Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
TURFGRASS
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
turfgrass,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
U.
S.
believes
is
critical
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
turfgrass
follows.

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

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

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

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

Under
the
essential
use
provisions,
in
order
to
even
be
considered
for
an
exemption,
it
was
necessary
for
each
proposed
use
to
be
"
critical
for
health,
safety
or
the
functioning
of
society."
This
extremely
high
Page
2
threshold
contrasts
sharply
with
the
criteria
established
for
the
methyl
bromide
critical
use
exemption.
Indeed,
for
methyl
bromide,
the
Parties
left
it
solely
to
the
nominating
governments
to
find
that
the
absence
of
methyl
bromide
would
create
a
significant
market
disruption.
In
addition,
it
was
agreed
that
the
Technology
and
Economic
Assessment
Panel
(
TEAP)
and
the
Parties
as
a
group
should
limit
their
review
to
whether
there
were
"
technically
and
economically
feasible
alternatives
or
substitutes"
for
the
nominated
use.

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

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

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

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

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

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

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

4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Turfgrass
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
EPA)
initiated
open
meetings
with
stakeholders
both
to
inform
them
of
the
Protocol
requirements
and
to
understand
the
issues
being
faced
in
researching
alternatives
to
methyl
bromide.
During
those
meetings,
which
were
attended
by
State
and
association
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
U.
S.
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11
which
calls
for
specific
information
to
be
presented
in
the
nomination.

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

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

Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.

5.
Overview
of
Agricultural
Production
Page
4
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
enable
the
U.
S.
to
be
a
uniquely
large
and
productive
agricultural
producer.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farm
land
totaled
381
million
hectares,
a
land
area
larger
than
the
size
of
many
entire
countries.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables
have
had
an
important
impact
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.
developed
a
unique
brand
of
highly
mechanized
farming
practices
that
are
highly
reliant
on
pesticides
such
as
methyl
bromide
and
other
non­
labor
inputs.
The
extent
of
mechanization
and
reliance
on
non­
labor
inputs
can
be
best
demonstrated
by
noting
the
very
low
levels
of
labor
inputs
on
U.
S.
farms.
In
2001,
only
2.05
million
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.

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
pesticides,
and
drip
irrigation,
as
well
as
improved
irrigation
practices.
Optimization
of
yields
through
these
and
other
scientific
and
mechanized
practices
make
U.
S.
agricultural
output
very
sensitive
to
changes
in
inputs.
Therefore,
as
evidenced
by
the
U.
S.
nomination
for
critical
uses
of
methyl
bromide,
the
phaseout
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.

5b.
Turfgrass
Production
The
turfgrass
sector
of
the
U.
S.
has
nominated
enough
methyl
bromide
to
treat
1
percent
of
the
sod
acreage
and
0.02
percent
of
the
golfcourse
acreage.
Production
of
turfgrass
occurs
throughout
the
great
diversity
of
climactic
and
soil
regions
of
the
U.
S.
 
from
the
hot
and
humid
south,
to
the
wet
and
cold
northwest.
In
each
region,
different
types
of
turfgrasses
have
been
selected,
and
selectively
adapted
because
of
their
suitability
to
local
climate
and
soils.
However,
with
this
diversity,
comes
a
large
number
of
pest
problems
that
methyl
bromide
has
proven
uniquely
able
to
address.
The
above
factors
have
contributed
to
a
harvest
of
many
different
types
of
turfgrass
species
that
have
allowed
the
U.
S.
to
Page
5
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
There
are
over
1,100
turfgrass
and
sod
producers
in
the
U.
S.
alone
growing
sod
on
132,000
hectares
(
326,000
acres)
of
land
and
16,000
golfcourses
on
about
728,000
hectares
(
1.2
million
acres).
The
wholesale
value
of
sod
is
US$
670
million.
The
success
of
the
turfgrass
industry
is
directly
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices.
Optimization
of
high
quality
sod
and
turfgrass
through
scientific
and
mechanized
practices
make
the
U.
S.
turfgrass
industry
very
sensitive
to
changes
in
inputs.
One
consequence
of
this
specialized
adaptation
to
very
localized
conditions
is
that
the
phaseout
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.

U.
S.
turfgrass
production
shares
many
of
the
same
characteristics
with
general
U.
S.
fruit
and
vegetable
production
but
there
are
some
key
differences.
Locally
adapted
varieties
of
turfgrass
are
widely
grown
across
the
U.
S.,
without
regional
production
centers
such
as
those
which
characterize
fruit
and
vegetable
production,
turfgrass
sod
is
actively
growing
and
cannot
be
stored
or
shipped
long
distances
after
being
lifted
from
the
soil.
This
nomination
covers
methyl
bromide
use
for
turfgrass
sod
production
across
the
U.
S.
as
well
as
new
construction
and
reconstruction
of
golfcourses.
Turf
and
sod
production
also
differs
from
production
of
fruits
and
vegetables
in
that
production
has
been
increasing,
partly
as
a
farmers
switch
out
of
crops
which
are
only
marginally
profitable
for
them
to
turfgrass
and
sod
production
which
is
much
more
profitable.

