2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
FOREST
TREE
SEEDLINGS
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
forest
tree
seedlings,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
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
forest
tree
seedlings
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
forest
tree
seedlings,
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
forest
tree
seedlings
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
extremely
toxic,
and
can
involve
threats
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
epidemiological
and
other
environmental
data
necessary
to
support
the
registration
request.

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
Forest
Tree
Seedlings
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
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
associated
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
forest
tree
seedling
growers
from
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.
Page
4
government.

5.
Overview
of
Agricultural
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
contribute
to
and
enable
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
mass
larger
than
the
size
of
many
countries.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
sizes
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
impact
on
the
way
agriculture
has
developed
in
the
U.
S.
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
farming
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.
developed
a
unique
brand
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
non­
labor
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
fewer
than
1
million
hired
workers.

Farming
in
the
U.
S.
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
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
nonlabor
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.
nomination
for
critical
uses
of
methyl
bromide,
the
phaseout
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
5
5b.
Forest
Tree
Seedling
Nurseries
U.
S.
forest
tree
seedling
production
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture
noted
above.
Specifically,
forest
tree
seedlings
are
grown
in
most
of
the
geographical
areas
of
the
U.
S..
As
a
consequence,
this
nomination
covers
use
in
a
variety
of
areas
with
differing
soil
and
climactic
characteristics.
Specifically,
it
covers
forest
tree
seedling
production
in
three
distinct
regions,
the
north,
south
and
west,
that
generally
face
different
pests
and
grow
slightly
different
species.

Forest
tree
nurseries
in
the
U.
S.
supply
seedlings
of
conifers
and
hardwoods
that
are
used
for
reforestation,
forest
establishment,
fiber
production,
and
wildlife
and
conservation
uses.
A
typical
forest
tree
seedling
nursery
ranges
in
size
from
40­
80
hectares.
About
55
hectares
within
a
nursery
is
available
for
growing
seedlings
in
any
given
year.
Nurseries
in
the
U.
S.
are
located
in
eight
climate
zones
(
Zones
3
to
10)
mostly
with
either
light
soils
with
0­
2
percent
organic
matter
or
medium
soils
with
2­
5
percent
organic
matter.
These
nurseries
produce
approximately
200­
300
million
bareroot
seedlings
each
year.
For
example,
in
the
southern
region
of
the
U.
S.,
nurseries
provide
forest
tree
seedlings
which
are
used
each
year
to
plant
600,000
hectares
of
forests.
Nationally,
the
majority
of
seedlings
are
species
of
conifers,
especially
pine.
In
addition,
30­
40
species
of
the
seedlings
produced
annually
are
hardwoods,
such
as
oaks,
hickory,
poplars,
and
ash.
Nurseries
produce
seedlings
adapted
to
their
respective
regional
conditions,
including
climate
and
soil
type.
Forest
tree
nurseries
are
operated
by
state
and
federal
governments,
large
commercial
companies
and
small
private
entities.
The
high
value
of
forest
tree
seedlings
is
reflected
in
the
value
of
conifer
production
in
the
U.
S.
estimated
at
over
US$
402
million
in
2000
(
USDA­
NASS,
2001).

Forest
tree
seedlings
are
valued
according
to
their
grade,
which
is
a
quality
assessment
that
includes
diameter,
root
volume,
and
seedling
height.
Seedlings
are
put
into
Grades:
#
1,
#
2,
and
culls.
The
quality
of
seedlings
is
correlated
with
the
ultimate
quality
of
the
forest
and
corresponding
long­
term
economic
and
use
benefits.
A
higher
quality
seedling
implies
better
survival
and
faster
growth.
Seedling
quality
is
reflected
in
the
price
received,
with
#
2
seedlings
valued
at
about
two­
thirds
that
of
#
1
seedlings.
Culls
cannot
be
sold
and
may
be
recycled
for
organic
matter.
Seedling
yield
and
quality
can
be
improved
by
optimizing
nursery
management
practices.
Disease
and
weed
management
strategies,
including
fumigation,
produce
healthy
seedlings
that
have
to
compete
less
for
nutrients
and
sunlight
while
maintaining
greater
ability
to
survive
under
forest
conditions.

6.
Results
of
Review
B
Determined
Need
for
Methyl
Bromide
for
Forest
Tree
Seedling
Nurseries
For
nurseries
producing
forest
tree
seedlings,
weeds,
especially
two
types
of
nutsedge,
and
fungal
pathogens
are
the
most
serious
concern.
The
critical
use
exemption
nomination
is
primarily
based
on
the
lack
of
reliable
alternatives
to
control
nutsedge
species
and
fungal
pathogens.
Nutsedge
species
interfere
with
the
intensive
production
practices
and
high
requirements
for
seedling
quality
of
this
sector.
Tree
seedlings,
of
course,
are
only
the
first
step
in
the
long
term
investment
associated
with
the
high
valued
forests,
whether
commercial
or
public.
The
implications
associated
with
forest
growth
and
health
extend
over
a
20­
40
year
period.
Seedling
quality
has
been
highly
correlated
with
Page
6
productive
and
healthy
forests
impacting
both
commercial
and
public
interests.

The
majority
of
forest
tree
nurseries
raise
conifer
seedlings
for
one
or
two
years
followed
by
one
or
two
years
of
fallow
or
cover
crops.
Therefore,
managers
typically
fumigate
a
particular
conifer
seedling
bed
with
methyl
bromide
only
once
every
3
to
4
years,
i.
e.,
only
1/
3­
1/
4
of
the
total
nursery
land
is
fumigated
each
year
to
produce
two
or
three
harvestable
forest
tree
seedling
crops
per
single
bed
fumigation.
For
hardwood
seedlings,
fumigation
is
usually
provided
prior
to
each
seedling
crop,
as
hardwood
species
are
generally
more
prone
to
root
rots
and
damping­
off
diseases.
Effective
fumigants,
such
as
methyl
bromide
permit
less
frequent
bed
fumigation
per
harvestable
seedling
crop.

Methyl
bromide
is
commonly
applied
in
combination
with
chloropicrin
with
a
methyl
bromide
component
of
67
percent
or
98
percent
(
e.
g.,
Landis
and
Campbell,
1989).
Rates
of
methyl
bromide
typically
range
between
115­
160
kg/
ha,
depending
on
the
region,
plant
species,
and
soil
type.
In
general,
warmer
and
moister
conditions
in
the
southern
U.
S.
promote
increased
pest
populations
and
require
higher
fumigation
rates
while
nurseries
in
the
cooler,
drier
western
and
northern
region
can
achieve
adequate
control
with
somewhat
lower
application
rates.
Methyl
bromide
provides
consistent
and
broad
control
over
the
target
pests,
including
severe
infestations
of
weeds,
pathogens,
(
and
where
they
are
a
problem)
nematodes.

