Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
ORCHARD
NURSERIES
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
comprehensive
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
orchard
nurseries,
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
orchard
nurseries
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
Page
2
much
different
from
the
criteria
negotiated
for
"
essential
uses"
for
other
chemicals.

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
orchard
nurseries,
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
orchard
nurseries
is
discussed
later
in
this
nomination.

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

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

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

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

The
Parties
to
the
Protocol
recognized
that
unlike
other
chemicals
controlled
under
the
Montreal
Protocol,
the
use
of
methyl
bromide
and
available
alternatives
could
be
site
specific
and
must
take
into
account
the
particular
needs
of
the
user.
Page
3
The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
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
Orchard
Nurseries
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
EPA)
initiated
open
meetings
with
stakeholders
both
to
inform
them
of
the
Protocol
requirements,
and
to
understand
the
issues
being
faced
in
researching
alternatives
to
methyl
bromide.
During
those
meetings,
which
were
attended
by
State
and
associated
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
U.
S.
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11,
which
calls
for
specific
information
to
be
presented
in
the
nomination.

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

Finally,
and
concurrent
with
our
preparation
phase,
we
developed
a
plan
to
ensure
a
robust
and
timely
review
of
any
and
all
critical
use
applications
we
might
receive.
This
involved
the
assembly
of
more
than
45
PhDs
and
other
qualified
reviewers
with
expertise
in
both
biological
and
economic
issues.
These
experts
were
divided
into
interdisciplinary
teams
to
enable
primary
and
secondary
reviewers
for
each
application/
crop.
As
a
consequence,
each
nomination
received
by
the
U.
S.
was
reviewed
by
two
separate
teams.
In
addition,
the
review
of
these
interdisciplinary
teams
was
put
to
a
broader
review
of
experts
on
all
other
sector
teams
to
enable
a
third
look
at
the
information,
and
to
ensure
consistency
in
review
between
teams.
The
result
was
a
thorough
evaluation
of
the
merits
of
each
request.
A
substantial
portion
of
requests
did
not
meet
the
criteria
of
decision
IX/
6,
and
a
strong
case
for
those
that
did
meet
the
criteria
has
been
included.
Page
4
Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.

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
for
producing
crops.
These
factors
contribute
to
and
enable
the
U.
S.
to
be
a
uniquely
large
and
productive
agricultural
producer.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farmland
totaled
381
million
hectares,
a
land
mass
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
sizes
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables
has
had
an
important
impact
on
the
way
agriculture
has
developed
in
the
U.
S.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

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

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

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
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
Page
5
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.

5b.
Orchard
Nurseries
The
orchard
nursery
sector
(
Appendix
A),
like
many
agricultural
sectors
in
the
U.
S.,
is
varied
and
complex.
The
fruit
tree
nurseries
(
including
citrus,
peaches,
prunes,
nectarines,
cherries,
plums,
apples,
avocados,
pears,
and
ornamental
fruit
trees)
in
California,
and
the
raspberry
nurseries
in
California
and
Washington
produce
the
majority
of
the
tree
seedlings
for
the
industry.
California
generates
95
percent
of
sales.
The
majority
of
the
sales
go
to
commercial
fruit
growers
and
the
remaining
trees
are
flowering
varieties
sold
primarily
to
landscapers.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
and
"
commercially
clean
with
respect
to
established
pests
of
general
distribution"
in
order
to
qualify
for
a
California
nursery
stock
certificate
for
interstate
and
intrastate
shipments.
Also,
according
to
the
California
code
of
regulations,
nursery
stock
for
commercial
farm
planting
must
be
nematode
free.
If
a
nursery
producer
uses
methyl
bromide,
and
in
certain
cases
if
1,3­
dichloropropene
(
manufactured
as
Telone
®
)
is
used,
the
crop
is
assumed
to
be
"
free
of
especially
injurious
pests
and
disease
symptoms".
However,
if
a
grower
fumigates
with
an
alternative
or
does
not
fumigate
at
all,
the
California
Department
of
Food
and
Agriculture
(
CDFA)
will
impose
nematode
sampling
requirements
at
a
cost
to
the
grower.

Practices
used
in
various
segments
of
the
industry
differ
significantly.
A
description
of
those
practices
follows:

Citrus
and
Avocado
Tree
Nursery
Practices.
Citrus
nursery
trees
for
commercial
production
include
seedling
rootstock,
which
is
budded
to
a
fruiting
scion
variety.
The
citrus
seedling
production
consists
of
two
phases­
seedling
production
until
transplanting
and
field
growing.
Each
nursery
has
approximately
12
hectares
of
seedling
production
annually.

Seeds
are
harvested
from
orchard
trees
of
a
known
lineage
grown
specifically
for
seed
production.
Once
the
seeds
are
harvested,
they
are
sown
into
flats,
seedbeds,
or
other
seedling
containers
in
the
greenhouse,
or
are
sown
into
other
protected
areas
during
the
spring.
As
seedlings
emerge,
they
are
inspected
for
off­
types
and
unhealthy
individuals,
which
are
discarded.
The
remaining
selected
seedlings
are
grown
to
the
desired
size.
In
some
cases
the
seedlings
are
transplanted
into
larger
interim
containers,
which
do
not
exceed
20
cm
diameter
and
80
cm
height.
During
this
stage
the
seedlings
are
usually
grown
in
a
soilless
substrate.
Routine
inspections
are
performed
to
detect
pests
or
diseases.
Once
the
seedlings
have
reached
the
desired
size
they
are
transplanted
to
the
field.
Page
6
During
the
field
growing
phase,
the
selected
seedlings
are
transplanted
into
larger
field
plots
or
into
larger
pots.
In
either
case,
the
growing
area
is
outdoors
and
exposed
to
full
sunlight.
The
substrate
generally
consists
of
a
mixture
of
topsoil,
sand
and
organic
material
in
pots.
These
materials
are
brought
to
the
nursery
from
outside
sources
and
held,
sometimes
for
sever
years.
For
the
in­
ground
production,
organic
amendments
may
be
worked
into
the
soil.
The
CDFA
mandates
that
the
substrate
be
commercially
clean
of
pests
and
diseases,
of
particular
concern
are
nematodes.
In
order
to
comply
with
the
mandate,
and
the
nursery's
covenant
with
its
customers
to
supply
pest­
free
materials,
the
substrates
are
fumigated
with
methyl
bromide
on
a
yearly
basis
prior
to
planting.
The
soil
substrate
is
blended
to
the
desired
makeup,
and
spread
and
fumigated
in
compliance
with
CDFA
regulations.
Pots
are
then
filled
with
the
fumigated
potting
substrate.
For
in­
field
production,
the
soil
is
worked
and
irrigated
to
the
proper
moisture
levels,
and
then
fumigated.

Seedlings
are
grown
in
the
field
until
appropriate
size,
a
process
that
takes
12
to
28
months.
Other
factors
that
influence
the
production
process
include
the
vigor
of
the
tree
and
bud
varieties,
and
weather
and
temperature
in
a
given
growing
period.

