Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
PEPPERS
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
pepper,
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
pepper
follows.

2.
Background
In
1997,
the
Parties
to
the
Montreal
Protocol
adjusted
Article
2H
of
the
Protocol,
and
agreed
to
accelerate
the
reduction
in
the
controlled
production
and
consumption
of
methyl
bromide.
This
adjustment
included
a
provision
calling
for
a
phaseout
of
methyl
bromide
by
the
year
2005
"
save
to
the
extent
that
the
Parties
decide
to
permit
the
level
of
production
or
consumption
that
is
necessary
to
satisfy
uses
agreed
by
them
to
be
critical
uses."
At
the
same
time,
the
Parties
adopted
decision
IX/
6,
the
critical
use
exemption
decision,
which
laid
out
the
terms
under
which
critical
use
exemptions
under
Article
2H
would
be
granted.

3.
Criteria
for
Critical
Uses
Under
the
Montreal
Protocol
In
crafting
Decision
IX/
6
outlining
the
criteria
for
a
critical
use
exemption,
the
Parties
recognized
the
significant
differences
between
methyl
bromide
uses
and
uses
of
other
ozone­
depleting
chemicals
previously
given
scrutiny
under
the
Protocol's
distinct
and
separate
Essential
Use
exemption
process.
The
United
States
believes
that
it
is
vitally
important
for
the
MBTOC
to
take
into
account
the
significant
differences
between
the
critical
use
exemption
and
the
essential
use
exemption
in
the
review
of
all
methyl
bromide
critical
use
nominations.

During
the
debate
leading
up
to
the
adoption
of
the
critical
use
exemption
Decision
IX/
6,
an
underlying
theme
voiced
by
many
countries
was
that
the
Parties
wanted
to
phase
out
methyl
bromide,
and
not
agriculture.
This
theme
was
given
life
in
various
provisions
of
the
critical
use
exemption,
and
in
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption.
Those
differences
are
outlined
below.

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

For
the
U.
S.
nomination
for
peppers,
following
detailed
technical
and
economic
review,
the
U.
S.
has
determined
that
some
use
of
methyl
bromide
in
pepper
production
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
peppers
is
discussed
later
in
this
nomination,
and
is
the
basis
for
the
U.
S.
estimate
of
the
amount
of
methyl
bromide
needed
within
this
sector.

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
toxic
and
pose
some
risk
to
human
health
or
the
environment;
in
some
cases,
a
chemical
alternative
may
pose
risks
even
greater
than
methyl
bromide.

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

In
fact,
even
after
an
alternative
is
tested
and
found
to
work
against
some
pests
in
a
controlled
setting,
adequate
testing
in
large­
scale
commercial
operations
in
the
many
regions
of
the
U.
S.
where
a
particular
crop
is
grown
can
take
many
cropping
seasons
before
the
viability
of
the
alternative
can
be
adequately
demonstrated.
In
addition,
the
process
of
securing
national
and
sub­
national
approval
of
the
use
of
alternatives
requires
extensive
analysis
of
environmental
consequences
and
risk
to
human
health.
The
average
time
for
the
national
review
of
scientific
information
in
support
of
a
new
pesticide,
starting
from
the
date
of
submission
to
registration,
is
approximately
38
months.
In
most
cases,
the
company
submitting
the
information
has
spent
approximately
7­
10
years
developing
the
toxicity
data
and
other
environmental
data
necessary
to
support
the
registration
request.

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

The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
Page
3
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
understand
the
unique
nature
of
U.
S.
agriculture,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
methyl
bromide.

4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Pepper
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
literally
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
pepper
growers
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.
Page
4
5.
Overview
of
Agricultural
Production
5a.
U.
S.
Agriculture
The
United
States
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
agricultural
climates.
These
factors
contribute
to
and
enable
the
U.
S.
to
be
a
uniquely
large
and
productive
agricultural
producer.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farm
land
totaled
381
million
hectares,
a
land
area
larger
than
the
size
of
many
entire
countries.
Of
this,
approximately
140
million
hectares
were
devoted
to
cropland,
with
the
rest
devoted
to
pasture,
forest,
and
other
special
uses.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables,
has
had
an
important
influence
on
the
way
agriculture
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

Other
factors
also
affected
the
general
development
of
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.
has
developed
a
system
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.

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
has
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices,
including
plastic
mulches,
row
covers,
high­
density
planting,
more
effective
pesticide
sprays,
and
drip
irrigation,
as
well
as
increased
water
irrigation
practices.
Optimization
of
yields
through
these
and
other
scientific
and
mechanized
practices
make
U.
S.
agricultural
output
very
sensitive
to
changes
in
inputs.
Therefore,
as
evidenced
by
the
U.
S.
nomination
for
critical
uses
of
methyl
bromide,
the
phaseout
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.

5b.
Pepper
Production
U.
S.
pepper
production
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture
noted
above.
Peppers
are
a
long­
season
commodity
grown
in
most
of
the
major
vegetable
growing
areas
of
the
U.
S.,
with
production
concentrated
in
California
and
Florida.
As
a
consequence,
this
nomination
covers
methyl
bromide
use
in
a
variety
of
areas
with
differing
soil
and
climactic
characteristics.
Page
5
Peppers
in
both
regions
are
mostly
grown
using
multiple
row
transplants
placed
in
polyethylene
plastic­
mulch
raised
beds.
Transplants
are
typically
planted
from
August
through
March
C
planted
in
January
and
February
in
the
spring,
and
in
September
during
the
fall
C
although
in
some
areas
they
are
present
in
the
field
through
the
year.
Plants
are
in
the
field
for
2.5
to
5
months,
depending
on
the
season
of
the
year.
Pepper
crops
are
sometimes
double­
cropped
with
a
cucurbit
crop
after
harvest
(
e.
g.,
cucumber,
squash,
watermelon).
Specialty
peppers
(
e.
g.,
chili
peppers,
pimentos,
jalapeño
peppers)
are
usually
grown
on
a
small
percentage
of
the
land
as
a
second
crop
in
fields
that
produced
tomatoes
as
the
primary
crop.

Peppers
are
grown
primarily
in
two
states
on
opposite
sides
of
the
U.
S.,
Florida
and
California,
with
significant
additional
pepper
production
in
several
other
Eastern
states
including
North
Carolina,
Georgia,
and
New
Jersey.
California
and
Florida
account
for
approximately
38
percent
and
27
percent
of
the
U.
S.
commercial
pepper
area,
respectively,
and
together
account
for
approximately
78
percent
of
the
value
of
U.
S.
commercial
pepper
production.
The
availability
of
land
and
the
fact
that
these
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables
has
had
an
important
influence
on
the
way
agriculture
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
is
generally
not
competitive
in
cost,
and
has
as
a
consequence,
been
limited.

In
all
production
areas,
peppers
are
generally
produced
using
mechanized,
scientific
practices
that
involve
deep
injection
of
methyl
bromide.
In
California,
methyl
bromide
is
used
in
certain
areas
to
control
a
fungal
disease,
Phytophthora
capsici,
for
which
effective
alternatives
are
not
available.
On
the
East
Coast,
methyl
bromide
is
used
primarily
to
control
a
pervasive
weed,
nutsedge,
for
which
there
are
no
effective
alternatives.
Estimates
of
the
impact
of
the
loss
of
methyl
bromide
in
vegetable
production
suggest
that
without
methyl
bromide,
a
significant
proportion
of
pepper
production
will
no
longer
be
economically
feasible.
Results
from
ongoing
research
evaluating
alternatives
to
methyl
bromide
lead
to
the
conclusion
that
methyl
bromide
cannot
be
replaced
with
a
single
chemical
or
cultural
tactic.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Peppers
6a.
Target
Pests
Controlled
with
Methyl
Bromide
In
growing
pepper,
weeds
­
especially
nutsedge
­
are
the
most
serious
concern
precipitating
methyl
bromide
use
in
both
transplant
beds
and
in
the
field.
The
critical
use
exemption
nomination
is
primarily
based
on
the
lack
of
reliable
alternatives
to
control
nutsedge
species.
Nutsedge
species
grow
even
under
adverse
growing
conditions
and
resist
traditional
and
modern
methods
of
weed
control
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeast
region
of
the
U.
S.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds
­
but
there
are
no
currently
registered
herbicides
to
address
sedge
weed
pests.
Nematodes
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern
and
are
commonly
more
of
a
problem
than
nutsedge
on
the
West
Coast
of
the
U.
S.
These
pests
are
expected
to
become
serious
problems
for
pepper
production
if
methyl
bromide
were
not
available
for
pre­
plant
fumigation.
Page
6
Yellow
&
purple
nutsedge:
(
Cyperus
spp.)
Yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
Cyperus
rotundus
L.)
are
perennial
species
of
the
Cyperacea
family
that
are
widely
recognized
for
their
detrimental
economic
impact
on
agriculture.
Purple
nutsedge
is
considered
the
world's
worst
weed
due
to
its
widespread
distribution
and
the
difficulties
in
controlling
it
(
Holm
et
al.,
1977).
Purple
nutsedge
is
considered
a
weed
in
at
least
92
countries
and
is
reported
infesting
at
least
52
different
crops.
Yellow
nutsedge
is
listed
among
the
top
fifteen
worst
weeds
and
is
found
throughout
the
continental
U.
S.
Purple
nutsedge
is
primarily
found
in
the
Southern
Coastal
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)
and
among
the
top
five
most
troublesome
weeds
in
corn,
cotton,
peanut,
and
soybean
(
Webster
et
al.,
2001
b).

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
dramatically
reduce
crop
yields,
even
at
low
plant
densities,
if
not
controlled
effectively.

