control
of
these
pests.
In
general,
while
the
underlying
reasons
are
unclear,
many
crop
experts
believe
that
metam­
sodium
is
not
an
effective
treatment
for
soil
fungi,
particularly
Phytophthora
species.
Since
cucurbit
crop
rotations
in
Michigan
involve
plants
(
cucumber,
pepper,
tomato,
and
squash)
susceptible
to
P.
capsici,
it
is
unlikely
that
rotation
combined
with
this
metamsodium
will
adequately
replace
methyl
bromide.

1,3­
D,
Metam­
Sodium,
Basamid.
This
combination
of
chemicals
is
not
currently
feasible
for
U.
S.
cucurbit
production
because
basamid
is
not
registered
for
use
in
this
group
of
crops.
Furthermore,
many
scientists
report
that
1,3­
D
provides
good
nematode
control,
only
moderate
disease
control,
and
poor
weed
control.
Another
issue
contributing
to
the
technical
infeasibility
of
any
combination
involving
1,3­
D
is
the
practicality
of
application,
particularly
in
the
hot,
humid
southeastern
U.
S.
states.
Workers
wearing
the
required
Personal
Protective
Equipment
(
PPE)
for
1,3­
D
become
at
risk
for
possible
heat
exhaustion
or
heat
stroke.
For
example,
PPE
rules
may
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
are
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity,
rapidly
become
unbearable
for
a
typical
applicator.

Chloropicrin.
Chloropicrin
alone
is
unlikely
to
control
the
nutsedges
that
are
the
key
pests
in
southern
U.
S.
cucurbits,
as
studies
in
other
cropping
systems
have
shown
poor
weed
control.
While
studies
in
other
crop
systems
(
e.
g.,
strawberries)
have
shown
some
control
of
soil
diseases,
no
studies
appear
to
have
been
done
to
show
technical
feasibility
of
chloropicrin
alone
as
a
control
strategy
for
Phytophthora
and
Fusarium
fungi
in
cucurbits.

Furthermore,
workers
have
expressed
concerns
about
eye
and
lung
irritation
when
applying
chloropicrin.
Airborne
chloropicrin
levels
of
0.1
ppm
require
the
use
of
air­
purifying
respirators
and
levels
exceeding
4
ppm
require
the
use
of
air­
supplying
respirators.
As
mentioned
for
1,3­
D,
this
could
render
application
of
large
amounts
of
chloropicrin
impractical
in
the
heat
and
humidity
of
the
U.
S.
growing
season.
Also
in
this
regard,
emission
of
chloropicrin
from
agricultural
fields
into
urban
areas
has
been
a
concern
due
to
its
lachrymating
effects.
Increased
use
of
chloropicrin
would
trigger
the
need
to
address
these
issues.
Indeed,
chloropicrin
has
been
determined
to
be
a
toxic
air
contaminant
by
California's
Department
of
Pesticide
Regulation,
and
other
jurisdictions
may
follow
suit.

Nematicides.
Nematicides
as
a
group
are
not
technically
feasible
methyl
bromide
alternatives,
in
the
Page
10
context
of
this
nomination,
because
nematodes
are
not
among
the
pests
cited
by
exemption
applicants
as
being
the
targets
of
concern.

Ozone.
Ozone
is
not
technically
feasible
because
there
is
no
known
available
and
field­
feasible
technology
for
generating
ozone
for
cucurbit
production
systems
in
the
U.
S.
In
addition,
initial
research
in
California
suggests
that
ozone
is
neutralized
so
rapidly
by
soil
particles
that
it
does
not
retain
its
biocidal
properties.
Even
if
effective,
the
practical
impediments
to
ozone
sterilization
of
soil
for
cucurbit
production
are
very
similar
to
steam's
constraints:
lack
of
portable
ozone
generation
equipment
that
would
be
needed
simultaneously
on
many,
widely
dispersed
farms.

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
For
cucurbits,
the
critical
use
exemption
review
group
analyzed
the
economic
losses
associated
with
the
use
of
metam­
sodium/
crop
rotation,
which
was
the
only
alternative
deemed
technically
feasible
and
only
in
areas
of
low
to
moderate
pest
pressure
by
nutsedges.
Since
metam­
sodium
is
not
technically
feasible
in
Michigan
due
to
fungal
pest
pressures,
no
economic
analysis
was
done
for
Michigan.

Even
under
fairly
conservative
estimates
of
yield
losses,
the
per
hectare
losses
are
substantial
for
metam­
sodium
trials,
and
they
would
likely
erase
grower
profits
from
cucurbit
production.
The
efficacy
of
metam­
sodium
at
controlling
nutsedge
is
not
well
understood,
and
therefore
the
yield
losses
that
would
result
from
reduced
control
have
been
shown
to
be
highly
variable
and
uncertain.
Table
2
provides
a
summary
of
the
estimated
economic
losses
in
Georgia
and
the
Southeastern
U.
S.
due
to
yield
losses
as
estimated
in
the
biological
section
and,
to
a
lesser
extent,
differences
in
the
cost
of
the
alternatives
including
application
costs.

The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide,
such
as
for
cucurbits,
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices.

The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
absolute
losses
per
hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
Page
11
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
3)
losses
per
kilogram
of
methyl
bromide
requested.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production
but
is
also
useful
for
structural
and
post­
harvest
uses.

(
4)
losses
as
a
percent
of
net
cash
revenues.
We
define
net
cash
revenues
as
gross
revenues
minus
operating
costs.
This
is
a
very
good
indicator
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
owners
or
operators
of
an
enterprise.
However,
operating
costs
can
often
be
difficult
to
measure
and
verify.

(
5)
changes
in
profit
margins.
We
define
profit
margin
to
be
profits
as
a
percentage
of
gross
revenues,
where
profits
are
gross
revenues
minus
all
fixed
and
operating
costs.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
curcurbit
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

Table
2.
Measures
of
Economic
Impact
on
Cucurbits
in
the
U.
S.
with
Metam­
Sodium/
Crop
Rotation
as
an
Alternative.
Loss
Measure
Georgia
Southeast**

Per
Hectare
US$
391

$
2,918
likely
$
1,862
loss
US$
1,210
­
$
9,190
likely
$
5,187
loss
Per
Kilogram
Methyl
Bromide
US$
1.74

$
13.00
likely
$
8.29
loss
US$
5.40
­
$
41.10
likely
$
23.10
loss
%
of
Gross
Revenue
1
­
11%
likely
7%
loss
4
­
30%
loss
likely
17%
loss
%
of
Net
Cash
Returns
6
­
50%
likely
28%
loss
9
­
73%
loss
likely
41%
loss
Yield
Losses
1
­
17%
likely
10%
loss
3
­
26%
loss
likely
15%
loss
Notes.
**
=
Loss
measures
were
calculated
based
on
the
data
from
the
USDA,
National
Agricultural
Statistics
Service
(
NASS).

The
analysis
strongly
indicates
that
metam­
sodium/
crop
rotation
is
not
an
economically
viable
alternative
to
methyl
bromide.
Losses
per
hectare
are
relatively
large
and
are
driven
by
yield
losses
and
cost
increases.
They
range
from
US$
391
in
Georgia
to
US$
9,190
in
the
Southeast
with
annual
fumigation.
This
represents
losses
of
US$
1.74
­
41.10
/
kg
of
methyl
bromide.
Gross
revenue
losses
are
likely
to
be
greater
than
10
percent,
significantly
higher
than
annual
losses
in
recent
years.
Depending
on
the
fumigation
cycle,
total
losses
vary
from
1­
30
percent
of
gross
revenues,
depending
on
which
baseline
is
used.
Even
using
the
higher
yields
and
prices
from
the
application,
grower
Page
12
returns
(
gross
revenues
less
operating
and
fixed
costs)
would
be
negative
with
metam­
sodium.
Overall,
the
results
are
fairly
consistent
across
the
southern
states,
and
suggest
that
metam­
sodium
is
not
economically
viable
as
an
alternative
for
methyl
bromide.

6e.
Technical
Feasibility
of
Not­
In­
Kind
(
Non­
Chemical)
Alternatives
This
section
summarizes
the
analysis
of
the
remainder
of
the
methyl
bromide
alternatives
identified
by
MBTOC
for
cucurbit
production,
primarily
non­
chemical
alternatives.
Table
3
contains
a
summary
of
the
technical
assessment,
which
is
that
none
of
these
alternatives
were
found
to
be
technically
feasible.
Because
no
alternative
was
found
to
be
technically
feasible
no
economic
assessment
was
conducted.
A
brief
description
of
the
technical
infeasibility
of
each
alternative
follows
the
table.

Table
3.
Not­
In­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Cucurbit
Crops.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Biofumigation
No
N/
A
Soil
solarization
No
N/
A
Steam
No
N/
A
Biological
control
No
N/
A
Cover
crops
and
mulching
No
N/
A
Crop
rotation/
fallow
No
N/
A
Endophytes
No
N/
A
Flooding
and
water
management
o
N/
A
General
IPM
(
Integrated
Pest
Management)
o
o
Grafting/
resistant
rootstock/
plant
breeding
o
o
Resistant
cultivars
o
o
Organic
production
o
o
Soilless
culture
o
o
Substrates/
Plug
plants
o
o
Biofumigation.
Biofumigation
is
not
technically
feasible
as
an
alternative
to
methyl
bromide
because
it
does
not
adequately
control
Phytophthora
species.
For
fungal
pathogens
in
Michigan
cucurbits,
chicken
manure
has
been
tested
for
efficacy
as
a
methyl
bromide
alternative,
and
found
to
be
inadequate.
Brassica
residues,
another
potential
biofumigant,
have
not
been
field
tested
against
these
cucurbit
pests.
However,
it
is
the
opinion
of
the
science
reviewers
of
the
critical
use
exemption
requests
that
neither
type
of
biofumigant
will
adequately
control
soil
fungi,
particularly
Phytophthora
species.
This
is
because
these
fungi
have
an
overwintering
structure,
called
an
oospore,
which
is
very
resistant
to
environmental
stresses
and
survives
well
in
Michigan's
relatively
cool,
moist
soils.
Further,
predatory
nematodes
that
would
aid
in
the
effects
of
biofumigation
have
not
been
properly
identified
or
quantified
in
Michigan's
vegetable
growing
regions
and
may
not
occur
in
adequate
densities.
Page
13
Control
of
some
species
of
small­
seeded
annual
weeds
has
been
reported
with
celery
residue
(
Bewick
et
al.
1994).
The
critical
use
exemption
review
group
was
unable
to
locate
similar
studies
using
other
biofumigants.
Interestingly,
biofumigation
using
Brassica
residue
may
be
harmful
to
the
crop
itself,
a
phenomenon
that
has
been
observed
for
wild
radish
(
a
Brassica
species)
growing
in
cotton
(
J.
Norsworthy,
Clemson
University,
unpublished
study).
Given
these
findings
and
the
associated
uncertainty
regarding
this
technique,
the
critical
use
exemption
review
group
concluded
that
biofumigation
is
currently
not
technologically
feasible
for
reliable
nutsedge
control.