Residents
of
the
U.
S.
live
far
more
spread
out
than
households
in
most
of
the
rest
of
the
world.
The
most
common
housing
situation
is
the
detached,
single
family
dwelling,
surrounded
by
a
lawn
of
grass.
Even
in
our
largest
and
most
densely
packed
cities,
with
the
exception
of
New
York
City,
fewer
than
50
percent
of
the
inhabitants
live
in
an
apartment
or
other
type
of
multiple
unit
housing.
Living
spread­
out,
surrounded
by
lawn,
creates
a
large
demand
for
turfgrass,
to
use
around
residences.
EPA
proprietary
survey
data
indicates
that
the
average
homeowner
has
1,760
m2
(
19,000
ft2)
of
lawn
area.
Additional
demand
is
created
by
the
increased
numbers
of
Americans
who
participate
in
sports;
golf
courses
and
athletic
fields
are
two
of
the
non­
residential
sectors
with
large
demands
for
turfgrass
sod.
An
estimated
one
out
of
eight
people
participate
in
golf
with
over
16,000
golfcourses
in
the
U.
S.

For
commercial
sod
production,
establishing
a
market
for
your
product
before
planting,
as
well
as
ensuring
continued
customer
satisfaction
by
providing
a
quality
product,
is
essential
for
a
business.
Wholesale
buyers
for
most
sod
producers
are
landscape
maintenance/
contractors,
garden
centers,
building
contractors,
homeowners,
and
golf
course/
athletic
field
superintendents.
Growers
harvest
up
to
9,200
square
meters/
hectare
(
40,000
sq.
ft.
per
acre)
per
cutting.
Normal
yields
are
generally
between
6,400
and
8,700
square
meters/
hectare
(
28,000
and
38,000
sq.
ft.
per
acre).
Costs
and
returns
vary
with
location,
equipment,
available
labor
and
management
practices.

Sod
The
primary
States
producing
turfgrass
sod
are
California,
Florida,
Georgia,
Alabama,
and
Texas.
There
are
at
least
1,143
turfgrass
sod
producers
across
the
U.
S.
who
farm
approximately
132,000
hectares,
with
a
wholesale
product
value
of
US$
670
million.
Methyl
bromide
is
used
only
on
approximately
1
percent
of
the
total
sod
area
in
any
single
year
(
1,416
hectares
were
requested
out
of
132,000
hectares
total).
Sod
producers
only
fumigate
with
methyl
bromide
when
they
have
severe
pest
pressure
and/
or
off­
type
grasses,
to
establish
new
fields,
or
to
eliminate
quarantine
pests.
Page
6
The
three
conditions
when
sod
fields
are
fumigated
with
methyl
bromide
are:
(
1)
when
establishing
a
new
piece
of
ground
for
sod
(
never
had
sod
on
it
before);
(
2)
as
a
pre­
plant
fumigation
when
pest
pressures
become
so
severe
that
a
"
clean"
(
i.
e.
pest
free
and
free
of
off­
type
grasses)
sod
can
not
be
produced;
and
(
3)
when
there
are
quarantine
pests
and
methyl
bromide
must
be
used
to
meet
the
official
requirement
of
the
destination
area.
On
average,
fumigation
of
the
soil
occurs
once
at
the
time
the
field
is
established
and
then
once
again
every
5­
10
years
for
the
reasons
stated
above.
From
planting
to
harvest,
a
sod
crop
takes
between
9­
12
months
to
reach
maturity.

The
U.
S.
consumer
market
generally
demands
turfgrass
that
consists
of
pure
varieties
of
grasses
that
are
uniform,
vigorous,
densely
growing,
and
free
of
the
pests
and
pathogens
that
would
reduce
its
vigor,
impede
its
ability
to
control
erosion,
and
reduce
its
production
of
oxygen
for
the
ecosystem.
The
standards
for
purity
are
so
strict
that
even
a
very
small
proportion
of
"
off
type"
blades
of
grass
will
lead
to
rejection
of
the
sod
according
to
major
industry
standards.

There
are
industry
certification
programs
for
sod
to
guarantee
that
the
grasses
are
genetically
pure.
Producers
of
certified
turfgrass
sod,
or
vegetative
propagules,
operate
under
zero­
tolerance
standards
for
pests
or
off­
type
grasses.
Infested
fields
lose
certification
status
and
the
sod
on
those
fields
can
no
longer
be
sold.
Since
there
is
no
secondary
market
for
contaminated
sod,
the
crop
can
not
be
sold
at
all
which
leads
to
a
complete
loss
to
the
grower.
Because
of
the
differential
susceptibility
of
species
to
drought,
temperature
extremes,
and
pathogens,
consumers
are
very
particular
about
the
species
of
turfgrass
that
they
buy.
The
off­
typing
issue
is
of
particular
importance
in
growing
bermudagrass
sod
where
the
product
is
a
specific
genetically
pure
species.
Contamination
with
off­
type
grasses
can
even
lead
to
legal
action
against
the
turfgrass
producer.

There
is
a
quarantine
program
in
most
of
the
southern
U.
S.
to
prevent
the
introduction
of
the
imported
fire
ant
in
sod
to
areas
outside
of
the
quarantined
zone.
While
methyl
bromide
is
used
to
prevent
the
introduction
of
a
quarantine
pest,
dazomet
is
not
a
substance
approved
by
USDA/
APHIS
under
this
quarantine
certification
program.