Deciduous
Tree
Nursery
Practices.
Deciduous
tree
nurseries
range
from
15
to
600
hectares
in
size.
The
median
size
of
a
California
operation
ranges
from
80
to
120
hectares.
While
some
nurseries
grow
specific
tree
crops,
most
grow
and
sell
a
wide
number
of
trees
types.
Nursery
stock
is
grown
in
a
system
that
includes
crop
rotation
or
cover
cropping
between
tree
production
cycles;
therefore,
not
all
of
a
nursery
is
in
tree
production
in
a
given
year.

The
tree
production
cycle
can
be
anywhere
from
one
to
several
years
depending
on
the
type
of
tree.
Trees
stay
in
nurseries
from
one
to
four
years
in
the
ground.
For
example,
almonds
typically
are
grown
for
one
year
while
walnuts
grow
for
two
years.

A
typical
nursery
cycle
starts
by
digging
the
current
tree
crop
then
planting
a
cover
crop,
for
one
or
two
years,
followed
by
replanting
with
a
new
tree
crop.
In
order
to
prepare
the
ground
for
planting,
the
fields
are
disked,
deep
ripped,
leveled,
and
then
fumigated
to
meet
certification
standards
set
by
CDFA.
Generally,
the
fumigation
work
is
contracted
to
a
pesticide
application
specialist.
A
shank
is
used
to
apply
a
broadcast
fumigation
of
75
percent
methyl
bromide
with
25
percent
chloropicrin
at
rate
of
340
kg/
ha.
At
the
same
time
the
majority
of
the
nursery
growers
cover
the
treated
area
with
a
high
barrier
tarp.
The
fumigations
are
carried
out
in
September,
and
planting
begins
in
October,
and
may
continue
through
January.

As
with
citrus
and
avocado
nurseries,
the
deciduous
tree
nurseries
come
under
the
same
mandates
set
forth
by
the
CDFA,
i.
e.,
trees
must
be
pest
free
to
be
sold
and
shipped.
Nurseries
use
methyl
bromide
to
meet
certification
requirements
because
it
is
the
only
method
acceptable
by
CDFA,
with
a
possible
exception
of
1,3­
dichloropropene,
which
is
allowed
in
limited
situations;
however,
due
to
restrictions
on
total
1,3­
dichloropropene
use
in
designated
areas
("
townships"),
this
chemical
may
be
unavailable
to
growers,
even
if
it
effectively
manages
their
pest
problems.
Page
7
Raspberry
Nursery
Practices.
The
raspberry
nursery
industry
uses
flat
fumigation
techniques
similar
to
the
strawberry
nurseries.
Raspberry
nursery
stock
is
grown
on
a
two
year
production
cycle
beginning
with
tissue
culture
followed
in
the
first
year
by
foundation
planting.
Winter
dormant
plants
are
replanted
in
commercial
nurseries
and
harvested
after
one
year.

6.
Results
of
Review
 
Determined
Need
for
Methyl
Bromide
in
Orchard
Nurseries
The
U.
S.
orchard
nursery
industry
is
varied
and
production
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture.
The
sector
is
large
and
diverse,
and
orchard
nurseries
are
situated
in
a
number
of
areas
with
diverse
soils,
climates,
and
production
systems.
The
sector
also
faces
significant
pest
problems
and
local
pesticide
regulatory
restrictions
that
may
limit
the
use
of
some
MBTOC
alternatives.
Sections
6a­
e
below,
address
production
and
pest
management
considerations
for
the
orchard
nursery
sector,
and
describe
the
critical
need
for
methyl
bromide
in
this
industry.

6a.
Target
Pests
Controlled
with
Methyl
Bromide
Nematodes
of
concern
in
the
nursery
industry
in
Washington
and
California
are
Meloidogyne
spp.,
Pratylenchus
spp.,
Trichodorus
spp.,
Xiphinema
spp.,
and
Criconemella
spp.,
Tylenchulus
semipenetrans,
and
Radopholus
similes.

While
nematodes
are
of
greatest
concern
to
the
nursery
industry,
methyl
bromide
successfully
manages
other
pests.
Weeds
(
nutsedges,
common
purslane,
lambsquarter,
little
mallo,
watergrass,
field
bindweed,
and
ragweed)
and
fungal
pathogens
(
Phytophthora
citrophthora,
P.
parasitica,
P.
cinnamomi,
Verticillium
spp.,
and
Armillaria
mellea)
are
important
pests
that
can
limit
tree
health
and
yield.

6b.
Overview
of
Technical
and
Economic
Assessments
of
Alternatives
Intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
yield
and
quality
goals.
The
nematicide
1,3­
dichloropropene
can
be
an
effective
tool
in
managing
nematode
problems
in
orchards
when
combined
with
metam­
sodium
or
chloropicrin,
or
both,
but
there
are
three
important
caveats.
First,
these
products
generally
are
effective
only
in
light,
sandy
soils
(
about
35
percent
of
orchards
in
California).
Second,
there
are
legal
restrictions,
called
"
township
caps",
in
the
use
of
1,3­
dichloropropene.
Third,
nursery
stock
must
be
certified
as
nematode­
free,
and
methyl
bromide
treatment
meets
the
legal
standard
for
this
certification
that
is
only
partially
applicable
to
alternatives
such
as
1,3­
dichloropropene.
Details
of
these
issues
are
described
in
the
following
sections.

Because
of
the
importance
placed
on
tree
quality
(
due
to
the
high
correlation
of
nursery
tree
quality
with
subsequent
orchard
health
and
value),
failure
to
achieve
consistently
healthy
nursery
trees,
in
even
a
portion
of
nursery
production
areas,
can
have
a
devastating
effect
on
this
sector's
ability
to
provide
acceptable
trees
for
orchard
establishment.
These
strategies
can
result
in
Page
8
reduced
tree
production.
Furthermore,
legal
requirements
for
certification
of
stock
as
nematodefree
introduces
additional
constraints
on
the
use
of
alternative
pest
management
measures.
In
addition,
as
the
analysis
below
demonstrates,
these
potential
alternatives
when
compared
with
methyl
bromide
are
not
economically
feasible.

