2003 NOMINATION FOR A CRITICAL USE EXEMPTION FOR EGGPLANTS 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 eggplant, like the nomination for all other crops included in the U. S. request, includes general background information that the U. S. 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 eggplants 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, and 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.

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 eggplants, following detailed technical and economic review, the U. S. has determined that some use of methyl bromide in eggplant production 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 eggplants is discussed later in this nomination, as is the basis for the U. S. estimate of the amount of methyl bromide needed within this sector.

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 toxic and pose some risk to human health or the environment; in some cases, a chemical alternative may pose risks even greater than 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 in the many regions of the U. S. where a particular crop is grown can take many cropping seasons before the viability of the alternative can be adequately demonstrated. In addition, the process of securing national and sub national approval of the use of alternatives requires extensive analysis of environmental consequences and risk to human health. 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 toxicity data 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 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 Eggplant 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 eggplant growers 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. 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 agricultural climates. These factors contribute to and enable the U. S. to be a uniquely large and productive agricultural producer. Indeed, the size and scope of farming in the U. S. is different than in most countries. Specifically, in 2001, U. S. farm land totaled 381 million hectares, a land area larger than the size of many entire countries. Of this, approximately 140 million hectares were devoted to cropland, with the rest devoted to pasture, forest, and other special uses. 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 of fruits and vegetables, has had an important influence on the way agriculture 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. has developed a system 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.

The 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.

Finally, the above factors have contributed to a harvest of commodities that has enabled the U. S. to meet not only its needs, but also the needs of many other countries. The U. S. produced 88.3 million metric tonnes of fruits and vegetables in 2001, up 10 percent from 1990. At the same time, the land planted in fruits and vegetables has remained stable, and individual farm size has increased as the number of farms has fallen. 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 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. Eggplant Production Production practices for eggplants are similar to production of other solanaceous crops ( e. g., tomato and pepper). The field is plowed and disced to turn under old crop residue, and then shaping the bed, fumigating, and fertilizing are done prior to plastic application. A combination of methyl bromide + chloropicrin ( 67/ 33) is often used to fumigate beds. Eggplant can be grown from seed or from transplants, but is mostly started from transplants.

Eggplant is grown year round. Because of the crop's extended harvest period, double cropping   or raising two crops in one growing year   is not as common a practice as it is for pepper and tomatoes. Eggplant can be double cropped with pepper or cucumber following harvest. A spring crop of eggplant may follow a fall crop of pepper or tomato.

Eggplant does well on well drained, fertile, sandy loam soils. Poorly drained soils may result in slow plant growth, reduced root systems, and low yields. Eggplant requires a long, warm, frost free growing season, usually of 14 to16 weeks.

6. Results of Review  Determined Need for Methyl Bromide in the Production of Eggplant 6a. Target Pests Controlled with Methyl Bromide Eggplant transplant beds and fields are most seriously affected by weeds, especially nutsedges. The critical use exemption nomination is primarily based on the lack of reliable alternatives to control nutsedge species. Nutsedge has a capacity to grow under adverse growing conditions and resist traditional and modern methods of weed control.

Nematodes and fungal diseases are also of concern to eggplant producers. Nematodes and fungi are expected to become serious problems for eggplant production if methyl bromide is not available for preplant fumigation.

Yellow & Purple Nutsedge: Cyperus spp. 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 the difficult control ( Holm et al. 1977). Nutsedge is considered a weed in at least 92 countries and is reported to infest at least 52 different crops. Yellow nutsedge is listed among the top 15 worst weeds and is found throughout the continental U. S. Purple nutsedge is primarily found in the coastal areas of the 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 the more than 30 different vegetable crops grown there. ( Webster et al. 2001).

Nutsedge is propagated by tubers formed along underground rhizomes and corms which are underground stems. The parent tuber could be a tuber or a corm from the previous generation. During soil tillage, the underground stems are broken and new plants are established from the pieces. 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 square meter have been reported for purple nutsedge ( Gamini et al. 1987). Nutsedge is very difficult to eradicate once it is established because of dormancy 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.

