Page 1 2003 NOMINATION FOR A CRITICAL USE EXEMPTION FOR CUCURBITS FROM THE UNITED STATES OF AMERICA 1. Introduction In consultation with the co chair of the 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 cucurbits, like the nomination for all other crops included in the U. S. nomination, 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 cucurbits 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 cucurbits, 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 cucurbits is discussed later in this nomination.

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

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

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

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

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

The Essential Use exemption largely assumed that an alternative used in one place could, if approved by the government, be used everywhere. Parties clearly understood that this was not the case with methyl bromide because of the large number of variables involved, such as crop type, soil types, pest pressure and local climate. That is why the methyl bromide Critical Use exemption calls for an Page 3 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 Cucurbits Work on the U. S. critical use exemption process began in early 2001. At that time, the U. S. Environmental Protection Agency ( EPA) initiated open meetings with stakeholders both to inform them of the Protocol requirements, and to understand the issues being faced in researching alternatives to methyl bromide. During those meetings, which were attended by State and association officials representing thousands of methyl bromide users, the provisions of the critical use exemption Decision IX/ 6 were reviewed in detail, and questions were taken. The feedback from these initial meetings led to efforts by the U. S. to have the Protocol Parties establish international norms for the details to be in submissions and to facilitate standardization for a fair and adequate review. These efforts culminated in decision XIII/ 11 which calls for specific information to be presented in the nomination.

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

Finally, and concurrent with our preparation phase, we developed a plan to ensure a robust and timely review of any and all critical use applications we might receive. This involved the assembly of more than 45 PhDs and other qualified reviewers with expertise in both biological and economic issues. These experts were divided into interdisciplinary teams to enable primary and secondary reviewers for each application/ crop. As a consequence, each nomination received by the U. S. was reviewed by two separate teams. In addition, the review of these interdisciplinary teams was put to a broader review of experts on all other sector teams to enable a third look at the information, and to ensure consistency in review between teams. The result was a thorough evaluation of the merits of each request. A substantial portion of requests did not meet the criteria of decision IX/ 6, and a strong case for those that did meet the criteria has been included.

Following our technical review, discussions were held with senior risk management personnel of the U. S. government to go over the recommendations and put together a draft package for submission to the parties. As a consequence of all of this work, it is safe to say that each of the sector specific nominations being submitted is the work of well over 150 experts both in and outside of the U. S. government. Page 4 Page 5 5. Overview of Agriculture 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 allow the U. S. to be a uniquely large and productive agricultural producer. Indeed, the size and scope of farming in the U. S. is different than in most countries. Specifically, in 2001, U. S. farm land totaled 381 million hectares, a land area larger than the 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 the 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 type 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 nonlabor 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. nominations for critical uses of methyl bromide, the phase out 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 6 5b. U. S. Cucurbit Production U. S. cucurbit production ( specifically, production of cucumbers, melons, cantaloupes, honeydews, watermelons, and various squash varieties) exemplifies many of the characteristics of U. S. agriculture noted above. Cucurbits are grown in large areas of many of the vegetable growing areas of the U. S.. About 202,345 hectares are planted annually. As a consequence, this nomination covers use in a variety of areas with differing soil and climactic characteristics, including: Georgia, Michigan, Alabama, Arkansas, North Carolina, South Carolina, Tennessee, and Virginia. Cucurbits covered by this nomination represent about one third of the U. S. land planted in cucurbits.

The value of the cucurbit crop covered in this nomination is also significant. Cucurbits grown by the eight states covered in this critical use exemption nomination account for about US $ 250 million, or about one sixth of the U. S. total. Of these, cucumbers account for about half, or US $ 125 million. Of the eight states in this nomination, Georgia, Michigan and North Carolina account for most of the US $ 250 million .

Cucurbits grown in these areas are generally produced using mechanized, scientific practices that involve deep injection of methyl bromide. In addition, they are mostly grown using multiple row transplants placed in polyethylene plastic mulch raised beds. Cucurbits generally require warm temperatures and are very sensitive to cold. Cucumbers, for example, grow optimally at temperatures between 18 o and 24 oC. Having deep roots, the plants are best suited to deep, fertile, well drained soils. Frequent irrigation of cucurbit crops is necessary, as insufficient soil moisture can distort fruit shape ( Schrader et al. 2002).

Fresh cucurbit production in the U. S. differs most significantly from international methods because of its frequent use of a double cropping field system with tomatoes, eggplants, or bell peppers. Climatic conditions, with heavy rains during the hottest season ( Georgia for example), also differentiate the U. S. from other cucurbit producing countries. These conditions lead to limited success of methyl bromide alternatives, particularly in the Southeast, as compared to other regions that have implemented alternatives.

A typical grower in the regions comprised by this nomination would produce cucurbits on about 1 12 hectares for local or regional markets, while a grower producing cucurbits for wholesale markets would typically utilize approximately 12 200 hectares. In Georgia, for example, a representative user of methyl bromide will farm a total average of 162 hectares; of those 162 hectares, 81 hectares would be treated with methyl bromide each year, due to high pest pressure.

6. Results of Review  Determined Need for Methyl Bromide in the Production of Cucurbits 6a. Target Pests Controlled with Methyl Bromide While U. S. cucurbit growers use methyl bromide as one of many options against a range of fungal pathogens, nematodes, insect larvae, and weeds, all but a few key organisms can be controlled in cucurbit crops with other pesticides or management strategies. Only the pests for which critical use Page 7 exemption requests were submitted by U. S. cucurbit growers are described in detail in this section.

Target pests for methyl bromide differ between the northern and southeastern regions encompassed in this nomination. Specifically, Michigan cucumber, squash, pumpkin, pepper, eggplant and tomato crops all experience significant damage from Phytophthora blight, a result of infection by the soil fungus Phytophthora capsici.. Another soil inhabiting fungal pathogen, Fusarium oxysporum, is also of great concern for Michigan cucurbit growers facing the loss of methyl bromide. Both fungi cause root, crown and fruit rot in cucurbits, greatly decreasing both yield and quality of cucurbit harvests. Early eradication of P. capsici, in particular, is very important as it can infect plants and produce additional oospores repeatedly during a growing season and result in an epidemic. Furthermore, P. capsici has developed resistance to a number of foliar applied fungicides. This has increased the importance of preventing infestations before planting, a goal currently achieved very effectively with methyl bromide. Michigan's cool and cloudy climate contribute to the challenge of suppressing fungal pathogens of plants, as this climate is optimum for the growth of these disease organisms.

For the southern and southeastern U. S. states, the main pests being targeted by methyl bromide are yellow and purple nutsedge ( Cyperus esculentum and C. rotundus, respectively). These plants are perennial species in the Cyperaceae family that are widely recognized for their extremely detrimental economic impact on agriculture. Purple nutsedge is considered the world's worst weed due to its widespread distribution and the difficulties in controlling it ( Holm et al. 1977). Purple nutsedge is considered a weed in at least 92 countries and is reported infesting at least 52 different crops. Yellow nutsedge is listed among the top fifteen worst weeds ( Holm et al. 1977). Yellow nutsedge is found throughout the continental U. S. Purple nutsedge is primarily found in the southern coastal U. S. and along the Pacific coast in California and Oregon. A survey conducted in Georgia ranked the nutsedges as the most troublesome weeds in vegetable crops, and among the top five most troublesome weeds in corn, cotton, peanut, and soybean ( Webster and Macdonald 2001).