6a.
Target
Pests
Controlled
With
Methyl
Bromide
Although
forest
nurseries
in
the
U.
S.
contend
with
a
variety
of
pests,
methyl
bromide
is
of
particular
importance
in
managing
fungal
pathogens
and
yellow
and
purple
nutsedges
(
species
of
the
Cyperus
weed)
(
Cram
and
Fraedrich,
1997).
Nutsedges
are
generally
considered
the
major
pests
of
the
forest
seedling
nurseries.
Nutsedge
is
propagated
by
tubers
formed
along
underground
rhizomes
and
corms.
During
tillage
of
the
soil,
the
underground
stems
are
broken
and
new
plants
are
established
from
either
single,
or
chains
of,
tubers.
Weeds
compete
with
the
seedlings
for
light,
nutrients,
and
water
and
reduce
the
quality
and
yield
of
seedlings
reducing
the
ability
of
nurseries
to
provide
acceptable
seedlings
for
forest
establishment.

In
addition
to
weed
problems,
forest
tree
seedling
nurseries
in
the
southern
and
northern
U.
S.
are
concerned
with
fungal
pathogens
such
as
species
of
Fusarium,
Alternaria,
Phytophthora,
Pythium
,
Rhizoctonia,
and
Macrophomina,
that
can
cause
severe
outbreaks
of
root
rots
and
damping­
off
diseases.
Significant
crop
losses
of
conifers
and
hardwood
seedlings
can
result
if
beds
are
not
properly
managed.
Nurseries
in
the
western
U.
S.
contend
with
disease­
causing
pathogens,
such
as
Pythium
spp.,
Fusarium
spp.,
Cylindrocladium
spp.,
Phytophthora
spp.,
as
well
as
yellow
nutsedge.
Of
particular
recent
concern
is
a
newly
identified
disease,
Sudden
Oak
Death,
caused
by
Phytophthora
ramorum
(
USDA­
APHIS,
2002).
Federal
and
state
quarantine
restrictions
for
movement
of
nursery
plant
material
are
currently
in
effect
in
California
and
Oregon.

6b.
Overview
of
Technical
and
Economic
Assessments
of
Alternatives
Intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
yield
and
quality
goals.
Page
7
In
spite
of
nearly
50
years
experience
with
methyl
isothiocyanate
(
MITC)
products
B
the
breakdown
active
ingredient
of
both
dazomet
and
metam­
sodium
B
their
efficacy
is
still
unpredictable.
The
inconsistency
of
MITC
products
ability
to
control
pests
may
be
due
to
the
significantly
lower
vapor
pressure
of
MITC
compared
to
methyl
bromide.
The
vapor
pressure
of
a
gas
affects
how
it
moves
through
soils.
The
uniform
dispersion
of
a
fumigant
throughout
the
soil
is
necessary
for
consistent
and
predictable
control
of
pests.
MITC­
producing
products,
while
at
times
effective,
have
been
associated
in
the
forest
tree
nursery
industry
with
inconsistent
production
and
reduced
seedling
quality
with
overall
higher
proportions
of
Grade
#
2
and
cull
seedlings.
Because
of
the
importance
placed
on
seedling
quality
(
due
to
the
high
correlation
of
quality
and
subsequent
forest
health
and
value),
failure
to
achieve
consistently
healthy
seedlings,
in
even
a
portion
of
production
beds,
can
have
a
devastating
effect
on
this
sector's
ability
to
provide
acceptable
seedlings
for
reforestation.
Both
dazomet
and
metam­
sodium
can
provide
effective
pest
management
in
some
situations,
but
they
are
unsuccessful
in
providing
consistently
high
quality
forest
tree
seedlings
especially
in
circumstances
with
high
nutsedge
and
pathogen
pressure.
Reduced
efficacy
for
both
dazomet
and
metam­
sodium
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
In
addition,
the
analysis
below
demonstrates
that
both
of
these
potential
alternatives,
when
compared
with
methyl
bromide,
are
not
economically
feasible.

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
We
begin
our
technical
and
economic
assessment
by
presenting
the
two
in­
kind
(
chemical)
alternatives
(
Table
1),
dazomet
and
metam­
sodium,
and
then
describe
the
attributes
of
the
not­
in­
kind
alternatives.

Table
1.
Methyl
bromide
Alternatives
Identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
for
Forest
Tree
Seedling
Nurseries.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Dazomet
(
Basamid
®
)
Yes
No
Metam­
sodium
(
Vapam
®
,
Busan
®
)
Yes
No
Biofumigation
No
N/
A
Solarization
No
N/
A
Crop
rotation/
Fallow
No
N/
A
Flooding
and
water
management
No
N/
A
General
IPM
(
Integrated
Pest
Management)
No
N/
A
Organic
amendments/
Compost
No
N/
A
Physical
removal/
Sanitation
No
N/
A
Plowing
and
tillage
No
N/
A
Note:
Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
viability.
Page
8
Dazomet
(
Basamid
®
)
.
Dazomet
can
be
considered
a
technically
feasible
alternative
by
itself
but
does
not
provide
consistent
control
of
nutsedge
or
pathogens
that
cause
root­
rot
and
damping­
off
(
refer
to
Target
Pests,
Section
6a).
Field
trials
using
400
kilogram
per
hectare
of
dazomet
showed
inconsistent,
non­
uniform,
and
reduced
seedling
size
(
diameter
and
height)
and
root
volume.
Using
dazomet
led
to
higher
counts
of
Grade
#
2
seedlings
and
culls
compared
to
methyl
bromide,
which
had
higher
counts
of
Grade
#
1
seedlings.

Direct
yield
losses
(
seedlings
per
hectare)
were
not
very
large
on
average,
but
there
was
a
high
degree
of
variability
in
yield
loss
estimates
reported
in
trials.
Average
or
expected
yield
losses
with
dazomet
compared
to
methyl
bromide
are
4
percent
(
with
tarping)
and
11
percent
(
without
tarping).
Data
from
studies
shows
that
yield
losses
range
from
none
to
13
percent
(
with
tarping)
and
6
percent
to
21
percent
(
without
tarping)
compared
to
methyl
bromide.
Reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
dazomet
resulted
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Soil
temperature
requirements
(
above
6

C/
optimal
12­
18

C)
for
dazomet,
due
to
vapor
pressure
properties,
constrains
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989).

