1 2003 NOMINATION FOR A CRITICAL USE EXEMPTION FOR ORNAMENTAL NURSERIES FROM THE UNITED STATES OF AMERICA 1. Introduction In consultation with the co chair of Methyl Bromide Technical Options Committee ( MBTOC), the United States ( U. S.) has organized this version of its Critical Use Exemption Nomination in a manner that would enable a holistic review of relevant information by each individual sector team reviewing the nomination for a specific crop or use. As a consequence, this nomination for two specific ornamental nursery sectors, like the nomination for all other crops included in the U. S. request, includes general background information that the United States believes is critical to enabling review of our nomination in a manner that meets the requirements of the Parties' critical use decisions. With that understanding, the fully integrated U. S. nomination for the ornamental nursery sector follows.

2. Background In 1997, the Parties to the Montreal Protocol adjusted Article 2H of the Protocol, and agreed to accelerate the reduction in the controlled production and consumption of methyl bromide. This adjustment included a provision calling for a phaseout of methyl bromide by the year 2005 " save to the extent that the Parties decide to permit the level of production or consumption that is necessary to satisfy uses agreed by them to be critical uses." At the same time, the Parties adopted decision IX/ 6, the critical use exemption decision, which laid out the terms under which critical use exemptions under Article 2H would be granted.

3. Criteria for Critical Uses under the Montreal Protocol In crafting Decision IX/ 6 outlining the criteria for a critical use exemption, the Parties recognized the significant differences between methyl bromide uses and uses of other ozone depleting chemicals previously given scrutiny under the Protocol's distinct and separate Essential Use exemption process. The United States believes that it is vitally important for the MBTOC to take into account the significant differences between the critical use exemption and the essential use exemption in the review of all methyl bromide critical use nominations.

During the debate leading up to the adoption of the critical use exemption Decision IX/ 6, an underlying theme voiced by many countries was that the Parties wanted to phase out methyl bromide, but not agriculture. This theme was given life in various provisions of the critical use exemption, and in the differences in approach taken between the critical use exemption and the essential use exemption. Those differences are outlined below.

The Protocol's negotiated criteria for the critical use exemptions for methyl bromide are much different from the criteria negotiated for " Essential Uses" for other chemicals. 2 Under the Essential Use provisions, in order to even be considered for an exemption, it was necessary for each proposed use to be " critical for health, safety or the functioning of society." This high threshold differs significantly from the criteria established for the methyl bromide Critical Use exemption. Indeed, for methyl bromide, the Parties left it solely to the nominating governments to find that the absence of methyl bromide would create a significant market disruption. .

For the U. S. nomination for two specific ornamental nursery sectors, following detailed technical and economic review, the U. S. has determined that the level of methyl bromide being requested is critical to ensuring that there is no significant market disruption. The detailed analysis of technical and economic viability of the alternatives listed by MBTOC for use in growing nursery chrysanthemums, and nursery roses is discussed later in this nomination.

In the case of methyl bromide, the Parties recognized many agricultural fumigants were inherently toxic, and therefore there was a strong desire not to replace one environmentally problematic chemical with another even more damaging.

The critical use exemption language explicitly requires that an alternative should not only be technically and economically feasible, it must also be acceptable from the standpoint of health and environment. This is particularly important given the fact that most chemical alternatives to methyl bromide are extremely toxic, and can involve threats to human health or the environment that are even greater than the threats posed by methyl bromide.

In the case of methyl bromide, the Parties recognized that evaluating, commercializing and securing national approval of alternatives and substitutes is a lengthy process.

In fact, even after an alternative is tested and found to work against some pests in a controlled setting, adequate testing in large scale commercial operations can take many cropping seasons before the viability of the alternative can be adequately assessed from the standpoint of the climate and soil for various potential users. In addition, the process of securing national and sub national approval of alternatives may require extensive analysis of environmental consequences and toxicology. The average time for the national review of scientific information in support of a new pesticide, starting from the date of submission to registration, is approximately 38 months. In most cases, the company submitting the information has spent approximately 7 10 years developing the epidemiological and other environmental data necessary to support the registration request.

The Parties to the Protocol recognized that unlike other chemicals controlled under the Montreal Protocol, the use of methyl bromide and available alternatives could be site specific and must take into account the particular needs of the user.

The Essential Use exemption largely assumed that an alternative used in one place could, if approved by the government, be used everywhere. Parties clearly understood that this was not the case with methyl bromide because of the large number of variables involved, such as crop type, soil types, pest pressure and local climate. That is why the methyl bromide Critical Use exemption calls for an examination of the feasibility of the alternative from the standpoint of the user, and in the context of the specific circumstances of the nomination, including use and geographic location. In order to effectively implement this last, very important provision, we believe it is critical for 3 MBTOC reviewers to understand the unique nature of U. S. agriculture, as well as U. S. efforts to minimize the use of methyl bromide, to research alternatives, and to register alternatives for methyl bromide.

4. U. S. Consideration/ Preparation of the Critical Use Exemption for Ornamental Nurseries Work on the U. S. critical use exemption process began in early 2001. At that time, the U. S. Environmental Protection Agency ( U. S. EPA) initiated open meetings with stakeholders both to inform them of the Protocol requirements, and to understand the issues being faced in researching alternatives to methyl bromide. During those meetings, which were attended by State and association officials representing thousands of methyl bromide users, the provisions of the critical use exemption Decision IX/ 6 were reviewed in detail, and questions were taken. The feedback from these initial meetings led to efforts by the U. S. to have the Protocol Parties establish international norms for the details to be in submissions and to facilitate standardization for a fair and adequate review. These efforts culminated in decision XIII/ 11 which calls for specific information to be presented in the nomination.

Upon return from the Sri Lanka meeting of the Parties, the U. S. took a three track approach to the critical use process. First, we worked to develop a national application form that would ensure that we had the information necessary to answer all of the questions posed in decision XIII/ 11. At the same time, we initiated sector specific meetings. This included meetings with representatives of the ornamental nursery sector across the U. S. to discuss their specific issues, and to enable them to understand the newly detailed requirements of the critical use application. These sector meetings allowed us to fine tune the application so we could submit the required information to the MBTOC in a meaningful fashion.

Finally, and concurrent with our preparation phase, we developed a plan to ensure a robust and timely review of any and all critical use applications we might receive. This involved the assembly of more than 45 PhDs and other qualified reviewers with expertise in both biological and economic issues. These experts were divided into interdisciplinary teams to enable primary and secondary reviewers for each application/ crop. As a consequence, each nomination received by the U. S. was reviewed by two separate teams. In addition, the review of these interdisciplinary teams was put to a broader review of experts on all other sector teams to enable a third look at the information, and to ensure consistency in review between teams. The result was a thorough evaluation of the merits of each request. A substantial portion of requests did not meet the criteria of decision IX/ 6, and a strong case for those that did meet the criteria has been included Following our technical review, discussions were held with senior risk management personnel of the U. S. government to go over the recommendations and put together a draft package for submission to the parties. As a consequence of all of this work, it is safe to say that each of the sector specific nominations being submitted is the work of well over 150 experts both in and outside of the U. S. government. 4 5. Overview of Agricultural Production 5a. U. S. Agriculture The U. S. is fortunate to have a large land expanse, productive soils and a variety of favorable farming climates. These factors contribute to and enable the U. S. to be uniquely large and productive. Indeed, the size and scope of farming in the U. S. is different than in most countries. Specifically, in 2001, U. S. farm land alone totaled 381 million hectares, a land area larger than the entire size of many entire countries. There were 2.16 million farms, with average farm size across all farms of 176 hectares ( approximately 10 times larger than average farm size in the European Union). The availability of land and the fact that so many U. S. regions are conducive to outdoor cultivation, has had an important impact on the way farming in the U. S. has developed. Specifically, these factors have meant that greenhouse production has generally proven to be very costly ( in relative terms) and has as a consequence, been limited.

Other factors also affected the general development of farming in the U. S. While land for farming is widely available, labor is generally more expensive and less plentiful. As a result, the U. S. developed a unique brand of highly mechanized farming practices that are highly reliant on pesticides such as methyl bromide and other non labor inputs. The extent of mechanization and reliance on non labor inputs can be best demonstrated by noting the very low levels of labor inputs on U. S. farms: in 2001, only 2.05 million workers operated the 2.16 million U. S. farms, with help from less than 1 million hired workers.

U. S. agriculture is also unique in terms of the broad range of crops produced. For example, the fruit and vegetable sector, the agricultural sector most reliant on methyl bromide, is diverse, and includes production of 107 separate fruit and vegetable commodities or groups of commodities. With this diversity, however, has come a large number of pest problems that methyl bromide has proven uniquely able to address.

The related yield increases per land area are almost exclusively related to non labor inputs, like the adoption of new varieties, and the application of new production practices, including plastic mulches, row covers, high density planting, more effective pesticide sprays, and drip irrigation, as well as increased water irrigation practices. Optimization of yields through these and other scientific and mechanized practices make U. S. agricultural output very sensitive to changes in inputs. Therefore, as evidenced by the U. S. nomination for critical uses of methyl bromide, the phaseout of methyl bromide can have a very significant impact on both the technical and economic viability of production of certain crops in certain areas.

5b. Chrysanthemum Propagative Material and Nursery Roses Production The U. S. is the world's largest producer and market for nursery and greenhouse crops. In terms of economic output, nursery and greenhouse crops are the second most important sector in U. S. agriculture. In 1997, nursery and greenhouse operations had sales of US$ 10.9 billion ( American Nursery and Landscape Association, 2002, www. anla. org) . 5 In terms of the species grown, pests, and cultural practices, the ornamental sector is extremely diverse. However, one factor is common to all aspects of the industry   that is the requirement for a high quality, pest free product. Because particular plant species are produced in only a few locations ( e. g., 60 percent of the nursery roses are produced in California; 90 percent of the chrysanthemum propagation material is produced in Florida) and then shipped throughout North America, a number of certification programs have been established, either by the growers themselves or by government agencies, to ensure that pests are not spread inadvertently. The use of agricultural chemicals, especially pesticides, are key to meeting the exacting standards of the consumer and the certification and quarantine requirements of the regulatory agencies.

Methyl bromide is the standard chemical used as a fumigant in the production of chrysanthemum propagative material and nursery roses to ensure that these crops can be consistently certified as pest free. In these crops methyl bromide is applied between crop cycles to the planting beds using shank injectors. The soil surface is covered with polyethylene film immediately after treatment. At the end of the exposure period ( which lasts up to two weeks), the tarpaulins are removed and the beds are aerated for about two weeks prior to the introduction of transplants.

Chrysanthemum Propagative Material   Cropping System A particular cultivar/ variety of chrysanthemums, with chosen color, shape and other characteristics is planted in a bed to establish the " mother plants" for the production of " cuttings". Before these cultivars are planted, the beds are fumigated with methyl bromide. The chrysanthemum " mother plants" are grown for 20 to 25 weeks. Cuttings are then taken from the mother plants. These cuttings, from a single producer in Florida, are then shipped throughout North America for nurseries to raise and sell commercially. Many states and other jurisdictions regulate and have certification programs for the interstate shipment of nursery stock ( propagative material), such as chrysanthemum cuttings.

Cuttings are harvested weekly from " mother plants" for the 20 to 25 weeks. At the end of this cycle, most of the above surface crop debris is removed ( crowns and roots are left in the soil), and the planting beds are again fumigated with methyl bromide ( typically 98 percent methyl bromide, 2 percent chloropicrin). The beds are then replanted after waiting 2 to 3 weeks for the next crop cycle. Typically two crop cycles are completed per year. This is a continuous cropping cycle throughout the year. Almost all U. S. chrysanthemum propagative material is produced on a relatively small land area   about 50 hectares.