Nutsedges have an allelopathic ( inhibitory) effect on the growth of cucumbers and other cucurbit species, among a variety of other plants ( Holm et al. 1977). Like other weeds, nutsedges also compete vigorously for soil nutrients, light, and moisture. Nutsedges do best in sunny, warm habitats ( typical of southern U. S. cucurbit growing regions), and are intolerant of shady conditions. Thus, nutsedges are frequently problems in the early part of the growing season, when crop plants have not produced many leaves. Later in the season, mature crops of leafy habit ( as are most cucurbits) can shade out new nutsedge infestations. This pattern of nutsedge competition with cucurbit seedlings highlights the critical need for effective pre plant control.

While nutsedges do produce seeds, vegetative reproduction ( i. e. through tuber formation) is more common ( Thullen and Keeley 1979). A single nutsedge plant is capable of producing 140 shoots ( yellow nutsedge) or 280 shoots ( purple nutsedge) over a 6 month growing season ( Webster 2000). Each shoot produces a single tuber, which produces plants in the following season. At least one study ( William and Warren 1975) reported that cucumber yield could be reduced by as much as 43 percent due to an infestation of nutsedge at a density of 1600 plants per square meter. To interpret this figure it is helpful to consider that uncontrolled nutsedge densities can exceed 7000 shoots ( or plants) per square meter ( Webster 2000). In extreme infestations, up to 95 percent losses can occur due to Page 8 uncontrolled nutsedge infestations! To eliminate yield reductions, cucumber must be kept weed free from 24 to 36 days after crop emergence ( Friesen 1978). Cucurbit quality is also reduced by the presence of nutsedge in fields. Nerson ( 1989) found that keeping fields weed free for 3 to 4 weeks after melon emergence resulted in significantly better fruit quality. Interestingly, some growers claim that soil fungi ( such as those mentioned above) can also reduce the quality of the resulting cucurbit crop, though there appear to be no formal studies quantifying the extent of loss.

6b. Overview of Technical and Economic Assessment of Alternatives Cucurbit growers generally rely on fumigation with methyl bromide/ chloropicrin within their plastic mulch production systems to control soil borne diseases and pests. There has been extensive research on alternatives for the sector, and where possible, many have been incorporated. However, the effectiveness of chemical and non chemical alternatives designed to fully replace methyl bromide must still be characterized as in a preliminary stage. These alternatives have not been shown to be standalone replacements for methyl bromide. Methyl bromide is believed to be the only treatment currently available that consistently provides reliable control of nutsedge species and the disease complex, in particular Phytophthora and Fusarium fungi, affecting cucurbit production in key growing areas of the U. S.

We begin our technical and economic assessment by presenting a brief discussion of in kind ( chemical) alternatives, and then describe the attributes of the not in kind alternatives.

6c. Technical Feasibility of In Kind ( Chemical) Alternatives Table 1 . In Kind Methyl Bromide Alternatives Identified by MBTOC for Cucurbit Crops. Methyl bromide alternative Assessment of Technical Feasibility Assessment of Economic Feasibility Metam sodium/ crop rotation Yes * No 1,3 D, Metam sodium, Basamid No N/ A Chloropicrin No N/ A Nematicides No N/ A Ozone No N/ A Notes. * = the alternative is technically feasible for some target pests ( fungi) but not others ( nutsedges). N/ A = Not applicable.

Metam Sodium/ Crop Rotation. Metam sodium is a technically feasible alternative for cucurbit production in southern U. S. states in areas of low to moderate nutsedge pressure. However, nutsedge control is not as complete as with methyl bromide, and yield losses, particularly in high pest pressure locations may cause significant economic impacts. The current estimates of typical yield losses with metam sodium replacing methyl bromide are about 8 to10 percent in the Southern U. S., with losses as high as 25 percent being possible ( based on discussions with extension specialists in Georgia). The financial impact of this loss is discussed in the section dealing with economic feasibility. While metam sodium has good efficacy in controlling other weedy plants, studies thus far ( and the field Page 9 experience of many crop experts in the relevant regions) suggest that it will not adequately control nutsedge species in the absence of methyl bromide. Though no studies appear to have been performed on cucurbit crops, trials of metam sodium in tomatoes and bell peppers suggest that control of nutsedge around the application area ( e. g. drip irrigation lines) can be as high as 80 to 90 percent with metam sodium ( Dowler 1999) in high pest pressure areas. However, the remaining nutsedge is still capable of causing appreciable yield loss.

Metam sodium is not a technically feasible alternative to methyl bromide ( whether used in continuous cropping or in conjunction with crop rotations) for fungal pathogens cited as the main targets by Michigan growers. A trial is currently underway in Michigan evaluating the efficacy of metamsodium against fungal pathogens in zucchini. Data thus far indicate that it does not provide acceptable control of these pests. In general, while the underlying reasons are unclear, many crop experts believe that metam sodium is not an effective treatment for soil fungi, particularly Phytophthora species. Since cucurbit crop rotations in Michigan involve plants ( cucumber, pepper, tomato, and squash) susceptible to P. capsici, it is unlikely that rotation combined with this metamsodium will adequately replace methyl bromide.

1,3 D, Metam Sodium, Basamid. This combination of chemicals is not currently feasible for U. S. cucurbit production because basamid is not registered for use in this group of crops. Furthermore, many scientists report that 1,3 D provides good nematode control, only moderate disease control, and poor weed control. Another issue contributing to the technical infeasibility of any combination involving 1,3 D is the practicality of application, particularly in the hot, humid southeastern U. S. states. Workers wearing the required Personal Protective Equipment ( PPE) for 1,3 D become at risk for possible heat exhaustion or heat stroke. For example, PPE rules may require applicators to wear fully sealed suits, with respirators. Such suits are do not have refrigeration components, and under conditions of high heat and humidity, rapidly become unbearable for a typical applicator.

Chloropicrin. Chloropicrin alone is unlikely to control the nutsedges that are the key pests in southern U. S. cucurbits, as studies in other cropping systems have shown poor weed control. While studies in other crop systems ( e. g., strawberries) have shown some control of soil diseases, no studies appear to have been done to show technical feasibility of chloropicrin alone as a control strategy for Phytophthora and Fusarium fungi in cucurbits.

Furthermore, workers have expressed concerns about eye and lung irritation when applying chloropicrin. Airborne chloropicrin levels of 0.1 ppm require the use of air purifying respirators and levels exceeding 4 ppm require the use of air supplying respirators. As mentioned for 1,3 D, this could render application of large amounts of chloropicrin impractical in the heat and humidity of the U. S. growing season. Also in this regard, emission of chloropicrin from agricultural fields into urban areas has been a concern due to its lachrymating effects. Increased use of chloropicrin would trigger the need to address these issues. Indeed, chloropicrin has been determined to be a toxic air contaminant by California's Department of Pesticide Regulation, and other jurisdictions may follow suit.

Nematicides. Nematicides as a group are not technically feasible methyl bromide alternatives, in the Page 10 context of this nomination, because nematodes are not among the pests cited by exemption applicants as being the targets of concern.