Purple
and
yellow
nutsedge
are
serious
problems
in
polyethylene
film
mulch
vegetable
production
systems.
Most
weeds
are
controlled
by
these
films,
but
nutsedges
are
able
to
penetrate
the
plastic
films
and
actively
compete
with
the
vegetable
crops,
causing
yield
losses
reported
between
41
and
89
percent
(
Patterson,
1998).

There
are
very
few
herbicides
that
provide
effective
nutsedge
control
and
none
are
registered
for
use
on
pepper.
The
herbicides
that
are
available
for
these
crops
are
generally
older
chemicals
that
are
marginally
effective
against
the
spectrum
of
weeds
that
are
problematic
for
solanaceous
crops.
Among
the
areas
covered
by
this
nomination
for
continued
methyl
bromide
in
peppers,
30
to
40
percent
of
East
Coast
pepper
production
areas
are
moderately
to
heavily
infested
with
nutsedge.

Root­
knot
nematode
(
Meloidogyne
spp.)
Root
damage
caused
by
these
nematodes
leads
to
reduced
rooting
systems,
which
in
turn
lead
to
reduced
water
and
nutrient
uptake.
The
gall
formation
induced
by
the
nematodes
at
their
root
feeding
sites
results
in
symptoms
like
stunting,
wilting,
and
chlorosis,
and
renders
the
plant
more
susceptible
to
secondary
infections.
Preplant
control
of
nematodes
is
important
because
once
root
damage
is
done
and
symptoms
are
evident,
it
is
very
difficult
to
avoid
significant
yield
losses.
Nematodes
are
found
in
all
pepper
producing
regions
in
the
U.
S.

Fungal
diseases.
Phytophthora
blight,
caused
by
Phytophthora
capsici,
causes
seed
rot
and
seedling
blight
in
many
solanaceous
crops
including
eggplants,
pepper,
and
tomato.
Phytophthora
blight
is
Page
7
one
of
the
most
destructive
diseases
and
there
are
few
control
measures.
Resistance
to
metalaxyl
has
been
documented
for
Phytophthora
species.
Southern
stem
blight,
caused
by
Sclerotium
rolfsii,
is
also
a
very
common
and
destructive
disease
affecting
pepper
and
other
solanaceous
crops.
In
California's
pepper
producing
areas,
Phytophthora
blight
is
the
major
problem
controlled
with
methyl
bromide,
and
this
disease
is
endemic
in
about
10
percent
of
California's
pepper
production
area.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Pepper
growers
rely
on
fumigation
with
methyl
bromide/
chloropicrin
within
the
full­
bed,
plastic
mulch
production
system
to
control
soil
borne
diseases
and
pests.
On
the
East
Coast,
where
most
methyl
bromide
is
needed
for
pepper
production,
this
system
is
designed
to
allow
effective
sedge
control
in
pepper
production.
In
California,
this
system
is
effective
in
controlling
fungal
diseases
where
other
control
are
ineffective.
In
both
areas,
methyl
bromide
is
also
effective
in
controlling
nematodes,
other
weeds
(
in
addition
to
nutsedge),
and
other
fungal
pathogens
(
in
addition
to
Phytophthora).
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.

We
begin
our
technical
and
economic
assessment
by
presenting
in­
kind
(
chemical)
alternatives,
and
then
describe
the
attributes
of
the
not­
in­
kind
alternatives.

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Table
1.
In­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Pepper.

Methyl
Bromide
Alternative
Technically
Feasible
Economically
Feasible
1,3­
Dichloropropene
(
Telone)
No
No
1,3­
Dichloropropene
+
Chloropicrin
No
No
Chloropicrin
No
No
Metam
Sodium
No
No
Metam
sodium
combined
with
crop
rotation
No
No
1,
3­
Dichloropropene.
Telone
is
not
a
technically
feasible
stand­
alone
alternative
to
methyl
bromide
for
the
control
of
nutsedge
and
the
disease
complex
that
affects
pepper
production.
Telone
provides
good
control
of
nematode
populations,
but
poor
control
of
diseases
and
weeds.
In
addition,
1,3­
dichloropropene
is
restricted
in
key
pepper
growing
areas
of
the
U.
S.
which
have
soils
underlain
by
karst
topography
and
sandy
(
porous)
sub­
soils,
geological
features
that
could
lead
to
ground­
water
contamination.
Approximately
40
percent
of
Florida's
pepper
production
land
is
in
areas
facing
these
Page
8
soil
constraints.
As
a
consequence,
1,3­
dichloropropene
is
prohibited
in
key
growing
areas
like
Dade
County,
Florida
where
about
1,300
hectares
of
peppers
are
grown
each
year.
In
California,
use
of
1,3­
dichloropropene
is
restricted
by
township
caps
and
buffer
zones.
In
areas
where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions
(~
100
meters
from
occupied
structures;
~
30
meters
for
emulsified
formulations
applied
via
chemigation)
may
limit
the
proportion
of
the
field
that
can
be
treated.
The
set
back
restrictions
are
expected
to
limit
1,3­
dichloropropene
use
in
about
1
percent
of
Florida's
pepper
production
area.

There
are
also
highly
restrictive
personal
protective
equipment
(
PPE)
requirements
for
1,3­
dichloropropene
application,
which
limit
the
ability
of
farmers
to
use
the
chemical
in
tropical
and
subtropical
climates.
For
example,
PPE
restrictions
may
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
are
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity,
rapidly
become
unbearable
for
a
typical
applicator.

Additionally,
a
3­
week
time
interval
before
planting
is
recommended
to
avoid
phytotoxic
levels
after
1,3­
dichloropropene
application.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
fetch
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.

Broadcast
applications
and
use
of
emulsified
formulations
applied
through
micro­
irrigation
systems
have
been
investigated
in
an
effort
to
minimize
the
impacts
of
PPE
and
worker
exposures.
While
related
trials
continue
in
an
effort
to
optimize
results,
results
from
prior
trials
using
these
application
techniques
indicate
increased
variability
in
the
efficacy
of
the
chemical.
Trials
comparing
broadcast
applications
with
standard
in­
row
applications
indicated
the
need
to
increase
the
amount
of
chloropicrin
to
compensate
for
the
potential
decrease
in
efficacy
of
1,3­
dichloropropene
applied
via
broadcast.
Applications
via
micro­
irrigation
systems
have
yielded
mixed
results,
probably
due
to
poor
lateral
distribution
of
the
chemical
in
the
soil.
Yield
losses
for
peppers
from
broadcast
methods
are
expected
to
be
6
to7
percent
greater
than
losses
from
more
precision
methods
(
compared
to
methyl
bromide),
based
on
reported
results
from
tomato.

1,
3­
Dichloropropene
+
Chloropicrin.
The
1,3­
dichloropropene
and
chloropicrin
combination
is
not
technically
feasible
in
cases
with
high/
moderate
nutsedge
pressure
because
it
needs
to
be
coupled
with
an
herbicide
to
provide
season
long
control.
It
does
however
provide
control
of
nematodes
and
diseases.
All
constraints
described
above
for
1­
3­
dichloropropene
also
apply
to
this
pesticide
combination,
including
soil
limitations,
township
caps,
and
worker
exposure
safeguards
(
PPE).

A
bell
pepper­
squash
rotation
field
study
early
in
the
growing
season
with
chisel
injected
applications
of
1,3­
dichloropropene
+
chloropicrin
(
Webster
et
al.,
2001a)
had
yield
losses
that
ranged
from
0
to
40
percent
compared
to
methyl
bromide.
However,
by
the
end
of
the
season,
only
methyl
bromide
treatments
effectively
controlled
nutsedge.
Interviews
with
growers
indicated
pepper
yield
losses
of
between
10
to
20
percent;
and
increases
of
nutsedge
and
nightshade
populations
of
approximately
30
percent
with
Telone
C­
35
treatments
compared
to
methyl
bromide
(
grower
estimates
were
not
verified
with
field
data).
Page
9
The
1,3­
dichloropropene
+
chloropicrin
combination
has
shown
activity
suppressing
weeds,
but
control
of
nutsedge
has
not
been
as
consistent
or
as
effective
as
methyl
bromide
in
pepper
production.

Trials
comparing
broadcast
applications
with
standard
in­
row
applications
indicated
the
need
to
increase
the
amount
of
chloropicrin
to
compensate
for
the
potential
decrease
in
efficacy
of
1,3­
dichloropropene
applied
via
broadcast.
Applications
via
micro­
irrigation
systems
have
yielded
mixed
results,
probably
due
to
poor
lateral
distribution
of
the
chemical
in
the
soil.
Yield
losses
for
peppers
from
broadcast
methods
are
expected
to
be
6
to7
percent
greater
than
losses
from
more
precision
methods
(
compared
to
methyl
bromide),
based
on
reported
results
from
tomato.
Based
on
the
results
experienced
in
the
tomato
trials,
we've
assumed
similar
results
for
peppers.
Yield
increases
of
up
to
2
percent
were
reported
compared
to
methyl
bromide
when
there
was
a
second
application
of
chloropicrin
at
the
time
of
bed
shaping
following
a
Telone
C­
35
broadcast
application.

Chloropicrin.
Chloropicrin
alone
is
not
technically
feasible
because
it
is
not
sufficiently
efficacious
against
nematodes
and
weeds.
Chloropicrin
provides
effective
control
of
soilborne
pathogens/
diseases
but
is
less
effective
against
nematodes
and
weeds.
Most
of
the
research
data
are
for
1,
3­
D
+
chloropicrin,
and
as
previously
noted,
control
of
nutsedge
and
nematodes
has
not
been
reliable
or
effective.

Airborne
concentrations
of
chloropicrin
must
be
monitored.
Airborne
chloropicrin
levels
of
0.1
ppm
require
the
use
of
air­
purifying
respirators
and
levels
exceeding
4
ppm
require
the
use
of
air­
supplying
respirators.
Furthermore,
emission
of
chloropicrin
from
agricultural
fields
into
urban
areas
has
been
a
concern
due
to
lachrymating
effects.
Increased
use
of
chloropicrin
will
trigger
the
need
to
address
these
issues.

