Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
GINGER
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
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
ginger,
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
ginger
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
ginger,
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
ginger
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
pre­
plant
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
chemical
alternatives
to
methyl
bromide
are
toxic,
and
can
pose
risks
to
human
health
or
the
environment
that
are
even
greater
than
the
risks
posed
by
methyl
bromide.

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

In
fact,
even
after
an
alternative
is
tested
and
found
to
work
against
some
pests
in
a
controlled
setting,
adequate
testing
in
large­
scale
commercial
operations
can
take
many
cropping
seasons
before
the
viability
of
the
alternative
can
be
adequately
assessed
from
the
standpoint
of
the
climate
and
soil
for
various
potential
users.
In
addition,
the
process
of
securing
national
and
sub­
national
approval
of
alternatives
may
require
extensive
analysis
of
environmental
consequences
and
toxicology.
The
average
time
for
the
national
review
of
scientific
information
in
support
of
a
new
pesticide,
starting
from
the
date
of
submission
to
registration,
is
approximately
38
months.
In
most
cases,
the
company
submitting
the
information
has
spent
approximately
7­
10
years
developing
the
toxicity
and
other
environmental
data
necessary
to
support
the
registration
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
Page
3
exemption
calls
for
an
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
Ginger
Work
on
this
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
grower
association
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
U.
S.
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11
which
calls
for
specific
information
to
be
presented
in
the
nomination.

Upon
return
from
the
Sri
Lanka
meeting
of
the
Parties,
the
U.
S.
took
a
three
track
approach
to
the
critical
use
process.
First,
we
worked
to
develop
a
national
application
form
that
would
ensure
that
we
had
the
information
necessary
to
answer
all
of
the
questions
posed
in
decision
XIII/
11.
At
the
same
time,
we
initiated
sector
specific
meetings.
This
included
discussions
with
representatives
of
ginger
growers
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
Page
4
outside
of
the
U.
S.
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.
In
2001,
U.
S.
farm
land
totaled
381
million
hectares,
a
land
area
larger
than
the
entire
size
of
many
entire
countries.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables,
has
had
an
important
influence
on
the
way
agriculture
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

Other
factors
also
affected
the
general
development
of
agriculture
in
the
U.
S..
While
land
for
farming
is
widely
available,
labor
is
generally
more
expensive
and
less
plentiful.
As
a
result,
the
U.
S.
has
developed
a
unique
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
less
than
1
million
hired
workers.

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

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
has
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices,
including
plastic
mulches,
row
covers,
high­
density
planting,
more
effective
pesticide
sprays,
and
drip
irrigation,
as
well
as
increased
water
irrigation
practices.
Optimization
of
yields
through
these
and
other
scientific
and
mechanized
practices
make
U.
S.
agricultural
output
very
sensitive
to
changes
in
inputs.
Therefore,
as
evidenced
by
the
U.
S.
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.
Ginger
Production
In
terms
of
its
scope,
ginger
production
in
the
U.
S.
is
confined
to
the
state
of
Hawaii.
Ginger
growers
have
produced
an
average
of
6,078,240
kgs
of
ginger
root
per
year
for
national
and
international
shipment
for
the
last
ten
years.
Total
farm
prices
averaged
US$
1.44
per
kg
with
total
farm
revenues
exceeding
US$
8.7
million
annually.
Currently,
total
U.
S.
ginger
production
takes
place
on
145
hectares
in
Hawaii
on
hilly
terrain
in
light
porous
soil
near
the
coast.
Ginger
is
produced
using
mechanized,
scientific
practices
that
involve
deep
injection
of
methyl
bromide.
Like
many
other
crops
grown
in
the
U.
S.,
ginger
is
grown
not
only
for
the
domestic
market,
but
also
for
exports.
Only
two
varieties
of
ginger
(
Zingiber
officinale
Roscoe)
are
grown
in
Hawaii
­
Chinese
and
Japanese.
Production
of
this
regional
commodity
is
targeted
to
the
fresh
market
and
the
majority
is
exported
to
niche
markets
in
the
mainland
U.
S.,
Canada,
and
Europe.

While
ginger
root
production
is
consistent
in
several
ways
with
other,
larger
U.
S.
agricultural
activities,
it
is
also
unique
in
several
respects.
First,
unlike
many
U.
S.
crops,
ginger
is
only
grown
in
one
state,
and
indeed
in
one
geographic
area
in
one
state.
Ginger
is
usually
grown
in
a
rotation
system
in
which
one
year
of
ginger
production
is
followed
by
three
years
in
which
the
land
is
not
used
for
ginger
to
help
reduce
the
incidence
of
disease
and
nematodes.
Some
growers
move
to
new
rented
land
each
year.
The
ginger
plant
grows
best
in
deep,
loose,
well­
drained,
and
nutrientrich
soil.
Abundant
rainfall,
sunlight,
and
warm
temperatures
are
necessary
throughout
its
growth
cycle
of
approximately
five
to
six
months.
The
soil
should
be
free
of
weeds
which
could
harbor
insects
and
diseases
that
attack
ginger
shoots
as
they
emerge.