Nursery Roses   Production System About 60 percent of the U. S. rose production is located in and around Kern County, California. This area produces approximately 30 million plants annually. The four year production cycle for roses, prior to commercial sale, includes one year of fallow, one year of a rotational crop and a two year rose crop. Typically, the two year rose crop cycle begins with land preparation ( removing the cover crop, deep cultivation, and fumigation with methyl bromide), followed by planting the rootstock, and T bud grafting. In late winter of the first year, the rootstock tops are removed. The rose crop matures by the second autumn and are then harvested. This cycle varies depending on the type of 6 rose crop being produced ( i. e., two year roses, one year minis and patio trees, or an 18 month mini bush).

6. Results of Review  Determined Need for Methyl Bromide in the Production of Ornamental Nurseries 6a. Target Pests Controlled with Methyl Bromide Chrysanthemum   Target Pests Methyl bromide is primarily used in the production of chrysanthemum cuttings as a soil fumigant to control fungal and bacterial pathogens such as Erwinia chrysanthemi, E. carotovora, Agrobacterium tumefaciens, Fusarium oxysporum, F. solani, and other Fusarium species, Verticillium albo atrum; nematodes such as Radopholus similes, Rotolenchus reniformis, Globodera spp., Heterodera spp.; and unspecified weeds. Methyl bromide is unique in providing control for all of these important pests.

Nursery Roses   Target Pests Methyl bromide is used in rose production to control pathogens such as Verticillium dahlia, Pythium spp., and Agrobacterium tumefaciens; to control nematodes such as the root knot nematode ( Meloidogyne spp), lesion nematode ( Paratylenchus vulnus), pin nematode ( Paratylenchus penetrans), and stubby root nematode; and to control unspecified weeds. Control of some of these nursery rose pests at depths over a meter is particularly important because of the deep rooted nature of this perennial crop. Methyl bromide uniquely provides pest control at these depths.

Yellow nutsedge ( Cyperus esculentus L.) and purple nutsedge Cyperus rotundus L.) are perennial species of the Cyperacea family that are widely recognized for their economic impact in agriculture. Purple nutsedge is considered the worst weed in the world due to its widespread distribution and difficult control ( Holm et al. 1977). Nutsedge is considered a weed in at least 92 countries and is reported to be infesting at least 52 different crops. Yellow nutsedge is listed among the top fifteen worst weeds. Yellow nutsedge is found throughout the continental U. S. Purple nutsedge is primarily found in the coastal southern U. S. and along the Pacific coast in California and Oregon. A survey conducted in Georgia ranked the nutsedges as the most troublesome weeds in vegetable crops ( there are more 30 vegetable crops grown in Georgia) ( Webster et al. 2001).

Nutsedge is propagated by tubers formed along underground rhizomes and corms. The parent tuber could be a tuber or a corm from the previous generation. During tillage of the soil, the underground stems are broken and new plants are established from either single or chains of tubers or corms. A single plant is capable of producing 1,200 new tubers within 25 weeks ( Gilreath et al. 1999). Each tuber is capable of sprouting several times ( Thullen et al. 1975). Tuber populations between 1,000 and 8,700 per/ m2 have been reported for purple nutsedge ( Gamini et al. 1987). Nutsedge is very difficult to eradicate once it is established because of dormancy factors in the tubers and their ability to survive an array of adverse conditions for long periods of time. Nutsedge species are strong competitors with most vegetable crops for water and nutrients and can reduce crop yields at low plant densities. 7 Purple and yellow nutsedge are serious problems in polyethylene film mulch vegetable production systems. Most weeds are controlled by polyethylene films, but nutsedges are able to penetrate the plastic films, and actively compete with the vegetable crops causing yield losses reported between 41 to 89 percent ( Patterson, 1998). It is unclear as to the magnitude of nutsedge pressure in Florida chrysanthemums.

There are very few herbicides that control nutsedge and none are registered for use on ornamental nurseries. The herbicides that are available for these crops are generally older chemicals that are marginally effective against weeds such as nutsedge.

6b. Overview of Technical and Economic Assessment of Alternatives Ornamental nursery growers rely on fumigation with methyl bromide/ chloropicrin within the fullbed plastic mulch production system to control soil borne diseases and pests. There has been extensive research on alternatives for the sector, and where possible, many have been incorporated. In addition, there have been many studies done on yield comparing alternatives in the forest tree seedling sector to methyl bromide and these results provide insights into likely yield impacts in nursery rose and chrysanthemum production. Sources for the studies are The Methyl Bromide Alternatives Conference, applications for critical use exemptions, and case studies. For each alternative, the amount of studies done is as follows: Bare fallow and combinations 22; Basamid and combinations 76; Brozone 4; Captan and combinations 2; Cedar sawdust 2; Chloropicrin and combinations 56; Compost 3; Eptam ( EPTC) 12; Fallow 41; Formaldehyde 1; Grafting 1; Hot water 3; Methyl bromide 200 1; Methyl bromide 300 8; Metam Sodium ( Vapam) and combinations 19; Nemagon 2; other non chemicals 1; Silica sand 1; Solarization 1; Telone ( 1,3 dichloropropene) and combinations 6; Thiram 1; Triform and combinations 8.

However, the effectiveness of chemical and non chemical alternatives designed to fully replace methyl bromide in ornamental production must still be characterized as in a preliminary stage. These alternatives have not been shown to be stand alone replacements for methyl bromide. Methyl bromide is believed to be the only treatment currently available that consistently provides reliable control of nutsedge species and the disease complex affecting ornamental nursery production.

6c. Technical Feasibility of Alternatives Chrysanthemum Propagative Material   Technical Assessment Of the 18 alternatives identified by MBTOC for chrysanthemums for propagation material, only steam sterilization of the soil was regarded as technically and economically feasible. Complete adoption of steam sterilization as an alternative to methyl bromide is planned to be phased in over the next 5 6 years. 8 Table 1. Feasibility of Methyl Bromide Alternatives Identified by MBTOC for Chrysanthemum Cuttings.

Alternative Technical Feasibility Economic Feasibility 1,3 Dichloropropene ( Telone) No No 1,3 D + chloropicrin ( Telone C 17) No No Chloropicrin No No Metam Sodium ( Vapam ® , Busan ® , Nemasol ® ) No No Metam Sodium + chloropicrin No No Metam Sodium and Crop rotation No No Dazomet ( Basamid) No No Dazomet + Chloropicrin No No Steam Sterilization Yes Yes Flooding and water management No No Sanitation, general IPM. No No Crop rotation/ fallow No No Solarization No No Biological control No No Crop residue compost No No Soilless culture Yes No Plug production No No Biofumigation No No Chrysanthemum Cuttings   Technical Feasibility 1, 3 Dichloropropene ( Telone) and 1,3 D + chloropicrin ( Telone C 17). These alternatives are not technically feasible because the control of disease organisms with Telone is limited and the Telone / chloropicrin combination causes phytotoxicity damage to plants in adjacent beds.. Telone does not control Erwinia and Agrobacterium in plant debris. While bacteria are not specifically listed among the organisms controlled on the Telone label and specific research testing the efficacy of Telone products against bacteria have not been identified. The addition of chloropicrin would help control fungi and bacteria, but use of chloropicrin ( 25 percent chloropicrin combined with methyl bromide) causes damage to plants in the adjacent beds ( see chloropicrin discussion). Neither Telone alone or in combination with chloropicrin has much activity against weeds. Further, the buffer zone requirement ( 76 meters) and restricted entry interval ( 5 days) for Telone would limit use in the production areas because occupied structures fall within the buffer zone. 9 Chloropicrin. Chloropicrin is not technically feasible because it is not effective against nematodes or weeds. Approximately 20 percent of the yearly production of chrysanthemum cuttings are shipped to locations ( CA, HI, LA TX and Bermuda) that have quarantine requirements for nematodes ( Radopholus similes, Rotolenchus reniformis, Globodera spp., Heterodera spp.). Further, the continuous production techniques used by the grower make the use of chloropicrin technically not feasible because of its phytotoxicity that affects adjacent beds. Greenhouses and field blocks contain many adjacent beds that are sequentially planted and are in continuous production. Each bed only comes out of production for a 2 3 week period between crop cycles. Trials with MC 25 ( 75 percent methyl bromide, 25 percent chloropicrin) burned plants up to 12 beds away, despite the use of 10 ft. high side curtains to try to contain the chloropicrin. Although chloropicrin alone was not evaluated, the grower stated that chloropicrin used at a much lower concentration in the MC 25 mixture caused significant crop loss in adjacent beds. Additionally, workers harvesting several days later in adjacent, non treated beds experienced eye irritation.

Metam Sodium ( Vapam ® , Busan ® , Nemasol ® , and several other trade names). Metam Sodium is not a technically feasible alternative because is does not consistently control the target pests. Virtually all of the chrysanthemum cuttings for the North American market ( including Canada and Mexico), must meet pest free plant material requirements. Supplying pathogen and pest free plant material may not be possible using Metam Sodium and could put shipments at risk of rejection and possible loss of customers. There is no evidence that Metam Sodium will control Erwinia and Agrobacterium in plant debris. As with Telone, bacteria are not listed on the metamsodium label and specific research testing the efficacy of metam sodium products against bacteria have not been identified. Further, metam sodium requires irrigation to be most effective and does not penetrate into the soil as well as methyl bromide. This may result in erratic and less than adequate control of fungi and bacteria. Additional cultivation to aerate the soil before planting may be needed. Additional time may be necessary between crops as it may be up to 60 days before new crop can be planted, depending on rate of metam sodium used, and how quickly the fumigant clears from the soil. It is considered to be fairly effective against many weeds and moderately effective against fungi and nematodes.

While research suggests Basamid and metam sodium can, in some situations, provide effective pest control for certain diseases and weeds, research data suggest that these products can not be relied on to provide necessary consistency of results.

In spite of nearly 50 years experience with methyl isothiocyanate ( MITC) products   the breakdown active ingredient of both dazomet and metam sodium   efficacy has been unpredictable. This may be due to the significantly lower vapor pressure of MITC compared to methyl bromide, which affects the movement of gases through soils. Uniformity of fumigants throughout the soil is necessary for consistent and predictable results. MITC producing products, while at times effective, have been associated in the nursery industry with inconsistent production performance and reduced seedling quality ( based on research from forest seedling production studies). Both dazomet and metam sodium can provide effective pest management in some situations, but they have not been successful in providing consistently high quality forest tree seedlings especially with high nutsedge and pathogen pressure. Accordingly, it is reasonable to conclude that for ornamentals, it is likely that there could be similar issues. 10 Metam Sodium + chloropicrin. A metam sodium and chloropicrin combination is not technically feasible in the continuous production system used by the grower because of the adverse effects of chloropicrin. ( see Chloropicrin above).

Metam Sodium and Crop rotation. A metam sodium and crop rotation combination is not technically feasible because there are no other crops in rotation. Chrysanthemums are grown continuously at the Florida nurseries.

Dazomet ( Basamid) and Dazomet plus Chloropicrin. Dazomet alone and Dazomet in combination with chloropicrin are not technically feasible alternatives because they can result in a 7 percent to 37 percent yield loss, depending on the chrysanthemum variety. Additionally, there are grower reports of stem burning and poor rooting on several mum cultivars using Basamid in field trials conducted at their facilities. Moreover, although weeds and Fusarium spp. were controlled, Erwinia was recovered from mum crowns in plant debris from field trials treated with Basamid. If stock plants are replanted in field soil infested with Erwinia, they can develop systemic infections that go undetected until the plants are received by the customer and begin growing. Pathogen and insect free plant material are either quarantine or nursery stock requirements for supplying starter plants and using Basamid is too large a risk because of its inconsistency   using it runs a great risk of rejected shipments loss or even loss of customers.

While research suggests Basamid and metam sodium can, in some situations, provide effective pest control for certain diseases and weeds, research data suggest that these products can not be relied on to provide necessary consistency of results. Specifically, neither Basamid ® nor metam sodium ( e. g., Vapam ® , Busan ® ) consistently provide acceptable levels of control for key pests when used at label rates.