Metam
Sodium.
Metam
sodium
is
not
a
technically
feasible
alternative
because
research
data
show
metam
sodium
alone
provides
limited
and
erratic
performance
at
suppressing
all
major
solanaceous
pathogens
and
pests.
Metam
sodium
degrades
in
the
soil
to
form
methylisothiocyanate,
which
has
activity
against
nematodes,
fungi,
insects,
and
weeds.
Metam
sodium
has
a
lower
vapor
pressure
than
methyl
bromide,
and
therefore
cannot
penetrate
and
diffuse
throughout
the
soil
as
effectively
as
methyl
bromide.
In
addition,
the
effectiveness
of
metam
sodium
is
very
dependent
on
the
organic
matter
and
moisture
content
of
the
soil.
Studies
to
evaluate
best
delivery
systems
for
metam
sodium
are
being
conducted.
Some
studies
have
shown
that
soil
injections
and
drenches
are
more
effective
than
drip
irrigation.
Research
trials
show
that
incorporation
of
metam
sodium
with
a
tractor­
mounted
tillovator
provides
good
results
but
most
growers
do
not
have
this
equipment.

A
3­
week
time
interval
before
planting
is
recommended
to
avoid
phytotoxic
levels;
causing
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profit
or
actually
causing
a
loss
for
a
grower.

Data
indicate
that
metam
sodium
is
not
an
effective
alternative
to
methyl
bromide
for
nutsedge
control.
Webster
et
al.
(
2002
a),
showed
that
commercial
rates
of
metam
sodium
did
not
control
nutsedge
in
bell
pepper
fields,
relative
to
the
non­
treated
control
by
the
end
of
the
season.
Locascio
et
al.
(
1997)
showed
a
54
to
80
percent
yield
loss
(
compared
to
methyl
bromide
+
chloropicrin
Page
10
treatments)
in
tomato
fields
with
heavy
and
very
heavy
densities
of
nutsedge.
Similar
effects
are
expected
for
peppers.
In
other
trials,
metam
sodium
applied
through
drip
irrigation
under
plastic
mulch
controlled
nutsedge
80
to
90
percent
in
a
23
cm
band
along
the
drip
line
(
Dowler,
1999).
However,
research
has
shown
that
nutsedge
tubers
from
adjacent
areas
can
quickly
re­
infest
previously
treated
areas
in
a
single
growing
season
(
Webster,
2002
b),
and
the
effectiveness
of
this
method
raises
enough
questions
that
further
research
is
needed,
and
it
cannot
currently
be
considered
an
effective
and
reliable
alternative.

Metam
Sodium
+
Crop
Rotation.
The
metam
sodium
and
crop
rotation
combination
is
not
a
technically
feasible
alternative
because
research
data
show
metam
sodium
alone
provides
limited
and
erratic
performance
at
suppressing
all
major
solanaceous
pathogens
and
pests
and
crop
rotation
does
not
address
this
deficiency.
Issues
regarding
effects
of
allelochemicals
from
cover
crops
are
also
a
concern.
Unpublished
data
(
Norsworthy,
2000)
shows
that
incorporation
of
wild
radish
(
metam
sodium
crop
rotation)
caused
stand
loss
and
phytotoxicity
to
cotton.
More
research
is
needed
to
evaluate
the
possibility
of
similar
effects
for
vegetable
crops.

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical
Alternatives)

None
of
the
alternatives
listed
by
MBTOC
and
reviewed
above
were
found
to
be
technically
viable
for
pepper.
Despite
this,
reviewers
analyzed
the
economic
losses
associated
with
the
use
of
two
alternative
pest­
control
regimes:
1,3­
dichloropropene
+
chloropicrin,
and
metam­
sodium.
These
are
the
two
alternatives
considered
most
likely
to
be
used
in
the
absence
of
methyl
bromide.

The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide,
such
as
for
peppers,
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.,
an
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
absolute
losses
per
hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.
Page
11
(
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
pepper
producers
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.

The
results
of
the
economic
evaluation
of
the
1,3­
dichloropropene/
chloropicrin
alternative
are
shown
below
in
Table
2,
beginning
with
the
estimates
of
yield
loss,
which
is
also
a
measure
of
gross
revenue
loss.
Percent
yield
losses
are
5
percent
in
California,
lower
than
in
the
East
because
losses
from
Phytophthora
are
not
expected
to
be
as
great
as
losses
from
nutsedge.
Yield
loss
in
California
is
only
expected
for
the
10
percent
of
the
California
growing
area
where
methyl
bromide
is
needed
to
control
Phytophthora,
and
in
our
analysis
the
level
of
disease
pressure
is
assumed
to
be
what
is
typically
found
in
California.
Yield
losses
in
Florida
and
the
Southeast
are
expected
to
be
20
percent,
primarily
due
to
difficulties
controlling
nutsedge,
as
described
earlier.
This
yield
loss
is
expected
on
the
30
to
40
percent
of
pepper
producing
area
in
this
region
infested
with
moderate
and
high
levels
of
nutsedge
pressure.
It
should
be
noted
that
the
yield
loss
estimates
has
substantial
uncertainty,
because
most
of
the
referenced
studies
reported
wide
ranges
of
yield
effects.
The
reviewing
experts
conducted
the
economic
analysis
with
yield
losses
estimates
that
they
believed
represented
a
likely
or
central
estimate.

Shifting
to
metam­
sodium
is
expected
to
slightly
decrease
production
costs.
In
California,
production
costs
are
expected
to
fall
about
US$
170
or
1
percent
(
calculated
from
crop
budgets).
Specific
estimates
of
cost
increases
were
not
available
for
Florida,
or
the
Southeast
so
we
assumed
the
decrease
was
the
same
as
in
California.

Economic
losses
(
per
hectare)
are
calculated
by
adding
the
expected
loss
in
yield/
revenue
to
the
increase
in
production
costs.
Revenue
losses
are
higher
for
Florida
and
California
because
they
have
relatively
high
yields
compared
to
the
Southeast,
which
generally
has
lower
yields
(
Georgia
has
the
highest
yields
in
this
region).
In
other
words,
a
20
percent
yield
loss
in
Florida
corresponds
to
a
higher
absolute
loss
than
a
20
percent
yield
loss
in
North
Carolina.
In
addition
to
region­
specific
yields,
the
analysis
takes
into
account
the
price
of
peppers
in
each
region.
Page
12
Economic
loss
per
kilogram
of
methyl
bromide
is
a
measure
of
the
marginal
contribution
of
methyl
bromide.
It
is
calculated
by
dividing
usage
rates
(
per
hectare)
into
the
estimate
of
economic
losses
per
hectare
Comparing
these
losses
provides
a
rough
measure
of
the
loss
in
economic
efficiency
associated
with
adoption
of
methyl
bromide
alternatives.
Under
this
measure,
pepper
production
in
Florida
suffers
high
efficiency
losses
compared
to
the
Southeast
and
California,
but
it
is
important
to
note
that
in
all
cases,
losses
are
greater
than
zero,
suggesting
the
loss
of
methyl
bromide
would
lead
to
efficiency
losses
in
all
pepper
producing
areas.

Expressed
as
proportion
of
gross
and
net
revenue,
economic
losses
can
also
describe
the
impact
on
the
economic
viability
of
a
given
production
system.
Using
these
measures,
one
can
see
that
adoption
of
1,3­
dichloropropene/
chloropicrin
as
the
methyl
bromide
alternative
would
lead
to
substantial
economic
impacts.
Given
the
competitive
nature
of
vegetable
production
in
the
U.
S.,
these
economic
impacts
would
represent
a
substantial
market
disruption
to
U.
S.
pepper
producers.

Table
2.
Economic
Impact
of
Using
1,3­
Dichloropropene
+
Chloropicrin
in
Place
of
Methyl
Bromide
on
Bell
Peppers
in
the
U.
S.
Florida
Southeast
(
including
Georgia)
California
Direct
yield
loss
20%
loss
(
great
uncertainty
about
this
number)
20%
loss
(
great
uncertainty
about
this
number)
5%
loss
(
higher
if
township
caps
and
setbacks
limit
use
of
alternatives)
Change
in
production
costs
$
170/
ha
reduction
in
operating
costs
(
assuming
similar
to
CA)
$
170/
ha
reduction
in
operating
costs
(
assuming
similar
to
CA)
$
170/
ha
reduction
in
operating
costs
1%
of
operating
costs
Economic
loss
per
hectare
$
6180
$
2064
$
830
Economic
loss
per
kg
of
methyl
bromide
$
20.02
$
6.69
$
4.15
Economic
loss
as
percent
of
gross
revenues
19%
18%
4%

Economic
loss
as
percent
of
net
cash
revenues
unknown
unknown
80%
loss
Note:
Florida
and
Southeast
economic
data
were
very
limited.
These
calculations
based
on
California
information
and
information
in
2001
Ag.
Stats.