Metam­
sodium
(
e.
g.,
Vapam
®
,
Busan
®
)
.
Metam
sodium
can
be
considered
a
technically
feasible
alternative
but
does
not
provide
consistent
nutsedge
and
pathogen
control
(
see
dazomet
alternative
above).
Average
yield
losses
are
approximately
6
percent
with
metam­
sodium
compared
to
methyl
bromide.
Data
from
studies
shows
that
the
range
of
yield
outcomes
with
metam­
sodium
compared
to
methyl
bromide
is
estimated
to
be
between
a
gain
of
2
percent
to
a
loss
of
11
percent.
As
with
dazomet,
seedling
quality
is
inconsistent
with
metam­
sodium
resulting
in
an
overall
higher
proportion
of
Grade
#
2
and
cull
seedlings.
As
with
dazomet,
reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
metam­
sodium
results
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Soil
temperature
requirements
(
above
4

C)
of
metam­
sodium,
due
to
vapor
pressure
properties,
can
constrain
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989).

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
An
economic
assessment
was
made
for
two
technically
feasible
in­
kind
(
chemical)
alternatives
for
the
forest
tree
seedling
nursery
sector,
dazomet
and
metam­
sodium.
A
general
cost
analysis
was
done
for
the
alternatives
and
is
reported
in
Appendix
B.
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide
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.
Page
9
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
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
forest
tree
seedling
nurseries
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.

Economic
reviewers
analyzed
potential
economic
losses
from
using
dazomet
and
metam­
sodium
because
they
are
currently
considered
technically
feasible
alternatives
for
nursery
tree
seedling
production.

Total
losses
are
similar
for
both
dazomet
and
metam
sodium.
Quantifiable
losses
originate
from
yield
losses
and
cost
increases.
Dazomet
has
slightly
smaller
yield
losses
than
metam­
sodium,
but
slightly
higher
treatment
costs.
Indirect
yield
losses
occurred
due
to
lengthening
of
the
production
cycle,
which
resulted
in
less
land
in
production
and
more
in
fallow
or
longer
time
for
seedlings
to
reach
appropriate
size.
Additional
losses
may
also
arise
due
to
a
shift
from
high
quality
Grade
#
1
seedlings
to
lower
quality
Grade
#
2,
which
causes
a
loss
of
about
30
percent
of
value,
and
more
seedlings
that
Page
10
must
be
culled.
Unfortunately,
data
were
lacking
to
measure
this
shift.
Thus,
total
losses
are
underestimated.

Table
2
provides
a
summary
of
the
estimated
economic
losses.
A
measure
of
profit
loss
is
not
included
in
Table
2
partly
because
many
nurseries
are
publicly
owned
and
seedling
prices
or
production
costs
are
subsidized.
Although
attempts
were
made
to
appropriately
value
the
seedlings
at
a
true
market
price,
losses
as
a
percentage
of
gross
revenues
and
of
net
cash
returns
should
be
viewed
with
caution.
Direct
yield
losses
are
similar
across
the
regions,
mainly
because
the
same
studies
were
used
to
predict
impacts.
The
range
of
losses
in
the
studies
is
rather
large
because
both
dazomet
and
metam­
sodium
provide
inconsistent
pest
control.
Indirect
losses
arising
from
shifts
in
the
production
cycle
were
only
quantified
for
the
Northern
region
where
the
impact
is
expected
to
be
more
pronounced
due
to
cooler
temperatures
and
longer
time
required
for
production
of
a
seedling
crop.
Changes
in
production
costs
arise
due
to
differences
between
the
costs
of
methyl
bromide
and
the
alternatives,
shifts
in
the
production
cycle
(
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period)
and
additional
expenses
such
as
supplementary
irrigation.
These
costs
vary
across
regions
and
within
the
Western
region,
which
is
highly
diverse,
because
of
differences
in
pests,
production
systems
and
regional
differences
in
costs
of
water
and
labor.
Costs
are
higher
in
the
South,
in
part
because
warmer
temperatures
increase
pest
pressure.
Page
11
Table
2.
Economic
Impact
of
Using
Dazomet
or
Metam­
Sodium
in
Place
of
Methyl
Bromide
on
Tree
Seedling
Nurseries
in
the
U.
S.
a
South
West
North
Direct
yield
loss
3%
gain
to
13%
loss
likely
5%
loss
3%
gain
to
13%
loss
likely
5%
loss
2%
gain
to
13%
loss
likely
3%
loss
Indirect
yield
loss
b
none
calculated
none
calculated
5
to
15%
loss
likely
13%
loss
Change
in
production
costs
c
US$
1930
to
2590/
ha
(
US$
780­
1050/
Acre)
11
to
15%
of
operating
costs
US$
370
to
1580/
ha
($
150­
640/
Acre)
2
to
5%
of
operating
costs
US$
640
to
1010/
ha
(
US$
260­
410/
Acre)
1
to
2%
of
operating
costs
Economic
loss
per
area
US$
1060­
6670/
ha
loss
likely
US$
3700/
ha
loss
(
US$
430­
2700/
acre
loss)
(
likely
US$
1500/
acre
loss)
US$
150
gain
to
US$
7660
ha/
loss
likely
US$
3200/
ha
loss
(
US$
60
gain
to
US$
3,100/
acre
loss)
(
likely
US$
1,300/
acre
loss)
US$
3330­
12600/
ha
loss
likely
US$
11,120/
ha
loss
(
US$
1350­
5100/
acre
loss)
(
likely
US$
4500/
acre
loss)

Economic
loss
per
amount
of
methyl
bromide
US$
3­
20/
kg
loss
likely
US$
10/
kg
loss
(
US$
1.30­
8.20/
lb
loss)
(
likely
US$
4.40/
lb
loss)
<
US$
1
gain
to
US$
26/
kg
loss
likely
US$
14/
kg
loss
(
US$
0.10
gain
to
US$
11.90/
lb
loss)
(
likely
US$
6.50/
lb
loss)
US$
9
to
US$
37/
kg
loss
likely
US$
32/
kg
loss
(
US$
4.30­
16.60/
lb
loss)
(
likely
US$
14.70/
lb
loss)

Economic
loss
as
percent
of
gross
revenues
3
to
22%
loss
likely
12%
loss
1%
gain
to
15%
loss
likely
6%
loss
5
to
19%
loss
likely
16%
loss
Economic
loss
as
percent
of
net
cash
revenues
8
to
49%
loss
likely
27%
1%
gain
to
27%
loss
likely
16%
loss
20
to
76%
loss
likely
67%
loss
aDazomet
and
metam­
sodium
have
similar
total
impacts.
bIndirect
yield
losses
arise
from
changes
in
the
production
cycle
including
longer
growing
periods
and
more
frequent
fallow.
cChange
results
from
different
costs
of
alternatives,
additional
pesticide
applications,
changes
in
production
patterns
and
additional
equipment.

