Page 1 2003 NOMINATION FOR A CRITICAL USE EXEMPTION FOR GINGER 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 ginger, 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 ginger 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. Page 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 ginger, 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 ginger 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 pre plant 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 chemical alternatives to methyl bromide are toxic, and can pose risks to human health or the environment that are even greater than the risks 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 toxicity 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 Page 3 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 Ginger Work on this 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 grower 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 discussions with representatives of ginger growers 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 Page 4 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. In 2001, U. S. farm land 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 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 agriculture 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 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.

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 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. Page 5 5b. Ginger Production In terms of its scope, ginger production in the U. S. is confined to the state of Hawaii. Ginger growers have produced an average of 6,078,240 kgs of ginger root per year for national and international shipment for the last ten years. Total farm prices averaged US$ 1.44 per kg with total farm revenues exceeding US$ 8.7 million annually. Currently, total U. S. ginger production takes place on 145 hectares in Hawaii on hilly terrain in light porous soil near the coast. Ginger is produced using mechanized, scientific practices that involve deep injection of methyl bromide. Like many other crops grown in the U. S., ginger is grown not only for the domestic market, but also for exports. Only two varieties of ginger ( Zingiber officinale Roscoe) are grown in Hawaii  Chinese and Japanese. Production of this regional commodity is targeted to the fresh market and the majority is exported to niche markets in the mainland U. S., Canada, and Europe.

While ginger root production is consistent in several ways with other, larger U. S. agricultural activities, it is also unique in several respects. First, unlike many U. S. crops, ginger is only grown in one state, and indeed in one geographic area in one state. Ginger is usually grown in a rotation system in which one year of ginger production is followed by three years in which the land is not used for ginger to help reduce the incidence of disease and nematodes. Some growers move to new rented land each year. The ginger plant grows best in deep, loose, well drained, and nutrientrich soil. Abundant rainfall, sunlight, and warm temperatures are necessary throughout its growth cycle of approximately five to six months. The soil should be free of weeds which could harbor insects and diseases that attack ginger shoots as they emerge.

Field preparation for ginger production begins in late fall with the use of a pre plant soil fumigant. Soil fumigation with methyl bromide occurs once during each crop cycle ( one year) at a rate of 415 kgs per hectare, to eliminate nematodes which are the primary target pests. After soil fumigation, the fields are furrowed and a pre plant fertilizer is applied and tilled into the bottom of the furrow before seeding. Pre planting preparation of ginger " root pieces" involves soaking the root pieces used for seeding in hot water at 50 oC for ten minutes primarily for nematode control. This practice also tends to minimize the rate of methyl bromide used. The heat treatment also serves to release the seed pieces from dormancy. Ginger seed pieces are particularly sensitive and vulnerable to diseases and pests while coming out of dormancy. Runoff water from other soils and fields should not be allowed to contaminate the planted areas. Disease and soil free equipment, machinery and personnel, as well as footbaths, are essential. Field sanitation is critical to keeping many diseases and pests away from the ginger seed pieces.

Planting of ginger seeds actually occurs in the early spring in Hawaii and the ginger is ready for harvest in July and August. On average, approximately 370 kgs of seed are required to plant an hectare of ginger. The optimum yield is typically obtained when the growing season is 10 months long. Harvested ginger rhizomes are allowed to cure for 3 to 5 days and then packed and sold in containers. Hawaiian ginger root is available in the marketplace beginning in December and continuing as late as September of the following year. A typical Hawaiian ginger grower is a family owned farm operating on rented land of about 1.2 to 2 hectares. Page 6 6. Results of Review  Determined Need for Methyl Bromide in the Production of Ginger 6a. Target Pests Controlled with Methyl Bromide Ginger root production in the U. S. is challenged with a variety of diseases and insects. While there are alternatives to control a number of these pests, growers particularly rely on methyl bromide to efficaciously control the root knot nematode ( Meloidogyne incognita), and bacterial wilt ( Pseudomonas solanacearum). Root knot nematode causes rhizome and root galls, while bacterial wilt causes drooping of the entire plant and rhizome rot. Infections with either of these pests can result in significant crop losses. All of the hectares of ginger in Hawaii is subject to pressure by these pests either alone or in combination. Ginger bacterial wilt has resulted to losses of up to 45 percent of the annual ginger crop in peak epidemics in Hawaii.