The
results
of
the
economic
evaluation
of
the
metam­
sodium
alternative
are
shown
below
in
Table
3,
beginning
with
the
estimates
of
yield
loss,
which
is
also
a
measure
of
gross
revenue
loss.
Percent
yield
losses
are
8
percent
in
California,
lower
than
in
the
East
because
losses
from
Phytophthora
are
not
expected
to
be
as
great
as
losses
from
nutsedge.
Yield
loss
in
California
is
only
expected
for
the
10
percent
of
California
growing
area
where
methyl
bromide
is
needed
to
control
Phytophthora,
and
in
our
analysis
the
level
of
disease
pressure
is
assumed
to
be
what
is
typically
found
in
California.
Yield
losses
in
Florida
and
the
Southeast
are
expected
to
be
30
percent,
primarily
due
to
difficulties
controlling
nutsedge,
as
described
earlier.
This
yield
loss
is
expected
on
the
30
to
40
percent
of
pepper
producing
area
in
this
region
infested
with
moderate
and
high
levels
of
nutsedge
pressure.
It
should
be
noted
that
the
yield
loss
estimates
have
substantial
uncertainty,
because
most
of
the
referenced
studies
reported
wide
ranges
of
yield
effects.
The
reviewing
experts
conducted
the
Page
13
economic
analysis
with
yield
losses
estimates
that
they
believed
represented
a
likely
or
central
estimate.

In
addition
to
declines
in
expected
gross
revenue,
shifting
to
the
metam­
sodium
combination
increases
production
costs.
These
costs
increase
because
of
higher
pesticide
costs,
as
well
as
higher
costs
of
applying
pesticides.
In
California,
production
costs
changes
of
about
US$
1065
per
hectare
or
6
percent
are
expected
(
calculated
from
crop
budgets).
Specific
estimates
of
cost
increases
were
not
available
for
Florida
and
the
Southeast
so
we
assumed
the
increase
would
be
the
same
as
in
California.

Economic
losses
(
per
hectare)
are
calculated
by
adding
the
expected
loss
in
yield/
revenue
to
the
increase
in
production
costs.
Revenue
losses
are
higher
for
Florida
and
California
because
they
have
relatively
high
yields
compared
to
the
Southeast,
which
generally
has
lower
yields
(
Georgia
has
the
highest
yields
in
this
region).
In
other
words,
a
30
percent
yield
loss
in
Florida
corresponds
to
a
higher
absolute
loss
than
a
30
percent
yield
loss
in
North
Carolina.
In
addition
to
region­
specific
yields,
the
analysis
takes
into
account
the
price
of
peppers
in
each
region.

Economic
losses
per
kilogram
of
methyl
bromide
are
a
measure
of
the
marginal
contribution
of
methyl
bromide.
It
is
calculated
by
dividing
usage
rates
(
per
hectare)
into
the
estimate
of
economic
losses
per
hectare.
Comparing
these
losses
provides
a
rough
measure
of
the
loss
in
economic
efficiency
associated
with
adoption
of
methyl
bromide
alternatives.
Under
this
measure,
pepper
production
in
Florida
suffers
high
efficiency
losses
compared
to
the
Southeast
and
California,
but
it
is
important
to
note
that
in
all
cases,
losses
are
greater
than
zero,
suggesting
efficiency
losses
in
all
pepper
producing
areas.

Expressed
as
proportion
of
gross
and
net
revenue,
economic
losses
can
also
describe
the
impact
on
the
economic
viability
of
a
given
production
system.
Using
these
measures,
one
can
see
that
adoption
of
metam­
sodium
as
the
methyl
bromide
alternative
would
lead
to
substantial
economic
impacts.
Page
14
Table
3.
Economic
Impact
of
Using
Metam­
Sodium
in
Place
of
Methyl
Bromide
on
Bell
Peppers
in
the
U.
S.

Florida
Southeast
(
including
Georgia)
California
Direct
yield
loss
30%
loss
(
great
uncertainty
about
this
number)
20%
loss
(
great
uncertainty
about
this
number)
8%
loss
(
higher
if
township
caps
and
setbacks
limit
use
of
alternatives)
Change
in
production
costs
$
1065/
ha
(
assuming
similar
to
CA)
$
1065/
ha
(
assuming
similar
to
CA)
$
1065/
ha
6%
of
operating
costs
Economic
loss
per
hectare
$
10591
$
4417
$
2,666
Economic
loss
per
kg
of
methyl
bromide
$
31.30
$
14.31
$
14.02
Economic
loss
as
percent
of
gross
revenues
33%
40%
13%

Economic
loss
as
percent
of
net
cash
revenues
unknown
unknown
250%
loss
Note:
Florida
and
Southeast
economic
data
were
very
limited.
These
calculations
based
on
California
information
and
information
in
2001
Ag.
Stats.

6e.
Technical
Feasibility
of
Not­
In­
Kind
(
Non­
Chemical)
Alternatives
This
section
summarizes
the
analysis
of
the
remainder
of
the
methyl
bromide
alternatives
identified
by
MBTOC
for
pepper,
primarily
non­
chemical
alternatives.
Table
4
contains
a
summary
of
the
technical
assessment,
which
is
that
none
of
these
alternatives
were
found
to
be
technically
feasible.
A
description
of
each
alternative
follows.
Because
no
alternative
was
found
to
be
technically
feasible,
no
economic
assessment
was
performed.

Table
4.
Not­
in­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Pepper
Methyl
Bromide
Alternative
Technically
Feasible
Economically
Feasible
Biofumigation
No
No
Solarization
No
No
Solarization,
Fungicides
No
No
Steam
No
No
Biological
control
No
No
Cover
crops
and
mulching
No
No
Crop
rotation/
Fallow
No
No
General
IPM
No
No
Grafting/
Resistant
rootstock/
Plant
breeding
No
No
Organic
amendments/
Compost
No
No
Resistant
Cultivars
No
No
Substrates/
Plug
plants
No
No
Page
15
Biofumigation
is
not
a
technically
feasible
alternative
because
it
has
not
been
shown
to
control
the
pest
complex.
Research
conducted
in
Florida
showed
some
control
of
plant
pathogens
but
no
control
of
nematodes
or
weeds
in
the
soil.
In
cases
where
biofumigation
have
been
shown
to
control
weeds,
the
data
are
mostly
for
small­
seeded
weed
species
that
have
small
carbohydrate
energy
sources
compared
to
nutsedge.
The
data
on
biofumigation
are
too
limited
to
consider
it
as
a
practical
alternative
to
methyl
bromide.

Solarization
is
not
technically
feasible
because
alone
it
does
not
control
the
wide
range
of
soil­
borne
diseases
and
pests
affecting
pepper.
Solarization
involves
covering
the
soil
with
clear
plastic
under
direct
sunlight
for
several
weeks.
Solarization
is
a
weather
sensitive
process
that
requires
ideal
soil
moisture
and
sunlight
conditions,
and
is
most
successful
in
regions
with
continuous
high
temperature
periods
during
summer.

Data
indicate
that
soil
solarization
can
be
an
effective
replacement
for
methyl
bromide
in
the
management
of
some
pests
and
diseases,
but
not
the
primary
pests
in
peppers
that
are
currently
controlled
through
fumigation.
Temperatures
of
65
degrees
C
for
30
minutes
will
control
many
soilborne
fungi,
nematodes
and
weeds,
with
the
exception
of
Cyperus
species.
Response
of
Cyperus
species
to
solarization
is
sporadic
and
not
well
understood
and
data
show
solarization
to
provide,
at
best,
suppression
of
nutsedge
populations
(
Chase
et
al.
1998;
Egley,
1983).
Field
studies
indicate
that
raising
and
maintaining
soil
temperatures
throughout
the
soil
profile
to
levels
shown
to
control
nutsedge
is
extremely
difficult.
Nutsedge
have
shown
ability
to
emerge
from
deep
in
the
soil
profile
and
to
reinvade
from
areas
outside
the
solarization
zone,
so
solarization
alone
will
not
be
an
effective
and
dependable
control
method
for
nutsedge,
which
is
the
primary
pest
underlying
the
nomination
for
continued
methyl
bromide
in
pepper.

Solarization
and
fungicides.
Fungicides
are
not
effective
for
control
of
weeds
and
nematodes.
Therefore,
their
use
in
combination
with
solarization
is
no
more
efficacious
than
solarization
alone.

Steam.
Steam
for
soil
sterilization
is
impractical
in
large­
scale,
open
field
production
areas
characteristic
of
pepper
production.
Steam
can
be
used
as
an
alternative
to
methyl
bromide
soil
fumigation
in
small­
scale
or
closed
production
areas
but
has
yet
to
be
proven
economical
and
practical
for
large­
scale,
open
field
production
systems
(
UNEP,
1998).
As
described
earlier,
U.
S.
pepper
production
is
not
of
a
scale
small
enough
to
make
steam
a
cost­
effective
alternative.

Biological
Control.
Biological
control
is
not
a
technically
feasible
alternative
to
methyl
bromide
in
pepper
production
because
no
biological
control
agent
has
been
identified
to
effectively
control
nutsedge
or
Phytophthora.
Therefore,
biological
control
is
not
a
stand­
along
replacement
for
methyl
bromide
in
pepper
crops.
Only
a
limited
number
of
biological
organisms
are
effectively
used
to
manage
soil
borne
diseases
and
pests.
Biocontrol
agents
are
usually
very
specific
regarding
the
organisms
they
control
and
their
successful
establishment
is
highly
dependent
on
environmental
conditions.

Several
pathogens
have
been
evaluated
for
control
of
nutsedge,
but
to
date,
there
are
no
bioherbicides
registered
for
management
of
nutsedge
species.
Dactylaria
higginssi
and
Puccinia
canaliculata
have
Page
16
shown
potential
to
control
nutsedge
tuber
formation,
however,
the
prolific
ability
of
nutsedge
to
reproduce
and
recolonize
will
limit
the
use
of
these
biological
control
agents
as
alternatives
to
methyl
bromide.

Biological
control
is
not
a
stand­
alone
replacement
for
methyl
bromide
in
pepper
crops.
Research
is
needed
to
develop
appropriate
mechanisms
to
integrate
the
use
of
biological
control
into
vegetable
production
systems,
including
proper
selection
of
pesticides
that
will
not
be
detrimental
to
populations
of
potential
biological
control
agents.