Steam Sterilization. Steam sterilization is technically feasible and is already being used. Steam sterilization does not result in either a quality or yield loss. Steam is effective against the major target pests listed. However, at this time, the applicant has equipment available to steam only 30 percent of the production fields. Adoption of this technique for all fields will require substantial additional capital investments as outlined in the proposal and described in the assessment of economic feasibility. It is estimated that it would take 5 6 years to acquire necessary capital for equipment investment to treat all hectares planted in chrysanthemum. Steam does require additional time to set up and take down the steaming equipment as compared with the time needed to apply methyl bromide. However, one advantage of steam over a chemical fumigant is that there is no waiting period needed for replanting when steam is used. The number of cropping cycles per year does not change with steam and the net impact on timing is negligible.

Flooding and water management. Flooding and water management are not technically feasible alternatives because they will not control the target pests. In some cases, flooding may actually make some of the diseases worse, such as Erwinia.

Sanitation, general IPM. Sanitation and general IPM, by themselves, are not technically feasible alternatives because they do not adequately control the target pests for sale of pest and pathogenfree starter plants. Although not sufficient by themselves to control the target pests, many sanitation 11 and general IPM methods are being used in chrysanthemum production. " Mother plants" at the Florida nurseries are planted in the fields and cuttings are harvested weekly. These cuttings are sent to nurseries throughout North America to produce finished chrysanthemums.

Crop rotation/ fallow. Crop rotation/ fallow is not technically feasible because it would not allow the grower to meet certification requirements for shipment of the propagative material. Research data does not support a conclusion that crop rotation/ fallow alone would control the target pests. Chrysanthemums are grown continuously on a 20 25 week cycle. No other crops are grown; the production areas are fumigated and replanted within 2 3 weeks of the final harvest of cuttings from the previous crop.

Solarization. Solarization is not a technically feasible alternative because it does not provide complete control of the pests/ pathogens listed for sale of pest free starter plants. The length of time between crop cycles would need to be increased by several weeks because solarization requires extended time period to have any effect on pests.

Biological control. Biocontrol is not a technically feasible alternative because no biological control has been developed to cover all the target pests/ pathogens.

Crop residue compost. Composting crop debris alone is not a technically feasible alternative because it would not control all the target pests to a degree necessary for sale of pest and pathogenfree starter plants. This alternative would not be practical in the field, within the time frame of this production system, since cops are planted continuously. If any debris was left uncomposted, it could serve as a reservoir for pathogens. The current practice is to remove the majority of the crop debris from the soil.

Soilless culture, plug production. Plug production is not technically feasible for production of chrysanthemum " mother plants". Although soilless culture would be a technically feasible alternative it would require much more time and money than to implement the best practicable methyl bromide alternative  steam. To switch to a soilless culture the current production practice would likely need to include such things as, building new or modifying existing greenhouses, building above ground benches, installing new irrigation systems, etc. In addition, research would be needed to determine whether the vigor of a soilless " mother plant" would allow for cutting over the extended 20 to 25 weeks.

Biofumigation. Biofumigation is not technically feasible because it would not likely provide the level of pest and pathogen control needed to produce certified pest free starter plants.

Nursery Roses   Technical and Economic Assessment Methyl bromide appears to be the standard chemical used to fumigate rose plant beds to ensure that the nursery roses can be consistently certified as pest free. Only two of the 13 alternatives identified by MBTOC are technically and/ or economically feasible ( Table 3), although results have been variable. 12 Table 2. Feasibility of Methyl Bromide Alternatives Identified by MBTOC for Nursery Rose Production. Alternative Technical Feasibility Economic Feasibility 1,3 Dichloropropene Regulatory limit on use Yes 1,3 Dichloropropene, Metam Sodium Regulatory limit on use Yes Basamid No No Metam Sodium No No Solarization No No Steam No No Biological Control No No Crop Residue/ Compost No No General IPM No No Grafting/ Resistant Rootstock/ Plant Breeding No No Physical Removal/ Sanitation No No Resistant Cultivars No No Substrates/ Plug Plants No No Nursery Roses   Technical Feasibility 1,3 Dichloropropene. 1,3 Dichloropropene is technically feasible and is already being used in some situations, especially in sandy soils where the soil moisture can be reduced to 12 percent or less. However, in addition to the possibility of a non certifiable crop, quality and size are taken into consideration in determining returns. Growers have reported that some portions of the nursery roses for shipment may be rejected without the entire shipment being in jeopardy of being rejected, but no specific numbers are available for these losses.

Although Telone appears to be an effective alternative to methyl bromide for nursery rose production, in California there are location specific Telone use restrictions. California regulations limit how much Telone can be used in specific locations called " townships" during a year. As a result, the growers in these specific " townships" cannot completely switch to using Telone instead of methyl bromide, because of the risk of not being able to obtain the alternative. The availability of 1,3 dichloropropene is potentially limited by the township cap. Within these specific " townships," all the growers of various crops, such as carrots, sweet potatoes, grapes, almonds and walnuts, compete for the limited quantity of Telone ( under the cap) that can used in the year. Once the cap is reached, the growers in the township will need to have another option for their soil fumigation production practices.

The U. S. is therefore nominating nursery roses in California to ensure growers have access to methyl bromide, once the Telone township cap is reached. California restricts the amount of Telone that can be used in certain locations because it is a hazardous air pollutant and a ground water contaminant. If the township cap is exceeded early in the year, when most of the crops are planted, there will not be any Telone available for growers to use later in the year. The California township caps for 13 Telone are fairly new and have not existed for many growing seasons, so it is difficult for the U. S. to predict how the Telone township cap may limit access in 2005. As a result, the U. S. views this nomination for California for a methyl bromide critical use exemption as a " contingent nomination." We consider it a " contingent nomination" because it is being submitted in the event that the growers of nursery roses in the specific townships face a situation in 2005, or 2006, when the Telone township cap is exceeded and they need to revert back to using methyl bromide.

The other crops that rose nurseries are competing with for Telone within the townships are carrots and almonds ( replant). If the situation should arise that the California Telone township cap limits access to Telone for nursery rose growers, the U. S. believes there would be a critical need for methyl bromide for the production of nursery roses. If, on the other hand, the Telone township cap is not reached, the nursery rose growers would not need to obtain any methyl bromide. As under the Essential Use Exemption allocation amounts for metered dose inhalers ( MDIs) in prior years, if a quantity of an ozone depleting substance is nominated and approved for an exemption, but some amount is not utilized ( not produced), the un utilized portion of the exemption would not adversely impact on the ozone layer. Instead, the approval of the exemption would be a crucial safety valve for a critical methyl bromide need, in case the ability to obtain Telone is denied due to California township cap regulation.

The rose production area has a known, high infestation of nematodes, and therefore a State of California certification standard was created to prevent the spread of these pests with the crop. According to California's nursery stock nematode regulation, farms can be treated with either methyl bromide or a dual application of Telone II, or, alternatively, the farmer may at great expense sample their fields to demonstrate the and show a complete absence of nematodes. Nursery rose growers rely on these treatments ( methyl bromide or a dual application of Telone II) to prevent rejection of their stock. Telone II treatments can be used in very limited cases with: ( 1) a known history of no nematodes, and ( 2) light soils, to meet the California's pest free certification requirement. The requested amount of methyl bromide in this U. S. nomination includes only those areas where the Telone II treatment cannot be used to meet the California certification requirements. A segment of each growers production may not need to meet the specific California nematode requirements because they are shipped out of state, but all other U. S. states have their own nursery stock pest free requirements. In general, nursery rose growers in California follow the more stringent California regulations to meet every other state's requirements for a nematode free product.

1,3 Dichloropropene/ Metam Sodium. The combination of 1,3 dichloropropene and metamsodium is technically feasible for addressing the target pests for nursery rose production in some situations. 1,3 Dichloropropene and metam sodium combined appears to be the most effective, currently available option, however, results have been highly variable and primarily dependent upon the soil moisture. In tests conducted using InLine, it was demonstrated that stubby root, stunt, and root knot nematode were controlled to a depth of 122 cm and stubby root and root knot were controlled to 1.3 meters. Stunt was not completely controlled at these depths and could still potentially result in rejection of the crop by a certifying agent.

Dazomet ( Basamid). Dazomet is not a technically feasible alternative because is does not adequately control target pests at deep enough levels in the soil. Dazomet and metam sodium are 14 both MITC generating substances and inability of MITC from metam sodium to penetrate deep enough at the maximum allowed application rate is likely to also be true for dazomet.

Metam Sodium. Metam Sodium is not a technically feasible alternative alone, because it results in nursery rose shipments that are not certifiable. Research indicates that a non certifiable crop occurs because metam sodium did not move deep enough into the soil. Tests conducted with high rates of metam sodium coupled with large quantities of water to increase movement in the soil have led to phytotoxicity problems. Rates needed for controlling target pests at 1.3 meters would exceed the current maximum allowable application rate, according to research results in walnut and peach trials. When metam sodium is combined with 1,3 dichloropropene and chloropicrin, and applied for weed control it appears to be useful in some production areas. In one rose trial using metam sodium, nematode control was achieved to a depth of 3 feet. Fungal pathogen control has been inadequate with this material applied alone.

Solarization, Steam Sterilization, Biological Control, Crop Residue/ Compost. These " not inkind alternatives are not technically feasible, by themselves to adequately control the target pests. The use of each of these techniques, by themselves, would not allow a nursery rose grower to meet the California certification standard.

General IPM, Grafting/ Resistant Rootstock/ Plant Breeding, Physical Removal/ Sanitation, Resistant Cultivars. Although these " not in kind" alternatives are being used by nursery rose growers to reduce pest pressure, in general, by themselves, each have not been successful at achieving adequate pest control. In addition, these " not in kind" alternatives alone would not allow the nursery rose grower to meet the certification standard of being nematode free.

Substrates/ Plug Plants. Use of " plug plants" is not technically feasible for nursery roses because virtually all production is by grafting on to resistant rootstock, not by the use of cuttings. Because roses are a deep rooted crop, it may be infeasible to shift from a field grown production system to an untried greenhouse production system ( substrates/ soilless culture). Research would need to be conducted to determine the commercial feasibility of make a change of this magnitude to a soilless culture.

6d. Economic Feasibility of Alternatives The economic assessment of feasibility for pre plant uses of methyl bromide included an evaluation of economic losses from three basic sources: ( 1) yield losses, referring to reductions in the quantity produced, ( 2) quality losses, which generally affect the price received for the goods, and ( 3) increased production costs, which may be due to the higher cost of using an alternative, additional pest control requirements, and/ or resulting shifts in other production or harvesting practices.

The economic reviewers then analyzed crop budgets for pre plant sectors to determine the likely economic impact if methyl bromide were unavailable. Various measures were used to quantify the impacts, including the following:

( 1) Losses as a percent of gross revenues. This measure has the advantage that gross revenues are usually easy to measure, at least over some unit, e. g., a hectare of land or a storage operation. 15 However, high value commodities or crops may provide high revenues but may also entail high costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity.

( 2) Absolute losses per hectare. For crops, this measure is closely tied to income. It is relatively easy to measure, but may be difficult to interpret in isolation.

( 3) Losses per kilogram of methyl bromide requested. This measure indicates the value of methyl bromide to crop production but is also useful for structural and post harvest uses.

( 4) Losses as a percent of net cash revenues. We define net cash revenues as gross revenues minus operating costs. This is a very good indicator as to the direct losses of income that may be suffered by the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify.

( 5) Changes in profit margins. We define profit margin to be profits as a percentage of gross revenues, where profits are gross revenues minus all fixed and operating costs. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more difficult.

These measures represent different ways to assess the economic feasibility of methyl bromide alternatives for methyl bromide users, who are producers of chrysanthemum cuttings and nursery roses in this case. Because producers ( suppliers) represent an integral part of any definition of a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

Chrysanthemum Cuttings  Economic Feasibility The major producer of chrysanthemum propagative material in the U. S. ( 90 percent of the North American market) is committed to a shifting to steam over the next 5 to 6 years, contingent on a projected time line for making sequential investments in capital equipment. For propagation material production, steam sterilization of the soil is listed as the most viable alternative, from a technical standpoint. The available data indicate that steam sterilization will reduce profits although profits remain positive. However, because use of steam requires a significant capital investment, reported economic impacts must be viewed with caution. Steam sterilization is economically feasible even though profits are estimated to fall by about US$ 7,700 per hectare per crop cycle ( Table 3), and there are typically 2 crop cycles per year. The increased cost of steam represents approximately a 2 percent change in gross revenue and therefore steam is viewed as the long term alternative. The planned to switch to steam is already underway and it will eventually replace methyl bromide for chrysanthemum production.