6b. Overview of Technical and Economic Assessment of Alternatives For the past several years, research on chemical and non chemical alternatives to methyl bromide has focused primarily on the control of either root knot nematode or bacterial wilt, but not on both simultaneously. At this point, the effectiveness of chemical and non chemical alternatives designed to fully replace methyl bromide must still be characterized as in a preliminary stage. The technical and economic feasibility of MBTOC alternatives was based on these research results as derived from the small body of literature specific to ginger production and from discussions with U. S. ginger experts. A summary of the results of the assessments of the technical ( i. e., biological or pest management) and economic feasibility of alternatives for methyl bromide use on ginger is provided in the tables below:

6c. Technical Feasibility of In Kind Methyl Bromide Alternatives Table 2. In Kind Methyl Bromide Alternatives Identified by MBTOC for Ginger Crops.

Methyl Bromide Alternative Assessment of Technical Feasibility Assessment of Economic Feasibility Basamid/ Solarization Not registered for use in the U. S.

Metam Sodium/ Solarization No No Ozone No No Basamid/ Solarization. Basamid is not registered in the U. S. for ginger root production.

Metam Sodium/ Solarization. There is no available research on metam sodium combined with solarization. However, metam sodium combined with solarization is not technically feasible because it would not adequately control the target pests, principally nematodes and disease. Studies of metam sodium and tarping ( using plastic tarpaulins) have shown significant yield losses Page 7 and some quality loss. Yield when methyl bromide is applied at a rate of 329 kgs/ hectare is 9,864 kgs/ hectare ( based on 3/ 91 Nematode Control in Ginger CES Progress Report where metam sodium was applied and tarping was used. No solarization was included in this research.). The yield when metam sodium is applied at a rate of 356 kgs/ hectare is 5,380 kgs/ hectare, which is equivalent to a 45 percent yield loss compared to cropping practices with methyl bromide. In addition, the metam sodium trial had a reduction in overall ginger quality due to a lack of control of Fusarium wilt. This research focused on root knot nematode control and not on bacterial wilt control. In the same study solarization alone had a 95 percent yield loss compared to methyl bromide. Therefore, if metam sodium and solarization led to 45 and 95 percent yield loss individually the combination would still provide unacceptable control. ( We recognize that the ginger yield in this test was lower than the average yield in Hawaii but the information was verified against the original published data.) There is some time lost in this combination treatment compared to methyl bromide because of the weeks to months required for solarization treatment.

Ozone. Ozone is not technically feasible because there is no known available and field feasible technology for generating ozone for ginger grower production systems in the state of Hawaii. In addition initial research in California suggests that ozone is neutralized so rapidly by soil particles that it does not retain its biocidal properties. Even if effective the practical impediments to ozone sterilization of soil for ginger production are very similar to steam's constraints: lack of portable ozone generation equipment that would be needed simultaneously on many small, dispersed, farms ( primarily rented land). Whether any ozone generating technology could be used on the hilly terrain where ginger is grown is also unknown, and in any case likely to be very difficult and time consuming to achieve.

6d. Technical Feasibility of Not In Kind ( Non chemical) Alternatives Table 3. Not In Kind ( Non chemical) Methyl Bromide Alternatives Identified by MBTOC for Ginger Crops.

Methyl Bromide Alternative Assessment of Technical Feasibility Assessment of Economic Feasibility Steam No No Biological Control No No Fallow No No Crop Rotation No No Solarization No No Solarization/ fungicides No No Page 8 Flooding and water management No No General IPM ( Integrated Pest Management) No No Grafting/ resistant rootstock/ plant breeding No No Organic amendments/ Compost No No Steam . Steam is not technically feasible because it is not operationally practicable and there are currently no portable steam generation units which are appropriate for field use in Hawaii's hilly terrain. Steam sterilization does not typically penetrate deep enough into the associated soil to address the target pests associated with ginger production such as the nematode Meloidogyne incognita and bacteria Pseudomonas solanacearum. Ginger production is seasonal with virtually all the planting starting at the same time ( in early spring) which would necessitate each small farmer ( there are an estimated 30 to 40 such farmers in Hawaii) having equipment to simultaneously steam sterilize their planting beds. None of these small ginger farmers are currently using steam for pre plant fumigation on their land, which is generally rented.

Biological Control. Biological control is not a technically feasible alternative alone because it provides inadequate control of bacterial wilt and root knot nematodes. There are ongoing studies on the interactions of different bacterial strains associated with R. solanacearum to determine if interactions affect the disease complex. Preliminary results indicate that bacterial wilt symptoms are reduced if other bacteria are on the ginger plant prior to exposure to R. solanacearum. Additional research is needed in this area.

