Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
FRESH
MARKET
TOMATOES
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
fresh
market
tomatoes,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
U.
S.
believes
is
critical
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
Fresh
market
tomatoes
is
one
of
these
uses.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
tomatoes
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
The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
understand
the
unique
nature
of
U.
S.
agriculture,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
methyl
bromide.

For
the
U.
S.
nomination
for
fresh
market
tomatoes,
following
detailed
technical
and
economic
review,
the
U.
S.
has
determined
that
some
use
of
methyl
bromide
in
tomato
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
tomatoes
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.
However,
the
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide.
That
is
why
the
methyl
bromide
critical
use
exemption
calls
for
an
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
understand
the
unique
nature
of
U.
S.
agriculture
in
growing
fresh
market
tomatoes,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
fresh
market
tomatoes.

4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Fresh
Market
Tomatoes
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
tomato
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
Page
4
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.

5.
Overview
of
Agricultural
Production
5a.
U.
S.
Agriculture
The
U.
S.
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
agricultural
climates.
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
mass
larger
than
the
entire
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
an
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
sizes
in
the
European
Union).
The
availability
of
land
in
these
regions,
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
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

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

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

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
has
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices,
including
plastic
mulches,
row
covers,
high­
density
planting,
more
effective
pesticide
sprays,
and
drip
irrigation,
as
well
as
increased
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
Page
5
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.

5b.
Fresh
Market
Tomato
Production
U.
S.
fresh
market
tomato
production
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture
noted
above.
Fresh
market
tomatoes
are
a
long­
season
commodity
grown
in
most
of
the
major
vegetable
growing
areas
of
the
U.
S.,
and
Florida
and
California
were
the
leading
producers,
accounting
for
almost
two­
thirds
of
the
hectares
used
to
grow
fresh
tomatoes
in
the
United
States
in
2001.
Florida
produced
about
41
percent
of
U.
S.
fresh
market
tomatoes,
while
California
ranked
second
with
39
percent.
Virginia,
Georgia,
Michigan,
and
other
Southeastern
states
(
SE)
also
produced
fresh
market
tomatoes.
As
a
consequence,
this
nomination
covers
methyl
bromide
use
in
a
variety
of
areas
with
differing
soil
and
climactic
characteristics.
Another
factor
that
makes
the
tomato
sector
typical
of
US
agriculture
is
its
size.
Fresh
market
tomatoes
comprise
over
$
4
billion
USD
retail
value
and
were
harvested
from
52,092
hectares
(
128,720
acres)
producing
1,678,000
tonnes
(
36,964,000
cwt)
in
2001.

Seventy
percent
of
U.
S.
fresh
tomatoes
are
domestically
consumed
with
30
percent
exported
to
the
world
market.
The
U.
S.
is
still
a
net
importer
of
fresh
tomatoes
from
Canada
and
Mexico
with
the
total
import
value
of
$
721
million
USD
in
2001.
Fresh
tomatoes
are
available
year­
round
in
the
United
States.
The
price
of
fresh
market
tomatoes
varies
during
the
year.
Prices
are
the
lowest
during
August
and
September
when
supplies
of
locally
grown
tomatoes
in
most
states
are
highest.

Finally,
tomatoes
grown
in
the
U.
S.
are
generally
produced
using
mechanized,
scientific
practices
that
involve
deep
injection
of
methyl
bromide.
Tomatoes
require
intense
management,
including
the
use
of
a
broad­
spectrum
soil
fumigant,
polyethylene
mulch,
fertilizers,
irrigation
and
pesticides.
Plants
are
in
the
field
for
4
to
8
months,
depending
on
the
season
and
location.
Tomato
crops
are
sometimes
double­
cropped
with
a
cucurbit
crop
after
harvest
(
e.
g.,
cucumber,
squash,
watermelon),
and
in
some
areas,
specialty
peppers
(
e.
g.,
chili
peppers,
pimentos,
jalapeño
peppers)
are
planted
as
a
second
short­
season
crop.

Tomato
growers
in
Michigan
and
some
areas
in
Southeastern
states
have
significant
pest
problems
that
are
currently
controlled
using
methyl
bromide,
including
combinations
of
fungi,
nematodes,
and
nutsedge
(
4,
5,
6,
11,
12).
In
Michigan,
the
moderate
weather
(
18
to
22

C)
with
high
humidity
favors
the
develop
of
Phytophthora,
which
can
be
a
devastating
fungal
pathogen
in
tomatoes.
There
are
currently
no
effective
registered
alternatives
for
controlling
this
pathogen
when
disease
pressure
is
high,
and
in
Michigan,
Phytophthora
is
a
primary
reason
for
using
methyl
bromide,
although
weed
and
nematode
control
are
also
important
benefits
from
fumigation.
In
Southeastern
states,
methyl
bromide
is
used
to
control
soil­
borne
fungi,
nematodes,
and
weeds.
While
these
are
all
important
pests,
methyl
bromide
is
particularly
needed
in
the
Southeastern
U.
S.
to
control
nutsedge,
a
weed
that
can
seriously
diminish
yields
in
fresh
market
tomatoes
(
as
well
as
many
other
crops).
There
are
currently
no
registered
herbicides
that
are
effective
in
controlling
moderate
to
high
level
of
nutsedge
infestations.
Page
6
Methyl
bromide
is
typically
used
in
combination
with
chloropicrin
at
a
rate
of
120
to
252
kg
per
hectare
(
107
to
225
lbs
per
acre).
The
application
rate
depends
on
the
climatic
region,
application
method
(
e.
g.
raised
bed
vs.
full
field),
soil
type,
and
soil­
borne
pest
pressure.
Full
field
applications
and
heavy
soils
tend
to
increase
application
rates,
while
raised
bed
and
light
soils
tend
to
decrease
application
rates.
Other
things
being
equal,
higher
pest
pressure,
particularly
weed
pressure,
leads
to
higher
application
rates.
Methyl
bromide
application
rates
in
Southeastern
states
tend
to
be
higher
than
those
in
Michigan
when
all
these
factors
are
taken
into
account.

Over
the
past
30
years,
methyl
bromide
and
methyl
bromide­
chloropicrin
combinations
have
become
the
standard
fumigant
in
fresh
market
tomatoes
produced
with
polyethylene
mulch.
These
fumigations
are
highly
effective
in
controlling
wide
spectrum
of
soil­
borne
pests
under
different
weather
conditions,
and
are
particularly
important
for
disease
control
in
Michigan
and
weed
control
in
Southeastern
states.
Estimates
of
the
impact
of
the
loss
of
methyl
bromide
in
vegetable
production
suggest
that
without
methyl
bromide,
a
significant
proportion
of
U.
S.
fresh
market
tomato
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.

As
a
consequence,
this
nomination
covers
use
in
several
tomato
producing
area
in
the
U.
S.,
with
differing
soil
and
climactic
characteristics.
Specifically,
the
U.
S.
nominates
fresh
market
tomatoes
in
the
Southeastern
U.
S.
and
in
the
State
of
Michigan
for
a
critical
use
exemption.
The
U.
S.
is
not
nominating
fresh
tomato
production
in
California,
because
the
U.
S.
has
found
that
it
is
not
a
critical
need.
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
some
methyl
bromide
use
in
tomato
production
in
the
southeastern
States
(
Florida,
Georgia,
Virginia,
Alabama,
Arkansas,
North
Carolina,
South
Carolina
and
Tennessee),
and
Michigan
due
to
significant
pest
pressure
from
weeds
(
specifically,
nutsedge)
or
fungal
pathogens
(
specifically,
Phytophthora)
and/
or
restrictions
on
the
use
of
alternatives
due
to
domestic
regulations.
By
consensus,
the
methyl
bromide
review
group
supported
the
finding
that
potential
yield
losses
associated
with
methyl
bromide
alternatives
lead
to
significant
market
disruption
and
economic
infeasibility
of
alternatives
in
the
areas
with
high
pest
pressure
in
the
Southeastern
states,
and
in
all
of
Michigan
tomato
production
due
to
widespread
disease
potential.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Tomatoes
6a.
Target
Pests
Controlled
with
Methyl
Bromide
In
growing
fresh
market
tomatoes,
weeds
C
especially
nutsedge
C
are
the
most
serious
concern
precipitating
methyl
bromide
use
in
both
transplant
beds
and
in
the
field.
The
critical
use
exemption
nomination
for
the
southeastern
U.
S.
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
the
fresh
market
tomato
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
high
sedge
weed
pest
pressures.
Fungal
diseases
(
such
as
Page
7
Phytophthora
blight)
are
also
of
great
concern
and
are
commonly
more
of
a
problem
than
nutsedge
in
Michigan,
the
second
area
covered
in
this
nomination.
These
pests
are
expected
to
become
serious
problems
for
fresh
market
tomato
production
if
methyl
bromide
were
not
available
for
pre­
plant
fumigation.

In
addition
to
nutsedge,
fresh
market
tomato
producers
in
the
Southeastern
U.
S.
have
to
contend
with
a
variety
of
other
pests,
pests
currently
controlled
using
methyl
bromide.
These
pests
include
weeds
(
nightshades
and
broad
leaf
weeds),
fungal
pathogens
(
Phytophthora,
Pythium,
Verticillium,
Fusarium
spp.,
Rhizoctonia
spp.,
Sclerotium
rolfsii),
and
nematodes
(
root­
knots
caused
by
Meloidogyne
spp.,
Pratylenchus,
Rotylenchus,
Belonolaimus).
Michigan
tomato
producers
rely
on
methyl
bromide
to
control
Phytophthora
capsici,
but
in
so
doing
also
achieve
control
of
wilts
(
Verticillium
spp.,
and
Fusarium
oxysporum
f.
sp.
lycopersicae).
A
discussion
of
these
pests
follows.