Ozone. Ozone is not technically feasible because there is no known available and field feasible technology for generating ozone for cucurbit production systems in the U. S. 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 cucurbit production are very similar to steam's constraints: lack of portable ozone generation equipment that would be needed simultaneously on many, widely dispersed farms.

6d. Economic Feasibility of In Kind ( Chemical) Alternatives For cucurbits, the critical use exemption review group analyzed the economic losses associated with the use of metam sodium/ crop rotation, which was the only alternative deemed technically feasible and only in areas of low to moderate pest pressure by nutsedges. Since metam sodium is not technically feasible in Michigan due to fungal pest pressures, no economic analysis was done for Michigan.

Even under fairly conservative estimates of yield losses, the per hectare losses are substantial for metam sodium trials, and they would likely erase grower profits from cucurbit production. The efficacy of metam sodium at controlling nutsedge is not well understood, and therefore the yield losses that would result from reduced control have been shown to be highly variable and uncertain. Table 2 provides a summary of the estimated economic losses in Georgia and the Southeastern U. S. due to yield losses as estimated in the biological section and, to a lesser extent, differences in the cost of the alternatives including application costs.

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

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

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

( 2) absolute losses per hectare. For crops, this measure is closely tied to income. It is relatively easy Page 11 to measure, but may be difficult to interpret in isolation.

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

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

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

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

Table 2. Measures of Economic Impact on Cucurbits in the U. S. with Metam Sodium/ Crop Rotation as an Alternative. Loss Measure Georgia Southeast**

Per Hectare US$ 391

$ 2,918 likely $ 1,862 loss US$ 1,210  $ 9,190 likely $ 5,187 loss Per Kilogram Methyl Bromide US$ 1.74

$ 13.00 likely $ 8.29 loss US$ 5.40  $ 41.10 likely $ 23.10 loss % of Gross Revenue 1  11% likely 7% loss 4  30% loss likely 17% loss % of Net Cash Returns 6  50% likely 28% loss 9  73% loss likely 41% loss Yield Losses 1  17% likely 10% loss 3  26% loss likely 15% loss Notes. ** = Loss measures were calculated based on the data from the USDA, National Agricultural Statistics Service ( NASS).

The analysis strongly indicates that metam sodium/ crop rotation is not an economically viable alternative to methyl bromide. Losses per hectare are relatively large and are driven by yield losses and cost increases. They range from US$ 391 in Georgia to US$ 9,190 in the Southeast with annual fumigation. This represents losses of US$ 1.74  41.10 / kg of methyl bromide. Gross revenue losses are likely to be greater than 10 percent, significantly higher than annual losses in recent years. Depending on the fumigation cycle, total losses vary from 1 30 percent of gross revenues, depending on which baseline is used. Even using the higher yields and prices from the application, grower Page 12 returns ( gross revenues less operating and fixed costs) would be negative with metam sodium. Overall, the results are fairly consistent across the southern states, and suggest that metam sodium is not economically viable as an alternative for methyl bromide.

6e. Technical Feasibility of Not In Kind ( Non Chemical) Alternatives This section summarizes the analysis of the remainder of the methyl bromide alternatives identified by MBTOC for cucurbit production, primarily non chemical alternatives. Table 3 contains a summary of the technical assessment, which is that none of these alternatives were found to be technically feasible. Because no alternative was found to be technically feasible no economic assessment was conducted. A brief description of the technical infeasibility of each alternative follows the table.

Table 3. Not In Kind Methyl Bromide Alternatives Identified by MBTOC for Cucurbit Crops. Methyl Bromide Alternative Assessment of Technical Feasibility Assessment of Economic Feasibility Biofumigation No N/ A Soil solarization No N/ A Steam No N/ A Biological control No N/ A Cover crops and mulching No N/ A Crop rotation/ fallow No N/ A Endophytes No N/ A Flooding and water management o N/ A General IPM ( Integrated Pest Management) o o Grafting/ resistant rootstock/ plant breeding o o Resistant cultivars o o Organic production o o Soilless culture o o Substrates/ Plug plants o o Biofumigation. Biofumigation is not technically feasible as an alternative to methyl bromide because it does not adequately control Phytophthora species. For fungal pathogens in Michigan cucurbits, chicken manure has been tested for efficacy as a methyl bromide alternative, and found to be inadequate. Brassica residues, another potential biofumigant, have not been field tested against these cucurbit pests. However, it is the opinion of the science reviewers of the critical use exemption requests that neither type of biofumigant will adequately control soil fungi, particularly Phytophthora species. This is because these fungi have an overwintering structure, called an oospore, which is very resistant to environmental stresses and survives well in Michigan's relatively cool, moist soils. Further, predatory nematodes that would aid in the effects of biofumigation have not been properly identified or quantified in Michigan's vegetable growing regions and may not occur in adequate densities. Page 13 Control of some species of small seeded annual weeds has been reported with celery residue ( Bewick et al. 1994). The critical use exemption review group was unable to locate similar studies using other biofumigants. Interestingly, biofumigation using Brassica residue may be harmful to the crop itself, a phenomenon that has been observed for wild radish ( a Brassica species) growing in cotton ( J. Norsworthy, Clemson University, unpublished study). Given these findings and the associated uncertainty regarding this technique, the critical use exemption review group concluded that biofumigation is currently not technologically feasible for reliable nutsedge control.

Solarization. Solarization is not technically feasible as a methyl bromide alternative for control of fungal pathogens in Michigan. The climate is typically cool ( less than 11 oC frequently through May) and cloudy, particularly early in the growing season when control of these pests is particularly important.

For nutsedge control in the southeastern U. S. states, solarization is unlikely to be technically feasible as a methyl bromide alternative. Research indicates that the lethal temperature for nutsedge tubers is 50 oC or higher ( Chase et al. 1999). While this may be achieved for some portion of the autumn cropping in southern cucurbit growing regions, it is very unlikely for any portion of the spring crops. Trials conducted in mid summer in Georgia resulted in maximal soil temperatures of 43 oC at 5 cm depth. Thus, solarization, even in the warmer months in southern states, did not result in temperatures reliably high enough to destroy nutsedge tubers, and tubers lodged deeper in the soil would be completely unaffected. Solarization may be adapted to reduce low nutsedge pressure in fall cucurbits plantings ( autumn), but only in combination with efficacious herbicides and other pest management tools. Currently, however, the effective use of solarization even in this production niche remains largely unknown.

The time period for solarization to be used to raise soil temperatures to the level needed to kill soil fungi or nutsedge in any U. S. cucurbit growing region is likely to also be the time period when the crops themselves must complete their growth cycle. In Michigan, this growing season is particularly short ( May to September), so the time needed to utilize solarization is likely to render the subsequent growing of crops impossible, even if it did somehow eliminate all fungal pathogens. Even in the southern states, the use of solarization would, at the very least, disrupt the spring planting cycle for cucumbers, melons, and squash.