Solarization.
Solarization
is
not
technically
feasible
as
a
methyl
bromide
alternative
for
control
of
fungal
pathogens
in
Michigan.
The
climate
is
typically
cool
(
less
than
11
oC
frequently
through
May)
and
cloudy,
particularly
early
in
the
growing
season
when
control
of
these
pests
is
particularly
important.

For
nutsedge
control
in
the
southeastern
U.
S.
states,
solarization
is
unlikely
to
be
technically
feasible
as
a
methyl
bromide
alternative.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50
oC
or
higher
(
Chase
et
al.
1999).
While
this
may
be
achieved
for
some
portion
of
the
autumn
cropping
in
southern
cucurbit
growing
regions,
it
is
very
unlikely
for
any
portion
of
the
spring
crops.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43
oC
at
5
cm
depth.
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
reliably
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
Solarization
may
be
adapted
to
reduce
low
nutsedge
pressure
in
fall
cucurbits
plantings
(
autumn),
but
only
in
combination
with
efficacious
herbicides
and
other
pest
management
tools.
Currently,
however,
the
effective
use
of
solarization
even
in
this
production
niche
remains
largely
unknown.

The
time
period
for
solarization
to
be
used
to
raise
soil
temperatures
to
the
level
needed
to
kill
soil
fungi
or
nutsedge
in
any
U.
S.
cucurbit
growing
region
is
likely
to
also
be
the
time
period
when
the
crops
themselves
must
complete
their
growth
cycle.
In
Michigan,
this
growing
season
is
particularly
short
(
May
to
September),
so
the
time
needed
to
utilize
solarization
is
likely
to
render
the
subsequent
growing
of
crops
impossible,
even
if
it
did
somehow
eliminate
all
fungal
pathogens.
Even
in
the
southern
states,
the
use
of
solarization
would,
at
the
very
least,
disrupt
the
spring
planting
cycle
for
cucumbers,
melons,
and
squash.

Steam
sterilization.
Steam
is
not
a
technically
feasible
alternative
for
open
field
cucurbit
production
in
Michigan
or
the
southeastern
U.
S.
because
it
requires
sustained
heat
over
a
required
period
of
time.
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
the
open
cucurbit
crops
in
Michigan.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
This
problem
also
applies
to
the
control
of
nutsedges
in
the
southern
cucurbit
growing
regions.
There
are
also
currently
no
portable
systems
for
any
field
grown
crops
available.
team
for
soil
sterilization
is
impractical
in
large­
scale,
open
field
production
areas
typical
in
U.
S.
cucurbit
production.
A
1998
UNEP
assessment
also
indicated
that
steam
is
an
alternative
to
methyl
bromide
soil
fumigation
in
Page
14
small­
scale
or
closed
production
areas,
but
has
yet
to
be
proven
economical
and
practical
for
largescale
open
field
production
systems
(
UNEP
1998).

Biological
control.
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nutsedges
that
afflict
cucurbits.
While
biological
control
may
have
utility
as
part
of
a
nutsedge
management
strategy,
alone
it
is
unlikely
to
replace
methyl
bromide
for
nutsedge
control.
The
bacterium
Burkholder
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
fungal
plant
pathogens.
However,
in
a
test
conducted
by
the
Michigan
applicants,
P.
capsici
was
not
controlled
adequately
in
summer
squash,
a
cucurbit
crop,
by
either
of
these
beneficial
microorganisms.

Puccinia
canalieunata,
which
causes
rust
(
a
fungus
disease),
and
isolates
of
another
fungus,
Dactylaria
higginsii,
have
been
studied
for
their
suppressive
effects
on
purple
nutsedge.
In
the
trial
with
rust,
stand
formation
was
reduced
by
46
percent,
tuber
formation
by
66
percent,
and
flowering
was
fully
eliminated
(
Phatak
1983).
D.
higginsii
reduced
the
dry
shoot
weight
and
number
of
tubers
produced
by
purple
nutsedge
by
45
to
71
percent
(
Kadir
et
al.
2000).
This
is
due
largely
to
the
enormous
reproductive
potential
of
nutsedge
tubers.
Research
conducted
in
Georgia
showed
that
under
the
prevailing
climate
there,
a
single
nutsedge
tuber
can
produce
29
shoots
in
3
months
and
more
than
320
shoots
in
6
months
(
Webster
et
al.
2002).
Additionally,
very
high
levels
of
one
fungus
(
D.
higginsii)
were
required
to
achieve
the
consistently
high
results
described
previously.
Because
the
fungus
levels
decline
after
the
nutsedge
is
destroyed
the
weed
can
freely
recolonize
the
areas
treated
with
the
fungus
(
Kadir
et
al.
2000).
Taken
together,
these
results
strongly
suggest
that
the
available
biological
control
agents
by
themselves
will
not
provide
adequate
control
of
nutsedge
in
southern
US
growing
regions.

Cover
crops
and
mulching.
Cover
crops
and
mulching
are
not
technically
feasible
for
the
soil
fungi
and
nutsedge
which
cause
yield
losses.
While
some
studies
done
outside
the
U.
S.
suggest
these
practices
provide
some
control
of
fungal
pathogens,
there
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
P.
capsici.
Control
of
P.
capsici
is
imperative
for
cucurbit
production
in
Michigan.
Plastic
mulch
is
already
in
widespread
use
in
Michigan
vegetables,
and
regional
crop
experts
state
that
it
is
not
an
adequate
protectant
when
used
without
methyl
bromide.
The
longevity
and
resistance
of
P.
capsici
oospores
renders
cover
crops
ineffective
as
a
stand­
alone
management
alternative
to
methyl
bromide.

As
is
the
case
with
soil
fungi
cited
by
Michigan
growers,
cover
crops
and
mulches
appear
to
control
many
weeds,
but
not
the
nutsedge
species
cited
by
the
southern
US
applicants.
For
example,
Burgos
and
Talbert
(
1996)
found
that
cover
crops
such
as
rye,
hairy
vetch
and
wheat
controlled
redroot
pigweed
(
Amaranthus
retroflexus)
and
large
crabgrass
(
Digitaria
sanguinalis),
but
failed
to
reduce
populations
of
yellow
nutsedge.
The
effect
of
cover
crops
on
cucurbit
crop
growth
and
yield
remains
unknown,
contributing
to
the
technical
obstacles
this
strategy
faces
as
a
methyl
bromide
alternative.
In
some
studies
cover
crops
have
delayed
crop
maturity
and
reduced
height
and
yield
of
plants
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
since
these
plants
are
able
to
penetrate
through
both
organic
and
Page
15
plastic
mulches
(
Munn
1992,
Patterson
1998).
Plastic
mulch
is
already
in
widespread
use
in
cucurbit
crops
in
the
U.
S.,
as
a
method
of
preserving
fertilizer
and
maintaining
more
optimal
soil
temperatures.
It
is
well
established
that
these
mulches
alone
do
not
prevent
nutsedge
growth.
In
sum,
the
evidence
thus
far
does
not
support
the
technical
feasibility
of
either
cover
crops
or
mulch
for
nutsedge
control
in
the
absence
of
methyl
bromide.

Crop
Rotation/
Fallow
Land.
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not,
by
itself,
provide
adequate
control
of
fungi
in
Michigan
or
nutsedge
in
southern
states.
The
crop
rotations
available
to
growers
in
Michigan
region
are
also
susceptible
to
these
fungi,
particularly
to
P.
capsici.
Fallow
land
can
still
harbor
P.
capsici
oospores.
Thus
fungi
would
persist
and
attack
cucurbits
if
crop
rotation/
fallow
land
was
the
main
management
regime.

In
the
case
of
nutsedge
also,
the
unusual
hardiness
of
these
weeds
is
likely
to
negate
the
beneficial
effects
of
rotating
crop
types
and
keeping
land
fallow.
Nutsedge
tubers
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land.
Furthermore,
nutsedge
plants
can
produce
tubers
within
8
weeks
after
emergence.
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.

Endophytes.
Endophytes
are
not
currently
technologically
feasible
as
a
methyl
bromide
alternative
for
Michigan
growers
for
the
control
of
Phytophthora
species,
and
for
southeastern
cucurbit
growers
for
the
control
of
nutsedge.
Though
these
organisms
(
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
have
been
shown
to
suppress
some
plant
pathogens
in
cucumber,
there
is
no
such
information
for
the
other
cucurbit
crops
grown
in
Michigan.
Furthermore,
the
pathogens
involved
did
not
include
Phytophthora
species,
which
are
arguably
the
greatest
single
threat
to
Michigan
cucurbits.
Similarly,
the
U.
S.
found
no
evidence
that
endophytes
control
nutsedges,
and
concluded
that
the
current
pest
management
information
does
not
support
the
technical
feasibility
of
endophyte
control
of
these
weeds.

Flooding
and
Water
Management.
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
P.
capsici,
and
is
likely
to
be
impractical
for
Michigan
cucurbit
growers.
It
is
unclear
whether
irrigation
methods
in
this
region
could
be
adapted
to
incorporate
flooding
or
alter
water
management
for
cucurbit
fields.
In
any
case,
there
appears
to
be
no
supporting
evidence
for
its
use
against
the
hardy
oospores
of
P.
capsici.

As
with
many
of
the
other
alternatives
to
methyl
bromide,
flooding
has
been
shown
to
control
a
number
of
weeds,
but
not
nutsedge
species.
Nutsedge
is
much
more
tolerant
of
watery
conditions
than
many
other
weed
pests.
For
example,
Horowitz
(
1972)
showed
that
submerging
nutsedge
in
flowing
or
stagnant
water
(
for
8
days
and
4
weeks,
respectively)
did
not
affect
the
sprouting
capacity
of
tubers.
There
are
also
serious
practical
obstacles
to
implementing
flood
management
approaches
in
cucurbit
production
in
the
southern
and
southeastern
U.
S.
states.
Droughts
are
common
in
many
parts
of
these
regions,
and
the
soil
composition
may
not
support
flooding
and
still
remain
productive.
Page
16
These
uncertainties,
along
with
the
water
tolerance
of
nutsedge,
led
the
critical
use
exemption
review
group
to
conclude
that
flooding
and
water
management
are
not
technically
feasible
alternatives
to
methyl
bromide
for
control
of
these
weeds.

Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
cucurbits,
they
have
been
grouped
together
for
discussion
in
this
document.
The
U.
S.
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges
in
cucurbits.
While
in
theory
plant
breeding
may
improve
the
ability
of
cucurbits
to
compete
with
these
weeds
for
nutrients,
light,
etc.,
it
would
certainly
not
provide
alternatives
within
the
time
span
considered
in
this
critical
use
exemption
nomination.
The
effect
on
the
quality
of
the
crops
involved
is
unknown
also.