Golf
Courses
In
the
U.
S.,
methyl
bromide
is
used
on
newly
constructed
and
reconstructed
golf
course
greens,
and
sometimes
on
tees
and
fairways.
There
are
approximately
16,000
golf
courses
across
the
U.
S.,
serving
over
26
million
golfers,
who
play
520
million
rounds
of
golf
annually
on
an
estimated
728,000
hectare
(
1.8
million
acres).
Methyl
bromide
is
used
only
on
approximately
0.02
percent
of
the
total
golfcourse
area
in
any
single
year
(
180
hectares
were
requested
out
of
728,000
hectares
total).
Renovation
of
golf
course
greens,
tees,
and
fairways
is
relatively
infrequent,
so
methyl
bromide
is
used
on
an
individual
golf
course
perhaps
every
15
to
20
years.
U.
S.
golf
courses
pride
themselves
in
maintaining
high
quality,
uniform,
playable
surfaces
that
are
free
of
weeds
and
pests.
Methyl
bromide
is
the
only
tool
currently
used
to
kill
the
numerous
pathogens
that
slowly
invade
and
destroy
high
quality
playing
surfaces.
Methyl
bromide
lowers
the
pest
level
and
ensures
the
establishment
and
long­
term
survival
of
new
turf.
On
golf
courses,
several
conditions
put
turfgrass
under
severe
stress
that
limit
root
development.
These
conditions
include:
low
mowing
height,
frequent
mowing,
compaction
due
to
high
traffic,
and,
frequent
irrigation.
In
addition,
during
the
15
to
20
years
between
fumigations
problems
with
insects,
diseases,
weeds
and
nematodes
begin
to
reduce
the
density
of
the
turf
and
lessen
the
Page
7
playability
of
the
surface.
When
a
green,
tee
or
fairway
is
infested,
the
golf
course
will
remove
the
turfgrass
and
fumigate
the
soil
with
methyl
bromide
to
re­
establish
a
new
grass
surface.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Turfgrass
The
two
turfgrass
uses
of
methyl
bromide
included
in
this
initial
U.
S.
critical
use
exemption
nomination
are:
sod
farms,
especially
those
where
warm
season
turfgrasses
are
grown,
and
as
a
soil
disinfectant
for
the
installation
and
renovation
of
golf
courses.
The
major
difference
between
sod
producers
and
golf
courses
is
that
sod
producers
grow
and
harvest
turfgrass
for
sale
to
another
location,
whereas
golf
courses
use
methyl
bromide
to
maintain
clean,
vigorous
playable
grass.

6a.
Target
Pests
Controlled
with
Methyl
Bromide
The
target
pests
of
turfgrass
sod
production
which
are
also
the
pests
that
invade
golf
courses
causing
them
to
require
renovation
include:
imported
red
fire
ants
(
Solenopsis
invicta),
scarabaeid
beetles,
more
than
15
genera
of
parasitic
nematodes,
such
as
lance
nematodes
(
Hoplolaimus
spp.
)
and
sting
nematodes
(
Belonolaimus
longicaudatus),
and
weeds
like
yellow
nutsedge
(
Cyperus
esculentus),
crabgrass
(
Digitaria
spp.),
goosegrass
(
Eleusine
indica),
purple
nutsedge
(
Cyperus
rotundus)
and
common
bermudagrass
(
Cynodon
dactylon).

Insects.
In
a
recent
survey
(
2000)
of
Georgia
sod
producers,
imported
red
fire
ants
(
Solenopsis
invicta)
received
the
highest
average
ranking
as
most
problematic
insect
pests
followed
by
white
grubs
(
there
is
a
complex
of
genera
in
Florida:
Bothynis,
Strategus,
Cyclocephala
and
Phyllophaga).
Although
not
directly
injurious
to
turfgrass,
imported
red
fire
ants
pose
problems
by
interfering
with
mowing,
harvesting,
selling
and
shipment
of
sod.

The
imported
red
fire
ant
(
Solenopsis
invicta)
currently
infests
all
of
Florida
and
Louisiana,
much
of
Georgia,
South
Carolina,
North
Carolina,
Tennessee,
Alabama,
Mississippi,
Arkansas,
Texas,
and
Oklahoma.
Its
pest
status
in
turf
results
from
its
stinging,
biting,
and
mound
making
habit,
which
interferes
with
turf
management
and
damages
maintenance
equipment.
Problems
with
quarantine
and
shipment
of
sod
outside
of
fire
ant
infested
zones
is
a
major
factor
affecting
productivity.
The
white
grub
complex
[
larvae
of
Japanese
beetle
(
Popillia
japonica),
oriental,
European,
northern
masked
chafers
(
Cyclocephala
spp.),
and
Asiatic
garden
beetles
(
Maladera
castanea)]
are
the
main
insect
problems
of
sod
growers.
For
control
of
several
species
of
scarabaeid
beetles,
damage
tresholds
vary
by
grub
species
and
turfgrass
species,
vigor
and
market
purpose.
"
Non­
injurious"
levels,
acceptable
in
landscape
situations
or
sod
not
scheduled
for
harvest,
are
unacceptable
to
consumers.
Unfortunately,
grub
populations
are
difficult
to
detect
until
noticeable
damaged
has
occurred,
and
larvae
are
in
the
third
instar
(
the
most
damaging
stage),
a
size
that
is
not
controlled
by
newer
products
available.
Green
June
beetle
grub
(
Cotinis
nitida),
for
instance,
keep
vertical
tunnels
in
the
ground
open
to
the
surface
by
pushing
mounds
of
loose
soil
that
can
interfere
with
mowing
and
damage
mowing
equipment.