Steam sterilization. Steam is not a technically feasible alternative for open field cucurbit production in Michigan or the southeastern U. S. because it requires sustained heat over a required period of time. While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in the open cucurbit crops in Michigan. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to pasteurize soil down to the rooting depth of field crops ( at least 20 50 cm). This problem also applies to the control of nutsedges in the southern cucurbit growing regions. There are also currently no portable systems for any field grown crops available. team for soil sterilization is impractical in large scale, open field production areas typical in U. S. cucurbit production. A 1998 UNEP assessment also indicated that steam is an alternative to methyl bromide soil fumigation in Page 14 small scale or closed production areas, but has yet to be proven economical and practical for largescale open field production systems ( UNEP 1998).

Biological control. Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens and/ or nutsedges that afflict cucurbits. While biological control may have utility as part of a nutsedge management strategy, alone it is unlikely to replace methyl bromide for nutsedge control. The bacterium Burkholder cepacia and the fungus Gliocladium virens have shown some potential in controlling fungal plant pathogens. However, in a test conducted by the Michigan applicants, P. capsici was not controlled adequately in summer squash, a cucurbit crop, by either of these beneficial microorganisms.

Puccinia canalieunata, which causes rust ( a fungus disease), and isolates of another fungus, Dactylaria higginsii, have been studied for their suppressive effects on purple nutsedge. In the trial with rust, stand formation was reduced by 46 percent, tuber formation by 66 percent, and flowering was fully eliminated ( Phatak 1983). D. higginsii reduced the dry shoot weight and number of tubers produced by purple nutsedge by 45 to 71 percent ( Kadir et al. 2000). This is due largely to the enormous reproductive potential of nutsedge tubers. Research conducted in Georgia showed that under the prevailing climate there, a single nutsedge tuber can produce 29 shoots in 3 months and more than 320 shoots in 6 months ( Webster et al. 2002). Additionally, very high levels of one fungus ( D. higginsii) were required to achieve the consistently high results described previously. Because the fungus levels decline after the nutsedge is destroyed the weed can freely recolonize the areas treated with the fungus ( Kadir et al. 2000). Taken together, these results strongly suggest that the available biological control agents by themselves will not provide adequate control of nutsedge in southern US growing regions.

Cover crops and mulching. Cover crops and mulching are not technically feasible for the soil fungi and nutsedge which cause yield losses. While some studies done outside the U. S. suggest these practices provide some control of fungal pathogens, there is no evidence these practices effectively substitute for the control methyl bromide provides against P. capsici. Control of P. capsici is imperative for cucurbit production in Michigan. Plastic mulch is already in widespread use in Michigan vegetables, and regional crop experts state that it is not an adequate protectant when used without methyl bromide. The longevity and resistance of P. capsici oospores renders cover crops ineffective as a stand alone management alternative to methyl bromide.

As is the case with soil fungi cited by Michigan growers, cover crops and mulches appear to control many weeds, but not the nutsedge species cited by the southern US applicants. For example, Burgos and Talbert ( 1996) found that cover crops such as rye, hairy vetch and wheat controlled redroot pigweed ( Amaranthus retroflexus) and large crabgrass ( Digitaria sanguinalis), but failed to reduce populations of yellow nutsedge. The effect of cover crops on cucurbit crop growth and yield remains unknown, contributing to the technical obstacles this strategy faces as a methyl bromide alternative. In some studies cover crops have delayed crop maturity and reduced height and yield of plants ( Burgos and Talbert 1996, Galloway and Weston 1996). Mulching has also been shown to be ineffective in controlling nutsedges, since these plants are able to penetrate through both organic and Page 15 plastic mulches ( Munn 1992, Patterson 1998). Plastic mulch is already in widespread use in cucurbit crops in the U. S., as a method of preserving fertilizer and maintaining more optimal soil temperatures. It is well established that these mulches alone do not prevent nutsedge growth. In sum, the evidence thus far does not support the technical feasibility of either cover crops or mulch for nutsedge control in the absence of methyl bromide.

Crop Rotation/ Fallow Land. Crop rotation/ fallow is not a technically feasible alternative to methyl bromide because it does not, by itself, provide adequate control of fungi in Michigan or nutsedge in southern states. The crop rotations available to growers in Michigan region are also susceptible to these fungi, particularly to P. capsici. Fallow land can still harbor P. capsici oospores. Thus fungi would persist and attack cucurbits if crop rotation/ fallow land was the main management regime.

In the case of nutsedge also, the unusual hardiness of these weeds is likely to negate the beneficial effects of rotating crop types and keeping land fallow. Nutsedge tubers provide new plants with larger energy reserves than the annual weeds that can be frequently controlled by crop rotations and fallow land. Furthermore, nutsedge plants can produce tubers within 8 weeks after emergence. This enhances their survival across different cropping regimes that can disrupt other plants that rely on a longer undisturbed growing period to produce seeds to propagate the next generation.

Endophytes. Endophytes are not currently technologically feasible as a methyl bromide alternative for Michigan growers for the control of Phytophthora species, and for southeastern cucurbit growers for the control of nutsedge. Though these organisms ( fungi that grow symbiotically or as parasites within plants) have been shown to suppress some plant pathogens in cucumber, there is no such information for the other cucurbit crops grown in Michigan. Furthermore, the pathogens involved did not include Phytophthora species, which are arguably the greatest single threat to Michigan cucurbits. Similarly, the U. S. found no evidence that endophytes control nutsedges, and concluded that the current pest management information does not support the technical feasibility of endophyte control of these weeds.

Flooding and Water Management. Flooding is not technically feasible as an alternative because it does not have any suppressive effect on P. capsici, and is likely to be impractical for Michigan cucurbit growers. It is unclear whether irrigation methods in this region could be adapted to incorporate flooding or alter water management for cucurbit fields. In any case, there appears to be no supporting evidence for its use against the hardy oospores of P. capsici.

As with many of the other alternatives to methyl bromide, flooding has been shown to control a number of weeds, but not nutsedge species. Nutsedge is much more tolerant of watery conditions than many other weed pests. For example, Horowitz ( 1972) showed that submerging nutsedge in flowing or stagnant water ( for 8 days and 4 weeks, respectively) did not affect the sprouting capacity of tubers. There are also serious practical obstacles to implementing flood management approaches in cucurbit production in the southern and southeastern U. S. states. Droughts are common in many parts of these regions, and the soil composition may not support flooding and still remain productive. Page 16 These uncertainties, along with the water tolerance of nutsedge, led the critical use exemption review group to conclude that flooding and water management are not technically feasible alternatives to methyl bromide for control of these weeds.

Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. Due to the paucity of scientific information on the utility of these alternatives as methyl bromide replacements in cucurbits, they have been grouped together for discussion in this document. The U. S. was unable to locate any studies showing any potential for grafting, resistant rootstock or plant breeding as technically feasible alternatives to methyl bromide control of nutsedges in cucurbits. While in theory plant breeding may improve the ability of cucurbits to compete with these weeds for nutrients, light, etc., it would certainly not provide alternatives within the time span considered in this critical use exemption nomination. The effect on the quality of the crops involved is unknown also.

For resistant rootstock at least, there are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major cucurbit pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of Phytophthora and Fusarium fungi.