MBTOC
identified
several
alternatives
for
use
in
nursery
orchards
that
are
considered
below
(
Table
1).
Page
9
Table
1.
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Orchard
Nurseries
(
Deciduous
Trees,
Raspberry
Stock,
and
Citrus
and
Avocado
Trees).
Methyl
Bromide
Alternatives
Deciduous
Nursery
Trees
Raspberry
Nursery
Stock
Citrus
and
Avocado
Nursery
Trees
Technical
Feasiblity
Economic
Feasibility
1
Technical
Feasiblity
Economic
Feasiblity
Technical
Feasiblity
Economic
Feasiblity
1,3­
Dichloropropene
2
No
No
No
No
No
No
1,3­
Dichloropropene
+
Chloropicrin
RLU
3
RLU
RLU
RLU
RLU
RLU
1,3­
Dichloropropene
+
Metam­
sodium
RLU
RLU
RLU
RLU
RLU
RLU
1,3­
Dichloropropene
+
Chloropicrin
+
Metamsodium
RLU
RLU
RLU
RLU
RLU
RLU
Dazomet
(
Basamid
®
)
No
No
No
No
No
No
Chloropicrin
No
No
No
No
No
No
Metam­
sodium
No
No
No
No
No
No
Biofumigation
No
No
No
No
No
No
Solarization
No
No
No
No
No
No
Steam
No
No
No
No
No
No
Cover
crops/
Mulch
No
No
No
No
No
No
Crop
residue
compost
No
No
No
No
No
No
Crop
rotation/
Fallow
No
No
No
No
No
No
Flooding/
Water
management
No
No
No
No
No
No
Integrated
Pest
Management
No
No
No
No
No
No
Grafting/
Resistant
rootstocks/
cultivars
No
No
No
No
No
No
Organic
amendments
No
No
No
No
No
No
Organic
production
No
No
No
No
No
No
Physical
removal/
Sanitation
No
No
No
No
No
No
Plowing
and
Tillage
No
No
No
No
No
No
Resistant
rootstock
and
Solarization
No
No
No
No
No
No
Soilless
culture
No
No
No
No
No
No
Plug
Plants
No
No
No
No
No
No
Biological
Control
No
No
No
No
No
No
1
Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
feasibility.
2
1,3
dichloropropene
is
manufactured
in
the
U.
S.
as
Telone
®
.
3
There
is
a
regulatory
limit
on
use
(
RLU)
of
1,3­
dichloropropene
in
the
U.
S.

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Page
10
The
technical
and
economic
assessments
describe
the
three
in­
kind
(
chemical)
alternatives
(
Table
1)
of
those
identified
by
MBTOC
that
in
some
situations
are
technically
feasible
for
orchard
nursery
pest
management.
These
are
1,3­
dichloropropene
+
chloropicrin,
1,3­
dichloropropene
+
metam­
sodium,
and
1,3­
dichloropropene
+
chloropicrin
+
metam­
sodium.
The
alternatives
identified
by
MBTOC
were
regarded
by
reviewers,
as
technically
and
economically
infeasible
for
acceptable
management
of
nematodes
where
certification
requirements
are
mandated
by
law.
They
were
generally
effective
in
orchards
with
light,
sandy
soils
and
where
legal
use
restrictions
make
them
available.
As
a
result,
the
nomination
being
put
forward
reflects
the
potential
use
of
alternatives
to
methyl
bromide
in
certain
situations.

1,3­
Dichloropropene
+
Chloropicrin;
1,3­
Dichloropropene
+
Metam­
sodium;
and
1,3­
Dichloropropene
+
Chloropicrin
+
Metam­
sodium.

The
alternatives
to
methyl
bromide
with
the
most
promise
for
orchard
nurseries
are
combinations
of
chemicals
that
include
1,3­
dichloropropene.
The
two
major
constraints
for
use
of
these
chemicals
are
the
inconsistency
in
pest
control
that
is
soil­
type
dependent,
and
legal
restrictions
on
use
of
1,3­
dichloropropene.

Studies
indicate
that
1,3­
dichloropropene
in
conjunction
with
chloropicrin
or
metam­
sodium,
may,
in
some
circumstances,
be
feasible.
Used
alone,
1,3­
dichloropropene
does
not
appear
to
be
technically
feasible
because
it
is
not
acceptably
effective
against
weeds
and
pathogens.
Chemicals
in
combination
with
1,3­
dichloropropene
are
currently
used
in
some
situations,
and
the
specific
situations
in
which
it
could
be
used
were
factored
into
a
final
decision
on
the
level
of
the
U.
S.
nomination
in
this
area.
However,
the
efficacy
or
potential
of
1,3­
dichloropropene
use
as
an
alternative
is
limited
by
several
technical
and
regulatory
factors.
Specifically,
1,3­
dichloropropene
alternatives
are
not
technically
feasible
alternatives
for
orchard
nurseries
with
heavy,
clay
soils.
Research
done
on
almond
and
peach
rootstocks
indicates
the
typical
rate
of
333
liters/
ha
would
not
provide
adequate
control
of
nematode
problems
in
the
heavier
soils.
Researchers
suggest
that
there
may
not
be
a
quality
loss
using
this
regimen,
but
there
probably
would
be
a
yield
loss.

Due
to
the
length
of
time
it
takes
to
generate
data
about
crop
yield
and
quality
in
orchard
nurseries
there
are
no
definitive
data
at
this
time,
although
field
trials
of
methyl
bromide
alternatives
are
on­
going.

Inadequate
soil
diffusion
of
1,3­
dichloropropene
and
metam­
sodium,
except
in
optimal
soil
conditions,
such
as
light,
sandy
type
soils,
reduces
the
area
that
can
be
effectively
treated
with
alternative
products.
More
tillage
and
supplemental
irrigations
are
required
for
these
alternatives,
compared
to
methyl
bromide,
to
provide
proper
tilth
and
soil
moisture
necessary
for
acceptable
efficacy.
These
additional
activities
prolong
preparation
time
causing
the
grower
to
miss
the
fumigation
window
prior
to
the
onset
of
the
rainy
season.
This
can
result
in
a
year's
delay
in
establishing
the
orchards,
except
for
walnuts
where
harvest
comes
too
late
for
replanting
even
with
methyl
bromide.
Page
11
California
regulations
limit
how
much
1,3­
dichloropropene
can
be
used
in
specific
locations
called
"
townships"
during
a
year.
California
restricts
the
amount
of
1,3­
dichloropropene
that
can
be
used
in
certain
locations
because
it
is
a
hazardous
air
pollutant
and
a
ground
water
contaminant.
As
a
result,
the
growers
in
these
specific
"
townships"
cannot
unilaterally
shift
to
1,3­
dichloropropene
instead
of
methyl
bromide
because
of
the
risk
of
not
being
able
to
obtain
the
alternative.
Within
these
specific
townships,
all
the
growers
of
various
crops,
such
as
carrots,
sweet
potatoes,
grapes,
almonds
and
walnuts,
compete
for
the
limited
quantity
of
1,3­
dichloropropene
(
under
the
cap)
that
can
be
used
in
a
year.
Once
the
cap
is
reached,
the
growers
in
the
township
will
need
to
have
another
option
for
their
soil
fumigation
production
practices.
If
the
township
cap
is
exceeded
early
in
the
year,
when
most
of
the
crops
are
planted,
there
will
not
be
any
1,3­
dichloropropene
available
for
growers
to
use
later
in
the
year.
The
California
township
caps
for
1,3­
dichloropropene
are
relatively
new
and
the
lack
of
historical
information
makes
it
difficult
to
predict
if
growers
will
reach
the
limit
on
1,3­
dichloropropene
within
specific
townships.

As
a
result,
the
U.
S.
views
a
portion
of
the
nomination
for
California
for
a
methyl
bromide
critical
use
exemption
as
a
"
contingent
nomination."
In
situations
where
1,3­
dichloropropene
is
technically
feasible,
if
the
situation
is
such
that
the
California
1,3­
dichloropropene
township
cap
limits
access
to
1,3­
dichloropropene
for
orchard
nurseries,
the
U.
S.
believes
there
would
be
a
critical
need
for
methyl
bromide
for
the
production
of
orchard
nursery
crops
for
that
portion
of
California
townships
not
able
to
use
1,3­
dichloropropene.
If
the
1,3­
dichloropropene
township
cap
is
not
reached,
in
areas
where
1,3­
dichloropropene
is
effective,
the
orchard
nurseries
would
not
need
methyl
bromide.
If
a
quantity
of
methyl
bromide
is
nominated
and
approved
for
an
exemption,
but
some
amount
is
not
used,
the
un­
used
portion
of
the
exemption
would
not
adversely
impact
the
ozone
layer.
Instead,
the
approval
of
the
exemption
would
be
a
crucial
safety
valve
for
a
critical
methyl
bromide
need.