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 reported yield losses of 41 to 89 percent. ( Patterson, 1998).

There are very few herbicides that control nutsedge and none are registered for use on eggplant. The herbicides that are available for these crops are generally older chemicals that are marginally effective against the spectrum of weeds that are problematic for solanaceous crops. Approximately 30 to 40 percent of the eggplant production areas covered by this nomination are moderately to heavily infested with nutsedge.

Root knot Nematode: Meloidogyne spp. Root damage caused by the root knot nematode leads to reductions in water and nutrient uptake. Nematodes induce galls ( swelling in plant tissues) at root feeding sites which result in symptoms such as stunting, wilting, and chlorosis ( loss of chlorophyll), and render the plant more susceptible to secondary infections. Pre plant control of nematodes is important because once root damage is done and symptoms are evident, it is very difficult to avoid significant yield losses.

Fungal Diseases: Phytophthora blight, induced by Phytophthora capsici, causes seed rot and seedling blight in many solanaceous crops including eggplant, pepper, and tomato. In eggplant, when weather conditions are favorable, this disease spreads rapidly causing serious damage to the crop. This is one of the most destructive diseases and there are few control measures. Southern stem blight, caused by Sclerotium rolfsii, is also a common problem in eggplant production.

6b. Overview of Technical and Economic Assessment of Alternatives Eggplant growers rely on methyl bromide/ chloropicrin fumigation in the full bed, plastic mulch production system to control soil borne diseases and pests. Research on the effectiveness of non chemical alternatives to methyl bromide is preliminary, particularly for high value, minor use crops such as eggplant. Many of these practices are under evaluation, and where possible have been named as a possible alternative. However, these alternatives have not shown to be stand alone replacements for methyl bromide. Some of these practices can, and are being implemented into overall pest management strategies. Methyl bromide is believed to be the only treatment currently available that consistently provides reliable control of nutsedge species and the disease complex affecting eggplant production. At this time it appears that use of methyl bromide will be critically needed until an appropriate combination of fumigants and herbicides is developed for areas where high weed and disease pressure require the broad spectrum action of methyl bromide. 6c. Technical Feasibility of Methyl Bromide Alternatives Identified by the MBTOC Only not in kind ( non chemical) alternatives to methyl bromide were identified by MBTOC for use on eggplant. The assessment of the technical feasibility of these alternatives is presented below.

Table 1. Methyl Bromide Alternatives Identified by MBTOC for Eggplant Methyl Bromide Alternative Technically Feasible Economically Feasible Solarization No No Solarization, Fungicides No No Flooding and water management No No Grafting/ Resistant rootstock/ Plant breeding No No Resistant Cultivars No No Substrates/ Plug plants No No Solarization. Solarization is the process of covering soil with clear plastic and exposing the soil to direct sunlight for several weeks. Solarization is a weather sensitive process that requires ideal soil moisture and sunlight conditions. This treatment is most successful in regions with continuous high temperature periods during summer. There are data indicating that soil solarization can be an effective replacement for methyl bromide in the management of several pests and diseases. Temperatures of 65 degrees C for 30 minutes will control many soil borne fungi, nematodes and weeds, with the exception of Cyperus species. Response of Cyperus species to solarization is sporadic and not well understood and data show solarization to provide, at best, suppression of nutsedge populations ( Chase et al. 1998; Egley, 1983). Field studies indicate that raising and maintaining soil temperatures throughout the soil profile to levels shown to control nutsedge is extremely difficult. Nutsedges have shown ability to emerge from deep in the soil profile and to re invade from areas outside the solarization zone, so solarization alone will not be an effective and dependable control method for nutsedge. Solarization treatments will take fields out of production since it would be needed during the spring and into the summer months, which are optimal for eggplant production.