Soilless culture, organic production, and substrates/ plug plants are also not technically viable alternatives to methyl bromide for either fungi or nutsedge. In fact, a large scale trial of soilless culture of tomatoes in Florida was wiped out by an infestation of Fusarium  one of the fungi listed by the Michigan applicant as a key pest ( see critical use exemption # 0054 in the tomato sector for details). This fungus ( like Phytophthora) can spread through water, making it difficult to keep any sort of area ( with or without soil) disease free. The U. S. experts found no evidence that soilless culture or substrates/ plug plants can be used to produce cucurbit crops on a large scale, or that they will control nutsedges, which like soil fungi are particularly hardy. Various aspects of organic production

organic mulches, cover crops, fallow land, steam sterilization have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. Based on these findings, and the lack of any formal studies documenting the effectiveness of a comprehensive organic production system at a farm level, the U. S. experts concluded that " organic production" is also not a technically comparable alternative to methyl bromide for any of the cucurbit pests discussed here.

General Integrated Pest Management ( IPM). General IPM is not technically feasible as a standalone alternative to methyl bromide because it does not control the relevant soil fungi and nutsedge. U. S. experts believe it is unlikely that the suite of biological, chemical, mechanical or cultural practices encompassed by the concept of general IPM would replace fungal control by methyl bromide in cucurbits, since these techniques are in widespread use already, and there are still significant yield losses when methyl bromide is not used.

The assessment of " general IPM" as an alternative to methyl bromide control of nutsedge is similar to that of its effectiveness against soil fungi. Techniques comprised within general IPM that reduce Page 17 weeds, such as use of plastic or other mulches, cropping cycles, crop rotations, etc., are already in widespread use in cucurbit crops in the southern U. S.. Virtually all of these are included in the MBTOC list of potential methyl bromide alternatives. However, as has been discussed in this document in the sections above, it appears that none of these techniques, either by themselves or together, is currently sufficient to achieve acceptable nutsedge control in the absence of methyl bromide. There is evidence that the fumigants, iodomethane or halosulfuron, used with general IPM techniques, may be able to accomplish adequate control of soil fungi and nutsedges, but these fumigants are not registered for use in the U. S.. The use of IPM ( with these alternative fumigants) will require multi year, on farm study before one can confidently assert that it will be technically equivalent to the use of methyl bromide in cucurbits.

7. Critical Use Exemption Nomination for Cucurbits The critical use exemption actual amount requested for cucurbits were submitted by representatives of growers groups in Michigan and southeastern U. S. states. The U. S. interdisciplinary review team found a critical need for methyl bromide forcucurbits for the southeastern states and Michigan.

1. The southeastern states ( Alabama, Arkansas, Georgia, North Carolina, South Carolina, Tennessee, and Virginia) are requesting methyl bromide for 2005, 2006, and 2007. The growers requested an average of 1,117,966kgs methyl bromide for fumigating a total of 6,700 hectares. The use rates conform to standard cucurbit practices in this region. Rates as requested conform to standard cucurbit practices in the southeast ( Table 4).

Table 4. Methyl Bromide Usage and Request for Cucurbits in Southeastern States.

1997 1998 1999 2000 2001 2005 2006 2007 tonne 1,049 1,240 1,018 991 1,161 1,160 1,162 1,162 hectares 4,590 5,400 6,160 6,540 7,720 7,720 7,720 7,720 rate ( kg/ ha) 235 235 170 150 150 150 150 150 It appears that the application rate in Georgia may be declining which would be consistent with the fact that the applicant has changed their formulation of methyl bromide from 98 percent to 67 percent methyl bromide formulations. Out of a total of 23,800 hectares estimated by U. S. EPA to be planted by the Georgia growers in 2001, we are nominating about 40 percent of their cucurbit hectares, which is the approximate amount of land that has a serious nutsedge infestation.

It seems that the application rate for the southeastern states may be declining, which would be consistent with the fact that, as with Georgia, growers here have changed their formulation of methyl bromide from 98 percent to 67 percent methyl bromide formulations. Out of a total of 20,440 hectares estimated by U. S. EPA to be planted by the Southeastern growers in 2001, we are Page 18 nominating about 25 percent of their cucurbit hectares which is the approximate amount of land that has nutsedge infestation.

2. Michigan farms are requesting methyl bromide for 2005, 2006, and 2007. The growers requested an average of 27,480 kgs methyl bromide for fumigating a total of 570 hectares a year. The use rates requested conform to standard cucurbit practices in Michigan ( Table 5).

Table 5. Methyl Bromide Usage and Requests for Cucurbits in Michigan.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 27,660 26,590 26,590 30,320 30,320 28,190 27,660 26,590 hectares 230 220 220 250 250 190 230 220 rate ( kg/ ha) 120 120 120 120 120 150 120 120 The application rate for Michigan appears to have remained consistent through the years, which is as expected, due to the fact that they have historically been using 67 percent methyl bromide since 1997. The use rate is lower in Michigan than elsewhere in the U. S. probably due to differences in pest pressure such that pests are controlled with a lower concentration of methyl bromide. Out of a total of 6,030 hectares estimated by U. S. EPA to be planted by the Michigan applicants in 2001, we are nominating 3 percent of their cucurbit hectares which is the approximate amount of land that has Phytophthora infestation.

The total U. S. nomination for cucurbits has been determined based first on consideration of the requests we received and an evaluation of the supporting material. This evaluation, which resulted in a reduction in the amount being nominated, included careful examination of issues including the area infested with the key target ( economically significant) pests for which methyl bromide is required, the extent of regulatory constraints on the use of registered alternatives ( buffer zones, township caps), environmental concerns such as soil based restrictions due to potential groundwater contamination, and historic use rates, among other factors.

Table 6. Methyl Bromide Critical Use Exemption Nomination for Cucurbits Year Total Request by Applicant ( kilograms) U. S. Sector Nomination ( kilograms)

2005 1,187,773 1,187,773 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 Page 19 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. Use/ 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 bromide, users have been experimenting with significant increases in the level of chloropicrin and reductions in the level of methyl bromide. While these new mixtures have generally been effective at controlling target pests, it must be stressed that the long term efficacy of these mixtures is unknown. Reduced methyl bromide concentrations in mixtures, more mechanized soil injection techniques, and the extensive use of tarps to cover land treated with methyl bromide has resulted in reduced emissions and an application rate that we believe is among the lowest in the world.

In terms of compliance, in general, the United States has used a combination of tight production and import controls, and the related market impacts to ensure compliance with the Protocol requirements on methyl bromide. Indeed, over the last

years, the price of methyl bromide has increased substantially. As Chart 1 in Appendix D demonstrates, the application of these policies has led to a more rapid U. S. phasedown in methyl bromide consumption than required under the Protocol. This accelerated phasedown on the consumption side may also have enabled methyl bromide production to be stockpiled to some extent to help mitigate the potentially significant impacts associated with the Protocol's 2003 and 2004 70% reduction. We are currently uncertain as to the exact quantity of existing stocks going into the 2003 season that may be stockpiled in the U. S. We currently believe that the limited existing stocks are likely to be depleted during 2003 and 2004. This factor is Page 20 reflected in our requests for 2005 and beyond.