For
resistant
rootstock
at
least,
there
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
cucurbit
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.

Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
either
fungi
or
nutsedge.
In
fact,
a
large­
scale
trial
of
soilless
culture
of
tomatoes
in
Florida
was
wiped
out
by
an
infestation
of
Fusarium
­
one
of
the
fungi
listed
by
the
Michigan
applicant
as
a
key
pest
(
see
critical
use
exemption
#
0054
in
the
tomato
sector
for
details).
This
fungus
(
like
Phytophthora)
can
spread
through
water,
making
it
difficult
to
keep
any
sort
of
area
(
with
or
without
soil)
disease
free.
The
U.
S.
experts
found
no
evidence
that
soilless
culture
or
substrates/
plug
plants
can
be
used
to
produce
cucurbit
crops
on
a
large
scale,
or
that
they
will
control
nutsedges,
which
like
soil
fungi
are
particularly
hardy.
Various
aspects
of
organic
production

organic
mulches,
cover
crops,
fallow
land,
steam
sterilization
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
Based
on
these
findings,
and
the
lack
of
any
formal
studies
documenting
the
effectiveness
of
a
comprehensive
organic
production
system
at
a
farm
level,
the
U.
S.
experts
concluded
that
"
organic
production"
is
also
not
a
technically
comparable
alternative
to
methyl
bromide
for
any
of
the
cucurbit
pests
discussed
here.

General
Integrated
Pest
Management
(
IPM).
General
IPM
is
not
technically
feasible
as
a
standalone
alternative
to
methyl
bromide
because
it
does
not
control
the
relevant
soil
fungi
and
nutsedge.
U.
S.
experts
believe
it
is
unlikely
that
the
suite
of
biological,
chemical,
mechanical
or
cultural
practices
encompassed
by
the
concept
of
general
IPM
would
replace
fungal
control
by
methyl
bromide
in
cucurbits,
since
these
techniques
are
in
widespread
use
already,
and
there
are
still
significant
yield
losses
when
methyl
bromide
is
not
used.

The
assessment
of
"
general
IPM"
as
an
alternative
to
methyl
bromide
control
of
nutsedge
is
similar
to
that
of
its
effectiveness
against
soil
fungi.
Techniques
comprised
within
general
IPM
that
reduce
Page
17
weeds,
such
as
use
of
plastic
or
other
mulches,
cropping
cycles,
crop
rotations,
etc.,
are
already
in
widespread
use
in
cucurbit
crops
in
the
southern
U.
S..
Virtually
all
of
these
are
included
in
the
MBTOC
list
of
potential
methyl
bromide
alternatives.
However,
as
has
been
discussed
in
this
document
in
the
sections
above,
it
appears
that
none
of
these
techniques,
either
by
themselves
or
together,
is
currently
sufficient
to
achieve
acceptable
nutsedge
control
in
the
absence
of
methyl
bromide.
There
is
evidence
that
the
fumigants,
iodomethane
or
halosulfuron,
used
with
general
IPM
techniques,
may
be
able
to
accomplish
adequate
control
of
soil
fungi
and
nutsedges,
but
these
fumigants
are
not
registered
for
use
in
the
U.
S..
The
use
of
IPM
(
with
these
alternative
fumigants)
will
require
multi­
year,
on­
farm
study
before
one
can
confidently
assert
that
it
will
be
technically
equivalent
to
the
use
of
methyl
bromide
in
cucurbits.

7.
Critical
Use
Exemption
Nomination
for
Cucurbits
The
critical
use
exemption
actual
amount
requested
for
cucurbits
were
submitted
by
representatives
of
growers
groups
in
Michigan
and
southeastern
U.
S.
states.
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
forcucurbits
for
the
southeastern
states
and
Michigan.

1.
The
southeastern
states
(
Alabama,
Arkansas,
Georgia,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia)
are
requesting
methyl
bromide
for
2005,
2006,
and
2007.
The
growers
requested
an
average
of
1,117,966kgs
methyl
bromide
for
fumigating
a
total
of
6,700
hectares.
The
use
rates
conform
to
standard
cucurbit
practices
in
this
region.
Rates
as
requested
conform
to
standard
cucurbit
practices
in
the
southeast
(
Table
4).

Table
4.
Methyl
Bromide
Usage
and
Request
for
Cucurbits
in
Southeastern
States.

1997
1998
1999
2000
2001
2005
2006
2007
tonne
1,049
1,240
1,018
991
1,161
1,160
1,162
1,162
hectares
4,590
5,400
6,160
6,540
7,720
7,720
7,720
7,720
rate
(
kg/
ha)
235
235
170
150
150
150
150
150
It
appears
that
the
application
rate
in
Georgia
may
be
declining
which
would
be
consistent
with
the
fact
that
the
applicant
has
changed
their
formulation
of
methyl
bromide
from
98
percent
to
67
percent
methyl
bromide
formulations.
Out
of
a
total
of
23,800
hectares
estimated
by
U.
S.
EPA
to
be
planted
by
the
Georgia
growers
in
2001,
we
are
nominating
about
40
percent
of
their
cucurbit
hectares,
which
is
the
approximate
amount
of
land
that
has
a
serious
nutsedge
infestation.

It
seems
that
the
application
rate
for
the
southeastern
states
may
be
declining,
which
would
be
consistent
with
the
fact
that,
as
with
Georgia,
growers
here
have
changed
their
formulation
of
methyl
bromide
from
98
percent
to
67
percent
methyl
bromide
formulations.
Out
of
a
total
of
20,440
hectares
estimated
by
U.
S.
EPA
to
be
planted
by
the
Southeastern
growers
in
2001,
we
are
Page
18
nominating
about
25
percent
of
their
cucurbit
hectares
which
is
the
approximate
amount
of
land
that
has
nutsedge
infestation.

2.
Michigan
farms
are
requesting
methyl
bromide
for
2005,
2006,
and
2007.
The
growers
requested
an
average
of
27,480
kgs
methyl
bromide
for
fumigating
a
total
of
570
hectares
a
year.
The
use
rates
requested
conform
to
standard
cucurbit
practices
in
Michigan
(
Table
5).

Table
5.
Methyl
Bromide
Usage
and
Requests
for
Cucurbits
in
Michigan.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
27,660
26,590
26,590
30,320
30,320
28,190
27,660
26,590
hectares
230
220
220
250
250
190
230
220
rate
(
kg/
ha)
120
120
120
120
120
150
120
120
The
application
rate
for
Michigan
appears
to
have
remained
consistent
through
the
years,
which
is
as
expected,
due
to
the
fact
that
they
have
historically
been
using
67
percent
methyl
bromide
since
1997.
The
use
rate
is
lower
in
Michigan
than
elsewhere
in
the
U.
S.
probably
due
to
differences
in
pest
pressure
such
that
pests
are
controlled
with
a
lower
concentration
of
methyl
bromide.
Out
of
a
total
of
6,030
hectares
estimated
by
U.
S.
EPA
to
be
planted
by
the
Michigan
applicants
in
2001,
we
are
nominating
3
percent
of
their
cucurbit
hectares
which
is
the
approximate
amount
of
land
that
has
Phytophthora
infestation.

The
total
U.
S.
nomination
for
cucurbits
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives
(
buffer
zones,
township
caps),
environmental
concerns
such
as
soil
based
restrictions
due
to
potential
groundwater
contamination,
and
historic
use
rates,
among
other
factors.

Table
6.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Cucurbits
Year
Total
Request
by
Applicant
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
1,187,773
1,187,773
8.
Availability
of
Methyl
Bromide
From
Recycled
or
Stockpiled
Sources
In
accordance
with
the
criteria
of
the
critical
use
exemption,
Parties
must
discuss
the
potential
that
the
Page
19
continued
need
for
methyl
bromide
can
be
met
from
recycled
or
stockpiled
sources.
With
regard
to
recycling
of
methyl
bromide,
it
is
fair
to
say
that
the
U.
S.
concurs
with
earlier
TEAP
conclusions
that
recycling
of
methyl
bromide
used
in
soil
fumigation
is
not
currently
feasible.
The
U.
S.
has
been
investigating
the
level
of
the
existing
stockpile,
and
we
believe
that
whatever
stock
pile
may
now
exist
will
likely
be
fully
depleted
by
2005
when
the
need
for
the
critical
use
exemption
will
start.

9.
Use/
Minimizing
Emissions
of
Methyl
Bromide
in
the
U.
S.

In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country
The
use
of
methyl
bromide
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
is
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
is
machine
injected
into
soil
to
specific
depths.
In
addition,
as
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
methyl
bromide
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.
Reduced
methyl
bromide
concentrations
in
mixtures,
more
mechanized
soil
injection
techniques,
and
the
extensive
use
of
tarps
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world.

In
terms
of
compliance,
in
general,
the
United
States
has
used
a
combination
of
tight
production
and
import
controls,
and
the
related
market
impacts
to
ensure
compliance
with
the
Protocol
requirements
on
methyl
bromide.
Indeed,
over
the
last

years,
the
price
of
methyl
bromide
has
increased
substantially.
As
Chart
1
in
Appendix
D
demonstrates,
the
application
of
these
policies
has
led
to
a
more
rapid
U.
S.
phasedown
in
methyl
bromide
consumption
than
required
under
the
Protocol.
This
accelerated
phasedown
on
the
consumption
side
may
also
have
enabled
methyl
bromide
production
to
be
stockpiled
to
some
extent
to
help
mitigate
the
potentially
significant
impacts
associated
with
the
Protocol's
2003
and
2004
70%
reduction.
We
are
currently
uncertain
as
to
the
exact
quantity
of
existing
stocks
going
into
the
2003
season
that
may
be
stockpiled
in
the
U.
S.
We
currently
believe
that
the
limited
existing
stocks
are
likely
to
be
depleted
during
2003
and
2004.
This
factor
is
Page
20
reflected
in
our
requests
for
2005
and
beyond.

At
the
same
time
we
have
made
efforts
to
reduce
emissions
and
use
of
methyl
bromide,
we
have
also
made
strong
efforts
to
find
alternatives
to
methyl
bromide.
The
section
that
follows
discusses
those
efforts.