Fallow. Fallowing land is not a technically feasible alternative by itself because it does not adequately control the target pests and therefore results in significant yield losses. However, by using a fallow period, ginger producers are able to benefit by minimizing methyl bromide use and increase soil nutrients. Thus, ginger growers already fallow a field for 3 years and then fumigate with methyl bromide. When methyl bromide is applied at a rate of 410 kgs/ hectare, ginger yield is 56,043 kgs/ hectare ( based on the 2001 industry yield average since direct comparison of yield was not available). The yield after a fallow period of 3 years without methyl bromide fumigation was 43,714 kgs/ hectare, which is equivalent to a 22 percent loss ( based on " Sunn Hemp ` Tropic Sun' as a Cover Crop in Edible Ginger Production Study" delivered at the 2000 International Conference on methyl Bromide Alternatives & Emissions Reductions.) In addition, the quality of the end product was also reduced. Specifically, it is also important to note here that this research has focused on root knot nematode control and not on bacterial wilt control.

Crop Rotation. Crop rotation is currently being used in ginger, but it is not technically feasible as a stand alone treatment to adequately control the target pests. When methyl bromide is applied at a rate of 410 kgs/ hectare, the yield is 56,043 kgs/ hectare ( based on the 2001 industry yield average since direct comparison of yield was not available). In contrast, field rotation with a cover crop, sunn hemp ( Crotalaria juncea), and no methyl bromide fumigation, resulted in a yield of 26,677 kgs/ hectare, equivalent to a 52 percent yield loss ( based on " Sunn Hemp ` Tropic Sun' Page 9 as a Cover Crop in Edible Ginger Production Study", a presentation delivered at the 2000 International Conference on Methyl Bromide Alternatives & Emissions Reductions). In addition, the quality of the end product was also reduced. Specifically, grower response was not enthusiastic to cover cropping since they hope to avoid growing a non income generating crop for several months prior to their cash crop, ginger. In addition, a cover crop might be still vulnerable to adverse weather conditions and interfere with the timely planting of the ginger crop. This research focused on root knot nematode control and not on bacterial wilt control. Since ginger is a long term crop and the root knot controlling effects of sunn hemp may not suppress the late nematode population growth as it normally does for shorter term cropping systems, other cover crops are currently being investigated for reducing root knot nematode in ginger. Additional research in this area would be beneficial.

Solarization. Solarization is not a technically feasible alternative by itself because it does not adequately control the target pests and studies show a 95 percent yield loss compared to methyl bromide. The yield when methyl bromide is applied at a rate of 329 kgs/ hectare is 9,864 kgs/ hectare ( based on 3/ 91 Nematode Control in Ginger CES Progress Report). Yield with soil solarization treatment is 448 kgs/ hectare, resulting in a yield loss of 95 percent. The soil was solarized for 2 weeks with 4 mil clear plastic. Nematode damage with soil solarization treatment was twice as high as the damage in non treated soil and almost seven times higher than the methyl bromide treatment. The cool coastal climate and high rainfall ( over 254 centimeters per year) of the region are not suitable to attain high enough temperature levels to adequately control nematodes. This research has focused on root knot nematode control and not on bacterial wilt control.

Solarization and fungicides. Solarization with the use of fungicides is not a technically feasible alternative to methyl bromide because there are no registered fungicides for use on ginger root. Chloropicrin has the ability to control fungi. However, based on the June 1994 CES research report, Evaluation of Alternative Fumigants for Ginger Root, chloropicrin treatments alone ( rates of 203 kgs/ hectare, 404 kgs/ hectare, and 806 kgs/ hectare) resulted in zero harvestable yields due to damage inflicted by uncontrolled bacterial wilt.

Flooding and water management. Flooding is not a technically feasible alternative because Hawaiian ginger growing soil texture is very sandy and porous and the practice will actually aggravate the spread of root knot nematodes ( as well as other soil diseases) to other farm sites.

