1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
ORNAMENTAL
NURSERIES
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
two
specific
ornamental
nursery
sectors,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
United
States
believes
is
critical
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
the
ornamental
nursery
sector
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
agriculture.
This
theme
was
given
life
in
various
provisions
of
the
critical
use
exemption,
and
in
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption.
Those
differences
are
outlined
below.

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

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

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

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

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

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

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

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

Upon
return
from
the
Sri
Lanka
meeting
of
the
Parties,
the
U.
S.
took
a
three
track
approach
to
the
critical
use
process.
First,
we
worked
to
develop
a
national
application
form
that
would
ensure
that
we
had
the
information
necessary
to
answer
all
of
the
questions
posed
in
decision
XIII/
11.
At
the
same
time,
we
initiated
sector
specific
meetings.
This
included
meetings
with
representatives
of
the
ornamental
nursery
sector
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.
4
5.
Overview
of
Agricultural
Production
5a.
U.
S.
Agriculture
The
U.
S.
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
farming
climates.
These
factors
contribute
to
and
enable
the
U.
S.
to
be
uniquely
large
and
productive.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farm
land
alone
totaled
381
million
hectares,
a
land
area
larger
than
the
entire
size
of
many
entire
countries.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation,
has
had
an
important
impact
on
the
way
farming
in
the
U.
S.
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

Other
factors
also
affected
the
general
development
of
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
less
than
1
million
hired
workers.

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

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.
Chrysanthemum
Propagative
Material
and
Nursery
Roses
Production
The
U.
S.
is
the
world's
largest
producer
and
market
for
nursery
and
greenhouse
crops.
In
terms
of
economic
output,
nursery
and
greenhouse
crops
are
the
second
most
important
sector
in
U.
S.
agriculture.
In
1997,
nursery
and
greenhouse
operations
had
sales
of
US$
10.9
billion
(
American
Nursery
and
Landscape
Association,
2002,
www.
anla.
org)
.
5
In
terms
of
the
species
grown,
pests,
and
cultural
practices,
the
ornamental
sector
is
extremely
diverse.
However,
one
factor
is
common
to
all
aspects
of
the
industry
 
that
is
the
requirement
for
a
high
quality,
pest­
free
product.
Because
particular
plant
species
are
produced
in
only
a
few
locations
(
e.
g.,
60
percent
of
the
nursery
roses
are
produced
in
California;
90
percent
of
the
chrysanthemum
propagation
material
is
produced
in
Florida)
and
then
shipped
throughout
North
America,
a
number
of
certification
programs
have
been
established,
either
by
the
growers
themselves
or
by
government
agencies,
to
ensure
that
pests
are
not
spread
inadvertently.
The
use
of
agricultural
chemicals,
especially
pesticides,
are
key
to
meeting
the
exacting
standards
of
the
consumer
and
the
certification
and
quarantine
requirements
of
the
regulatory
agencies.

Methyl
bromide
is
the
standard
chemical
used
as
a
fumigant
in
the
production
of
chrysanthemum
propagative
material
and
nursery
roses
to
ensure
that
these
crops
can
be
consistently
certified
as
pest­
free.
In
these
crops
methyl
bromide
is
applied
between
crop
cycles
to
the
planting
beds
using
shank
injectors.
The
soil
surface
is
covered
with
polyethylene
film
immediately
after
treatment.
At
the
end
of
the
exposure
period
(
which
lasts
up
to
two
weeks),
the
tarpaulins
are
removed
and
the
beds
are
aerated
for
about
two
weeks
prior
to
the
introduction
of
transplants.

Chrysanthemum
Propagative
Material
 
Cropping
System
A
particular
cultivar/
variety
of
chrysanthemums,
with
chosen
color,
shape
and
other
characteristics
is
planted
in
a
bed
to
establish
the
"
mother
plants"
for
the
production
of
"
cuttings".
Before
these
cultivars
are
planted,
the
beds
are
fumigated
with
methyl
bromide.
The
chrysanthemum
"
mother
plants"
are
grown
for
20
to
25
weeks.
Cuttings
are
then
taken
from
the
mother
plants.
These
cuttings,
from
a
single
producer
in
Florida,
are
then
shipped
throughout
North
America
for
nurseries
to
raise
and
sell
commercially.
Many
states
and
other
jurisdictions
regulate
and
have
certification
programs
for
the
interstate
shipment
of
nursery
stock
(
propagative
material),
such
as
chrysanthemum
cuttings.

Cuttings
are
harvested
weekly
from
"
mother
plants"
for
the
20
to
25
weeks.
At
the
end
of
this
cycle,
most
of
the
above
surface
crop
debris
is
removed
(
crowns
and
roots
are
left
in
the
soil),
and
the
planting
beds
are
again
fumigated
with
methyl
bromide
(
typically
98
percent
methyl
bromide,
2
percent
chloropicrin).
The
beds
are
then
replanted
after
waiting
2
to
3
weeks
for
the
next
crop
cycle.
Typically
two
crop
cycles
are
completed
per
year.
This
is
a
continuous
cropping
cycle
throughout
the
year.
Almost
all
U.
S.
chrysanthemum
propagative
material
is
produced
on
a
relatively
small
land
area
 
about
50
hectares.

Nursery
Roses
 
Production
System
About
60
percent
of
the
U.
S.
rose
production
is
located
in
and
around
Kern
County,
California.
This
area
produces
approximately
30
million
plants
annually.
The
four
year
production
cycle
for
roses,
prior
to
commercial
sale,
includes
one
year
of
fallow,
one
year
of
a
rotational
crop
and
a
two
year
rose
crop.
Typically,
the
two­
year
rose
crop
cycle
begins
with
land
preparation
(
removing
the
cover
crop,
deep
cultivation,
and
fumigation
with
methyl
bromide),
followed
by
planting
the
rootstock,
and
T­
bud
grafting.
In
late
winter
of
the
first
year,
the
rootstock
tops
are
removed.
The
rose
crop
matures
by
the
second
autumn
and
are
then
harvested.
This
cycle
varies
depending
on
the
type
of
6
rose
crop
being
produced
(
i.
e.,
two­
year
roses,
one­
year
minis
and
patio
trees,
or
an
18­
month
mini
bush).

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Ornamental
Nurseries
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Chrysanthemum
 
Target
Pests
Methyl
bromide
is
primarily
used
in
the
production
of
chrysanthemum
cuttings
as
a
soil
fumigant
to
control
fungal
and
bacterial
pathogens
such
as
Erwinia
chrysanthemi,
E.
carotovora,
Agrobacterium
tumefaciens,
Fusarium
oxysporum,
F.
solani,
and
other
Fusarium
species,
Verticillium
albo­
atrum;
nematodes
such
as
Radopholus
similes,
Rotolenchus
reniformis,
Globodera
spp.,
Heterodera
spp.;
and
unspecified
weeds.
Methyl
bromide
is
unique
in
providing
control
for
all
of
these
important
pests.

Nursery
Roses
 
Target
Pests
Methyl
bromide
is
used
in
rose
production
to
control
pathogens
such
as
Verticillium
dahlia,
Pythium
spp.,
and
Agrobacterium
tumefaciens;
to
control
nematodes
such
as
the
root
knot
nematode
(
Meloidogyne
spp),
lesion
nematode
(
Paratylenchus
vulnus),
pin
nematode
(
Paratylenchus
penetrans),
and
stubby
root
nematode;
and
to
control
unspecified
weeds.
Control
of
some
of
these
nursery
rose
pests
at
depths
over
a
meter
is
particularly
important
because
of
the
deep
rooted
nature
of
this
perennial
crop.
Methyl
bromide
uniquely
provides
pest
control
at
these
depths.

Yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
Cyperus
rotundus
L.)
are
perennial
species
of
the
Cyperacea
family
that
are
widely
recognized
for
their
economic
impact
in
agriculture.
Purple
nutsedge
is
considered
the
worst
weed
in
the
world
due
to
its
widespread
distribution
and
difficult
control
(
Holm
et
al.
1977).
Nutsedge
is
considered
a
weed
in
at
least
92
countries
and
is
reported
to
be
infesting
at
least
52
different
crops.
Yellow
nutsedge
is
listed
among
the
top
fifteen
worst
weeds.
Yellow
nutsedge
is
found
throughout
the
continental
U.
S.
Purple
nutsedge
is
primarily
found
in
the
coastal
southern
U.
S.
and
along
the
Pacific
coast
in
California
and
Oregon.
A
survey
conducted
in
Georgia
ranked
the
nutsedges
as
the
most
troublesome
weeds
in
vegetable
crops
(
there
are
more
30
vegetable
crops
grown
in
Georgia)
(
Webster
et
al.
2001).

Nutsedge
is
propagated
by
tubers
formed
along
underground
rhizomes
and
corms.
The
parent
tuber
could
be
a
tuber
or
a
corm
from
the
previous
generation.
During
tillage
of
the
soil,
the
underground
stems
are
broken
and
new
plants
are
established
from
either
single
or
chains
of
tubers
or
corms.
A
single
plant
is
capable
of
producing
1,200
new
tubers
within
25
weeks
(
Gilreath
et
al.
1999).
Each
tuber
is
capable
of
sprouting
several
times
(
Thullen
et
al.
1975).
Tuber
populations
between
1,000
and
8,700
per/
m2
have
been
reported
for
purple
nutsedge
(
Gamini
et
al.
1987).
Nutsedge
is
very
difficult
to
eradicate
once
it
is
established
because
of
dormancy
factors
in
the
tubers
and
their
ability
to
survive
an
array
of
adverse
conditions
for
long
periods
of
time.
Nutsedge
species
are
strong
competitors
with
most
vegetable
crops
for
water
and
nutrients
and
can
reduce
crop
yields
at
low
plant
densities.
7
Purple
and
yellow
nutsedge
are
serious
problems
in
polyethylene
film
mulch
vegetable
production
systems.
Most
weeds
are
controlled
by
polyethylene
films,
but
nutsedges
are
able
to
penetrate
the
plastic
films,
and
actively
compete
with
the
vegetable
crops
causing
yield
losses
reported
between
41
to
89
percent
(
Patterson,
1998).
It
is
unclear
as
to
the
magnitude
of
nutsedge
pressure
in
Florida
chrysanthemums.

There
are
very
few
herbicides
that
control
nutsedge
and
none
are
registered
for
use
on
ornamental
nurseries.
The
herbicides
that
are
available
for
these
crops
are
generally
older
chemicals
that
are
marginally
effective
against
weeds
such
as
nutsedge.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Ornamental
nursery
growers
rely
on
fumigation
with
methyl
bromide/
chloropicrin
within
the
fullbed
plastic
mulch
production
system
to
control
soil
borne
diseases
and
pests.
There
has
been
extensive
research
on
alternatives
for
the
sector,
and
where
possible,
many
have
been
incorporated.
In
addition,
there
have
been
many
studies
done
on
yield
comparing
alternatives
in
the
forest
tree
seedling
sector
to
methyl
bromide
and
these
results
provide
insights
into
likely
yield
impacts
in
nursery
rose
and
chrysanthemum
production.
Sources
for
the
studies
are
The
Methyl
Bromide
Alternatives
Conference,
applications
for
critical
use
exemptions,
and
case
studies.
For
each
alternative,
the
amount
of
studies
done
is
as
follows:
Bare
fallow
and
combinations­
22;
Basamid
and
combinations­
76;
Brozone­
4;
Captan
and
combinations­
2;
Cedar
sawdust­
2;
Chloropicrin
and
combinations­
56;
Compost­
3;
Eptam
(
EPTC)­
12;
Fallow­
41;
Formaldehyde­
1;
Grafting­
1;
Hot
water­
3;
Methyl
bromide­
200­
1;
Methyl
bromide­
300­
8;
Metam­
Sodium
(
Vapam)
and
combinations­
19;
Nemagon­
2;
other
non­
chemicals­
1;
Silica
sand­
1;
Solarization­
1;
Telone
(
1,3­
dichloropropene)
and
combinations­
6;
Thiram­
1;
Triform
and
combinations­
8.

However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
in
ornamental
production
must
still
be
characterized
as
in
a
preliminary
stage.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
ornamental
nursery
production.

6c.
Technical
Feasibility
of
Alternatives
Chrysanthemum
Propagative
Material
 
Technical
Assessment
Of
the
18
alternatives
identified
by
MBTOC
for
chrysanthemums
for
propagation
material,
only
steam
sterilization
of
the
soil
was
regarded
as
technically
and
economically
feasible.
Complete
adoption
of
steam
sterilization
as
an
alternative
to
methyl
bromide
is
planned
to
be
phased
in
over
the
next
5­
6
years.
8
Table
1.
Feasibility
of
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Chrysanthemum
Cuttings.

Alternative
Technical
Feasibility
Economic
Feasibility
1,3
Dichloropropene
(
Telone)
No
No
1,3
D
+
chloropicrin
(
Telone
C­
17)
No
No
Chloropicrin
No
No
Metam­
Sodium
(
Vapam
®
,
Busan
®
,
Nemasol
®
)
No
No
Metam­
Sodium
+
chloropicrin
No
No
Metam­
Sodium
and
Crop
rotation
No
No
Dazomet
(
Basamid)
No
No
Dazomet
+
Chloropicrin
No
No
Steam
Sterilization
Yes
Yes
Flooding
and
water
management
No
No
Sanitation,
general
IPM.
No
No
Crop
rotation/
fallow
No
No
Solarization
No
No
Biological
control
No
No
Crop
residue
compost
No
No
Soilless
culture
Yes
No
Plug
production
No
No
Biofumigation
No
No
Chrysanthemum
Cuttings
 
Technical
Feasibility
1,
3
Dichloropropene
(
Telone)
and
1,3
D
+
chloropicrin
(
Telone
C­
17).
These
alternatives
are
not
technically
feasible
because
the
control
of
disease
organisms
with
Telone
is
limited
and
the
Telone
/
chloropicrin
combination
causes
phytotoxicity
damage
to
plants
in
adjacent
beds..
Telone
does
not
control
Erwinia
and
Agrobacterium
in
plant
debris.
While
bacteria
are
not
specifically
listed
among
the
organisms
controlled
on
the
Telone
label
and
specific
research
testing
the
efficacy
of
Telone
products
against
bacteria
have
not
been
identified.
The
addition
of
chloropicrin
would
help
control
fungi
and
bacteria,
but
use
of
chloropicrin
(
25
percent
chloropicrin
combined
with
methyl
bromide)
causes
damage
to
plants
in
the
adjacent
beds
(
see
chloropicrin
discussion).
Neither
Telone
alone
or
in
combination
with
chloropicrin
has
much
activity
against
weeds.
Further,
the
buffer
zone
requirement
(
76
meters)
and
restricted
entry
interval
(
5
days)
for
Telone
would
limit
use
in
the
production
areas
because
occupied
structures
fall
within
the
buffer
zone.
9
Chloropicrin.
Chloropicrin
is
not
technically
feasible
because
it
is
not
effective
against
nematodes
or
weeds.
Approximately
20
percent
of
the
yearly
production
of
chrysanthemum
cuttings
are
shipped
to
locations
(
CA,
HI,
LA
TX
and
Bermuda)
that
have
quarantine
requirements
for
nematodes
(
Radopholus
similes,
Rotolenchus
reniformis,
Globodera
spp.,
Heterodera
spp.).
Further,
the
continuous
production
techniques
used
by
the
grower
make
the
use
of
chloropicrin
technically
not
feasible
because
of
its
phytotoxicity
that
affects
adjacent
beds.
Greenhouses
and
field
blocks
contain
many
adjacent
beds
that
are
sequentially
planted
and
are
in
continuous
production.
Each
bed
only
comes
out
of
production
for
a
2­
3
week
period
between
crop
cycles.
Trials
with
MC­
25
(
75
percent
methyl
bromide,
25
percent
chloropicrin)
burned
plants
up
to
12
beds
away,
despite
the
use
of
10
ft.
high
side
curtains
to
try
to
contain
the
chloropicrin.
Although
chloropicrin
alone
was
not
evaluated,
the
grower
stated
that
chloropicrin
used
at
a
much
lower
concentration
in
the
MC­
25
mixture
caused
significant
crop
loss
in
adjacent
beds.
Additionally,
workers
harvesting
several
days
later
in
adjacent,
non­
treated
beds
experienced
eye
irritation.