Field
preparation
for
ginger
production
begins
in
late
fall
with
the
use
of
a
pre­
plant
soil
fumigant.
Soil
fumigation
with
methyl
bromide
occurs
once
during
each
crop
cycle
(
one
year)
at
a
rate
of
415
kgs
per
hectare,
to
eliminate
nematodes
which
are
the
primary
target
pests.
After
soil
fumigation,
the
fields
are
furrowed
and
a
pre­
plant
fertilizer
is
applied
and
tilled
into
the
bottom
of
the
furrow
before
seeding.
Pre­
planting
preparation
of
ginger
"
root
pieces"
involves
soaking
the
root
pieces
used
for
seeding
in
hot
water
at
50
oC
for
ten
minutes
primarily
for
nematode
control.
This
practice
also
tends
to
minimize
the
rate
of
methyl
bromide
used.
The
heat
treatment
also
serves
to
release
the
seed
pieces
from
dormancy.
Ginger
seed
pieces
are
particularly
sensitive
and
vulnerable
to
diseases
and
pests
while
coming
out
of
dormancy.
Runoff
water
from
other
soils
and
fields
should
not
be
allowed
to
contaminate
the
planted
areas.
Disease
and
soil­
free
equipment,
machinery
and
personnel,
as
well
as
footbaths,
are
essential.
Field
sanitation
is
critical
to
keeping
many
diseases
and
pests
away
from
the
ginger
seed
pieces.

Planting
of
ginger
seeds
actually
occurs
in
the
early
spring
in
Hawaii
and
the
ginger
is
ready
for
harvest
in
July
and
August.
On
average,
approximately
370
kgs
of
seed
are
required
to
plant
an
hectare
of
ginger.
The
optimum
yield
is
typically
obtained
when
the
growing
season
is
10
months
long.
Harvested
ginger
rhizomes
are
allowed
to
cure
for
3
to
5
days
and
then
packed
and
sold
in
containers.
Hawaiian
ginger
root
is
available
in
the
marketplace
beginning
in
December
and
continuing
as
late
as
September
of
the
following
year.
A
typical
Hawaiian
ginger
grower
is
a
family
owned
farm
operating
on
rented
land
of
about
1.2
to
2
hectares.
Page
6
6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Ginger
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Ginger
root
production
in
the
U.
S.
is
challenged
with
a
variety
of
diseases
and
insects.
While
there
are
alternatives
to
control
a
number
of
these
pests,
growers
particularly
rely
on
methyl
bromide
to
efficaciously
control
the
root­
knot
nematode
(
Meloidogyne
incognita),
and
bacterial
wilt
(
Pseudomonas
solanacearum).
Root­
knot
nematode
causes
rhizome
and
root
galls,
while
bacterial
wilt
causes
drooping
of
the
entire
plant
and
rhizome
rot.
Infections
with
either
of
these
pests
can
result
in
significant
crop
losses.
All
of
the
hectares
of
ginger
in
Hawaii
is
subject
to
pressure
by
these
pests
either
alone
or
in
combination.
Ginger
bacterial
wilt
has
resulted
to
losses
of
up
to
45
percent
of
the
annual
ginger
crop
in
peak
epidemics
in
Hawaii.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
For
the
past
several
years,
research
on
chemical
and
non­
chemical
alternatives
to
methyl
bromide
has
focused
primarily
on
the
control
of
either
root­
knot
nematode
or
bacterial
wilt,
but
not
on
both
simultaneously.
At
this
point,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
in
a
preliminary
stage.
The
technical
and
economic
feasibility
of
MBTOC
alternatives
was
based
on
these
research
results
as
derived
from
the
small
body
of
literature
specific
to
ginger
production
and
from
discussions
with
U.
S.
ginger
experts.
A
summary
of
the
results
of
the
assessments
of
the
technical
(
i.
e.,
biological
or
pest
management)
and
economic
feasibility
of
alternatives
for
methyl
bromide
use
on
ginger
is
provided
in
the
tables
below:

6c.
Technical
Feasibility
of
In­
Kind
Methyl
Bromide
Alternatives
Table
2.
In­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Ginger
Crops.

Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Basamid/
Solarization
Not
registered
for
use
in
the
U.
S.

Metam
Sodium/
Solarization
No
No
Ozone
No
No
Basamid/
Solarization.
Basamid
is
not
registered
in
the
U.
S.
for
ginger
root
production.

