US Environmental Protection Agency

Methyl Bromide Critical Use Exemption

Office of Pesticide Programs

911 Bay, BEAD

1921 Jefferson Davis Highway

Arlington, VA  22202

July 3, 2005

Re:  Methyl Bromide CUE Request for California Peppers

To Whom It May Concern:

The California Pepper Commission (CPC) is again submitting a CUE
application.  The request is for 1,000 acres, which is only 5% of a
20,000 acre industry in the state of California.  This is about 60%
reduction from previous application requests due to implementation of
alternatives and extending periods between applications.

The affected California pepper industry is not large.  Research is
expensive and the CPC must allocate funds that benefit the majority of
its membership, not just the few that must rely on methyl bromide;
therefore, the burden of learning to use methyl bromide alternatives has
been placed on a few members who rely on their own experimentation.  It
is also difficult to justify expensive, multi-year studies when there is
little confidence that CUE requests will be granted or given the same
consideration as some of the larger consortia, as historical evidence
suggests.

Growers have altered use by no longer applying methyl bromide on an
annual basis, and have even stretched applications to every three years.
 What we have learned is that about 1,000 acres of peppers, primarily on
coastal land, can not farm the land without a buildup of soilborne
pathogen inoculum and without experiencing an increased problem with
nightshade and nutsedge; metam sodium can suppress these problems in for
two or three years, but a methyl bromide application is required to
clean up the pest populations every two or three years in order to
maintain production.  This is illustrated in CDPR’s Pesticide Use
Reports where a 90% decrease in methyl bromide use occurred between 1999
and 2002 but, in 2003, the use reverted to the 2001 levels because
growers saw they were in trouble and had to clean their fields.

Growers have less land to lease because of urbanization and the land
available is becoming more marginal for production.  Because of the
expense to prepare a field for production, especially with irrigation,
growers cannot be nomadic farmers and change fields every year.  We are
fighting simply to maintain.

Please give this application every consideration.  Call me if there are
questions.  We do not believe we are getting as much consideration as
the larger commodity groups because we do not have the money or the
lobbying efforts to be taken seriously.  

Sincerely,

Glen A. Fischer

Commissioner/Chairman

California Pepper Commission