Nematodes.
Nematode
damage
to
turf
is
more
common
in
Florida
than
in
other
states
because
sandy
soils
and
long
growing
seasons
favor
the
development
of
high
nematode
populations
and
enhance
grass'
susceptibility
to
their
effects.
More
than
15
genera
of
nematodes
attack
warm
season
turfgrasses,
and
all
common
species
of
turfgrasses
are
susceptible.
In
addition,
turf
weakened
by
nematode
damage
becomes
more
susceptible
to
fungi
infestations
and
other
root
diseases.
Page
8
Weeds.
Grassy
weeds
which
are
a
problem
in
sod
production
include
annual
bluegrass
(
Poa
annua),
crabgrass
(
Digitaria
spp.),
goosegrass
(
Eleusine
indica),
vaseygrass
(
Paspalum
urvillei),
signalgrass
(
Brachiaria
platyphyla),
sprangletop
(
Leptochloa
fascicularis),
torpedograss
(
Panicum
repens),
and
bermudagrass
(
Cynodon
dactylon).
Broadleaf
weeds
include
purslane
(
Portulaca
oleracea),
betony
(
Betonica
spp.),
Florida
pusley
(
Richardia
scabra),
pennywort/
dollarweed
(
Hydrocotyle
spp.),
4­
leaved
clover
oxalis
(
Oxalis
spp.),
and
spurge
(
Euphorbia
spp.).
Purple
nutsedge
(
Cyperus
rotundus)
and
yellow
nutsedge
(
Cyperus
escullentus)
also
constitute
serious
weed
problems.
One
important
category
of
weed
is
off­
type
grasses
or
turfgrass
species
that
infest
the
soil
from
the
previous
planting.
These
offtype
grasses
can
have
different
disease
resistance
genes,
pest
resistance,
rooting
characteristics,
leaf
textures,
leaf
color,
or
competitive
characteristics.

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
turfgrass
for
water
and
nutrients
and
are
not
acceptable
in
certified
sod.
Among
the
areas
covered
by
this
nomination
for
continued
methyl
bromide
use
in
turfgrass
production,
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.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Turfgrass
producers
rely
on
fumigation
with
methyl
bromide
to
establish
new
growing
areas
and
to
control
weeds,
diseases
and
insects
on
land
currently
producing
sod
(
i.
e.
1
percent
of
the
sod
farms
total
area
per
year).
Golf
course
superintendents
rely
on
fumigation
with
methyl
bromide
when
a
new
golf
course
is
being
established
and
for
golf
course
renewal,
every
15
to
20
years
thereafter
as
the
tees,
green,
and
fairways
become
re­
colonized
with
the
pest
species
(
described
above)
with
the
ensuing
degradation
of
the
playing
surface
(
i.
e.
0.025
percent
of
the
golf
courses
total
area
per
year).

6c.
Technical
Feasibility
of
Alternatives
Page
9
Table
1.
Summary
of
Technical
and
Economic
Feasibility
Assessment
of
Alternatives
Identified
by
MBTOC
for
Turfgrass
Sod
Production
and
Golfcourses.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
Dazomet
No
N/
A1
For
alternatives
which
were
found
to
be
not
technically
feasible,
economic
feasibility
was
not
assessed.

Table
2.
Alternatives
Not
Identified
by
MBTOC
but
Considered
for
Turfgrass
Sod
Production
and
Golfcourses.
Methyl
Bromide
Alternative
Assessment
of
Technical
Feasibility
Assessment
of
Economic
Feasibility
1,3­
Dichloropropene
No
N/
A1
1,3­
Dichloropropene/
chloropicrin
No
N/
A1
Metam­
sodium
No
N/
A!
Nematicides
No
N/
A1
The
only
"
in­
kind"
alternative
identified
for
turf/
sod
production
by
MBTOC
is
Basamid.
In
an
effort
to
minimize
reliance
on
methyl
bromide
fumigation,
this
report
also
addresses
the
evaluation
of
several
alternatives
to
methyl
bromide
that
are
not
specifically
identified
by
MBTOC
for
use
in
the
turfgrass
sod
industry,
and
turfgrass
golf
course
renovation
projects.

Basamid
®
(
dazomet)
(
rate:
285
to
500
kg/
ha;
255­
450
lb/
A)
is
not
a
technically
feasible
alternative
because
it
does
not
provide
consistent
control
of
the
target
pests.
While
research
suggests
dazomet
and
metam­
sodium
can,
in
some
situations,
provide
effective
pest
control
for
certain
diseases
and
weeds,
research
data
suggest
that
these
products
can
not
be
relied
on
to
provide
necessary
consistency
of
results
(
Csinos
et
al,
1997,
Unruh
and
Brecke,
2001
and
Unruh
et
al
,2002)
.
Specifically,
neither
dazomet
(
used
at
390
kg/
ha;
350
lbs/
acre)
nor
metam­
sodium
(
e.
g.,
Vapam
®
,
Busan
®
)
(
used
at
470
to
950
l/
ha;
50­
100
gal/
acre)
consistently
provide
acceptable
control
of
nutsedge,
off
type
turfgrass,
or
nematodes.
Methyl
bromide
appears
to
be
the
only
treatment
that
consistently
provides
effective
control
of
off­
type
turfgrass,
disease,
and
nutsedge
weeds,
while
individual
research
trials
show
great
variability
in
efficacy
of
alternatives
(
Unruh
et
al,
2002).
In
addition
to
providing
higher
rates
of
efficacy
and
more
consistent
results
than
the
other
alternatives
tested,
methyl
bromide
also
allows
for
quick
planting
after
treatment.
The
methyl
bromide
treated
area
can
be
planted
within
48
hours
after
the
tarp
(
plastic
cover)
is
removed,
while
a
minimum
waiting
period
of
14
to
21
days
before
planting
is
required
when
metam­
sodium
or
dazomet
is
used
to
treat
the
soil.
There
have
been
problems
with
dazomet
washing
off
of
properly
prepared
golfcourse
sites
into
nearby
streams
during
rainstorms
as
occurred
in
Washington,
D.
C.