10.
U.
S.
Efforts
to
Find,
Register
and
Commercialize
Alternatives
to
Methyl
Bromide
Over
the
past
ten
years,
the
United
States
has
committed
significant
financial
and
technical
resources
to
the
goal
of
seeking
alternatives
to
methyl
bromide
that
are
technically
and
economically
feasible
to
provide
pest
protection
for
a
wide
variety
of
crops,
soils,
and
pests,
while
also
being
acceptable
in
terms
of
human
health
and
environmental
impacts.
The
U.
S.
pesticide
registration
program
has
established
a
rigorous
process
to
ensure
that
pesticides
registered
for
use
in
the
United
States
do
no
present
an
unreasonable
risk
of
health
or
environmental
harm.
Within
the
program,
we
have
given
the
highest
priority
to
rapidly
reviewing
methyl
bromide
alternatives,
while
maintaining
our
high
domestic
standard
of
environmental
protection.
A
number
of
alternatives
have
already
been
registered
for
use,
and
several
additional
promising
alternatives
are
under
review
at
this
time.
Our
research
efforts
to
find
new
alternatives
to
methyl
bromide
and
move
them
quickly
toward
registration
and
commercialization
have
allowed
us
to
make
great
progress
over
the
last
decade
in
phasing
out
many
uses
of
methyl
bromide.
However,
these
efforts
have
not
provided
effective
alternatives
for
all
crops,
soil
types
and
pest
pressures,
and
we
have
accordingly
submitted
a
critical
use
nomination
to
address
these
limited
additional
needs.

Research
Program
When
the
United
Nations,
in
1992,
identified
methyl
bromide
as
a
chemical
that
contributes
to
the
depletion
of
the
ozone
layer
and
the
Clean
Air
Act
committed
the
U.
S.
to
phase
out
the
use
of
methyl
bromide,
the
U.
S.
Department
of
Agriculture
(
USDA)
initiated
a
research
program
to
find
viable
alternatives.
Finding
alternatives
for
agricultural
uses
is
extremely
complicated
compared
to
replacements
for
other,
industrially
used
ozone­
depleting
substances
because
many
factors
affect
the
efficacy
such
as:
crop
type,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
among
localities
within
a
region.

Through
2002,
the
USDA
Agricultural
Research
Service
(
ARS)
alone
has
spent
US$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
(
see
Table
1
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
agricultural
and
forestry
leaders
from
private
industry,
academia,
state
governments,
and
the
federal
government
to
assess
the
problem,
formulate
priorities,
and
implement
research
directed
at
providing
solutions
under
the
USDA's
Methyl
Bromide
Alternatives
program.
The
ARS
within
USDA
has
22
national
programs,
one
of
which
is
the
Methyl
Bromide
Alternatives
program
(
Select
Methyl
Bromide
Page
21
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov
).
The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
the
extensive
private
sector
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
While
research
has
been
undertaken
in
all
sectors,
federal
government
efforts
have
been
based
on
the
input
of
experts
as
well
as
the
fact
that
nearly
80
percent
of
preplant
methyl
bromide
soil
fumigation
is
used
in
a
limited
number
of
crops.
Accordingly,
much
of
the
federal
government
pre­
plant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.

Table
1:
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Expenditures
by
the
U.
S.
Department
of
Agriculture
(
US$
Million)

1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
The
USDA/
ARS
strategy
for
evaluating
possible
alternatives
is
to
first
test
the
approaches
in
controlled
experiments
to
determine
efficacy,
then
testing
those
that
are
effective
in
field
plots.
The
impact
of
the
variables
that
affect
efficacy
is
addressed
by
conducting
field
trials
at
multiple
locations
with
different
crops
and
against
various
diseases
and
pests.
Alternatives
that
are
effective
in
field
plots
are
then
tested
in
field
scale
validations,
frequently
by
growers
in
their
own
fields.
University
scientists
are
also
participants
in
this
research.
Research
teams
that
include
ARS
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

Research
results
submitted
with
the
CUE
request
packages
(
including
published,
peer­
reviewed
studies
by
(
primarily)
university
researchers,
university
extension
reports,
and
unpublished
studies)
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
Page
22
the
MBTOC
list.

As
demonstrated
by
the
table
above,
U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
substantial,
and
they
have
been
growing
in
size
as
the
phaseout
has
approached.
The
United
States
is
committed
to
sustaining
these
research
efforts
in
the
future
to
continue
to
aggressively
search
for
technically
and
economically
feasible
alternatives
to
methyl
bromide.
We
are
also
committed
to
continuing
to
share
our
research,
and
enable
a
global
sharing
of
experience.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

Research
Results
Submitted
for
Cucurbits
Government
funded
studies
related
to
U.
S.
cucurbit
production
that
are
currently
on­
going
include
a
multi­
year
study
(
currently
ongoing
and
ending
in
2005)
in
the
southeaster
U.
S.,
being
conducted
by
the
ARS.
This
project
will
examine
the
integrated
management
and
ecology
of
weed
populations
in
crops
grown
in
the
Southeastern
coastal
plain.
Among
other
goals,
this
project
will
develop
alternative
nutsedge
management
systems
for
selected
vegetable
crops
(
including
cucurbits)
with
an
emphasis
on
integrating
cultural
and
tillage
practices
for
weed
control.
Alternate
methods
for
fumigating
soil
to
manage
weeds
and
other
soil
pests
are
being
evaluated
in
this
effort.
Also,
weedcrop
interactions
and
weed
population
dynamics
in
irrigated
and
reduced
tillage
systems
are
being
studied
as
part
of
this
work.
The
ARS
is
also
undertaking
research
projects
studying
alternative
methods
to
control
Phytophthora
and
Fusarium
fungi,
albeit
in
non­
cucurbit
crops
such
as
tomatoes
and
peppers.
Results
from
this
work
should
be
applicable
to
cucurbit
production
also.
Details
of
these
projects
are
provided
in
the
nomination
chapters
for
those
crops.

The
U.
S.
government,
along
with
grower
associations,
is
also
indirectly
supporting
research
conducted
by
universities
on
alternatives
to
methyl
bromide
use
in
cucurbits.
Research
results
submitted
with
the
cucurbit
critical
use
exemption
request
packages
(
including
published,
peerreviewed
studies
by
university
researchers,
university
extension
reports,
and
unpublished
studies)
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
the
MBTOC
list.
Research
planned
for
the
next
few
years
will
also
refine
estimates
of
yield
loss,
and
to
quantify
impacts
on
quality
of
harvested
cucurbits,
in
situations
where
chemical
or
non­
chemical
alternatives
are
used
in
place
of
methyl
bromide.

In
addition
to
the
research
that
is
ongoing
under
the
U.
S.
Department
of
Agriculture
(
described
above),
applicants
that
have
submitted
critical
use
exemption
requests
for
cucurbits
have
cited
the
following
research
plans
as
ones
they
are
funding
or
otherwise
participating
in:

(
1)
For
Michigan
cucurbits,
testing
is
planned
for
alternatives
to
methyl
bromide
for
control
of
P.
capsici
and
F.
oxysporum
on
cucurbits
in
Michigan.
Testing
is
planned
for
April
to
October,
2003­
2004
in
southwestern
Michigan.
Alternatives
to
be
tested
include:
furfural
(
Multiguard),
alone
and
Page
23
with
metam­
sodium,
1,3
dichloropropene
(
telone),
chloropicrin
(
100
percent),
iodomethane,
and
composted
chicken
manure.
So
far,
US
$
1.1
million
has
been
spent
on
research.

(
2)
For
Georgia
squash
and
cucumbers,
testing
is
planned
for
combinations
of
fumigants
and
herbicide
replacements.
Testing
is
planned
for
2003­
2004
in
southwest
Georgia.
Alternatives
to
be
tested
include:
chloropicrin,
1,3­
dichloropropene
(
alone
and
in
combination),
as
well
as
halosulfuron,
metolachlor,
metam­
sodium,
metam
potassium,
sulfentrazone,
and
many
combinations
of
these
chemicals.
So
far,
US
$
230,000
has
been
spent
on
research.

(
3)
For
southeastern
cucurbits,
testing
is
planned
for
various
alternatives
including
herbicides
(
metolachlor,
rimsulfuron,
dimethenamid)
in
combination
with
certain
fumigants.
In
2003,
studies
will
be
conducted
in
North
Carolina
to
evaluate
halosulfuron
and
flumioxazin
herbicides
applied
at
different
times
prior
to
planting
cucurbit
crops
for
control
of
both
yellow
and
purple
nutsedge.

Trials
with
1,3­
dichloropropene
and
1,3­
dichloropropene
+
chloropicrin
have
shown
inadequate
control
of
fungi
in
cucurbits.
However,
as
stated
earlier,
it
may
be
possible
to
incorporate
1,3­
dichloropropene
into
a
larger
fungus
management
program
involving
other
fungicides
and
cultural
control.
Iodomethane
shows
promise
in
controlling
Phytophthora
and
Fusarium
fungi
in
efficacy
trials
and
efforts
are
underway
to
register
it
for
cucurbit
crops
in
the
U.
S.
Larger
scale
field
trials
are
planned
for
iodomethane
related
to
control
of
soil
pathogens.
Research
is
also
planned
for
the
next
few
years
to
study
the
implementation
of
cultural
practices
such
as
raised
beds,
different
crop
spacing
schemes,
and
timing
of
irrigation,
to
improve
control
of
soil
fungal
pathogens
of
cucurbits.

For
nutsedge
control,
research
results
thus
far
indicate
good
control
with
halosulfuron
of
both
yellow
and
purple
nutsedge
(
selectively
over
other
weed
species).
However,
the
selectivity
of
halosulfuron
suggests
that
despite
its
effectiveness
against
nutsedge,
it
can
only
be
a
part
of
a
larger
management
regime
if
methyl
bromide
is
fully
eliminated
from
cucurbit
crops.

The
research
summarized
here
will
undoubtedly
take
several
years
to
yield
optimal
strategies
for
replacing
methyl
bromide.
Replacement
will
likely
require
multiple
techniques
simultaneously
implemented
(
regardless
of
whether
the
pests
involved
are
fungi
or
weeds).
Thus,
it
is
reasonable
to
expect
that
a
"
generalized"
IPM
approach
involving
the
judicious
use
of
the
fumigants
mentioned
in
this
section,
along
with
modifications
in
cultural
practices
can
be
developed
over
the
next
few
years.
However,
the
need
to
demonstrate
the
effectiveness
of
new
management
strategies
over
multiple
growing
seasons,
on
a
large
field
scale,
means
that
the
research
described
here
will
not
enable
total
methyl
bromide
replacement
in
cucurbits,
for
the
next
3
to
4
years,
at
least.

While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.
Page
24
Registration
Program
The
United
States
has
one
of
the
most
rigorous
programs
in
the
world
for
safeguarding
human
health
and
the
environment
from
the
risks
posed
by
pesticides.
While
we
are
proud
of
our
efforts
in
this
regard,
related
safeguards
do
not
come
without
a
cost
in
terms
of
both
money
and
time.
Because
the
registration
process
is
so
rigorous,
it
can
take
a
new
pesticide
several
years
(
3­
5)
to
get
registered
by
EPA.
It
also
takes
a
large
number
of
years
to
perform,
draft
results
and
deliver
the
large
number
of
health
and
safety
studies
that
are
required
for
registration.

