1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
ORCHARD
REPLANT
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
critical
use
exemption
nomination
in
a
manner
that
would
enable
a
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
replant
of
stone
fruit
including
(
cherry,
peach,
nectarine,
plum
and
prune),
and
almonds,
walnuts
and
grapes,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
U.
S.
finds
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
replant
of
stone
fruit
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,
but
not
adversely
affect
agriculture.
This
was
addressed
in
the
critical
use
exemption
provisions,
and
exemplified
by
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption
processes.
Those
differences
are
outlined
below.

The
Protocol's
negotiated
criteria
for
the
critical
use
exemptions
for
methyl
bromide
are
much
different
from
the
criteria
negotiated
for
"
essential
uses"
for
other
chemicals.

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
2
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
replant,
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
orchard
replantings
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
many
chemical
alternatives
to
methyl
bromide
are
toxic;
some
may
pose
higher
risks
to
human
health
or
the
environment
than
methyl
bromide.

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

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

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

The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
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
Replant
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
3
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
growers
from
across
the
U.
S.
to
discuss
their
specific
issues,
and
to
enable
them
to
understand
the
newly
detailed
requirements
of
the
critical
use
application.
These
sector
meetings
allowed
us
to
fine
tune
the
application
so
we
could
submit
the
required
information
to
the
MBTOC
in
a
meaningful
fashion.

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

Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
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
climates
favorable
to
growing
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.
4
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
the
broad
range
of
crops
produced.
For
example,
the
fruit
and
vegetable
sector,
the
agricultural
sector
most
reliant
on
methyl
bromide,
includes
production
of
107
separate
fruit
and
vegetable
commodities
or
groups
of
commodities.
With
this
diversity,
however,
has
come
a
large
number
of
pest
problems
that
methyl
bromide
has
proven
uniquely
able
to
manage.

Agricultural
productivity
has
enabled
the
U.
S.
to
meet
not
only
its
food
and
commodity
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
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
Replant
The
crops
covered
in
the
nomination
for
orchard
replant
(
Appendix
A)
in
California
are
very
important.
Among
stone
fruits,
peaches
are
grown
commercially
throughout
the
U.
S.,
but
the
majority
of
production
is
in
California,
with
over
70
percent
of
production
by
weight.
Nectarines,
which
are
a
variety
of
peach,
are
primarily
grown
in
the
same
orchards.
Sweet
cherries
are
produced
primarily
in
four
U.
S.
states,
California,
Michigan,
Oregon,
and
Washington,
with
California
being
a
relatively
minor
producer.
California
is
the
leading
producer
of
plums,
prunes,
and
table
grape,
with
over
97
percent
of
the
total
production.
Production
from
table
grape
vineyards
is
aimed
at
the
fresh
market,
although
a
portion
of
production
is
processed
and
dried
for
raisins
or
made
into
wine
or
juice.
California
is
the
sole
producer
of
almonds
and
walnuts
in
the
U.
S.
Table
1
provides
a
summary
of
area,
production
and
value
for
these
orchard
crops.
5
Table
1.
California
Orchard
Area,
Production
and
Value.
Crop
Area
of
Bearing
Trees
(
ha)
Yield
(
MT/
ha)
Total
Production
(
MT)
Percent
of
U.
S.
Production
Value
of
Production
(
US$
1000)
Peaches/
Nectarines
42,230
27.3
1,151,500
70.0
346,547
Sweet
Cherries
7,690
5.1
39,100
19.0
67,822
Plums
15,380
12.5
192,100
95.0
847,000
Prunes
33,600
20.1
677,000
98.0
101,080
Table
Grapes
36,840
19.8
728,100
98.0
433,924
Almonds
212,550
2.0
416,500
100.0
847,000
Walnuts
79,350
3.8
298,900
100.0
270,000
Noncitrus
Fruits
and
Nuts,
2001
preliminary
summary,
2002.

The
producing
life
of
an
orchard
varies
according
to
the
type
of
tree,
with
most
stone
fruit
producing
for
about
20
years.
Plum
trees
for
prunes
are
longer
lived,
lasting
about
40
years.
Grapes
and
almonds
typically
produce
for
about
25
years
and
walnuts
about
40
years.
When
production
declines,
the
old
trees
are
removed
and
new
trees
are
replanted
on
the
same
land.
While
most
of
the
biomass
of
the
old
trees
is
removed,
a
significant
amount
of
the
tree
roots
remain
in
the
soil.

Throughout
the
life
of
the
orchard
or
vineyard,
there
is
an
increase
in
populations
of
soil
pests
and
pathogens
(
see
Section
6a
below).
Old
established
trees
and
vines
can
withstand
moderate
to
high
pest
pressure,
but
young
stock
is
vulnerable
to
numerous
pests,
and
especially
pest
complexes
such
as
replant
disorder.
An
orchard
destined
for
replant
has
trees
harvested
from
September
to
October,
after
which
old
trees
are
removed
and
the
soil
is
prepared
and
fumigated.
Fumigation
with
methyl
bromide
effectively
kills
or
reduces
pest
populations
and
permits
seedlings
or
new
vines
to
become
established
in
the
absence
of
competing
organisms,
such
as
nematodes,
pathogens,
or
weeds.
Failure
to
adequately
control
the
range
of
pests
commonly
found
in
established
orchards
can
result
in
reduced
yields,
stunting
and
even
tree
mortality.
Methyl
bromide
penetrates
and
diffuses
through
soils
due
to
its
high
vapor
pressure.
Therefore,
it
can
be
used
effectively
on
various
soil
types
(
sandy
or
clay),
which
permits
rapid
orchard
replanting.
New
trees
are
planted
in
California
in
the
early
spring,
following
the
rainy
season
(
November
to
March)
to
optimize
root
development
and
growth
of
trees.
Walnuts,
however,
are
harvested
in
late
fall
and
it
is
rare
that
fields
can
be
fumigated
before
the
rainy
season.
Instead,
growers
leave
the
land
fallow
a
year,
fumigate
the
following
fall
and
plant
in
early
spring
of
the
next
year.