Although
not
on
the
2002
MBTOC
list
for
sod/
turf,
Telone
II
[
1,3­
Dichloropropene
(
1,3­
D)]
may
be
used
in
sod
farms
but
not
in
golf
courses.
This
alternative
is
not
technically
feasible
because
it
does
not
control
the
entire
pest
complex
which
affects
turfgrass
operations.
Telone
II
has
good
activity
against
plant­
parasitic
nematodes,
but
not
other
pests.
Telone
C­
17
[
1,3­
dichloropropene
+
Page
10
17%
chloropicrin]
has
added
efficacy
against
many
soil­
borne
fungi
resulting
from
the
activity
of
chloropicrin,
but
neither
of
these
products
are
very
effective
as
herbicides
and
so
do
not
control
the
weed
species,
in
particular
the
yellow
and
purple
nutsedge,
that
affect
turfgrass
production.
In
the
limited
circumstances
when
methyl
bromide
is
necessary
(
approximately
1
percent
of
the
hectares
in
turfgrass
production
in
a
year),
1,3­
dichloropropene
will
not
adequately
control
the
target
pests.

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.

Although
not
on
the
2002
MBTOC
list
for
sod/
turf,
metam­
sodium
is
sometime
used
by
sod
farms
and
in
the
establishment/
renovation
of
golf
courses.
This
is
not
a
technically
feasible
alternative
because
it
is
not
effective
against
the
entire
pest
complex
which
affects
this
crop
and
because
it
provides
very
inconsistent
control
of
pests.
Metam­
sodium
is
the
active
ingredient
in
several
product
lines
Vapam
®
,
Busan
®
,
Nemasol
and
metam
products.
Research
data
demonstrate
that
metam­
sodium
(
used
at
470
to
950
l/
ha;
50­
100
gal/
acre)
does
not
provide
acceptable
levels
of
nutsedge
control,
and
in
that
respect,
it
is
similar
to
dazomet
(
see
other
comparisons
about
the
similarity
between
metam­
sodium
and
dazomet
above).
Metam­
sodium
can
be
used
to
reduce
levels
of
nematodes
and
many
other
soil
pests
which
interfere
with
turf
establishment.

The
personal
protective
equipment
requirements
(
coveralls,
long
sleeves,
masks
and
goggles)
for
metam­
sodium
applications
are
impractical
for
use
in
extremely
hot
climates
such
as
southern
states,
thus
limiting
widespread
acceptance
of
this
system.

Although
not
on
the
2002
MBTOC
list
for
sod/
turf,
Nematicides
are
sometimes
used
for
sod
turfgrass
production
and
for
establishment/
renovation
of
golf
courses.
Few
non­
fumigant
nematicides
are
available
for
use
on
established
commercial
turf
(
e.
g.,
golf
courses,
sod
farms,
and
cemeteries
in
Florida).
Treatment
with
such
products
must
be
followed
by
an
overhead
application
of
0.2
to
1.0
cm
(
0.1
to
0.5
inches)
of
water
as
directed
in
the
product
label.

The
potential
for
outbreak
of
secondary
pests
after
repetitive
and
frequent
use
of
nematicides
is
a
concern.
Not
all
nematicides
are
equally
effective
against
all
species
of
nematodes,
so
frequent
use
of
the
same
product
on
a
particular
site
enables
less­
affected
species
to
become
dominant
in
the
population.
This
seems
to
have
occurred
in
situation
where
Mocap
has
been
used
repeatedly.
Mocap
is
not
systemic
(
absorbed
into
living
tissues)
and
therefore
can
not
reach
nematodes
that
live
inside
roots.

Furthermore,
prolonged
use
of
a
nematicide
on
the
same
site
causes
selection
and
build
up
of
bacteria
and
soil­
borne
microbes
which
metabolize
the
product
more
quickly.
The
result
of
repeated
use
of
a
nematicide
is,
therefore,
enhanced
biodegradation
(
that
is:
microbial
degradation
of
the
product)
shortens
the
net
effect
from
a
particular
treatment
over
time.
This
situation
has
been
Page
11
already
reported
for
over
200
soil­
applied
pesticides,
including
nematicides
used
repetitively
on
a
given
location.

Reduction
of
nematode
damage
was
added
to
the
label
of
Triumph
4E,
a
pesticide
labeled
for
lawns,
sod
farms,
industrial
sites,
sport
turf,
as
well
as
golf
courses,
based
on
field
trial
experience
with
lance
nematodes
(
Hoplolaimus
spp.
)
and
sting
nematodes
(
Belonolaimus
longicaudatus)
on
bermudagrass
(
Cynodon
dactylon)
golf
greens.
It
has
also
been
effective
on
St.
Augustinegrass
(
Stenotaphrum
secundatum)
and
centipedegrass
(
Eremochloa
ophiuroides),
but
there
have
also
been
many
disappointing
results
because
the
performance
of
many
non­
fumigant
nematicides
are
variable
depending
on
grass
and
soil
type,
rate
of
application,
and
height
at
which
grass
is
cut
(
lawn
and
sport
turf
are
cut
much
higher
than
golf
course
greens
and
tees).
Thus,
besides
the
need
for
irrigation
following
treatment,
variability
of
results
add
to
the
limitations
on
the
effectiveness
of
non­
fumigant
nematicides.
6d.
Economic
Feasibility
of
Alternatives
None
of
the
alternatives
listed
by
MBTOC
and
reviewed
above
were
found
to
be
technically
feasible
for
turfgrass.
Therefore,
no
economic
analysis
was
conducted.