Finally,
in
California
tree
nursery
production
must
meet
a
99.9
percent
nematode­
free
standard
in
order
for
a
nursery
to
be
certified
under
CDFA
regulations.
Other
states,
including
Washington,
have
similar
regulations
for
nursery
stock.
In
sandy
soils
1,3­
dichloropropene
with
chloropicrin,
metam­
sodium,
or
both,
can
be
effective
as
long
as
township
caps
have
not
been
exceeded.
In
heavier
clay
soils,
1,3­
dichloropropene
combinations
are
not
technically
feasible
due
to
the
failure
provide
consistently
high
quality
nursery
stock
that
would
be
allowed
for
sale
and
shipping.

Dazomet
(
Basamid
®
)
.
Dazomet
is
not
technically
feasible
for
orchard
nurseries
because
it
does
not
effectively
manage
nursery
pest
problems,
especially
nematodes.

Metam­
Sodium
(
Vapam
®
,
Busan
®
)
.
Metam­
sodium
alone
is
not
technically
feasible
for
orchard
nurseries
because
it
does
not
effectively
manage
nursery
pest
problems,
especially
nematodes.

Chloropicrin.
Chloropicrin
has
some
activity
against
weeds,
nematodes,
and
pathogens,
but
it
does
not
effectively
manage
nursery
pest
problems,
especially
nematodes.
It
is
used
successfully
Page
12
in
combination
with
methyl
bromide
and
allows
lower
rates
of
methyl
bromide.

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
An
economic
assessment
was
made
for
1,3­
dichloropropene
+
chloropicrin,
1,3­
dichloropropene
+
metam­
sodium,
and
1,3­
dichloropropene
+
chloropicrin
+
metam­
sodium,
which
were
alternatives
that
were
assessed
as
conditionally
technically
feasible
(
see
Table
1).

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

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

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

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

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

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

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

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
use
by
orchard
nurseries.
Because
producers
(
suppliers)
Page
13
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

Economic
reviewers
analyzed
potential
economic
losses
from
using
1,3­
dichloropropene
+
chloropicrin,
1,3­
dichloropropene
+
metam­
sodium,
and
1,3­
dichloropropene
+
chloropicrin
+
metam­
sodium
because
they
are
currently
considered
technically
feasible
alternatives
for
nursery
orchards,
although
only
with
light,
sandy
soils
and
where
1,3­
dichloropropene
may
be
available
under
"
township
cap"
restrictions.

The
alternatives
1,3­
dichloropropene
with
chloropicrin
and/
or
metam­
sodium
were
not
economically
feasible,
in
general,
because
of
the
requirement
that
the
nursery
stock
be
certified
as
pest
free.
If
an
approved
fumigation
chemical
is
not
used
in
the
nursery,
a
costly
nematode
sampling
procedure
is
imposed
by
CDFA.
If
nematodes
are
found,
all
nursery
stock
in
an
area
must
be
destroyed,
resulting
in
the
loss
of
one
or
two
years
work
and
income.
As
discussed
above,
if
soils
are
amenable
to
1,3­
dichloropropene
and
legal
restrictions
do
not
apply,
the
use
of
1,3­
dichloropropene
with
chloropicrin
or
metam­
sodium
may
serve
as
a
methyl
bromide
alternative.
The
U.
S.
has
taken
these
very
limited
cases
into
account
in
compiling
the
nomination
for
a
methyl
bromide
critical
use
for
orchard
nurseries.
A
general
cost
analysis
was
done
for
the
alternatives
and
is
reported
in
Appendix
B.

6e.
Technical
Feasibility
of
"
Not
In­
Kind"
MBTOC
Alternatives
This
section
summarizes
the
analysis
of
the
"
not
in­
kind"
(
non­
chemical)
alternatives
identified
by
MBTOC
for
orchard
nurseries.
Table
1
contains
a
summary
of
the
technical
assessment,
which
shows
that
none
of
the"
not
in­
kind"
alternatives
were
found
to
be
technically
feasible,
and
therefore
no
economic
assessment
was
conducted.

Each
of
the
"
not
in
kind"
(
non­
chemical)
alternatives
for
orchard
nurseries,
listed
in
Table
1,
was
deemed
technically
infeasible
as
a
substitute
for
methyl
bromide.
These
alternatives
do
not
effectively
manage
the
pests
associated
with
orchard
nurseries,
especially
nematode
problems,
and
are
not
approved
as
measures
that
would
allow
state
certification
for
nematode­
free
stock.
However,
many
of
these
alternatives
are
currently
being
employed
with
current
orchard
nursery
practices
in
addition
to
methyl
bromide,
and
serves
as
a
useful
measure
to
optimize
and
even
reduce
the
use
of
methyl
bromide.
Some
of
the
listed
alternatives,
such
as
biofumigation
and
solarization
are
not
feasible
due
to
planting
times
or
the
lack
of
practicality
for
biofumigation
to
work
(
in
terms
of
the
amount
of
biomass
needed
to
provide
control).
In
general
the
effective
soil
depth
of
these
alternatives
is
insufficient
relative
to
where
the
pests,
especially
nematodes,
are
found.
Biological
control
may
have
a
role
in
the
future
as
part
of
an
Integrated
Pest
Management
(
IPM)
program.
The
University
of
California
has
made
progress
in
the
area
of
biological
control
but
research
is
still
in
the
early
stages.
The
other
above
listed
alternatives
work
well
in
conjunction
with
other
practices,
but
can
not
act
alone
alternatives
to
methyl
bromide.
Page
14
The
following
is
a
description
of
the
technical
feasibility
of
not
in­
kind
alternatives
for
orchard
nurseries:

Biological
Control.
Biological
control
is
already
being
used
in
certain
regions
of
the
U.
S.
as
a
part
of
integrated
pest
management
programs,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
There
are
a
limited
number
of
biological
organisms
that
are
effectively
used
to
manage
soil
borne
diseases
and
pests.
Biological
control
agents
are
usually
very
specific
in
regards
to
the
organisms
they
control
and
their
successful
establishment
is
highly
dependent
on
environmental
conditions.
California
growers
use
biological
control
organisms
primarily
for
insect
management.
Any
choice
of
alternative
fumigants
must
be
evaluated
for
compatibility
with
this
important
component
of
their
existing
integrated
pest
management
system.

Cover
crops/
mulching.
Cover
crops/
mulching
is
already
being
used
many
nurseries
to
reduce
weed
populations
and
as
a
part
of
IPM
programs,
but
it
does
not
offer
adequate
pest
control
by
itself.