Losses
per
hectare
are
relatively
large
and
are
driven
by
yield
losses
and
increased
production
costs,
particularly
in
the
southern
region.
Revenue
losses
are
particularly
sizeable
in
the
northern
region
because
cooler
temperatures
combine
to
drastically
increase
the
length
of
the
production
cycle
for
conifers
so
that
many
fewer
seedlings
are
ready
for
sale
in
any
particular
year.
The
western
region
Page
12
has
a
larger
range,
in
part
because
it
covers
much
more
variable
environmental
conditions,
from
the
Pacific
Northwest
to
Great
Plains
states.
Overall,
the
results
are
fairly
consistent
across
the
regions
and
suggest
that
the
dazomet
and
metam­
sodium
are
not
economically
viable
as
alternatives
for
methyl
bromide.
We
did
not
attempt
to
quantify
the
human
health
and
environmental
costs
associated
with
these
alternatives.
Dazomet
has
raised
concerns
about
potential
genotoxicity
and
metam­
sodium
has
been
classified
as
a
potential
human
carcinogen
(
US­
GAO,
1995).
Concerns
over
groundwater
contamination
with
methyl
isothiocyanate
are
associated
with
the
use
of
both
chemicals.

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
forest
tree
seedling
nurseries,
non­
chemical
alternatives.
Table
1
contains
a
summary
of
the
technical
assessment,
which
is
that
none
of
the
not­
in­
kind
alternatives
were
found
to
be
technically
feasible,
and
therefore
no
economic
assessment
was
conducted.
A
description
of
each
not­
in­
kind
alternative
follows:

Biofumigation.
Biofumigation
is
not
technically
feasible
because
of
difficulty
in
obtaining
sufficient
biomass
to
produce
effective
amounts
of
MITC
to
manage
diseases
and
weeds
under
nursery
conditions.
In
some
forest
nurseries,
trials
have
grown
mustard
species
(
Brassica
spp.)
for
disking
into
the
soil
to
generate
the
bioactive
breakdown
product
MITC.
Eleven
metric
tons
per
hectare
of
Brassica
plants
B
an
amount
that
is
considered
high
production
B
is
equivalent
to
approximately
68
kg
of
dazomet,
which
is
significantly
less
than
effective
dazomet
fumigation
rates.
In
addition,
increased
Fusarium
populations
due
to
favorable
conditions
provided
by
Brassica
plants
have
been
reported
to
increase
seedling
diseases
after
biofumigation
treatments.

Solarization.
Solarization
is
not
technically
feasible
because
it
would
require
several
months
of
covered
beds
to
heat
soil
to
a
sufficient
depth
(
25­
30
cm)
in
order
to
affect
soil­
borne
pathogens.
In
addition,
nutsedges,
Fusarium
spp.,
Macrophomina
spp.
are
not
controlled,
or
unpredictably
controlled,
by
solarization
(
Elmore
et
al.,
1997).
Seeds
of
some
weed
species
are
resistant
to
temperatures
obtained
with
solarization.
Conceivably,
solarization
could
be
optimized
for
efficacy
and
incorporated
into
an
integrated
pest
management
(
IPM)
program
that
would
help
reduce
chemical
use
for
bed
preparation,
but
because
of
intensive
scheduling
of
seedling
production,
solarization
is
inadequate
as
a
sole
replacement
for
methyl
bromide
in
the
forest
tree
seedling
nursery
industry
even
in
the
southern
U.
S.

Crop
rotation/
Fallow.
Cover
crops
and
mulching
are
not
technically
feasible
alternatives
because
data
do
not
support
their
use
as
stand­
alone
alternatives
to
methyl
bromide.
The
use
of
cover
crops
is
a
common
practice
to
improve
soil
structure
and
suppress
an
array
of
soilborne
pathogens.
Cover
crops
and
mulches
have
been
integrated
to
forest
tree
seedling
production
management.

Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
et
al.,
1996;
Galloway
et
al.,
1996).
Cowpea
and
sunn
hemp
have
been
shown
to
suppress
nutsedge,
but
the
effect
is
short
lived,
due
to
the
weed's
Page
13
capacity
for
rapid
tuber
production.
Allelochemicals
released
by
some
cover
crops
or
organic
mulches
can
injure
crops
(
Johnson
et
al.,
1993;
Norsworthy,
2002).

Trials
conducted
in
southern
Florida
with
the
leguminous
crops
sunn
hemp,
velvet
bean,
cowpea,
and
sorghum
Sudan
grass
showed
crop
yields
comparable
to
methyl
bromide
+
chloropicrin
treatments.
However,
nematode
and
disease
densities
were
described
as
very
low
in
the
soils
involved
in
these
studies.
Iron
clay
cowpea
has
been
shown
to
reduce
populations
of
northern
root
knot
nematode,
and
to
increase
population
of
the
sting
nematode.
Increased
sting
nematode
populations
have
been
reported
as
well
with
millet
as
a
cover
crop.
Proper
selection
of
cover
crops
can
be
very
important
in
suppressing
or
promoting
pest
populations.

Flooding/
Water
management.
Flooding
and
water
management
are
not
technically
feasible
because
nursery
beds
are
generally
designed
and
graded
for
good
drainage
to
prevent
standing
water.
Flooding
could
increase
incidence
of
Phytophthora
and
Pythium,
leading
to
damping­
off
and
root
rot
diseases.
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.