Metam
Sodium/
Solarization.
There
is
no
available
research
on
metam­
sodium
combined
with
solarization.
However,
metam­
sodium
combined
with
solarization
is
not
technically
feasible
because
it
would
not
adequately
control
the
target
pests,
principally
nematodes
and
disease.
Studies
of
metam
sodium
and
tarping
(
using
plastic
tarpaulins)
have
shown
significant
yield
losses
Page
7
and
some
quality
loss.
Yield
when
methyl
bromide
is
applied
at
a
rate
of
329
kgs/
hectare
is
9,864
kgs/
hectare
(
based
on
3/
91
Nematode
Control
in
Ginger
CES
Progress
Report
where
metam
sodium
was
applied
and
tarping
was
used.
No
solarization
was
included
in
this
research.).
The
yield
when
metam
sodium
is
applied
at
a
rate
of
356
kgs/
hectare
is
5,380
kgs/
hectare,
which
is
equivalent
to
a
45
percent
yield
loss
compared
to
cropping
practices
with
methyl
bromide.
In
addition,
the
metam
sodium
trial
had
a
reduction
in
overall
ginger
quality
due
to
a
lack
of
control
of
Fusarium
wilt.
This
research
focused
on
root­
knot
nematode
control
and
not
on
bacterial
wilt
control.
In
the
same
study
solarization
alone
had
a
95
percent
yield
loss
compared
to
methyl
bromide.
Therefore,
if
metam
sodium
and
solarization
led
to
45
and
95
percent
yield
loss
individually
the
combination
would
still
provide
unacceptable
control.
(
We
recognize
that
the
ginger
yield
in
this
test
was
lower
than
the
average
yield
in
Hawaii
but
the
information
was
verified
against
the
original
published
data.)
There
is
some
time
lost
in
this
combination
treatment
compared
to
methyl
bromide
because
of
the
weeks
to
months
required
for
solarization
treatment.

Ozone.
Ozone
is
not
technically
feasible
because
there
is
no
known
available
and
field
feasible
technology
for
generating
ozone
for
ginger
grower
production
systems
in
the
state
of
Hawaii.
In
addition
initial
research
in
California
suggests
that
ozone
is
neutralized
so
rapidly
by
soil
particles
that
it
does
not
retain
its
biocidal
properties.
Even
if
effective
the
practical
impediments
to
ozone
sterilization
of
soil
for
ginger
production
are
very
similar
to
steam's
constraints:
lack
of
portable
ozone
generation
equipment
that
would
be
needed
simultaneously
on
many
small,
dispersed,
farms
(
primarily
rented
land).
Whether
any
ozone
generating
technology
could
be
used
on
the
hilly
terrain
where
ginger
is
grown
is
also
unknown,
and
in
any
case
likely
to
be
very
difficult
and
time­
consuming
to
achieve.

6d.
Technical
Feasibility
of
Not
In­
Kind
(
Non­
chemical)
Alternatives
Table
3.
Not
In­
Kind
(
Non­
chemical)
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Ginger
Crops.

Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Steam
No
No
Biological
Control
No
No
Fallow
No
No
Crop
Rotation
No
No
Solarization
No
No
Solarization/
fungicides
No
No
Page
8
Flooding
and
water
management
No
No
General
IPM
(
Integrated
Pest
Management)
No
No
Grafting/
resistant
rootstock/
plant
breeding
No
No
Organic
amendments/
Compost
No
No
Steam
.
Steam
is
not
technically
feasible
because
it
is
not
operationally
practicable
and
there
are
currently
no
portable
steam
generation
units
which
are
appropriate
for
field
use
in
Hawaii's
hilly
terrain.
Steam
sterilization
does
not
typically
penetrate
deep
enough
into
the
associated
soil
to
address
the
target
pests
associated
with
ginger
production
such
as
the
nematode
Meloidogyne
incognita
and
bacteria
Pseudomonas
solanacearum.
Ginger
production
is
seasonal
with
virtually
all
the
planting
starting
at
the
same
time
(
in
early
spring)
which
would
necessitate
each
small
farmer
(
there
are
an
estimated
30
to
40
such
farmers
in
Hawaii)
having
equipment
to
simultaneously
steam
sterilize
their
planting
beds.
None
of
these
small
ginger
farmers
are
currently
using
steam
for
pre­
plant
fumigation
on
their
land,
which
is
generally
rented.

Biological
Control.
Biological
control
is
not
a
technically
feasible
alternative
alone
because
it
provides
inadequate
control
of
bacterial
wilt
and
root­
knot
nematodes.
There
are
ongoing
studies
on
the
interactions
of
different
bacterial
strains
associated
with
R.
solanacearum
to
determine
if
interactions
affect
the
disease
complex.
Preliminary
results
indicate
that
bacterial
wilt
symptoms
are
reduced
if
other
bacteria
are
on
the
ginger
plant
prior
to
exposure
to
R.
solanacearum.
Additional
research
is
needed
in
this
area.