Metam­
Sodium
(
Vapam
®
,
Busan
®
,
Nemasol
®
,
and
several
other
trade
names).
Metam­
Sodium
is
not
a
technically
feasible
alternative
because
is
does
not
consistently
control
the
target
pests.
Virtually
all
of
the
chrysanthemum
cuttings
for
the
North
American
market
(
including
Canada
and
Mexico),
must
meet
pest­
free
plant
material
requirements.
Supplying
pathogen
and
pest­
free
plant
material
may
not
be
possible
using
Metam­
Sodium
and
could
put
shipments
at
risk
of
rejection
and
possible
loss
of
customers.
There
is
no
evidence
that
Metam­
Sodium
will
control
Erwinia
and
Agrobacterium
in
plant
debris.
As
with
Telone,
bacteria
are
not
listed
on
the
metamsodium
label
and
specific
research
testing
the
efficacy
of
metam­
sodium
products
against
bacteria
have
not
been
identified.
Further,
metam­
sodium
requires
irrigation
to
be
most
effective
and
does
not
penetrate
into
the
soil
as
well
as
methyl
bromide.
This
may
result
in
erratic
and
less
than
adequate
control
of
fungi
and
bacteria.
Additional
cultivation
to
aerate
the
soil
before
planting
may
be
needed.
Additional
time
may
be
necessary
between
crops
as
it
may
be
up
to
60
days
before
new
crop
can
be
planted,
depending
on
rate
of
metam­
sodium
used,
and
how
quickly
the
fumigant
clears
from
the
soil.
It
is
considered
to
be
fairly
effective
against
many
weeds
and
moderately
effective
against
fungi
and
nematodes.

While
research
suggests
Basamid
and
metam­
sodium
can,
in
some
situations,
provide
effective
pest
control
for
certain
diseases
and
weeds,
research
data
suggest
that
these
products
can
not
be
relied
on
to
provide
necessary
consistency
of
results.

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
in
the
nursery
industry
with
inconsistent
production
performance
and
reduced
seedling
quality
(
based
on
research
from
forest
seedling
production
studies).
Both
dazomet
and
metam­
sodium
can
provide
effective
pest
management
in
some
situations,
but
they
have
not
been
successful
in
providing
consistently
high
quality
forest
tree
seedlings
especially
with
high
nutsedge
and
pathogen
pressure.
Accordingly,
it
is
reasonable
to
conclude
that
for
ornamentals,
it
is
likely
that
there
could
be
similar
issues.
10
Metam­
Sodium
+
chloropicrin.
A
metam­
sodium
and
chloropicrin
combination
is
not
technically
feasible
in
the
continuous
production
system
used
by
the
grower
because
of
the
adverse
effects
of
chloropicrin.
(
see
Chloropicrin
above).

Metam­
Sodium
and
Crop
rotation.
A
metam­
sodium
and
crop
rotation
combination
is
not
technically
feasible
because
there
are
no
other
crops
in
rotation.
Chrysanthemums
are
grown
continuously
at
the
Florida
nurseries.

Dazomet
(
Basamid)
and
Dazomet
plus
Chloropicrin.
Dazomet
alone
and
Dazomet
in
combination
with
chloropicrin
are
not
technically
feasible
alternatives
because
they
can
result
in
a
7
percent
to
37
percent
yield
loss,
depending
on
the
chrysanthemum
variety.
Additionally,
there
are
grower
reports
of
stem
burning
and
poor
rooting
on
several
mum
cultivars
using
Basamid
in
field
trials
conducted
at
their
facilities.
Moreover,
although
weeds
and
Fusarium
spp.
were
controlled,
Erwinia
was
recovered
from
mum
crowns
in
plant
debris
from
field
trials
treated
with
Basamid.
If
stock
plants
are
replanted
in
field
soil
infested
with
Erwinia,
they
can
develop
systemic
infections
that
go
undetected
until
the
plants
are
received
by
the
customer
and
begin
growing.
Pathogen
and
insect
free
plant
material
are
either
quarantine
or
nursery
stock
requirements
for
supplying
starter
plants
and
using
Basamid
is
too
large
a
risk
because
of
its
inconsistency
 
using
it
runs
a
great
risk
of
rejected
shipments
loss
or
even
loss
of
customers.

While
research
suggests
Basamid
and
metam­
sodium
can,
in
some
situations,
provide
effective
pest
control
for
certain
diseases
and
weeds,
research
data
suggest
that
these
products
can
not
be
relied
on
to
provide
necessary
consistency
of
results.
Specifically,
neither
Basamid
®
nor
metam­
sodium
(
e.
g.,
Vapam
®
,
Busan
®
)
consistently
provide
acceptable
levels
of
control
for
key
pests
when
used
at
label
rates.

Steam
Sterilization.
Steam
sterilization
is
technically
feasible
and
is
already
being
used.
Steam
sterilization
does
not
result
in
either
a
quality
or
yield
loss.
Steam
is
effective
against
the
major
target
pests
listed.
However,
at
this
time,
the
applicant
has
equipment
available
to
steam
only
30
percent
of
the
production
fields.
Adoption
of
this
technique
for
all
fields
will
require
substantial
additional
capital
investments
as
outlined
in
the
proposal
and
described
in
the
assessment
of
economic
feasibility.
It
is
estimated
that
it
would
take
5­
6
years
to
acquire
necessary
capital
for
equipment
investment
to
treat
all
hectares
planted
in
chrysanthemum.
Steam
does
require
additional
time
to
set
up
and
take
down
the
steaming
equipment
as
compared
with
the
time
needed
to
apply
methyl
bromide.
However,
one
advantage
of
steam
over
a
chemical
fumigant
is
that
there
is
no
waiting
period
needed
for
replanting
when
steam
is
used.
The
number
of
cropping
cycles
per
year
does
not
change
with
steam
and
the
net
impact
on
timing
is
negligible.

Flooding
and
water
management.
Flooding
and
water
management
are
not
technically
feasible
alternatives
because
they
will
not
control
the
target
pests.
In
some
cases,
flooding
may
actually
make
some
of
the
diseases
worse,
such
as
Erwinia.

Sanitation,
general
IPM.
Sanitation
and
general
IPM,
by
themselves,
are
not
technically
feasible
alternatives
because
they
do
not
adequately
control
the
target
pests
for
sale
of
pest­
and
pathogenfree
starter
plants.
Although
not
sufficient
by
themselves
to
control
the
target
pests,
many
sanitation
11
and
general
IPM
methods
are
being
used
in
chrysanthemum
production.
"
Mother
plants"
at
the
Florida
nurseries
are
planted
in
the
fields
and
cuttings
are
harvested
weekly.
These
cuttings
are
sent
to
nurseries
throughout
North
America
to
produce
finished
chrysanthemums.

Crop
rotation/
fallow.
Crop
rotation/
fallow
is
not
technically
feasible
because
it
would
not
allow
the
grower
to
meet
certification
requirements
for
shipment
of
the
propagative
material.
Research
data
does
not
support
a
conclusion
that
crop
rotation/
fallow
alone
would
control
the
target
pests.
Chrysanthemums
are
grown
continuously
on
a
20­
25
week
cycle.
No
other
crops
are
grown;
the
production
areas
are
fumigated
and
replanted
within
2­
3
weeks
of
the
final
harvest
of
cuttings
from
the
previous
crop.