General Integrated Pest Management ( IPM). IPM is currently being used but it is not technically feasible as a stand alone alternative because it does is not currently control the primary target pests of ginger. Basic IPM control strategies focus on good management practices utilizing proper seed selection, new land selection, and good sanitation procedures, but IPM without methyl bromide use often results in yield and quality losses in ginger. A hot water dip is already used on ginger seed pieces to control the transfer of root knot nematode from the seed pieces to the field. Potential ginger fields are also examined to make sure that the fields are free of bacterial wilt. Also, it is important to make sure that water from adjacent fields does not run into ginger fields and bring in nematode eggs or bacterial cells. Page 10 Grafting/ resistant rootstock/ plant breeding. Grafting, resistant rootstock and plant breeding are not technically feasible alternatives because ginger cannot be grafted since its flowering period is very short. There is no information on traditional breeding or genetic engineering research for ginger root.

Organic Amendments/ Compost. Organic amendments/ composting are currently being used but are not technically feasible alternatives by themselves because they do not control ginger pests and result in yield and quality losses. Studies of crop rotations and cover crops that deliver organic matter to the soil show that alone they are not comparable with ginger root production with methyl bromide. It is common practice for chicken or cow manure to be added as a soil amendment in ginger root production, however the selected organic matter must be compatible with a long term cropping cycle. Research indicates that soil amendments such as chicken manure, added to soil infested with bacterial wilt have the potential to suppress and/ or inhibit the pathogen. Specifically, there is research that suggests that 44,834 kgs/ hectare of chicken manure will control pests but not eliminate them.

Additional research is needed in this area, but at this point this alternative appears technically infeasible.

6e. Economic Feasibility of Alternatives None of the above alternatives listed by MBTOC and reviewed were found to be technically feasible for ginger, therefore, no economic analysis was conducted. However, a brief discussion of the economic aspects of some of the MBTOC methyl bromide alternatives for ginger root are provided below.

Fallow. As mentioned in the previous section, a multi year study of fallowing in ginger production reported a 22 percent yield loss and reduction in harvest quality. Such a yield loss, coupled with even a 10 percent reduction in price for quality reasons, would result in sufficient losses to make the alternative ( which has been already identified as technically infeasible because it does not alone control the target pests, specifically root knot nematode and bacterial wilt) economically infeasible. It is pertinent to note here that the price of ginger dropped 33 percent from US$ 0.45 / lb in 2001 to US$ 0.30/ lb in 2002 as a result of a lower quality product and increased imports from Asia. The lower quality product was claimed by the exemption applicant to be associated with fewer hectares being fumigated with methyl bromide.

Table 3. Loss Measures with Fallow and 10 Percent Price Loss Percent Yield Loss 22%

Gross Revenue Loss 29%

Increased Costs as a % of Gross Revenue  13%

Loss as a % of Gross Revenue 16%

$ Loss/ Hectare US$ 8,342 $ Loss per kg ai of methyl bromide US$ 20.19 Page 11 % Operating Profit Loss 100%

Profit Margin ( 18% with methyl bromide)  47%

Steam. Steam is currently used in Florida for chrysanthemum propagative material ( or " cuttings") The capital cost of a boiler and equipment is about US$ 236,000. This investment has the capacity to treat about 900 square meters in about 2 days to a depth of about 20 cm in sandy soil. At this rate it would take about 3 weeks to treat one hectare at an operating cost of over US$ 14,000 per hectare. To treat more hectares would require more equipment and/ or more time. This technology is only marginally economically feasible even for chrysanthemum cuttings ( arguably a higher value product than ginger root), because the equipment can be used throughout the year since chrysanthemum cuttings are planted throughout the year at different times. However, for ginger, such a capital investment would not be economically feasible for using just one time each year. Furthermore, the cost would be higher because the terrain is hilly and the equipment would have to be mobile to cover the widely scattered rented plots.

Ozone. Some research has been done with ozone on other crops. While the costs of treating soil with ozone at a rate of 280 kg/ hectare are comparable to methyl bromide, a large initial investment would be required. The capital cost of enough ozone generating capacity to treat one hectare per day at a rate 280 kg/ hectare would be almost US$ 500,000. Such an investment would be economically infeasible for small growers such as ginger farmers, especially since test results of ozone are very preliminary. Although ozone out performs untreated controls, there is very little data comparing it to methyl bromide. ( SoilZone, 1999)

7. Critical Use Exemption Nomination for Ginger Root The actual amount of methyl bromide being requested for ginger root production is 18,340 kgs of 98 percent methyl bromide. This would be needed for 45 hectares each year in 2005, 2006, and 2007 ( Table 4). This is about 35 percent of the total area planted ( based on 2002 U. S. Department of Agriculture ( USDA) survey data). Rates as requested conform to standard practices in this region.