Fallow.
Fallowing
land
is
not
a
technically
feasible
alternative
by
itself
because
it
does
not
adequately
control
the
target
pests
and
therefore
results
in
significant
yield
losses.
However,
by
using
a
fallow
period,
ginger
producers
are
able
to
benefit
by
minimizing
methyl
bromide
use
and
increase
soil
nutrients.
Thus,
ginger
growers
already
fallow
a
field
for
3
years
and
then
fumigate
with
methyl
bromide.
When
methyl
bromide
is
applied
at
a
rate
of
410
kgs/
hectare,
ginger
yield
is
56,043
kgs/
hectare
(
based
on
the
2001
industry
yield
average
since
direct
comparison
of
yield
was
not
available).
The
yield
after
a
fallow
period
of
3
years
without
methyl
bromide
fumigation
was
43,714
kgs/
hectare,
which
is
equivalent
to
a
22
percent
loss
(
based
on
"
Sunn
Hemp
`
Tropic
Sun'
as
a
Cover
Crop
in
Edible
Ginger
Production
Study"
delivered
at
the
2000
International
Conference
on
methyl
Bromide
Alternatives
&
Emissions
Reductions.)
In
addition,
the
quality
of
the
end
product
was
also
reduced.
Specifically,
it
is
also
important
to
note
here
that
this
research
has
focused
on
root­
knot
nematode
control
and
not
on
bacterial
wilt
control.

Crop
Rotation.
Crop
rotation
is
currently
being
used
in
ginger,
but
it
is
not
technically
feasible
as
a
stand­
alone
treatment
to
adequately
control
the
target
pests.
When
methyl
bromide
is
applied
at
a
rate
of
410
kgs/
hectare,
the
yield
is
56,043
kgs/
hectare
(
based
on
the
2001
industry
yield
average
since
direct
comparison
of
yield
was
not
available).
In
contrast,
field
rotation
with
a
cover
crop,
sunn
hemp
(
Crotalaria
juncea),
and
no
methyl
bromide
fumigation,
resulted
in
a
yield
of
26,677
kgs/
hectare,
equivalent
to
a
52
percent
yield
loss
(
based
on
"
Sunn
Hemp
`
Tropic
Sun'
Page
9
as
a
Cover
Crop
in
Edible
Ginger
Production
Study",
a
presentation
delivered
at
the
2000
International
Conference
on
Methyl
Bromide
Alternatives
&
Emissions
Reductions).
In
addition,
the
quality
of
the
end
product
was
also
reduced.
Specifically,
grower
response
was
not
enthusiastic
to
cover
cropping
since
they
hope
to
avoid
growing
a
non­
income­
generating
crop
for
several
months
prior
to
their
cash
crop,
ginger.
In
addition,
a
cover
crop
might
be
still
vulnerable
to
adverse
weather
conditions
and
interfere
with
the
timely
planting
of
the
ginger
crop.
This
research
focused
on
root­
knot
nematode
control
and
not
on
bacterial
wilt
control.
Since
ginger
is
a
long
term
crop
and
the
root­
knot
controlling
effects
of
sunn
hemp
may
not
suppress
the
late
nematode
population
growth
as
it
normally
does
for
shorter
term
cropping
systems,
other
cover
crops
are
currently
being
investigated
for
reducing
root­
knot
nematode
in
ginger.
Additional
research
in
this
area
would
be
beneficial.

Solarization.
Solarization
is
not
a
technically
feasible
alternative
by
itself
because
it
does
not
adequately
control
the
target
pests
and
studies
show
a
95
percent
yield
loss
compared
to
methyl
bromide.
The
yield
when
methyl
bromide
is
applied
at
a
rate
of
329
kgs/
hectare
is
9,864
kgs/
hectare
(
based
on
3/
91
Nematode
Control
in
Ginger
CES
Progress
Report).
Yield
with
soil
solarization
treatment
is
448
kgs/
hectare,
resulting
in
a
yield
loss
of
95
percent.
The
soil
was
solarized
for
2
weeks
with
4
mil
clear
plastic.
Nematode
damage
with
soil
solarization
treatment
was
twice
as
high
as
the
damage
in
non­
treated
soil
and
almost
seven
times
higher
than
the
methyl
bromide
treatment.
The
cool
coastal
climate
and
high
rainfall
(
over
254
centimeters
per
year)
of
the
region
are
not
suitable
to
attain
high
enough
temperature
levels
to
adequately
control
nematodes.
This
research
has
focused
on
root­
knot
nematode
control
and
not
on
bacterial
wilt
control.

Solarization
and
fungicides.
Solarization
with
the
use
of
fungicides
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
there
are
no
registered
fungicides
for
use
on
ginger
root.
Chloropicrin
has
the
ability
to
control
fungi.
However,
based
on
the
June
1994
CES
research
report,
Evaluation
of
Alternative
Fumigants
for
Ginger
Root,
chloropicrin
treatments
alone
(
rates
of
203
kgs/
hectare,
404
kgs/
hectare,
and
806
kgs/
hectare)
resulted
in
zero
harvestable
yields
due
to
damage
inflicted
by
uncontrolled
bacterial
wilt.