The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
U.
S.
EPA
registers
pesticides
provided
its
use
does
not
impose
adverse
effects
on
humans
or
the
environment.
Under
FFDCA,
the
U.
S.
EPA
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

The
process
by
which
U.
S.
EPA
examines
the
ingredients
of
a
pesticide
to
determine
if
they
are
safe
is
called
the
registration
process.
The
U.
S.
EPA
evaluates
the
pesticide
to
ensure
that
it
will
not
have
any
unreasonable
adverse
effects
on
humans,
the
environment,
and
non­
target
species.
Applicants
seeking
pesticide
registration
are
required
to
submit
a
wide
range
of
health
and
ecological
effects
toxicity
data,
environmental
fate,
residue
chemistry
and
worker/
bystander
exposure
data
and
product
chemistry
data.
A
pesticide
cannot
be
legally
used
in
the
U.
S.
if
it
has
not
been
registered
by
U.
S.
EPA,
unless
it
has
an
exemption
from
regulation
under
FIFRA.

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
processes
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
EPA
to
initiate
its
review.
Once
the
review
process
begins,
the
average
processing
time
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
addition,
the
registrant
(
the
pesticide
applicant)
has
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
Page
25
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
methyl
bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
groundwater
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
$
13.5
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
submitted
to
the
USDA's
Cooperative
State
Research,
Education,
and
Extension
Service
methyl
bromide
alternatives
research
program
of
US$
2.5
million
per
year
has
further
ensured
that
critical
registration
issues
are
being
addressed
by
the
research
community.

Since
1997,
EPA
has
registered
the
following
chemical/
use
combinations
as
part
of
its
commitment
to
expedite
the
review
of
methyl
bromide
alternatives:

1999:
Pebulate
to
control
weeds
in
tomatoes
2000:
Phosphine
to
control
insects
in
stored
commodities
2001:
Indian
Meal
Moth
Granulosis
Virus
to
control
Indian
meal
moth
in
stored
grains
2001:
Terrazole
to
control
pathogens
in
tobacco
float
beds
2001:
Telone
applied
through
drip
irrigation
­
all
crops
2002:
Halosulfuron­
methyl
to
control
weeds
in
melons
and
tomatoes
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:

 
Iodomethane
as
a
pre­
plant
soil
fumigant
for
various
crops
 
Fosthiazate
as
a
pre­
plant
nematocide
for
tomatoes
 
Sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
stored
commodities
 
Trifloxysulfuron
sodium
as
a
pre­
plant
herbicide
for
tomatoes
 
Dazomet
as
a
pre­
plant
soil
fumigant
for
strawberries
and
tomatoes
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
issues
related
to
toxicity,
ground
water
contamination,
and
the
release
of
air
pollutants
may
pose
significant
problems
with
respect
to
some
alternatives
that
may
lead
to
use
restrictions
since
many
of
the
growing
regions
are
in
sensitive
areas
such
as
those
in
close
proximity
to
schools
and
homes.
Ongoing
research
on
alternate
fumigants
is
evaluating
ways
to
reduce
emission
under
various
application
regimes
and
examining
whether
commonly
used
agrochemicals,
such
as
fertilizers
and
nitrification
inhibitors,
could
be
used
to
rapidly
degrade
soil
fumigants.
For
example,
if
registration
of
iodomethane
or
another
alternative
occurs
in
the
near
future,
commercial
availability
and
costs
will
be
factors
that
must
be
taken
into
Page
26
consideration.

It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
registering
those
alternatives
is
not
the
end
of
the
story.
Those
alternatives
must
be
trialed
by
users
and
must
be
finally
adopted,
which
takes
time.
Allowing
for
users
to
trial
alternatives,
so
farmers
can
adopt
them,
also
involves
time.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
In
an
effort
to
reduce
related
time
frames,
the
United
States
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

11.
Conclusion
and
Policy
Issues
Associated
with
the
Nomination
In
summary,
a
review
of
the
critical
use
exemption
criteria
in
Decision
IX/
6
demonstrates
that
the
Parties
clearly
understood
the
many
issues
that
make
methyl
bromide
distinctly
different
from
the
industrial
chemicals
previously
addressed
by
the
Parties
under
the
essential
use
process.
It
is
now
the
challenge
of
the
MBTOC,
TEAP
and
the
Parties
to
consider
the
national
submission
of
critical
use
nominations
in
the
context
of
those
criteria,
and
the
information
requirements
established
under
Decision
XIII/
11.

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
of
the
methyl
bromide
alternatives
included
in
the
MBTOC
list,
only
one
(
metamsodium
appears
to
have
some
technical
efficacy,
and
only
against
nutsedges
affecting
the
southeastern
States
in
the
U.
S.
Even
in
this
case,
the
estimated
yield
losses
incurred
by
reliance
on
metam­
sodium
are
likely
to
be
economically
devastating
for
growers
in
these
regions.
While
some
of
the
other
alternatives
hold
promise
against
either
fungal
pathogens
or
nutsedge
weeds,
they
cannot
be
used
as
single
alternatives
to
methyl
bromide.
Research
over
multiple
years
is
needed
before
a
combination
of
management
techniques,
incorporating
all
alternatives
that
have
some
efficacy,
will
be
able
to
take
the
place
of
methyl
bromide.
Without
the
methyl
bromide
exemption
for
2005
and
2006,
growers
of
cucumbers,
melons
and
squash
in
the
eight
states
are
not
expected
to
be
able
to
maintain
their
annual
crop
values
at
levels
comparable
to
those
of
1997­
2001,
due
to
the
current
lack
of
effective
alternatives
to
methyl
bromide
to
control
target
pests,
which
would
result
in
significantly
lower
than
historical
yields.

In
addition,
we
have
demonstrated
that
the
U.
S.
continues
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
in
cucurbits
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
unreasonable
adverse
effects
to
human
health
and
the
environment,
is
long
and
rigorous.
Therefore,
the
U.
S.
need
for
methyl
bromide
for
cucurbits
will
be
maintained
for
the
period
being
requested.

In
reviewing
this
nomination,
we
believe
that
it
is
important
for
the
MBTOC,
the
TEAP
and
the
Parties
to
understand
some
of
the
policy
issues
associated
with
our
request.
A
discussion
of
those
Page
27
follows:

a.
Request
for
Aggregate
Exemption
for
All
Covered
Methyl
Bromide
Uses:
As
mandated
by
Decision
XIII/
11,
the
nomination
information
that
is
being
submitted
with
this
package
includes
information
requested
on
historic
use
and
estimated
need
in
individual
sectors.
That
said,
we
note
our
agreement
with
past
MBTOC
and
TEAP
statements
which
stress
the
dynamic
nature
of
agricultural
markets,
uncertainty
of
specific
production
of
any
one
crop
in
any
specific
year,
the
difficulty
of
projecting
several
years
in
advance
what
pest
pressures
might
prevail
on
a
certain
crop,
and,
the
difficulty
of
estimating
what
a
particular
market
for
a
specific
crop
might
look
like
in
a
future
year.
We
also
concur
with
the
MBTOC's
fear
that
countries
that
have
taken
significant
efforts
to
reduce
methyl
bromide
use
and
emissions
through
dilution
with
chloropicrin
may
be
experiencing
only
short
term
efficacy
in
addressing
pest
problems.
On
the
basis
of
those
factors,
we
urge
the
MBTOC
and
the
TEAP
to
follow
the
precedent
established
under
the
essential
use
exemption
process
for
Metered
Dose
Inhalers
(
MDIs)
in
two
key
areas.

First,
because
of
uncertainties
in
both
markets
and
the
future
need
for
individual
active
moieties
of
drugs,
the
TEAP
has
never
provided
a
tonnage
limit
for
each
of
the
large
number
of
active
moieties
found
in
national
requests
for
a
CFC
essential
use
exemption
for
MDIs,
but
has
instead
recommended
an
aggregate
tonnage
exemption
for
national
use.
This
has
been
done
with
an
understanding
that
the
related
country
will
ensure
that
the
tonnage
approved
for
an
exemption
will
be
used
solely
for
the
group
of
active
moieties/
MDIs
that
have
been
granted
the
exemption.
We
believe
that
the
factors
of
agricultural
uncertainty
surrounding
both
pest
pressures
in
future
year
crops,
and
efficacy
of
reduced
methyl
bromide
application
provide
an
even
stronger
impetus
for
using
a
similar
approach
here.
The
level
of
unpredictability
in
need
leads
to
a
second
area
of
similarity
with
MDIs,
the
essential
need
for
a
review
of
the
level
of
the
request
which
takes
into
account
the
need
for
a
margin
of
safety.

b.
Recognition
of
Uncertainty
in
Allowing
Margin
for
Safety:
With
MDIs,
it
was
essential
to
address
the
possible
change
in
patient
needs
over
time,
and
in
agriculture,
this
is
essential
to
address
the
potential
that
the
year
being
requested
for
could
be
a
particularly
bad
year
in
terms
of
weather
and
pest
pressure.
In
that
regard,
the
TEAP's
Chart
2
in
Appendix
D
demonstrates
the
manner
in
which
this
need
for
a
margin
of
safety
was
addressed
in
the
MDI
area.
Specifically,
Chart
2
in
Appendix
D
tracks
national
CFC
requests
for
MDIs
compared
with
actual
use
of
CFC
for
MDIs
over
a
number
of
years.

Chart
2
in
Appendix
D
demonstrates
several
things.
First,
despite
the
best
efforts
of
many
countries
to
predict
future
conditions,
it
shows
that
due
to
the
acknowledged
uncertainty
of
out­
year
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
Page
28
made
two
to
three
years
in
advance
of
the
time
of
actual
use.