Results in Table 3 do not appropriately account for the time needed to acquire the capital requirements for steam sterilization. Because of the capital requirement for steam sterilization, the applicant will need time to acquire the financial resources and purchase and install the needed 16 equipment before being able to fully convert to steam sterilization. The applicant projects that full conversion will require an additional 5 6 years.

Table 3. Measures of Economic Impact on the Chrysanthemum Propagation Material Producer Changing from Methyl Bromide Soil Fumigation to Steam Sterilization. Loss Measure Steam Sterilization compared with methyl bromide Per hectare per crop cycle US$ 7,700 Per kg methyl bromide US$ 8.70 Percent of gross revenue 2 % Percent of net cash returns 18 %

Note: All economic impacts are assumed to be due to the increased costs of steam sterilization.

Nursery Roses   Economic Feasibility For nursery rose production, Telone or a combination of Telone and metam sodium is feasible on sandy soils with 12 percent or less moisture. Although Telone alone, and Telone combinations, may be technically and economically feasible alternatives in these locations to control key pests, these techniques could become unavailable to nursery rose growers if the limit on the amount of Telone that can be used in a California township is reached because of other uses of Telone in agricultural crop production. The nursery rose growers being nominated for a critical use exemption are primarily located in Kern county, California. Again, it is worth noting that within Kern county, the other crops that rose nurseries are competing with for Telone within the townships are carrots and almonds ( replant).

The U. S. nomination for nursery rose production analyzed cost information and yield loss scenarios for the alternative regimen of using tarped Telone EC applications plus hand weeding. The results of these analyses are below in Table 4.

Table 4. Measures of Economic Impact on the Rose Producer Changing from Methyl Bromide Soil Fumigation to the Use of 1,3 Dichloropropene with Hand Weeding. Loss Measure 1,3 D with 5% yield loss scenario 1,3 D with 10% yield loss scenario Per hectare US$ 3,500 US$ 7,400 Per kg methyl bromide US$ 10.30 US$ 21.75 Percent of gross revenue 4 % 9 % Percent of net cash returns 8 % 16 % Note: Impacts due primarily to yield losses.

7. Critical Use Exemption ( CUE) Nomination for Ornamental Nurseries This nomination is for a critical use exemption for methyl bromide for the ornamental nursery sector, specifically production of chrysanthemum propagative material and nursery roses. The actual 17 amount requested was 268,000 kilograms of methyl bromide is needed to treat 715 hectares. The average application rates for these uses and states conform to standard practices.

The U. S. interdisciplinary review team found a critical need for methyl bromide for production of chrysanthemum propagative material and nursery roses. Most of the alternatives identified by the MBTOC were, as reviewed in detail above, regarded by reviewers as technically and economically infeasible for acceptable management of the major pests.

The chrysanthemum request is for a grower who produces approximately 90 percent ( 185 million cuttings per year) of the North American chrysanthemum propagation material. The grower is nominated for treating 35 hectares in 2005 with methyl bromide. Please note that the grower expects this area with a critical need for methyl bromide to decline to 25 hectares in 2006 and 14 hectares in 2007, as the use of steam sterilization is increased. Complete adoption of steam sterilization as an alternative to methyl bromide is planned to be phased in over the next 5 6 years.

Table 5. Methyl Bromide Usage and Critical Use Exemption Request for the Production of Chrysanthemum Cuttings in the U. S.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 42,725 44,176 35,001 40,034 36,187 31,593 22,205 12,637 hectares 49 50 40 46 41 35 25 14 rate ( kg/ ha) 880 880 879 879 881 892 896 892 The nursery rose request is for California rose production. The U. S. estimates that 235,868 kilograms of methyl bromide is needed for 2005 to fumigate 680 hectares. Application rates for this crop appear to be typical for this region ( Table 6).

Roses must be " commercially clean" as defined by the requirements of the Regulations for the Nursery Stock Nematode Certification Program, California Code of Regulations. All material being sold can be inspected and rejected as not being " commercially clean," regardless of the soil treatment used in production.

Of the 13 MBTOC alternatives identified for roses, all but two ( 1,3 D [ Telone] and 1,3 D [ Telone] combined with metam sodium) were regarded as not being technically feasible. Economic analysis of these two technically feasible alternatives indicate a 4 and 9 percent loss of gross revenues, 18 respectively. California rose production represents about 60 percent of total U. S. production. Many research studies on the efficacy of MIDAS ( iodomethane with chloropicrin) and metam sodium or other weed control measures are underway and are expected to continue over the next few years.

Table 6. Methyl Bromide Usage and Critical Use Exemption Request for the Production of Nursery Roses in the U. S.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 205,613 201.803 204,933 217,588 235,868 235,868 235,868 hectares 611 600 609 647 645 680 680 680 rate ( kg/ ha) 336 336 336 336 341 347 347 347 The U. S. nomination ( Table 7) has been determined based first on consideration of the requests we received and an evaluation of the supporting material. This evaluation, which resulted in a reduction in the amount being nominated, included careful examination of issues including the area infested with the key target ( economically significant) pests for which methyl bromide is required, 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, among other factors.

Table 7. Methyl Bromide Critical Use Exemption Nomination for Ornamentals Year Total Request by Applicants ( kilograms) U. S. Sector Nomination ( kilograms)

2005 267,461 29,412 8. Minimizing Use/ Emissions of Methyl Bromide in the United States/ Stockpiles In accordance with the criteria of the critical use exemption, we will now describe ways in which we strive to minimize use and emissions of methyl bromide. While each sector based nomination includes information on this topic, we thought it would be useful to provide some general information that is applicable to most methyl bromide uses in the country The use of methyl bromide in the United States is minimized in several ways. First, because of its toxicity, methyl bromide is regulated as a restricted use pesticide in the United States. As a consequence, methyl bromide can only be used by certified applicators who are trained at handling these hazardous pesticides. In practice, this means that methyl bromide is applied by a limited number of very experienced applicators with the knowledge and expertise to minimize dosage to the lowest level possible to achieve the needed results. In keeping with both local requirements to avoid " drift" of methyl bromide into inhabited areas, as well as to preserve methyl bromide and keep related emissions to the lowest level possible, methyl bromide is machine injected into soil to specific depths. In addition, as methyl bromide has become more scarce, users in the United States 19 have, where possible, experimented with different mixes of methyl bromide and chloropicrin. Specifically, in the early 1990s, methyl bromide was typically sold and used in methyl bromide mixtures made up of 98% methyl bromide and 2% chloropicrin, with the chloropicrin being included solely to give the chemical a smell enabling those in the area to be alerted if there was a risk. However, with the outset of very significant controls on methyl bromide, users have been experimenting with significant increases in the level of chloropicrin and reductions in the level of methyl bromide. While these new mixtures have generally been effective at controlling target pests, it must be stressed that the long term efficacy of these mixtures is unknown. Reduced methyl bromide concentrations in mixtures, more mechanized soil injection techniques, and the extensive use of tarps to cover land treated with methyl bromide has resulted in reduced emissions and an application rate that we believe is among the lowest in the world.

In terms of compliance, in general, the United States has used a combination of tight production and import controls, and the related market impacts to ensure compliance with the Protocol requirements on methyl bromide. Indeed, over the last   years, the price of methyl bromide has increased substantially. As Chart 1 in Appendix D demonstrates, the application of these policies has led to a more rapid U. S. phasedown in methyl bromide consumption than required under the Protocol. This accelerated phasedown on the consumption side may also have enabled methyl bromide production to be stockpiled to some extent to help mitigate the potentially significant impacts associated with the Protocol's 2003 and 2004 70% reduction. We are currently uncertain as to the exact quantity of existing stocks going into the 2003 season that may be stockpiled in the U. S. We currently believe that the limited existing stocks are likely to be depleted during 2003 and 2004. This factor is reflected in our requests for 2005 and beyond.

At the same time we have made efforts to reduce emissions and use of methyl bromide, we have also made strong efforts to find alternatives to methyl bromide. The section that follows discusses those efforts.

9. U. S. Efforts to Find, Register and Commercialize Alternatives to Methyl Bromide Over the past ten years, the United States has committed significant financial and technical resources to the goal of seeking alternatives to methyl bromide that are technically and economically feasible to provide pest protection for a wide variety of crops, soils, and pests, while also being acceptable in terms of human health and environmental impacts. The U. S. pesticide registration program has established a rigorous process to ensure that pesticides registered for use in the United States do no present an unreasonable risk of health or environmental harm. Within the program, we have given the highest priority to rapidly reviewing methyl bromide alternatives, while maintaining our high domestic standard of environmental protection. A number of alternatives have already been registered for use, and several additional promising alternatives are under review at this time. Our research efforts to find new alternatives to methyl bromide and move them quickly toward registration and commercialization have allowed us to make great progress over the last decade in phasing out many uses of methyl bromide. However, these efforts have not provided effective alternatives for all crops, soil types and pest pressures, and we have accordingly submitted a critical use nomination to address these limited additional needs. 20 Research Program When the United Nations, in 1992, identified methyl bromide as a chemical that contributes to the depletion of the ozone layer and the Clean Air Act committed the U. S. to phase out the use of methyl bromide, the U. S. Department of Agriculture ( USDA) initiated a research program to find viable alternatives. Finding alternatives for agricultural uses is extremely complicated compared to replacements for other, industrially used ozone depleting substances because many factors affect the efficacy such as: crop, climate, soil type, and target pests, which change from region to region and even among localities within a region.

Through 2002, the USDA Agricultural Research Service ( ARS) alone has spent US$ 135.5 million to implement an aggressive research program to find alternatives to methyl bromide ( see Table below). Through the Cooperative Research, Education and Extension Service, USDA has provided an additional $ 11.4m since 1993 to state universities for alternatives research and outreach. This federally supported research is a supplement to extensive sector specific private sector efforts, and that all of this research is very well considered. Specifically, the phaseout challenges brought together agricultural and forestry leaders from private industry, academia, state governments, and the federal government to assess the problem, formulate priorities, and implement research directed at providing solutions under the USDA's Methyl Bromide Alternatives program. The ARS within USDA has 22 national programs, one of which is the Methyl Bromide Alternatives program ( Select Methyl Bromide Alternatives at this web site: http:// www. nps. ars. usda. gov). The resulting research program has taken into account these inputs, as well as the extensive private sector research and trial demonstrations of alternatives to methyl bromide. While research has been undertaken in all sectors, federal government efforts have been based on the input of experts as well as the fact that nearly 80 percent of preplant methyl bromide soil fumigation is used in a limited number of crops. Accordingly, much of the federal government pre plant efforts have focused on strawberries, tomatoes, ornamentals, peppers and nursery crops, ( forest, ornamental, strawberry, pepper, tree, and vine), with special emphasis on tomatoes in Florida and strawberries in California as model crops. 21 Table 8: Methyl Bromide Alternatives Research Funding History Year Expenditures by the U. S. Department of Agriculture ( US$ Million)

1993 $ 7.255 1994 $ 8.453 1995 $ 13.139 1996 $ 13.702 1997 $ 14.580 1998 $ 14.571 1999 $ 14.380 2000 $ 14.855 2001 $ 16.681 2002 $ 17.880 The USDA/ ARS strategy for evaluating possible alternatives is to first test the approaches in controlled experiments to determine efficacy, then testing those that are effective in field plots. The impact of the variables that affect efficacy is addressed by conducting field trials at multiple locations with different crops and against various diseases and pests. Alternatives that are effective in field plots are then tested in field scale validations, frequently by growers in their own fields. University scientists are also participants in this research. Research teams that include ARS and university scientists, extension personnel, and grower representatives meet periodically to evaluate research results and plan future trials.