Solarization.
Solarization
is
not
a
technically
feasible
alternative
because
it
does
not
provide
complete
control
of
the
pests/
pathogens
listed
for
sale
of
pest­
free
starter
plants.
The
length
of
time
between
crop
cycles
would
need
to
be
increased
by
several
weeks
because
solarization
requires
extended
time
period
to
have
any
effect
on
pests.

Biological
control.
Biocontrol
is
not
a
technically
feasible
alternative
because
no
biological
control
has
been
developed
to
cover
all
the
target
pests/
pathogens.

Crop
residue
compost.
Composting
crop
debris
alone
is
not
a
technically
feasible
alternative
because
it
would
not
control
all
the
target
pests
to
a
degree
necessary
for
sale
of
pest­
and
pathogenfree
starter
plants.
This
alternative
would
not
be
practical
in
the
field,
within
the
time
frame
of
this
production
system,
since
cops
are
planted
continuously.
If
any
debris
was
left
uncomposted,
it
could
serve
as
a
reservoir
for
pathogens.
The
current
practice
is
to
remove
the
majority
of
the
crop
debris
from
the
soil.

Soilless
culture,
plug
production.
Plug
production
is
not
technically
feasible
for
production
of
chrysanthemum
"
mother
plants".
Although
soilless
culture
would
be
a
technically
feasible
alternative
it
would
require
much
more
time
and
money
than
to
implement
the
best
practicable
methyl
bromide
alternative
­­
steam.
To
switch
to
a
soilless
culture
the
current
production
practice
would
likely
need
to
include
such
things
as,
building
new
or
modifying
existing
greenhouses,
building
above
ground
benches,
installing
new
irrigation
systems,
etc.
In
addition,
research
would
be
needed
to
determine
whether
the
vigor
of
a
soilless
"
mother
plant"
would
allow
for
cutting
over
the
extended
20
to
25
weeks.

Biofumigation.
Biofumigation
is
not
technically
feasible
because
it
would
not
likely
provide
the
level
of
pest
and
pathogen
control
needed
to
produce
certified
pest­
free
starter
plants.

Nursery
Roses
 
Technical
and
Economic
Assessment
Methyl
bromide
appears
to
be
the
standard
chemical
used
to
fumigate
rose
plant
beds
to
ensure
that
the
nursery
roses
can
be
consistently
certified
as
pest­
free.
Only
two
of
the
13
alternatives
identified
by
MBTOC
are
technically
and/
or
economically
feasible
(
Table
3),
although
results
have
been
variable.
12
Table
2.
Feasibility
of
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Nursery
Rose
Production.
Alternative
Technical
Feasibility
Economic
Feasibility
1,3­
Dichloropropene
Regulatory
limit
on
use
Yes
1,3­
Dichloropropene,
Metam­
Sodium
Regulatory
limit
on
use
Yes
Basamid
No
No
Metam­
Sodium
No
No
Solarization
No
No
Steam
No
No
Biological
Control
No
No
Crop
Residue/
Compost
No
No
General
IPM
No
No
Grafting/
Resistant
Rootstock/
Plant
Breeding
No
No
Physical
Removal/
Sanitation
No
No
Resistant
Cultivars
No
No
Substrates/
Plug
Plants
No
No
Nursery
Roses
 
Technical
Feasibility
1,3­
Dichloropropene.
1,3­
Dichloropropene
is
technically
feasible
and
is
already
being
used
in
some
situations,
especially
in
sandy
soils
where
the
soil
moisture
can
be
reduced
to
12
percent
or
less.
However,
in
addition
to
the
possibility
of
a
non­
certifiable
crop,
quality
and
size
are
taken
into
consideration
in
determining
returns.
Growers
have
reported
that
some
portions
of
the
nursery
roses
for
shipment
may
be
rejected
without
the
entire
shipment
being
in
jeopardy
of
being
rejected,
but
no
specific
numbers
are
available
for
these
losses.

Although
Telone
appears
to
be
an
effective
alternative
to
methyl
bromide
for
nursery
rose
production,
in
California
there
are
location
specific
Telone
use
restrictions.
California
regulations
limit
how
much
Telone
can
be
used
in
specific
locations
called
"
townships"
during
a
year.
As
a
result,
the
growers
in
these
specific
"
townships"
cannot
completely
switch
to
using
Telone
instead
of
methyl
bromide,
because
of
the
risk
of
not
being
able
to
obtain
the
alternative.
The
availability
of
1,3­
dichloropropene
is
potentially
limited
by
the
township
cap.
Within
these
specific
"
townships,"
all
the
growers
of
various
crops,
such
as
carrots,
sweet
potatoes,
grapes,
almonds
and
walnuts,
compete
for
the
limited
quantity
of
Telone
(
under
the
cap)
that
can
used
in
the
year.
Once
the
cap
is
reached,
the
growers
in
the
township
will
need
to
have
another
option
for
their
soil
fumigation
production
practices.

The
U.
S.
is
therefore
nominating
nursery
roses
in
California
to
ensure
growers
have
access
to
methyl
bromide,
once
the
Telone
township
cap
is
reached.
California
restricts
the
amount
of
Telone
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,
there
will
not
be
any
Telone
available
for
growers
to
use
later
in
the
year.
The
California
township
caps
for
13
Telone
are
fairly
new
and
have
not
existed
for
many
growing
seasons,
so
it
is
difficult
for
the
U.
S.
to
predict
how
the
Telone
township
cap
may
limit
access
in
2005.
As
a
result,
the
U.
S.
views
this
nomination
for
California
for
a
methyl
bromide
critical
use
exemption
as
a
"
contingent
nomination."
We
consider
it
a
"
contingent
nomination"
because
it
is
being
submitted
in
the
event
that
the
growers
of
nursery
roses
in
the
specific
townships
face
a
situation
in
2005,
or
2006,
when
the
Telone
township
cap
is
exceeded
and
they
need
to
revert
back
to
using
methyl
bromide.

The
other
crops
that
rose
nurseries
are
competing
with
for
Telone
within
the
townships
are
carrots
and
almonds
(
replant).
If
the
situation
should
arise
that
the
California
Telone
township
cap
limits
access
to
Telone
for
nursery
rose
growers,
the
U.
S.
believes
there
would
be
a
critical
need
for
methyl
bromide
for
the
production
of
nursery
roses.
If,
on
the
other
hand,
the
Telone
township
cap
is
not
reached,
the
nursery
rose
growers
would
not
need
to
obtain
any
methyl
bromide.
As
under
the
Essential
Use
Exemption
allocation
amounts
for
metered
dose
inhalers
(
MDIs)
in
prior
years,
if
a
quantity
of
an
ozone­
depleting
substance
is
nominated
and
approved
for
an
exemption,
but
some
amount
is
not
utilized
(
not
produced),
the
un­
utilized
portion
of
the
exemption
would
not
adversely
impact
on
the
ozone
layer.
Instead,
the
approval
of
the
exemption
would
be
a
crucial
safety
valve
for
a
critical
methyl
bromide
need,
in
case
the
ability
to
obtain
Telone
is
denied
due
to
California
township
cap
regulation.

The
rose
production
area
has
a
known,
high
infestation
of
nematodes,
and
therefore
a
State
of
California
certification
standard
was
created
to
prevent
the
spread
of
these
pests
with
the
crop.
According
to
California's
nursery
stock
nematode
regulation,
farms
can
be
treated
with
either
methyl
bromide
or
a
dual
application
of
Telone
II,
or,
alternatively,
the
farmer
may
at
great
expense
sample
their
fields
to
demonstrate
the
and
show
a
complete
absence
of
nematodes.
Nursery
rose
growers
rely
on
these
treatments
(
methyl
bromide
or
a
dual
application
of
Telone
II)
to
prevent
rejection
of
their
stock.
Telone
II
treatments
can
be
used
in
very
limited
cases
with:
(
1)
a
known
history
of
no
nematodes,
and
(
2)
light
soils,
to
meet
the
California's
pest­
free
certification
requirement.
The
requested
amount
of
methyl
bromide
in
this
U.
S.
nomination
includes
only
those
areas
where
the
Telone
II
treatment
cannot
be
used
to
meet
the
California
certification
requirements.
A
segment
of
each
growers
production
may
not
need
to
meet
the
specific
California
nematode
requirements
because
they
are
shipped
out
of
state,
but
all
other
U.
S.
states
have
their
own
nursery
stock
pest­
free
requirements.
In
general,
nursery
rose
growers
in
California
follow
the
more
stringent
California
regulations
to
meet
every
other
state's
requirements
for
a
nematode­
free
product.

