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
Tomatoes
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
tomato
sector.
Field­
grown
tomatoes
were
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.

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
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
2,865,262
kilograms
of
methyl
bromide
for
field­
grown
tomatoes
nationwide.
However,
this
request
did
not
include
California,
because
the
California
applicant
did
not
submit
data
that
demonstrated
sufficient
yield
losses
without
methyl
bromide.
Therefore,
their
application
was
not
included
in
the
original
U.
S.
nomination
for
the
2005
use
year.
However,
during
the
second
round
of
critical
use
exemption
application
evaluations,
the
applicant
supplied
additional
data
on
pest
pressure
and
registered
alternatives
that
did
not
provide
consistent
control
of
target
pests.
In
addition,
some
registered
alternatives
were
problematic
due
to
the
hilly
terrain
in
the
nominated
regions.
Therefore,
the
California
applicant
requested
102,058
kilograms
of
methyl
bromide
for
critical
uses
in
2006;
this
amount
was
requested
in
the
subsequent
annual
nomination.
In
October,
2004,
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
and
the
Technical
and
Economic
Assessment
Panel
(
TEAP)
issued
a
report
recommending
an
additional
10,746
kilograms
of
methyl
bromide
for
tomatoes
for
use
year
2005.

At
the
16th
Meeting
of
the
Parties
to
the
Montreal
Protocol,
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
10,746
kilograms
of
methyl
bromide
for
field­
grown
tomatoes
in
the
United
States.

The
amount
of
methyl
bromide
nominated
by
the
United
States
for
critical
uses
in
the
tomato
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."