Research results submitted with the CUE request packages ( including published, peer reviewed studies by ( primarily) university researchers, university extension reports, and unpublished studies) include trials conducted to assess the effectiveness of the most likely chemical and non chemical alternatives to methyl bromide, including some potential alternatives that are not currently included in the MBTOC list.

As demonstrated by the table above, U. S. efforts to research alternatives for methyl bromide have been substantial, and they have been growing in size as the phaseout has approached. The United States is committed to sustaining these research efforts in the future to continue to aggressively search for technically and economically feasible alternatives to methyl bromide. We are also committed to continuing to share our research, and enable a global sharing of experience. Toward that end, for the past several years, key U. S. government agencies have collaborated with industry to host an annual conference on alternatives to methyl bromide. This conference, the Methyl Bromide Alternatives Outreach ( MBAO), has become the premier forum for researchers and others to discuss scientific findings and progress in this field. 22 While the U. S. government's role to find alternatives is primarily in the research arena, we know that research is only one step in the process. As a consequence, we have also invested significantly in efforts to register alternatives, as well as efforts to support technology transfer and education activities with the private sector.

Government funded studies related to U. S. ornamental nursery production that are currently ongoing include the following:

1. Alternatives to Methyl Bromide for Management of Soilborne Pathogens in Ornamental Crops ( Apr 1999  Jun 2003) Identify and evaluate botanical compounds for activity against soilborne pathogens, including plot and field testing. Develop integrated disease control systems utilizing botanical compounds in combination with other strategies including biological control and modified cultural practices. Characterize the ecology of soilborne pathogens and beneficial microorganisms following treatment of soil with botanicals alone and in combination with other treatments.

2. Control of Plant Parasitic Nematodes and Root Diseases in Ornamental Production Systems ( Sep 2000  Sep 2003) Develop methods to effectively control root lesion and root knot nematodes in ornamental production systems. Reduce transmission of root disease pathogens via irrigation water.

3. Management of Root Knot Nematodes in Field Production of Floral and Ornamental Crops ( Sep 2001  Aug 2003) To assess the benefits of integrating practices such as soil solarization, cover crops, resistant cultivars, and environmentally compatible chemicals for effective control of root knot and other plant parasite nematodes in ornamental production systems. As resources permit, research will be conducted on novel approaches to manipulating soil environments common to ornamental production systems so that they are suppressive to root knot nematodes, yet encouraging or neutral to ornamentals and non target plants.

4. Alternatives to Methyl Bromide Soil Fumigation for Vegetable Production and Floriculture/ nursery Crops ( Apr 1999  Apr 2004) Identify impact of pest management tactics on functional diversity of soil microflora and weed populations, their competitive interactions, & effects on crop health. Develop Integrated Pest Management ( IPM) systems to include chemical and non chemical components to replace methyl bromide soil treatments for growing floriculture & related nursery crops to allow continued profitable operation of this industry after the ban of methyl bromide in January 2005.

5. Disease Management in Ornamental Crops ( UC Davis/ CSREES  Oct 1999  Sep 2004) To develop new technologies for the control of plant pathogens. Work will include research to develop alternatives to methyl bromide for controlling soil borne pathogens, methods for eliminating 23 water borne pathogens in recycled irrigation water, and technologies for effective, environmentallyresponsible control of powdery mildew in greenhouse roses.

Research results submitted with the critical use exemption request packages ( including published, peer reviewed studies by ( primarily) university researchers, university extension reports, and unpublished studies) include trials conducted to assess the effectiveness of the most likely chemical and non chemical alternatives to methyl bromide, including some potential alternatives that are not currently included in the MBTOC list.

Chrysanthemum Propagative Material Steam sterilization appears to be the best alternative regimen to methyl bromide. However, it is more expensive to use than methyl bromide and several other chemical alternatives, and the grower currently lacks the capacity to steam the entire production area. One applicant stated that it should be possible to develop sufficient capacity within 5 6 years for steam sterilization. A strong research plan is ongoing and more than US$ 1 million has been spent evaluating steam and other methyl bromide alternatives. This new research includes studies with methyl iodide at different application rates, even though it is not currently registered for use on this crop, trials with steam sterilization, MC 25, Sectagon, and VIF. Additionally, research should be supported to develop more energyefficient cost effective portable steam units for field use.

Nursery Roses Registration of MIDAS ( iodomethane with chloropicrin) appears to be the best solution to replace the use of methyl bromide on this crop. Studies have shown the control of all nematode genera found on roses at a depth of 1.3 meters. This treatment is likely to require some additional weed control measures, but does provide weed control that is comparable to methyl bromide in many cases. Many studies are currently underway and are in the first year or beginning the second year of testing. This research includes:

$ Field fumigation trials looking at Telone C 35 and methyl iodide and their impact on weed control, phytotoxicity, and crop yield. These trials will be conducted in California from 2001 2002.

$ Evaluations on a commercial rose grower field of iodomethane, Telone II EC, an iodomethane and chloropicrin combination, and metam sodium. This on going project will be conducted in California until 2003.

$ An soil fumigation trial testing a telone and chloropicrin combination, a telone plus Ridomyl combination, and a K Pam ( potassium methane) and telone combination on nematode control, soil borne disease control and weed control. These trials were conducted in 2002 in California.

Research in application technology ( e. g., injection methods and application rates) may improve the uniformity of soil movement of chemicals, such as metam sodium. Non chemical alternatives have been incorporated and methods such as IPM, mulching, solarization, and biofumigation are being 24 examined as part of an overall strategy to manage ornamental nursery production, in general. Trials evaluating compost based systems as alternatives for chemical based fumigations are already being conducted. These trials will continue and weed ratings, disease incidence, and crop yield data will be collected.

As demonstrated by the chart above, U. S. efforts to research alternatives for methyl bromide have been substantial, and they have been growing in size as the phaseout has approached. The U. S. is committed to sustaining its research efforts out into the future until technically and economically viable alternatives are found for each and every controlled use of methyl bromide. We are also committed to continuing to share our research, and enable a global sharing of experience. Toward that end, for the past several years, key U. S. government agencies have collaborated with industry to host an annual conference on alternatives to methyl bromide. This conference, the Methyl Bromide Alternatives Outreach ( MBAO), has become the premier forum for researchers and others to discuss scientific findings and progress in this field.

Registration Program The United States has one of the most rigorous programs in the world for safeguarding human health and the environment from the risks posed by pesticides. While we are proud of our efforts in this regard, related safeguards do not come without a cost in terms of both money and time. Because the registration process is so rigorous, it can take a new pesticide several years ( 3 5) to get registered by EPA. It also takes a large number of years to perform, draft results and deliver the large number of health and safety studies that are required for registration.

The U. S. EPA regulates the use of pesticides under two major federal statutes: the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) and the Federal Food, Drug, and Cosmetic Act ( FFDCA), both significantly amended by the Food Quality Protection Act of 1996 ( FQPA). Under FIFRA, U. S. EPA registers pesticides provided its use does not pose unreasonable adverse effects to humans or the environment. Under FFDCA, the U. S. EPA is responsible for setting tolerances ( maximum permissible residue levels) for any pesticide used on food or animal feed. With the passage of FQPA, the U. S. EPA is required to establish a single, health based standard for pesticides used on food crops and to determine that establishment of a tolerance will result in a " reasonable certainty of no harm" from aggregate exposure to the pesticide.

The process by which U. S. EPA examines the ingredients of a pesticide to determine if they are safe is called the registration process. The U. S. EPA evaluates the pesticide to ensure that it will not have any unreasonable adverse effects on humans, the environment, and non target species. Applicants seeking pesticide registration are required to submit a wide range of health and ecological effects toxicity data, environmental fate, residue chemistry and worker/ bystander exposure data and product chemistry data. A pesticide cannot be legally used in the U. S. if it has not been registered by U. S. EPA, unless it has an exemption from regulation under FIFRA.

Since 1997, the U. S. EPA has made the registration of alternatives to methyl bromide a high registration priority. Because the U. S. EPA currently has more applications for all types of 25 pesticides pending in its review process than resources to evaluate them, U. S. EPA prioritizes the applications in its registration queue. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review. This review process takes an average of 38 months to complete. Additionally, the registrant ( the pesticide applicant) has, in most cases, spent approximately 7 10 years developing the data necessary to support registration.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the U. S. EPA has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the U. S. EPA's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the U. S. EPA has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, U. S. EPA scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability that the data is done right the first time and rework delays are minimized The U. S. EPA has also co chaired the USDA/ EPA Methyl Bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. The work group conducted six workshops in Florida and California ( states with the highest use of methyl bromide) with growers and researchers to identify potential alternatives, critical issues, and grower needs covering the major methyl bromide dependent crops and post harvest uses.

This coordination has resulted in key registration issues ( such as worker and bystander exposure through volatilization, township caps and groundwater concerns) being directly addressed through USDA's Agricultural Research Service's $ 13.5 million per year research program conducted at more than 20 field evaluation facilities across the country. Also EPA's participation in the evaluation of research grant proposals submitted to the USDA's Cooperative State Research, Education, and Extension Service methyl bromide alternatives research program of US$ 2.5 million per year has further ensured that critical registration issues are being addressed by the research community.

Since 1997, EPA has registered the following chemical/ use combinations as part of its commitment to expedite the review of methyl bromide alternatives:

1999: Pebulate to control weeds in tomatoes 2000: Phosphine to control insects in stored commodities 2001: Indian Meal Moth Granulosis Virus to control Indian meal moth in stored grains 2001: Terrazole to control pathogens in tobacco float beds 2001: Telone applied through drip irrigation  all crops 2002: Halosulfuron methyl to control weeds in melons and tomatoes EPA is currently reviewing several additional applications for registration as methyl bromide alternatives, with several registration eligibility decisions expected within the next year, including: 26   Iodomethane as a pre plant soil fumigant for various crops   Fosthiazate as a pre plant nematicide for tomatoes   Sulfuryl fluoride as a post harvest fumigant for stored commodities   Trifloxysulfuron sodium as a pre plant herbicide for tomatoes   Dazomet as a pre plant soil fumigant for strawberries and tomatoes Again, while these activities appear promising, it must be noted that issues related to toxicity, ground water contamination, and the release of air pollutants may pose significant problems with respect to some alternatives that may lead to use restrictions since many of the growing regions are in sensitive areas such as those in close proximity to schools and homes. Ongoing research on alternate fumigants is evaluating ways to reduce emission under various application regimes and examining whether commonly used agrochemicals, such as fertilizers and nitrification inhibitors, could be used to rapidly degrade soil fumigants. For example, if registration of iodomethane or another alternative occurs in the near future, commercial availability and costs will be factors that must be taken into consideration.

Several additional, promising alternatives are under review at U. S. EPA that may be able to be used on ornamental nursery crops in the future. These include: iodomethane ( methyl iodide) and propargyl bromide, which currently look very promising in field studies. Although iodomethane is chemically similar to methyl bromide, it photodegrades before it reaches the stratosphere, and therefore is not a significant ozone depleter. While iodomethane and propargyl bromide are not currently registered for use as pesticides in the U. S., research on combinations of pesticides with chemicals like methyl iodide are also planned. Again, while these activities appear promising, it must be noted that concerns about toxicity, ground water contamination, and the release of air pollutants regarding some alternatives presents another difficulty that may restrict use since many of the growing regions are in sensitive areas such as those in close proximity to schools and homes. Ongoing research on alternate fumigants is evaluating ways to reduce emission under various application regimes and examining whether commonly used agrochemicals, such as fertilizers and nitrification inhibitors, could be used to rapidly degrade soil fumigants. If registration of iodomethane or propargyl bromide occurs in the near future, commercial availability and costs will be factors that must be taken into consideration.