Chart
2
in
Appendix
D
also
demonstrates
that,
even
though
MDI
requests
included
a
significant
margin
of
safety,
the
nominations
were
approved
and
the
countries
receiving
the
exemption
for
MDIs
did
not
produce
the
full
amount
authorized
when
there
was
not
a
patient
need.
As
a
result,
there
was
little
or
no
environmental
consequence
of
approving
requests
that
included
a
margin
of
safety,
and
the
practice
can
be
seen
as
being
normalized
over
time.
In
light
of
the
similar
significant
uncertainty
surrounding
agriculture
and
the
out
year
production
of
crops
which
use
methyl
bromide,
we
wish
to
urge
the
MBTOC
and
TEAP
to
take
a
similar,
understanding
approach
for
methyl
bromide
and
uses
found
to
otherwise
meet
the
critical
use
criteria.
We
believe
that
this
too
would
have
no
environmental
consequence,
and
would
be
consistent
with
the
Parties
aim
to
phaseout
methyl
bromide
while
ensuring
that
agriculture
itself
is
not
phased
out.

c.
Duration
of
Nomination:
It
is
important
to
note
that
while
the
request
included
for
the
use
above
appears
to
be
for
a
single
year,
the
entire
U.
S.
request
is
actually
for
two
years
 
2005
and
2006.
This
multi­
year
request
is
consistent
with
the
TEAP
recognition
that
the
calendar
year
does
not,
in
most
cases,
correspond
with
the
cropping
year.
This
request
takes
into
account
the
facts
that
registration
and
acceptance
of
new,
efficacious
alternatives
can
take
a
long
time,
and
that
alternatives
must
be
tested
in
multiple
cropping
cycles
in
different
geographic
locations
to
determine
efficacy
and
consistency
before
they
can
be
considered
to
be
widely
available
for
use.
Finally,
the
request
for
multiple
years
is
consistent
with
the
expectation
of
the
Parties
and
the
TEAP
as
evidenced
in
the
Parties
and
MBTOC
request
for
information
on
the
duration
of
the
requested
exemption.
As
noted
in
the
Executive
Summary
of
the
overall
U.
S.
request,
we
are
requesting
that
the
exemption
be
granted
in
a
lump
sum
of
9,920,965
kilograms
for
2005
and
9,445,360
kilograms
for
2006.
While
it
is
our
hope
that
the
registration
and
demonstration
of
new,
cost
effective
alternatives
will
result
in
even
speedier
reductions
on
later
years,
the
decrease
in
our
request
for
2006
is
a
demonstration
of
our
commitment
to
work
toward
further
reductions
in
our
consumption
of
methyl
bromide
for
critical
uses.
At
this
time,
however,
we
have
not
believed
it
possible
to
provide
a
realistic
assessment
of
exactly
which
uses
would
be
reduced
to
account
for
the
overall
decrease.

12.
Contact
Information
For
further
general
information
or
clarifications
on
material
contained
in
the
U.
S.
nomination
for
critical
uses,
please
contact:

Primary
Contact:
John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
Page
29
e­
mail:
ThompsonJE2@
state.
gov
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
13.
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Shilling,
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A.
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B.,
R.
Charudattan,
W.
M.
Stall,
and
B.
J.
Brecke.
2000.
"
Field
efficacy
of
Dactylaria
higginsii
as
a
bioherbicide
for
the
control
of
purple
nutsedge
(
Cyperus
rotundus)."
Weed
Technology
4(
1):
1

6.

Holm,
L.
G.,
D.
L.
Plucknett,
J.
V.
Pancho,
and
J.
P.
Herberger.
1977.
The
World's
Worst
Weeds:
Distribution
and
Biology.
East­
West
Center,
University
Press
of
Hawaii,
Honolulu.
609
pp.

Horowitz,
M.
1972.
"
Effects
of
desiccation
and
submergence
on
the
viability
of
rhizome
fragments
of
bermudagrass
and
johnsongrass
and
tubers
of
nutsedge."
Israel
J.
Agric.
Res.
22
(
4):
215

220.
Page
30
Munn.
D.
A.
1992.
"
Comparison
of
shredded
newspaper
and
wheat
straw
as
crop
mulches."
Hoert
technol.
2:
361
­
366.
Nerson,
H.
1989.
"
Weed
competition
in
muskmelon
and
its
effects
on
yield
and
fruit
quality."
Crop
Prot.
8:
439­
442.

Patterson,
D.
T.
1998.
"
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch."
Weed
Technol.
12:
275­
280.

hatak,
S.
C.,
D.
R.
Sumner,
H.
D.
Wells,
D.
K.
Bell,
and
N.
C.
Glaze.
1983.
"
Biological
control
of
yellow
nutsedge,
Cyperus
esculentus,
with
the
indigenous
rust
fungus
Puccinia
canaliculata."
Science.
219:
1446

1448.

Schrader,
W.
L.,
J.
L.
Aguiar,
and
K.
S.
Mayberry.
2002.
"
Cucumber
production
in
California."
University
of
California
Agriculture
and
Natural
Resources.
Publication
8050.
http://
anrcatalog.
ucdavis.
edu/
pdf/
8050.
pdf
Thullen
R.
J.,
and
P.
E.
Keeley.
1979.
Seed
production
and
germination
in
Cyperus
esculentus
and
Cyperus
rotundus.
Weed
Sci.
27
(
5):
502

505.

UNEP
(
United
Nations
Environment
Programme).
1998.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
1998
assessment
of
alternatives
to
methyl
bromide.
p.
49.
USDA.
2000.
Vegetables,
Annual
Summary.
NASS
(
National
Agricultural
Statistical
Service).

USDA.
2002.
Vegetables,
Annual
Summary.
NASS
(
National
Agricultural
Statistical
Service).

Webster,
T.
M.
2000.
Nutsedge
(
Cyperus
spp.)
"
Eradication:
Impossible
Dream?"
In:
Riley,
L.
E.,
R.
K.
Dumroese,
and
T.
D.
Landis
(
eds.).
National
Nursery
Proceedings
RMRS­
P­
000.
USDA
Forest
Service.
Ogden,
Utah.

Webster,
T.
M.
,
and
G.
E.
Macdonald.
2001(
b).
"
A
survey
of
weeds
in
various
crops
in
Georgia."
Weed
Technol.
15:
771­
790.
Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2002.
"
Methyl
bromide
alternatives
in
a
bell
pepper

squash
rotation."
Crop
Prot.
20
(
7):
605

614.

William,
R.
D.,
and
G.
F.
Warren.
1975.
"
Competition
between
purple
nutsedge
and
vegetables."
Weed
Sci.
23:
317­
323.

14.
Appendices.

Appendix
A:
List
of
Critical
Use
Exemption
(
CUE)
Requests
for
the
Cucurbit
Crop
Sector
in
the
U.
S.

CUE
02­
0005,
Michigan
Cucurbit
Page
31
CUE
02­
0042,
Southeastern
Cucurbit
Consortium
CUE
02­
0048,
Georgia
Fruit
and
Vegetable
Growers
Association
­
Squash
CUE
02­
0051,
Georgia
Fruit
and
Vegetable
Growers
Association
­
Cucumber
CUE
02­
0052,
Georgia
Fruit
and
Vegetable
Growers
Association
­
Melon
Page
32
Appendix
B.
Spreadsheets
Supporting
Economic
Analyses.

This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
subregions
or
production
systems.
A
baseline
analysis
was
done
to
establish
the
outcome
of
treating
with
methyl
bromide
for
each
of
these
scenarios.
Therefore,
the
rows
of
the
tables
correspond
to
the
production
scenarios,
with
each
production
scenario
accounting
for
row
and
the
alternative(
s)
accounting
for
additional
rows.

The
columns
of
the
table
correspond
to
the
estimated
impacts
for
each
scenario.
(
The
columns
of
the
table
are
spread
over
several
pages
because
they
do
not
fit
onto
one
page.)
The
impacts
for
the
methyl
bromide
baseline
are
given
as
zero
percent,
and
the
impacts
for
the
alternatives
are
given
relative
to
this
baseline.
Loss
estimates
include
analyses
of
yield
and
revenue
losses,
along
with
estimates
of
increased
production
costs.
Losses
are
expressed
as
total
losses,
as
well
as
per
unit
treated
and
per
kilogram
of
methyl
bromide.
Impacts
on
profits
are
also
provided.

After
the
estimates
of
economic
impacts,
the
tables
contain
basic
information
about
the
production
systems
using
methyl
bromide.
These
columns
include
data
on
output
price,
output
volume,
and
total
revenue.
There
are
also
columns
that
include
data
on
methyl
bromide
prices
and
amount
used,
along
with
data
on
the
cost
of
alternatives,
and
amounts
used.
Additional
columns
describe
estimates
of
other
production
(
operating)
costs,
and
fixed/
overhead
costs.

The
columns
near
the
end
of
the
tables
combine
individual
costs
into
an
estimate
of
total
production
costs,
and
compare
total
costs
to
revenue
in
order
to
estimate
profits.
Finally,
the
last
several
columns
contain
the
components
of
the
loss
estimates.
Page
33
#
Notes
1
alternative
assumed
to
cost
the
same
as
MeBr
2
applicant
statistics,
10%
yield
loss
in
squash,
5%
losses
in
following
cabbage
3
5%
yield
loss
in
squash,
no
losses
in
following
cabbage
4
25%
yield
loss
in
squash,
no
losses
in
following
cabbage
5
applicant
statistics,
10%
yield
loss
in
cantaloup
and
squash
6
applicant
statistics,
10%
yield
loss
in
cantaloup
and
squash,
no
losses
in
cabbage
7
applicant
statistics,
5%
yield
loss
in
cantaloup,
no
yield
losses
in
following
crops
Page
34
8
applicant
statistics,
25%
yield
loss
in
cantaloup,
no
yield
losses
in
following
crops
Page
35
*
lb
ai
that
would
be
applied/
acre
=
application
rate
for
the
alternatives
or
requested
application
rate
for
MBr.
Page
36
*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
Page
37
Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.
She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.
(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)
cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

William
John
Chism
(
Lead
Biologist).
Bill
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
He
evaluates
the
efficacy
of
pesticides
for
weed
and
insect
control.
He
earned
his
Ph.
D.
(
Weed
Science)
from
Virginia
Polytechnic
Institute
and
State
University
(
Blacksburg),
a
Master
of
Science
(
Plant
Physiology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Agriculture)
from
California
Polytechnic
State
University
(
San
Luis
Obispo).
Dr.
Chism
is
a
1978
graduate
of
The
University
of
California
(
Davis).
For
ten
years
prior
to
joining
the
EPA
Dr.
Chism
held
research
scientist
positions
at
several
speciality
chemical
companies,
conducting
and
evaluating
research
on
pesticides.

Technical
Team
Jonathan
J.
Becker
(
Biologist)
Jonathan
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Scientific
Advisor
within
the
Office
of
Pesticides
Programs.
In
this
position
he
leads
the
advancement
of
scientific
methods
and
approaches
related
to
the
development
of
pesticides
use
information,
the
assessment
of
impacts
of
pesticides
regulations,
and
the
evaluation
of
the
benefits
from
the
use
of
pesticides.
He
earned
his
Ph.
D.
(
Zoology)
from
The
University
of
Florida
(
Gainesville)
and
a
Masters
of
Science
(
Biology/
Zoology)
from
Idaho
State
University
(
Pocatello).
Dr.
Becker
is
a
graduate
of
Idaho
State
University.
Prior
to
joining
EPA,
Dr.
Becker
worked
as
a
senior
environmental
scientist
with
an
environmental
consulting
firm
located
in
Virginia.

