Mr.
Marco
Gonzalez
Secretariat
for
the
Montreal
Protocol
P.
O.
Box
30552,
Nairobi,
Kenya
Dr.
H.
J.
Banks
10
Beltana
Road
Pialligo,
ACT
2609
Australia
Dr.
Nahum
Marban
Mendoza
Autonomic
University
of
Chapingo
PO
Box
56230
Chapingo,
Mexico
Dear
Mr.
Gonzalez,
Dr.
Banks,
and
Dr.
Mendoza:

The
United
States
submits
the
attached
documents
in
response
to
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
co­
chairs'
22
May
letter
to
the
U.
S.
Department
of
State
requesting
additional
information
on
the
U.
S.
Critical
Use
Exemption
(
CUE)
nomination.
The
attachment
provides
additional
information
requested
in
the
letter
and
also
addresses
issues
raised
in
the
May
2003
Progress
report
of
the
Technology
and
Economic
Assessment
Panel
(
TEAP).
The
attachments
are
organized
as
separate
chapters
for
each
sector,
and
include
additional
information
for
thirteen
sectors
in
the
U.
S.
CUE
nomination.
We
are
submitting
these
documents
electronically,
but
would
be
pleased
to
provide
you
with
a
hard
copy
upon
request.

We
believe
that
we
have
provided
all
of
the
information
requested
by
MBTOC.
However,
as
our
productive
discussion
in
Montreal
in
July
demonstrated,
an
immediate
answer
to
a
question
can
sometimes
clear
up
an
issue
in
a
short
time.
Given
the
importance
that
both
MBTOC
and
the
Parties
place
on
ensuring
that
recommendations
are
made
in
a
timely
manner
on
the
basis
of
full
and
correct
information,
I
urge
MBTOC
to
contact
us
should
it
have
questions
regarding
the
attachment.
If
any
such
additional
information
is
needed,
please
contact
John
Thompson
at
the
U.
S.
Department
of
State
(
ThompsonJE2@
state.
gov
or
202­
647­
9799).

I
would
like
to
take
this
opportunity
to
discuss
several
general
issues
that
came
up
during
the
preparation
of
this
document
or
that
were
discussed
at
the
Open
Ended
Working
Group
in
July:
2
Multi­
Year
Nominations:
The
U.
S.
nomination
requested
a
CUE
for
both
2005
and
2006,
but
it
appears
that
the
MBTOC's
initial
view
was
to
make
recommendations
at
this
time
for
2005
CUEs.
While
we
recognize
that
there
is
some
uncertainty
because
this
is
the
first
time
the
CUE
process
has
been
carried
out,
the
United
States
still
believes
it
is
appropriate
for
the
Parties
to
consider
granting
multi­
year
exemptions
with
the
understanding
that
an
exemption
for
the
second
year
is
contingent,
and
can
be
reviewed
if
alternatives
are
found
to
be
available
sooner
than
expected.
We
believe
that
this
can
be
advantageous
in
terms
of
providing
greater
certainty
to
the
agricultural
community
as
well
as
helping
manage
the
work
of
the
Parties
and
MBTOC
in
developing
and
reviewing
applications
and
in
addressing
the
issue
at
the
Meeting
of
the
Parties.