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
(
16).
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.
Yellow
nutsedge
is
found
throughout
the
continental
U.
S.
Purple
nutsedge
is
primarily
found
in
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
(
17).

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
(
18).
Each
tuber
is
capable
of
sprouting
several
times
(
19).
Tuber
populations
between
1,000
and
8,700
per/
m2
have
been
reported
for
purple
nutsedge
(
20).
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
(
21).

There
are
very
few
herbicides
that
provide
effective
nutsedge
control
and
the
only
one
registered
for
use
on
tomatoes,
pebulate,
is
no
longer
available
since
the
registration
expired
on
December
31,
2002
and
the
registrant
is
bankrupt.
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
Page
8
solanaceous
crops.
Among
the
areas
covered
by
this
nomination
for
continued
methyl
bromide
use
in
fresh
market
tomatoes,
15
to
60
percent
of
production
areas
are
moderately
to
highly
infested
with
nutsedge,
with
the
majority
falling
in
the
40
to
60
percent
range.

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
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
tomatoes,
and
other
solanaceous
crops.
In
Michigan's
tomato
producing
areas,
Phytophthora
is
the
major
problem
controlled
with
methyl
bromide,
and
this
disease
is
endemic
to
the
entire
tomato
producing
areas
in
Michigan.
Other
fungal
pathogens
(
Verticillium,
Fusarium
spp.,
Rhizoctonia
spp.)
can
also
infect
tomatoes
and
are
controlled
by
methyl
bromide
soil
fumigation.

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
tomato
producing
regions
in
the
U.
S..

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Tomato
growers
rely
on
fumigation
with
methyl
bromide/
chloropicrin
within
the
plastic
mulch
production
system
to
control
soil
borne
diseases
and
pests.
In
the
Southeastern
states,
where
methyl
bromide
is
needed
to
produce
fresh
market
tomatoes,
this
fumigation
system
is
designed
to
allow
effective
sedge
control
in
tomato
production.
In
Michigan,
this
system
is
effective
in
controlling
fungal
diseases
where
other
controls
are
ineffective.
In
both
areas,
methyl
bromide
is
also
effective
in
controlling
nematodes,
other
weeds,
and
diseases
other
than
Phytophthora
blight.

There
has
been
extensive
research
on
alternatives
for
the
tomato
sector,
and
have
been
incorporated
into
production
systems
where
possible.
However,
the
effectiveness
of
chemical
alternatives
in
fully
replacing
methyl
bromide
depends
critically
on
pest
pressure:
under
conditions
of
low
to
moderate
pest
pressure,
methyl
bromide
alternatives
may
be
effective,
but
are
almost
invariably
technically
and
economically
infeasible
when
pest
pressure
is
high.
For
non­
chemical
alternatives,
the
effectiveness
in
controlling
key
pests
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.
Given
the
variability
in
pest
pressure,
and
proportion
of
time
that
pest
pressure
can
be
characterized
as
heavy,
methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
fresh
market
tomato
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.
Page
9
6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Table
1
provides
a
summary
of
technical
and
economic
assessment
of
the
chemical
alternatives
to
methyl
bromide,
as
identified
by
MBTOC
for
fresh
tomatoes.
As
mentioned
above,
the
technical
feasibility
of
some
methyl
bromide
alternatives
depend
on
the
level
of
pest
pressure.
When
pest
pressure
is
low
to
moderate,
some
alternatives
may
be
technically
(
and
economically)
feasible,
but
under
conditions
of
high
pest
pressure,
these
same
alternatives
are
neither
technically
nor
economically
feasible.
The
discussion
below
describes
these
conditions
in
more
detail.

Table
1.
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Tomatoes.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
1,3­
Dichloropropene
(
Telone)
No
NA2
1,3­
Dichloropropene,
Chloropicrin
Yes/
No1
Yes/
No
1,3­
Dichloropropene,
Chloropicrin,
Pebulate
Yes/
No1
Yes/
No
Basamid
Yes/
No1
Yes/
No
Basamid,
Solarization
Yes/
No1
Yes/
No
Chloropicrin
No
NA
Metam
Sodium
Yes/
No1
Yes/
No
Metam
sodium,
Crop
rotation
Yes/
No1
Yes/
No
Methyl
Iodide
Not
registered
in
the
U.
S.
NA
Propargyl
bromide
Not
registered
in
the
U.
S.
NA
1When
nutsedge,
nematode
and/
or
fungal
disease
pressure
is
very
high,
which
occurs
in
40­
60%
of
Southeastern
area,
and
all
of
the
Michigan
area,
these
alternatives
are
not
technically
feasible.
2Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
viability.

1,3­
Dichloropropene
(
Telone):
Telone
is
not
a
technically
feasible
stand­
alone
alternative
to
methyl
bromide
for
the
control
of
nutsedge
and
the
fungal
pathogen
complex
that
affects
tomato
production.
Telone
provides
good
control
of
nematode
populations,
with
some
effect
on
certain
fungal
pathogens,
but
generally
offers
poor
control
of
diseases
and
weeds
(
4,
5,
6).
In
addition,
1,3­
dichloropropene
is
restricted
in
key
tomato
growing
areas
of
the
U.
S.
which
have
hydrogeological
conditions
conducive
to
the
transport
of
chemical
to
groundwater
(
specifically,
soils
underlain
by
karst
topography
and
sandy
sub­
soils
with
short
depth
to
aquifers).
Karst
topography
is
irregular
topography
resulting
from
solutions
of
carbonate
rock
units.
Areas
where
karst
topography
and
certain
surface
features
occur
(
e.
g.,
sinkholes)
are
indicative
of
areas
where
karst
is
near
the
surface
and
where
the
potential
for
groundwater
contamination
is
the
highest.
Approximately
40
percent
of
Florida's
tomato
area
is
in
areas
facing
this
type
of
hydrogeological
constraint.
As
a
consequence,
1,3­
dichloropropene
use
is
prohibited
in
key
growing
areas
like
Dade
County,
Florida
where
1335
hectares
of
tomatoes
are
grown
each
year.
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)
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
tomato
production
area.
Page
10
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,
the
recommended
PPE
for
1,3­
dichloropropene
involves
applicators
wearing
coveralls
over
short
sleeve
shirts
and
shorts,
chemical
resistant
gloves,
footwear
and
socks,
an
apron
and
chemical
resistant
headgear.
Under
conditions
of
extreme
heat
and
humidity
(
which
is
characteristic
of
the
Southeastern
U.
S.
in
the
summer),
wearing
this
ensemble
rapidly
become
unbearable
for
a
typical
applicator,
and
could
cause
heat
exhaustion
or
heat
stroke.

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
the
fresh
market
tomato
crops.
For
example,
tomatoes
produced
during
the
winter
fetch
a
higher
price
than
tomatoes
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.

1,3­
Dichloropropene
and
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
can
be
effective
for
production
areas
where
the
nutsedge
problem
is
minimal
and
there
is
low
disease
pressure
of
fungal
and
nematode
pests.
With
severe
nutsedge
infestations,
yield
losses
can
be
30
to
40
percent
compared
to
methyl
bromide
treatment.
All
constraints
described
above
for
1,3­
dichloropropene
also
apply
to
this
pesticide
combination,
including
soil
limitations,
buffer
constraints,
and
worker
exposure
safeguards
(
PPE).
In
fact,
PPE
recommendations
for
telone
C­
17
are
even
more
stringent
than
for
1,3­
dichloropropene
alone
and
include
a
chemical
resistant
protective
suit
and
a
respirator.
These
issues
were
taken
into
account
in
the
level
of
the
U.
S.
nomination.

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.
Potential
yield
losses
of
6
to
7
percent
were
reported,
compared
to
precision
methods.
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,
but
once
again,
this
depends
on
pest
pressure.

Combinations
of
1,3­
dichloropropene
and
chloropicrin
are
not
effective
in
controlling
Phytophthora
capsici
(
22).

1,3­
Dichloropropene
and
Chloropicrin
and
Pebulate
(
Tillam):
Pebulate
is
not
currently
registered
in
the
U.
S.
and
is
therefore
not
available.
This
combination
is
not
technically
feasible
where
pest
pressure
is
high.
Methyl
bromide
is
significantly
superior
where
severe
nutsedge,
nematode,
or
pathogen
infestations
exist.
When
compared
with
methyl
bromide,
average
yield
losses
of
14
percent
have
been
reported
(
5,
6).
Yield
losses
of
approximately
40
percent
were
experienced
in
some
fields
historically
not
managed
for
high
populations
of
nematodes
and
fungal
pathogens
(
5,6).
Page
11
A
major
concern
with
this
alternative
is
the
phytotoxicity
of
pebulate
in
some
fields
when
used
at
3
kg/
ha,
which
is
the
rate
necessary
for
effective
weed
control.
At
lower
rates
(~
1.5
kg/
ha)
plants
are
not
adversely
affected
but
nutsedge
control
is
significantly
reduced.
In
areas
with
severe
nutsedge
infestations,
this
would
not
be
acceptable
for
nutsedge
management.
Also
of
issue
is
the
label
restriction
of
pebulate
prohibiting
hand
transplant
use.
Over
85
percent
of
transplants
involve
some
hand
transplanting
operations
during
planting
(
USDA
Crop
Profiles
 
Tomatoes,
TN;
http://
pestdata.
ncsu.
edu/
cropprofiles/
docs/
tntomatoes.
html).
Finally,
pebulate,
is
no
longer
available
in
the
U.
S.
since
the
registration
expired
on
December
31,
2002
and
the
registrant
is
bankrupt.