Flooding
and
water
management.
Flooding
and
water
management
is
not
being
used
and
it
is
not
technically
feasible.
In
California,
use
of
flooding
is
not
practical
because
of
limited
water
resources
and
the
uneven
topographic
features
of
many
production
areas
prevent
complete
flooding
of
the
higher
areas.

General
IPM
(
Integrated
Pest
Management).
General
IPM
is
being
used,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
IPM
practices
include
monitoring,
field
sanitation
to
limit
inoculum
buildup,
crop
rotation
to
provide
non
host
periods,
and
breeding
for
resistance
to
pathogens.
IPM
practices
do
not
offer
adequate
pest
control
alone.

Organic
amendments/
compost.
Organic
amendments/
compost
is
already
being
used
in
orchard
nurseries,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
Composting
is
management
intensive
and
it
does
not
offer
adequate
pest
control
by
itself.

Steam.
Steam
for
soil
sterilization
is
impractical
in
large­
scale,
open
field
production
areas
characteristic
of
large
orchard
nurseries
(
up
to
600
hectares
in
size).
A
1998
United
Nations
assessment
indicates
that
this
alternative
is
only
practical
in
small­
scale
production
areas.

Biofumigation.
Biofumigation
is
not
technically
feasible
because
of
difficulty
in
obtaining
sufficient
biomass
to
produce
effective
amounts
of
MITC
to
manage
diseases
and
weeds
under
nursery
conditions.
Furthermore,
MITC
is
not
particularly
effective
against
nematodes,
a
major
pest
of
orchard
nurseries.
In
some
nurseries,
trials
have
grown
mustard
species
(
Brassica
spp.)
for
disking
into
the
soil
to
generate
the
bioactive
breakdown
product
MITC.
Eleven
metric
tons
per
hectare
of
Brassica
plants
 
an
amount
that
is
considered
high
production
 
is
equivalent
to
approximately
68
kg
of
dazomet,
which
is
significantly
less
than
effective
dazomet
fumigation
rates.
Page
15
Solarization.
Solarization
is
not
technically
feasible
because
it
would
require
several
months
of
covered
beds
to
heat
soil
to
a
sufficient
depth
(
25­
30
cm)
in
order
to
affect
soil­
borne
pathogens.
Large­
scale
commercial
nursery
production
is
not
amenable
to
this
technique.

Crop
rotation/
Fallow.
Cover
crops
and
mulching
are
not
technically
feasible
alternatives
because
there
are
no
data
to
suggest
acceptable
pest
management,
especially
to
the
extent
required
for
nematode­
free
certification.
However,
the
use
of
cover
crops
is
a
common
practice
to
improve
soil
structure
and
suppress
an
array
of
soilborne
pathogens.
Cover
crops
and
mulches
have
been
integrated
to
orchard
nursery
practices.

Physical
removal/
Sanitation.
Physical
removal
and
sanitation
are
not
technically
feasible
because
it
is
not
available
for
nematode
control.
Appropriate
sanitation
is
already
practiced
by
nurseries
as
this
improves
productivity.

Plowing/
Tillage.
Plowing
and
tillage
are
not
technically
feasible
because
nematode
and
other
pests
are
not
effectively
controlled.
Plowing/
tillage
is
currently
being
used
but
by
itself
is
not
sufficient
to
adequately
control
the
target
pests.

7.
Critical
Use
Exemption
Nomination
for
Orchard
Nurseries
This
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
(
Table
2)
for
orchard
nurseries
for
field
and
nursery
pot
fumigation.
The
nomination
for
orchard
nurseries
in
California
and
Washington
is
a
"
contingent
nomination".
This
is
based
on
growers'
need
for
methyl
bromide,
if
the
area
in
which
orchard
nursery
crops
are
grown
has
reached
the
legal
limit
of
1,3­
dichloropropene
use,
or
where
1,3­
dichloropropene
used
in
conjunction
with
other
chemicals,
are
ineffective
due
to
heavy,
clay
soil
types.
Because
nurseries
occur
in
areas
with
intensive
agricultural
production,
1,3­
dichloropropene
"
township
caps"
may
be
reached
early
in
the
season.
Therefore,
methyl
bromide
will
be
critical
for
use
in
nursery
orchards
in
these
situations.
Similarly,
orchards
with
heavy,
clay
soils
do
not
have
alternatives
to
methyl
bromide
to
meet
legal
certification
requirements.
Table
2
provides
information
on
methyl
bromide
historical
usage,
including
area
treated,
and
actual
amount
requested
for
orchard
nurseries.

Table
2.
Methyl
Bromide
Usage
and
Request
for
Orchard
Nurseries
(
Western
Raspberry
Consortium,
Deciduous
Fruit
and
Nut
Tree
Nurseries,
and
Citrus
and
Avocado
Nurseries).
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
258,132
239,190
266,315
250,171
246,976
290,088
293,458
296,995
hectares
792
754
843
793
773
895
908
922
rate
(
kg/
ha)
336
332
331
310
293
346
346
346
The
U.
S.
nomination
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
Page
16
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
3.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Orchard
Nurseries
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
290,088
45,789
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
Use/
Emissions
of
Methyl
Bromide
in
the
United
States
In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country
The
use
of
methyl
bromide
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
is
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
is
machine
injected
into
soil
to
specific
depths.
In
addition,
as
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
methyl
bromide
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
Page
17
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.
Reduced
methyl
bromide
concentrations
in
mixtures,
more
mechanized
soil
injection
techniques,
and
the
extensive
use
of
tarps
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world.

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

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

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

Research
Program
When
the
United
Nations,
in
1992,
identified
methyl
bromide
as
a
chemical
that
contributes
to
the
depletion
of
the
ozone
layer
and
the
Clean
Air
Act
committed
the
U.
S.
to
phase
out
the
use
of
Page
18
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
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
Page
19
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.

Research
conducted
by,
and
on
behalf
of,
the
deciduous
tree,
and
citrus
and
avocado
nurseries
has
been
actively
seeking
methyl
bromide
alternatives.
Studies
include
alternatives
to
methyl
bromide
in
stone
fruit
and
walnut;
plant
growth
promoting
Rhizobacteria
in
walnut
and
Prunus
nurseries
and
orchards;
epidemiology
and
control
of
crown
gall
on
walnuts;
evaluation
of
alternatives
for
fumigation
in
commercial
fruit
and
nut
tree
nurseries;
evaluation
of
broccoli
residue
for
nematode
control
on
nursery
fruit
and
nut
tree
rootstocks
and
grapevines;
propagation
and
retesting
of
walnut
rootstock
genotypes
putatively
resistant
to
Phytophthora
spp.,
crown
gall,
and
nematodes;
development
of
molecular
assay
for
identification
of
plant
parasitic
nematode
species
in
soil
samples;
tarped
metam­
sodium
as
a
replacement
for
methyl
bromide
for
nematode
control
on
nursery
fruit
and
nut
tree
rootstocks
and
grapevines
under
northern
California
nursery
conditions;
and
four
approaches
to
treatment
of
finer
textured
nursery
soils
after
2005.
In
addition,
the
citrus
and
avocado
industry
will
continue
to
study
1,3­
dichloropropene.
The
Western
Raspberry
Nursery
Consortium
has
tested
fumigation
alternatives
in
nurseries
in
Washington
and
California
for
several
years.
1,3­
dichloropropene
with
chloropicrin
and
metam­
Page
20
sodium
combinations
are
currently
being
assessed
for
efficacy.
Raspberry
breeding
programs
have
screened
stock
for
resistance
to
Phytophthora
spp.
and
Verticillium
spp.