Aggregate
Nominations:
The
U.
S.
Government
is
in
the
process
of
establishing
domestic
regulations
to
manage
the
amount
of
methyl
bromide
produced
and/
or
imported
under
a
critical
use
exemption
and
to
ensure
that
the
amount
is
used
solely
for
purposes
determined
to
be
critical
needs
by
the
Parties.
We
believe
that
while
Parties
take
on
such
a
responsibility
to
implement
their
CUEs,
each
Party
should
be
given
the
freedom
to
do
so
as
it
best
fits
within
its
national
context.
In
the
context
of
the
United
States,
this
is
particularly
important.
As
one
example,
we
note
that
while
our
analysis
divided
among
the
relevant
crops
the
full
level
of
1,3­
D
allowed
under
the
township
caps
in
California,
it
is
not
possible
to
determine
in
advance
which
sectors
will
utilize
1,3­
D
in
a
future
year.
Accordingly,
providing
the
exemption
on
a
crop­
by­
crop
basis
will
not
enable
the
United
States
to
utilize
1,3­
D
where
it
may
be
most
effective.
This
is
just
one
example
of
why
we
believe
that,
with
respect
to
the
United
States,
it
is
most
appropriate
to
grant
an
aggregate
allotment
to
be
used
within
sectors
agreed
by
the
Parties
to
be
critical.
We
believe
there
will
be
unnecessary
burdens
that
will
not
benefit
the
environment
associated
with
attempts
to
determine
with
great
specificity
exactly
where
methyl
bromide
will
be
used
under
approved
CUEs.
Under
the
procedure
used
in
the
essential
use
exemption
process,
Parties
have
the
discretion
to
use
their
essential
use
allotment
among
approved
CFCMDIs
to
allow
the
needs
of
patients
to
be
fully
met;
we
believe
similar
discretion
should
be
provided
for
CUEs
so
that
critical
agricultural
needs
are
met.

Economic
Feasibility
The
United
States
does
not
believe
it
is
appropriate
to
adopt
the
TEAP
proposal
to
use
an
average
cost
effectiveness
from
Multilateral
Fund
projects
as
a
threshold
to
evaluate
economic
feasibility.
This
single
measure
does
not
fully
account
for
the
specific
conditions
each
applicant
faces
and,
in
recognition
of
this
fact,
the
Multilateral
Fund
has
not
applied
this
value
across
sectors
in
such
a
manner.

The
United
States
notes,
however,
that
the
CUE
criteria
specifically
enable
the
grant
of
an
exemption
if
alternatives
are
found
to
be
economically
infeasible.
While
we
recognize
the
difficulties
in
applying
the
economic
criterion,
we
do
not
believe
it
is
appropriate
for
the
MBTOC
and
the
Parties
to
set
aside
this
important
criterion
this
year.
Indeed,
the
Parties
understand
that
while
an
alternative
may
be
technically
feasible,
users
should
not
be
expected
to
adopt
alternatives
that
make
crop
production
economically
infeasible.
3
Given
the
importance
of
economic
feasibility,
we
believe
the
task
warrants
consideration
of
more
than
a
single
economic
criterion.
In
fact,
the
United
States
used
a
`
portfolio'
or
`
weight
of
evidence'
approach
to
assess
economic
feasibility
using
five
measurements:
(
1)
loss
per
hectare,
(
2)
loss
per
kilogram
of
methyl
bromide,
(
3)
loss
as
a
percent
of
gross
revenue,
(
4)
loss
as
a
percent
of
net
cash
returns,
and
(
5)
change
in
profit
margins.
In
certain
specific
sectors,
other
factors
such
as
benefits
to
the
environment
not
captured
by
cost
measures
were
also
considered.
Using
an
approach
involving
weighing
multiple
measures
allows
for
a
more
complete
understanding
and
balancing
of
the
potential
impacts
of
using
alternatives.

California
Township
Caps
As
noted
above,
a
number
of
sector
nominations
for
the
United
States
in
the
State
of
California
are
impacted
by
regulatory
township
caps
put
in
place
to
promote
human
health
and
environmental
protection.
The
approach
used
in
the
U.
S.
CUE
was
to
assume
that
1,3­
D
would
be
used
up
to
the
amount
of
the
cap,
and
this
use
was
distributed
proportionally
within
sectors
where
1,3­
D
was
a
feasible
alternative.
Thus,
the
U.
S.
nomination
did
not
request
CUEs
in
townships
where
1,3­
D
is
feasible
and
can
be
used
up
to
the
level
of
the
township
cap.

Thank
you
very
much
for
your
consideration
of
the
U.
S.
CUE
nomination.
The
United
States
recognizes
that
the
task
taken
on
by
the
MBTOC
and
TEAP
is
an
arduous
and
difficult
one;
particularly
as
this
is
the
first
year
the
CUE
process
has
been
used.
We
appreciate
your
efforts,
and
look
forward
to
continuing
to
work
with
you
on
our
nomination
should
additional
information
be
needed.

Sincerely,

Jeffry
Burnam
Deputy
Assistant
Secretary
for
Environment