Flooding
and
water
management.
Flooding
is
not
a
technically
feasible
alternative
because
Hawaiian
ginger
growing
soil
texture
is
very
sandy
and
porous
and
the
practice
will
actually
aggravate
the
spread
of
root­
knot
nematodes
(
as
well
as
other
soil
diseases)
to
other
farm
sites.

General
Integrated
Pest
Management
(
IPM).
IPM
is
currently
being
used
but
it
is
not
technically
feasible
as
a
stand­
alone
alternative
because
it
does
is
not
currently
control
the
primary
target
pests
of
ginger.
Basic
IPM
control
strategies
focus
on
good
management
practices
utilizing
proper
seed
selection,
new
land
selection,
and
good
sanitation
procedures,
but
IPM
without
methyl
bromide
use
often
results
in
yield
and
quality
losses
in
ginger.
A
hot
water
dip
is
already
used
on
ginger
seed
pieces
to
control
the
transfer
of
root­
knot
nematode
from
the
seed
pieces
to
the
field.
Potential
ginger
fields
are
also
examined
to
make
sure
that
the
fields
are
free
of
bacterial
wilt.
Also,
it
is
important
to
make
sure
that
water
from
adjacent
fields
does
not
run
into
ginger
fields
and
bring
in
nematode
eggs
or
bacterial
cells.
Page
10
Grafting/
resistant
rootstock/
plant
breeding.
Grafting,
resistant
rootstock
and
plant
breeding
are
not
technically
feasible
alternatives
because
ginger
cannot
be
grafted
since
its
flowering
period
is
very
short.
There
is
no
information
on
traditional
breeding
or
genetic
engineering
research
for
ginger
root.

Organic
Amendments/
Compost.
Organic
amendments/
composting
are
currently
being
used
but
are
not
technically
feasible
alternatives
by
themselves
because
they
do
not
control
ginger
pests
and
result
in
yield
and
quality
losses.
Studies
of
crop
rotations
and
cover
crops
that
deliver
organic
matter
to
the
soil
show
that
alone
they
are
not
comparable
with
ginger
root
production
with
methyl
bromide.
It
is
common
practice
for
chicken
or
cow
manure
to
be
added
as
a
soil
amendment
in
ginger
root
production,
however
the
selected
organic
matter
must
be
compatible
with
a
long
term
cropping
cycle.
Research
indicates
that
soil
amendments
such
as
chicken
manure,
added
to
soil
infested
with
bacterial
wilt
have
the
potential
to
suppress
and/
or
inhibit
the
pathogen.
Specifically,
there
is
research
that
suggests
that
44,834
kgs/
hectare
of
chicken
manure
will
control
pests
but
not
eliminate
them.

Additional
research
is
needed
in
this
area,
but
at
this
point
this
alternative
appears
technically
infeasible.

6e.
Economic
Feasibility
of
Alternatives
None
of
the
above
alternatives
listed
by
MBTOC
and
reviewed
were
found
to
be
technically
feasible
for
ginger,
therefore,
no
economic
analysis
was
conducted.
However,
a
brief
discussion
of
the
economic
aspects
of
some
of
the
MBTOC
methyl
bromide
alternatives
for
ginger
root
are
provided
below.

Fallow.
As
mentioned
in
the
previous
section,
a
multi­
year
study
of
fallowing
in
ginger
production
reported
a
22
percent
yield
loss
and
reduction
in
harvest
quality.
Such
a
yield
loss,
coupled
with
even
a
10
percent
reduction
in
price
for
quality
reasons,
would
result
in
sufficient
losses
to
make
the
alternative
(
which
has
been
already
identified
as
technically
infeasible
because
it
does
not
alone
control
the
target
pests,
specifically
root
knot
nematode
and
bacterial
wilt)
economically
infeasible.
It
is
pertinent
to
note
here
that
the
price
of
ginger
dropped
33
percent
from
US$
0.45
/
lb
in
2001
to
US$
0.30/
lb
in
2002
as
a
result
of
a
lower
quality
product
and
increased
imports
from
Asia.
The
lower
quality
product
was
claimed
by
the
exemption
applicant
to
be
associated
with
fewer
hectares
being
fumigated
with
methyl
bromide.