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
forest
tree
seedlings,
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
weeds,
such
as
use
of
plastic
or
other
mulches,
cropping
cycles,
crop
rotations,
etc.,
are
already
in
widespread
use
in
forest
tree
seedlings
in
the
southern
U.
S..
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,
methyl
iodide
(
iodomethane)
or
halosulfuron
methyl,
used
with
general
IPM
techniques,
may
be
able
to
accomplish
adequate
control
of
soil
fungi
and
nutsedges,
but
these
fumigants
are
not
register
for
use
in
the
U.
S.
The
use
of
IPM
(
with
these
alternative
fumigants)
will
require
multi­
year,
on­
farm
study
before
the
critical
use
exemption
review
group
can
confidently
assert
that
it
will
be
technically
equivalent
to
the
use
of
methyl
bromide
in
growing
forest
tree
seedlings.

Organic
amendments/
Compost.
Organic
amendments
and
compost
are
not
technically
feasible
because
these
measures
by
themselves
do
not
provide
adequate
weed
and
disease
control.
However,
most
nurseries
employ
various
soil
amendments
to
enhance
seedling
growth
and
quality.
Page
14
Physical
removal/
Sanitation.
Physical
removal
and
sanitation
are
not
technically
feasible
because
weed
control
by
mechanical
means
is
impractical
for
large­
scale
nursery
seedling
production
and
disease
problems
would
still
require
additional
measures.
Appropriate
sanitation
practices
are
already
followed
by
nurseries
as
this
improves
productivity.

Plowing/
Tillage.
Plowing
and
tillage
are
not
technically
feasible
because
nursery
beds,
especially
medium
textured
soils
with
higher
clay
or
organic
matter
than
light
soil
beds,
are
susceptible
to
damaged
soil
structure
and
development
of
an
impermeable
"
plow
pan"
layer,
resulting
in
less
productive
seedling
beds.
Plowing/
tillage
is
currently
being
used
but
by
itself
is
not
sufficient
to
adequately
control
the
target
pests.

7.
Critical
Use
Exemption
Nomination
for
Forest
Tree
Seedlings
As
noted
above,
this
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
for
forest
tree
seedling
production
in
three
distinct
regions
of
the
U.
S.
B
the
South,
West,
and
North
(
Appendix
A).
The
alternatives
identified
by
MBTOC
were
regarded
by
reviewers,
as
reviewed
in
detail
above,
as
technically
and
economically
infeasible
for
acceptable
management
of
the
major
forest
tree
seedling
pests,
most
importantly,
yellow
and
purple
nutsedge
and
several
nematode
and
fungal
pathogens.
The
two
alternatives
deemed
technically
feasible,
dazomet
and
metam
sodium,
although
providing
inconsistent
results
in
controlling
pests
were,
nevertheless,
economically
assessed
and
determined
to
be
economically
infeasible
in
comparison
to
methyl
bromide.

The
Southern
request
(
representing
nurseries
in
12
states,
see
Appendix
A)
is
for
310,215
kg
to
fumigate
832
hectares
annually
for
2005,
2006,
and
2007.
Table
3
provides
information
on
historical
usage,
including
area
treated,
and
the
actual
amount
requested.

Table
3.
Methyl
Bromide
Usage
and
Request
for
Forest
Tree
Seedling
Nurseries
in
the
Southern
U.
S.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
329,958
306,354
349,250
311,832
301,913
310,215
310,215
310,215
hectares
858
808
913
843
831
832
832
832
average
rate
(
kg/
ha)
400
391
395
356
339
364
364
364
The
Western
request
(
representing
nurseries
in
seven
states,
see
Appendix
A)
is
for
97,554
kg
to
fumigate
357
hectares
for
2005.
Historical
usage
and
area
treated
are
shown
in
Table
4,
along
with
the
actual
amount
of
methyl
bromide
requested
for
2005,
2006,
and
2007.
Page
15
Table
4.
Methyl
Bromide
Usage
and
Request
for
Forest
Tree
Seedling
Nurseries
in
the
Western
U.
S.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
64,874
92,446
88,767
95,814
92,155
97,554
98,160
99,096
hectares
216
304
292
336
343
357
359
363
average
rate
(
kg/
ha)
309
312
311
300
284
286
286
286
The
Northern
request
(
representing
nurseries
in
11
states,
see
Appendix
A)
is
for
46,520
kg
to
fumigate
147
hectares
for
2005.
Historical
usage
and
area
treated
are
shown
in
Table
5,
along
with
the
actual
amount
of
methyl
bromide
requested
for
2005,
2006,
2007.

Table
5.
Methyl
Bromide
Usage
and
Request
for
Forest
Tree
Seedling
Nurseries
in
the
Northern
U.
S.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
51,650
55,668
48,632
46,344
42,386
46,520
45,863
45,330
hectares
150
168
154
154
133
147
145
143
average
rate
(
kg/
ha)
345
337
295
286
291
291
291
292
The
U.
S.
nomination
has
been
determined
based
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
Forest
Tree
Seedlings
Year
Total
Request
From
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
454,289
192,515
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
continued
need
for
methyl
bromide
can
be
met
from
recycled
or
stockpiled
sources.
With
regard
to
Page
16
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.
Minimizing
Use/
Emissions
of
Methyl
Bromide
in
the
United
States
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
B
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
17
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
18
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
19
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.

Considerable
resources
have
been
spent
examining
methods
to
reduce
costs
and
improve
efficiency
in
forest
seedling
production
because
of
relatively
high
nursery
production
costs.
The
Auburn
University
consortium,
which
includes
commercial
and
public
forest
tree
seedling
nurseries,
has
spent
US$
1.2
million
on
methyl
bromide
alternatives
since
1992.
An
investment
of
this
magnitude
is
significant
considering
several
member
nurseries
are
publicly
owned
and
have
limited
resources
for
independent
research.
Research
included
trials
to
assess
effectiveness
of
the
most
likely
chemical
and
non­
chemical
methyl
bromide
alternatives,
including
some
potential
alternatives
that
are
not
currently
listed
by
MBTOC
for
forest
tree
seedlings,
such
as:
combinations
of
chemicals
such
as
1,3­
dichloropropene
(
1,3­
D,
manufactured
as
Telone
®
)
,
chloropicrin,
and
methyl
iodide
(
not
currently
registered
in
the
U.
S.).

Non­
chemical
procedures
have
been
adopted
widely
in
the
industry
and
methods
such
as
IPM,
mulching,
solarization,
biofumigation,
are
being
examined
as
part
of
an
overall
strategy
to
improve
seedling
production.
Modification
of
fertilization
regimes
may
help
to
compensate
for
reduced
seedling
quality
that
can
occur
when
MITC
producing
fumigants
are
used;
results
have
been
inconclusive
thus
far.