Basamid
(
dazomet):
Basamid
is
not
technically
feasible
where
severe
nutsedge,
nematode,
or
pathogen
infestations
exist.
It
is
inconsistent
in
its
efficacy
against
fungal
pests.
In
addition,
it
has
not
been
reported
to
be
effective
against
yellow
or
purple
nutsedge.
Yield
losses
of
30
to
40
percent
have
been
reported
in
Southeastern
areas
where
nutsedge
infestation
was
heavy
(
4).

Basamid
(
dazomet)
and
Solarization:
This
combination
is
not
technically
feasible
where
severe
nutsedge,
nematode,
or
pathogen
infestations
exist.
It
is
inconsistent
in
its
efficacy
against
fungal
pests.
In
addition,
it
has
not
been
reported
to
be
effective
against
yellow
or
purple
nutsedge.
Yield
losses
of
30
to
40
percent
have
been
reported
in
Southeastern
areas
where
nutsedge
infestation
was
heavy
(
4).
Neither
Basamid
nor
solarization
has
been
effective
in
nematode
or
nutsedge
management
(
2,4).

Chloropicrin:
Chloropicrin
alone
is
not
technically
feasible
because
it
is
not
sufficiently
efficacious
against
nematodes
and
weeds.
Chloropicrin
provides
some
control
of
soilborne
pathogens/
diseases
but
is
less
effective
against
nematodes
and
weeds.
Most
of
the
research
data
are
for
1,
3­
dichloropropene
+
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
technically
feasible
where
severe
nutsedge,
nematode,
or
heavy
fungal
pathogen
infestations
exist.
Metam­
sodium
used
in
combination
with
chloropicrin
and/
or
1,3­
dichloropropene
may
be
effective
where
severe
infestations
of
nutsedge
do
not
exist
(
e.
g.,
in
Michigan).

Metam
sodium
has
been
reported
to
be
inconsistent
in
its
efficacy
against
soil­
borne
pests
(
4).
Metam
sodium
degrades
in
the
soil
to
form
methyl
isothiocyanate,
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.
Page
12
Research
trials
show
that
incorporation
of
metam
sodium
with
a
tractor­
mounted
tillovator
provides
good
results
but
most
growers
do
not
have
this
equipment.
The
results
of
two
efficacy
trials
conducted
in
2000
by
IR­
4
(
Inter­
regional
Initiative
4,
a
USDA
funded
organization
supporting
minor
uses)
showed
control
of
major
pests,
however
there
was
very
low
pest
pressure
at
the
test
sites.

Moreover,
there
are
some
regulatory
restrictions
on
metam
sodium
that
limit
its
use
in
Michigan.
The
metam
sodium
label
recommends
a
minimum
of
21
days
of
waiting
period
after
application
if
soil
temperatures
are
below
15
degrees
Celsius.
Tomato
planting
may
be
delayed
by
14
days
if
metam
sodium
were
used
as
a
soil
fumigant
due
to
Michigan's
cold
climate,
which
may
cause
loss
both
from
lower
yields
(
shorter
growing
season)
and
lower
prices
(
from
missing
key
markets).
Therefore,
in
addition
to
problems
with
the
spectrum
and
magnitude
of
control,
metam
sodium
may
not
be
a
viable
methyl
bromide
alternative
in
Michigan's
cold
weather
conditions
that
last
late
into
the
year.

Metam
Sodium
and
Crop
Rotation:
The
metam
sodium
and
crop
rotation
combination
is
not
a
technically
feasible
alternative
in
high
pest
pressure
areas,
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.
It
is
not
technically
feasible
where
severe
nutsedge,
nematode,
or
heavy
fungal
pathogen
infestations
exist.
Moreover,
intensive
cultivation
(
and
land
prices
determined
by
productivity)
leaves
little
land
for
crop
rotation.

Methyl
Iodide:
It
is
not
registered
for
soil
fumigation
in
the
United
States.

Propargyl
Bromide:
It
is
not
registered
for
soil
fumigation
in
the
United
States.

6d.
Economic
Feasibility
of
In­
Kind
Alternatives
The
economic
analysis
of
the
tomato
application
compared
data
on
yields,
crop/
commodity
prices,
revenues
and
costs
using
methyl
bromide
and
using
alternative
pest
control
regimens
in
order
to
estimate
the
loss
of
methyl
bromide
availability.
The
alternatives
identified
as
technically
feasible
­
in
cases
of
low
pest
infestation
­
by
the
U.
S.
are:
(
a)
1,3­
Dichloropropene
and
Chloropicrin
and
Pebulate;
(
b)
1,3­
Dichloropropene
and
Chloropicrin;
(
c)
Basamid;
(
d)
Basamid
and
Solarization;
(
e)
Metam
sodium;
and
(
f)
Metam
sodium
and
crop
rotation.
Pest
control
costs
for
tomatoes
are
less
than
4
percent
of
total
variable
costs
and
therefore
changes
in
pest
control
costs
would
have
little
impact
on
any
of
the
economic
measures
used
in
the
analysis.
The
economic
factor
that
really
drives
the
feasibility
analysis
is
yield
loss
associated
with
the
alternatives,
and
in
some
cases,
loss
due
to
missed
market
windows
(
lost
price
premiums).

The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide,
such
as
for
fresh
market
tomatoes,
includes
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.
Page
13
The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

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

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

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

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

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

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
tomato
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.

1,3­
Dichloropropene
with
Chloropicrin
and
Pebulate
The
results
of
the
economic
evaluation
of
the
1,3­
Dichloropropene/
Chloropicrin/
Pebulate
combination
(
which
assumes
that
pebulate
is
available
even
though
the
registrant
has
gone
bankrupt
and
the
U.
S.
registration
has
expired),
relative
to
methyl
bromide,
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
estimated
to
be
25
percent
in
Michigan,
primarily
due
to
losses
from
failure
to
control
Phytophthora.
In
Southeastern
states,
yield
losses
are
estimated
to
range
from
5
to
15
percent.
Areas
with
high
pest
pressure
would
suffer
yield
losses
higher
than
10
percent,
and
high
pest
pressure
is
expected
on
50
to
60
percent
of
tomato
growing
area
in
this
region.

Economic
losses
(
per
hectare)
are
calculated
by
adding
the
expected
loss
in
yield/
revenue
to
the
increase
in
production
costs.
As
mentioned
earlier,
yield
losses
are
expected
to
dominate
economic
Page
14
losses,
with
some
decline
in
revenue
coming
from
missing
price
premiums
in
key
markets
due
to
delayed
planting
(
i.
e.,
these
estimates
somewhat
understate
impacts
compared
to
including
increases
in
chemical
costs,
but
the
conclusions
are
the
same).
These
effects
are
expressed
as
economic
loss
per
hectare
in
the
second
row
of
Table
2.
Under
conditions
of
high
pest
pressure,
significant
yield
loss
would
result
in
substantial
economic
losses
to
fresh
tomato
growers.
In
areas
with
high
pest
pressure
in
Southeastern
states,
economic
loss
was
estimated
up
to
$
6,721
USD
per
hectare.
Moreover,
this
alternative
might
not
be
technically
feasible
in
some
Southeastern
states
because
of
the
label
restriction
of
pebulate
prohibiting
hand
transplant
use,
and
over
85
percent
of
transplants
actually
involve
some
hand
transplanting
operations
during
planting.
Putting
aside
the
worker
protection
issue,
if
pest
pressure
were
low,
the
use
of
1,3­
dichloropropene,
chloropicrin,
pebulate
would
result
in
economic
losses
closer
to
$
950
USD
per
hectare.
In
Michigan,
economic
losses
would
be
more
than
$
10,000
USD
per
hectare
in
areas
with
heavy
pest
pressure,
based
on
assuming
25
percent
yield
losses.

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,
tomato
production
in
Michigan
suffers
high
efficiency
losses
compared
to
the
Southeast
region,
but
it
is
important
to
note
that
in
both
cases,
losses
are
greater
than
zero,
suggesting
efficiency
losses
in
both
tomato
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/
Pebulate
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
render
this
alternative
economically
infeasible
for
U.
S.
fresh
market
tomato
producers.

Table
2.
Measures
of
Economic
Impact
on
Fresh
Market
Tomatoes
in
the
U.
S.
Loss
Measure
Michigan1
Southeast
Direct
Yield
Loss
20
­
30%
5
­
15%
Economic
Loss
Per
Hectare
$
10,550
$
950
 
$
6,721
likely
$
2,230
Economic
Loss
Per
Kilogram
methyl
bromide
$
97
$
11.10
 
$
30.55
likely
$
13.70
Economic
Loss
as
%
of
Gross
Revenue
31%
7
­
16%
likely
9%
Economic
Loss
as
%
of
Net
Cash
Returns
160%
87
­
112%
likely
109%
1The
economic
measures
were
calculated
for
the
projected
yield
loss
of
25%.
Analysis
for
Michigan
is
based
on
using
1,3­
D
and
Chloropicrin
as
the
methyl
bromide
alternative
treatment.
Analysis
for
the
Southeast
region
is
based
on
using
1,3­
D,
chloropicrin,
and
pebulate
as
the
methyl
bromide
alternative.