1,3­
Dichloropropene/
Metam­
Sodium.
The
combination
of
1,3­
dichloropropene
and
metamsodium
is
technically
feasible
for
addressing
the
target
pests
for
nursery
rose
production
in
some
situations.
1,3­
Dichloropropene
and
metam­
sodium
combined
appears
to
be
the
most
effective,
currently
available
option,
however,
results
have
been
highly
variable
and
primarily
dependent
upon
the
soil
moisture.
In
tests
conducted
using
InLine,
it
was
demonstrated
that
stubby
root,
stunt,
and
root
knot
nematode
were
controlled
to
a
depth
of
122
cm
and
stubby
root
and
root
knot
were
controlled
to
1.3
meters.
Stunt
was
not
completely
controlled
at
these
depths
and
could
still
potentially
result
in
rejection
of
the
crop
by
a
certifying
agent.

Dazomet
(
Basamid).
Dazomet
is
not
a
technically
feasible
alternative
because
is
does
not
adequately
control
target
pests
at
deep
enough
levels
in
the
soil.
Dazomet
and
metam­
sodium
are
14
both
MITC
generating
substances
and
inability
of
MITC
from
metam­
sodium
to
penetrate
deep
enough
at
the
maximum
allowed
application
rate
is
likely
to
also
be
true
for
dazomet.

Metam­
Sodium.
Metam­
Sodium
is
not
a
technically
feasible
alternative
alone,
because
it
results
in
nursery
rose
shipments
that
are
not
certifiable.
Research
indicates
that
a
non­
certifiable
crop
occurs
because
metam­
sodium
did
not
move
deep
enough
into
the
soil.
Tests
conducted
with
high
rates
of
metam­
sodium
coupled
with
large
quantities
of
water
to
increase
movement
in
the
soil
have
led
to
phytotoxicity
problems.
Rates
needed
for
controlling
target
pests
at
1.3
meters
would
exceed
the
current
maximum
allowable
application
rate,
according
to
research
results
in
walnut
and
peach
trials.
When
metam­
sodium
is
combined
with
1,3­
dichloropropene
and
chloropicrin,
and
applied
for
weed
control
it
appears
to
be
useful
in
some
production
areas.
In
one
rose
trial
using
metam­
sodium,
nematode
control
was
achieved
to
a
depth
of
3
feet.
Fungal
pathogen
control
has
been
inadequate
with
this
material
applied
alone.

Solarization,
Steam
Sterilization,
Biological
Control,
Crop
Residue/
Compost.
These
"
not
inkind
alternatives
are
not
technically
feasible,
by
themselves
to
adequately
control
the
target
pests.
The
use
of
each
of
these
techniques,
by
themselves,
would
not
allow
a
nursery
rose
grower
to
meet
the
California
certification
standard.

General
IPM,
Grafting/
Resistant
Rootstock/
Plant
Breeding,
Physical
Removal/
Sanitation,
Resistant
Cultivars.
Although
these
"
not
in­
kind"
alternatives
are
being
used
by
nursery
rose
growers
to
reduce
pest
pressure,
in
general,
by
themselves,
each
have
not
been
successful
at
achieving
adequate
pest
control.
In
addition,
these
"
not
in­
kind"
alternatives
alone
would
not
allow
the
nursery
rose
grower
to
meet
the
certification
standard
of
being
nematode
free.

Substrates/
Plug
Plants.
Use
of
"
plug
plants"
is
not
technically
feasible
for
nursery
roses
because
virtually
all
production
is
by
grafting
on
to
resistant
rootstock,
not
by
the
use
of
cuttings.
Because
roses
are
a
deep
rooted
crop,
it
may
be
infeasible
to
shift
from
a
field
grown
production
system
to
an
untried
greenhouse
production
system
(
substrates/
soilless
culture).
Research
would
need
to
be
conducted
to
determine
the
commercial
feasibility
of
make
a
change
of
this
magnitude
to
a
soilless
culture.

6d.
Economic
Feasibility
of
Alternatives
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices.

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

(
1)
Losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
15
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

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

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

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

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

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

Chrysanthemum
Cuttings
­
Economic
Feasibility
The
major
producer
of
chrysanthemum
propagative
material
in
the
U.
S.
(
90
percent
of
the
North
American
market)
is
committed
to
a
shifting
to
steam
over
the
next
5
to
6
years,
contingent
on
a
projected
time
line
for
making
sequential
investments
in
capital
equipment.
For
propagation
material
production,
steam
sterilization
of
the
soil
is
listed
as
the
most
viable
alternative,
from
a
technical
standpoint.
The
available
data
indicate
that
steam
sterilization
will
reduce
profits
although
profits
remain
positive.
However,
because
use
of
steam
requires
a
significant
capital
investment,
reported
economic
impacts
must
be
viewed
with
caution.
Steam
sterilization
is
economically
feasible
even
though
profits
are
estimated
to
fall
by
about
US$
7,700
per
hectare
per
crop
cycle
(
Table
3),
and
there
are
typically
2
crop
cycles
per
year.
The
increased
cost
of
steam
represents
approximately
a
2
percent
change
in
gross
revenue
and
therefore
steam
is
viewed
as
the
long­
term
alternative.
The
planned
to
switch
to
steam
is
already
underway
and
it
will
eventually
replace
methyl
bromide
for
chrysanthemum
production.

Results
in
Table
3
do
not
appropriately
account
for
the
time
needed
to
acquire
the
capital
requirements
for
steam
sterilization.
Because
of
the
capital
requirement
for
steam
sterilization,
the
applicant
will
need
time
to
acquire
the
financial
resources
and
purchase
and
install
the
needed
16
equipment
before
being
able
to
fully
convert
to
steam
sterilization.
The
applicant
projects
that
full
conversion
will
require
an
additional
5­
6
years.

Table
3.
Measures
of
Economic
Impact
on
the
Chrysanthemum
Propagation
Material
Producer
Changing
from
Methyl
Bromide
Soil
Fumigation
to
Steam
Sterilization.
Loss
Measure
Steam
Sterilization
compared
with
methyl
bromide
Per
hectare
per
crop
cycle
US$
7,700
Per
kg
methyl
bromide
US$
8.70
Percent
of
gross
revenue
2
%
Percent
of
net
cash
returns
18
%

Note:
All
economic
impacts
are
assumed
to
be
due
to
the
increased
costs
of
steam
sterilization.

Nursery
Roses
 
Economic
Feasibility
For
nursery
rose
production,
Telone
or
a
combination
of
Telone
and
metam­
sodium
is
feasible
on
sandy
soils
with
12
percent
or
less
moisture.
Although
Telone
alone,
and
Telone
combinations,
may
be
technically
and
economically
feasible
alternatives
in
these
locations
to
control
key
pests,
these
techniques
could
become
unavailable
to
nursery
rose
growers
if
the
limit
on
the
amount
of
Telone
that
can
be
used
in
a
California
township
is
reached
because
of
other
uses
of
Telone
in
agricultural
crop
production.
The
nursery
rose
growers
being
nominated
for
a
critical
use
exemption
are
primarily
located
in
Kern
county,
California.
Again,
it
is
worth
noting
that
within
Kern
county,
the
other
crops
that
rose
nurseries
are
competing
with
for
Telone
within
the
townships
are
carrots
and
almonds
(
replant).