Research
in
application
technology
(
e.
g.,
injection
methods
and
application
rates)
may
improve
the
uniformity
of
soil
movement
of
chemicals,
such
as
metam­
sodium.
Non­
chemical
alternatives
have
been
incorporated
and
methods
such
as
IPM,
mulching,
solarization,
and
biofumigation
are
being
examined
as
part
of
an
overall
strategy
to
manage
forest
tree
seedling
production.
Trials
evaluating
compost­
based
systems
as
alternatives
for
chemical­
based
fumigations
are
already
being
conducted.
These
trials
will
continue
and
weed
ratings,
disease
incidence,
and
crop
yield
data
will
be
collected.

In
addition,
there
have
been
many
studies
done
on
yield
comparing
alternatives
in
the
forest
tree
seedling
sector
to
methyl
bromide.
Sources
for
the
studies
are
The
Methyl
Bromide
Alternatives
Conference,
applications
for
critical
use
exemption,
and
case
studies.
For
each
alternative,
the
number
of
studies
done
is
as
follows:
bare
fallow
and
combinations
(
22);
dazomet
and
combinations
(
76);
cedar
sawdust
(
2);
chloropicrin
and
combinations
(
56);
compost
(
3);
Eptam
(
EPTC)
(
12);
fallow
(
41);
formaldehyde
(
1);
grafting
(
1);
hot
water
(
3);
MBR­
200
(
1);
MBR­
300
(
8);
metamsodium
and
combinations
(
19);
Nemagon
(
2);
other
non­
chemical
(
1);
silica
sand
(
1);
solarization
(
1);
Page
20
1,3­
D
and
combinations
(
6);
thiram
(
1);
triform
and
combinations
(
8).

Government
funded
studies
related
to
U.
S.
forest
tree
seedling
production
that
are
currently
on­
going
include
the
following:

1.
Factors
Affecting
the
Production
and
Processing
of
Small
Fruit
Or
Nursery
Crops
in
the
Pacific
Northwest
(
U.
S.)
(
Sep
1999
­
Sep
2003)
The
objective
of
this
cooperative
research
project
is
to
determine
factors
that
can
improve
the
production
and
processing
practices
used
for
horticultural
crops
(
especially
nursery
crops
and
small
fruit
crops)
grown
in
the
Pacific
Northwest,
including
cultural
practices,
propagation
methods,
environmental
stresses,
diseases,
insects
(
and
mites),
soil
fertility
and
fertilization,
organic
amendments,
irrigation,
and
pruning.

2.
Biological
Control
of
Fusarium
Wilt
and
Other
Soilborne
Plant
Pathogenic
Fungi
(
Nov
2002
­
Nov
2007)
The
objective
of
this
research
is
to
assess
the
potential
of
microbes
to
control
soil­
borne
plant
pathogenic
fungi
and
determine
biological,
environmental
and
ecological
factors
affecting
performance
of
these
microbes.
The
research
will
help
to
characterize
biological,
ecological
and
genetic
relationships
among
and
within
pathogenic,
saprophytic
and
biological
control
soil­
borne
microorganisms,
as
well
as
elucidate
mechanisms
of
action
of
biological
control
agents
used
against
soil­
borne
plant
pathogens;
where
previous
work
identified
a
general
mechanism
of
action,
the
research
will
identify
the
specific
underlying
basis
of
the
mechanism.
Work
will
include,
but
is
not
limited
to,
the
nature
of
resistance
to
Fusarium
wilt
in
tomato,
induced
by
Fusarium
oxysporum
strain
CS­
20,
which
can
serve
as
a
model
for
other
systems
including
forest
tree
seedling
nurseries.

3.
Evaluation
of
Fumigant
Efficacy
with
Virtually
Impermeable
Film
(
VIF)
Plastic
(
Sep
2002
­
Mar
2005)
The
objective
of
this
research
is
to
evaluate
the
effect
of
methyl
bromide
replacement
soil
fumigants
applied
under
standard
polyethylene
plastic
of
virtually
impermeable
film
on
pathogen
control
and
plant
health
in
production
fields.

4.
Evaluation
of
Fumigant
Efficacy
with
Virtually
Impermeable
Film
(
VIF)
Plastic
(
UC
Davos/
CSREES­
Sep
2002
­
Sep
2004)
The
objective
of
this
research
is
to
identify
methods
to
maximize
the
effects
of
alternative
fumigants
on
soil
borne
pests,
while
minimizing
environmental
risk.
To
determine
the
minimum
effective
doses
of
chloropicrin
and
1,3­
dichloropropene
plus
chloropicrin
on
soil
borne
pathogens,
weeds
and
alla
lily
bulbs
under
virtually
impermeable
film
(
VIF).

5.
Replacement
of
Herbicides
and
Methyl
Bromide
by
Microbiological
Control
of
Weeds
(
May
2000
­
Apr
2003)
The
objective
of
this
research
is
to
discover
and
evaluate
pathogens
as
bioherbicides
of
agronomic
weeds
and
horticultural
weeds
formerly
controlled
by
methyl
bromide.
To
develop
new
formulations/
adjuvants/
synergists
which
overcome
constraints
that
limit
biocontrol
potential
such
as
Page
21
moisture
requirements
and
narrow
host
ranges.
To
optimize
bioherbicide
mass
production.
To
conduct
biochemical
studies
of
weed
pathogenesis
by
bioherbicides.
To
discover/
identify/
produce
phytotoxins
that
could
be
used
to
produce
safer
herbicides.

6.
Improving
Efficacy
of
Fumigants
by
Promoting
Uniform
Dispersion
in
Soil
and
Minimizing
Emissions
to
the
Atmosphere
(
Dec
2002
­
Dec
2007)
The
objective
of
this
research
is
to
determine
the
efficiency
of
various
barrier
films,
and
absorbents,
catalysts,
and/
or
reactants
applied
to
the
film
or
soil
surface,
alone
or
in
combination,
for
decreasing
emissions
or
preplant
soil
fumigants
to
the
atmosphere.
Improve
the
efficacy
of
methyl
bromide
alternative
fumigants
(
1,3­
dichloropropene,
chloropicrin,
and
MITC)
by
promoting
uniform
dispersion
and
solubilization
in
the
liquid
phase
in
soil.
Develop
microemulsion
methodologies
for
reduced
volatilization
and
improved
dispersion
of
alternative
fumigants
from
drip­
tube
application
or
shank
injection
traces.