The
use
of
methyl
bromide
in
the
U.
S.
for
orchard
replant
exemplifies
many
of
the
broader
characteristics
of
U.
S.
agriculture
noted
above.
Methyl
bromide
is
currently
considered
to
be
critical
for
the
reestablishment
of
healthy
orchards
and
vineyards,
where
there
is
a
high
correlation
between
seedling
health
and
future
orchard
productivity.
For
this
use,
methyl
bromide
is
mechanically
injected
into
the
soil
immediately
prior
to
replanting
to
reduce
pest
populations
and
to
ensure
that
young
trees
and
vines
receive
optimal
growth
conditions.
After
orchard
replant,
soils
are
not
fumigated
during
the
productive
life
of
the
orchard
(
20
to
40
years).
6
6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
for
Orchard
Replant
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Growers
replanting
orchards
or
vineyards
on
non­
virgin
ground
face
what
is
often
referred
to
as
the
"
replant
problem."
The
replant
problem
is
a
poorly
understood
complex
that
refers
to
a
decline
in
vigor
of
the
orchard
crop
due
to
both
well­
defined
pests
and
unidentified
pests.
The
known
pests
include
fungal
pathogens,
including
Armillaria
spp.
and
Phytophthora
spp.,
and
parasitic
nematodes
that
infest
orchard
crops,
such
as
Mesocriconema
xenoplax
(
ring
nematode),
Meloidogyne
spp.
(
root
knot
nematodes),
Pratylenchus
vulnus
(
root
lesion
nematode),
and
Xiphinema
americanum
(
dagger
nematode).
In
addition,
a
newly
identified
insect
that
may
be
a
part
of
replant
disorder
in
California
is
the
Polyphylla
decemlineata
(
tenlined
June
beetle).
Weeds,
such
as
yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
(
Cyperus
rotundus
L.),
are
widely
recognized
for
their
economic
impact
in
replant
situations.
Weeds
compete
with
young
trees
for
water,
nutrients,
and
light,
especially
early
in
the
orchard
establishment,
and
methyl
bromide,
in
addition
to
effectively
managing
replant
disorder,
is
the
most
effective
treatment
for
reducing
competition
from
weeds.
Because
fumigation
is
administered
only
once
during
the
life
of
an
orchard,
maximum
effectiveness
of
pest
control
is
required
to
obtain
healthy
trees
and
optimal
yields.

6b.
Overview
of
Technical
and
Economic
Assessments
of
Alternatives
MBTOC
identified
several
alternatives
for
use
in
orchard
and
vineyard
replants;
these
are
listed
below
(
Table
2):

Table
2.
Methyl
Bromide
Alternatives
Identified
by
the
Methyl
Bromide
Technical
Options
Committee
for
Fruit
and
Nut
Tree
Orchard
Replant
and
Grape
Vineyard
Replant.
Methyl
bromide
alternatives
identified
for
fruit
and
nut
tree
orchards
Methyl
bromide
alternatives
identified
for
grape
vineyards
1,3­
dichloropropene
Sodium
tetrathiocarbonate
1,3­
dichloropropene
+
chloropicrin
Biofumigation
1,3­
dichloropropene
+
metam­
sodium
Solarization
Dazomet
(
Basamid
®
)
Steam
Metam­
sodium
Biological
control
Nematicides
Cover
crop
and
mulching
Biofumigation
Crop
rotation/
fallow
Solarization
Crop
residue
and
compost
Steam
Substrate/
plug
plants
Biological
control
Plowing/
tillage
Cover
crop
and
mulching
Resistant
cultivars
Crop
rotation/
fallow
Grafting/
resistant
rootstock
Physical
removal
Organic
amendments/
compost
Integrated
pest
management
None
of
these
alternatives
was
found
to
be
technically
feasible
for
use
on
table
and
raisin
grapes
replants.
None
of
the
alternatives
proposed
by
MBTOC
for
vineyards
provide
effective
control
of
the
replant
problem.
Of
the
alternatives
proposed
by
MBTOC
for
fruit
and
nut
orchards,
1,3­
7
dichloropropene
(
manufactured
as
Telone
®
)
alone
or
in
conjunction
with
chloropicrin
or
metam­
sodium,
has
shown
promise
on
some
soil
types
(
specifically
light
soils,
which
make
up
one
third
of
the
California
orchard
area),
but
research
on
tree
survival
and
on
yield
impacts
is
incomplete
because
long
orchard
life
and
high
establishment
costs
result
in
limited
sites
available
for
research
trials.

Economic
analyses
show
that
even
minimal
biological
impacts,
in
terms
of
planting
delays,
tree
survival
rates,
and
yield
losses,
as
may
be
expected
with
the
use
of
1,3­
dichloropropene,
can
significantly
reduce
the
value
of
an
orchard.
Furthermore,
as
a
potential
carcinogen,
use
of
1,3­
dichloropropene
is
severely
restricted
("
township
caps")
in
California
where
most
orchards
are
located.

While
testing
alternatives
has
been,
and
continues
to
be
done,
reliable
data
are
limited
for
fruit
and
nut
tree
orchards
because
of
the
time
required
for
studies
in
perennial
crops
and
to
the
difficulty
of
extrapolating
from
small
research
plots
to
commercial
scale
production
(
particularly
concerning
long­
term
impacts
on
yield).

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Three
alternatives
were
found
to
be
technically
feasible
for
orchards
(
at
least
for
certain
soil
conditions)
but
not
vineyards,
and
are
discussed
below.
A
summary
of
technical
and
economic
assessments
are
provide
in
Table
3a
(
stone
fruit,
almonds
and
walnut
replant)
and
Table
3b
(
vineyard
replant).
An
economic
analysis
of
the
technically
feasible
alternatives
are
reported
in
Section
6d.

Table
3a.
Technical
and
Economic
Assessments
of
Methyl
Bromide
Alternatives
for
Orchard
(
Stone
Fruit,
Almond
and
Walnut)
Replant.
Methyl
Bromide
Alternatives
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
1,3
Dichloropropene
Yes,
on
light
soils
No
1,3­
Dichloropropene
+
chloropicrin
Yes,
on
light
soils
No
1,3­
Dichloropropene
+
metam
sodium
Yes,
on
light
soils
No
Dazomet
(
Basamid
®
)
No
N/
A
Metam­
sodium
No
N/
A
Nematicides
No
N/
A
Biofumigation
No
N/
A
Solarization
No
N/
A
Steam
No
N/
A
Biological
control
No
N/
A
Cover
crops
and
mulching
No
N/
A
Crop
rotation/
fallow
No
N/
A
Note:
Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
viability.
8
Table
3b.
Technical
and
Economic
Assessments
of
Methyl
Bromide
Alternatives
for
Vineyard
(
Table
Grape)
Replant.
Methyl
Bromide
Alternatives
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Sodium
tetrathiocarbonate
No
N/
A
Biofumigation
No
N/
A
Solarization
No
N/
A
Steam
No
N/
A
Biological
control
No
N/
A
Cover
crops
and
mulching
No
N/
A
Crop
rotation/
fallow
No
N/
A
Crop
residue
and
compost
No
N/
A
Substrate/
plug
plants
No
N/
A
Plowing/
tillage
No
N/
A
Resistant
cultivars
No
N/
A
Grafting/
resistant
rootstock
No
N/
A
Physical
removal
No
N/
A
Organic
amendments/
compost
No
N/
A
Integrated
Pest
Management
No
N/
A
Note:
Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
viability.

