Richard Keigwin/DC/USEPA/US
12/11/2007 11:26 AM	To
	"Burleson.Smith@usda.gov" <Burleson.Smith@usda.gov>
	cc
	"Amanda_I._Lee@omb.eop.gov%inter2" <Amanda_I._Lee@omb.eop.gov>, Aaron 
Levy/DC/USEPA/US@EPA
	bcc
	
	Subject
	RE: if you have your blackberry, please say yes
	
	

Burleson--

There is a revised version of the uptake assessment (the version I sent to 
you at 10:42am) that represents a different range than Amanda sent you.  
The revised assessment was validated against some of the EUP data.  We 
believe the revised assessment is more appropriate and supportable.  This 
revised range is 11,578kg to 17,367 kg (midpoint would be approximately 
14,472kg).  The range represents between 0.045% and 0.068% of baseline.

--Rick



"Burleson.Smith@usda.gov" <Burleson.Smith@usda.gov> 
12/11/2007 11:20 AM	
	To
	"Amanda_I._Lee@omb.eop.gov%inter2" <Amanda_I._Lee@omb.eop.gov>
	cc
	Richard Keigwin/DC/USEPA/US@EPA
	Subject
	RE: if you have your blackberry, please say yes
	
	
	
	


Amanda,

I like your numbers as they are lower than what I saw from Rick Keigwin 
earlier (around 10:42 a.m.).  Any comments that can clarify this situation?

Burleson

-----Original Message-----
From: Amanda_I._Lee@omb.eop.gov%inter2 [mailto:Amanda_I._Lee@omb.eop.gov] 
Sent: Tuesday, December 11, 2007 11:08 AM
To: Smith, Burleson
Cc: Levy.Aaron@epamail.epa.gov%inter2
Subject: RE: if you have your blackberry, please say yes

Burleson, I'm forwarding the earlier email from EPA on iodomethane.  EPA
wants to consider 11578 kg of iodomethane uptake in the 2008 FRM.  If
you concur, please let me know ASAP.


Hello Burleson and John,

EPA estimates that based on currently available information iodomethane
can replace 5,789 -- 11,578 kilograms of methyl bromide in 2008
(representing between 0.023% to 0.045% of the 1991 baseline).  Briefly,
OPP's technical estimate accounts for the following:
- 14 States have registered iodomethane
- due to time-limited registration, iodomethane will be available for 10
of 12 months in 2008 (i.e. 83% of growing season)
- there are restrictions on iodomethane, such as buffer zones, that do
not apply to  methyl bromide
- the total cost of using iodomethane is currently greater than the cost
of methyl bromide
- grower inexperience with iodomethane, and a nascent distribution
system

EPA/OPP has expressed support for any value within the technical range.
EPA/SPD supports the high end of the range primarily because other
states, most notably Florida, may register iodomethane during 2008.  SPD
also notes that while iodomethane is only registered for 10 months in
2008, the first 10 months usually accounts for more than 83% of annual
fumigation volume.

With agreement from USDA and DOS, EPA is prepared to consider 11,578 kg
of iodomethane uptake in the 2008 Final Rule, and update the preamble
accordingly.  Please respond ASAP so that we can move this rule forward.


 