1,3­
Dichloropropene
with
Chloropicrin
Page
15
Potential
economic
losses
to
fresh­
market
tomato
growers
in
Michigan
would
be
significant
because
estimated
yield
losses
would
be
20
to
30
percent
for
the
1,3­
Dichloropropene/
Chloropicrin
combination.
Michigan
does
not
have
a
nutsedge
infestation
problem,
and
use
of
Pebulate
is
not
necessary,
but
the
losses
from
Phytophthora
would
be
similar
to
the
scenario
presented
in
Table
2.
Price
would
also
be
lower
due
to
missed
early
season
premiums
and
reduced
quality
of
the
products.
Since
the
estimated
yield
impacts
are
so
large,
this
alternative
is
not
considered
economically
feasible.

As
an
alternative
treatment
in
the
Southeast
region,
1,3­
Dichloropropene/
Chloropicrin
might
be
feasible
for
a
limited
time
in
areas
with
low
nutsedge
pressure,
providing
an
alternative
herbicide
is
available
(
see
earlier
discussion).
However,
this
nomination
includes
the
portion
of
tomato
production
in
the
Southeast
region
where
nutsedge
pressure
is
high.
In
such
cases,
1,3­
Dichloropropene/
Chloropicrin
is
not
a
technically
feasible
alternative
and
is,
therefore,
not
included
in
this
economic
analysis.

Other
Alternatives
(
Basamid;
Basamid
with
Solarization;
Metam
Sodium;
Metam
Sodium
with
Crop
Rotation)

Data
show
that
these
different
alternatives
showed
the
same
(
or
greater)
yield
losses
as
1,3­
Dichloropropene/
Chloropicrin/
Pebulate
for
the
production
regions
of
interest.
Once
again,
yield
losses
play
the
major
role
in
determining
the
size
of
economic
loss
for
tomatoes
growers,
and
these
technically
feasible
alternatives
would
have
the
same
(
or
greater)
economic
losses
as
the
use
of
1,3­
Dichloropropene/
Chloropicrin/
Pebulate.

What
is
the
best
alternative
regimen
to
methyl
bromide?

Where
regulations
permit,
a
combination
of
1,3­
Dichloropropene/
Chloropicrin/
Pebulate
(
assuming
that
pebulate
once
again
becomes
available
in
the
U.
S.)
may
be
the
best
alternative
to
methyl
bromide
for
fungal,
nematode
and
nutsedge
pest
control;
however,
inconsistency
in
the
level
of
pest
control
still
may
exist
(
4).
Among
the
other
alternatives,
Telone
C­
35
(
1,3­
dichloropropene
with
35
percent
chloropicrin),
metam­
sodium,
methyl
iodide
(
currently
not
registered
in
the
U.
S.),
and
chloropicrin
may
be
potential
alternatives,
but
weed
(
nutsedge)
control
remains
problematic.
Pebulate
(
Tillam),
an
herbicide
labeled
for
tomatoes
(
but
apparently
no
longer
being
produced
in
the
U.
S.
as
of
this
report
date),
has
shown
some
success
in
managing
low
and
moderate
infestations
of
nutsedge.
When
pebulate
is
used
in
combination
with
1,3­
dichloropropene
and
chloropicrin,
it
can
be
effective
against
Verticillium
wilt
and
nematodes.
Crucially,
however,
it
is
not
labeled
for
hand
transplant,
which
is
the
common
method
of
planting
fresh
market
tomatoes
in
the
Southeastern
region
of
the
U.
S..
Moreover,
pebulate
has
been
implicated
as
phytotoxic
when
used
at
rates
compatible
with
effective
weed
control.
Nutsedge
does
not
appear
to
be
a
problem
in
Michigan
tomato
fields,
but
Phytophthora
can
be
a
major
problem.
Michigan's
cold
climate
seems
to
be
unfavorable
for
metam
sodium
use
in
a
timely
manner,
due
to
planting
delays
after
fumigation.
This
precludes
capturing
key
early
markets
for
tomatoes.

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
Page
16
MBTOC
for
tomatoes,
primarily
non­
chemical
alternatives.
Table
3
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.
No
economic
assessment
for
these
alternatives
was
conducted
because
of
their
technical
infeasibility.

Table
3.
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Tomato.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility1
Biofumigation
No
NA
Solarization
No
NA
Solarization,
fungicides
No
NA
Steam
No
NA
Biological
Control
No
NA
Cover
Crops
and
mulching
No
NA
Crop
Residue
Compost
No
NA
Crop
Rotation/
Fallow
No
NA
Flooding
and
Water
management
No
NA
General
IPM
No
NA
Grafting/
Resistant
Root
Stock/
Plant
Breeding
No
NA
Organic
Amendments/
Compost
No
NA
Planting
Time
No
NA
Ploughing
and
Tillage
No
NA
Resistant
Cultivars
No
NA
Soil­
less
Culture
No
NA
Substrate/
Plug
Plants
No
NA
1Alternatives
not
found
technically
feasible
were
not
assessed
for
economic
viability.

Biofumigation.
Biofumigation
is
not
technically
feasible
in
the
United
States
because
of
the
large
amount
of
brassica
required
to
alter
fumigation
practices
in
the
large
tomato
production
area
in
the
U.
S..
The
efficacy
of
biofumigation
at
large
has
not
been
extensively
tested
for
tomato
production.
Four
studies
were
conducted
with
cabbage
residue
as
a
biofumigant
for
tomato
production
but
these
studies
did
not
result
in
comparable
yields
to
methyl
bromide.
It
is
almost
impossible
to
conduct
biofumigation
across
a
large
scale
to
obtain
commercially
acceptable
pest
control
because
of
the
delays
in
planting
times
biofumigation
would
cause
and
due
to
the
additional
costs
growers
would
face.

Solarization
is
not
technically
feasible
in
the
U.
S.
The
tomato
growers
would
generally
not
be
able
to
take
advantage
of
the
best
timing
for
solarization,
since
tomatoes
are
produced
from
April
until
October.
Cooler
months
when
plants
are
not
in
the
ground
would
not
provide
the
necessary
solar
heat
requirements.
In
Florida,
where
solarization
may
be
more
effective
than
other
areas,
researchers
Page
17
have
found
that
solarization
resulted
in
significantly
more
weeds,
fewer
tomato
fruit,
and
more
root
knot
nematodes
(
2).

Solarization
and
Fungicides
is
not
technically
feasible
in
the
U.
S.
(
see
Alternative
12).
Fungicides
do
not
control
weed
or
nematode
pests.

Steam
is
not
technically
feasible
to
sterilize
tomato
fields
for
control
of
fungal,
nematode
and
weed
pests
at
commercial
scale
in
open
field
production.
Steam
sterilization
does
not
typically
penetrate
deep
enough
into
the
associated
soil
to
address
target
pests
associated
with
tomato
production.
The
only
available
prototypes
have
very
limited
range
and
speed
and
can
only
sterilize
approximately
half
to
one
hectare
(
one
to
2
acres)
a
day.
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).

Biological
Control
is
not
technically
feasible
because
it
is
not
a
stand
alone
replacement
to
methyl
bromide.
The
USDA's
Agricultural
Research
Service
(
ARS)
conducted
a
multi­
year
study
of
nonpathogenic
fusarium
to
control
fusarium
wilt.
Although
the
study
showed
promising
results,
it
requires
further
examination
to
determine
the
frequency
and
consequences
if
the
biological
control
organism
mutates.

Cover
Crops
and
Mulching:
Presently,
plastic
mulch
is
largely
used
in
tomato
production
under
field
conditions
and
it
does
not
prevent
pathogenic
fungal
infestations,
nematodes
and/
or
weeds.

Crop
Residue
Compost:
There
is
no
research
showing
that
this
will
significantly
affect
nutsedge
or
other
pests
of
concern
in
plastic
culture
of
tomatoes.

Crop
Rotation/
Fallow
is
not
feasible
technically
and/
or
economically
at
field
level
because
it
does
not
control
nutsedge,
nematode,
and
diseases.

Flooding
and
Water
Management
is
not
feasible
technically
and/
or
economically
in
field
production
because
it
does
not
control
nutsedge,
nematode,
and
diseases
when
pest
pressure
is
high.
One
researcher
in
Florida
reported
that
there
was
no
significant
difference
between
flooded
and
nonflooded
treatments
concerning
marketable
yields,
numbers
of
nutsedge,
nematode
galls,
or
root
rots
in
tomato.

General
IPM
is
not
technically
feasible
by
itself.
IPM
does
not
reliably
deliver
adequate
crop
protection
under
condition
of
high
pest
pressure,
especially
for
weeds.
It
is
not
feasible
technically
and/
or
economically
at
the
field
level
because
it
does
not
control
nutsedge,
nematode,
and
diseases
when
pest
pressure
is
high.

Grafting;
resistant
rootstock;
plant
breeding:
Disease,
nematode,
and
heat­
resistant
cultivars
are
common
in
the
industry,
as
well
as
cultivars
for
quality
characteristics.
These
do
not
address
weed
issues
and
genetic
resistance
is
never
complete
against
diseases
and
pests.
Plant
breeding
has
always
been
an
integral
part
of
tomato
production.
Page
18
Organic
Amendments/
Compost:
As
a
part
of
standard
IPM,
amendments
are
frequently
used
to
improve
soil
fertility
to
boost
yields,
however,
it
is
not
a
stand
alone
replacement
to
methyl
bromide.
In
addition,
this
practice
does
not
address
severe
nutsedge
infestations
in
production
fields.