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

These
three
alternatives
were
considered
conditionally
"
technically
feasible"
for
orchard
(
although
not
vineyard)
replant
since
they
appeared
to
provide
effective
management
of
replant
disorder,
but
generally
only
among
orchards
with
light,
sandy
type
soils.
Studies
indicated
that
1,3­
dichloropropene
,
alone
or
in
conjunction
with
chloropicrin
or
metam­
sodium,
may,
in
some
circumstances,
be
feasible.
1,3­
dichloropropene
is
currently
used
in
some
situations
(
for
example,
in
orchards
with
sandy
soils),
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
sector.
However,
the
efficacy
or
potential
of
1,3­
dichloropropene
use
as
an
alternative
is
limited
by
several
technical
and/
or
regulatory
factors.
Specifically,
1,3­
dichloropropene
alternatives
are
not
technically
feasible
alternatives
for
orchard
replant
in
medium
and
heavy,
clay
soils
(
comprising
approximately
65
percent
of
California
orchards).
Research
done
on
almond
and
peach
rootstocks
indicate
that
the
typical
rate
of
333
liters/
ha
would
not
provide
adequate
control
of
the
replant
problem
in
heavier
soils.
Researchers
suggest
that
there
may
not
be
a
quality
loss
using
this
regimen,
but
there
likely
would
be
a
yield
loss.

Field
trials
of
methyl
bromide
alternatives
are
on­
going.
In
some
field
trials
(
Browne
et
al.,
2001;
Browne
et
al.,
2002),
all
of
the
trees
had
to
be
replaced
due
to
ineffective
disease
control
with
alternatives.
Under
less
than
optimal
conditions
(
e.
g.,
poor
soil
preparation,
poor
moisture
content,
medium
and
heavy
soils),
1,3­
dichloropropene
does
not
diffuse
throughout
the
root
zone
to
be
effective
in
disease
management.
More
tillage
and
supplemental
irrigations
are
required
than
with
methyl
9
bromide
to
ensure
optimal
efficacy
of
the
alternative
compounds.
These
additional
activities
prolong
replant
preparation
time,
causing
a
delay
in
fumigation
and
potentially
preventing
application
prior
to
the
rainy
season.
This
can
result
in
up
to
a
year's
delay
in
establishing
an
orchard
(
with
the
exception
of
walnuts
where
harvest
comes
too
late
for
replanting
even
with
methyl
bromide
use).

In
addition
to
chemical
limitations
of
the
three
alternatives,
the
California
Department
of
Food
and
Agriculture
has
imposed
restrictions
that
limit
the
amount
of
1,3­
dichloropropene
that
can
be
applied
in
a
given
area
("
township
cap"),
because
it
has
been
implicated
as
a
potential
carcinogen.
Within
these
specific
townships,
growers
of
all
crops
compete
for
the
limited
allowable
amount
of
1,3­
dichloropropene
(
under
the
cap)
that
can
used
in
the
year.
Once
the
1,3­
dichloropropene
capacity
is
reached,
1,3­
dichloropropene
will
no
longer
be
available,
and
therefore
not
an
"
alternative"
to
methyl
bromide.
As
a
result,
growers
with
orchards
in
the
identified
townships
with
1,3­
dichloropropene
restrictions
may
require
an
effective
replacement
(
methyl
bromide).

California
also
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.
If
the
township
cap
is
exceeded
early
in
the
year
when
most
of
the
crops
are
planted,
1,3­
dichloropropene
will
not
be
available
for
use
later
in
the
year.
The
California
township
regulations
for
1,3­
dichloropropene
have
been
implemented
relatively
recently
making
it
difficult
to
predict
the
availability
of
1,3­
dichloropropene
throughout
the
year.

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
California's
1,3­
dichloropropene
township
caps
limit
the
availability
for
orchard
replant
growers,
there
would
be
a
critical
need
for
methyl
bromide
for
use
on
orchard
replant
crops.
If,
the
1,3­
dichloropropene
township
cap
is
not
reached,
in
areas
where
1,3­
dichloropropene
is
effective,
the
orchard
replant
growers
would
not
require
methyl
bromide.

Dazomet
(
Basamid
®
)
.
In
spite
of
nearly
50
years
experience
with
methyl
isothiocyanate
(
MITC)
products
 
the
breakdown
active
ingredient
of
both
dazomet
and
metam­
sodium
 
efficacy
has
been
unpredictable.
This
may
be
due
to
the
significantly
lower
vapor
pressure
of
MITC
compared
to
methyl
bromide,
which
affects
the
movement
of
gases
through
soils.
Uniformity
of
fumigants
throughout
the
soil
is
necessary
for
consistent
and
predictable
results.
MITC­
producing
products,
while
at
times
effective,
have
been
associated
with
inconsistent
production
performance
and
performance
appears
to
be
highly
dependent
on
specific
soil
type
and
preparation.

Dazomet
is
not
technically
feasible
for
orchard
replant
because
it
has
yielded
inconsistent
results
in
field
trials,
especially
when
trials
were
conducted
in
orchards
with
diverse
soil
types.
Dazomet,
because
of
its
low
vapor
pressure,
requires
high
soil
moisture
to
ensure
the
product
will
diffuse
through
the
target
area.
Obtaining
this
moisture
content
requires
additional
irrigation
systems,
since
standard
irrigation
in
an
orchard
is
concentrated
toward
the
individual
tree,
through
drip
or
furrow
systems,
in
order
to
reduce
water
requirements.
Dazomet
was
only
assessed
for
the
orchard
replant
situations
and
not
for
the
grape
vineyard
scenario
(
because
is
not
identified
as
an
alternative
for
vineyards
by
MBTOC).

Metam­
Sodium
(
Vapam
®
,
Busan
®
)
.
Metam­
sodium
alone
is
not
technically
feasible
for
orchard
replant
because
national
restrictions
on
application
rates
are
far
below
the
quantity
that
would
be
needed
to
address
the
replant
disorder.
The
use
rate
of
metam­
sodium
would
need
to
be
around
365
kg/
ha
to
provide
control
to
a
depth
of
90­
150
cm
that
would
be
necessary
in
the
orchard
situation.
In
10
addition,
this
substance
was
not
deemed
feasible
due
to
its
lack
of
ability
to
control
nematodes,
which
are
a
major
part
of
the
replant
disorder
in
California.
Like
dazomet,
metam­
sodium
requires
that
the
soil
be
irrigated
to
near
field
capacity
in
order
for
the
chemical
to
diffuse
properly
and
control
at
the
depths
necessary.
Diffusion
in
medium
and
heavy
soils
is
particularly
problematic.