It must be emphasized, however, that finding potential alternatives, and even registering those alternatives is not the end of the story. Alternatives must be tested by users and found to be technically and economically feasible before they are widely adopted. As noted by TEAP, a specific alternative, once available may take two or three cropping seasons of use before efficacy can be determined in the specific circumstance of the user. In an effort to speed adoption, the U. S. government has also been involved in these steps by promoting technology transfer, experience transfer, and private sector training.

10. Conclusion and Policy Issues Associated with the Nomination On the basis of an exhaustive review of a large, multi disciplinary team of sector and general agricultural experts, we have determined that the TEAP listed potential alternatives for the specific 27 crops and areas covered in this nomination are not currently technically or economically viable from the standpoint of United States growers covered by this exemption request. We have also determined that the absence of methyl bromide for the nominated uses will result in a significant market disruption to the effected sectors. We have and continue to expend significant efforts to find and commercialize alternatives, and that potential alternatives to the use of methyl bromide for many important uses are under investigation and may be on the horizon. Based on this analysis, we believe those requests included in this nomination meet the criteria set out by the Parties in Decision IX/ 6.

In accordance with those Decisions, we believe that the U. S. nomination contained in this document provides all of the information that has been requested by the Parties. On the basis of an exhaustive review of a large, multi disciplinary team of sector and general agricultural experts, we have determined that the MBTOC listed potential alternatives for the ornamental nursery sector are not currently technically or economically feasible from the standpoint of U. S. for the growers of chrysanthemum propagative material and nursery roses covered by this exemption nomination. In addition, we have demonstrated that we have and continue to expend significant efforts to find and commercialize alternatives, and that potential alternatives to the use of methyl bromide for chrysanthemums and nursery roses may be on the horizon. The registration process, which is designed to ensure that new pesticides do not pose unreasonable risks to human health and the environment, is long and rigorous. The U. S. need for methyl bromide for chrysanthemums and nursery roses will be maintained for the period being requested.

In reviewing this nomination, we believe that it is important for the MBTOC, the TEAP and the Parties to understand some of the policy issues associated with our request. A discussion of those follows:

a. Request for Aggregate Exemption for All Covered Methyl Bromide Uses: As mandated by Decision XIII/ 11, the nomination information that is being submitted with this package includes information requested on historic use and estimated need in individual sectors. That said, we note our agreement with past MBTOC and TEAP statements which stress the dynamic nature of agricultural markets, uncertainty of specific production of any one crop in any specific year, the difficulty of projecting several years in advance what pest pressures might prevail on a certain crop, and, the difficulty of estimating what a particular market for a specific crop might look like in a future year. We also concur with the MBTOC's fear that countries that have taken significant efforts to reduce methyl bromide use and emissions through dilution with chloropicrin may be experiencing only short term efficacy in addressing pest problems. On the basis of those factors, we urge the MBTOC and the TEAP to follow the precedent established under the essential use exemption process for Metered Dose Inhalers ( MDIs) in two key areas.

First, because of uncertainties in both markets and the future need for individual active moieties of drugs, the TEAP has never provided a tonnage limit for each of the large number of active moieties found in national requests for a CFC essential use exemption for MDIs, but has instead recommended an aggregate tonnage exemption for national use. This has been done with an understanding that the related country will ensure that the tonnage approved for an exemption will 28 be used solely for the group of active moieties/ MDIs that have been granted the exemption. We believe that the factors of agricultural uncertainty surrounding both pest pressures in future year crops, and efficacy of reduced methyl bromide application provide an even stronger impetus for using a similar approach here. The level of unpredictability in need leads to a second area of similarity with MDIs, the essential need for a review of the level of the request which takes into account the need for a margin of safety.

b. Recognition of Uncertainty in Allowing Margin for Safety: With MDIs, it was essential to address the possible change in patient needs over time, and in agriculture, this is essential to address the potential that the year being requested for could be a particularly bad year in terms of weather and pest pressure. In that regard, the TEAP's Chart 2 in Appendix D demonstrates the manner in which this need for a margin of safety was addressed in the MDI area. Specifically, Chart 2 in Appendix D tracks national CFC requests for MDIs compared with actual use of CFC for MDIs over a number of years.

Chart 2 in Appendix D demonstrates several things. First, despite the best efforts of many countries to predict future conditions, it shows that due to the acknowledged uncertainty of out year need for MDIs, Parties had the tendency to request, the TEAP recommended, and the Parties approved national requests that turned out to include an appreciable margin of safety. In fact, this margin of safety was higher at the beginning   about 40% above usage   and then went down to 30% range after 4 years. Only after 5 years of experience did the request come down to about 10% above usage. While our experience with the Essential Use process has aided the U. S. in developing its Critical Use nomination, we ask the MBTOC, the TEAP and the Parties to recognize that the complexities of agriculture make it difficult to match our request exactly with expected usage when the nomination is made two to three years in advance of the time of actual use.

Chart 2 in Appendix D also demonstrates that, even though MDI requests included a significant margin of safety, the nominations were approved and the countries receiving the exemption for MDIs did not produce the full amount authorized when there was not a patient need. As a result, there was little or no environmental consequence of approving requests that included a margin of safety, and the practice can be seen as being normalized over time. In light of the similar significant uncertainty surrounding agriculture and the out year production of crops which use methyl bromide, we wish to urge the MBTOC and TEAP to take a similar, understanding approach for methyl bromide and uses found to otherwise meet the critical use criteria. We believe that this too would have no environmental consequence, and would be consistent with the Parties aim to phaseout methyl bromide while ensuring that agriculture itself is not phased out.

c. Duration of Nomination: It is important to note that while the request included for the use above appears to be for a single year, the entire U. S. request is actually for two years   2005 and 2006. This multi year request is consistent with the TEAP recognition that the calendar year does not, in most cases, correspond with the cropping year. This request takes into account the facts that registration and acceptance of new, efficacious alternatives can take a long time, and that alternatives must be tested in multiple cropping cycles in different geographic locations to determine efficacy and consistency before they can be considered to be widely available for use. Finally, the request for 29 multiple years is consistent with the expectation of the Parties and the TEAP as evidenced in the Parties and MBTOC request for information on the duration of the requested exemption. As noted in the Executive Summary of the overall U. S. request, we are requesting that the exemption be granted in a lump sum of 9,920,965 kilograms for 2005 and 9,445,360 kilograms for 2006. While it is our hope that the registration and demonstration of new, cost effective alternatives will result in even speedier reductions on later years, the decrease in our request for 2006 is a demonstration of our commitment to work toward further reductions in our consumption of methyl bromide for critical uses. At this time, however, we have not believed it possible to provide a realistic assessment of exactly which uses would be reduced to account for the overall decrease.

11. Contact Information For further general information or clarifications on material contained in the U. S. nomination for critical uses, please contact:

John E. Thompson, Ph. D. Office of Environmental Policy US Department of State 2201 C Street NW Rm 4325 Washington, DC 20520 tel: 202 647 9799 fax: 202 647 5947 e mail: ThompsonJE2@ state. gov Alternate Contact: Denise Keehner, Director Biological and Economic Analysis Division Office of Pesticides Programs US Environmental Protection Agency, 7503C Washington, DC 20460 tel: 703 308 8200 fax: 703 308 8090 e mail: methyl. bromide@ epa. gov 12. References Gamini, S. and R. K. Nishimoto. 1987. Propagules of purple nutsedge ( Cyperus rotundus) in soil. Weed Technol. 1: 217 220.

Gilreath, J. P., J. W. Noling, and P. R. Gilreath. 1999. Nutsedge management with cover crop for tomato in the absence of methyl bromide. Research summary, USDA Specific Cooperative Agreement 58 6617 6 013. 30 Holm, L. G., D. L. Plucknett, J. V. Pancho, and J. P. Herberger. 1977. The world's worst weeds: distribution and biology. Honolulu, HI: University of Hawaii Press, pp. 8 24.

Patterson, D. T. 1998. Suppression of purple nutsedge ( Cyperus rotundus) with polyethylene film mulch. Weed Technol. 12: 275 280.

Thullen, R. J. and P. E. Keeley. 1975. Yellow nutsedge sprouting and resprouting potential. Weed Sci. 23: 333 337.

Webster, T. M. and G. E. Macdonald. 2001. A survey of weeds in various crops in Georgia. Weed Technol. 15: 771 790.

13. Appendices Appendix A. List of Critical Use Exemption Requests for U. S. Ornamental Nurseries CUE 02 0020: Yoder Brothers, Chrysanthemum Propagation Material CUE 02 0028: California Rose Growers represented by the Garden Rose Council Appendix B. Spreadsheets Supporting Economic Analysis This appendix presents the calculations, for each sector, that underlie the economic analysis presented in the main body of the nomination chapter. As noted in the nomination chapter, each sector is comprised of a number of applications from users of methyl bromide in the United States, primarily groups ( or consortia) of users. The tables below contain the analysis that was done for each individual application, prior to combining them into a sector analysis. Each application was assigned a unique number ( denoted as CUE #), and an analysis was done for each application for technically feasible alternatives. Some applications were further sub divided into analyses for specific sub regions or production systems. A baseline analysis was done to establish the outcome of treating with methyl bromide for each of these scenarios. Therefore, the rows of the tables correspond to the production scenarios, with each production scenario accounting for row and the alternative( s) accounting for additional rows.

The columns of the table correspond to the estimated impacts for each scenario. ( The columns of the table are spread over several pages because they do not fit onto one page.) The impacts for the methyl bromide baseline are given as zero percent, and the impacts for the alternatives are given relative to this baseline. Loss estimates include analyses of yield and revenue losses, along with estimates of increased production costs. Losses are expressed as total losses, as well as per unit treated and per kilogram of methyl bromide. Impacts on profits are also provided. 31 After the estimates of economic impacts, the tables contain basic information about the production systems using methyl bromide. These columns include data on output price, output volume, and total revenue. There are also columns that include data on methyl bromide prices and amount used, along with data on the cost of alternatives, and amounts used. Additional columns describe estimates of other production ( operating) costs, and fixed/ overhead costs.

The columns near the end of the tables combine individual costs into an estimate of total production costs, and compare total costs to revenue in order to estimate profits. Finally, the last several columns contain the components of the loss estimates. 1 A 15% loss would result in the alternative being economically infeasible by some criteria. There is no yield loss data.

* kg ai that would be applied/ hectare = application rate for the alternatives or requested application rate for MBr.

* Other pest control costs are those other than methyl bromide or its alternatives. 35 Appendix C: U. S. Technical and Economic Review Team Members Christine M. Augustyniak ( Technical Team Leader). Christine has been with the U. S. Environmental Protection Agency since 1985. She has held several senior positions, both technical and managerial, including Special Assistant to the Assistant Administrator for Prevention, Pesticides, and Toxic Substances, Chief of the Analytical Support Branch in EPA's office of Environmental Information and Deputy Director for the Environmental Assistance Division in the Office of Pollution Prevention and Toxics. She earned her Ph. D. ( Economics) from The University of Michigan ( Ann Arbor). Dr. Augustyniak is a 1975 graduate of Harvard University ( Cambridge) cum laude ( Economics). Prior to joining EPA, Dr. Augustyniak was a member of the economics faculty at the College of the Holy Cross ( Worcester).

William John Chism ( Lead Biologist). Bill has been with the U. S. Environmental Protection Agency since 2000. He evaluates the efficacy of pesticides for weed and insect control. He earned his Ph. D. ( Weed Science) from Virginia Polytechnic Institute and State University ( Blacksburg), a Master of Science ( Plant Physiology) from The University of California ( Riverside) and a Master of Science ( Agriculture) from California Polytechnic State University ( San Luis Obispo). Dr. Chism is a 1978 graduate of The University of California ( Davis). For ten years prior to joining the EPA Dr. Chism held research scientist positions at several speciality chemical companies, conducting and evaluating research on pesticides.