Planting
Time:
Planting
time
is
determined
by
market
requirements
and
will
not
address
pest
issues.

Ploughing
and
Tillage:
It
is
not
technically
feasible
because
it
does
not
control
diseases,
nematodes,
or
nutsedge
weeds.

Resistant
Cultivars:
There
are
currently
no
tomato
cultivars
with
host­
plant
resistance
to
all
fungal
and/
or
nematodes
pests.
It
may
be
possible
to
produce
a
new
tomato
cultivar
with
resistance
to
a
few
specific
pests.
The
National
Center
for
Food
and
Agricultural
Policy
(
Washington,
DC)
recently
estimated
that
100
percent
of
Florida's
tomato
production
already
employs
fusarium
and/
or
verticillium
wilt
resistant
cultivars.
Much
research
was
conducted
on
the
Mi
gene
to
create
a
nematode
resistant
tomato
variety.
Unfortunately,
the
variety
failed
as
a
result
of
heat
instability
or
apparent
temperature
sensitivity
of
the
gene
rendering
it
infeasible
for
certain
climates
or
seasonal
plantings.

Soil­
less
Culture
is
technically
infeasible
as
a
means
to
grow
the
bulk
of
the
U.
S.
national
supply
of
tomatoes,
due
to
the
volume
of
production,
despite
the
fact
some
farms
that
have
moved
their
production
indoors.
In
addition,
the
cost
of
soil­
less
culture
is
very
high
and
requires
an
initial
capital
investment
for
the
physical
structure
to
build
greenhouses,
benches,
irrigation
systems,
etc
and
the
development
of
new
tomato
varieties
suitable
for
production
in
all
parts
of
the
U.
S.
Moreover,
there
are
some
risks
associated
with
soil­
less
culture.
A
fungal
infection,
for
example,
can
spread
quickly
through
the
growing
medium
in
a
greenhouse
from
one
plant
to
many
others
with
days.

Substrate/
Plug
Plants:
Fungal,
nematode
and
weed
infestations
are
field
problems
not
addressed
by
substrate/
plug
methodology.

7.
Critical
Use
Exemption
Nomination
for
Tomatoes.

As
noted
above,
this
nomination
is
for
a
critical
use
exemption
for
methyl
bromide
for
fresh
market
tomato
production
in
Michigan
and
a
collection
of
states
in
the
Southeastern
region
of
the
U.
S..
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
tomato
growers
in
Michigan
and
the
Southeastern
states
in
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
tomato
pests
under
high
pest
pressure
situations.
Because
such
pest
pressure
conditions
are
known
to
be
endemic
on
a
significant
proportion
of
tomato
production
area
in
Michigan
and
the
Southeastern
U.
S.,
these
areas
form
the
basis
for
the
nomination.

Table
4
and
5
summarize
methyl
bromide
historical
usage,
including
area
treated,
and
the
actual
amount
requested
for
2005
thru
2007
for
tomato.

Table
4.
Methyl
Bromide
Usage
and
Request
for
Tomatoes
in
Southeastern
States.
Page
19
1997
1998
1999
2000
2001
2005
2006
2007
tonne
3,704
4,005
3,574
3,360
5,076
5,045
5,045
5,045
hectares*
16,780
18,410
18,980
19,410
31,490
32,080
32,160
32,240
rate
(
kg/
ha)
230
230
200
180
175
160
160
160
*
The
information
used
to
determine
tomato
production
area
changed
in
2001
in
Florida
based
on
methods
for
counting
specialty
varieties
of
tomatoes.

Table
5.
Methyl
Bromide
Usage
and
Request
for
Tomatoes
in
Michigan.

1997
1998
1999
2000
2001
2005
2006
2007
tonne
51
49
49
34
34
34
34
34
hectares
427
410
410
284
284
284
284
284
rate
(
kg/
ha)
120
120
120
120
120
120
120
120
The
use
rate
is
lower
than
elsewhere
is
the
U.
S.
due
to
differences
in
pest
pressure
that
are
controlled
with
a
lower
concentration
of
methyl
bromide.
The
total
area
requested
for
Michigan
equal
only
3%
of
all
solanaceous
hectares
in
the
state
which
are
the
acres
with
Phytophthora
capsici
infestations.

The
hectares
and
tonnes
associated
with
Michigan's
historic
use
on
tomatoes
also
include
some
hectares
of
pepper
and
eggplant
crops
because
Michigan
substituted
pepper
and
eggplant
on
small
amounts
of
tomato
production
land
to
respond
to
local
conditions
and
market
demands.
For
the
purposes
of
the
nomination,
only
the
tomato
portion
of
this
cropping
system
is
included
(
284
hectares).

It
is
also
important
to
note
that
critical
use
exemption
requests
for
fresh
market
tomatoes
were
submitted
by
tomato
growers
association,
growers
or
tomato
commission
in
Southeast
regions
of
the
U.
S.,
and
Michigan.
There
is
a
tremendous
amount
of
variation
in
the
use
of
chemicals
across
these
agricultural
systems,
and
this
variation
is
the
result
of
heterogeneous
market
conditions
for
a
commodity,
hectares
planted,
weather
events,
financial
position
of
the
industry,
pest
pressures
etc.
Because
of
the
variation
due
to
biologic,
climatic,
and
economic
conditions,
it
is
difficult
to
predict
the
precise
amount
of
methyl
bromide
that
may
be
necessary
for
a
specific
use
(
see
discussion
below
under
section
9).

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

Table
6.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Tomatoes.

Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)

2005
5,233,521
2,865,262
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
Page
21
Protocol.
This
accelerated
phasedown
on
the
consumption
side
may
also
have
enabled
methyl
bromide
production
to
be
stockpiled
to
some
extent
to
help
mitigate
the
potentially
significant
impacts
associated
with
the
Protocol's
2003
and
2004
70%
reduction.
We
are
currently
uncertain
as
to
the
exact
quantity
of
existing
stocks
going
into
the
2003
season
that
may
be
stockpiled
in
the
U.
S.
We
currently
believe
that
the
limited
existing
stocks
are
likely
to
be
depleted
during
2003
and
2004.
This
factor
is
reflected
in
our
requests
for
2005
and
beyond.

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

9.
U.
S.
Efforts
to
Find,
Register
and
Commercialize
Alternatives
to
Methyl
Bromide
Over
the
past
ten
years,
the
United
States
has
committed
significant
financial
and
technical
resources
to
the
goal
of
seeking
alternatives
to
methyl
bromide
that
are
technically
and
economically
feasible
to
provide
pest
protection
for
a
wide
variety
of
crops,
soils,
and
pests,
while
also
being
acceptable
in
terms
of
human
health
and
environmental
impacts.
The
U.
S.
pesticide
registration
program
has
established
a
rigorous
process
to
ensure
that
pesticides
registered
for
use
in
the
United
States
do
no
present
an
unreasonable
risk
of
health
or
environmental
harm.
Within
the
program,
we
have
given
the
highest
priority
to
rapidly
reviewing
methyl
bromide
alternatives,
while
maintaining
our
high
domestic
standard
of
environmental
protection.
A
number
of
alternatives
have
already
been
registered
for
use,
and
several
additional
promising
alternatives
are
under
review
at
this
time.
Our
research
efforts
to
find
new
alternatives
to
methyl
bromide
and
move
them
quickly
toward
registration
and
commercialization
have
allowed
us
to
make
great
progress
over
the
last
decade
in
phasing
out
many
uses
of
methyl
bromide.
However,
these
efforts
have
not
provided
effective
alternatives
for
all
crops,
soil
types
and
pest
pressures,
and
we
have
accordingly
submitted
a
critical
use
nomination
to
address
these
limited
additional
needs.

Research
Program
When
the
United
Nations,
in
1992,
identified
methyl
bromide
as
a
chemical
that
contributes
to
the
depletion
of
the
ozone
layer
and
the
Clean
Air
Act
committed
the
U.
S.
to
phase
out
the
use
of
methyl
bromide,
the
USDA
initiated
a
research
program
to
find
viable
alternatives.
Finding
alternatives
for
agricultural
uses
is
extremely
complicated
compared
to
replacements
for
other,
industrially
used
ozone
depleting
substances
because
many
factors
affect
the
efficacy
such
as:
crop,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
even
among
localities
within
a
region.

Through
2002,
the
USDA
Agricultural
Research
Service
(
ARS)
alone
has
spent
US$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
(
see
table
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
Page
22
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.

In
addition
to
federally
supported
research,
applicants
for
methyl
bromide
critical
use
exemptions
have
reported
that
they
have
expended
in
excess
of
$
17
million
USD
conducting
their
own
research
into
the
use
of
alternatives
to
methyl
bromide
since
the
announcement
of
the
phaseout
in
1992.