Government
funded
studies
related
to
U.
S.
orchard
nurseries
that
are
currently
on­
going
include
the
following:

1.
Etiology,
Epidemiology,
and
Management
of
Diseases
of
Deciduous
Tree
Fruits
and
Nuts,
and
Small
Fruit
(
Nov.,
1999
 
July,
2004)
The
objective
of
the
research
is
to
determine
the
etiology
and
epidemiology
of
Phytophthora
root
and
crown
rots,
bacterial,
virus
and
virus­
like
diseases
of
tree
fruits
and
nuts,
grapevines
and
strawberries.
Other
objectives
are
to
develop
improved
reliable
methods
to
detect
and
identify
the
pathogens
associated
with
these
diseases.
In
addition,
research
attempts
to
develop
safe,
effective,
environmentally
sound
disease
management
strategies,
including
alternatives
to
methyl
bromide
pre­
plant
soil
fumigation.

2.
Sustainable
Systems
for
Control
of
Soilborne
Diseases
in
Tree
Fruit
Agro­
Ecosystems
(
Nov
2002
­
Nov
2007)
The
fundamental
goal
of
this
research
program
is
the
development
of
sustainable
methods
for
the
control
of
soilborne
diseases
of
fruit
trees.
Thus,
the
objectives
are
to
examine
the
plant
genotype­
specific
induction
of
disease
suppressive
soils
with
attention
to
the
operative
soil
microbial
communities
and
host
factors
contributing
to
this
phenomenon,
investigate
the
role
of
soil
microbial
communities
in
disease
suppression
attained
through
incorporation
of
Brassicaceae
plant
residues,
evaluate
clonal
rootstocks,
evaluate
Malus
germplasm
and
resistance
to
Rhizoctonia
solani
and
Pythium
spp.,
support
plant
beneficial
microbial
communities,
and
develop
and
field
validate
biologically
sustainable
management
strategies
for
control
of
soilborne
diseases,
with
emphasis
on
apple
replant
disease,
in
conventional
and
organic
production
systems.

3.
Biology
and
Management
of
Soilborne
Diseases
and
Beneficial
Soil
and
Root­
Inhabiting
Microorganisms
(
March,
1998
 
March,
2003)
The
objective
is
to
develop
and
evaluate
biologically­
based
strategies
for
the
management
of
soilborne
disease
and
parasitic
nematodes
of
small
fruit
and
nursery
crops.
An
additional
objective
is
to
characterize
mechanisms
of
biological
control
of
soilborne
plant
diseases,
and
evaluate
the
etiology
and
epidemiology
of
soilborne
disease
of
small
fruit
and
nursery
crops
and
the
biology
of
causal
pathogens.
Work
will
also
attempt
to
develop
management
practices
that
optimize
mineral
nutrient
use
and
root
development
and
function
of
grapevines.

4.
Soil
Solarization
Component
of
Integrated
Program
to
Control
Phytophthora
Root
Rot
of
Red
Raspberry
(
July,
2001
 
July,
2006)
This
research
will
evaluate
soil
solarization
and
in
combination
with
raised
beds
and
gypsum
soil
amendments
in
an
integrated
plan
for
controlling
root
rot
on
red
raspberry.

5.
Factors
Affecting
the
Production
and
Processing
of
Small
Fruit
Or
Nursery
Crops
in
the
Pacific
Northwest
(
U.
S.)
(
Sept.,
1999
to
Sept.,
2003)
Page
21
The
objective
of
this
cooperative
research
project
is
to
determine
factors
that
can
improve
the
production
and
processing
practices
used
for
horticultural
crops
(
especially
nursery
crops
and
small
fruit
crops)
grown
in
the
Pacific
Northwest,
including
cultural
practices,
propagation
methods,
environmental
stresses,
diseases,
insects
(
and
mites),
soil
fertility
and
fertilization,
organic
amendments,
irrigation,
pruning,
and
irrigation.

6.
Development
of
an
IPM
Framework
for
Implementation
of
Methyl
Bromide
Alternatives
into
Orchard
and
Vineyard
Replant
Settings
(
UC
Riverside/
CSREES­
Oct.,
2000
to
Sept.,
2005)
This
work
will
evaluate
newly
developed
strategies
and
tactics
that
will
replace
methyl
bromide
use
in
commercial
vineyards,
orchards
and
nurseries.

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,
EPA
registers
pesticides
provided
its
use
does
not
pose
unreasonable
adverse
effects
to
humans
or
the
environment.
Under
FFDCA,
the
U.
S.
EPA
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
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
EPA,
unless
it
has
an
exemption
from
regulation
under
FIFRA.
Page
22
Since
1997,
the
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
priority.
Because
the
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
the
EPA
to
initiate
its
review.
The
average
processing
time
for
a
new
active
ingredient,
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
most
cases,
the
registrant
(
the
pesticide
applicant)
has
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
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
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
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
Page
23
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:

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

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

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

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
by
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
potential
alternatives
identified
by
MBTOC
for
orchard
nurseries
are
not
technically
or
economically
feasible
as
covered
by
this
exemption
nomination
for
the
orchard
nursery
sector.
Certain
MBTOC
alternatives
(
1,3­
dichloropropene
with
chloropicrin,
with
Page
24
metam­
sodium,
or
with
both
chloropicrin
and
metam­
sodium)
were
only
effective
against
major
pests
of
orchard
nurseries
within
limited
situations.
For
instance,
these
chemicals
are
only
effective
against
nematodes
and
plant
pathogens
when
orchards
have
light,
sandy
soils.
In
the
orchards
with
heavier,
clay
soils
these
chemicals
are
not
effective
because
of
low
diffusion
into
soils.
Furthermore,
because
of
certification
restrictions
for
nematode­
free
nursery
stock,
only
methyl
bromide
provides
overall
consistent
results
in
heavy,
clay
soils.
Finally,
there
are
restrictions
in
the
use
of
1,3­
dichloropropene
due
to
"
township
caps"
that
limit
the
total
amount
of
1,3­
dichloropropene
allowed
in
a
certain
area.
Once
the
limit
has
been
reached
no
further
use
of
1,3­
dichloropropene
is
legal.
Therefore,
even
when
alternatives
containing
1,3­
dichloropropene
are
effective,
township
limitations
may
make
them
unavailable.
As
a
result,
methyl
bromide
is
being
supported
for
use
by
the
orchard
nursery
sector
for
those
nurseries
that
have
no
effective
alternatives
to
methyl
bromide,
or
in
cases
where
alternatives
are
not
available
due
to
legal
restrictions.