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

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

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

Crop
Rotation/
Fallow.
Crop
rotation/
fallow
are
not
technically
feasible
alternatives
because
they
do
not
control
nutsedge.
Crop
rotation
and
fallow
are
effective
tools
for
management
of
weeds,
diseases
and
nematodes,
especially
as
part
of
an
IPM
program.
However,
these
practices
may
be
difficult
for
growers
of
pepper
and
other
high­
value
crops;
especially
in
areas
were
land
is
a
limited
and
expensive
resource.
Agronomic
crops
are
more
effective
competitors
than
vegetable
crops
and
planting
dates
are
difficult
to
adjust
for
vegetable
crops
due
to
marketing
factors.
There
are
registered
herbicides
that
are
effective
for
nutsedge
control
in
agronomic
crops.
These
herbicides
are
not
available
for
most
vegetable
crops,
and
many
of
them
have
12
to
26­
month
carryover
restrictions
to
vegetable
crops.

Crop
rotation
and
fallow
will
not
suppress
nutsedge.
Johnson
&
Mullinix
(
1997)
showed
that
uninterrupted
plantings
of
peanut,
corn,
or
cotton,
with
moderate
levels
of
weed
management
suppressed
yellow
nutsedge
in
Georgia.
Their
data
also
showed
an
increase
in
nutsedge
densities
in
fallow
plots,
likely
due
to
the
longevity
of
nutsedge
tubers
in
soil,
mild
winters
that
prevent
winter­
kill
of
tubers,
and
the
ability
of
tubers
to
regenerate
with
the
long
growing
season
in
the
southeastern
coastal
plain.
There
are
also
reports
of
increasing
populations
of
yellow
nutsedge
in
fallowed
fields,
Page
17
even
when
weed
control/
management
is
performed.
Since
there
are
no
herbicides
registered
for
use
on
pepper
that
will
effectively
control
nutsedge,
management
of
these
weeds
during
short­
term
rotations
and
fallow
is
not
effective.

General
IPM.
IPM,
the
use
of
pest
monitoring
activities
coupled
with
chemical
and
non­
chemical
management
tools,
has
been
adopted
for
management
of
weed,
diseases,
and
nematodes
on
solanaceous
crops.
However,
problematic
weeds
like
nutsedge
and
nightshade,
and
soilborne
diseases
and
nematodes
are
not
effectively
controlled
by
these
practices.

Grafting/
Resistant
Rootstock/
Plant
Breeding.
Grafting
has
not
been
evaluated
for
vegetable
production
due
to
the
high
cost
and
the
large
number
of
plants
that
would
be
needed.
These
alternatives
are
primarily
used
for
nematode
and
disease
management,
but
there
is
no
evidence
that
they
apply
to
competition
from
weeds.

Plant
breeding
is
suited
for
the
management
of
soilborne
diseases
as
part
of
an
IPM
program.
This
alternative
is
not
applicable
to
competition
from
weeds.
Breeding
for
resistance
is
a
long
term
process
and
is
dependent
on
the
availability
of
natural
sources
of
resistance.

Organic
Amendments/
Compost.
Organic
amendment/
compost
is
not
a
technically
feasible
standalone
alternative
for
methyl
bromide
for
solanaceous
crop
production.
The
use
of
compost
as
a
pest
control
tool
is
still
new
and
not
clearly
understood.
Although
available
data
suggest
that
the
use
of
compost
is
a
viable
alternative
for
suppression
of
some
diseases,
especially
when
used
with
IPM
in
small­
scale
and
greenhouse
operations,
additional
research
is
needed
to
determine
the
specific
interactions
that
make
compost
effective
and
to
determine
its
usefulness
in
large­
scale
field
applications.

Resistant
Cultivars.
Resistant
cultivars
by
themselves
are
not
technically
feasible
alternatives
for
controlling
all
the
target
pests
of
pepper
production.
Disease
resistant
varieties
are
used
in
pepper
production,
especially
for
bacterial
and
viral
diseases.
Research
with
root­
knot
nematode
resistant
varieties
has
shown
that
genes
for
nematode
resistance
are
heat
sensitive
and
not
stable
at
high
soil
temperatures
typical
of
pepper
crop
production
areas.
These
plants
are
open
pollinated
and
homozygous
for
the
resistant
gene,
which
means
that
the
host­
plant
resistance
does
not
persist
across
generations.

Substrates/
Plug
Plants.
Substrates/
plug
plants
by
themselves
are
not
technically
feasible
alternatives
because
they
do
not
control
competition
from
nutsedge.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
peppers.
Amendments
with
biological
control
organisms
provide
limited
resistance/
control
and
yield
enhancements
in
solanaceous
crops
due
to
the
specific
nature
of
biological
control
microorganisms
and
the
heterogeneous
distribution
of
pathogens
in
soils.

7.
Critical
Use
Exemption
Nomination
for
Peppers
Page
18
As
noted
above,
this
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
for
pepper
production
in
the
states
of
Florida,
Georgia,
California,
and
a
group
of
Southeastern
states.
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
pepper
growers
in
Florida,
Georgia,
California
and
Southeastern
states
the
U.
S.
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
pepper
pests,
most
importantly,
yellow
and
purple
nutsedge
and
several
nematode
and
fungal
pathogens.

The
following
tables
provide
information
on
methyl
bromide
historical
usage,
including
area
treated,
and
the
2005
thru
2007
actual
amount
requested
for
pepper.

Table
5.
Methyl
Bromide
Usage
&
Request
for
Peppers
in
Florida
1997
1998
1999
2000
2001
2005
2006
2007
kg
1,727,644
1,630,376
1,644,501
1,431,639
1,577,412
1,371,662
1,371,662
1,371,662
hectares
9,429
8,903
8,984
8,741
8,741
8,741
8,741
8,741
rate
(
kg/
ha)
183
183
183
164
180
157
157
157
For
purposes
of
calculating
the
overall
U.
S.
critical
need
for
methyl
bromide,
only
enough
MeBr
to
treat
Florida
pepper
production
infested
with
nutsedge,
that
has
superficial
karst
topography
or
that
has
regulatory
constraints
is
included
in
the
nomination.

Florida
pepper
production
typically
uses
a
67/
33
formulation
of
methyl
bromide.

Table
6.
Methyl
Bromide
Usage
&
Request
for
Peppers
in
Georgia
1997
1998
1999
2000
2001
2005
2006
2007
kg
294,550
313,053
337,163
347,944
338,248
338,248
338,248
338,248
hectares
1,192
1,267
1,767
2,263
2,252
2,252
2,252
2,252
rate
(
kg/
ha)
247
247
191
154
150
150
150
150
For
purposes
of
calculating
the
overall
U.
S.
critical
need
for
methyl
bromide,
only
enough
MeBr
to
treat
Georgia
pepper
production
infested
with
nutsedge
is
included
in
the
nomination.

Methyl
bromide
use
in
Georgia
pepper
production
has
changed
over
time
from
the
98/
2
formulation
commonly
used
in
1997
to
predominately
the
67/
33
formulation
used
in
2000
and
2001.
Page
19
Table
7.
Methyl
Bromide
Usage
&
Request
for
Peppers
in
the
Southeast
(
excluding
Georgia)

1997
1998
1999
2000
2001
2005
2006
2007
kg
151,137
164,472
118,524
112,445
112,445
112,445
112,445
112,445
hectares
688
749
789
749
749
749
749
749
rate
(
kg/
ha)
220
220
150
150
150
150
150
150
For
purposes
of
calculating
the
overall
U.
S.
critical
need
for
methyl
bromide,
only
enough
MeBr
to
treat
Southeastern
pepper
production
infested
with
nutsedge,
which
represent
about
10%
of
pepper
production,
is
included
in
the
nomination.

Methyl
bromide
use
in
southeastern
pepper
production
has
changed
over
time
from
the
98/
2
formulation
commonly
used
in
1997
to
predominately
the
67/
33
formulation
used
currently.

Table
8.
Methyl
Bromide
Usage
&
Request
for
Peppers
in
California
1997
1998
1999
2000
2001
2005
2006
2007
kg
133,882
182,834
247,191
170,830
224,528
181,437
181,437
181,437
hectares
726
864
1,226
995
890
1,012
1,012
1,012
rate
(
kg/
ha)
184
212
202
172
252
179
179
179
The
amount
requested
in
the
nomination
reflects
area
for
California
pepper
growers
that
is
infested
with
Phytophthora
and
Verticilium
pathogens
and
represents
about
10%
of
total
California
production.
For
purposes
of
calculating
the
overall
U.
S.
critical
need
for
methyl
bromide,
only
enough
MeBr
to
treat
California
pepper
production
infested
Phytophthora
and
Verticilium
pathogens,
representing
about
10%
of
this
state's
total
pepper
production,
is
included
in
the
nomination.

The
total
U.
S.
nomination
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives
(
buffer
zones,
township
caps),
environmental
concerns
such
as
soil
based
restrictions
due
to
potential
groundwater
contamination,
and
historic
use
rates,
among
other
factors.
Page
20
Table
9.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Peppers
Year
Total
Request
by
Applicant
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
2,003,793
1,085,265
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
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
Page
21
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.

Research
Program
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.
Page
22
Table
6.
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Million
(
US$)

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.