Table
3.
Loss
Measures
with
Fallow
and
10
Percent
Price
Loss
Percent
Yield
Loss
22%

Gross
Revenue
Loss
29%

Increased
Costs
as
a
%
of
Gross
Revenue
­
13%

Loss
as
a
%
of
Gross
Revenue
16%

$
Loss/
Hectare
US$
8,342
$
Loss
per
kg
ai
of
methyl
bromide
US$
20.19
Page
11
%
Operating
Profit
Loss
100%

Profit
Margin
(­
18%
with
methyl
bromide)
­
47%

Steam.
Steam
is
currently
used
in
Florida
for
chrysanthemum
propagative
material
(
or
"
cuttings")
The
capital
cost
of
a
boiler
and
equipment
is
about
US$
236,000.
This
investment
has
the
capacity
to
treat
about
900
square
meters
in
about
2
days
to
a
depth
of
about
20
cm
in
sandy
soil.
At
this
rate
it
would
take
about
3
weeks
to
treat
one
hectare
at
an
operating
cost
of
over
US$
14,000
per
hectare.
To
treat
more
hectares
would
require
more
equipment
and/
or
more
time.
This
technology
is
only
marginally
economically
feasible
even
for
chrysanthemum
cuttings
(
arguably
a
higher
value
product
than
ginger
root),
because
the
equipment
can
be
used
throughout
the
year
since
chrysanthemum
cuttings
are
planted
throughout
the
year
at
different
times.
However,
for
ginger,
such
a
capital
investment
would
not
be
economically
feasible
for
using
just
one
time
each
year.
Furthermore,
the
cost
would
be
higher
because
the
terrain
is
hilly
and
the
equipment
would
have
to
be
mobile
to
cover
the
widely
scattered
rented
plots.

Ozone.
Some
research
has
been
done
with
ozone
on
other
crops.
While
the
costs
of
treating
soil
with
ozone
at
a
rate
of
280
kg/
hectare
are
comparable
to
methyl
bromide,
a
large
initial
investment
would
be
required.
The
capital
cost
of
enough
ozone
generating
capacity
to
treat
one
hectare
per
day
at
a
rate
280
kg/
hectare
would
be
almost
US$
500,000.
Such
an
investment
would
be
economically
infeasible
for
small
growers
such
as
ginger
farmers,
especially
since
test
results
of
ozone
are
very
preliminary.
Although
ozone
out
performs
untreated
controls,
there
is
very
little
data
comparing
it
to
methyl
bromide.
(
SoilZone,
1999)

7.
Critical
Use
Exemption
Nomination
for
Ginger
Root
The
actual
amount
of
methyl
bromide
being
requested
for
ginger
root
production
is
18,340
kgs
of
98
percent
methyl
bromide.
This
would
be
needed
for
45
hectares
each
year
in
2005,
2006,
and
2007
(
Table
4).
This
is
about
35
percent
of
the
total
area
planted
(
based
on
2002
U.
S.
Department
of
Agriculture
(
USDA)
survey
data).
Rates
as
requested
conform
to
standard
practices
in
this
region.

Table
4.
Hawaiian
Ginger
Production
­
Methyl
Bromide
Use
and
Request
1997
1998
1999
2000
2001
2005
2006
2007
kgs
44,680
43,930
54,530
11,620
8,890
18,340
18,340
18,340
hectares
108
106
132
28
22
45
45
45
rate
(
kg/
hectare)
412
413
412
413
407
412
412
412
The
U.
S.
nomination
for
ginger
root
production
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
Page
12
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
5.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Ginger
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
18,336
9,221
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
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
Emissions
of
Methyl
Bromide
in
the
U.
S.

In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country
The
use
of
methyl
bromide
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
is
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
is
machine
injected
into
soil
to
specific
depths.
In
addition,
as
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
methyl
bromide
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
Page
13
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
reflected
in
our
requests
for
2005
and
beyond.

Ginger
growers
currently
use
tarpaulins
(
high
density
polyethylene),
select
appropriate
crop
sites,
and
use
proper
field
preparation
and
application
methods,
all
in
an
effort
to
minimize
their
use
and/
or
emissions
of
methyl
bromide.
They
also
plan
to
use
non­
fumigant
herbicides
as
they
become
available
and
are
registered
on
this
crop.
They
rotate
to
land
that
has
not
been
planted
in
ginger
(
though
the
cost
and
ability
to
secure
rented
land
is
uncertain
each
year
and
creates
inconsistency
in
the
adoption
of
this
practice).

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
Page
14
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
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
Page
15
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
nonchemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
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.

Although
ginger
production
is
small
compared
to
other
crops
that
rely
on
methyl
bromide,
it
has
been
a
focus
of
research
activity
on
the
national
level.
Ginger
root
growers
have
remained
committed
to
finding
replacements
for
methyl
bromide
although
their
support
has
been
limited
by
the
financial
conditions
of
this
small
crop
sector.
Approximately
US$
40,000
has
been
spent
on
research
for
alternatives
on
behalf
of
this
industry,
solely
in
the
state
of
Hawaii.

