MEMORANDUM
TO:
E­
Docket
OAR­
2004­
0506
FROM:
U.
S.
Environmental
Protection
Agency/
Office
of
Air
and
Radiation/
Office
of
Atmospheric
Programs/
Stratospheric
Protection
Division
RE:
Calculations
of
amounts
of
Methyl
Bromide
requested
for
Critical
Use
Exemptions
for
California
Strawberries
for
the
2005
Supplemental
Request
This
memo
concerns
modifications
made
to
the
U.
S.
2005
Supplemental
Request
for
critical
use
exemptions
(
CUEs)
for
methyl
bromide
within
the
strawberry
fruit
sector.
Strawberry
fruit
was
not
originally
nominated
for
the
2005
Supplemental
Request.
The
Supplemental
Request
was
submitted
to
the
Ozone
Secretariat
on
February
7,
2004,
in
conjunction
with
the
annual
U.
S.
nomination
requesting
exemptions
for
the
2006
use
year.

After
submission
to
the
Ozone
Secretariat,
the
nominations
are
reviewed
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
and
the
Technical
and
Economic
Assessment
Panel
(
TEAP),
advisory
bodies
to
the
Parties.
After
reviewing
the
MBTOC
and
TEAP
recommendations,
the
Parties
authorize
amounts
of
methyl
bromide
for
critical
uses.

As
part
of
the
original
request
for
the
2005
use
year,
submitted
to
the
Ozone
Secretariat
in
January
2003,
the
U.
S.
technical
experts
evaluated
many
factors
concerning
the
technical
and
economic
feasibility
of
alternatives
to
methyl
bromide.
The
same
factors
were
considered
in
the
annual
U.
S.
request
for
the
2006
use
year,
and
the
2005
supplemental
request.
The
evaluation
of
the
applicant's
request,
which
resulted
in
the
reduction
of
the
total
amount
nominated,
included
consideration
of
issues
such
as
the
area
afflicted
with
the
key
target
pests,
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.

For
the
2005
use
year,
the
U.
S.
requested
2,468,873
(
2468.873
metric
tonnes),
kilograms
of
methyl
bromide
for
strawberry
fruit
nationwide,
with
1,816,637
kilograms
(
1816.637
MT)
requested
for
California.
In
their
"
Critical
Use
Nominations:
Supplementary
Report"
issued
in
October,
2003,
MBTOC
recommended
that
2468.87
MT
be
authorized
for
the
strawberry
field
industry
in
the
U.
S.
(
p.
40).
Prior
to
the
issuance
of
this
report,
the
MBTOC
had
asked
for
clarification
on
technical
issues
in
the
nomination,
including
the
strawberry
fruit
sector.
The
U.
S.
Government
responses
were
transmitted
to
the
Ozone
secretariat
on
August
27,
2003.

At
their
15th
annual
meeting,
held
during
November
2003
in
Nairobi,
Kenya,
the
Parties
were
unable
to
come
to
a
decision
about
methyl
bromide
critical
use
exemption
nominations.
An
Extraordinary
Meeting
was
scheduled
for
March,
2004.
As
a
result,
MBTOC
requested
additional
clarifications
on
the
U.
S.
nomination
on
December
4,
2003,
and
responses
were
transmitted
on
January
30,
2004.
In
a
second
report
titled
"
Critical
Use
Nominations:
2004
Supplementary
Report,"
issued
on
February
14,
2004,
the
MBTOC
reduced
their
recommendation
for
strawberry
field
crops
in
the
U.
S.
to
1834
MT.
This
reduction
was
based
an
adjustments
made
that
indicated
that
alternatives
were
technically
feasible
and
that
if
the
double
(
2X)
Telone
allowed
under
township
cap
restrictions
continued
in
California,
there
would
be
scope
for
additional
reduction
(
p.
35).

However,
after
discussions
with
U.
S.
experts,
MBTOC
realized
that
the
authorization
for
the
Strawberry
sector
had
been
reduced
by
a
greater
amount
(
634
MT)
than
it
should
have
been,
and
that
the
MBTOC
had
also
assumed
a
transition
to
alternatives
that
was
too
rapid,
based
on
recent
data.
Therefore,
MBTOC
informed
the
U.
S.
technical
experts
that
they
should
request
an
additional
supplemental
amount
to
compensate
for
this
reduction
error,
which
focused
on
California.

However,
at
the
time
of
issuance
of
the
report,
and
of
the
Parties'
subsequent
authorizations
at
the
Extraordinary
Meeting
in
March,
the
2004
Nomination
(
for
use
year
2006),
which
included
the
2005
supplemental
request,
had
already
been
submitted.
(
The
2nd
annual
nomination
was
submitted
on
February
7,
2003).
Because
the
MBTOC
recommendation
for
the
reduction
came
after
the
submission
of
the
2005
supplemental
request,
the
strawberry
sector
was
not
accounted
for
in
the
original
supplemental
request.

At
the
First
Extraordinary
Meeting
of
the
Parties,
held
in
March,
2004,
the
Parties
approved
1225.935
MT
for
field­
grown
strawberries
in
the
U.
S.

At
the
16th
Meeting
of
the
Parties,
which
took
place
in
Prague,
Czech
Republic,
in
November
2004,
the
Parties
authorized
the
2005
supplemental
requests.
Decision
XVI/
2,
Annex
1A,
authorized
an
additional
219,000
(
219
MT)
kilograms
of
methyl
bromide
for
strawberry
fruit
in
the
United
States,
noting
that
additional
time
is
required
for
an
effective
transition
to
alternatives
(
p.
48).

The
amount
of
methyl
bromide
nominated
by
the
United
States
for
critical
uses
in
the
strawberry
fruit
sector
also
incorporates
minimum
efficacious
use
rates,
mixtures
of
methyl
bromide
with
chloropicrin,
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions,
and
also
includes
a
small
margin
of
error.
More
information
on
the
development
of
the
U.
S.
Nomination
for
Critical
Use
Exemptions
for
the
2005
use
year
is
available
on
E­
Docket
OAR­
2003­
0230,
document
#
104,
in
a
memo
titled
"
Development
of
2003
Nomination
for
a
Critical
Use
Exemption
for
Methyl
Bromide
from
the
United
States
of
America."