Technical Team Jonathan J. Becker ( Biologist) Jonathan has been with the U. S. Environmental Protection Agency since 1997. He has held several technical positions and currently serves as a Senior Scientific Advisor within the Office of Pesticides Programs. In this position he leads the advancement of scientific methods and approaches related to the development of pesticides use information, the assessment of impacts of pesticides regulations, and the evaluation of the benefits from the use of pesticides. He earned his Ph. D. ( Zoology) from The University of Florida ( Gainesville) and a Masters of Science ( Biology/ Zoology) from Idaho State University ( Pocatello). Dr. Becker is a graduate of Idaho State University. Prior to joining EPA, Dr. Becker worked as a senior environmental scientist with an environmental consulting firm located in Virginia.

Diane Brown Rytlewski ( Biologist) Diane is the Nursery and Landscape IPM Integrator at Michigan State University, a position she has held since 2000. She acts as liaison between industry and the university, facilitating research partnerships and cooperative relationships, developing outreach programs and resource materials to further the adoption of IPM. Ms. Rytlewski holds a Master of Science ( Plant Pathology) and a Bachelor of Science ( Entomology), both from the University of Wisconsin ( Madison). She has over twenty year experience working in the horticulture field, including eight years as supervisor of the IPM program at the Chicago Botanic Garden. 36 Greg Browne ( Biologist). Greg has been with the Agricultural Research Service of the U. S. Department of Agriculture since 1995. Located in the Department of Plant Pathology of the University of California ( Davis), Greg does research on soilborne diseases of crop systems that currently use methyl bromide for disease control, with particular emphasis on diseases caused by Phytophthora species. He is the author of numerous articles on the use of alternatives to methyl bromide for the control of diseases in fruit and nut crops He earned his Ph. D. ( Plant Pathology) from the University of California ( Davis) and a Master of Science ( Plant Pathology) from the same institution. Dr. Browne is a graduate of The University of California ( Davis). Prior to joining USDA was a farm advisor in Kern County.

Nancy Burrelle ( Biologist). Nancy Burelle is a Research Ecologist with USDA's Agricultural Research Service, currently working on preplant alternatives to methyl bromide. She earned both her Ph. D. and Master of Science degrees ( both in Plant Pathology) from Auburn University ( Auburn).

Linda Calvin ( Economist). Linda Calvin is an agricultural economist with USDA's Economic Research Service, specializing in research on topics affecting fruit and vegetable markets. She earned her Ph. D. ( Agricultural Economics) from The University of California ( Berkeley).

Kitty F. Cardwell ( Biologist). Kitty has been the National Program Leader in Plant Pathology for the U. S. Department of Agriculture Cooperative State Research, Extension and Education Service since 2001. In this role she administrates all federally funded research and extension related to plant pathology, of the Land Grant Universities throughout the U. S. She earned her Ph. D. ( Phytopathology) from Texas A& M University ( College Station). Dr. Cardwell is a 1976 graduate of The University of Texas ( Austin) cum laude ( Botany). For twelve years prior to joining USDA Dr. Cardwell managed multinational projects on crop disease mitigation and food safety with the International Institute of Tropical Agriculture in Cotonou, Bénin and Ibadan, Nigeria.

William Allen Carey ( Biologist). Bill is a Research Fellow in pest management for southern forest nurseries , supporting the Auburn University Southern Forest Nursery Management Cooperative. He is the author of numerous articles on the use of alternative fumigants to methyl bromide in tree nursery applications. He earned his Ph. D. ( Forest Pathology) from Duke University ( Durham) and a Master of Science ( Plant Pathology ) from The University of Florida ( Gainesville). Dr. Carey is a nationally recognized expert in the field of nursery pathology.

Margriet F. Caswell ( Economist). Margriet has been with the USDA Economic Research Service since 1991. She has held both technical and managerial positions, and is now a Senior Research Economist in the Resource, Technology & Productivity Branch, Resource Economics Division. She earned her Ph. D. ( Agricultural Economics) from the University of California ( Berkeley). Dr. Caswell also received a Master of Science ( Resource Economics) and Bachelor of Science ( Natural Resource Management) from the University of Rhode Island ( Kingston). Prior to joining USDA, 37 Dr. Caswell was a member of both the Environmental Studies and Economics faculties at the University of California at Santa Barbara.

Tara Chand Goyal ( Biology). Tara has been with the U. S. Environmental Protection Agency since 1997. He serves in the Office of Pesticide Programs as a plant pathologist and specializes in analyzing the efficacy of pesticides with emphasis on risk reduction. He earned his Ph. D. ( Mycology and Plant Pathology) from The Queen's University ( Belfast) and a Master of Science ( Plant Pathology and Mycology) from Punjab University ( Ludhiana). Dr. Chand Goyal is a graduate of Punjab University. Prior to joining EPA Dr. Chand Goyal was a member of the faculty of The Oregon State University ( Corvallis) and of The University of California ( Riverside). His areas of research and publication include: the biology of viral, bacterial and fungal diseases of plants; biological control of plant diseases; and, genetic manipulation of microorganisms.

Daniel Chellemi ( Biologist). Dan has been a research plant pathologist with the U. S. Department of Agriculture since 1997. His research speciality is the ecology, epidemiology, and management of soilborne plant pathogens. He earned his Ph. D. ( Plant Pathology) from The University of California ( Davis) and a Master of Science ( Plant Pathology) from The University of Hawaii ( Manoa). Dr. Chellemi is a 1982 graduate of the University of Florida ( Gainesville) with a degree in Plant Science. He is the author of numerous articles in the field of plant pathology. In 2000 Dr. Chellemi was awarded the ARS " Early Career Research Scientist if the Year". Prior to joining USDA, Dr. Chellemi was a member of the plant pathology department of The University of Florida ( Gainesville).

Angel Chiri ( Biologist). Angel has been with the U. S. Environmental Protection Agency since 1997. He serves in the Office of Pesticide Programs as an entomologist and specializes in analyzing the efficacy of pesticides with emphasis on benefits of pesticide use. He earned his Ph. D. ( Entomology) from The University of California ( Riverside) and a Master of Science ( Biology/ Entomology) from California State University ( Long Beach). Dr. Chiri is a graduate of California State University ( Los Angeles). Prior to joining EPA Dr. Chiri was a pest and pesticide management advisor for the U. S. Agency for International Development working mostly in Latin America on IPM issues.

Colwell Cook ( Biologist). Colwell has been with the U. S. Environmental Protection Agency since 2000. She serves in the Office of Pesticide Programs as an entomologist and specializes in analyzing the efficacy of pesticides with emphasis on benefits of pesticide use. She earned her Ph. D. ( Entomology) from Purdue University ( West Lafayette) and has a Master of Science ( Entomology) from Louisiana State University ( Baton Rouge). Dr. Cook is a 1979 graduate of Clemson University. Prior to joining EPA Dr. Cook held several faculty positions at Wabash College ( Crawfordsville) and University of Evansville ( Evansville). 38 Julie B. Fairfax ( Biologist) Julie has been with the U. S. Environmental Protection Agency since 1989. She currently serves as a senior biologist in the Biological and Economics Analysis Division, and has previously served as a Team Leader in other divisions within the Office of Pesticides Programs. She has held several technical positions specializing in the registration, re registration, special review and regulation of fungicidal, antimicrobial, and wood preservative pesticides. Ms. Fairfax is a 1989 graduate of James Madison University ( Harrisonburg, VA) where she earned her degree in Biology. Prior to joining EPA, Julie worked as a laboratory technician for the Virginia Poultry Industry.

John Faulkner ( Economist) John has been with the U. S . Environmental Protection Agency since 1989. He serves in the Office of Pesticide Programs analyzing the costs imposed by the regulation of pesticides. He earned his Ph. D. ( Economics) from the University of Colorado ( Boulder) and holds a Master's of Business Administration from The University of Michigan ( Ann Arbor). Dr. Faulkner is a 1965 graduate of the University of Colorado ( Boulder). Prior to joining EPA was a member of the economics faculty of the Rochester Institute of Technology ( Rochester), The University of Colorado ( Boulder) and of the Colorado Mountain College ( Aspen).

Clara Fuentes ( Biologist). Clara has been with the U. S. Environmental Protection agency since 1999, working in the Philadelphia, Pennsylvania ( Region III) office. She specializes in reviewing human health risk evaluations to pesticides exposures and supporting the state pesticide programs in Region III. She earned her Ph. D. ( Entomology) from The University of Maryland ( College Park) and a Master of Science ( Zoology) from Iowa State University ( Ames). Prior to joining EPA, Dr. Fuentes worked as a research assistant at U. S. Department of Agriculture, Agricultural Research Service ( ARS) ( Beltsville), Maryland, and as a faculty member of the Natural Sciences Department at InterAmerican University of Puerto Rico. Her research interest is in the area of Integrated Pest Management in agriculture.

James Gilreath ( Biologist). Jim has been with the University of Florida Gulf Coast Research and Education Center since 1981. In this position his primary responsibilities are to plan, implement and publish the results of investigations in weed science in vegetable and ornamental crops. One main focus of the research is the evaluation and development of weed amangement programs for specific weed pests. He earned his Ph. D. ( Horticulture) from The University of Florida ( Gainesville) and a Master of Science, also in Horticulture, from Clemson University ( Clemson). Dr. Gilreath is a 1974 graduate of Clemson University ( Clemson) with a degree in Agronomy and Soils.

Arthur Grube ( Economist). Arthur has been with the U. S. Environmental Protection Agency since 1987. He is now a Senior Economist in the Biological and Economics Analysis Division, Office of Pesticide Programs. He earned his Ph. D. ( Economics) from North Carolina State University ( Raleigh) and a Masters of Arts ( Economics) also from North Carolina State University. Dr. Grube is a 1970 graduate of Simon Fraser University ( Vancouver) where his Bachelor of Arts degree ( Economics) was earned with honors. Prior to joining EPA Dr. Grube conducted work on the costs 39 and benefits of pesticide use at the University of Illinois ( Urbana). Dr. Grube has been a co author of a number of journal articles in various areas of pesticide economics LeRoy Hansen ( Economist). LeRoy Hansen is currently employed as an Agricultural Economist for the USDA Economic Research Service, Resource Economics Division in the Resources and Environmental Policy Branch. He received his Ph. D. in resource economics from Iowa State University ( Ames) in 1986. During his 16 years at USDA, Dr. Hansen has published USDA reports, spoken at profession meetings, and appeared in television and radio interviews.

Frank Hernandez ( Economist). Frank has been with the U. S. Environmental Protection Agency since 1991. He is a staff economist at the Biological and Economic Analysis Division of the Office of Pesticide Programs. He holds degrees in Economics and Political Science from the City University of New York.

Arnet W. Jones ( Biologist). Arnet has been with the U. S. Environmental Protection Agency since 1990. He has had several senior technical and management positions and currently serves as Chief of the Herbicide and Insecticide Branch, Biological and Economic Analysis Division, Office of Pesticide Programs. Prior to joining EPA he was Senior Agronomist at Development Assistance Corporation, a Washington, D. C. firm that specialized in international agricultural development. He holds a Master of Science ( Agronomy) from the University of Maryland ( College Park).

Hong Jin Kim ( Economist). Jin has been an economist at the National Center for Environmental Economics at the U. S. Environmental Protection Agency ( EPA) since 1998. His primary areas of research interest include environmental cost accounting for private industries He earned his Ph. D. ( Environmental and Resource Economics) from The University of California ( Davis) and holds a Master of Science from the same institution. Dr. Kim is a 1987 graduate of Korea University ( Seoul) with a Bachelor of Arts ( Economics). Prior to joining the U. S. EPA, Dr. Kim was an assistant professor at the University of Alaska ( Anchorage) and an economist at the California Energy Commissions. Dr. Kim is the author of numerous articles in the fields of resource and environmental economics.

James Leesch ( Biologist). Jim has been a research entomologist with the Agricultural Resarch Service of the U. S. Department of Agriculture since 1971. His main area of interest is post harvest commodity protection at the San Joaquin Valle. He earned his Ph. D. ( Entomology/ Insect Toxicology) from The University of California ( Riverside) Dr. Leesch received a B. A. degree in Chemistry from Occidental College in Los Angeles, CA in 1965. He is currently a Research entomologist for the Agricultural Research Service ( USDA) researching Agricultural Sciences Center in Parlier, CA. He joined ARS in June of 1971.