In
2001,
research
on
ginger
bacterial
wilt
was
funded
through
a
special
allocation
to
the
ARS.
A
full
time
plant
pathologist
is
employed
to
work
on
the
project
through
the
Tropical
Germplasm
Research
Project
of
the
Pacific
Basin
Agriculture
Research
Center
(
PBARC).
The
project
works
Page
16
with
the
tropical
commodity
treatment
group
with
PBARC
within
ARS,
and
also
cooperatively
with
the
University
of
Hawaii,
Hilo
and
Manoa,
the
Hawaii
Agriculture
Research
Center,
the
Agriculture
Extension
Service,
ginger
farmers,
and
other
industry
interests.
A
broad
approach
of
an
interdisciplinary
nature
is
being
applied
to
this
research
area.
Areas
of
study
include
clean
seed
production,
the
genetic
diversity
of
the
bacterial
wilt
pathogen,
interactions
of
bacteria
wilt
with
other
bacteria
in
the
ginger
crop
system,
improved
ways
to
assay
the
pathogen
in
the
field,
and
potential
methods
for
improving
disease
management.

In
addition
to
the
significant
national
research
to
find
alternatives
to
methyl
bromide,
ginger
root
growers
have
to
date
undertaken
significant
efforts
to
find
replacements.
Ivan
Kawamoto,
of
the
grower
group
Mokichi
Okada
Association
(
MOA),
received
funds
from
U.
S.
EPA
via
a
grant
to
American
Farmland
Trust,
for
August
1999
to
December
2000,
to
use
organic
amendments
and
cover
crops
for
nematode
(
root­
knot
and
reniform)
control
and
nutrient
supply
(
two
Crotalaria
species
and
organic
compost)
in
growing
ginger.
The
results
were
compared
to
results
from
fallow
plots
used
as
controls.
There
was
no
apparent
damage
from
either
the
root­
knot
or
reniform
nematodes
in
the
experimental
plots.
Ginger
crops
following
Crotalaria
had
greater
nutrient
levels
than
those
following
fallow
soil,
thus
accounting
for
differences
in
total
weights
harvested
between
treatments.
Further
trials
are
needed
to
demonstrate
the
consistency
of
these
promising
results.

While
past
research
has
not
demonstrated
the
full
efficacy
of
methyl
bromide
alternatives,
research
is
underway
and
still
more
is
planned.
For
example,
the
Hawaiian
College
of
Tropical
Agriculture
and
Human
Resources,
under
Dwight
Sato,
Vegetable
Production
Extension
Agent,
is
planning
to
field
test
a
new
application
method
using
1,
3
dichloropropene
(
telone
C­
35)
as
a
pre­
plant
soil
fumigant
for
root­
knot
nematode
control
in
2003.
It
is
hoped
that
this
formulation
will
provide
both
nematode
and
fungal
control
of
soil
pests.
Sato
is
also
collaborating
with
Ron
Harding,
a
Dow
Chemical
Western
Regional
Technical
Representative
based
in
California,
on
the
construction
of
a
telone
fumigation
application
rig
for
Hawaii's
hilly
terrain.
A
field
demonstration
will
be
installed
in
late
Spring
2003
with
a
cooperating
ginger
grower.
The
resulting
yield
and
disease
control
will
be
measured
after
harvest
in
early
2004.
This
trial
will
consist
of
a
simple
field
crop
comparison
of
telone
fumigation
vs.
no
fumigation
in
90
square
meter
plots.
Ginger
plantings
will
be
otherwise
maintained
according
to
typical
industry
standards.

Studies
are
also
being
planned
to
study
the
efficacy
of
iodomethane,
in
combination
with
plastic
tarps,
on
both
nematodes
and
bacterial
wilt
in
ginger
crops
in
Hawaii.
Tests
in
other
crops
have
shown
that
this
product
performs
very
similarly
to
methyl
bromide
in
controlling
soil
pests
and
diseases
but
without
harming
the
ozone
layer.

As
regards
non­
chemical
alternatives
to
methyl
bromide,
some
research
suggests
that
heated
air
reduces
bacterial
wilt
incidence.
Studies
conducted
using
non­
saturated
heated
air
to
control
bacterial
wilt
on
the
seeds
showed
that
effective
treatment
was
obtained
when
seed
pieces
were
heated
for
30
minutes
and
their
center
temperatures
maintained
at
49
oC
for
60
minutes.
Over
85
percent
of
the
seeds
in
this
trial
germinated.
However,
additional
research
is
needed
to
investigate
the
feasibility
of
the
application
of
heat
treatment
to
large
quantities
of
seeds.
Field
tests
are
also
Page
17
needed
to
study
the
long­
term
effects
of
the
heat
treatment
on
crop
growth
and
rhizome
yield.

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
(
licenses)
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,
the
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

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

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
than
the
resources
to
evaluate
them,
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
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
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.
Page
18
As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized.

The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
methyl
bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

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

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

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

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
Page
19
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.