Currently,
there
are
no
technically
feasible
alternatives
to
replace
the
use
of
methyl
bromide
for
turfgrass
sod
production
and
establishment/
renovation
of
golf
courses.
The
only
alternative
on
the
2002
MBTOC
list
for
the
sod/
turf
sector
is
dazomet.
Dazomet
is
not
technically
feasible
because
it
does
not
consistently
control
the
target
pests.
Metam­
sodium,
another
MITC
generating
substance,
also
has
the
constraint
of
not
providing
consistent
control
of
target
pests.
This
nomination
lists
other
potential
alternatives
for
sod/
turf
that
are
not
on
the
2002
MBTOC
list
because
they
are
sometimes
used,
but
they
cannot
be
relied
on
to
provide
control
of
the
full
range
of
sod/
turf
target
pests.
Thus,
there
is
a
critical
need
for
methyl
bromide
for
turfgrass
sod
production
and
for
establishment/
renovation
of
gold
courses.

7.
Critical
Use
Exemption
Nomination
for
Turfgrass
The
U.
S.
interdisciplinary
review
team
found
a
critical
need
for
methyl
bromide
for
the
turfgrass
sod
production
sector
and
turfgrass
golf
course
maintenance
industry.
The
only
chemical
alternative,
Basamid,
identified
by
the
MBTOC
for
turf
and
sod
was
reviewed
in
detail
and
regarded
by
U.
S.
reviewers
as
not
technically
feasible
for
effective
control
of
the
major
target
pests.

Table
3
summarizes
methyl
bromide
historical
usage,
including
area
treated,
and
the
actual
amount
requested
for
2005
thru
2007
for
turfgrass
sod
production.

Table
3.
Methyl
Bromide
Usage
and
Request
for
Turfgrass
Sod
1997
1998
1999
2000
2001
2005
2006
2007
tonnes
596
600
914
762
500
680
680
680
hectares
1,221
1,232
1,874
1,563
1,029
1,416
1,416
1,416
rate
(
kg/
ha)
490
490
490
490
490
480
480
480
The
U.
S.
is
nominating
a
critical
need
for
methyl
bromide
to
establish
new
and
reconstruct
existing
golf
course
greens
(
and
less
frequently
tees
and
fairways)
at
the
16,000
golf
courses
throughout
the
Page
12
country.
Renovation
of
golf
course
greens,
tees
and
fairways
is
relatively
infrequent
so
that
methyl
bromide
is
used
on
individual
golf
courses
perhaps
every
15
to
20
years.

Table
4
summarizes
methyl
bromide
historical
usage,
including
area
treated,
and
the
actual
amount
requested
for
2005
thru
2007
for
golf
course
establishment
and
maintenance.

Table
4.
Methyl
Bromide
Usage
and
Request
for
Golf
Course
Maintenance.
1997
1998
1999
2000
2001
2005
2006
2007
tonnes
100
102
130
79
97
111
111
111
hectares
160
180
210
130
160
180
180
180
rate
(
kg/
ha)
613
559
611
612
608
610
610
610
The
total
U.
S.
nomination
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues
including
the
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required,
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives
(
buffer
zones,
township
caps),
environmental
concerns
such
as
soil
based
restrictions
due
to
potential
groundwater
contamination,
and
historic
use
rates,
among
other
factors.

Table
5.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Turfgrass
Sod
and
Golf
Course
Maintenance.
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
791,427
352,194
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
Page
13
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.
Reduced
methyl
bromide
concentrations
in
mixtures,
more
mechanized
soil
injection
techniques,
and
the
extensive
use
of
tarps
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world.

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

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

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

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
Page
14
bromide,
the
U.
S.
Department
of
Agriculture
(
USDA)
initiated
a
research
program
to
find
viable
alternatives.
Finding
alternatives
for
agricultural
uses
is
extremely
complicated
compared
to
replacements
for
other,
industrially
used
ozone
depleting
substances
because
many
factors
affect
the
efficacy
such
as:
crop,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
even
among
localities
within
a
region.

Through
2002,
the
USDA
Agricultural
Research
Service
(
ARS)
alone
has
spent
US$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
(
see
table
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
agricultural
and
forestry
leaders
from
private
industry,
academia,
state
governments,
and
the
federal
government
to
assess
the
problem,
formulate
priorities,
and
implement
research
directed
at
providing
solutions
under
the
USDA's
Methyl
Bromide
Alternatives
program.
The
ARS
within
USDA
has
22
national
programs,
one
of
which
is
the
Methyl
Bromide
Alternatives
program
(
Select
Methyl
Bromide
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov).
The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
the
extensive
private
sector
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
While
research
has
been
undertaken
in
all
sectors,
federal
government
efforts
have
been
based
on
the
input
of
experts
as
well
as
the
fact
that
nearly
80
percent
of
preplant
methyl
bromide
soil
fumigation
is
used
in
a
limited
number
of
crops.
Accordingly,
much
of
the
federal
government
pre­
plant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.