Diane
Brown­
Rytlewski
(
Biologist)
Diane
is
the
Nursery
and
Landscape
IPM
Integrator
at
Michigan
State
University,
a
position
she
has
held
since
2000.
She
acts
as
liaison
between
industry
and
the
university,
facilitating
research
partnerships
and
cooperative
relationships,
developing
outreach
programs
and
resource
materials
to
further
the
adoption
of
IPM.
Ms.
Rytlewski
holds
a
Master
of
Science
(
Plant
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.
Located
in
the
Department
of
Plant
Pathology
of
the
Page
38
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

Nancy
Burrelle
(
Biologist).
Nancy
Burelle
is
a
Research
Ecologist
with
USDA's
Agricultural
Research
Service,
currently
working
on
preplant
alternatives
to
methyl
bromide.
She
earned
both
her
Ph.
D.
and
Master
of
Science
degrees
(
both
in
Plant
Pathology)
from
Auburn
University
(
Auburn).

Linda
Calvin
(
Economist).
Linda
Calvin
is
an
agricultural
economist
with
USDA's
Economic
Research
Service,
specializing
in
research
on
topics
affecting
fruit
and
vegetable
markets.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Berkeley).

Kitty
F.
Cardwell
(
Biologist).
Kitty
has
been
the
National
Program
Leader
in
Plant
Pathology
for
the
U.
S.
Department
of
Agriculture
Cooperative
State
Research,
Extension
and
Education
Service
since
2001.
In
this
role
she
administrates
all
federally
funded
research
and
extension
related
to
plant
pathology,
of
the
Land
Grant
Universities
throughout
the
U.
S.
She
earned
her
Ph.
D.
(
Phytopathology)
from
Texas
A&
M
University
(
College
Station).
Dr.
Cardwell
is
a
1976
graduate
of
The
University
of
Texas
(
Austin)
cum
laude
(
Botany).
For
twelve
years
prior
to
joining
USDA
Dr.
Cardwell
managed
multinational
projects
on
crop
disease
mitigation
and
food
safety
with
the
International
Institute
of
Tropical
Agriculture
in
Cotonou,
Bénin
and
Ibadan,
Nigeria.

William
Allen
Carey
(
Biologist).
Bill
is
a
Research
Fellow
in
pest
management
for
southern
forest
nurseries
,
supporting
the
Auburn
University
Southern
Forest
Nursery
Management
Cooperative.
He
is
the
author
of
numerous
articles
on
the
use
of
alternative
fumigants
to
methyl
bromide
in
tree
nursery
applications.
He
earned
his
Ph.
D.
(
Forest
Pathology)
from
Duke
University
(
Durham)
and
a
Master
of
Science
(
Plant
Pathology
)
from
The
University
of
Florida
(
Gainesville).
Dr.
Carey
is
a
nationally
recognized
expert
in
the
field
of
nursery
pathology.

Margriet
F.
Caswell
(
Economist).
Margriet
has
been
with
the
USDA
Economic
Research
Service
since
1991.
She
has
held
both
technical
and
managerial
positions,
and
is
now
a
Senior
Research
Economist
in
the
Resource,
Technology
&
Productivity
Branch,
Resource
Economics
Division.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
the
University
of
California
(
Berkeley).
Dr.
Caswell
also
received
a
Master
of
Science
(
Resource
Economics)
and
Bachelor
of
Science
(
Natural
Resource
Management)
from
the
University
of
Rhode
Island
(
Kingston).
Prior
to
joining
USDA,
Dr.
Caswell
was
a
member
of
both
the
Environmental
Studies
and
Economics
faculties
at
the
University
of
California
at
Santa
Barbara.

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
Page
39
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­
Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,
genetic
manipulation
of
microorganisms.

Daniel
Chellemi
(
Biologist).
Dan
has
been
a
research
plant
pathologist
with
the
U.
S.
Department
of
Agriculture
since
1997.
His
research
speciality
is
the
ecology,
epidemiology,
and
management
of
soilborne
plant
pathogens.
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.
Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).

Angel
Chiri
(
Biologist).
Angel
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
California
State
University
(
Los
Angeles).
Prior
to
joining
EPA
Dr.
Chiri
was
a
pest
and
pesticide
management
advisor
for
the
U.
S.
Agency
for
International
Development
working
mostly
in
Latin
America
on
IPM
issues.

Colwell
Cook
(
Biologist).
Colwell
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
She
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
She
earned
her
Ph.
D.
(
Entomology)
from
Purdue
University
(
West
Lafayette)
and
has
a
Master
of
Science
(
Entomology)
from
Louisiana
State
University
(
Baton
Rouge).
Dr.
Cook
is
a
1979
graduate
of
Clemson
University.
Prior
to
joining
EPA
Dr.
Cook
held
several
faculty
positions
at
Wabash
College
(
Crawfordsville)
and
University
of
Evansville
(
Evansville).

Julie
B.
Fairfax
(
Biologist)
Julie
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
currently
serves
as
a
senior
biologist
in
the
Biological
and
Economics
Analysis
Division,
and
has
previously
served
as
a
Team
Leader
in
other
divisions
within
the
Office
of
Pesticides
Programs.
She
has
held
several
technical
positions
specializing
in
the
registration,
re­
registration,
special
review
and
regulation
of
fungicidal,
antimicrobial,
and
wood
preservative
pesticides.
Ms.
Fairfax
is
a
1989
graduate
of
James
Madison
University
(
Harrisonburg,
VA)
where
she
earned
her
degree
in
Biology.
Prior
to
joining
EPA,
Julie
worked
as
a
laboratory
technician
for
the
Virginia
Poultry
Industry.

John
Faulkner
(
Economist)
John
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
Page
40
1989.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
He
earned
his
Ph.
D.
(
Economics)
from
the
University
of
Colorado
(
Boulder)
and
holds
a
Master's
of
Business
Administration
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Faulkner
is
a
1965
graduate
of
the
University
of
Colorado
(
Boulder).
Prior
to
joining
EPA
was
a
member
of
the
economics
faculty
of
the
Rochester
Institute
of
Technology
(
Rochester),
The
University
of
Colorado
(
Boulder)
and
of
the
Colorado
Mountain
College
(
Aspen).

Clara
Fuentes
(
Biologist).
Clara
has
been
with
the
U.
S.
Environmental
Protection
agency
since
1999,
working
in
the
Philadelphia,
Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.

Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
and
benefits
of
pesticide
use
at
the
University
of
Illinois
(
Urbana).
Dr.
Grube
has
been
a
co­
author
of
a
number
of
journal
articles
in
various
areas
of
pesticide
economics
LeRoy
Hansen
(
Economist).
LeRoy
Hansen
is
currently
employed
as
an
Agricultural
Economist
for
the
USDA
Economic
Research
Service,
Resource
Economics
Division
in
the
Resources
and
Environmental
Policy
Branch.
He
received
his
Ph.
D.
in
resource
economics
from
Iowa
State
University
(
Ames)
in
1986.
During
his
16
years
at
USDA,
Dr.
Hansen
has
published
USDA
reports,
spoken
at
profession
meetings,
and
appeared
in
television
and
radio
interviews.

Frank
Hernandez
(
Economist).
Frank
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1991.
He
is
a
staff
economist
at
the
Biological
and
Economic
Analysis
Division
of
the
Office
of
Pesticide
Programs.
He
holds
degrees
in
Economics
and
Political
Science
from
the
City
University
of
Page
41
New
York.

Arnet
W.
Jones
(
Biologist).
Arnet
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1990.
He
has
had
several
senior
technical
and
management
positions
and
currently
serves
as
Chief
of
the
Herbicide
and
Insecticide
Branch,
Biological
and
Economic
Analysis
Division,
Office
of
Pesticide
Programs.
Prior
to
joining
EPA
he
was
Senior
Agronomist
at
Development
Assistance
Corporation,
a
Washington,
D.
C.
firm
that
specialized
in
international
agricultural
development.
He
holds
a
Master
of
Science
(
Agronomy)
from
the
University
of
Maryland
(
College
Park).

Hong­
Jin
Kim
(
Economist).
Jin
has
been
an
economist
at
the
National
Center
for
Environmental
Economics
at
the
U.
S.
Environmental
Protection
Agency
(
EPA)
since
1998.
His
primary
areas
of
research
interest
include
environmental
cost
accounting
for
private
industries
He
earned
his
Ph.
D.
(
Environmental
and
Resource
Economics)
from
The
University
of
California
(
Davis)
and
holds
a
Master
of
Science
from
the
same
institution.
Dr.
Kim
is
a
1987
graduate
of
Korea
University
(
Seoul)
with
a
Bachelor
of
Arts
(
Economics).
Prior
to
joining
the
U.
S.
EPA,
Dr.
Kim
was
an
assistant
professor
at
the
University
of
Alaska
(
Anchorage)
and
an
economist
at
the
California
Energy
Commissions.
Dr.
Kim
is
the
author
of
numerous
articles
in
the
fields
of
resource
and
environmental
economics.

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)
researching
Agricultural
Sciences
Center
in
Parlier,
CA.
He
joined
ARS
in
June
of
1971.

Sean
Lennon
(
Biologist).
Sean
is
a
Biologist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
He
will
receive
his
M.
S.
in
Plant
and
Environmental
Science
in
December
2003
from
Clemson
University
(
Clemson).
Mr.
Lennon
is
a
graduate
of
Georgia
College
&
State
University
(
Milledgeville)
where
he
earned
a
Bachelor
of
Science
(
Biology).
Sean
is
conducting
research
in
Integrated
Pest
Management
of
Southeastern
Peaches.
He
has
eight
years
of
experience
in
the
commercial
peach
industry.

Nikhil
Mallampalli
(
Biologist).
Nikhil
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
is
an
entomologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
and
analysis
of
the
impacts
of
risk
mitigation
on
pest
management.
Dr.
Mallampalli
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
holds
a
Master
of
Science
(
Entomology)
from
the
samr
institution.
Prior
to
joining
the
EPA,
he
worked
as
a
postdoctoral
research
fellow
at
Michigan
State
University
(
East
Lansing)
on
IPM
projects
designed
to
reduce
reliance
on
pesticides
in
small
fruit
production.
Page
42
Tom
Melton
(
Biologist).
Tom
has
been
a
member
of
the
Plant
Pathology
faculty
at
North
Carolina
State
University
since
1987.
Starting
as
an
assistant
professor
and
extension
specialist,
Tom
has
become
the
Philip
Morris
Professor
at
North
Carolina
State
University.
His
primary
responsibilities
are
to
develop
and
disseminate
disease
management
strategies
for
tobacco.
Dr.
Melton
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
(
Pest
Management)
degree
from
North
Carolina
State
University
(
Raleigh).
He
is
a
1978
graduate
of
Norht
Carolina
State
University
(
Raleigh)
Prior
to
joining
the
North
Carolina
State
faculty,
Dr.
Melton
was
a
member
of
the
faculty
at
The
University
of
Illinois
(
Urbana­
Champaign).

Richard
Michell
(
Biologist).
Rich
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1972.
He
is
a
nematologist/
plant
pathologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
with
special
emphasis
on
fungicide
and
nematicide
use
and
the
development
of
risk
reduction
options
for
fungicides
and
nematicides.
Dr.
Michell
earned
his
Ph.
D.
(
Plant
Pathology/
Nematology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
degree
(
Plant
Pathology/
Nematology)
from
The
University
of
Georgia
(
Athens).