The
U.
S.
expends
significant
efforts
to
find
and
commercialize
alternatives,
and
potential
alternatives
to
the
use
of
methyl
bromide
for
orchard
nurseries.
However,
the
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
unreasonable
adverse
effects
on
human
health
or
the
environment,
is
a
long
and
rigorous
one.
The
U.
S.
need
for
methyl
bromide
for
orchard
nurseries
will
be
maintained
for
the
period
being
requested.

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

a.
Request
for
Aggregate
Exemption
for
All
Covered
Methyl
Bromide
Uses:
As
mandated
by
Decision
XIII/
11,
the
nomination
information
that
is
being
submitted
with
this
package
includes
information
requested
on
historic
use
and
estimated
need
in
individual
sectors.
That
said,
we
note
our
agreement
with
past
MBTOC
and
TEAP
statements
which
stress
the
dynamic
nature
of
agricultural
markets,
uncertainty
of
specific
production
of
any
one
crop
in
any
specific
year,
the
difficulty
of
projecting
several
years
in
advance
what
pest
pressures
might
prevail
on
a
certain
crop,
and,
the
difficulty
of
estimating
what
a
particular
market
for
a
specific
crop
might
look
like
in
a
future
year.
We
also
concur
with
the
MBTOC's
fear
that
countries
that
have
taken
significant
efforts
to
reduce
methyl
bromide
use
and
emissions
through
dilution
with
chloropicrin
may
be
experiencing
only
short
term
efficacy
in
addressing
pest
problems.
On
the
basis
of
those
factors,
we
urge
the
MBTOC
and
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
Page
25
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
outyear
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
made
two
to
three
years
in
advance
of
the
time
of
actual
use.

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

c.
Duration
of
Nomination:
It
is
important
to
note
that
while
the
request
included
for
the
use
above
appears
to
be
for
a
single
year,
the
entire
U.
S.
request
is
actually
for
two
years
 
2005
and
2006.
This
multi­
year
request
is
consistent
with
the
TEAP
recognition
that
the
calendar
year
does
not,
in
most
cases,
correspond
with
the
cropping
year.
This
request
takes
into
account
the
facts
that
registration
and
acceptance
of
new,
efficacious
alternatives
can
take
a
long
time,
and
that
alternatives
must
be
tested
in
multiple
cropping
cycles
in
different
geographic
locations
to
Page
26
determine
efficacy
and
consistency
before
they
can
be
considered
to
be
widely
available
for
use.
Finally,
the
request
for
multiple
years
is
consistent
with
the
expectation
of
the
Parties
and
the
TEAP
as
evidenced
in
the
Parties
and
MBTOC
request
for
information
on
the
duration
of
the
requested
exemption.
As
noted
in
the
Executive
Summary
of
the
overall
U.
S.
request,
we
are
requesting
that
the
exemption
be
granted
in
a
lump
sum
of
9,920,965
kilograms
for
2005
and
9,445,360
kilograms
for
2006.
While
it
is
our
hope
that
the
registration
and
demonstration
of
new,
cost
effective
alternatives
will
result
in
even
speedier
reductions
on
later
years,
the
decrease
in
our
request
for
2006
is
a
demonstration
of
our
commitment
to
work
toward
further
reductions
in
our
consumption
of
methyl
bromide
for
critical
uses.
At
this
time,
however,
we
have
not
believed
it
possible
to
provide
a
realistic
assessment
of
exactly
which
uses
would
be
reduced
to
account
for
the
overall
decrease.

12.
Contact
Information:

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

John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
US
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
e­
mail:
ThompsonJE2@
state.
gov
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
13.
References
Browne,
G.,
L.
Bulluck,
J.
Connell,
T.
Trout
and
S.
Schneider.
2001.
Determining
unknown
causes
of
replant
disorder
on
Prunus
species
in
California,
Conference
proceedings
of
the
2001
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions,
at
http://
mbao.
org/
2002proc/
mbrpro01.
html.
Page
27
Browne,
G.,
J.
Connell,
L.
Bulluck,
T.
Trout
and
S.
Schneider.
2002.
Management
of
replant
disorder
on
almond
and
peach,
Conference
proceedings
of
the
2002
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions,
at
http://
mbao.
org/
2002proc/
mbrpro02.
html.

Buchner,
R.,
J.
Edstrom,
J.
Hasey,
W.
Krueger,
W.
Olson,
W.
Reil,
K.
Klonsky
and
R.
De
Moura.
2002.
Sample
costs
to
establish
a
walnut
orchard
and
produce
walnuts,
Sacramento
Valley,
University
of
California
Cooperative
Extension,
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
cost­
studies/
WalnutSac2002.
pdf
Day,
K.,
H.
Andris,
R.
Beede,
K.
Klonsky,
R.
De
Moura
and
P.
Livingston.
2000a.
Sample
costs
to
establish
a
peach/
nectarine
orchard
and
produce
peaches/
nectarines,
southern
San
Joaquin
Valley,
University
of
California
Cooperative
Extension,
available
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
cost­
studies/
2000peach.
pdf.

Day,
K.,
H.
Andris,
R.
Beede,
K.
Klonsky,
R.
De
Moura
and
P.
Livingston.
2000b.
Sample
costs
to
establish
a
plum
orchard
and
produce
plums,
southern
San
Joaquin
Valley,
University
of
California
Cooperative
Extension,
available
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
cost­
studies/
Plums2000.
pdf.

Duncan,
R.,
P.
Verdegaal,
B.
Holtz,
K.
Klonsky
and
R.
De
Moura.
2002.
Sample
costs
to
establish
an
almond
orchard
and
produce
almonds,
San
Joaquin
Valley
North,
micro­
sprinkler
irrigation,
University
of
California
Cooperative
Extension,
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
coststudies/
AMSPRKVN02.
pdf.

Grant,
J.,
J.
Caprile,
K.
Kelley,
K.
Klonsky
and
R.
De
Moura.
2001.
Sample
costs
to
establish
an
orchard
and
produce
sweet
cherries,
San
Joaquin
Valley
­
North,
University
of
California
Cooperative
Extension,
available
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
coststudies
CherrySJVN2001.
pdf.

Klonsky,
K.,
H.
Andris,
B.
Beede,
S.
Sibbett
and
P.
Livingston.
1997.
Sample
costs
to
establish
a
prune
orchard
and
produce
prunes,
in
the
southern
San
Joaquin
Valley,
University
of
California
Cooperative
Extension,
available
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
cost­
studies/
97Prunes.
pdf.

Larson,
K.
D.
and
Shaw,
D.
V.
2000.
Soil
fumigation
and
runner
plant
production:
a
synthesis
of
four
years
of
strawberry
nursery
field
trials.
HortScience
35:
642­
646.

Larson,
K.
D.
and
Shaw,
D.
V.
1999.
A
meta­
analysis
of
strawberry
yield
response
to
preplant
soil
fumigation
with
combinations
of
methyl
bromide
 
chloropicrin
and
four
alternative
systems.
HortScience
34:
839­
845.

McKenry,
M.
V.
2000.
Evaluation
of
alternatives
to
methyl
bromide
for
soil
fumigation
at
Page
28
commercial
fruit
and
nut
tree
nurseries.
submitted
in
Critical
Use
Exemption
request,
originally
submitted
to
California
Department
of
Pesticide
Regulation
(
contract
#
98­
0281).