The
following
are
some
examples
of
additional
research
supported
by
public
and
private
forest
tree
nurseries:

In
addition
to
the
research
that
is
ongoing
under
the
U.
S.
Department
of
Agriculture,
applicants
have
cited
the
following
research
plans
as
ones
they
are
funding
or
otherwise
participating
in.
They
are:
Illinois
Prairie
Forbs
which
includes
a
submitted
research
plan
to
test
dazomet
at
the
Mason
State
Tree
Nursery
in
2003;
Michigan
Seedlings
includes
a
study
planned
for
methyl
bromide
alternatives
and
research
and
education
for
herbaceous
perennials,
woody
ornamentals
and
vegetables
in
Michigan,
New
York
and
Rhode
Island.
The
tests
are
planned
for
2003­
2004
in
Michigan.
The
alternatives
to
be
tested
are
1,3­
dichloropropene
1,3­
dichloropropenewith
17
percent
chloropicrin,
1,3­
dichloropropenewith
35
percent
chloropicrin,
metam­
sodium,
metam­
sodium/
1,3­
dichloropropenecombinations,
methyl
iodide,
halosulfuron,
flumioxazin,
sulfentrazone,
carfentrazone,
cover
crop
and
composting;
Additional
trials
associated
with
USDA
projects
are
being
done
with
organic
acids,
and
screening
of
biological
organisms
for
use
as
methyl
bromide
alternatives
in
nursery
production
systems.
So
far,
US$
13,000
has
been
spent
on
research;
Other
research
includes
a
system
of
growing
that
involves
using
plug
culture
in
retractable­
roof
greenhouses
allowing
seedlings
to
be
grown
without
methyl
bromide
B
however,
costs
run
about
US$,
250,000/
hectare.

Western
U.
S.
Seedling
Industry
includes
various
studies
to
be
done
by
the
USDA
Forest
Service
and
State
nursery
cooperators.
The
testing
was
planned
for
2002
and
continues
in
various
nurseries
throughout
the
region
(
CA,
ID,
KS,
NE,
OR,
UT,
WA).
The
alternatives
to
be
tested
include:
dazomet,
metam­
sodium,
and
organic
amendments/
cover
crops/
sowing
alternatives.
Studies
plan
to
test
methyl
bromide
alternatives
in
2003
in
nurseries
in
Oregon
and
Washington.
Studies
plan
to
further
test
chloropicrin,
possibly
in
combination
with
metam­
sodium,
and
test
the
efficacy
of
methyl
iodide.
So
far,
US$
0,000
has
been
spent
on
research;
Weyerhauser
Company
(
NW
U.
S.)
conducts
studies
planned
to
test
alternatives
to
methyl
bromide
in
Mima
Nursery,
Little
Rock,
WA.
To
be
tested
were:
MBC
(
operational
control),
chloropicrin
(
untreated­
weeds),
and
metam­
sodium
+
chloropicrin
(
tarped).
Additional
testing
is
planned
for
spring,
2003,
when
methyl
iodide
+
chloropicrin
will
be
compared
to
methyl
bromide
for
spring
fumigation.
So
far,
about
US$
25,000
has
Page
22
been
spent
on
research.

Southeastern
Seedling
Industry
includes
research
by
The
Auburn
University
Southern
Forest
Nursery
Management
Cooperative.
The
testing
was
planned
starting
in
Fall,
2002
and
continuing
in
several
locations
throughout
the
southern
U.
S..
The
alternatives
to
be
tested
include
methyl
iodide,
chloropicrin,
EPTC
and
probably
azides.
So
far,
US$,
266,673
has
been
spent
on
research.
International
Paper
conducts
studies
planned
to
evaluate
potential
chemical
and
integrated
pest
management
alternatives.
The
studies
were
planned
to
begin
in
2002,
and
continue
at
nine
international
paper
nurseries.
Alternatives
to
be
tested
are
methyl
iodide,
chloropicrin,
EPTC,
azides,
integrated
pest
management
techniques
such
as
crop
rotations,
fallow
field
soil
management,
herbicides,
solarization
and
allopathic
interactions
of
crops
and
weeds.
So
far,
US$,
005,000
has
been
spent
on
research.
Other
investments
include
dues
for
International
Paper's
membership
in
the
Auburn
University
Nursery
Cooperative
which
are
US$,
300
per
year.
Weyerhauser
Company
(
SE
U.
S.)
plans
to
study
1,3­
dichloropropene
chloropicrin
and
MITC
agent
combinations.
Tests
are
planned
for
2003­
2007.
Alternatives
to
be
tested
are
1,3­
dichloropropene+
17%
chloropicrin
(
1,3­
dichloropropenewith
17
percent
chloropicrin)
1,3­
dichloropropene
25%
chloropicrin,
or
1,3­
dichloropropene+
35%
chloropicrin
in
combination
with
MITC
agent
(
Vapam);
also
pebulate
(
Tillam
®
in
combination
with
1,3­
dichloropropene+
17%
chloropicrin
if
permission
to
use
pebulate
can
be
obtained
for
pine.
So
far,
US$
00,000
has
been
spent
on
this
research.

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.

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
pose
unreasonable
adverse
effects
to
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,
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.
Page
23
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,
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
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
the
EPA
to
initiate
its
review.
The
average
processing
time
for
a
new
active
ingredient,
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
most
cases,
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,
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,
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
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:
Page
24
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:

B
Iodomethane
as
a
pre­
plant
soil
fumigant
for
various
crops
B
Fosthiazate
as
a
pre­
plant
nematocide
for
tomatoes
B
Sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
stored
commodities
B
Trifloxysulfuron
sodium
as
a
pre­
plant
herbicide
for
tomatoes
B
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
consideration.

Alternatives
must
be
field­
tested
and
found
technically
and
economically
feasible
before
finally
being
adopted.
Testing
alternatives
requires
sufficient
time
for
consideration
of
efficacy
of
the
products
for
managing
the
pest
problems.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
for
the
specific
circumstances
of
the
user.
In
an
effort
to
speed
adoption,
the
U.
S.
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

Some
alternatives
under
review
by
EPA
may
be
available
for
forest
tree
seedling
nurseries
in
the
future.
These
include:
methyl
iodide
and
propargyl
bromide,
which
currently
look
promising
in
field
studies.
Although
methyl
iodide
is
chemically
similar
to
methyl
bromide,
it
photodegrades
before
it
reaches
the
stratosphere,
and
therefore
is
not
a
significant
ozone
depleter.
While
methyl
iodide
and
propargyl
bromide
are
not
currently
registered
for
use
as
pesticides
in
the
U.
S.,
research
on
these
and
other
alternatives
is
on­
going.