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
An
economic
assessment
was
made
for
1,3­
dichloropropene,
1,3­
dichloropropene
+
chloropicrin,
and
1,3­
dichloropropene
+
metam­
sodium,
which
were
alternatives
that
were
assessed
as
conditionally
technically
feasible
(
see
Table
3a).
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide,
such
as
for
orchard
replant,
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
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
in
orchard
replant.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

For
orchard
replant
uses,
reviewers
analyzed
the
economic
losses
that
might
arise
from
substitution
of
1,3­
dichloropropene
alone
or
in
combination
with
chloropicrin
or
metam­
sodium.
These
alternatives
11
are
technically
feasible
only
on
light
soils,
which
represent
about
one­
third
of
the
area
on
which
orchards
are
maintained.
No
listed
alternatives,
however,
were
found
to
be
feasible
for
use
on
medium
to
heavy
soils
or
for
vineyard
replant
uses.

Losses
originate
from
a
number
of
different
sources.
Quantifiable
losses
arise
from
changes
in
fumigation
costs
and
from
planting
delays
due
to
soil
moisture
requirements.
In
addition,
yield
losses
have
been
observed
in
trees
planted
on
land
fumigated
with
1,3­
dichloropropene
since
some
trees
produce
so
little
that
they
must
be
replaced.
Unfortunately,
sufficient
data
were
not
available
to
estimate
long­
term
yield
losses
or
the
percentage
of
trees
that
would
be
replaced.
Therefore,
we
used
a
low
estimate
range
of
yield
loss
for
the
economic
analysis.
Minimal
losses
were
analyzed,
and
suggested
that
significant
economic
losses
were
likely
to
result.
Tables
4,
5,
and
6
indicate
the
biological
measures
of
impact
used
in
the
analyses
and
the
range
of
cost
changes.

Establishing
an
orchard
requires
a
high
initial
investment
in
land
preparation
and
planting.
Production
does
not
begin
for
several
years
but
continues
for
a
long
period
of
time.
Fumigation
only
occurs
as
part
of
land
preparation.
Therefore,
the
analyses
examined
the
net
present
value
(
NPV)
of
the
orchard
under
different
fumigation
alternatives.
NPV
calculates
the
value
today
of
a
stream
of
costs
and
income
over
a
period
of
time,
where
future
costs
and
income
are
discounted.
The
figures
in
Tables
4,
5,
and
6
represent
a
5
percent
discount
rate.
A
higher
discount
rate
puts
more
emphasis
on
current
costs
and
less
on
future
income
and
results
in
lower
NPV.
The
opposite
is
true
for
a
lower
discount
rate.
Different
discount
rates
were
examined.
The
absolute
value
of
the
investments
changes
with
the
discount
rate,
but
changes
make
little
difference
in
relative
results,
i.
e.,
absolute
or
percentage
change
in
value
per
hectare
or
kilogram
of
methyl
bromide.

The
NPV
of
an
orchard
was
calculated
under
the
various
alternatives
and
it
was
compared
with
the
NPV
of
an
orchard
when
fumigating
with
methyl
bromide.
Data
for
the
analysis
come
from
crop
budgets
prepared
by
the
University
of
California
Cooperative
Extension
(
Buchner
et
al.,
2002;
Day
et
al.,
2000a/
b;
Duncan
et
al.,
2002;
Grant
et
al.,
2001;
Klonsky
et
al.,
1997).
Unfortunately,
these
studies
indicate
that
some
of
the
orchards,
particularly
peach/
nectarine,
plums
and
almonds,
are
not
profitable.
Therefore,
while
we
have
confidence
in
the
measures
of
absolute
losses,
the
losses
as
a
percentage
of
NPV
should
be
viewed
with
caution.

Losses
due
to
the
delay
in
planting
are
equivalent
to
a
5
percent
yield
loss
in
stone
fruits
and
about
3
percent
for
almonds.
These
losses
arise
from
the
fact
that
land
must
stay
in
production
one
additional
year
in
order
to
achieve
the
same
total
productions.
Stone
fruit
tree
production
time
is
typically
20
years
and
almonds
are
25
years.
There
are
no
delays
in
walnuts
with
alternatives
relative
to
methyl
bromide.
The
reviewers
analyzed
replacement
rates
between
5
and
18
percent
of
the
trees.
With
methyl
bromide,
growers
expect
to
replace
about
2
percent
of
the
trees,
mostly
due
to
problems
with
the
seedling,
rather
than
with
soil
pests.
We
evaluated
the
impacts
of
yield
losses
from
reduced
vigor
between
1
to
8
percent
in
comparison
to
methyl
bromide.
Losses
were
assumed
to
be
slightly
higher
in
walnuts
because
historical
data
showed
use
of
a
higher
rate
of
methyl
bromide,
while
the
rates
for
the
alternatives,
except
for
metam­
sodium,
were
identical
for
all
orchard
crops.
For
all
orchard
crops,
the
budget
data
indicated
that
harvest
costs
were
proportional
to
yields
and
comprised
a
major
proportion
of
annual
operating
costs.
These
costs
were
reduced
in
proportion
to
the
yield
losses.

The
lowest
cost
alternative
to
methyl
bromide
was
1,3­
dichloropropene
and
ranged
from
a
savings
of
US$
8
to
US$
1,700/
ha,
including
the
cost
of
application.
We
assumed
that
this
alternative
is
associated
with
the
higher
yield
losses
and
replacement
rate
since
it
provides
narrower
control
than
when
it
is
used
in
conjunction
with
chloropicrin
or
metam­
sodium
(
see
Table
4).
Economic
losses
in
this
scenario
arise
12
primarily
from
higher
establishment
costs
caused
by
the
necessity
of
replacing
trees
that
succumb
to
the
replant
disorder.
Additional
losses
occur
due
to
the
delay
in
establishing
the
orchard
and
in
yield
losses
suffered
by
trees
that
are
weakened,
but
not
killed,
by
the
pest
complex
comprising
the
replant
problem.
Despite
reductions
in
fumigation
costs,
economic
losses
over
the
life
span
of
the
orchards
could
range
from
US$
1,600/
ha
in
walnuts
to
nearly
US$
7,000/
ha
in
stone
fruit
and
represent
between
15
and
93
percent
of
value
of
the
orchard.

Table
4.
Economic
Impacts
of
Substituting
1,3­
Dichloropropene
Alone
for
Methyl
Bromide.
Stone
Fruits
Walnuts
Almonds
Delay
in
establishment
(
yield
loss
equivalent)
5%
0%
3%
Yield
loss
5
to
8%
6
to
8%
5
to
8%
Replacement
rate
10
to
15%
12
to
18%
10
to
15%
Change
in
fumigation
costs
(
US$/
ha)
US$
5
less
US$
1,700
less
US$
1,130
less
Economic
loss
per
ha
US$
2350
to
6,960
US$
1,610
to
2,870
US$
1,810
to
3,370
Loss
per
kg
of
Methyl
Bromide
US$
12
to
35
US$
4
to
7
US$
6
to
10
Impact
as
percent
of
NPV
1
31
to
93%
15
to
27%
17
to
32%
1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
methyl
bromide.
At
a
lower
discount
rate,
NPV
was
positive
for
prunes
and
almonds
with
methyl
bromide,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.