Table
7.
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Expenditures
by
the
U.
S.
Department
of
Agriculture
(
US$
Million)

1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
Major
areas
of
research
have
included
preplant
soil
applications
and
post­
harvest
commodity
storage
over
a
wide
range
of
commodities,
including
but
not
limited
to
tomatoes,
strawberries,
eggplants,
melons
and
other
cucurbits,
sweet
potato,
citrus,
dried
fruits
and
nuts,
grain,
stone
fruits,
fresh
fruits
Page
23
and
vegetables,
forestry
seedlings,
raspberries,
ornamental
and
nursery
crops,
vineyard
crops,
and
turfgrasses.
While
much
research
has
been
targeted
for
support
of
crops
such
as
tomatoes
and
strawberries,
the
primary
users
of
methyl
bromide
in
the
U.
S.,
most
of
the
pre­
plant
soil
applied
alternatives
work
has
had
implications
for
disease
and
nematode
control
across
many
other
crops.
Logical
groupings
for
such
transfer
of
research
information
include
annual
fruit
and
vegetable
crops
(
e.
g.
solanaceous
crops,
strawberries,
and
melons),
perennial
tree
and
vine
crops
(
e.
g.
citrus,
grapes,
avocado,
stone
fruits,
almonds,
walnut,
and
raspberry),
and
stored
commodities
(
e.
g.
walnuts,
dried
fruits,
grains,
and
processed
foods).
Research
objectives
for
ongoing
and
proposed
research
by
Federal
and
private
sources
to
determine
the
potential
efficacy
of
methyl
bromide
alternatives
and
their
implementation
in
commercial
agricultural
and
food
processing
operations
are
described
below.

The
USDA
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
USDA
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

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

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

a.
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
rhizobacteria
(
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
percent
peat,
30
percent
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
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
Page
24
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.

b.
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.

c.
Potential
Uses
of
Mi
Gene
Resistance
As
a
Component
of
Integrated
Nematode
Management
in
Tomato
(
Sep
2001
­
Aug
2002)
Determine
the
host
status
of
Mi
gene
resistant
tomatoes
to
15
field
populations
of
Meloidogyne
spp.;
determine
if
first
crop
chemical
rates
can
be
reduced
when
using
this
resistance;
observe
the
effects
of
Mi
gene
resistance
from
a
first
crop
on
root­
knot
nematode
population
densities
and
damage
in
a
second
crop;
determine
utility
of
the
resistance
and
yield
potential
of
resistant
varieties
under
large­
scale
grower
conditions.
Greenhouse
trials
will
be
performed
on
fifteen
field
populations
of
root­
knot
nematodes
to
determine
presence
of
Mi
gene
resistance­
breaking
biotypes.
A
small
plot
tomato
field
trial
will
be
conducted
in
the
spring
followed
by
a
fall
cantaloupe
crop
at
the
same
site.
The
spring
trial
will
consist
of
the
following
chemical
treatments
as
main
plots­
control:
methyl
bromide
(
67­
33
350
lbs./
A),
Telone
II
(
18
gals./
A),
Telone
II
(
24
gals./
A),
Telone
C­
17
(
35
gals./
A),
Telone
C­
35
(
35
gals./
A)
and
an
untreated
control.
Main
plots
will
consist
of
chemical
treatments
and
sub­
plots
shall
include
resistant
and
susceptible
tomato
varieties.
The
trial
will
be
followed
by
a
fall
cantaloupe
crop
without
further
treatment.
Data
collection
in
both
the
spring
and
fall
crops
will
include
fruit
weight,
number,
grade,
root
galling
and
plant
vigor
ratings.

d.
Efficacy
of
Cultural
Practices,
Organic
Amendments
&
Fumigants
on
Tomato
Production,
Soil
Thermal
Properties
&
Soil
Water
(
Sep
2001
­
Aug
2003)
The
objective
of
this
study
is
to
develop
a
cropping
system
that
combines
the
beneficial
effects
of
several
systems
in
a
replicated
design
demonstrated
in
a
grower's
field
for
tomato
production
and
compare
it
to
methyl
bromide
system.
Fourteen
treatments
will
be
evaluated
in
a
grower's
field
for
their
effectiveness
on
plant
growth,
production
and
conservation
of
water.
Treatments
will
include
fallow,
Sunn
hemp
'
Tropic
Sun',
co­
compost,
solarization,
K­
pam,
chloropicrin,
and
methyl
bromide.

e.
Field
Demo
and
Scale­
Up
of
Soilless
Culture
As
An
Alternative
to
Soil/
Methyl
Bromide
for
Tomato
and
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
Page
25
will
be
monitored
and
compared
to
conventional
crop
production
practices.

f.
Field
Evaluation
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
off­
season
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.

g.
Biological
Control
of
Fusarium
Wilt
and
Other
Soilborne
Plant
Pathogenic
Fungi
(
Nov
2002
­
Nov
2007)
Assess
the
potential
of
microbes
to
control
soil­
borne
plant
pathogenic
fungi
and
determine
biological,
environmental
and
ecological
factors
affecting
performance
of
these
microbes.
Characterize
biological,
ecological
and
genetic
relationships
among
and
within
pathogenic,
saprophytic
and
biocontrol
soil­
borne
microorganisms.
Elucidate
mechanisms
of
action
of
biocontrol
agents
used
against
soil­
borne
plant
pathogens,
and,
where
previous
work
identified
a
general
mechanism
of
action,
identify
the
specific
underlying
basis
of
the
mechanism.
Work
will
include,
but
is
not
limited
to,
the
nature
of
resistance
to
Fusarium
wilt
in
tomato
induced
by
Fusarium
oxysporum
strain
CS­
20.

h.
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.

In
addition
to
the
research
that
is
ongoing
under
the
USDA,
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:

Michigan
Solanaceous
Crops
Consortium
(
including
Tomatoes):
In
2003
and
2004,
university
researchers
will
trial
the
following
alternatives
on
test
plots
owned
by
commercial
growers:
Telone
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.
These
trials
will
analyze
the
ability
of
these
alternatives
to
Page
26
control
Verticillium,
Fusarium
and
Phytophthora.

Southeastern
U.
S.
Tomatoes
Consortium:
A
study
on
fumigation
alternatives
will
be
conducted
on
the
Eastern
Shore
of
Virginia.
Treatments
will
include
Telone
C­
35
with
herbicide;
Telone
II
with
chloropicrin
and/
or
herbicide;
and
Vapam
with
chloropicrin,
with
or
without
herbicide.
This
study
will
measure
crop
yield.
A
study
entitled,
Methyl
Bromide
Alternatives
for
Tomato,
Pepper
and
Cucurbit
Crops,
conducted
by
David
Monks
and
Frank
Louis
will
be
conducted
in
North
Carolina.
Herbicides
such
as
metolachlor,
halosulfuron,
rimsulfuron,
and
dimehenamid
will
be
tested
in
combination
with
certain
fumigants.
Yield
will
be
measured.
A
study
entitled
"
Combinations
of
fumigants
and
herbicide
replacements
for
methyl
bromide"
will
be
conducted
in
2003­
2004
for
watermelon,
pepper
and
tomato
crops
by
A.
S.
Culpepper,
D.
B.
Langston,
Jr.,
W.
T.
Kelley
and
G.
Fonash.
Treatments
will
include
chloropicrin;
1,3­
D;
halosulfuron;
metam
sodium;
metam
potassium;
sulfentrazone
and
combinations
of
the
above.
This
study
will
measure
yield.

In
addition,
a
summary
table
that
captures
the
results
of
alternative
trials
is
shown
below
(
Table
5).
This
table
summarizes
the
results
of
studies
with
quantitative
yield
data
presented
at
the
Methyl
Bromide
Alternatives
Conferences,
The
National
Center
for
Food
and
Agricultural
Policy
(
NCFAP)
"
The
Economic
Impact
of
the
Scheduled
Phaseout
of
Methyl
Bromide,"
2000
and
the
applications
for
Critical
Use
Exemptions.

As
the
table
aptly
summarizes,
even
among
studies
that
demonstrate
significant
yields
using
the
alternatives,
there
is
still
variation
in
the
performance
of
the
alternative.
Thus,
while
it
may
perform
well
in
one
study,
it
may
also
perform
below
acceptable
standards
in
another
study.
It
is
true
that
some
of
the
older
studies
may
skew
this
result,
but
nonetheless,
the
result
still
shows
inconsistency
to
some
degree
even
with
the
tremendous
strides
made
to
date
in
optimizing
application
and
use
of
the
alternatives.
The
standard
used
to
characterize
success
in
the
analysis
presented
here
is
if
the
alternative
produced
crops
with
at
least
95
percent
of
the
yield
of
the
crop
with
a
methyl
bromide
control.
However,
in
some
instances,
even
a
95
percent
yield
may
involve
some
profit
losses.
Page
27
Table
8:
Summary
of
Research
Results
for
U.
S.
Tomatoes
Alternatives
Total
Number
of
Studies
Number
of
Studies
with
Yield
Greater
than
95%
Compared
to
Methyl
Bromide
Basamid
(
Dazomet)
and
combinations
41
11
Cabbage
Residue
4
2
Chloropicrin
and
combinations
45
15
Compost
and
combinations
3
0
Metam
sodium
(
Vapam)
combinations
132
25
Solarization
13
4
1,3­
dichloropropene
(
1,3­
D)
and
combinations
128
47
Tetrathiocarbonate
5
0
XRM
5053
1
0
As
demonstrated
by
the
table
above,
U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
substantial,
and
they
have
been
growing
in
size
as
the
phaseout
has
approached.
The
United
States
is
committed
to
sustaining
these
research
efforts
in
the
future
to
continue
to
aggressively
search
for
technically
and
economically
feasible
alternatives
to
methyl
bromide.
We
are
also
committed
to
continuing
to
share
our
research,
and
enable
a
global
sharing
of
experience.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