While
none
of
the
registration
activity
envisioned
currently
or
in
the
near
future
specifically
involves
ginger
as
a
use
site,
the
U.
S.
is
committed
to
helping
minor
crop
producers
ensure
the
availability
of
necessary
pesticide
alternatives.
As
registrations
of
new
materials
are
completed
on
other
crops,
U.
S.
EPA,
USDA
and
programs
such
as
the
IR­
4
program
will
work
with
registrants
to
encourage
support
of
registration
of
these
products
on
smaller
crop
sites,
such
as
ginger.

It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
even
registering
those
alternatives
is
not
the
end
of
the
story.
Alternatives
must
be
tested
by
users
and
found
to
be
technically
and
economically
feasible
before
widespread
adoption.
As
noted
by
TEAP,
once
a
specific
alternative
is
available,
it
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
in
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.

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

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
ginger
root
sector
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
U.
S.
ginger
root
production
covered
by
this
nomination.
Accordingly,
we
believe
that
methyl
bromide
is
necessary
for
successful
and
profitable
ginger
root
production
in
the
U.
S..
In
order
for
the
ginger
farmers
in
Hawaii
to
compete
with
the
world
production
of
ginger
imports,
it
is
imperative
that
they
continue
to
have
access
to
the
use
of
methyl
bromide
to
manage
root­
knot
nematode
and
bacterial
wilt.
In
addition,
we
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
Page
20
in
ginger
root
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
unreasonable
adverse
effects
to
human
health
and
the
environment,
is
a
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
ginger
root
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
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
Page
21
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
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:
Page
22
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
13.
References
Economics
of
Ginger
Root
Production
in
Hawaii.
Dec.
1998.
Agribusiness.
Hawaii
Cooperative
Extension
Service,
College
of
Tropical
Agriculture
and
Human
Resources,
University
of
Hawaii
at
Manoa.

Hawaii
Ginger
Root:
Annual
Summary.
2002.
Hawaii
Agricultural
Statistics
Service
(
HASS).
Hawaii
Department
of
Agriculture
and
U.
S.
Department
of
Agriculture.

Martin,
Donald
A.
2002.
Hawaii
Ginger
Root.
Hawaii
Agricultural
Statistics
Service
(
HASS).
Hawaii
Department
of
Agriculture
and
U.
S.
Department
of
Agriculture.

Nishina,
M.
S.,
D.
M.
Sato,
W.
T.
Nishijima,
R.
F.
L.
Mau.
1992.
Ginger
Root
Production
In
Hawaii.
Commodity
Fact
Sheet
GIN­
3(
A).
Hawaii
Cooperative
Extension
Service,
Hawaii
Institute
of
Tropical
Agriculture
and
Human
Resources,
University
of
Hawaii
at
Manoa.

Ozone
Gas
as
a
Soil
Fumigant.
1998.
Electric
Power
Research
Institute.
SoilZone,
1999.

Sato,
Dwight
and
Don
Schmidt.
1991.
Nematode
Control
in
Ginger
CES
Progress
Report.

Sato,
Dwight.
1994.
Evaluation
of
Alternative
Fumigants
for
Ginger
Root
Research
Report.

Sato,
Dwight.
1998.
Reducing
Methyl
Bromide
in
Preplant
Soil
Treatment
for
Ginger
Root.

Sato,
Dwight,
Bob
Joy
and
Matthew
Wung.
Sunn
Hemp
`
Tropic
Sun'
as
a
Cover
Crop
in
Edible
Page
23
Ginger
Production"
.
Presentation
delivered
at
the
2000
International
Conference
on
Methyl
Bromide
Alternatives
&
Emissions
Reductions.

Tsang,
M.
M.
C.
and
M.
Shintaku.
1998.
Hot
Air
Treatment
for
Control
of
Bacterial
Wilt
in
Ginger
Root.
Applied
Engineering
in
Agriculture.
Vol
14(
2):
159­
163.

14.
Appendices
Appendix
A.
List
of
critical
use
exemption
requests
for
the
ginger
crop
sector
in
the
U.
S.

CUE
02­
0045.
Application
for
Critical
Use
Exemption
for
Methyl
Bromide
Use
in
Hawaii
Ginger.
Page
24
Appendix
B.
Spreadsheets
Supporting
Economic
Analyses
This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
sub­
regions
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
25
*
kg
ai
that
would
be
applied/
hectare
=
application
rate
for
the
alternatives
or
requested
application
rate
for
MBr.

*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
Page
26
Page
27
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.
Page
28
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
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.
Page
29
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
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,
reregistration
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
Page
30
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).

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
Page
31
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).

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
postharvest
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.
Page
32
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
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
Page
33
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).

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
Page
34
(
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.
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
Page
35
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
(
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
36
Appendix
D:
CHARTS
(
See
the
separate
electronic
file
for
CHART
1
and
CHART
2)