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

10. U. S. Efforts to Find, Register and Commercialize Alternatives to Methyl Bromide Over the past ten years, the United States has committed significant financial and technical resources to the goal of seeking alternatives to methyl bromide that are technically and economically feasible to provide pest protection for a wide variety of crops, soils, and pests, while also being acceptable in terms of human health and environmental impacts. The U. S. pesticide registration program has established a rigorous process to ensure that pesticides registered for use in the United States do no present an unreasonable risk of health or environmental harm. Within the program, we have given the highest priority to rapidly reviewing methyl bromide alternatives, while maintaining our high domestic standard of environmental protection. A number of alternatives have already been registered for use, and several additional promising alternatives are under review at this time. Our research efforts to find new alternatives to methyl bromide and move them quickly toward registration and commercialization have allowed us to make great progress over the last decade in phasing out many uses of methyl bromide. However, these efforts have not provided effective alternatives for all crops, soil types and pest pressures, and we have accordingly submitted a critical use nomination to address these limited additional needs.

Research Program When the United Nations, in 1992, identified methyl bromide as a chemical that contributes to the depletion of the ozone layer and the Clean Air Act committed the U. S. to phase out the use of methyl bromide, the U. S. Department of Agriculture ( USDA) initiated a research program to find viable alternatives. Finding alternatives for agricultural uses is extremely complicated compared to replacements for other, industrially used ozone depleting substances because many factors affect the efficacy such as: crop type, climate, soil type, and target pests, which change from region to region and among localities within a region.

Through 2002, the USDA Agricultural Research Service ( ARS) alone has spent US$ 135.5 million to implement an aggressive research program to find alternatives to methyl bromide ( see Table 1 below). Through the Cooperative Research, Education and Extension Service, USDA has provided an additional $ 11.4m since 1993 to state universities for alternatives research and outreach. This federally supported research is a supplement to extensive sector specific private sector efforts, and that all of this research is very well considered. Specifically, the phaseout challenges brought together agricultural and forestry leaders from private industry, academia, state governments, and the federal government to assess the problem, formulate priorities, and implement research directed at providing solutions under the USDA's Methyl Bromide Alternatives program. The ARS within USDA has 22 national programs, one of which is the Methyl Bromide Alternatives program ( Select Methyl Bromide Page 21 Alternatives at this web site: http:// www. nps. ars. usda. gov ). The resulting research program has taken into account these inputs, as well as the extensive private sector research and trial demonstrations of alternatives to methyl bromide. While research has been undertaken in all sectors, federal government efforts have been based on the input of experts as well as the fact that nearly 80 percent of preplant methyl bromide soil fumigation is used in a limited number of crops. Accordingly, much of the federal government pre plant efforts have focused on strawberries, tomatoes, ornamentals, peppers and nursery crops, ( forest, ornamental, strawberry, pepper, tree, and vine), with special emphasis on tomatoes in Florida and strawberries in California as model crops.

Table 1: Methyl Bromide Alternatives Research Funding History Year Expenditures by the U. S. Department of Agriculture ( US$ Million)

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

Research results submitted with the CUE request packages ( including published, peer reviewed studies by ( primarily) university researchers, university extension reports, and unpublished studies) include trials conducted to assess the effectiveness of the most likely chemical and non chemical alternatives to methyl bromide, including some potential alternatives that are not currently included in Page 22 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.

Research Results Submitted for Cucurbits Government funded studies related to U. S. cucurbit production that are currently on going include a multi year study ( currently ongoing and ending in 2005) in the southeaster U. S., being conducted by the ARS. This project will examine the integrated management and ecology of weed populations in crops grown in the Southeastern coastal plain. Among other goals, this project will develop alternative nutsedge management systems for selected vegetable crops ( including cucurbits) with an emphasis on integrating cultural and tillage practices for weed control. Alternate methods for fumigating soil to manage weeds and other soil pests are being evaluated in this effort. Also, weedcrop interactions and weed population dynamics in irrigated and reduced tillage systems are being studied as part of this work. The ARS is also undertaking research projects studying alternative methods to control Phytophthora and Fusarium fungi, albeit in non cucurbit crops such as tomatoes and peppers. Results from this work should be applicable to cucurbit production also. Details of these projects are provided in the nomination chapters for those crops.

The U. S. government, along with grower associations, is also indirectly supporting research conducted by universities on alternatives to methyl bromide use in cucurbits. Research results submitted with the cucurbit critical use exemption request packages ( including published, peerreviewed studies by university researchers, university extension reports, and unpublished studies) include trials conducted to assess the effectiveness of the most likely chemical and non chemical alternatives to methyl bromide, including some potential alternatives that are not currently included in the MBTOC list. Research planned for the next few years will also refine estimates of yield loss, and to quantify impacts on quality of harvested cucurbits, in situations where chemical or non chemical alternatives are used in place of methyl bromide.

In addition to the research that is ongoing under the U. S. Department of Agriculture ( described above), applicants that have submitted critical use exemption requests for cucurbits have cited the following research plans as ones they are funding or otherwise participating in:

( 1) For Michigan cucurbits, testing is planned for alternatives to methyl bromide for control of P. capsici and F. oxysporum on cucurbits in Michigan. Testing is planned for April to October, 2003 2004 in southwestern Michigan. Alternatives to be tested include: furfural ( Multiguard), alone and Page 23 with metam sodium, 1,3 dichloropropene ( telone), chloropicrin ( 100 percent), iodomethane, and composted chicken manure. So far, US $ 1.1 million has been spent on research.

( 2) For Georgia squash and cucumbers, testing is planned for combinations of fumigants and herbicide replacements. Testing is planned for 2003 2004 in southwest Georgia. Alternatives to be tested include: chloropicrin, 1,3 dichloropropene ( alone and in combination), as well as halosulfuron, metolachlor, metam sodium, metam potassium, sulfentrazone, and many combinations of these chemicals. So far, US $ 230,000 has been spent on research.

( 3) For southeastern cucurbits, testing is planned for various alternatives including herbicides ( metolachlor, rimsulfuron, dimethenamid) in combination with certain fumigants. In 2003, studies will be conducted in North Carolina to evaluate halosulfuron and flumioxazin herbicides applied at different times prior to planting cucurbit crops for control of both yellow and purple nutsedge.

Trials with 1,3 dichloropropene and 1,3 dichloropropene + chloropicrin have shown inadequate control of fungi in cucurbits. However, as stated earlier, it may be possible to incorporate 1,3 dichloropropene into a larger fungus management program involving other fungicides and cultural control. Iodomethane shows promise in controlling Phytophthora and Fusarium fungi in efficacy trials and efforts are underway to register it for cucurbit crops in the U. S. Larger scale field trials are planned for iodomethane related to control of soil pathogens. Research is also planned for the next few years to study the implementation of cultural practices such as raised beds, different crop spacing schemes, and timing of irrigation, to improve control of soil fungal pathogens of cucurbits.

For nutsedge control, research results thus far indicate good control with halosulfuron of both yellow and purple nutsedge ( selectively over other weed species). However, the selectivity of halosulfuron suggests that despite its effectiveness against nutsedge, it can only be a part of a larger management regime if methyl bromide is fully eliminated from cucurbit crops.

The research summarized here will undoubtedly take several years to yield optimal strategies for replacing methyl bromide. Replacement will likely require multiple techniques simultaneously implemented ( regardless of whether the pests involved are fungi or weeds). Thus, it is reasonable to expect that a " generalized" IPM approach involving the judicious use of the fumigants mentioned in this section, along with modifications in cultural practices can be developed over the next few years. However, the need to demonstrate the effectiveness of new management strategies over multiple growing seasons, on a large field scale, means that the research described here will not enable total methyl bromide replacement in cucurbits, for the next 3 to 4 years, at least.