The
highest
cost
option
was
with
1,3­
dichloropropene
+
metam­
sodium,
which
one
study
suggested
provides
nearly
equivalent
control
of
the
replant
problem
in
light
soils
compared
to
methyl
bromide.
Therefore
we
assumed
lower
yield
losses
and
replacement
rates
were
associated
with
this
option
compared
to
the
other
two
alternatives.
Use
of
metam­
sodium
requires
some
additional
capital
expenditure
on
temporary
irrigation
equipment,
which
was
included
in
these
cost
figures.
Table
5
presents
the
results
of
the
assessment.
Fumigation
costs
are
considerably
higher
than
for
methyl
bromide
and
contribute
significantly
to
the
increase
in
establishment
costs
that,
combined
with
the
costs
of
replacing
dead
or
poorly
performing
trees,
form
an
important
share
of
the
total
economic
losses.
The
extra
costs
make
this
alternative
particularly
unattractive
for
the
nut
crops,
although
it
may
be
the
best
option
for
stone
fruits.
Losses
range
from
slightly
more
than
US$
2,000/
ha
in
stone
fruits
to
over
US$
5,500/
ha
in
almonds
and
could
comprise
over
half
of
the
value
of
the
orchards.
13
Table
5.
Economic
Impacts
of
Substituting
1,3­
Dichloropropene
with
Metam­
Sodium
for
Methyl
Bromide.
Stone
Fruits
Walnuts
Almonds
Delay
in
establishment
(
yield
loss
equivalent)
5%
0%
3%
Yield
loss
1
to
2%
2
to
3%
1
to
2%
Replacement
rate
5
to
8%
8
to
10%
5
to
8%
Change
in
fumigation
costs
(
US$/
ha)
US$
930
more
US$
2,830
more
US$
3,430
more
Economic
loss
per
ha
US$
2,070
to
4,500
US$
4,290
to
4,830
US$
4,820
to
5,600
Loss
per
kg
of
Methyl
Bromide
US$
9
to
20
US$
10
to
11
US$
13
to
15
Impact
as
percent
of
NPV
1
28
to
60%
41
to
46%
46
to
53%

1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
methyl
bromide.
At
a
lower
discount
rate,
NPV
was
positive
for
prunes
and
almonds
with
methyl
bromide,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.

The
final
alternative,
1,3­
dichloropropene
+
chloropicrin,
is
somewhat
more
expensive
to
use
than
methyl
bromide,
but
is
less
costly
than
1,3­
dichloropropene
+
metam
sodium.
The
assessment
is
shown
in
Table
6.
Again,
total
economic
losses
are
primarily
driven
by
increases
in
establishment
costs,
including
the
fumigation
and
replacement
of
trees.
Losses
could
be
as
low
as
US$
800/
ha
in
walnuts
but
could
be
nearly
US$
5,500/
ha
in
stone
fruit
and
represent
between
eight
and
73
percent
of
the
value
of
the
orchards.
1,3­
dichloropropene
+
chloropicrin
may
be
the
best
available
alternative
to
methyl
bromide
in
sandy
soils,
but
enough
uncertainty
exists
that
its
use
is
economically
risky.
Considering
the
high
investment
costs
of
establishing
an
orchard
and
the
slow
returns
over
20
to
40
years,
more
information
is
needed
to
determine
that
no
serious
economic
consequences
will
result
from
the
loss
of
methyl
bromide.

Table
6.
Economic
Impacts
of
Substituting
1,3­
Dichloropropene
with
Chloropicrin
for
Methyl
Bromide.
Stone
Fruits
Walnuts
Almonds
Delay
in
establishment
(
yield
loss
equivalent)
5%
0%
3%
Yield
loss
2
to
5%
3
to
5%
2
to
5%
Replacement
rate
8
to
10%
10
to
15%
8
to
10%
Change
in
fumigation
costs
(
US$/
ha)
US$
490
more
US$
1,240
more
US$
630
more
Economic
loss
per
ha
US$
1,830
to
5,470
US$
800
to
2,020
US$
1,060
to
2,360
Loss
per
kg
of
Methyl
Bromide
US$
8
to
24
US$
2
to
5
US$
3
to
6
Impact
as
percent
of
NPV
1
24
to
73%
8
to
19%
10
to
22%
1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
methyl
bromide.
At
a
lower
discount
14
rate,
NPV
was
positive
for
prunes
and
almonds
with
methyl
bromide,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.

6e.
Technical
Feasibility
of
"
Not
In­
Kind"
MBTOC
Alternatives
This
section
summarizes
the
analysis
of
the
"
not
in­
kind"
(
non­
chemical)
methyl
bromide
alternatives
identified
by
MBTOC
for
orchard
replant.
Table
3a
and
Table
3b
contain
a
summary
of
the
technical
assessment,
which
is
that
none
of
the
"
not­
in­
kind"
alternatives
were
found
to
be
technically
feasible,
and
therefore
no
economic
assessment
was
conducted.
A
general
cost
analysis
was
done
for
the
alternatives
and
is
reported
in
Appendix
B.
A
description
of
each
these
alternatives
follows:

Nematicides.
Nematicides
are
not
technically
feasible
by
themselves
in
controlling
all
the
other
pests
contributing
to
the
replant
problem
in
California.
In
particular,
they
are
ineffective
in
controlling
fungal
pathogens,
namely
Armillaria
spp.
and
Phytophthora
spp.
that
affect
California
orchards.

Sodium
tetrathiocarbonate.
Sodium
tetrathiocarbonate
is
not
technically
feasible
in
managing
the
pest
complex
because
of
inadequate
penetration
to
old
rootstock,
which
harbor
various
fungal
pathogens
and
nematodes.
The
use
of
this
product
alone
will
not
provide
adequate
control
of
the
pest
complex
in
the
grape
vineyards.
This
product
is
being
used
by
some
growers,
not
as
a
replacement
for
methyl
bromide
for
replant
use,
but
as
a
means
to
maintain
low
pest
population
levels
in
established
vineyards.
This
product
can
be
integrated
with
other
pest
management
practices,
but
it
does
not
control
the
replant
problem.