Table
6.
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Expenditures
by
the
U.
S.
Department
of
Agriculture
(
US$
Million)
1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
The
USDA/
ARS
strategy
for
evaluating
possible
alternatives
is
to
first
test
the
approaches
in
controlled
experiments
to
determine
efficacy,
then
testing
those
that
are
effective
in
field
plots.
The
impact
of
the
variables
that
affect
efficacy
is
addressed
by
conducting
field
trials
at
multiple
locations
with
different
crops
and
against
various
diseases
and
pests.
Alternatives
that
are
effective
in
field
plots
are
then
tested
in
field
scale
validations,
frequently
by
growers
in
their
own
fields.
Page
15
University
scientists
are
also
participants
in
this
research.
Research
teams
that
include
ARS
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

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

One
example
of
research
into
methyl
bromide
alternatives
on
turfgrass
was
Dr.
Bryan
Unruh,
Extension
Turfgrass
Specialist
at
the
University
of
Florida
work
from
1998.
Data
gathered
from
Dr.
Unruh's
research
trials
comparing
methyl
bromide
to
several
fumigants,
alone
and
in
combination,
indicate
inferior
weed
control
by
all
alternatives
considered,
including
Basamid
®
(
dazomet),
the
only
registered
alternative
for
turfgrass
sod
on
the
MBTOC
list
of
alternatives.
Experimental
results
from
trials
conducted
in
Florida
in
1998
show
that
dazomet
provided
less
control
than
methyl
bromide
on
all
weed
species
measured.
Further,
for
golf
course
renovations,
dazomet
requires
an
extended
waiting
period
prior
to
planting
in
order
to
avoid
phytotoxicity
on
seedlings.
The
dazomet
label
states
that
24
days
are
needed
for
effective
fumigation.
The
applicant
estimates
that
losses
related
to
extended
golf
course
closures
are
in
the
range
of
US$
70,000
to
US$
199,500
per
renovation.
If
renovations
are
required
more
frequently
due
to
the
inferior
performance
of
dazomet
in
controlling
weeds,
these
estimates
will
increase.

Although
no
single
alternative
for
all
of
the
methyl
bromide
uses
presently
exist,
the
turfgrass
industry
continues
to
research
and
test
a
number
of
options
that
are
available.
The
most
promising
alternative
under
investigation
is
methyl
iodide,
which
is
not
registered
for
use
in
the
U.
S.
Proposed
studies
include
evaluation
of
sodium
azide
as
a
preplant
soil
fumigant
for
turf,
dazomet
blended
with
Greensmix
as
a
replacement
for
methyl
bromide
fumigation
in
golf
greens
construction,
and
ways
to
improve
chemical
application
technology
to
increase
the
efficacy
of
some
of
the
alternatives
assessed
above.

Research
in
application
technology
(
e.
g.,
injection
methods
and
application
rates)
may
improve
the
uniformity
of
soil
movement
of
chemicals,
such
as
metam­
sodium.

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
Page
16
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

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

The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
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
to
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
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
process
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
The
average
processing
time
for
a
new
active
ingredient,
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
most
cases,
the
registrant
(
the
pesticide
applicant)
has
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
Page
17
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

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

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

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

 
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.
Page
18
It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
even
registering
those
alternatives
is
not
the
end
of
the
story.
Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
In
an
effort
to
speed
adoption,
the
U.
S.
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

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

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
turfgrass
sector
are
not
currently
technically
feasible
from
the
standpoint
of
U.
S.
turfgrass
sod
producers,
or
for
establishment
and
renovation
of
golf
courses
as
covered
by
this
exemption
request.
In
addition,
we
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
in
turfgrass
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unreasonable
adverse
effect
to
human
health
or
the
environment,
is
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
turfgrass
sod
production
and
the
establishment
and
renovation
of
golf
courses
will
be
maintained
for
the
period
being
requested.

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

a.
Request
for
Aggregate
Exemption
for
All
Covered
Methyl
Bromide
Uses:
As
mandated
by
Decision
XIII/
11,
the
nomination
information
that
is
being
submitted
with
this
package
includes
information
requested
on
historic
use
and
estimated
need
in
individual
sectors.
That
said,
we
note
our
agreement
with
past
MBTOC
and
TEAP
statements
which
stress
the
dynamic
nature
of
agricultural
markets,
uncertainty
of
specific
production
of
any
one
crop
in
any
specific
year,
the
difficulty
of
projecting
several
years
in
advance
what
pest
pressures
might
prevail
on
a
certain
crop,
and,
the
difficulty
of
estimating
what
a
particular
market
for
a
specific
crop
might
look
like
in
a
future
year.
We
also
concur
with
the
MBTOC's
fear
that
countries
that
have
taken
significant
efforts
Page
19
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.

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.
Page
20
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.

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
Page
21
12.
References
Allen,
L.
H.,
S.
J.
Locascio,
D.
W.
Dickson,
D.
J.
Mitchell,
and
S.
D.
Nelson.
1999.
Flooding
(
soil
anoxia)
for
control
of
pests
of
vegetables.
Research
Summary,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.

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

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

Csinos,
A.
S.,
W.
C.
Johnson,
A.
W.
Johnson,
D.
R.
Sumner,
R.
M.
McPherson,
and
R.
D.
Gitaitis.
1997.
Alternative
fumigants
for
methyl
bromide
in
tobacco
and
pepper
transplant
production.
Crop
Prot.
16:
585­
594.

Egley,
G.
H.
1983.
Weed
seed
and
seedling
reductions
by
soil
solarization
with
transparent
polyethylene
sheets.
Weed
Sci.
31:
404­
409.

Galloway,
B.
A.
and
L.
A.
Weston.
1996.
Influence
of
cover
crop
and
herbicide
treatment
on
weed
control
and
yield
in
no­
till
sweet
corn
(
Zea
mays
L.)
and
pumpkin
(
Cucurbita
maxima
Duch).
Weed
Technol.
10:
341­
346.