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

1.
Multi­
Tactic
Approach
to
Pest
Management
for
Methyl
Bromide
Dependent
Crops
in
Florida
(
Sep
2000
­
Aug
2003)
To
evaluate
the
use
of
reduced
risk
pesticides
applied
through
drip
irrigation
for
nematode,
fungal
pathogen
control
and
yield;
to
evaluate
vegetable
transplants
grown
in
mixes
amended
with
plant
growth­
promoting
rhizobcteria
(
PGPR)
in
a
production
system
that
includes
the
most
promising
alternatives
for
methyl
bromide.
Tomato
or
pepper
seed
will
be
placed
in
a
standard
70%
peat,
30%
vermiculite
medium.
Medium
amendment(
s)
consisting
of
formulations
of
plant
growth
promoting
rhizobacteria
(
PGPR)
will
be
applied
as
formulations
of
BioYield
213
before
seeding.
A
subsample
of
5
to
6
week
old
seedlings,
depending
on
time
of
year,
will
be
assessed
for
height,
root
and
shoot
dry
weight,
leaf
area,
stem
caliper,
chlorophyll
density,
and
associated
calculated
ratios.
Both
treated
and
Page
23
untreated
plants
will
be
transplanted
to
field
plots
treated
with
a
variety
of
alternative
soil
treatments
and
application
methodologies
including
the
reduced
risk
chemical
Plantpro
applied
through
drip
irrigation.
Natural
incidences
of
soilborne
pathogens
will
be
assessed
throughout
the
growing
season.
Disease
incidence
ratings
will
be
made
and
confirmed
where
necessary
by
plating
on
appropriate
media.
Marketable
yield
will
be
assessed
for
treated
and
untreated
plots.
These
treatments
will
be
evaluated
in
four
field
trials
conducted
over
24
months.
Trials
will
utilize
split
plot
designs.

2.
Field
Scale
Demonstration/
validation
Studies
of
Alternatives
for
Methyl
Bromide
in
Plastic
Mulch
(
Apr
2000
­
Jun
2003)
Evaluate
and
validate
the
effectiveness
and
economic
viability
of
alternatives
to
Methyl
Bromide
soil
fumigation
for
nematode
disease
and
weed
control
in
plastic
mulch
vegetable
production
systems
in
Florida.
Establish
alternative
treatments
on
grower
fields
at
a
scale
sufficient
to
allow
their
evaluation
as
components
of
production
systems;
Establish
paired
subplots
in
alternative
treatments
and
adjacent
grower
standard
treatments;
Diagnose
and
monitor
nematodes,
soil­
borne
diseases,
and
practice
including
grading
fruit
and
recording
weights
conduct
a
comparative
cost/
benefit
analysis
of
the
alternative
treatments
using
the
whole
enterprise
budget
analysis
method.

3.
Field
Demo
and
Scale­
Up
of
Soilless
Culture
As
An
Alternative
to
Soil/
methyl
Bromide
for
Tomato
&
Pepper
(
Sep
2001
­
Aug
2002)
The
objective
of
this
research
will
be
to
field
test
the
practicality
and
economics
of
outdoor
soilless
culture
of
tomato
and
pepper,
and
to
determine
solutions
to
scale­
up
problems.
A
soilless
system
will
be
field
tested
on
a
commercial
farm
operation
using
tomato
and
pepper.
Inputs
and
crop
production
will
be
monitored
and
compared
to
conventional
crop
production
practices.

4.
Field
Eval
Studies
of
Dactylaria
Higginsii
As
a
Component
in
An
Integrated
Approach
to
Pest
Management
(
Sep
2001
­
Aug
2003)
The
objective
of
this
cooperative
research
agreement
is
to
evaluate
the
nutsedge
biological
control
agent,
Dactylaria
higginsii,
as
a
component
in
an
integrated
pest
management
program
for
vegetables.
Large­
scale
field
experiments
will
be
conducted
to
include
multiple
offseason
nutsedge
management
tools
including
tillage,
herbicide
applications
and
the
biological
control
agent
dactylaria
higginsii.
A
fall
tomato
crop
will
then
be
produced
using
a
conventional
system
and
the
biologically
based
system.

5.
Resistance
to
Diseases
and
Nematodes
in
Vegetable
Crops
(
Apr
2001
­
Apr
2003)
Describe
the
nature,
genetics,
and
mechanisms
of
host
resistance
to
major
pathogens
and
root­
knot
nematodes
that
attack
vegetable
crops
region­
wide
or
nationally.
Develop
durable,
resistant
cultivars
and
formulate
environmentally
compatible
management
practices
that
reliably
reduce
disease
losses
and
pesticide
use.
In
southern
peas
and
peppers,
use
PCR
to
identify
molecular
markers
for
resistance
to
root­
knot
nematodes;
characterize
mechanisms,
stability,
specificity
of
resistance;
as
alternatives
to
methyl
bromide
and
nematicides,
determine
efficacy
of
resistance
and
develop
cropping
systems
rotating
nematode
resistant
cultivars
with
susceptible
to
reduce
losses.
In
sweet
potato,
characterize
resistance
to
root­
knot
species.
In
melons,
use
PCR
to
identify
molecular
markers
for
disease
resistance;
investigate
downy
mildew
resistance
in
cucumber;
identify
sources
of
durable
resistance;
verify
downy
mildew
resistance
in
broccoli
lines.
Cooperate
with
public
plant
breeders
and
Page
24
seed
companies
to
facilitate
use
of
identified
resistance
and
markers
in
development
of
resistant
cultivars
of
vegetable
crops.

6.
Evaluation
of
Fumigant
Efficacy
with
Virtually
Impermeable
Film
(
VIF)
Plastic
(
Sep
2002
­
Mar
2005)
Evaluate
the
effect
of
methyl
bromide
replacement
soil
fumigants
applied
under
standard
polyethylene
plastic
or
virtually
impermeable
film
on
pathogen
control
and
plant
health
in
production
fields.

7.
Replacement
of
Methyl
Bromide
by
Integrating
the
Use
of
Alternative
Soil
Fumigants,
Cultural
Practices,
and
Herbicides
for
Tomato,
Pepper
(
University
of
Georgia/
CSREES
Sep
2001
­
Sep
2003)
Evaluate
soil
fumigant
alternatives
to
methyl
bromide
for
management
of
weeds,
diseases,
and
nematodes
in
cooperation
with
growers
in
tomato,
pepper,
and
watermelon.
Evaluate
the
most
effective
application
methods
for
soil
fumigant
alternatives
in
tomato,
pepper
and
watermelon.
Evaluate
the
need
and
efficacy
of
herbicides
applied
in
combination
with
methyl
bromide
alternative
soil
fumigants
in
tomato,
pepper
and
watermelon.
Additionally,
evaluate
crop
tolerance
to
these
herbicides.
To
determine
a
systems
approach
of
managing
weeds,
diseases,
and
nematodes
that
can
be
effectively
and
economically
adopted
by
growers
in
tomato,
pepper
and
watermelon.

8.
Sodium
Azide
and
Furfural­
Based
Biofumigants
for
soil
Pest
Control
in
Crops
(
Auburn
University/
CSREES
Sep
2001
­
Sep
2003)
Develop,
optimize
and
implement
management
strategies
using
sodium
azide
as
an
alternative
to
methyl
bromide
to
control
nematodes,
weeds
and
pathogens
in
bell
peppers
and
ornamental
nursery
crops.

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.

Based
on
preliminary
results
from
research
conducted
in
this
area
and
largely
in
the
area
of
tomatoes
and
strawberries,
researchers
believe
that
a
mix
of
fumigants
together
with
an
herbicide
treatment
is
the
best
possible
alternative
to
methyl
bromide.
Combinations
of
Telone/
chloropicrin,
and
metamsodium
chloropicrin
are
being
tested
for
disease
and
weed
control.
Future
research
plans
will
test
combinations
of
these
fumigants
with
chemicals,
such
as
halosulfuron,
metolachlor,
and
sulfentrazone.
A
program
to
evaluate
host
resistance
to
Phytophthora
root
and
crown
rot
has
been
implemented.
Growers
are
starting
to
deploy
lines
identified
as
having
both
genetic
resistance
and
acceptable
horticultural
qualities.

Research
in
application
technology
(
e.
g.,
injection
methods
and
application
rates)
may
improve
the
uniformity
of
soil
movement
of
chemicals,
such
as
metam­
sodium.
Non­
chemical
alternatives
have
been
incorporated
and
methods
such
as
IPM,
mulching,
solarization,
and
biofumigation
are
being
examined
as
part
of
an
overall
strategy
to
manage
pepper
production.
Trials
evaluating
compost­
Page
25
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
United
States
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.

In
addition
to
the
research
that
is
ongoing
under
the
U.
S.
Department
of
Agriculture,
applicants
to
the
U.
S.
government
for
inclusion
in
the
nomination
for
critical
uses
have
cited
the
following
research
plans
as
ones
they
are
funding
or
otherwise
participating
in.
Many
of
the
studies
are
the
same
ones
conducted
for
tomatoes
and
eggplant.
They
are:

Florida
Peppers:
Ongoing
research
conducted
by
USDA,
University
of
Florida
Institute
of
Food
and
Agricultural
Sciences
and
the
Florida
Fruit
and
Vegetable
association
will
continue.
In
the
near
term,
additional
attention
will
be
paid
to
Telone/
chloropicrin/
herbicide
combinations
(
see
appendix
for
list
of
planned
grower
trials).
Over
120
peer
reviewed
articles
have
been
published
to
date
based
on
trials
conducted
in
cooperation
with
the
above
groups.

Georgia
Peppers:
A
study
will
be
conducted
in
2003­
2004
for
watermelon,
pepper
and
tomato
crops
by
University
experts
They
will
test
chloropicrin;
1,3­
dichloropropene;
chloropicrin
+
1,3­
D;
halosulfuron;
metam
sodium;
metam
potassium;
sulfentrazone
and
combinations
of
the
above.
This
study
will
measure
yield.

Southeastern
Pepper
Consortium:
A
study
will
be
conducted
in
North
Carolina
by
regional
experts
looking
at
herbicides
such
as
metolachlor,
halosulfuron,
rimsulfuron,
and
dimehenamid.
These
herbicides
will
be
tested
in
combination
with
certain
fumigants.
Yield
will
be
measured.