Sean Lennon ( Biologist). Sean is a Biologist interning with the Office of Pesticide Programs of the U. S. Environmental Protection Agency. He will receive his M. S. in Plant and Environmental 40 Science in December 2003 from Clemson University ( Clemson). Mr. Lennon is a graduate of Georgia College & State University ( Milledgeville) where he earned a Bachelor of Science ( Biology). Sean is conducting research in Integrated Pest Management of Southeastern Peaches. He has eight years of experience in the commercial peach industry.

Nikhil Mallampalli ( Biologist). Nikhil has been with the U. S. Environmental Protection Agency since 2001. He is an entomologist in the Herbicide and Insecticide Branch of the Biological and Economic Analysis Division. His primary duties include the assessment of pesticide efficacy in a variety of crops, and analysis of the impacts of risk mitigation on pest management. Dr. Mallampalli earned his Ph. D. ( Entomology) from The University of Maryland ( College Park) and holds a Master of Science ( Entomology) from the samr institution. Prior to joining the EPA, he worked as a postdoctoral research fellow at Michigan State University ( East Lansing) on IPM projects designed to reduce reliance on pesticides in small fruit production.

Tom Melton ( Biologist). Tom has been a member of the Plant Pathology faculty at North Carolina State University since 1987. Starting as an assistant professor and extension specialist, Tom has become the Philip Morris Professor at North Carolina State University. His primary responsibilities are to develop and disseminate disease management strategies for tobacco. Dr. Melton earned his Ph. D. ( Plant Pathology) from The University of Illinois ( Urbana Champaign) and holds a Master of Science ( Pest Management) degree from North Carolina State University ( Raleigh). He is a 1978 graduate of Norht Carolina State University ( Raleigh) Prior to joining the North Carolina State faculty, Dr. Melton was a member of the faculty at The University of Illinois ( Urbana Champaign).

Richard Michell ( Biologist). Rich has been with the U. S. Environmental Protection Agency since 1972. He is a nematologist/ plant pathologist in the Herbicide and Insecticide Branch of the Biological and Economic Analysis Division. His primary duties include the assessment of pesticide efficacy in a variety of crops, with special emphasis on fungicide and nematicide use and the development of risk reduction options for fungicides and nematicides. Dr. Michell earned his Ph. D. ( Plant Pathology/ Nematology) from The University of Illinois ( Urbana Champaign) and holds a Master of Science degree ( Plant Pathology/ Nematology) from The University of Georgia ( Athens).

Lorraine Mitchell ( Economist). Lorraine has been an agricultural economist with the U. S. Department of Agriculture, Economic Research Service since 1998. She works on agricultural trade issues, particularly pertaining to consumer demand in the EU and emerging markets. Dr. Mitchell earned her Ph. D. ( Economics) from The University of California ( Berkeley). Prior to joining ERS, Dr. Mitchell was a member of the faculty of the School of International Service of The American University ( Washington) and a research assistant at the World Bank.

Thuy Nguyen ( Chemist). Thuy has been with the U. S. Environmental Protection Agency since 1997, as a chemist in the Office of Pesticides Program. She assesses and characterizes ecological risk of pesticides in the environment as a result of agricultural uses. She earned her degrees of Master of Science ( Chemistry) from the University of Delaware and Bachelor of Science ( Chemistry and Mathematics) from Mary Washington College ( Fredericksburg, VA). Prior to joining the EPA, 41 Ms Nguyen held a research and development scientist position at Sun Oil company in Marcus Hook, PA, then managed the daily operation of several EPA certified laboratories for the analyses of pesticides and other organic compounds in air, water, and sediments.

Jack Norton( Biologist). Jack has worked for the U. S. Department of Agriculture Interregional research Project # 4 ( IR 4) as a consultant since 1998. The primary focus of his research is the investigation of potential methyl bromide replacement for registration on minor crops. He is an active member of the USDA/ EPA Methyl Bromide Alternatives Working Group. Dr, Norton earned his Ph. D. ( Horticulture) from Texas A& M University ( College Station) and holds a Master of Science ( Horticultural Science) from Oklahoma State University( Stillwater). He is a graduate of Oklahoma State University ( Stillwater). Prior to joining the IR 4 program, Dr. Norton worked in the crop protection industry for 27 years where he was responsible for the development and registration of a number of important products.

Olga Odiott ( Biologist) Olga has been with the U. S. Environmental Protection Agency since 1989. She has held several technical positions and currently serves as a Senior Biologist within the Office of Science Coordination and Policy. In this position she serves as Designated Federal Official and liaison on behalf of the Office of Pesticide Programs and the FIFRA Scientific Advisory Panel, an independent peer review body that provides advice to the Agency on issues concerning the impact of pesticides on health and the environment. She holds a Masters of Science ( Plant Pathology) from the University of Puerto Rico ( San Juan). Prior to joining EPA, Ms. Odiott worked for the U. S. Department of Agriculture.

Craig Osteen( Economist). Craig has been with the U. S. Department of Agriculture for over 20 years. He currently is with the Economic Research Service in the Production Management and Technology Branch, Resource Economics Division. He primary areas of interest relate to issues of pest control, including pesticide regulation, integrated pest management, and the methyl bromide phase out. Dr. Osteen earned his Ph. D. ( Natural Resource Economics) from Michigan State University ( East Lansing).

Elisa Rim ( Economist). Elisa is an Agricultural Economist interning with the Office of Pesticide Programs of the U. S. Environmental Protection Agency. She earned her Master of Science ( Agricultural Economics) from The Ohio State University ( Columbus) and holds a Bachelor of Arts ( Political Science) from the same institution. She has conducted research in environmental economics and developed a cost analysis optimization model for stream naturalization projects in northwest Ohio.

Erin Rosskopf ( Biologist). Erin received her PhD from the Plant Pathology Department, University of Florida, Gainesville in 1997. She is currently a Research Microbiologist with the USDA, ARS and has served in this position for 5 years. 42 Carmen L. Sandretto ( Agricultural Economist). Carmen has been with the Economic Research Service of the U. S. Department of Agriculture for over 30 years in a variety of assignments at several field locations, and since 1985 in Washington, DC. He has worked on a range of natural resource economics issues and in recent years on soil conservation and management, pesticide use and water quality, and small farm research studies. Mr. Sandretto holds a Master of Arts degree ( Economics) from Harvard University ( Cambridge) and a Master of Science ( Agricultural Economics) from The University of Wisconsin ( Madison). Mr Sandretto is a graduate of Michigan State University ( East Lansing). Prior to serving in Washington, D. C. he was a member of the economics faculty at Michigan State University and at the University of New Hampshire ( Durham).

Judith St. John ( Biologist). Judy has been with the USDA's Agricultural Research Service since 1967. She currently serves as Associate Deputy Administrator and as such she is responsible for the Department's intramural research programs in the plant sciences, including those dealing with pre and post harvest alternatives to methyl bromide. Dr. St. John earned her Ph. D. ( Plant Physiology) from The University of Florida ( Gainesville).

James Throne ( Biologist). Jim is a Research Entomologist with the U. S. Department of Agriculture's Agricultural Research Service and Research Leader of the Biological Research Unit at the Grain Marketing and Production Research Center in Manhattan, Kansas. He conducts research in insect ecology and development of simulation models for improving integrated pest management systems for stored grain and processed cereal products. Other current areas of research include investigating seed resistance to stored grain insect pests and use of near infrared spectroscopy for detection of insect infested grain. Jim has been with ARS since 1985. Dr. Throne earned his Ph. D. ( Entomology) in 1983 from Cornell University ( Ithaca) and earned a Master of Science Degree ( Entomology) in 1978 from Washington State University ( Pullman). Dr. throne is a 1976 graduate ( Biology) of Southeastern Massachusetts University ( N. Dartmouth).

Thomas J. Trout ( Agricultural Engineer). Tom has been with the U. S. Department of Agriculture, Agricultural Research Service since 1982. He currently serves ar research leader in the Water Management Research Laboratory in Fresno, CA. His present work includes studying factors that affect infiltration rates and water distribution uniformity under irrigation, determining crop water requirements, and developing alternatives to methyl bromide fumigation. Dr. Trout earned his Ph. D. ( Agricultural Engineering) from Colorado State University ( Fort Collins) and holds a Master of Science degree from the same institution, also in agricultural engineering. Dr. Trout is a 1972 graduate of Case Western Reserve University ( Cleveland) with a degree in mechanical engineering. Prior to joining the ARS, Dr. trout was a member of the engineering faculty of Colorado State University ( Fort Collins). He is the author of numerous publications on the subject of methyl bromide alternatives.

J. Bryan Unruh ( Biologist). Bryan is Associate Professor of Environmental Horticulture at The University of Florida ( Milton) and an extension specialist in turfgrass. He leads the statewide 43 turfgrass extension design team. Dr. Unruh earned his Ph. D. ( Horticulture) from Iowa State University ( Ames) and holds a Master of Science degree ( Horticulture) from Kansas State University ( Manhattan). He is a 1989 graduate of Kansas State University.

David Widawsky ( Chief, Economic Analysis Branch). David has been with the U. S. Environmental Protection Agency since 1998. He has also served as an economist and a team leader. As branch chief, David is responsible for directing a staff of economists to conduct economic analyses in support of pesticide regulatory decisions. He earned his Ph. D. ( Development and Applied Economics) from Stanford University ( Palo Alto), and a Master of Science ( Agricultural Economics) from Colorado State University ( Fort Collins). Dr. Widawsky is a 1987 graduate ( Plant and Soil Biology, Agricultural Economics) of the University of California ( Berkeley). Prior to joining EPA, Dr. Widawsky conducted research on the economics of integrated pest management in Asian rice production, while serving as an agricultural economist at the International Rice Research Institute ( IRRI) in the Philippines.

TJ Wyatt ( Economist). TJ has been with the U. S . Environmental Protection Agency since 2001. He serves in the Office of Pesticide Programs analyzing the costs and benefits of pesticide regulation. His other main area of research is farmer decision making, especially pertaining to issues of soil fertility and soil conservation and of pesticide choice. Dr. Wyatt earned his Ph. D. ( Agricultural Economics) from The University of California ( Davis). Dr. Wyatt holds a Master of Science ( International Agricultural Development) from the same institution. He is a 1985 graduate of The University of Wyoming ( Laramie). Prior to joining the EPA, he worked at the International Crops Research Institute for the Semi Arid Tropics ( ICRISAT) and was based at the Sahelian Center in Niamey, Niger.

Leonard Yourman ( Biologist). Leonard is a plant pathologist with the Biological and Economic Analysis Division of the U. S. Environmental Protection Agency. He currently conducts assessments of pesticide use as they relate to crop diseases He earned his Ph. D. ( Plant Pathology) from Clemson University ( Clemson) and holds a Master of Science ( Horticulture/ Plant Breeding) from Texas A& M University ( College Station). Dr. Yourman is a graduate ( English Literature) of The George Washington University ( Washington, DC). . Prior to joining EPA, he conducted research on biological control of invasive plants with USDA at the Foreign Disease Weed Science Research Unit ( Ft. Detrick, MD). He has also conducted research on biological control of post harvest diseases of apples and pears at the USDA Appalachian Fruit Research Station ( Kearneysville, WV). Research at Clemson University concerned the molecular characterization of fungicide resistance in populations of the fungal plant pathogen Botrytis cinerea.

Istanbul Yusuf ( Economist). Istanbul has been with the U. S . Environmental Protection Agency since 1998. She serves in the Office of Pesticide Programs analyzing the costs imposed by the regulation of pesticides. She earned her Master= s degree in Economics from American University ( Washington). Ms Yusuf is a 1987 graduate of Westfield State College ( Westfield) with a Bachelor 44 of Arts in Business Administration. Prior to joining EPA Istanbul worked for an International Trading Company in McLean, Virginia. 45 Appendix D: Charts ( see separate electronic file for Chart 1 and Chart 2)