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

Gilreath,
J.
P.,
J.
W.
Noling,
and
P.
R.
Gilreath.
1999.
Nutsedge
management
with
cover
crop
for
tomato
in
the
absence
of
methyl
bromide.
Research
summary.,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013
Holm,
L.
G.,
D.
L.
Plucknett,
J.
V.
Pancho,
and
J.
P.
Herberger.
1977.
The
world's
worst
weeds:
distribution
and
biology.
Honolulu,
HI:
University
of
Hawaii
Press,
pp.
8­
24
Horowitz,
M.
1972.
Effects
of
desiccation
and
submergence
on
the
viability
of
rhizome
fragments
of
bermudagrass,
johnsongrass,
and
tubers
of
nutsedge.
Israel
J.
Agric.
Res.
22(
4):
215­
220.

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

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

Patterson,
D.
T.
1998.
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch.
Weed
Technol.
12:
275­
280.
Page
22
Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.

Unruh,
J.
B.
and
B.
J.
Brecke.
2001.
Seeking
Alternatives
for
Methyl
Bromide.
Golf
Course
Management.
69(
3):
65­
72.

Unruh,
J.
B.,
B.
J.
Brecke,
J.
A.
Dusky
and
J.
S.
Godbehere.
2001.
Fumigant
Alternatives
for
Replacement
of
Methyl
Bromide
in
Turfgrass.
Weed
Technology.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2001(
a).
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Rotation
20:
605­
614
Webster,
T.
M.
and
G.
E.
Macdonald.
2001(
b).
A
survey
of
weeds
in
various
crops
in
Georgia.
Weed
Technol.
15:
771­
790.

13.
Appendices
Appendix
A.
List
of
Critical
Use
Exemption
(
CUE)
requests
for
the
turfgrass
and
golfcourse
sector
in
the
U.
S.

CUE­
02­
0044,
Turfgrass
Producers
International.
Representing
turfgrass
sod.

CUE­
02­
0055:
Preplant;
Golf
Course
Superintendents
Association
of
America.

Appendix
B.
Spreadsheets
supporting
Economic
Analyses
None
of
the
alternatives
listed
by
MBTOC
and
reviewed
above
were
found
to
be
technically
feasible
for
turfgrass.
Therefore,
no
economic
analysis
was
conducted.

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).
Page
23
William
John
Chism
(
Lead
Biologist).
Bill
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
He
evaluates
the
efficacy
of
pesticides
for
weed
and
insect
control.
He
earned
his
Ph.
D.
(
Weed
Science)
from
Virginia
Polytechnic
Institute
and
State
University
(
Blacksburg),
a
Master
of
Science
(
Plant
Physiology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Agriculture)
from
California
Polytechnic
State
University
(
San
Luis
Obispo).
Dr.
Chism
is
a
1978
graduate
of
The
University
of
California
(
Davis).
For
ten
years
prior
to
joining
the
EPA
Dr.
Chism
held
research
scientist
positions
at
several
speciality
chemical
companies,
conducting
and
evaluating
research
on
pesticides.

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

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

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.
Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

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

Linda
Calvin
(
Economist).
Linda
Calvin
is
an
agricultural
economist
with
USDA's
Economic
Research
Service,
specializing
in
research
on
topics
affecting
fruit
and
vegetable
markets.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Berkeley).
Page
24
Kitty
F.
Cardwell
(
Biologist).
Kitty
has
been
the
National
Program
Leader
in
Plant
Pathology
for
the
U.
S.
Department
of
Agriculture
Cooperative
State
Research,
Extension
and
Education
Service
since
2001.
In
this
role
she
administrates
all
federally
funded
research
and
extension
related
to
plant
pathology,
of
the
Land
Grant
Universities
throughout
the
U.
S.
She
earned
her
Ph.
D.
(
Phytopathology)
from
Texas
A&
M
University
(
College
Station).
Dr.
Cardwell
is
a
1976
graduate
of
The
University
of
Texas
(
Austin)
cum
laude
(
Botany).
For
twelve
years
prior
to
joining
USDA
Dr.
Cardwell
managed
multinational
projects
on
crop
disease
mitigation
and
food
safety
with
the
International
Institute
of
Tropical
Agriculture
in
Cotonou,
Bénin
and
Ibadan,
Nigeria.

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

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

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­
Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,
genetic
manipulation
of
microorganisms.

Daniel
Chellemi
(
Biologist).
Dan
has
been
a
research
plant
pathologist
with
the
U.
S.
Department
of
Agriculture
since
1997.
His
research
speciality
is
the
ecology,
epidemiology,
and
management
of
soilborne
plant
pathogens.
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.
Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).
Page
25
Angel
Chiri
(
Biologist).
Angel
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
California
State
University
(
Los
Angeles).
Prior
to
joining
EPA
Dr.
Chiri
was
a
pest
and
pesticide
management
advisor
for
the
U.
S.
Agency
for
International
Development
working
mostly
in
Latin
America
on
IPM
issues.

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

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

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

Clara
Fuentes
(
Biologist).
Clara
has
been
with
the
U.
S.
Environmental
Protection
agency
since
1999,
working
in
the
Philadelphia,
Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
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
Page
26
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.

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

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

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

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

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Page
27
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)
researching
Agricultural
Sciences
Center
in
Parlier,
CA.
He
joined
ARS
in
June
of
1971.

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

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

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

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

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
Page
28
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
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.
Page
29
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
as
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.
trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

J.
Bryan
Unruh
(
Biologist).
Bryan
is
Associate
Professor
of
Environmental
Horticulture
at
The
University
of
Florida
(
Milton)
and
an
extension
specialist
in
turfgrass.
He
leads
the
statewide
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.
Page
30
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
Masters
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.

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