Registration
Program
The
United
States
has
one
of
the
most
rigorous
programs
in
the
world
for
safeguarding
human
health
and
the
environment
from
the
risks
posed
by
pesticides.
While
we
are
proud
of
our
efforts
in
this
regard,
related
safeguards
do
not
come
without
a
cost
in
terms
of
both
money
and
time.
Because
the
registration
process
is
so
rigorous,
it
can
take
a
new
pesticide
several
years
(
3­
5)
to
get
registered
by
EPA.
It
also
takes
a
large
number
of
years
to
perform,
draft
results
and
deliver
the
large
number
of
health
and
safety
studies
that
are
required
for
registration.
Page
28
The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
U.
S.
EPA
registers
pesticides
provided
its
use
does
not
pose
unreasonable
adverse
effects
to
humans
or
the
environment.
Under
FFDCA,
the
U.
S.
EPA
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

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

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
for
all
types
of
pesticides
pending
in
its
review
than
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
high
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.
A
methyl
bromide
alternative
is
still
likely
to
go
through
the
average
processing
time.
Once
review
process
begins,
it
takes
an
average
processing
time
of
38
months
from
date
of
submission
to
issuance
of
a
registration
decision.
Even
for
methyl
bromide
alternatives,
the
registrant
(
the
pesticide
applicant)
has,
in
most
cases,
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.
Page
29
This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
groundwater
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
$
13.5
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
submitted
to
the
USDA's
Cooperative
State
Research,
Education,
and
Extension
Service
methyl
bromide
alternatives
research
program
of
US$
2.5
million
per
year
has
further
ensured
that
critical
registration
issues
are
being
addressed
by
the
research
community.

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

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

 
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.
Those
alternatives
must
be
tested
by
users
and
must
be
technically
and
economically
feasible
before
wide­
spread
adoptions.
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
for
speedy
adoption,
the
United
States
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
Page
30
transfer,
and
private
sector
training.

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

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
for
the
use
of
methyl
bromide
for
fresh
market
tomato
production
in
Michigan
and
the
southeastern
U.
S.
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
TEAP
listed
potential
alternatives
for
tomatoes
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
United
States
tomato
growers
covered
by
this
nomination.
Specifically,
we
have
determined
that
a
switch
from
methyl
bromide
to
an
alternative
fumigant
will
impact
Michigan
and
southeastern
U.
S.
fresh
market
tomato
production
largely
due
to
yield
losses
associated
with
inadequate
control
of
pests
in
areas
of
high
pest
pressures.
These
applicants
have
generally
made
a
strong
case
that
the
alternatives
reduce
yield
significantly
and
the
resulting
financial
and
economic
impacts
are
large
enough
to
affect
the
profitability
and
competitiveness
of
Michigan
and
southeastern
U.
S.
fresh
tomato
production.

In
Michigan,
the
U.
S.
has
made
a
strong
case
that
the
alternatives
may
not
be
consistent
in
controlling
soil­
borne
pests,
particularly
Phytophthora
capsici,
when
pest
pressures
are
high
and
soiltemperatures
are
low
at
preplant
fumigation
time.
Accordingly,
areas
in
Michigan
that
meet
these
criteria
are
included
in
this
nomination.
It
is
worth
noting
that
this
happens
to
be
a
small
percentage
of
the
total
solanaceous
growing
area
in
Michigan.

In
the
southeastern
U.
S.,
the
U.
S.
has
made
a
strong
case
that
there
is
a
critical
need
for
the
use
of
methyl
bromide
in
areas
where
alternatives
are
not
sufficient
to
allow
production
of
acceptable
yields
of
marketable
tomatoes.
Methyl
bromide
is
a
necessary
component
for
proper
pest
management
and
for
acceptable
production
needs
when
pest
infestations,
particularly
nutsedge
pressures,
are
severe.
However,
economic
measures
showed
that
fresh­
tomato
growers
in
areas
of
the
southeastern
U.
S.
without
high
pest
pressure
are
not
likely
to
suffer
heavy
losses
because
yield
losses
associated
with
methyl
bromide
alternatives
are
moderate
when
pest
pressures
are
low
to
moderate.

In
addition
to
finding
alternatives
infeasible,
we
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
Page
31
use
of
methyl
bromide
in
tomatoes
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
unreasonable
adverse
effects
to
human
health
and
the
environment,
is
a
long
and
rigorous
process.
The
U.
S.
need
for
methyl
bromide
for
tomatoes
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.

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.
Page
32
Chart
2
in
Appendix
D
demonstrates
several
things.
First,
despite
the
best
efforts
of
many
countries
to
predict
future
conditions,
it
shows
that
due
to
the
acknowledged
uncertainty
of
out­
year
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
made
two
to
three
years
in
advance
of
the
time
of
actual
use.

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

c.
Duration
of
Nomination:
It
is
important
to
note
that
while
the
request
included
for
the
use
above
appears
to
be
for
a
single
year,
the
entire
U.
S.
request
is
actually
for
two
years
 
2005
and
2006.
This
multi­
year
request
is
consistent
with
the
TEAP
recognition
that
the
calendar
year
does
not,
in
most
cases,
correspond
with
the
cropping
year.
This
request
takes
into
account
the
facts
that
registration
and
acceptance
of
new,
efficacious
alternatives
can
take
a
long
time,
and
that
alternatives
must
be
tested
in
multiple
cropping
cycles
in
different
geographic
locations
to
determine
efficacy
and
consistency
before
they
can
be
considered
to
be
widely
available
for
use.
Finally,
the
request
for
multiple
years
is
consistent
with
the
expectation
of
the
Parties
and
the
TEAP
as
evidenced
in
the
Parties
and
MBTOC
request
for
information
on
the
duration
of
the
requested
exemption.
As
noted
in
the
Executive
Summary
of
the
overall
U.
S.
request,
we
are
requesting
that
the
exemption
be
granted
in
a
lump
sum
of
9,920,965
kilograms
for
2005
and
9,445,360
kilograms
for
2006.
While
it
is
our
hope
that
the
registration
and
demonstration
of
new,
cost
effective
alternatives
will
result
in
even
speedier
reductions
on
later
years,
the
decrease
in
our
request
for
2006
is
a
demonstration
of
our
commitment
to
work
toward
further
reductions
in
our
consumption
of
methyl
bromide
for
critical
uses.
At
this
time,
however,
we
have
not
believed
it
possible
to
provide
a
realistic
assessment
of
exactly
which
uses
would
be
reduced
to
account
for
the
overall
decrease.
Page
33
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
1.
Agricultural
Statistics.
2001.
United
States
Department
of
Agriculture.
National
Agricultural
Statistics
Service.
United
States
Government
Printing
Office,
Washington,
DC
20402.

2.
Carpenter,
Janet,
Leonard
Gianessi,
and
Lori
Lynch.
The
Economic
Impact
of
the
Scheduled
U.
S.
Phaseout
of
Methyl
Bromide.
National
Center
for
Food
and
Agricultural
Policy.
2000.

3.
Deepak,
M.
S.,
Thomas
H.
Spreen,
and
John
J.
Van
Sickle.
An
Analysis
of
the
Impact
of
a
Ban
of
Methyl
Bromide
on
the
U.
S.
Winter
Fresh
Vegetable
Market.
Journal
of
Agricultural
and
Applied
Economics
v28,
n2
(
December
1996):
433­
443.

4.
Gilreath,
J.
P.,
Noling,
J.
W.,
Locascio,
S.
J.,
and
Chellemi,
D.
O.
1999.
Effect
of
methyl
bromide,
1,3­
dichloropropene
+
chloropicrin
with
pebulate
and
soil
solarization
on
soilborne
pest
control
in
tomato
followed
by
double­
cropped
cucumber.
Proc.
Fla.
State
Hort.
Soc.
112:
292­
297.

5.
Locascio,
S.
J.,
Dickson,
D.
W.,
and
Kucharek,
T.
A.
1994.
Nutsedge,
root­
knot
nematode,
and
fungal
control
with
fumigant
alternatives
to
methyl
bromide
in
polyethylene
mulched
tomato.
Page
34
Annual
International
Research
Conference
on
Methyl
Bromide
(
1994).

6.
Locascio,
S.
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.,
Kucharek,
T.
A.,
Jones,
J.
P.,
and
Noling,
J.
W.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene­
mulched
tomato.
HortScience
32:
1208­
1211.

7.
Lynch,
Lori
and
Janet
Carpenter.
The
Economic
Impact
of
Banning
Methyl
Bromide:
Where
Do
we
Need
More
Research.
in
Proceedings
of
the
1999
Annual
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reduction.

8.
Lynch,
Lori
and
Bruce
McWilliams,
and
David
Zilberman.
Economic
Implications
of
Banning
Methyl
Bromide:
How
have
They
Changed
with
Recent
Development?.
in
Proceedings
of
the
1997
Annual
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reduction.

9.
NASS­
USDA,
Agricultural
Chemical
Use
(
Vegetables)
2000
(
July,
2001).
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
other/
pcu­
bb/
agcv0701.
txt
10.
National
Agricultural
Statistics
Service.
U.
S.
Tomato
Statistics.
1960
­
2001.
http://
usda.
mannlib.
cornell.
edu/
data­
sets/
specialty/
92010.

11.
Nelson,
S.
D.,
Locascio,
S.
J.,
Allen,
L.
H.,
Dickson,
D.
W.,
and
Mitchell,
D.
J.
1999.
Soil
flooding
and
chemical
alternatives
to
methyl
bromide
in
tomato
production.
Annual
International
Research
Conference
on
Methyl
Bromide
(
1999).