Biofumigation,
Solarization,
Crop
rotation/
fallow,
Crop
residue
and
compost,
Substrate/
plug
plants,
Plowing/
tillage,
Resistant
cultivars,
Grafting/
resistant
rootstock,
Physical
removal.
Each
of
the
above
"
not
in
kind"
(
non­
chemical)
alternatives
for
orchard
and
vineyard
replant
was
deemed
technically
infeasible
as
a
substitute
for
methyl
bromide.
However,
many
of
these
alternatives
are
currently
being
employed
in
orchards
in
addition
to
methyl
bromide.
They
serve
as
a
useful
measure
to
optimize
and
limit
the
amount
of
methyl
bromide
needed
for
replant
uses.
Some
of
these
alternatives,
such
as
biofumigation
and
solarization
are
not
feasible
due
to
conflicts
in
planting
times
or
the
inability
to
achieve
sufficient
biomass
for
efficacy
(
biofumigation).
In
general,
the
effective
soil
depth
of
these
alternatives
is
insufficient
relative
to
where
the
pest
management
must
occur.
These
alternatives
can
work
in
conjunction
with
other
practices
to
improve
orchard
health,
but
are
not
sufficient
alternatives
to
methyl
bromide.

The
following
alternatives
are
described
with
consideration
of
the
technical
feasibility
for
orchard
replant:

Biological
Control.
Biological
control
is
already
being
used
by
orchard
managers
as
part
of
integrated
pest
management
(
IPM)
programs,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
There
are
limited
biological
control
organisms
that
are
effectively
used
to
manage
soil
borne
diseases
and
pests
in
orchards.
California
orchard
managers
use
biological
control
organisms
primarily
for
insect
management,
but
use
for
complex
disease
problems
such
as
replant
disorder
is
only
in
the
research
stage
of
development.

Cover
crops/
mulching.
Cover
crops/
mulching
is
already
being
used
in
orchards
as
a
part
of
IPM
programs,
but
it
does
not
offer
adequate
nematode
or
replant
disorder
control
by
itself.
15
Flooding
and
water
management.
Flooding
and
water
management
is
not
technically
feasible
for
addressing
orchard
replant
concerns.
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.
Furthermore,
there
are
no
data
to
suggest
that
replant
disorder
can
be
successfully
managed
with
flooding.

General
IPM
(
Integrated
Pest
Management).
General
IPM
is
currently
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
measures
that
address
problems
associated
with
replanting
orchards..

Organic
amendments/
compost.
Organic
amendments/
compost
is
already
being
used
in
orchards
for
replant,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
Composting
does
not
offer
adequate
management
of
orchard
replant
disorder,
although
it
provides
improvement
of
soil
texture
and
fertility.

Steam.
Steam
for
soil
sterilization
is
impractical
in
large­
scale,
open
field
production
areas
characteristic
of
orchard
replant.
A
United
Nations
Environment
Programme
assessment
(
UNEP,
1998)
indicated
that
this
alternative
is
only
practical
in
small­
scale
production
areas.

7.
Critical
Use
Exemption
Nomination
for
Orchard
Replant
The
critical
use
exemption
nomination
for
methyl
bromide
is
for
replanting
orchards
and
vineyards
on
orchard
land
that
was
previously
planted
with
stone
fruit,
almonds,
walnuts,
and/
or
grapes
(
Appendix
A).
The
U.
S.
is
not
nominating
methyl
bromide
for
orchard
establishment
on
virgin
land;
in
fact,
the
U.
S.
nomination
represents
less
than
1
percent
of
the
total
bearing
area
of
this
crop.
Methyl
bromide
for
replanting
stone
fruit,
almond,
and
walnut
orchards
and
grape
vineyards
in
California
had
an
actual
amount
requested
of
1.3
million
kg
to
be
applied
to
approximately
3,778
hectares
of
orchards
to
be
replanted
in
2005
(
Table
7).
Similar
areas
are
expected
to
be
replanted
in
2006
and
2007
and
the
requested
amount
was
the
same
for
each
year.
The
available
alternatives
to
methyl
bromide
do
not
adequately
control
the
orchard
replant
disease
complex
to
ensure
that
new
trees
and
vines
are
established
and
become
sufficiently
productive
to
realize
profitable
returns
on
the
investments.

Table
7.
Methyl
Bromide
Use
and
Request
for
Orchard
Replant.
Year
Amount
(
kg)
Area
(
ha)
Rate
(
kg/
ha)
1997­
2000
average
1,690,640
5,772
293
2001
1,218,144
3,944
259
2005
request
1,256,223
3,778
341
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
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.
16
Table
8.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Orchard
Replant
Year
Total
Request
by
Applicant
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
1,256,223
706,176
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
stockpile
may
now
exist
will
likely
be
fully
depleted
by
2005
when
the
need
for
the
critical
use
exemption
will
start.

9.
Use/
Minimizing
Emissions
of
Methyl
Bromide
in
the
United
States.

In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country.

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

In
terms
of
compliance,
in
general,
the
United
States
has
used
a
combination
of
tight
production
and
import
controls,
and
the
related
market
impacts
to
ensure
compliance
with
the
Protocol
requirements
on
methyl
bromide.
Indeed,
over
the
last
 
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
17
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
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
18
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
preplant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.

Table
1:
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Expenditures
by
the
U.
S.
Department
of
Agriculture
(
US$
Million)
1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
The
USDA/
ARS
strategy
for
evaluating
possible
alternatives
is
to
first
test
the
approaches
in
controlled
experiments
to
determine
efficacy,
then
testing
those
that
are
effective
in
field
plots.
The
impact
of
the
variables
that
affect
efficacy
is
addressed
by
conducting
field
trials
at
multiple
locations
with
different
crops
and
against
various
diseases
and
pests.
Alternatives
that
are
effective
in
field
plots
are
then
tested
in
field
scale
validations,
frequently
by
growers
in
their
own
fields.
University
scientists
are
also
participants
in
this
research.
Research
teams
that
include
ARS
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

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

Government
funded
studies
related
to
U.
S.
orchard
replant
production
that
are
currently
on­
going
include
the
following:
19
1.
Etiology,
Epidemiology
and
Management
of
Diseases
of
Deciduous
Tree
Fruits
and
Nuts,
and
Small
Fruit
(
Nov.,
1999
to
July,
2004)
Determine
the
etiology
and
epidemiology
of
Phytophthora
root
and
crown
rots,
bacterial,
virus
and
virus­
like
disease
of
tree
fruits
and
nuts,
grapevines
and
strawberries.
Develop
improved
reliable
methods
to
detect
and
identify
the
pathogens
associated
with
these
diseases.
Develop
safe,
effective,
environmentally
sound
disease
management
strategies,
including
alternatives
to
methyl
bromide
preplant
soil
fumigation.