The
U.
S.
nomination
for
nursery
rose
production
analyzed
cost
information
and
yield
loss
scenarios
for
the
alternative
regimen
of
using
tarped
Telone
EC
applications
plus
hand
weeding.
The
results
of
these
analyses
are
below
in
Table
4.

Table
4.
Measures
of
Economic
Impact
on
the
Rose
Producer
Changing
from
Methyl
Bromide
Soil
Fumigation
to
the
Use
of
1,3­
Dichloropropene
with
Hand
Weeding.
Loss
Measure
1,3­
D
with
5%
yield
loss
scenario
1,3­
D
with
10%
yield
loss
scenario
Per
hectare
US$
3,500
US$
7,400
Per
kg
methyl
bromide
US$
10.30
US$
21.75
Percent
of
gross
revenue
4
%
9
%
Percent
of
net
cash
returns
8
%
16
%
Note:
Impacts
due
primarily
to
yield
losses.

7.
Critical
Use
Exemption
(
CUE)
Nomination
for
Ornamental
Nurseries
This
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
for
the
ornamental
nursery
sector,
specifically
production
of
chrysanthemum
propagative
material
and
nursery
roses.
The
actual
17
amount
requested
was
268,000
kilograms
of
methyl
bromide
is
needed
to
treat
715
hectares.
The
average
application
rates
for
these
uses
and
states
conform
to
standard
practices.

The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
production
of
chrysanthemum
propagative
material
and
nursery
roses.
Most
of
the
alternatives
identified
by
the
MBTOC
were,
as
reviewed
in
detail
above,
regarded
by
reviewers
as
technically
and
economically
infeasible
for
acceptable
management
of
the
major
pests.

The
chrysanthemum
request
is
for
a
grower
who
produces
approximately
90
percent
(
185
million
cuttings
per
year)
of
the
North
American
chrysanthemum
propagation
material.
The
grower
is
nominated
for
treating
35
hectares
in
2005
with
methyl
bromide.
Please
note
that
the
grower
expects
this
area
with
a
critical
need
for
methyl
bromide
to
decline
to
25
hectares
in
2006
and
14
hectares
in
2007,
as
the
use
of
steam
sterilization
is
increased.
Complete
adoption
of
steam
sterilization
as
an
alternative
to
methyl
bromide
is
planned
to
be
phased
in
over
the
next
5­
6
years.

Table
5.
Methyl
Bromide
Usage
and
Critical
Use
Exemption
Request
for
the
Production
of
Chrysanthemum
Cuttings
in
the
U.
S.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
42,725
44,176
35,001
40,034
36,187
31,593
22,205
12,637
hectares
49
50
40
46
41
35
25
14
rate
(
kg/
ha)
880
880
879
879
881
892
896
892
The
nursery
rose
request
is
for
California
rose
production.
The
U.
S.
estimates
that
235,868
kilograms
of
methyl
bromide
is
needed
for
2005
to
fumigate
680
hectares.
Application
rates
for
this
crop
appear
to
be
typical
for
this
region
(
Table
6).

Roses
must
be
"
commercially
clean"
as
defined
by
the
requirements
of
the
Regulations
for
the
Nursery
Stock
Nematode
Certification
Program,
California
Code
of
Regulations.
All
material
being
sold
can
be
inspected
and
rejected
as
not
being
"
commercially
clean,"
regardless
of
the
soil
treatment
used
in
production.

Of
the
13
MBTOC
alternatives
identified
for
roses,
all
but
two
(
1,3
D
[
Telone]
and
1,3
D
[
Telone]
combined
with
metam­
sodium)
were
regarded
as
not
being
technically
feasible.
Economic
analysis
of
these
two
technically
feasible
alternatives
indicate
a
4
and
9
percent
loss
of
gross
revenues,
18
respectively.
California
rose
production
represents
about
60
percent
of
total
U.
S.
production.
Many
research
studies
on
the
efficacy
of
MIDAS
(
iodomethane
with
chloropicrin)
and
metam­
sodium
or
other
weed
control
measures
are
underway
and
are
expected
to
continue
over
the
next
few
years.

Table
6.
Methyl
Bromide
Usage
and
Critical
Use
Exemption
Request
for
the
Production
of
Nursery
Roses
in
the
U.
S.

1997
1998
1999
2000
2001
2005
2006
2007
kilograms
205,613
201.803
204,933
217,588
235,868
235,868
235,868
hectares
611
600
609
647
645
680
680
680
rate
(
kg/
ha)
336
336
336
336
341
347
347
347
The
U.
S.
nomination
(
Table
7)
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives
(
buffer
zones,
township
caps),
environmental
concerns
such
as
soil
based
restrictions
due
to
potential
groundwater
contamination,
and
historic
use
rates,
among
other
factors.

Table
7.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Ornamentals
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
267,461
29,412
8.
Minimizing
Use/
Emissions
of
Methyl
Bromide
in
the
United
States/
Stockpiles
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
19
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
methyl
bromide
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.
Reduced
methyl
bromide
concentrations
in
mixtures,
more
mechanized
soil
injection
techniques,
and
the
extensive
use
of
tarps
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world.

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

9.
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.
20
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,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
even
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
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
agricultural
and
forestry
leaders
from
private
industry,
academia,
state
governments,
and
the
federal
government
to
assess
the
problem,
formulate
priorities,
and
implement
research
directed
at
providing
solutions
under
the
USDA's
Methyl
Bromide
Alternatives
program.
The
ARS
within
USDA
has
22
national
programs,
one
of
which
is
the
Methyl
Bromide
Alternatives
program
(
Select
Methyl
Bromide
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov).
The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
the
extensive
private
sector
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
While
research
has
been
undertaken
in
all
sectors,
federal
government
efforts
have
been
based
on
the
input
of
experts
as
well
as
the
fact
that
nearly
80
percent
of
preplant
methyl
bromide
soil
fumigation
is
used
in
a
limited
number
of
crops.
Accordingly,
much
of
the
federal
government
pre­
plant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.
21
Table
8:
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.
22
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.

Government
funded
studies
related
to
U.
S.
ornamental
nursery
production
that
are
currently
ongoing
include
the
following:

1.
Alternatives
to
Methyl
Bromide
for
Management
of
Soilborne
Pathogens
in
Ornamental
Crops
(
Apr
1999
­
Jun
2003)
Identify
and
evaluate
botanical
compounds
for
activity
against
soilborne
pathogens,
including
plot
and
field
testing.
Develop
integrated
disease
control
systems
utilizing
botanical
compounds
in
combination
with
other
strategies
including
biological
control
and
modified
cultural
practices.
Characterize
the
ecology
of
soilborne
pathogens
and
beneficial
microorganisms
following
treatment
of
soil
with
botanicals
alone
and
in
combination
with
other
treatments.

2.
Control
of
Plant
Parasitic
Nematodes
and
Root
Diseases
in
Ornamental
Production
Systems
(
Sep
2000
­
Sep
2003)
Develop
methods
to
effectively
control
root­
lesion
and
root­
knot
nematodes
in
ornamental
production
systems.
Reduce
transmission
of
root
disease
pathogens
via
irrigation
water.

3.
Management
of
Root­
Knot
Nematodes
in
Field
Production
of
Floral
and
Ornamental
Crops
(
Sep
2001
­
Aug
2003)
To
assess
the
benefits
of
integrating
practices
such
as
soil
solarization,
cover
crops,
resistant
cultivars,
and
environmentally
compatible
chemicals
for
effective
control
of
root­
knot
and
other
plant
parasite
nematodes
in
ornamental
production
systems.
As
resources
permit,
research
will
be
conducted
on
novel
approaches
to
manipulating
soil
environments
common
to
ornamental
production
systems
so
that
they
are
suppressive
to
root­
knot
nematodes,
yet
encouraging
or
neutral
to
ornamentals
and
non­
target
plants.