UNEP
(
United
Nations
Environment
Programme),
1998.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
1998
assessment
of
alternatives
to
methyl
bromide.
p.
49
U.
S.
Department
of
Agriculture,
National
Agricultural
Statistics
Service
(
USDA/
NASS).
2001.
Noncitrus
Fruits
and
Nuts,
2000
Summary,
July.

Yuen,
G.
Y.,
Schroth,
M.
N.,
Weinhold,
A.
R.,
and
Hancock,
J.
G.
1991.
Effects
of
soil
fumigation
with
methyl
bromide
and
chloropicrin
on
root
health
and
yield
in
strawberry.
Plant
Disease
75:
416­
420.

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

CUE­
02­
0010,
Western
Raspberry
Nursery
Consortium
CUE­
02­
0035,
California
Association
of
Nurserymen
 
Deciduous
Fruit
and
Nut
Tree
Growers
CUE­
02­
0036,
California
Association
of
Nurserymen
 
Citrus
and
Avocado
Growers
Page
29
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
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
30
#
Notes
1
Costs
and
revenues
are
per
crop
cycle
or
harvest.

Typically
one
crop
is
grown
for
2
years
every
4
years
with
2
years
of
fallow,
rotation,
or
cover
crop.

2
Based
on
strawberry
nursery
data.

3
This
estimate
was
added
to
be
consistent
with
CUEs
35
&
36.

No
yield
loss
estimates
were
available
specifically
for
raspberries,
so
the
yield
loss
impact
was
not
estimated.

The
cost
of
this
alternative
was
made
equal
to
CUEs
35
&
36
for
consistency.

*
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
31
Page
32
Page
33
Page
34
Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.
She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.
(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)
cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

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

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

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

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.
Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
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
Page
35
County.

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

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

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

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

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

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­
Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
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
Page
36
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.
Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).

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

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

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

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

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
Page
37
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.

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

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

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

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

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)
researching
Agricultural
Sciences
Center
in
Page
38
Parlier,
CA.
He
joined
ARS
in
June
of
1971.

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

Nikhil
Mallampalli
(
Biologist).
Nikhil
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
is
an
entomologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
and
analysis
of
the
impacts
of
risk
mitigation
on
pest
management.
Dr.
Mallampalli
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
holds
a
Master
of
Science
(
Entomology)
from
the
samr
institution.
Prior
to
joining
the
EPA,
he
worked
as
a
postdoctoral
research
fellow
at
Michigan
State
University
(
East
Lansing)
on
IPM
projects
designed
to
reduce
reliance
on
pesticides
in
small
fruit
production.

Tom
Melton
(
Biologist).
Tom
has
been
a
member
of
the
Plant
Pathology
faculty
at
North
Carolina
State
University
since
1987.
Starting
as
an
assistant
professor
and
extension
specialist,
Tom
has
become
the
Philip
Morris
Professor
at
North
Carolina
State
University.
His
primary
responsibilities
are
to
develop
and
disseminate
disease
management
strategies
for
tobacco.
Dr.
Melton
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
(
Pest
Management)
degree
from
North
Carolina
State
University
(
Raleigh).
He
is
a
1978
graduate
of
Norht
Carolina
State
University
(
Raleigh)
Prior
to
joining
the
North
Carolina
State
faculty,
Dr.
Melton
was
a
member
of
the
faculty
at
The
University
of
Illinois
(
Urbana­
Champaign).

Richard
Michell
(
Biologist).
Rich
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1972.
He
is
a
nematologist/
plant
pathologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
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
Page
39
organic
compounds
in
air,
water,
and
sediments.

Jack
Norton(
Biologist).
Jack
has
worked
for
the
U.
S.
Department
of
Agriculture
Interregional
research
Project
#
4
(
IR­
4)
as
a
consultant
since
1998.
The
primary
focus
of
his
research
is
the
investigation
of
potential
methyl
bromide
replacement
for
registration
on
minor
crops.
He
is
an
active
member
of
the
USDA/
EPA
Methyl
Bromide
Alternatives
Working
Group.
Dr,
Norton
earned
his
Ph.
D.
(
Horticulture)
from
Texas
A&
M
University
(
College
Station)
and
holds
a
Master
of
Science
(
Horticultural
Science)
from
Oklahoma
State
University(
Stillwater).
He
is
a
graduate
of
Oklahoma
State
University
(
Stillwater).
Prior
to
joining
the
IR­
4
program,
Dr.
Norton
worked
in
the
crop
protection
industry
for
27
years
where
he
was
responsible
for
the
development
and
registration
of
a
number
of
important
products.

Olga
Odiott
(
Biologist)
Olga
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Biologist
within
the
Office
of
Science
Coordination
and
Policy.
In
this
position
she
serves
as
Designated
Federal
Official
and
liaison
on
behalf
of
the
Office
of
Pesticide
Programs
and
the
FIFRA
Scientific
Advisory
Panel,
an
independent
peer
review
body
that
provides
advice
to
the
Agency
on
issues
concerning
the
impact
of
pesticides
on
health
and
the
environment.
She
holds
a
Masters
of
Science
(
Plant
Pathology)
from
the
University
of
Puerto
Rico
(
San
Juan).
Prior
to
joining
EPA,
Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

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

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
Page
40
University
and
at
the
University
of
New
Hampshire
(
Durham).

Judith
St.
John
(
Biologist).
Judy
has
been
with
the
USDA's
Agricultural
Research
Service
since
1967.
She
currently
serves
as
Associate
Deputy
Administrator
and
as
such
she
is
responsible
for
the
Department's
intramural
research
programs
in
the
plant
sciences,
including
those
dealing
with
pre­
and
post­
harvest
alternatives
to
methyl
bromide.
Dr.
St.
John
earned
her
Ph.
D.
(
Plant
Physiology)
from
The
University
of
Florida
(
Gainesville).

James
Throne
(
Biologist).
Jim
is
a
Research
Entomologist
with
the
U.
S.
Department
of
Agriculture's
Agricultural
Research
Service
and
Research
Leader
of
the
Biological
Research
Unit
at
the
Grain
Marketing
and
Production
Research
Center
in
Manhattan,
Kansas.
He
conducts
research
in
insect
ecology
and
development
of
simulation
models
for
improving
integrated
pest
management
systems
for
stored
grain
and
processed
cereal
products.
Other
current
areas
of
research
include
investigating
seed
resistance
to
stored­
grain
insect
pests
and
use
of
near­
infrared
spectroscopy
for
detection
of
insect­
infested
grain.
Jim
has
been
with
ARS
since
1985.
Dr.
Throne
earned
his
Ph.
D.
(
Entomology)
in
1983
from
Cornell
University
(
Ithaca)
and
earned
a
Master
of
Science
Degree
(
Entomology)
in
1978
from
Washington
State
University
(
Pullman).
Dr.
throne
is
a
1976
graduate
(
Biology)
of
Southeastern
Massachusetts
University
(
N.
Dartmouth).

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

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

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

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
Page
41
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
42
Appendix
D:
CHARTS
(
See
the
separate
electronic
file
for
Chart
1
and
Chart
2.)