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
Page
25
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
described
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
by
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
potential
alternatives
identified
by
MBTOC
for
forest
tree
seedling
nurseries
are
not
technically
or
economically
feasible
as
covered
by
the
exemption
nomination
for
the
forest
tree
seedling
nursery
sector.
Certain
MBTOC
alternatives
(
dazomet
and
metam­
sodium)
were
only
effective
against
major
pests
(
particularly
nutsedges)
in
limited
situations
and
were
inconsistent
in
their
effectiveness
in
acceptable
pest
management.
Forests
in
the
U.
S.
are
extremely
valuable
for
economic
and
environmental
reasons.
Forest
tree
nurseries
in
the
U.
S.
supply
seedlings
of
conifers
and
hardwoods
that
are
used
for
reforestation,
forest
establishment,
fiber
production,
and
wildlife
and
conservation
uses.
Because
of
the
high
correlation
between
healthy
seedlings
and
the
health
of
a
forest
over
its
20
to
40
(
or
more)
year
life,
consistently
high
quality
seedling
production
in
the
forest
tree
seedling
nursery
sector
is
of
prime
importance
to
the
U.
S.
As
a
result,
methyl
bromide
is
being
supported
for
use
by
the
forest
tree
seedling
nursery
sector
to
maintain
the
consistent
production
of
high
quality
forest
trees.

The
U.
S.
expends
significant
efforts
to
find
and
commercialize
alternatives,
and
potential
alternatives
to
the
use
of
methyl
bromide
for
forest
tree
seedling
nurseries.
However,
the
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
unreasonable
adverse
effects
on
human
health
or
the
environment,
is
a
long
and
rigorous
one.
The
U.
S.
need
for
methyl
bromide
for
forest
tree
seedling
nurseries
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
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
Page
26
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
B
about
40%
above
usage
B
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
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
Page
27
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
B
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:

John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
US
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
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
Page
28
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USDA­
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(
Animal
and
Plant
Health
Inspection
Service),
Plant
Protection
and
Quarantine.
2002.
Sudden
Oak
Death.
http://
www.
aphis.
usda.
gov/
ppq/
ispm/
sod/

USDA­
NASS
(
United
States
Department
of
Agriculture­
National
Agricultural
Statistics
Service).
2001.
Nursery
Crops
C
2000
(
August)
Summary.

US­
GAO
(
General
Accounting
Office).
1995.
Potential
alternatives
to
methyl
bromide
for
agricultural
uses.
Appendix
II,
pg.
30,
In:
The
Phaseout
of
Methyl
Bromide
in
the
United
States.
GAO/
RCED­
96­
16.

Webster,
T.
M.,
Csinos,
A.
S.,
Johnson,
A.
W.,
Dowler,
C.
C.,
Sumner,
D.
R.,
Fery,
R.
L.
2001.
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Protection
20:
605­
614.

14.
Appendices
Appendix
A.
List
of
Critical
Use
Exemption
Requests
for
the
Forest
Tree
Seedling
Nursery
Sector
in
the
U.
S.

South:
Alabama,
Arkansas,
Georgia,
Florida,
Louisiana,
Mississippi,
North
Carolina,
Oklahoma,
South
Carolina,
Tennessee,
Texas,
Virginia
CUE­
02­
0003,
Auburn
University
Southern
Forest
Nursery
Management
Cooperative
CUE­
02­
0007,
International
Paper
(
also
a
member
of
the
Auburn
University
consortium)
CUE­
02­
0021,
Weyerhaeuser­
South
(
also
a
member
of
the
Auburn
University
consortium)

West:
California,
Idaho,
Kansas,
Nebraska,
Oregon,
Utah,
Washington
CUE­
02­
0008,
Western
Forest
and
Conservation
Public
Nursery
Association
CUE­
02­
0009,
Nursery
Technology
Cooperative
CUE­
02­
0022,
Weyerhaeuser­
West
Page
31
North:
Illinois,
Indiana,
Kentucky,
Maryland,
Michigan,
Missouri,
New
Jersey,
Ohio,
Pennsylvania,
West
Virginia,
Wisconsin
CUE­
02­
0011,
Illinois
Department
of
Natural
Resources
Nursery
Program
CUE­
02­
0032,
Northeastern
Forest
and
Conservation
Nursery
Association
CUE­
02­
0039,
Michigan
Seedling
Association
Page
32
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
*
Numbers
in
the
tables
reflect
most
likely
loss
estimates.

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
Page
34
#
Notes
1
Seedling
price
is
much
lower
in
the
southern
region
according
to
applicants.
This
could
be
due
to
a
number
of
reasons
including
better
growing
conditions
and
accounting
practices
of
major
growers
in
the
timber
and
paper
industries.

2
Applicant
is
also
a
member
of
the
Auburn
consortium.

3
Applicant
is
also
a
member
of
the
Auburn
consortium.
Revenue
losses
due
to
yield
losses
and
shift
in
production
from
4­
year
cycle
with
1
year
fallow
to
3­
year
cycle
with
1
year
fallow.

4
Analysis
was
revised
to
make
it
consistant
with
others
in
sector,
specifically,
a
3­
year
fumigation
cycle
was
assumed.
Price
and
yield
are
a
composite
of
several
products.
Costs
are
underestimated
due
to
data
limitations.

5
Price
and
yield
are
a
composite
of
several
products.
Revenue
losses
due
to
yield
losses
and
shift
in
production
of
some
species
from
2­
year
production
to
3­
year
production.

6
Costs
are
likely
underestimated
due
to
data
limitations.
Page
35
Page
36
Page
37
*
kg
ai
that
would
be
applied
per
hectare
=
application
rate
for
the
alternatives
or
requested
application
rate
for
MeBr.

*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
Page
38
Page
39
Page
40
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
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
Page
41
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
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
Page
42
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
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).
Page
43
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
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).
Page
44
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.

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
Page
45
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.

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).
Page
46
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).

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.
Page
47
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
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
Page
48
(
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
49
Appendix:
CHARTS
(
See
the
separate
electronic
files
for
CHART
1
and
CHART
2.)