Soil solarization is not a stand alone replacement to pre plant fumigation with methyl bromide for control of the wide range of soil borne diseases and pests in vegetable crops. However, the available data indicate that as part of an IPM program, soil solarization is compatible with raised bed plastic mulch production systems, is cost effective, and can be an effective tool for the management of many economically important pests and diseases. IPM has been adopted for management of weeds, diseases, and nematodes on solanaceous crops. However, problematic weeds like nutsedge and soil borne diseases and nematodes are not effectively controlled by these practices alone.

Solarization/ Fungicides. Fungicides are not effective for control of weeds and nematodes, therefore, their use in combination with solarization is no more efficacious than solarization alone.

Flooding and Water Management. Flooding is not a technically feasible alternative to methyl bromide for several reasons. First, eggplant requires well drained, sandy loam soil and therefore planting beds are designed to provide good drainage. Also, flooding does not provide adequate control of the entire pest complex affecting eggplant that is controlled by methyl bromide, especially nematodes and nutsedge. Cyperus species have shown tolerance to flooding. Submergence of nutsedge tubers for periods of 8 days to 4 weeks showed no effect on the sprouting capabilities of the tubers ( Horowitz, 1972). Studies in Florida showed ineffective nematode, disease, and nutsedge control overall. ( Allen, 1999)

Additional factors prevent flooding from being a viable, cost effective alternative to methyl bromide in most areas in the U. S. These include water management regulations, land configuration, the frequency and severity of droughts, and the economics of developing and managing flood capabilities.

Grafting/ Resistant Rootstock/ Plant Breeding. Grafting, resistant rootstock and plant breeding are not a stand alone replacements for methyl bromide. Resistant rootstock and plant breeding are primarily developed for nematode control and disease management. There is no evidence that they can be used successfully against weed competition. Grafting has not been evaluated for vegetable production due to the high cost and the large number of plants that would be needed. These alternatives are primarily used for nematode and disease management, but there is no evidence that they apply to competition from weeds.

Plant breeding is suited for the management of soil borne diseases as part of an IPM program. This alternative is not applicable to competition from weeds. Breeding for resistance is a long term process and is dependent on the availability of natural sources of resistance.

Organic Amendments/ Compost. The use of compost as a pest control tool is still new and not clearly understood. Available data suggest that the use of compost is a viable alternative for suppression of some diseases, especially when used with IPM. However, results are inconsistent and therefore should not be considered a stand alone alternative to methyl bromide for solanaceous crop production. Also, organic amendments and compost do not control nutsedge.

Resistant Cultivars. Resistant cultivars are not technically feasible as a stand alone replacement for methyl bromide . Furthermore, resistant cultivars provide little control against weed pressures in general and nutsedge in particular. However, the use of resistant cultivars as an alternative to methyl bromide pre plant fumigation is suited for the management of soil borne diseases as part of an IPM program. Breeding for resistance is a long term process and is dependent on the availability of natural sources of resistance. To date, there are no eggplant cultivars with resistance to Phytophthora and Meloidogyne, important soil borne organisms that are effectively controlled by methyl bromide.

Substrates and Plug Transplants. Substrates ( alternative growth media) and plug transplants ( small plugs of soil containing seedlings) are not technically feasible as a stand alone replacements for methyl bromide. Plug transplants are extensively used on high value vegetable crops like eggplants. However, even with plug transplants pre fumigation with methyl bromide is still necessary to provide control of the pest complex. Also, plug transplants do not control weeds. Even when amended with biological control organisms, substrates and plug transplants provide limited disease resistance and control due to the specific nature of biological control microorganisms and the heterogeneous distribution of pathogens in soils. Economic Feasibility None of the alternatives listed by MBTOC and reviewed above were found to be technically feasible for eggplants therefore no economic analysis was conducted.