4.
Alternatives
to
Methyl
Bromide
Soil
Fumigation
for
Vegetable
Production
and
Floriculture/
nursery
Crops
(
Apr
1999
­
Apr
2004)
Identify
impact
of
pest
management
tactics
on
functional
diversity
of
soil
microflora
and
weed
populations,
their
competitive
interactions,
&
effects
on
crop
health.
Develop
Integrated
Pest
Management
(
IPM)
systems
to
include
chemical
and
non­
chemical
components
to
replace
methyl
bromide
soil
treatments
for
growing
floriculture
&
related
nursery
crops
to
allow
continued
profitable
operation
of
this
industry
after
the
ban
of
methyl
bromide
in
January
2005.

5.
Disease
Management
in
Ornamental
Crops
(
UC
Davis/
CSREES
­
Oct
1999
­
Sep
2004)
To
develop
new
technologies
for
the
control
of
plant
pathogens.
Work
will
include
research
to
develop
alternatives
to
methyl
bromide
for
controlling
soil­
borne
pathogens,
methods
for
eliminating
23
water­
borne
pathogens
in
recycled
irrigation
water,
and
technologies
for
effective,
environmentallyresponsible
control
of
powdery
mildew
in
greenhouse
roses.

Research
results
submitted
with
the
critical
use
exemption
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.

Chrysanthemum
Propagative
Material
Steam
sterilization
appears
to
be
the
best
alternative
regimen
to
methyl
bromide.
However,
it
is
more
expensive
to
use
than
methyl
bromide
and
several
other
chemical
alternatives,
and
the
grower
currently
lacks
the
capacity
to
steam
the
entire
production
area.
One
applicant
stated
that
it
should
be
possible
to
develop
sufficient
capacity
within
5­
6
years
for
steam
sterilization.
A
strong
research
plan
is
ongoing
and
more
than
US$
1
million
has
been
spent
evaluating
steam
and
other
methyl
bromide
alternatives.
This
new
research
includes
studies
with
methyl
iodide
at
different
application
rates,
even
though
it
is
not
currently
registered
for
use
on
this
crop,
trials
with
steam
sterilization,
MC­
25,
Sectagon,
and
VIF.
Additionally,
research
should
be
supported
to
develop
more
energyefficient
cost­
effective
portable
steam
units
for
field
use.

Nursery
Roses
Registration
of
MIDAS
(
iodomethane
with
chloropicrin)
appears
to
be
the
best
solution
to
replace
the
use
of
methyl
bromide
on
this
crop.
Studies
have
shown
the
control
of
all
nematode
genera
found
on
roses
at
a
depth
of
1.3
meters.
This
treatment
is
likely
to
require
some
additional
weed
control
measures,
but
does
provide
weed
control
that
is
comparable
to
methyl
bromide
in
many
cases.
Many
studies
are
currently
underway
and
are
in
the
first
year
or
beginning
the
second
year
of
testing.
This
research
includes:

$
Field
fumigation
trials
looking
at
Telone
C­
35
and
methyl
iodide
and
their
impact
on
weed
control,
phytotoxicity,
and
crop
yield.
These
trials
will
be
conducted
in
California
from
2001­
2002.

$
Evaluations
on
a
commercial
rose
grower
field
of
iodomethane,
Telone
II
EC,
an
iodomethane
and
chloropicrin
combination,
and
metam­
sodium.
This
on­
going
project
will
be
conducted
in
California
until
2003.

$
An
soil
fumigation
trial
testing
a
telone
and
chloropicrin
combination,
a
telone
plus
Ridomyl
combination,
and
a
K­
Pam
(
potassium
methane)
and
telone
combination
on
nematode
control,
soil­
borne
disease
control
and
weed
control.
These
trials
were
conducted
in
2002
in
California.

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
24
examined
as
part
of
an
overall
strategy
to
manage
ornamental
nursery
production,
in
general.
Trials
evaluating
compost­
based
systems
as
alternatives
for
chemical­
based
fumigations
are
already
being
conducted.
These
trials
will
continue
and
weed
ratings,
disease
incidence,
and
crop
yield
data
will
be
collected.

As
demonstrated
by
the
chart
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
U.
S.
is
committed
to
sustaining
its
research
efforts
out
into
the
future
until
technically
and
economically
viable
alternatives
are
found
for
each
and
every
controlled
use
of
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.

Registration
Program
The
United
States
has
one
of
the
most
rigorous
programs
in
the
world
for
safeguarding
human
health
and
the
environment
from
the
risks
posed
by
pesticides.
While
we
are
proud
of
our
efforts
in
this
regard,
related
safeguards
do
not
come
without
a
cost
in
terms
of
both
money
and
time.
Because
the
registration
process
is
so
rigorous,
it
can
take
a
new
pesticide
several
years
(
3­
5)
to
get
registered
by
EPA.
It
also
takes
a
large
number
of
years
to
perform,
draft
results
and
deliver
the
large
number
of
health
and
safety
studies
that
are
required
for
registration.

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

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

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
for
all
types
of
25
pesticides
pending
in
its
review
process
than
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
This
review
process
takes
an
average
of
38
months
to
complete.
Additionally,
the
registrant
(
the
pesticide
applicant)
has,
in
most
cases,
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

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

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

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

1999:
Pebulate
to
control
weeds
in
tomatoes
2000:
Phosphine
to
control
insects
in
stored
commodities
2001:
Indian
Meal
Moth
Granulosis
Virus
to
control
Indian
meal
moth
in
stored
grains
2001:
Terrazole
to
control
pathogens
in
tobacco
float
beds
2001:
Telone
applied
through
drip
irrigation
­
all
crops
2002:
Halosulfuron­
methyl
to
control
weeds
in
melons
and
tomatoes
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:
26
 
Iodomethane
as
a
pre­
plant
soil
fumigant
for
various
crops
 
Fosthiazate
as
a
pre­
plant
nematicide
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.

Several
additional,
promising
alternatives
are
under
review
at
U.
S.
EPA
that
may
be
able
to
be
used
on
ornamental
nursery
crops
in
the
future.
These
include:
iodomethane
(
methyl
iodide)
and
propargyl
bromide,
which
currently
look
very
promising
in
field
studies.
Although
iodomethane
is
chemically
similar
to
methyl
bromide,
it
photodegrades
before
it
reaches
the
stratosphere,
and
therefore
is
not
a
significant
ozone
depleter.
While
iodomethane
and
propargyl
bromide
are
not
currently
registered
for
use
as
pesticides
in
the
U.
S.,
research
on
combinations
of
pesticides
with
chemicals
like
methyl
iodide
are
also
planned.
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
concerns
about
toxicity,
ground
water
contamination,
and
the
release
of
air
pollutants
regarding
some
alternatives
presents
another
difficulty
that
may
restrict
use
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.
If
registration
of
iodomethane
or
propargyl
bromide
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
even
registering
those
alternatives
is
not
the
end
of
the
story.
Alternatives
must
be
tested
by
users
and
found
to
be
technically
and
economically
feasible
before
they
are
widely
adopted.
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
speed
adoption,
the
U.
S.
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

10.
Conclusion
and
Policy
Issues
Associated
with
the
Nomination
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
TEAP
listed
potential
alternatives
for
the
specific
27
crops
and
areas
covered
in
this
nomination
are
not
currently
technically
or
economically
viable
from
the
standpoint
of
United
States
growers
covered
by
this
exemption
request.
We
have
also
determined
that
the
absence
of
methyl
bromide
for
the
nominated
uses
will
result
in
a
significant
market
disruption
to
the
effected
sectors.
We
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
for
many
important
uses
are
under
investigation
and
may
be
on
the
horizon.
Based
on
this
analysis,
we
believe
those
requests
included
in
this
nomination
meet
the
criteria
set
out
by
the
Parties
in
Decision
IX/
6.