Lorraine
Mitchell
(
Economist).
Lorraine
has
been
an
agricultural
economist
with
the
U.
S.
Department
of
Agriculture,
Economic
Research
Service
since
1998.
She
works
on
agricultural
trade
issues,
particularly
pertaining
to
consumer
demand
in
the
EU
and
emerging
markets.
Dr.
Mitchell
earned
her
Ph.
D.
(
Economics)
from
The
University
of
California
(
Berkeley).
Prior
to
joining
ERS,
Dr.
Mitchell
was
a
member
of
the
faculty
of
the
School
of
International
Service
of
The
American
University
(
Washington)
and
a
research
assistant
at
the
World
Bank.

Thuy
Nguyen
(
Chemist).
Thuy
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997,
as
a
chemist
in
the
Office
of
Pesticides
Program.
She
assesses
and
characterizes
ecological
risk
of
pesticides
in
the
environment
as
a
result
of
agricultural
uses.
She
earned
her
degrees
of
Master
of
Science
(
Chemistry)
from
the
University
of
Delaware
and
Bachelor
of
Science
(
Chemistry
and
Mathematics)
from
Mary
Washington
College
(
Fredericksburg,
VA).
Prior
to
joining
the
EPA,
Ms
Nguyen
held
a
research
and
development
scientist
position
at
Sun
Oil
company
in
Marcus
Hook,
PA,
then
managed
the
daily
operation
of
several
EPA
certified
laboratories
for
the
analyses
of
pesticides
and
other
organic
compounds
in
air,
water,
and
sediments.

Jack
Norton(
Biologist).
Jack
has
worked
for
the
U.
S.
Department
of
Agriculture
Interregional
research
Project
#
4
(
IR­
4)
as
a
consultant
since
1998.
The
primary
focus
of
his
research
is
the
investigation
of
potential
methyl
bromide
replacement
for
registration
on
minor
crops.
He
is
an
active
member
of
the
USDA/
EPA
Methyl
Bromide
Alternatives
Working
Group.
Dr,
Norton
earned
his
Ph.
D.
(
Horticulture)
from
Texas
A&
M
University
(
College
Station)
and
holds
a
Master
of
Science
(
Horticultural
Science)
from
Oklahoma
State
University(
Stillwater).
He
is
a
graduate
of
Oklahoma
State
University
(
Stillwater).
Prior
to
joining
the
IR­
4
program,
Dr.
Norton
worked
in
the
crop
protection
industry
for
27
years
where
he
was
responsible
for
the
development
and
registration
of
a
number
of
important
products.
Page
43
Olga
Odiott
(
Biologist)
Olga
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Biologist
within
the
Office
of
Science
Coordination
and
Policy.
In
this
position
she
serves
as
Designated
Federal
Official
and
liaison
on
behalf
of
the
Office
of
Pesticide
Programs
and
the
FIFRA
Scientific
Advisory
Panel,
an
independent
peer
review
body
that
provides
advice
to
the
Agency
on
issues
concerning
the
impact
of
pesticides
on
health
and
the
environment.
She
holds
a
Masters
of
Science
(
Plant
Pathology)
from
the
University
of
Puerto
Rico
(
San
Juan).
Prior
to
joining
EPA,
Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

Craig
Osteen(
Economist).
Craig
has
been
with
the
U.
S.
Department
of
Agriculture
for
over
20
years.
He
currently
is
with
the
Economic
Research
Service
in
the
Production
Management
and
Technology
Branch,
Resource
Economics
Division.
He
primary
areas
of
interest
relate
to
issues
of
pest
control,
including
pesticide
regulation,
integrated
pest
management,
and
the
methyl
bromide
phase
out.
Dr.
Osteen
earned
his
Ph.
D.
(
Natural
Resource
Economics)
from
Michigan
State
University
(
East
Lansing).

Elisa
Rim
(
Economist).
Elisa
is
an
Agricultural
Economist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
She
earned
her
Master
of
Science
(
Agricultural
Economics)
from
The
Ohio
State
University
(
Columbus)
and
holds
a
Bachelor
of
Arts
(
Political
Science)
from
the
same
institution.
She
has
conducted
research
in
environmental
economics
and
developed
a
cost
analysis
optimization
model
for
stream
naturalization
projects
in
northwest
Ohio.

Erin
Rosskopf
(
Biologist).
Erin
received
her
PhD
from
the
Plant
Pathology
Department,
University
of
Florida,
Gainesville
in
1997.
She
is
currently
a
Research
Microbiologist
with
the
USDA,
ARS
and
has
served
in
this
position
for
5
years.

Carmen
L.
Sandretto
(
Agricultural
Economist).
Carmen
has
been
with
the
Economic
Research
Service
of
the
U.
S.
Department
of
Agriculture
for
over
30
years
in
a
variety
of
assignments
at
several
field
locations,
and
since
1985
in
Washington,
DC.
He
has
worked
on
a
range
of
natural
resource
economics
issues
and
in
recent
years
on
soil
conservation
and
management,
pesticide
use
and
water
quality,
and
small
farm
research
studies.
Mr.
Sandretto
holds
a
Master
of
Arts
degree
(
Economics)
from
Harvard
University
(
Cambridge)
and
a
Master
of
Science
(
Agricultural
Economics)
from
The
University
of
Wisconsin
(
Madison).
Mr
Sandretto
is
a
graduate
of
Michigan
State
University
(
East
Lansing).
Prior
to
serving
in
Washington,
D.
C.
he
was
a
member
of
the
economics
faculty
at
Michigan
State
University
and
at
the
University
of
New
Hampshire
(
Durham).

Judith
St.
John
(
Biologist).
Judy
has
been
with
the
USDA's
Agricultural
Research
Service
since
1967.
She
currently
serves
as
Associate
Deputy
Administrator
and
as
such
she
is
responsible
for
the
Department's
intramural
research
programs
in
the
plant
sciences,
including
those
dealing
with
pre­
and
post­
harvest
alternatives
to
methyl
bromide.
Dr.
St.
John
earned
her
Ph.
D.
(
Plant
Physiology)
from
The
University
of
Florida
(
Gainesville).
Page
44
James
Throne
(
Biologist).
Jim
is
a
Research
Entomologist
with
the
U.
S.
Department
of
Agriculture's
Agricultural
Research
Service
and
Research
Leader
of
the
Biological
Research
Unit
at
the
Grain
Marketing
and
Production
Research
Center
in
Manhattan,
Kansas.
He
conducts
research
in
insect
ecology
and
development
of
simulation
models
for
improving
integrated
pest
management
systems
for
stored
grain
and
processed
cereal
products.
Other
current
areas
of
research
include
investigating
seed
resistance
to
stored­
grain
insect
pests
and
use
of
near­
infrared
spectroscopy
for
detection
of
insect­
infested
grain.
Jim
has
been
with
ARS
since
1985.
Dr.
Throne
earned
his
Ph.
D.
(
Entomology)
in
1983
from
Cornell
University
(
Ithaca)
and
earned
a
Master
of
Science
Degree
(
Entomology)
in
1978
from
Washington
State
University
(
Pullman).
Dr.
throne
is
a
1976
graduate
(
Biology)
of
Southeastern
Massachusetts
University
(
N.
Dartmouth).

Thomas
J.
Trout
(
Agricultural
Engineer).
Tom
has
been
with
the
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
since
1982.
He
currently
serves
ar
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.
trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

J.
Bryan
Unruh
(
Biologist).
Bryan
is
Associate
Professor
of
Environmental
Horticulture
at
The
University
of
Florida
(
Milton)
and
an
extension
specialist
in
turfgrass.
He
leads
the
statewide
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.

David
Widawsky
(
Chief,
Economic
Analysis
Branch).
David
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1998.
He
has
also
served
as
an
economist
and
a
team
leader.
As
branch
chief,
David
is
responsible
for
directing
a
staff
of
economists
to
conduct
economic
analyses
in
support
of
pesticide
regulatory
decisions.
He
earned
his
Ph.
D.
(
Development
and
Applied
Economics)
from
Stanford
University
(
Palo
Alto),
and
a
Master
of
Science
(
Agricultural
Economics)
from
Colorado
State
University
(
Fort
Collins).
Dr.
Widawsky
is
a
1987
graduate
(
Plant
and
Soil
Biology,
Agricultural
Economics)
of
the
University
of
California
(
Berkeley).
Prior
to
joining
EPA,
Dr.
Widawsky
conducted
research
on
the
economics
of
integrated
pest
management
in
Asian
rice
production,
while
serving
as
an
agricultural
economist
at
the
International
Rice
Research
Institute
(
IRRI)
in
the
Philippines.

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
farmer
decision­
making,
especially
pertaining
to
issues
of
soil
Page
45
fertility
and
soil
conservation
and
of
pesticide
choice.
Dr.
Wyatt
earned
his
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Davis).
Dr.
Wyatt
holds
a
Master
of
Science
(
International
Agricultural
Development)
from
the
same
institution.
He
is
a
1985
graduate
of
The
University
of
Wyoming
(
Laramie).
Prior
to
joining
the
EPA,
he
worked
at
the
International
Crops
Research
Institute
for
the
Semi­
Arid
Tropics
(
ICRISAT)
and
was
based
at
the
Sahelian
Center
in
Niamey,
Niger.

Leonard
Yourman
(
Biologist).
Leonard
is
a
plant
pathologist
with
the
Biological
and
Economic
Analysis
Division
of
the
U.
S.
Environmental
Protection
Agency.
He
currently
conducts
assessments
of
pesticide
use
as
they
relate
to
crop
diseases
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
Clemson
University
(
Clemson)
and
holds
a
Master
of
Science
(
Horticulture/
Plant
Breeding)
from
Texas
A&
M
University
(
College
Station).
Dr.
Yourman
is
a
graduate
(
English
Literature)
of
The
George
Washington
University
(
Washington,
DC).
.
Prior
to
joining
EPA,
he
conducted
research
on
biological
control
of
invasive
plants
with
USDA
at
the
Foreign
Disease
Weed
Science
Research
Unit
(
Ft.
Detrick,
MD).
He
has
also
conducted
research
on
biological
control
of
post
harvest
diseases
of
apples
and
pears
at
the
USDA
Appalachian
Fruit
Research
Station
(
Kearneysville,
WV).
Research
at
Clemson
University
concerned
the
molecular
characterization
of
fungicide
resistance
in
populations
of
the
fungal
plant
pathogen
Botrytis
cinerea.

Istanbul
Yusuf
(
Economist).
Istanbul
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1998.
She
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
She
earned
her
Master
s
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.
Page
46
Appendix
D:
CHARTS
(
See
separate
electronic
file
for
CHART
1
and
CHART
2)