7. Critical Use Exemption Nomination for Eggplant The critical use exemption nomination for the eggplant sector includes crops in the states of Georgia and Florida in areas with heavy to moderate nutsedge infestation. The U. S. interdisciplinary review team found a critical need for methyl bromide for eggplant growers in Georgia and Florida. The alternatives identified by the MBTOC were, as reviewed in detail above, regarded by reviewers as technically infeasible for acceptable management of the major eggplant pests, most importantly, yellow and purple nutsedge and several nematode and fungal pathogens. The demonstration above that alternatives are technically infeasible for controlling the major eggplant pests obviates the need to demonstrate that the alternatives are economically infeasible.

Tables 2 and 3 provide information on methyl bromide historical usage, including area treated, and the 2005 thru 2007 the actual amount requested for eggplant.

Table 2. Methyl Bromide Usage & Request for Eggplant in Georgia. 1997 1998 1999 2000 2001 2005 2006 2007 kg 70,312 41,407 47,723 51,245 48,868 48,868 48,868 48,868 hectares 284 168 251 333 325 325 325 325 rate ( kg/ ha) 247 247 191 154 150 150 150 150 Table 3. Methyl Bromide Usage & Request for Eggplant in Florida 1997 1998 1999 2000 2001 2005 2006 2007 kg 163,335 149,723 127,384 114,646 149,413 114,305 114,305 114,305 hectares 971 890 809 728 728 728 728 728 rate ( kg/ ha) 168 168 157 157 205 157 157 157 The total U. S. nomination 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 afflicted 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 4. Methyl Bromide Critical Use Exemption Nomination for Eggplant Year Total Request by Applicants ( kilograms) U. S. Sector Nomination ( kilograms) 2005 163,173 73,565 8. Availability of Methyl Bromide from Recycled or Stockpiled Sources In accordance with the criteria of the critical use exemption, Parties must discuss the potential that the continued need for methyl bromide can be met from recycled or stockpiled sources. With regard to recycling of methyl bromide, it is fair to say that the U. S. concurs with earlier TEAP conclusions that recycling of methyl bromide used in soil fumigation is not currently feasible. The U. S. has been investigating the level of the existing stockpile, and we believe that whatever stock pile may now exist will likely be fully depleted by 2005 when the need for the critical use exemption will start.

9. Minimizing Use/ Emissions of Methyl Bromide in the U. S.

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 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.

10. 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.

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 type, climate, soil type, and target pests, which change from region to region and 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 1 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.

Table 1: 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. USDA funded studies related to U. S. eggplant production that are currently on going include the following study:

" Field Evaluation of Amended Transplant Mixes & Soil Solarization for Control of Soil Borne Pathogens" ( July 1998  June 2003). The objective of the proposed research is to evaluate the efficacy of Plantpro 45, a complex form of iodine, to control several important pathogens of vegetables, and to determine the optimum application system for controlling soilborne pathogens in currently used commercial production systems.

In addition to ongoing USDA funded research, other eggplant research over the next few years includes:

Michigan Eggplant: Michigan State University's Research and Extension Center will test a variety of alternatives on test plots owned by commercial growers in Michigan in 2003 and 2004. They will analyze the ability of these alternatives to control Verticillium, Fusarium and Phytophthora. Alternatives they will test include Ptyalin C 35( 15,32 gal); Multigard FFA ( 47, 71 gal/ A); Multigard Protect with Vapam HL ( 37,56 gal/ A); CX 100 ( applied as drip or preplant); Chloropicrin ( 100%); Iodomethane/ chloropicrin ( 67%/ 33%); and composted chicken manure.

Florida Eggplant: Ongoing research conducted by USDA, University of Florida Institute of Food and Agricultural Sciences and the Florida Fruit and Vegetable association will continue. In the near term, additional attention will be paid to Telone/ chloropicrin/ herbicide combinations.

Based on preliminary results from research conducted in this area and largely in the area of tomatoes and strawberries, researchers believe that a mix of fumigants together with an herbicide treatment is the best possible alternative to methyl bromide. Combinations of Telone/ chloropicrin, and metam sodium/ chloropicrin are being tested for disease and weed control. Future research plans will test combinations of these fumigants with chemicals such as halosulfuron, metolachlor, and sulfentrazone. A program to evaluate host resistance to Phytophthora root and crown rot has been implemented. Growers are starting to deploy lines identified as having both genetic resistance and acceptable horticultural qualities.