California
Peppers:
Applicant
will
conduct
various
research
studies
in
California
on
breeding
stocks
and
alternatives.
For
example,
the
applicant
will
test
disease
resistant
strains,
using
broccoli
as
a
rotational
crop,
and
ongoing
grower
attempts
to
learn
how
to
use
Vapam
and
Telone/
Cloropicrin
combinations
in
an
efficacious
way.
Yield
will
be
measured.

Michigan
Peppers:
Page
26
University
experts
will
trial
a
variety
of
alternatives
on
test
plots
owned
by
commercial
growers
in
Michigan
in
2003
and
2004.
They
will
analyze
the
ability
of
these
alternatives
to
control
Verticillium,
Fusarium
and
Phytophthora.
Alternatives
they
will
test
include
Ptyalin
C­
35;
Multigard
FFA;
Multigard
Protect
with
Vapam
HL;
CX­
100
(
applied
as
drip
or
preplant);
Chloropicrin
(
100%);
Iodomethane
(
67%/
33%);
and
composted
chicken
manure.

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
United
States
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
United
States
if
it
has
not
been
registered
by
U.
S.
EPA,
unless
it
has
an
exemption
from
regulation
under
FIFRA.
Page
27
Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
process
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
The
average
processing
time
for
a
new
active
ingredient,
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
most
cases,
the
registrant
(
the
pesticide
applicant)
has
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
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
Page
28
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:

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

It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
even
registering
those
alternatives
is
not
the
end
of
the
story.
Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption
will
occur.
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
United
States
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

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.

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
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.
Page
29
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
peppers
are
not
currently
technically
or
economically
feasible
in
the
management
of
the
major
pests
of
peppers,
specifically
on
insects,
weeds,
nematodes,
and
pathogens
from
the
standpoint
of
United
States
pepper
growers
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
in
peppers
may
be
on
the
horizon.
That
said,
it
must
be
stressed
that
the
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unacceptable
risk,
is
a
long
and
rigorous
process,
and
the
U.
S.
need
for
methyl
bromide
for
peppers
will
be
maintained
for
the
period
being
requested
for
an
exemption
in
this
nomination.

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

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

First,
because
of
uncertainties
in
both
markets
and
the
future
need
for
individual
active
moieties
of
drugs,
the
TEAP
has
never
provided
a
tonnage
limit
for
each
of
the
large
number
of
active
moieties
found
in
national
requests
for
a
CFC
essential
use
exemption
for
MDIs,
but
has
instead
recommended
an
aggregate
tonnage
exemption
for
national
use.
This
has
been
done
with
an
understanding
that
the
related
country
will
ensure
that
the
tonnage
approved
for
an
exemption
will
be
used
solely
for
the
group
of
active
moieties/
MDIs
that
have
been
granted
the
exemption.
We
believe
that
the
factors
of
agricultural
uncertainty
surrounding
both
pest
pressures
in
future
year
crops,
and
efficacy
of
reduced
methyl
bromide
application
provide
an
even
stronger
impetus
for
using
a
similar
approach
here.
The
level
of
unpredictability
in
need
leads
to
a
second
area
of
similarity
with
MDIs,
the
essential
need
for
a
review
of
the
level
of
the
request
which
takes
into
account
the
need
for
a
margin
of
safety.
Page
30
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
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
Page
31
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
Allen,
L.
H.,
S.
J.
Locascio,
D.
W.
Dickson,
D.
J.
Mitchell,
and
S.
D.
Nelson.
1999.
Flooding
(
soil
anoxia)
for
control
of
pests
of
vegetables.
Research
Summary,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.

Burgos,
N.
R.
and
R.
E.
Talbert.
1996.
Weed
control
and
sweet
corn
(
Zea
mays
var.
rugosa)
response
in
a
no­
till
system
with
cover
crops.
Weed
Sci.
44:
355­
361.

Chase,
C.
A.,
T.
R.
Sinclair,
D.
G.
Shilling,
J.
P.
Gilreath,
and
S.
J.
Locascio.
1998.
Light
effects
on
rhizome
morphogenesis
in
nutsedges
(
Cyperus
spp):
Implications
for
control
by
soil
solarization.
Weed
Sci.
46:
575­
580.

Egley,
G.
H.
1983.
Weed
seed
and
seedling
reductions
by
soil
solarization
with
transparent
polyethylene
sheets.
Weed
Sci.
31:
404­
409.
Page
32
Galloway,
B.
A.
and
L.
A.
Weston.
1996.
Influence
of
cover
crop
and
herbicide
treatment
on
weed
control
and
yield
in
no­
till
sweet
corn
(
Zea
mays
L.)
and
pumpkin
(
Cucurbita
maxima
Duch).
Weed
Technol.
10:
341­
346.

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
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
Horowitz,
M.
1972.
Effects
of
desiccation
and
submergence
on
the
viability
of
rhizome
fragments
of
bermudagrass,
johnsongrass,
and
tubers
of
nutsedge.
Israel
J.
Agric.
Res.
22(
4):
215­
220.

Johnson,
G.
A.,
M.
S.
Defelice,
and
A.
R.
Helsel.
1993.
Cover
crop
management
and
weed
control
in
corn
(
Zea
mays).
Weed
Technol.
7425­
430.

Norsworthy,
J.
2000.
Allelopathic
effects
of
wild
radish
on
cotton.
Clemson
University.
Unpublished.

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.

United
Nations
Environment
Programme
(
UNEP),
1998
.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC).
1998
Assessment
of
alternatives
to
methyl
bromide.
p.
49.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2001(
a).
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Rotation
20:
605­
614
Webster,
T.
M.
and
G.
E.
Macdonald.
2001(
b).
A
survey
of
weeds
in
various
crops
in
Georgia.
Weed
Technol.
15:
771­
790.
Page
33
13.
Appendices
Appendix
A.
List
of
Critical
Use
Exemption
(
CUE)
Requests
for
the
Pepper
Sector
in
the
U.
S.

CUE­
02­
0017,
California
Pepper
Commission
CUE­
02­
0041,
Southeastern
Pepper
Consortium
(
Alabama,
Arkansas,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia)

CUE­
02­
0049,
Georgia
Fruit
and
Vegetable
Growers
Association
CUE­
02­
0054,
Florida
Fruit
&
Vegetable
Association
Appendix
B.
Spreadsheets
Supporting
Economic
Analyses
This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
subregions
or
production
systems.
A
baseline
analysis
was
done
to
establish
the
outcome
of
treating
with
methyl
bromide
for
each
of
these
scenarios.
Therefore,
the
rows
of
the
tables
correspond
to
the
production
scenarios,
with
each
production
scenario
accounting
for
row
and
the
alternative(
s)
accounting
for
additional
rows.

The
columns
of
the
table
correspond
to
the
estimated
impacts
for
each
scenario.
(
The
columns
of
the
table
are
spread
over
several
pages
because
they
do
not
fit
onto
one
page.)
The
impacts
for
the
methyl
bromide
baseline
are
given
as
zero
percent,
and
the
impacts
for
the
alternatives
are
given
relative
to
this
baseline.
Loss
estimates
include
analyses
of
yield
and
revenue
losses,
along
with
estimates
of
increased
production
costs.
Losses
are
expressed
as
total
losses,
as
well
as
per
unit
treated
and
per
kilogram
of
methyl
bromide.
Impacts
on
profits
are
also
provided.

After
the
estimates
of
economic
impacts,
the
tables
contain
basic
information
about
the
production
systems
using
methyl
bromide.
These
columns
include
data
on
output
price,
output
volume,
and
total
revenue.
There
are
also
columns
that
include
data
on
methyl
bromide
prices
and
amount
used,
along
with
data
on
the
cost
of
alternatives,
and
amounts
used.
Additional
columns
describe
estimates
of
other
production
(
operating)
costs,
and
fixed/
overhead
costs.

The
columns
near
the
end
of
the
tables
combine
individual
costs
into
an
estimate
of
total
production
costs,
and
compare
total
costs
to
revenue
in
order
to
estimate
profits.
Finally,
the
last
several
columns
contain
the
components
of
the
loss
estimates.
Page
34
#
Notes
1
Assumed
alternative
cost
the
same
as
MeBr.
If
it
costs
more,
then
it
is
less
economically
feasible.

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

*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
Page
35
Page
36
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
Page
37
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.

Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

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

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

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.
Page
38
Margriet
F.
Caswell
(
Economist).
Margriet
has
been
with
the
USDA
Economic
Research
Service
since
1991.
She
has
held
both
technical
and
managerial
positions,
and
is
now
a
Senior
Research
Economist
in
the
Resource,
Technology
&
Productivity
Branch,

Resource
Economics
Division.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
the
University
of
California
(
Berkeley).
Dr.

Caswell
also
received
a
Master
of
Science
(
Resource
Economics)
and
Bachelor
of
Science
(
Natural
Resource
Management)
from
the
University
of
Rhode
Island
(
Kingston).
Prior
to
joining
USDA,
Dr.
Caswell
was
a
member
of
both
the
Environmental
Studies
and
Economics
faculties
at
the
University
of
California
at
Santa
Barbara.

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­

Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,

genetic
manipulation
of
microorganisms.

Daniel
Chellemi
(
Biologist).
Dan
has
been
a
research
plant
pathologist
with
the
U.
S.
Department
of
Agriculture
since
1997.
His
research
speciality
is
the
ecology,
epidemiology,
and
management
of
soilborne
plant
pathogens.
He
earned
his
Ph.
D.
(
Plant
Pathology)

from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.

Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).

Angel
Chiri
(
Biologist).
Angel
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.