12.
Stall,
W.
M.
and
Morales­
Payan,
J.
P.
The
critical
period
of
nutsedge
interference
in
tomato.
http://
www.
imok.
ufl.
edu/
LIV/
groups/
IPM/
weed_
con/
nutsedge.
htm
13.
United
States
Department
of
Agriculture.
Economic
Implications
of
the
Methyl
Bromide
Phaseout.
An
Economic
Research
Report.
Economic
Research
Service.
2000.

14.
University
of
California
Cooperative
Extension.
Sample
Costs
to
Produce
Fresh
Market
Tomatoes
­
San
Joaquin
County:
Furrow
Irrigated.
2000.

15.
VanSickle,
John
J.,
Chalene
Brewster,
and
Thomas
H.
Spreen.
Impact
of
a
Methyl
Bromide
Ban
on
the
U.
S.
Vegetable
Industry.
University
of
Florida,
2000.

16.
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.

17.
Webster,
T.
M.
and
G.
E.
Macdonald.
2001(
b).
A
survey
of
weeds
in
various
crops
in
Georgia.
Weed
Technol.
15:
771­
790.

18.
Gilreath,
J.
P.,
J.
W.
Noling,
and
P.
R.
Gilreath.
1999.
Nutsedge
management
with
cover
crop
for
Page
35
tomato
in
the
absence
of
methyl
bromide.
Research
summary.,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.

19.
Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.

20.
Gamini,
S.
and
R.
K.
Nishimoto.
1987.
Propagules
of
purple
nutsedge
(
Cyperus
rotundus)
in
soil.
Weed
Technol.
1:
217­
220.

21.
Patterson,
D.
T.
1998.
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch.
Weed
Technol.
12:
275­
280.

22.
UNEP,
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
1998
Assessment
of
Alternatives
to
Methyl
Bromide,
United
Nations
Environment
Programme,
1998.
(
B83,
B­
28,
B281,
B87,
B287)

13.
Appendices
Appendix
A.
List
of
critical
use
exemption
(
CUE)
applications
for
the
Tomato
sector
in
the
U.
S.

CUE
02­
0004,
Michigan
Solanaceous
CUE
02­
0006,
California
Tomato
Commission
CUE
02­
0012,
Virginia
Tomato
Growers
CUE
02­
0040,
Southeastern
Tomato
Consortium
CUE
02­
0046,
Florida
Fruit
and
Vegetable
Association
­
Tomato
CUE
02­
0047,
Georgia
Fruit
and
Vegetable
Growers
Association
­
Tomato
Page
36
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
37
Page
38
#
Notes
1
Assumed
alternative
cost
the
same
as
MeBr.
If
it
costs
more,
then
it
is
less
economically
feasible.

2
1,3
D
cannot
be
used
in
Dade
County
FL.

*
kg
ai
that
would
be
applied/
hectare
=
application
rate
for
the
alternatives
or
requested
application
rate
for
methyl
bromide.
Page
39
*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
Page
40
Page
41
Page
42
Page
43
Page
44
Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.

She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.

(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)

cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

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

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

Diane
Brown­
Rytlewski
(
Biologist)
Diane
is
the
Nursery
and
Landscape
IPM
Integrator
at
Michigan
State
University,
a
position
she
has
held
since
2000.
She
acts
as
liaison
between
industry
and
the
university,
facilitating
research
partnerships
and
cooperative
relationships,

developing
outreach
programs
and
resource
materials
to
further
the
adoption
of
IPM.
Ms.
Rytlewski
holds
a
Master
of
Science
(
Plant
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.

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

Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
Page
45
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

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

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

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

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

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

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

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

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
Page
46
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,

genetic
manipulation
of
microorganisms.

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

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

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

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

He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
California
State
University
(
Los
Angeles).
Prior
to
joining
EPA
Dr.

Chiri
was
a
pest
and
pesticide
management
advisor
for
the
U.
S.
Agency
for
International
Development
working
mostly
in
Latin
America
on
IPM
issues.

Colwell
Cook
(
Biologist).
Colwell
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
She
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.

She
earned
her
Ph.
D.
(
Entomology)
from
Purdue
University
(
West
Lafayette)
and
has
a
Master
of
Science
(
Entomology)
from
Louisiana
State
University
(
Baton
Rouge).
Dr.
Cook
is
a
1979
graduate
of
Clemson
University.
Prior
to
joining
EPA
Dr.
Cook
held
several
faculty
positions
at
Wabash
College
(
Crawfordsville)
and
University
of
Evansville
(
Evansville).

Julie
B.
Fairfax
(
Biologist)
Julie
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
currently
serves
as
a
senior
biologist
in
the
Biological
and
Economics
Analysis
Division,
and
has
previously
served
as
a
Team
Leader
in
other
divisions
within
the
Office
of
Pesticides
Programs.
She
has
held
several
technical
positions
specializing
in
the
registration,
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,
Page
47
Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,

from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.
Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
and
benefits
of
pesticide
use
at
the
University
of
Illinois
(
Urbana).
Dr.
Grube
has
been
a
co­
author
of
a
number
of
journal
articles
in
various
areas
of
pesticide
economics
LeRoy
Hansen
(
Economist).
LeRoy
Hansen
is
currently
employed
as
an
Agricultural
Economist
for
the
USDA
Economic
Research
Service,
Resource
Economics
Division
in
the
Resources
and
Environmental
Policy
Branch.
He
received
his
Ph.
D.
in
resource
economics
from
Iowa
State
University
(
Ames)
in
1986.
During
his
16
years
at
USDA,
Dr.
Hansen
has
published
USDA
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
Page
48
Protection
Agency
(
EPA)
since
1998.
His
primary
areas
of
research
interest
include
environmental
cost
accounting
for
private
industries
He
earned
his
Ph.
D.
(
Environmental
and
Resource
Economics)
from
The
University
of
California
(
Davis)
and
holds
a
Master
of
Science
from
the
same
institution.
Dr.
Kim
is
a
1987
graduate
of
Korea
University
(
Seoul)
with
a
Bachelor
of
Arts
(
Economics).
Prior
to
joining
the
U.
S.
EPA,
Dr.
Kim
was
an
assistant
professor
at
the
University
of
Alaska
(
Anchorage)
and
an
economist
at
the
California
Energy
Commissions.
Dr.
Kim
is
the
author
of
numerous
articles
in
the
fields
of
resource
and
environmental
economics.

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.

(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)

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

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

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

Nikhil
Mallampalli
(
Biologist).
Nikhil
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
is
an
entomologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
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
Page
49
(
Athens).
Lorraine
Mitchell
(
Economist).
Lorraine
has
been
an
agricultural
economist
with
the
U.
S.
Department
of
Agriculture,
Economic
Research
Service
since
1998.
She
works
on
agricultural
trade
issues,
particularly
pertaining
to
consumer
demand
in
the
EU
and
emerging
markets.
Dr.
Mitchell
earned
her
Ph.
D.
(
Economics)
from
The
University
of
California
(
Berkeley).
Prior
to
joining
ERS,
Dr.
Mitchell
was
a
member
of
the
faculty
of
the
School
of
International
Service
of
The
American
University
(
Washington)
and
a
research
assistant
at
the
World
Bank.

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

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

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

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

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

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

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

Elisa
Rim
(
Economist).
Elisa
is
an
Agricultural
Economist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Page
50
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).

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.
Page
51
J.
Bryan
Unruh
(
Biologist).
Bryan
is
Associate
Professor
of
Environmental
Horticulture
at
The
University
of
Florida
(
Milton)
and
an
extension
specialist
in
turfgrass.
He
leads
the
statewide
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.

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

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

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
farmer
decision­
making,
especially
pertaining
to
issues
of
soil
fertility
and
soil
conservation
and
of
pesticide
choice.
Dr.
Wyatt
earned
his
Ph.
D.
(
Agricultural
Economics)

from
The
University
of
California
(
Davis).
Dr.
Wyatt
holds
a
Master
of
Science
(
International
Agricultural
Development)
from
the
same
institution.
He
is
a
1985
graduate
of
The
University
of
Wyoming
(
Laramie).
Prior
to
joining
the
EPA,
he
worked
at
the
International
Crops
Research
Institute
for
the
Semi­
Arid
Tropics
(
ICRISAT)
and
was
based
at
the
Sahelian
Center
in
Niamey,
Niger.

Leonard
Yourman
(
Biologist).
Leonard
is
a
plant
pathologist
with
the
Biological
and
Economic
Analysis
Division
of
the
U.
S.

Environmental
Protection
Agency.
He
currently
conducts
assessments
of
pesticide
use
as
they
relate
to
crop
diseases
He
earned
his
Ph.

D.
(
Plant
Pathology)
from
Clemson
University
(
Clemson)
and
holds
a
Master
of
Science
(
Horticulture/
Plant
Breeding)
from
Texas
A&
M
University
(
College
Station).
Dr.
Yourman
is
a
graduate
(
English
Literature)
of
The
George
Washington
University
(
Washington,
DC).
.

Prior
to
joining
EPA,
he
conducted
research
on
biological
control
of
invasive
plants
with
USDA
at
the
Foreign
Disease
Weed
Science
Research
Unit
(
Ft.
Detrick,
MD).
He
has
also
conducted
research
on
biological
control
of
post
harvest
diseases
of
apples
and
pears
at
the
USDA
Appalachian
Fruit
Research
Station
(
Kearneysville,
WV).
Research
at
Clemson
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.

Appendix
D:
Page
52
See
separate
electronic
file
for
charts
1
and
2.