Table 4. Hawaiian Ginger Production  Methyl Bromide Use and Request 1997 1998 1999 2000 2001 2005 2006 2007 kgs 44,680 43,930 54,530 11,620 8,890 18,340 18,340 18,340 hectares 108 106 132 28 22 45 45 45 rate ( kg/ hectare) 412 413 412 413 407 412 412 412 The U. S. nomination for ginger root production 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 Page 12 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 5. Methyl Bromide Critical Use Exemption Nomination for Ginger Year Total Request by Applicants ( kilograms) U. S. Sector Nomination ( kilograms)

2005 18,336 9,221 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 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 Page 13 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 B 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.

Ginger growers currently use tarpaulins ( high density polyethylene), select appropriate crop sites, and use proper field preparation and application methods, all in an effort to minimize their use and/ or emissions of methyl bromide. They also plan to use non fumigant herbicides as they become available and are registered on this crop. They rotate to land that has not been planted in ginger ( though the cost and ability to secure rented land is uncertain each year and creates inconsistency in the adoption of this practice).

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 Page 14 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 Page 15 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 nonchemical 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.

Although ginger production is small compared to other crops that rely on methyl bromide, it has been a focus of research activity on the national level. Ginger root growers have remained committed to finding replacements for methyl bromide although their support has been limited by the financial conditions of this small crop sector. Approximately US$ 40,000 has been spent on research for alternatives on behalf of this industry, solely in the state of Hawaii.

In 2001, research on ginger bacterial wilt was funded through a special allocation to the ARS. A full time plant pathologist is employed to work on the project through the Tropical Germplasm Research Project of the Pacific Basin Agriculture Research Center ( PBARC). The project works Page 16 with the tropical commodity treatment group with PBARC within ARS, and also cooperatively with the University of Hawaii, Hilo and Manoa, the Hawaii Agriculture Research Center, the Agriculture Extension Service, ginger farmers, and other industry interests. A broad approach of an interdisciplinary nature is being applied to this research area. Areas of study include clean seed production, the genetic diversity of the bacterial wilt pathogen, interactions of bacteria wilt with other bacteria in the ginger crop system, improved ways to assay the pathogen in the field, and potential methods for improving disease management.

In addition to the significant national research to find alternatives to methyl bromide, ginger root growers have to date undertaken significant efforts to find replacements. Ivan Kawamoto, of the grower group Mokichi Okada Association ( MOA), received funds from U. S. EPA via a grant to American Farmland Trust, for August 1999 to December 2000, to use organic amendments and cover crops for nematode ( root knot and reniform) control and nutrient supply ( two Crotalaria species and organic compost) in growing ginger. The results were compared to results from fallow plots used as controls. There was no apparent damage from either the root knot or reniform nematodes in the experimental plots. Ginger crops following Crotalaria had greater nutrient levels than those following fallow soil, thus accounting for differences in total weights harvested between treatments. Further trials are needed to demonstrate the consistency of these promising results.

While past research has not demonstrated the full efficacy of methyl bromide alternatives, research is underway and still more is planned. For example, the Hawaiian College of Tropical Agriculture and Human Resources, under Dwight Sato, Vegetable Production Extension Agent, is planning to field test a new application method using 1, 3 dichloropropene ( telone C 35) as a pre plant soil fumigant for root knot nematode control in 2003. It is hoped that this formulation will provide both nematode and fungal control of soil pests. Sato is also collaborating with Ron Harding, a Dow Chemical Western Regional Technical Representative based in California, on the construction of a telone fumigation application rig for Hawaii's hilly terrain. A field demonstration will be installed in late Spring 2003 with a cooperating ginger grower. The resulting yield and disease control will be measured after harvest in early 2004. This trial will consist of a simple field crop comparison of telone fumigation vs. no fumigation in 90 square meter plots. Ginger plantings will be otherwise maintained according to typical industry standards.

Studies are also being planned to study the efficacy of iodomethane, in combination with plastic tarps, on both nematodes and bacterial wilt in ginger crops in Hawaii. Tests in other crops have shown that this product performs very similarly to methyl bromide in controlling soil pests and diseases but without harming the ozone layer.

As regards non chemical alternatives to methyl bromide, some research suggests that heated air reduces bacterial wilt incidence. Studies conducted using non saturated heated air to control bacterial wilt on the seeds showed that effective treatment was obtained when seed pieces were heated for 30 minutes and their center temperatures maintained at 49 oC for 60 minutes. Over 85 percent of the seeds in this trial germinated. However, additional research is needed to investigate the feasibility of the application of heat treatment to large quantities of seeds. Field tests are also Page 17 needed to study the long term effects of the heat treatment on crop growth and rhizome yield.