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
ornamental
nursery
sector
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
U.
S.
for
the
growers
of
chrysanthemum
propagative
material
and
nursery
roses
covered
by
this
exemption
nomination.
In
addition,
we
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
for
chrysanthemums
and
nursery
roses
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
unreasonable
risks
to
human
health
and
the
environment,
is
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
chrysanthemums
and
nursery
roses
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
28
be
used
solely
for
the
group
of
active
moieties/
MDIs
that
have
been
granted
the
exemption.
We
believe
that
the
factors
of
agricultural
uncertainty
surrounding
both
pest
pressures
in
future
year
crops,
and
efficacy
of
reduced
methyl
bromide
application
provide
an
even
stronger
impetus
for
using
a
similar
approach
here.
The
level
of
unpredictability
in
need
leads
to
a
second
area
of
similarity
with
MDIs,
the
essential
need
for
a
review
of
the
level
of
the
request
which
takes
into
account
the
need
for
a
margin
of
safety.

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

Chart
2
in
Appendix
D
demonstrates
several
things.
First,
despite
the
best
efforts
of
many
countries
to
predict
future
conditions,
it
shows
that
due
to
the
acknowledged
uncertainty
of
out­
year
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
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
29
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.

11.
Contact
Information
For
further
general
information
or
clarifications
on
material
contained
in
the
U.
S.
nomination
for
critical
uses,
please
contact:

John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
US
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
e­
mail:
ThompsonJE2@
state.
gov
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
12.
References
Gamini,
S.
and
R.
K.
Nishimoto.
1987.
Propagules
of
purple
nutsedge
(
Cyperus
rotundus)
in
soil.
Weed
Technol.
1:
217­
220.

Gilreath,
J.
P.,
J.
W.
Noling,
and
P.
R.
Gilreath.
1999.
Nutsedge
management
with
cover
crop
for
tomato
in
the
absence
of
methyl
bromide.
Research
summary,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.
30
Holm,
L.
G.,
D.
L.
Plucknett,
J.
V.
Pancho,
and
J.
P.
Herberger.
1977.
The
world's
worst
weeds:
distribution
and
biology.
Honolulu,
HI:
University
of
Hawaii
Press,
pp.
8­
24.

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

Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.

Webster,
T.
M.
and
G.
E.
Macdonald.
2001.
A
survey
of
weeds
in
various
crops
in
Georgia.
Weed
Technol.
15:
771­
790.

13.
Appendices
Appendix
A.
List
of
Critical
Use
Exemption
Requests
for
U.
S.
Ornamental
Nurseries
CUE­
02­
0020:
Yoder
Brothers,
Chrysanthemum
Propagation
Material
CUE­
02­
0028:
California
Rose
Growers
represented
by
the
Garden
Rose
Council
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
sub­
regions
or
production
systems.
A
baseline
analysis
was
done
to
establish
the
outcome
of
treating
with
methyl
bromide
for
each
of
these
scenarios.
Therefore,
the
rows
of
the
tables
correspond
to
the
production
scenarios,
with
each
production
scenario
accounting
for
row
and
the
alternative(
s)
accounting
for
additional
rows.

The
columns
of
the
table
correspond
to
the
estimated
impacts
for
each
scenario.
(
The
columns
of
the
table
are
spread
over
several
pages
because
they
do
not
fit
onto
one
page.)
The
impacts
for
the
methyl
bromide
baseline
are
given
as
zero
percent,
and
the
impacts
for
the
alternatives
are
given
relative
to
this
baseline.
Loss
estimates
include
analyses
of
yield
and
revenue
losses,
along
with
estimates
of
increased
production
costs.
Losses
are
expressed
as
total
losses,
as
well
as
per
unit
treated
and
per
kilogram
of
methyl
bromide.
Impacts
on
profits
are
also
provided.
31
After
the
estimates
of
economic
impacts,
the
tables
contain
basic
information
about
the
production
systems
using
methyl
bromide.
These
columns
include
data
on
output
price,
output
volume,
and
total
revenue.
There
are
also
columns
that
include
data
on
methyl
bromide
prices
and
amount
used,
along
with
data
on
the
cost
of
alternatives,
and
amounts
used.
Additional
columns
describe
estimates
of
other
production
(
operating)
costs,
and
fixed/
overhead
costs.

The
columns
near
the
end
of
the
tables
combine
individual
costs
into
an
estimate
of
total
production
costs,
and
compare
total
costs
to
revenue
in
order
to
estimate
profits.
Finally,
the
last
several
columns
contain
the
components
of
the
loss
estimates.
1
A
15%
loss
would
result
in
the
alternative
being
economically
infeasible
by
some
criteria.
There
is
no
yield
loss
data.

*
kg
ai
that
would
be
applied/
hectare
=
application
rate
for
the
alternatives
or
requested
application
rate
for
MBr.

*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
35
Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.
She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.
(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)
cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

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

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

Diane
Brown­
Rytlewski
(
Biologist)
Diane
is
the
Nursery
and
Landscape
IPM
Integrator
at
Michigan
State
University,
a
position
she
has
held
since
2000.
She
acts
as
liaison
between
industry
and
the
university,
facilitating
research
partnerships
and
cooperative
relationships,
developing
outreach
programs
and
resource
materials
to
further
the
adoption
of
IPM.
Ms.
Rytlewski
holds
a
Master
of
Science
(
Plant
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.
36
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).

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,
37
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
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).
38
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
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.

Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
39
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
40
Science
in
December
2003
from
Clemson
University
(
Clemson).
Mr.
Lennon
is
a
graduate
of
Georgia
College
&
State
University
(
Milledgeville)
where
he
earned
a
Bachelor
of
Science
(
Biology).
Sean
is
conducting
research
in
Integrated
Pest
Management
of
Southeastern
Peaches.
He
has
eight
years
of
experience
in
the
commercial
peach
industry.

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

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

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

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

Thuy
Nguyen
(
Chemist).
Thuy
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997,
as
a
chemist
in
the
Office
of
Pesticides
Program.
She
assesses
and
characterizes
ecological
risk
of
pesticides
in
the
environment
as
a
result
of
agricultural
uses.
She
earned
her
degrees
of
Master
of
Science
(
Chemistry)
from
the
University
of
Delaware
and
Bachelor
of
Science
(
Chemistry
and
Mathematics)
from
Mary
Washington
College
(
Fredericksburg,
VA).
Prior
to
joining
the
EPA,
41
Ms
Nguyen
held
a
research
and
development
scientist
position
at
Sun
Oil
company
in
Marcus
Hook,
PA,
then
managed
the
daily
operation
of
several
EPA
certified
laboratories
for
the
analyses
of
pesticides
and
other
organic
compounds
in
air,
water,
and
sediments.

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

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

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

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.
42
Carmen
L.
Sandretto
(
Agricultural
Economist).
Carmen
has
been
with
the
Economic
Research
Service
of
the
U.
S.
Department
of
Agriculture
for
over
30
years
in
a
variety
of
assignments
at
several
field
locations,
and
since
1985
in
Washington,
DC.
He
has
worked
on
a
range
of
natural
resource
economics
issues
and
in
recent
years
on
soil
conservation
and
management,
pesticide
use
and
water
quality,
and
small
farm
research
studies.
Mr.
Sandretto
holds
a
Master
of
Arts
degree
(
Economics)
from
Harvard
University
(
Cambridge)
and
a
Master
of
Science
(
Agricultural
Economics)
from
The
University
of
Wisconsin
(
Madison).
Mr
Sandretto
is
a
graduate
of
Michigan
State
University
(
East
Lansing).
Prior
to
serving
in
Washington,
D.
C.
he
was
a
member
of
the
economics
faculty
at
Michigan
State
University
and
at
the
University
of
New
Hampshire
(
Durham).

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

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

Thomas
J.
Trout
(
Agricultural
Engineer).
Tom
has
been
with
the
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
since
1982.
He
currently
serves
ar
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
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
43
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.

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

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

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

Istanbul
Yusuf
(
Economist).
Istanbul
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1998.
She
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
She
earned
her
Master=
s
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
44
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.
45
Appendix
D:
Charts
(
see
separate
electronic
file
for
Chart
1
and
Chart
2)