He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
California
State
University
(
Los
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.
Page
39
She
earned
her
Ph.
D.
(
Entomology)
from
Purdue
University
(
West
Lafayette)
and
has
a
Master
of
Science
(
Entomology)
from
Louisiana
State
University
(
Baton
Rouge).
Dr.
Cook
is
a
1979
graduate
of
Clemson
University.
Prior
to
joining
EPA
Dr.
Cook
held
several
faculty
positions
at
Wabash
College
(
Crawfordsville)
and
University
of
Evansville
(
Evansville).

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

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

Clara
Fuentes
(
Biologist).
Clara
has
been
with
the
U.
S.
Environmental
Protection
agency
since
1999,
working
in
the
Philadelphia,

Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
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.
Page
40
Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
and
benefits
of
pesticide
use
at
the
University
of
Illinois
(
Urbana).
Dr.
Grube
has
been
a
co­
author
of
a
number
of
journal
articles
in
various
areas
of
pesticide
economics
LeRoy
Hansen
(
Economist).
LeRoy
Hansen
is
currently
employed
as
an
Agricultural
Economist
for
the
USDA
Economic
Research
Service,
Resource
Economics
Division
in
the
Resources
and
Environmental
Policy
Branch.
He
received
his
Ph.
D.
in
resource
economics
from
Iowa
State
University
(
Ames)
in
1986.
During
his
16
years
at
USDA,
Dr.
Hansen
has
published
USDA
reports,
spoken
at
profession
meetings,
and
appeared
in
television
and
radio
interviews.

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

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

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

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
Page
41
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)

researching
Agricultural
Sciences
Center
in
Parlier,
CA.
He
joined
ARS
in
June
of
1971.

Sean
Lennon
(
Biologist).
Sean
is
a
Biologist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
He
will
receive
his
M.
S.
in
Plant
and
Environmental
Science
in
December
2003
from
Clemson
University
(
Clemson).
Mr.

Lennon
is
a
graduate
of
Georgia
College
&
State
University
(
Milledgeville)
where
he
earned
a
Bachelor
of
Science
(
Biology).
Sean
is
conducting
research
in
Integrated
Pest
Management
of
Southeastern
Peaches.
He
has
eight
years
of
experience
in
the
commercial
peach
industry.

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

Tom
Melton
(
Biologist).
Tom
has
been
a
member
of
the
Plant
Pathology
faculty
at
North
Carolina
State
University
since
1987.

Starting
as
an
assistant
professor
and
extension
specialist,
Tom
has
become
the
Philip
Morris
Professor
at
North
Carolina
State
University.
His
primary
responsibilities
are
to
develop
and
disseminate
disease
management
strategies
for
tobacco.
Dr.
Melton
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
(
Pest
Management)

degree
from
North
Carolina
State
University
(
Raleigh).
He
is
a
1978
graduate
of
Norht
Carolina
State
University
(
Raleigh)
Prior
to
joining
the
North
Carolina
State
faculty,
Dr.
Melton
was
a
member
of
the
faculty
at
The
University
of
Illinois
(
Urbana­
Champaign).

Richard
Michell
(
Biologist).
Rich
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1972.
He
is
a
nematologist/
plant
pathologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
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).
Page
42
Lorraine
Mitchell
(
Economist).
Lorraine
has
been
an
agricultural
economist
with
the
U.
S.
Department
of
Agriculture,
Economic
Research
Service
since
1998.
She
works
on
agricultural
trade
issues,
particularly
pertaining
to
consumer
demand
in
the
EU
and
emerging
markets.
Dr.
Mitchell
earned
her
Ph.
D.
(
Economics)
from
The
University
of
California
(
Berkeley).
Prior
to
joining
ERS,
Dr.
Mitchell
was
a
member
of
the
faculty
of
the
School
of
International
Service
of
The
American
University
(
Washington)
and
a
research
assistant
at
the
World
Bank.

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

Jack
Norton(
Biologist).
Jack
has
worked
for
the
U.
S.
Department
of
Agriculture
Interregional
research
Project
#
4
(
IR­
4)
as
a
consultant
since
1998.
The
primary
focus
of
his
research
is
the
investigation
of
potential
methyl
bromide
replacement
for
registration
on
minor
crops.
He
is
an
active
member
of
the
USDA/
EPA
Methyl
Bromide
Alternatives
Working
Group.
Dr,
Norton
earned
his
Ph.
D.

(
Horticulture)
from
Texas
A&
M
University
(
College
Station)
and
holds
a
Master
of
Science
(
Horticultural
Science)
from
Oklahoma
State
University(
Stillwater).
He
is
a
graduate
of
Oklahoma
State
University
(
Stillwater).
Prior
to
joining
the
IR­
4
program,
Dr.
Norton
worked
in
the
crop
protection
industry
for
27
years
where
he
was
responsible
for
the
development
and
registration
of
a
number
of
important
products.

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

Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

Craig
Osteen(
Economist).
Craig
has
been
with
the
U.
S.
Department
of
Agriculture
for
over
20
years.
He
currently
is
with
the
Economic
Research
Service
in
the
Production
Management
and
Technology
Branch,
Resource
Economics
Division.
He
primary
areas
of
Page
43
interest
relate
to
issues
of
pest
control,
including
pesticide
regulation,
integrated
pest
management,
and
the
methyl
bromide
phase
out.

Dr.
Osteen
earned
his
Ph.
D.
(
Natural
Resource
Economics)
from
Michigan
State
University
(
East
Lansing).

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

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

Carmen
L.
Sandretto
(
Agricultural
Economist).
Carmen
has
been
with
the
Economic
Research
Service
of
the
U.
S.
Department
of
Agriculture
for
over
30
years
in
a
variety
of
assignments
at
several
field
locations,
and
since
1985
in
Washington,
DC.
He
has
worked
on
a
range
of
natural
resource
economics
issues
and
in
recent
years
on
soil
conservation
and
management,
pesticide
use
and
water
quality,

and
small
farm
research
studies.
Mr.
Sandretto
holds
a
Master
of
Arts
degree
(
Economics)
from
Harvard
University
(
Cambridge)
and
a
Master
of
Science
(
Agricultural
Economics)
from
The
University
of
Wisconsin
(
Madison).
Mr
Sandretto
is
a
graduate
of
Michigan
State
University
(
East
Lansing).
Prior
to
serving
in
Washington,
D.
C.
he
was
a
member
of
the
economics
faculty
at
Michigan
State
University
and
at
the
University
of
New
Hampshire
(
Durham).

Judith
St.
John
(
Biologist).
Judy
has
been
with
the
USDA's
Agricultural
Research
Service
since
1967.
She
currently
serves
as
Associate
Deputy
Administrator
and
as
such
she
is
responsible
for
the
Department's
intramural
research
programs
in
the
plant
sciences,

including
those
dealing
with
pre­
and
post­
harvest
alternatives
to
methyl
bromide.
Dr.
St.
John
earned
her
Ph.
D.
(
Plant
Physiology)
from
The
University
of
Florida
(
Gainesville).

James
Throne
(
Biologist).
Jim
is
a
Research
Entomologist
with
the
U.
S.
Department
of
Agriculture's
Agricultural
Research
Service
and
Research
Leader
of
the
Biological
Research
Unit
at
the
Grain
Marketing
and
Production
Research
Center
in
Manhattan,
Kansas.
He
conducts
research
in
insect
ecology
and
development
of
simulation
models
for
improving
integrated
pest
management
systems
for
stored
grain
and
processed
cereal
products.
Other
current
areas
of
research
include
investigating
seed
resistance
to
stored­
grain
insect
pests
and
use
of
near­
infrared
spectroscopy
for
detection
of
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).
Page
44
Thomas
J.
Trout
(
Agricultural
Engineer).
Tom
has
been
with
the
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
since
1982.
He
currently
serves
ar
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.

trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

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

David
Widawsky
(
Chief,
Economic
Analysis
Branch).
David
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1998.
He
has
also
served
as
an
economist
and
a
team
leader.
As
branch
chief,
David
is
responsible
for
directing
a
staff
of
economists
to
conduct
economic
analyses
in
support
of
pesticide
regulatory
decisions.
He
earned
his
Ph.
D.
(
Development
and
Applied
Economics)
from
Stanford
University
(
Palo
Alto),
and
a
Master
of
Science
(
Agricultural
Economics)
from
Colorado
State
University
(
Fort
Collins).
Dr.

Widawsky
is
a
1987
graduate
(
Plant
and
Soil
Biology,
Agricultural
Economics)
of
the
University
of
California
(
Berkeley).
Prior
to
joining
EPA,
Dr.
Widawsky
conducted
research
on
the
economics
of
integrated
pest
management
in
Asian
rice
production,
while
serving
as
an
agricultural
economist
at
the
International
Rice
Research
Institute
(
IRRI)
in
the
Philippines.

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
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.
Page
45
D.
(
Plant
Pathology)
from
Clemson
University
(
Clemson)
and
holds
a
Master
of
Science
(
Horticulture/
Plant
Breeding)
from
Texas
A&
M
University
(
College
Station).
Dr.
Yourman
is
a
graduate
(
English
Literature)
of
The
George
Washington
University
(
Washington,
DC).
.

Prior
to
joining
EPA,
he
conducted
research
on
biological
control
of
invasive
plants
with
USDA
at
the
Foreign
Disease
Weed
Science
Research
Unit
(
Ft.
Detrick,
MD).
He
has
also
conducted
research
on
biological
control
of
post
harvest
diseases
of
apples
and
pears
at
the
USDA
Appalachian
Fruit
Research
Station
(
Kearneysville,
WV).
Research
at
Clemson
University
concerned
the
molecular
characterization
of
fungicide
resistance
in
populations
of
the
fungal
plant
pathogen
Botrytis
cinerea.

Istanbul
Yusuf
(
Economist).
Istanbul
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1998.
She
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
She
earned
her
Master=
s
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.
Page
46
Appendix
D:
Charts
(
See
the
separate
electronic
file
for
CHART
1
and
CHART
2)