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 ( licenses) 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 pending in its review than the resources to evaluate them, 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 EPA receives the application and supporting data rather than waiting in turn for 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. Page 18 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:

B Iodomethane as a pre plant soil fumigant for various crops B Fosthiazate as a pre plant nematocide for tomatoes B Sulfuryl fluoride as a post harvest fumigant for stored commodities B Trifloxysulfuron sodium as a pre plant herbicide for tomatoes B Dazomet as a pre plant soil fumigant for strawberries and tomatoes Page 19 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.

While none of the registration activity envisioned currently or in the near future specifically involves ginger as a use site, the U. S. is committed to helping minor crop producers ensure the availability of necessary pesticide alternatives. As registrations of new materials are completed on other crops, U. S. EPA, USDA and programs such as the IR 4 program will work with registrants to encourage support of registration of these products on smaller crop sites, such as ginger.

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 widespread adoption. As noted by TEAP, once a specific alternative is available, it may take two or three cropping seasons of use before efficacy can be determined in the specific circumstances 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.

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 nominations 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 ginger root sector are not currently technically or economically feasible from the standpoint of U. S. ginger root production covered by this nomination. Accordingly, we believe that methyl bromide is necessary for successful and profitable ginger root production in the U. S.. In order for the ginger farmers in Hawaii to compete with the world production of ginger imports, it is imperative that they continue to have access to the use of methyl bromide to manage root knot nematode and bacterial wilt. 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 Page 20 in ginger root may be on the horizon. The registration process, which is designed to ensure that new pesticides do not pose unreasonable adverse effects to human health and the environment, is a long and rigorous. The U. S. need for methyl bromide for ginger root 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 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 Page 21 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 B about 40% above usage B 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 B 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: Page 22 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 Economics of Ginger Root Production in Hawaii. Dec. 1998. Agribusiness. Hawaii Cooperative Extension Service, College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa.

Hawaii Ginger Root: Annual Summary. 2002. Hawaii Agricultural Statistics Service ( HASS). Hawaii Department of Agriculture and U. S. Department of Agriculture.

Martin, Donald A. 2002. Hawaii Ginger Root. Hawaii Agricultural Statistics Service ( HASS). Hawaii Department of Agriculture and U. S. Department of Agriculture.

Nishina, M. S., D. M. Sato, W. T. Nishijima, R. F. L. Mau. 1992. Ginger Root Production In Hawaii. Commodity Fact Sheet GIN 3( A). Hawaii Cooperative Extension Service, Hawaii Institute of Tropical Agriculture and Human Resources, University of Hawaii at Manoa.

Ozone Gas as a Soil Fumigant. 1998. Electric Power Research Institute. SoilZone, 1999.

Sato, Dwight and Don Schmidt. 1991. Nematode Control in Ginger CES Progress Report.

Sato, Dwight. 1994. Evaluation of Alternative Fumigants for Ginger Root Research Report.

Sato, Dwight. 1998. Reducing Methyl Bromide in Preplant Soil Treatment for Ginger Root.

Sato, Dwight, Bob Joy and Matthew Wung. Sunn Hemp ` Tropic Sun' as a Cover Crop in Edible Page 23 Ginger Production" . Presentation delivered at the 2000 International Conference on Methyl Bromide Alternatives & Emissions Reductions.

Tsang, M. M. C. and M. Shintaku. 1998. Hot Air Treatment for Control of Bacterial Wilt in Ginger Root. Applied Engineering in Agriculture. Vol 14( 2): 159 163.

14. Appendices Appendix A. List of critical use exemption requests for the ginger crop sector in the U. S.

CUE 02 0045. Application for Critical Use Exemption for Methyl Bromide Use in Hawaii Ginger. Page 24 Appendix B. Spreadsheets Supporting Economic Analyses 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.

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. Page 25 * 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. Page 26 Page 27 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. Page 28 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. Page 29 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, reregistration 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 Page 30 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 Page 31 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 postharvest 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. Page 32 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 Page 33 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 Page 34 ( 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 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 Page 35 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 of Arts in Business Administration. Prior to joining EPA Istanbul worked for an International Trading Company in McLean, Virginia. Page 36 Appendix D: CHARTS ( See the separate electronic file for CHART 1 and CHART 2)