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. Page 24 Registration Program The United States has one of the most rigorous programs in the world for safeguarding human health and the environment from the risks posed by pesticides. While we are proud of our efforts in this regard, related safeguards do not come without a cost in terms of both money and time. Because the registration process is so rigorous, it can take a new pesticide several years ( 3 5) to get registered by EPA. It also takes a large number of years to perform, draft results and deliver the large number of health and safety studies that are required for registration.

The U. S. EPA regulates the use of pesticides under two major federal statutes: the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) and the Federal Food, Drug, and Cosmetic Act ( FFDCA), both significantly amended by the Food Quality Protection Act of 1996 ( FQPA). Under FIFRA, U. S. EPA registers pesticides provided its use does not impose adverse effects on 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 registration priority. Because the U. S. EPA currently has more applications pending in its review processes than the resources to evaluate them, U. S. EPA prioritizes the applications in its registration queue. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for EPA to initiate its review. Once the review process begins, the average processing time from date of submission to issuance of a registration decision, is approximately 38 months. In addition, the registrant ( the pesticide applicant) has spent approximately 7 10 years developing the data necessary to support registration.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the U. S. EPA has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the U. S. EPA's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the U. S. EPA has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, U. S. EPA scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability Page 25 that the data is done right the first time and rework delays are minimized The U. S. EPA has also co chaired the USDA/ EPA methyl bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. The work group conducted six workshops in Florida and California ( states with the highest use of methyl bromide) with growers and researchers to identify potential alternatives, critical issues, and grower needs covering the major methyl bromide dependent crops and post harvest uses.

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

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

1999: Pebulate to control weeds in tomatoes 2000: Phosphine to control insects in stored commodities 2001: Indian Meal Moth Granulosis Virus to control Indian meal moth in stored grains 2001: Terrazole to control pathogens in tobacco float beds 2001: Telone applied through drip irrigation  all crops 2002: Halosulfuron methyl to control weeds in melons and tomatoes EPA is currently reviewing several additional applications for registration as methyl bromide alternatives, with several registration eligibility decisions expected within the next year, including:

  Iodomethane as a pre plant soil fumigant for various crops   Fosthiazate as a pre plant nematocide for tomatoes   Sulfuryl fluoride as a post harvest fumigant for stored commodities   Trifloxysulfuron sodium as a pre plant herbicide for tomatoes   Dazomet as a pre plant soil fumigant for strawberries and tomatoes Again, while these activities appear promising, it must be noted that issues related to toxicity, ground water contamination, and the release of air pollutants may pose significant problems with respect to some alternatives that may lead to use restrictions since many of the growing regions are in sensitive areas such as those in close proximity to schools and homes. Ongoing research on alternate fumigants is evaluating ways to reduce emission under various application regimes and examining whether commonly used agrochemicals, such as fertilizers and nitrification inhibitors, could be used to rapidly degrade soil fumigants. For example, if registration of iodomethane or another alternative occurs in the near future, commercial availability and costs will be factors that must be taken into Page 26 consideration.

It must be emphasized, however, that finding potential alternatives, and registering those alternatives is not the end of the story. Those alternatives must be trialed by users and must be finally adopted, which takes time. Allowing for users to trial alternatives, so farmers can adopt them, also involves time. As noted by TEAP, a specific alternative, once available may take two or three cropping seasons of use before efficacy can be determined in the specific circumstance of the user. In an effort to reduce related time frames, the United States government has also been involved in these steps by promoting technology transfer, experience transfer, and private sector training.

11. Conclusion and Policy Issues Associated with the Nomination In summary, a review of the critical use exemption criteria in Decision IX/ 6 demonstrates that the Parties clearly understood the many issues that make methyl bromide distinctly different from the industrial chemicals previously addressed by the Parties under the essential use process. It is now the challenge of the MBTOC, TEAP and the Parties to consider the national submission of critical use nominations in the context of those 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 of the methyl bromide alternatives included in the MBTOC list, only one ( metamsodium appears to have some technical efficacy, and only against nutsedges affecting the southeastern States in the U. S. Even in this case, the estimated yield losses incurred by reliance on metam sodium are likely to be economically devastating for growers in these regions. While some of the other alternatives hold promise against either fungal pathogens or nutsedge weeds, they cannot be used as single alternatives to methyl bromide. Research over multiple years is needed before a combination of management techniques, incorporating all alternatives that have some efficacy, will be able to take the place of methyl bromide. Without the methyl bromide exemption for 2005 and 2006, growers of cucumbers, melons and squash in the eight states are not expected to be able to maintain their annual crop values at levels comparable to those of 1997 2001, due to the current lack of effective alternatives to methyl bromide to control target pests, which would result in significantly lower than historical yields.

In addition, we have demonstrated that the U. S. continues to expend significant efforts to find and commercialize alternatives, and that potential alternatives to the use of methyl bromide in cucurbits 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 long and rigorous. Therefore, the U. S. need for methyl bromide for cucurbits 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 Page 27 follows:

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

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

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

Chart 2 in Appendix D demonstrates several things. First, despite the best efforts of many countries to predict future conditions, it shows that due to the acknowledged uncertainty of out year need for MDIs, Parties had the tendency to request, the TEAP recommended, and the Parties approved national requests that turned out to include an appreciable margin of safety. In fact, this margin of safety was higher at the beginning   about 40% above usage   and then went down to 30% range after 4 years. Only after 5 years of experience did the request come down to about 10% above usage. While our experience with the Essential Use process has aided the U. S. in developing its Critical Use nomination, we ask the MBTOC, the TEAP and the Parties to recognize that the complexities of agriculture make it difficult to match our request exactly with expected usage when the nomination is Page 28 made two to three years in advance of the time of actual use.

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

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

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

Primary Contact: John E. Thompson, Ph. D. Office of Environmental Policy U. S. Department of State 2201 C Street NW Rm 4325 Washington, DC 20520 tel: 202 647 9799 fax: 202 647 5947 Page 29 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 Bewick, T. A., D. G. Shilling, J. A. Dusky, and D. Williams. 1994. " Effects of celery ( Apium graveolens) root residue on growth of various crops and weeds." Weed Technology 8: 625

629.

Burgos, N. R. and R. E. Talbert. 1996. " Weed control and sweet corn ( Zea mays var. rugosa) response in a no till system with cover crops." Weed Science 44 ( 2): 355

361.

Chase, C. A., T. R. Sinclair, and S. J. Locascio. 1999. " Effects of soil temperature and tuber depth on Cyperus spp. control." Weed Science 47: 467

472.

Dowler, C. C. 1999. " Herbicide activity of metham, methyl iodide, and methyl bromide applied through irrigation systems. Proc. Southern" Weed Science Soc. 52: 77

78.

Friesen, G. H. 1978. " Weed interference in pickling cucumbers ( Cucumis sativus)." Weed Science 26( 6): 626 628.

Galloway, B. A. and L. A. Weston. 1996. " Influence of cover crop and herbicide treatment on weed control and yield in no till sweet corn ( Zea mays L.) and pumpkin ( Cucurbita maxima Duch.)." Weed Technology 10 ( 2): 341

346.