2.
Sustainable
Systems
for
Control
of
Soilborne
Diseases
in
Tree
Fruit
AgroEcosystems
(
Nov.,
2002
to
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,
and
elements
of
the
Malus
germplasm,
in
terms
of
tolerance
or
resistance
towards
Rhizoctonia
solani
and
Pythium
spp.,
as
well
as
the
ability
to
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
to
March,
2003)
Develop
and
evaluate
biologically
based
strategies
for
the
management
of
soilborne
diseases
and
parasitic
nematodes
of
small
fruit
and
nursery
crops.
Characterize
mechanisms
of
biological
control
of
soilborne
plant
diseases.
Evaluate
the
etiology
and
epidemiology
of
soilborne
diseases
of
small
fruit
and
nursery
crops
and
the
biology
of
causal
pathogens.
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
to
July,
2006)
To
evaluate
soil
solarization
alone
and
in
combination
with
raised
beds
and
gypsum
soil
amendment
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)
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.
Non­
Chemical
Pest
Control
in
Fruits
and
Nuts
Using
Electromagnetic
Energy
(
Sept.,
2000
to
Sept.,
2004)
Conduct
research
on
quality
of
grapefruit,
conduct
research
on
Mexican
fruit
fly
and
apple
maggot.
Conduct
pilot
scale
testing
using
RF
equipment
to
develop
process
protocols
for
fruits
(
grapefruit
and
orange)
of
interest
to
Texas.
Coordinate
large
scale
testing
in
Texas.
20
7.
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)
Evaluate
newly
developed
strategies
and
tactics
that
will
replace
methyl
bromide
use
in
commercial
vineyards,
orchards
and
nurseries.

Research
results
submitted
with
the
critical
use
exemption
request
packages
(
including
published,
peerreviewed
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.

Field
research
programs
are
being
conducted
to
determine
and
demonstrate
the
efficacy
of
alternatives
for
orchard
replant.
This
research
will
give
growers
greater
information
for
decisions
about
which
alternative
regime
will
work
in
particular
circumstances.
By
the
nature
of
orchards
and
vineyards
this
research
is
necessarily
long­
term.
Research
is
also
being
done
on
a
county­
by­
county
basis
in
California
to
determine
how
regulations
effect
the
adoption
of
the
alternatives.
Total
use
of
1,3­
dichloropropene
is
limited
across
all
crops
and
buffer
zones
are
required
for
the
use
of
metam­
sodium.
A
large
source
of
uncertainty
is
that
results
from
research
plots
are
difficult
to
transfer
to
full­
scale
orchards.

The
University
of
California
has
been
working
with
other
universities
across
the
country
on
a
biological
control
agent
for
the
fungal
pathogen
Armillaria
mellea.
This
is
a
promising
area
of
research
that
might
be
incorporated
into
an
IPM
program.
In
addition,
predictive
models
are
being
tested
to
help
growers
anticipate
the
level
of
infestation
likely
in
a
field
that
is
to
be
replanted.

Research
in
application
technology
(
e.
g.,
injection
methods
and
application
rates)
may
improve
the
uniformity
of
soil
movement
of
chemicals,
such
as
metam­
sodium.
Non­
chemical
alternatives
have
been
incorporated
and
methods
such
as
IPM,
mulching,
solarization,
and
biofumigation
are
being
examined
as
part
of
an
overall
strategy
to
manage
orchard
replanting.

In
addition
to
the
aforementioned
research,
applicants
to
the
U.
S.
government
for
inclusion
in
the
nomination
for
critical
uses
have
cited
the
following
research
plans
as
ones
they
are
funding
or
otherwise
participating
in.

Table
Grapes:
The
table
grape
industry
provides
research
funding
to
Dr.
Michael
McKenry,
University
of
California
(
UC),
Riverside,
Department
of
Nematology
and
UC
Kearney
Agricultural
Center,
Parlier,
CA
for
the
continuing
research
project
entitled
"
Evaluation
of
Two
New
Delivery
Methods
and
a
Variety
of
Products
Indicated
to
be
Nematicidal."
The
table
grape
industry
recognizes
and
supports,
at
about
US$
15,000
annually,
research
efforts
to
test
viable
alternatives
to
methyl
bromide
to
control
nematodes
and
other
soil
pests.
Some
of
the
potential
alternatives
include
fosthiazate,
Oxycom,
Cordon,
Enzone,
Admire,
DiTera
and
Nemacur.
Methods
of
delivering
these
nematicidal
agents
are
being
researched
and
include
adapting
a
Patchen
sensing
and
spraying
system
and
a
new
pre­
plant
drencher
for
post­
plant
nematicides
to
vineyards
not
having
drip
irrigation.
Dr.
McKenry
conducts
the
aforementioned
research
in
the
Central
San
Joaquin
Valley,
primarily
at
the
UC
Kearney
Agricultural
Center,
Parlier,
CA
where
he
is
based.
The
current
research
project
mentioned
above
is
in
its
fourth
year
and
will
likely
continue
for
several
years.
21
Walnuts:
The
walnut
industry
is
conducting
ongoing
evaluations
of
existing
field
trials
testing
1,3­
dichloropropene
,
metam
sodium
and
dazomet
on
nematode
control.
This
three­
year
study
on
nematode
resistance
by
Mike
McKenry
is
currently
in
the
second
year.
The
Walnut
Marketing
Board
has
allocated
US$
30,000
per
year
to
this
research.

Stone
Fruit
and
Almonds:
The
almond
industry
supports
the
following
research,
also
by
Mike
McKenry,
to
find
alternative
methods
for
controlling
replant
disorder.
In
2003,
stone
fruit
and
walnut
will
be
replanted
after
methyl
iodide
(
iodomethane),
metam­
sodium,
sodium
azide
and
several
other
treatments.
The
stone
fruit
plantings
include
replanting
on
peach
almond
hybrid
versus
nemaguard
rootstocks
(
both
used
in
the
almond
industry
as
well).
Growth
will
be
monitored
for
at
least
three
years
to
determine
the
efficacy
of
the
trials
compared
to
methyl
bromide
and
no
pre­
plant
soil
treatments.
Current
funding
for
this
project
is
US$
20,000
per
year.

Studies
are
being
conducted
to
determine
if
injection
of
chloropicrin
at
0.23­
0.45
kg
into
planting
holes
is
effective
for
controlling
the
fungal
component
of
replant
disorder
and
to
determine
if
hole
injection
methods
for
1,3­
dichloropropene
are
effective.
This
continues
work
that
was
started
in
2000.
A
new
trial
will
be
planted
in
northern
Central
Valley
of
California
in
2003,
comparing
the
efficacy
of
1,3­
dichloropropene
,
iodomethane
(
methyl
iodide),
chloropicrin
and
methyl
bromide
applied
to
tree
holes
during
2002
on
the
disease
component
of
replant
disorder
and
tree
growth.
First
growth
results
are
expected
for
the
fall
of
2003,
and
growth
of
trees
will
be
monitored
for
several
years.

Plans
to
expand
testing
to
the
central
and
southern
sections
of
the
Central
Valley
include
comparing
the
efficacy
of
treatment
of
tree
sites,
tree­
row
strips
and
broadcast
treatments
of
methyl
bromide
and
several
alternatives.
Treatments
would
occur
in
the
fall
of
2003
and
plantings
occur
in
the
spring
of
2004.
Funding
is
US$
17,000
to
18,000
per
year
from
the
Almond
Board.
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.