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 examined as part of an overall strategy to manage eggplant production. 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.

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.

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 United States 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 priority. Because the U. S. EPA currently has more applications pending in its review process than the 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. The average processing time for a new active ingredient, from date of submission to issuance of a registration decision, is approximately 38 months. In most cases, the registrant ( the pesticide applicant) has 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:

  Iodomethane as a pre plant soil fumigant for various crops   Fosthiazate as a pre plant nematocide 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. 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 technically and economically feasible before widespread adoption will occur. 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 United States government has also been involved in these steps by promoting technology transfer, experience transfer, and private sector training.

11. Conclusion and Policy Issues Associated with the Nomination In summary, a review of the critical use exemption criteria in Decision IX/ 6 demonstrates that the Parties clearly understood the many issues that make methyl bromide distinctly different from the industrial chemicals previously addressed by the Parties under the essential use process. It is now the challenge of the MBTOC, TEAP and the Parties to consider the national submission of critical use nomination in the context of that criteria, and the information requirements established under Decision XIII/ 11.

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 eggplant sector are not currently technically viable from the standpoint of U. S. eggplant growers covered by this exemption nomination. This is primarily due to the technical infeasibility of these alternatives to control the major pests in eggplant.

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 in eggplant may be on the horizon. That said, it must be stressed that the registration process, which is designed to ensure that new pesticides do not pose an unacceptable risk, is a long and rigorous process, and the U. S. need for methyl bromide for eggplant will be maintained for the period being requested for an exemption in this nomination.

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 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 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.

12. 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 13. References Allen, L. H., S. J. Locascio, D. W. Dickson, D. J. Mitchell, and S. D. Nelson. 1999. Flooding ( soil anoxia) for control of pests of vegetables. Research Summary, USDA Specific Cooperative Agreement 58 6617 6 013. Chase, C. A., T. R. Sinclair, D. G. Shilling, J. P. Gilreath, and S. J. Locascio. 1998. Light effects on rhizome morphogenesis in nutsedges ( Cyperus sop): Implications for control by soil solarization. Weed Sci. 46: 575 580.

Egley, G. H. 1983. Weed seed and seedling reductions by soil solarization with transparent polyethylene sheets. Weed Sci. 31: 404 409.

Gamini, S. and R. K. Nishimoto. 1987. Propagules of purple nutsedge ( Cyperus rotundus) in soil. Weed Technology. 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 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 Horowitz, M. 1972. Effects of desiccation and submergence on the viability of rhizome fragments of bermudagrass, johnsongrass, and tubers of nutsedge. Israel J. Agric. Res. 22( 4): 215 220.

Patterson, D. T. 1998. Suppression of purple nutsedge ( Cyperus rotundus) with polyethylene film mulch. Weed Technology, 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 Technology 15: 771 790.

14. Appendices Appendix A. List of Critical Use Exemption ( CUE) requests for the eggplant sector in the U. S.

Georgia: CUE 02 0050, Georgia Fruit and Vegetable Growers Association  Eggplant Florida: CUE 02 0054, Florida Fruit and Vegetable Association  Eggplant Appendix B. Spreadsheets Supporting Economic Analysis None of the alternatives listed by MBTOC and reviewed were found to be technically feasible for eggplants therefore no economic analysis was conducted. 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.

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, 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).

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 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 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, 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. 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 as 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 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 Masters degree in Economics from American University ( Washington). Ms Yusuf is a 1987 graduate of Westfield State College ( Westfield) with a Bachelor of Arts in Business Administration. Prior to joining EPA Istanbul worked for an International Trading Company in McLean, Virginia.

Appendix D: CHARTS Charts 1 and 2 attached as separate electronic file.