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
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
22
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
EPA
examines
the
ingredients
of
a
new
pesticide
to
determine
if
it
is
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.

Since
1997,
the
US
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
US
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
US
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
US
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,
US
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
US
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
23
2001:
Terrazole
to
control
pathogens
in
tobacco
float
beds
2001:
Telone
applied
through
drip
irrigation
­
all
crops
2002:
Halosulfuron­
methyl
to
control
weeds
in
melons
and
tomatoes
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:

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

Some
alternatives
currently
under
review
by
EPA
may
be
available
for
orchard
replant
in
the
future.
These
include:
methyl
iodide
and
propargyl
bromide,
which
currently
look
promising
in
field
studies.
Although
methyl
iodide
is
chemically
similar
to
methyl
bromide,
it
photodegrades
before
it
reaches
the
stratosphere,
and
therefore
does
not
appear
to
be
an
ozone
depleter.
While
methyl
iodide
and
propargyl
bromide
are
not
currently
registered
in
the
U.
S.,
research
on
these
and
other
alternatives
is
on­
going.

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

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
described
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
by
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
potential
alternatives
identified
by
MBTOC
for
orchard
replant
are
not
technically
24
or
economically
feasible
as
covered
by
this
exemption
nomination
for
the
orchard
replant
sector.
Certain
MBTOC
alternatives
(
1,3­
dichloropropene;
1,3­
dichloropropene
with
chloropicrin;
and
1,3­
dichloropropene
with
metam­
sodium)
were
only
effective
against
major
pests
of
replanted
orchards
in
limited
situations.
For
instance,
these
chemicals
were
only
effective
against
some
pests
associated
with
replant
disorder,
when
orchards
had
light,
sandy
soils.
In
the
orchards
with
medium
and
heavy
soils
(
approximately
65
percent
of
the
orchards
in
California)
these
chemicals
were
not
effective
because
of
poor
diffusion
of
fumigants
into
soils.
Furthermore,
in
some
areas
there
are
restrictions
in
the
use
of
1,3­
dichloropropene
due
to
"
township
caps"
that
limit
the
total
amount
of
1,3­
dichloropropene
allowed.
Once
the
limit
has
been
reached,
no
further
use
of
1,3­
dichloropropene
is
legally
allowed.
Therefore,
even
when
alternatives
containing
1,3­
dichloropropene
are
effective,
township
limitations
may
make
them
unavailable
for
orchard
use.
As
a
result,
methyl
bromide
is
being
supported
for
use
by
the
orchard
replant
sector
for
those
orchards
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
replant.
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
replant
will
be
maintained
for
the
period
being
requested.

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

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

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

b.
Recognition
of
Uncertainty
in
Allowing
Margin
for
Safety:
With
MDIs,
it
was
essential
to
address
the
possible
change
in
patient
needs
over
time,
and
in
agriculture,
this
is
essential
to
address
the
25
potential
that
the
year
being
requested
for
could
be
a
particularly
bad
year
in
terms
of
weather
and
pest
pressure.
In
that
regard,
the
TEAP's
Chart
2
in
Appendix
D
demonstrates
the
manner
in
which
this
need
for
a
margin
of
safety
was
addressed
in
the
MDI
area.
Specifically,
Chart
2
in
Appendix
D
tracks
national
CFC
requests
for
MDIs
compared
with
actual
use
of
CFC
for
MDIs
over
a
number
of
years.

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

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

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

12.
Contact
Information:

For
further
general
information
or
clarifications
on
material
contained
in
the
U.
S.
nomination
for
critical
uses,
please
contact:
26
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
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L.
Bulluck,
J.
Connell,
T.
Trout
and
S.
Schneider.
2001.
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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.

Browne,
G.,
J.
Connell,
L.
Bulluck,
T.
Trout
and
S.
Schneider.
2002.
Management
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replant
disorder
on
almond
and
peach,
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proceedings
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the
2002
Annual
International
Research
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Methyl
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org/
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mbrpro02.
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agecon.
ucdavis.
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crop/
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to
establish
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nectarine
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nectarines,
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University
of
California
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agecon.
ucdavis.
edu/
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crop/
cost­
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R.
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establish
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plum
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produce
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southern
San
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Valley,
University
of
California
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Extension,
available
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http://
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agecon.
ucdavis.
edu/
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crop/
cost­
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Duncan,
R.,
P.
Verdegaal,
B.
Holtz,
K.
Klonsky
and
R.
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Moura.
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Sample
costs
to
establish
an
almond
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and
produce
almonds,
San
Joaquin
Valley
North,
micro­
sprinkler
irrigation,
27
University
of
California
Cooperative
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at
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agecon.
ucdavis.
edu/
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crop/
coststudies/
AMSPRKVN02.
pdf.

Grant,
J.,
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Caprile,
K.
Kelley,
K.
Klonsky
and
R.
De
Moura.
2001.
Sample
costs
to
establish
an
orchard
and
produce
sweet
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San
Joaquin
Valley
­
North,
University
of
California
Cooperative
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available
at
http://
www.
agecon.
ucdavis.
edu/
outreach/
crop/
cost­
studies/
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/
coststudies
97Prunes.
pdf.

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.

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

CUE
02­
0013,
California
Grape
and
Tree
Fruit
League
(
Stone
Fruit)

CUE
02­
0014,
California
Grape
and
Tree
Fruit
League
(
Table
and
Raisin
Grapes)

CUE
02­
0029,
California
Walnut
Commission
CUE
02­
0043,
Almond
Hullers
and
Processors
Association
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
Appendix
B
is
attached
as
a
separate
file.

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).
28
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
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).
29
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
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
30
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
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
management
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
31
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
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,
32
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
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.
33
Olga
Odiott
(
Biologist)
Olga
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Biologist
within
the
Office
of
Science
Coordination
and
Policy.
In
this
position
she
serves
as
Designated
Federal
Official
and
liaison
on
behalf
of
the
Office
of
Pesticide
Programs
and
the
FIFRA
Scientific
Advisory
Panel,
an
independent
peer
review
body
that
provides
advice
to
the
Agency
on
issues
concerning
the
impact
of
pesticides
on
health
and
the
environment.
She
holds
a
Masters
of
Science
(
Plant
Pathology)
from
the
University
of
Puerto
Rico
(
San
Juan).
Prior
to
joining
EPA,
Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

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

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

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

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

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

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
insectinfested
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
34
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
as
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.
trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

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

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

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
farmer
decision­
making,
especially
pertaining
to
issues
of
soil
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
35
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
Masters
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.

Appendix
D:
CHARTS
Charts
1
and
2
attached
as
separate
electronic
file.