Kadir, J. B., R. Charudattan, W. M. Stall, and B. J. Brecke. 2000. " Field efficacy of Dactylaria higginsii as a bioherbicide for the control of purple nutsedge ( Cyperus rotundus)." Weed Technology 4( 1): 1

6.

Holm, L. G., D. L. Plucknett, J. V. Pancho, and J. P. Herberger. 1977. The World's Worst Weeds: Distribution and Biology. East West Center, University Press of Hawaii, Honolulu. 609 pp.

Horowitz, M. 1972. " Effects of desiccation and submergence on the viability of rhizome fragments of bermudagrass and johnsongrass and tubers of nutsedge." Israel J. Agric. Res. 22 ( 4): 215

220. Page 30 Munn. D. A. 1992. " Comparison of shredded newspaper and wheat straw as crop mulches." Hoert technol. 2: 361  366. Nerson, H. 1989. " Weed competition in muskmelon and its effects on yield and fruit quality." Crop Prot. 8: 439 442.

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

hatak, S. C., D. R. Sumner, H. D. Wells, D. K. Bell, and N. C. Glaze. 1983. " Biological control of yellow nutsedge, Cyperus esculentus, with the indigenous rust fungus Puccinia canaliculata." Science. 219: 1446

1448.

Schrader, W. L., J. L. Aguiar, and K. S. Mayberry. 2002. " Cucumber production in California." University of California Agriculture and Natural Resources. Publication 8050. http:// anrcatalog. ucdavis. edu/ pdf/ 8050. pdf Thullen R. J., and P. E. Keeley. 1979. Seed production and germination in Cyperus esculentus and Cyperus rotundus. Weed Sci. 27 ( 5): 502

505.

UNEP ( United Nations Environment Programme). 1998. Methyl Bromide Technical Options Committee ( MBTOC) 1998 assessment of alternatives to methyl bromide. p. 49. USDA. 2000. Vegetables, Annual Summary. NASS ( National Agricultural Statistical Service).

USDA. 2002. Vegetables, Annual Summary. NASS ( National Agricultural Statistical Service).

Webster, T. M. 2000. Nutsedge ( Cyperus spp.) " Eradication: Impossible Dream?" In: Riley, L. E., R. K. Dumroese, and T. D. Landis ( eds.). National Nursery Proceedings RMRS P 000. USDA Forest Service. Ogden, Utah.

Webster, T. M. , and G. E. Macdonald. 2001( b). " A survey of weeds in various crops in Georgia." Weed Technol. 15: 771 790. Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, and R. L. Fery. 2002. " Methyl bromide alternatives in a bell pepper

squash rotation." Crop Prot. 20 ( 7): 605

614.

William, R. D., and G. F. Warren. 1975. " Competition between purple nutsedge and vegetables." Weed Sci. 23: 317 323.

14. Appendices.

Appendix A: List of Critical Use Exemption ( CUE) Requests for the Cucurbit Crop Sector in the U. S.

CUE 02 0005, Michigan Cucurbit Page 31 CUE 02 0042, Southeastern Cucurbit Consortium CUE 02 0048, Georgia Fruit and Vegetable Growers Association  Squash CUE 02 0051, Georgia Fruit and Vegetable Growers Association  Cucumber CUE 02 0052, Georgia Fruit and Vegetable Growers Association  Melon Page 32 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 subregions 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 33 # Notes 1 alternative assumed to cost the same as MeBr 2 applicant statistics, 10% yield loss in squash, 5% losses in following cabbage 3 5% yield loss in squash, no losses in following cabbage 4 25% yield loss in squash, no losses in following cabbage 5 applicant statistics, 10% yield loss in cantaloup and squash 6 applicant statistics, 10% yield loss in cantaloup and squash, no losses in cabbage 7 applicant statistics, 5% yield loss in cantaloup, no yield losses in following crops Page 34 8 applicant statistics, 25% yield loss in cantaloup, no yield losses in following crops Page 35 * lb ai that would be applied/ acre = application rate for the alternatives or requested application rate for MBr. Page 36 * Other pest control costs are those other than methyl bromide or its alternatives. Page 37 Appendix C: U. S. Technical and Economic Review Team Members Christine M. Augustyniak ( Technical Team Leader). Christine has been with the U. S. Environmental Protection Agency since 1985. She has held several senior positions, both technical and managerial, including Special Assistant to the Assistant Administrator for Prevention, Pesticides, and Toxic Substances, Chief of the Analytical Support Branch in EPA's office of Environmental Information and Deputy Director for the Environmental Assistance Division in the Office of Pollution Prevention and Toxics. She earned her Ph. D. ( Economics) from The University of Michigan ( Ann Arbor). Dr. Augustyniak is a 1975 graduate of Harvard University ( Cambridge) cum laude ( Economics). Prior to joining EPA, Dr. Augustyniak was a member of the economics faculty at the College of the Holy Cross ( Worcester).

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

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

Diane Brown Rytlewski ( Biologist) Diane is the Nursery and Landscape IPM Integrator at Michigan State University, a position she has held since 2000. She acts as liaison between industry and the university, facilitating research partnerships and cooperative relationships, developing outreach programs and resource materials to further the adoption of IPM. Ms. Rytlewski holds a Master of Science ( Plant Pathology) and a Bachelor of Science ( Entomology), both from the University of Wisconsin ( Madison). She has over twenty year experience working in the horticulture field, including eight years as supervisor of the IPM program at the Chicago Botanic Garden.

Greg Browne ( Biologist). Greg has been with the Agricultural Research Service of the U. S. Department of Agriculture since 1995. Located in the Department of Plant Pathology of the Page 38 University of California ( Davis), Greg does research on soilborne diseases of crop systems that currently use methyl bromide for disease control, with particular emphasis on diseases caused by Phytophthora species. He is the author of numerous articles on the use of alternatives to methyl bromide for the control of diseases in fruit and nut crops He earned his Ph. D. ( Plant Pathology) from the University of California ( Davis) and a Master of Science ( Plant Pathology) from the same institution. Dr. Browne is a graduate of The University of California ( Davis). Prior to joining USDA was a farm advisor in Kern County.

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

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

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

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

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

Tara Chand Goyal ( Biology). Tara has been with the U. S. Environmental Protection Agency since 1997. He serves in the Office of Pesticide Programs as a plant pathologist and specializes in Page 39 analyzing the efficacy of pesticides with emphasis on risk reduction. He earned his Ph. D. ( Mycology and Plant Pathology) from The Queen's University ( Belfast) and a Master of Science ( Plant Pathology and Mycology) from Punjab University ( Ludhiana). Dr. Chand Goyal is a graduate of Punjab University. Prior to joining EPA Dr. Chand Goyal was a member of the faculty of The Oregon State University ( Corvallis) and of The University of California ( Riverside). His areas of research and publication include: the biology of viral, bacterial and fungal diseases of plants; biological control of plant diseases; and, genetic manipulation of microorganisms.

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

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

Colwell Cook ( Biologist). Colwell has been with the U. S. Environmental Protection Agency since 2000. She serves in the Office of Pesticide Programs as an entomologist and specializes in analyzing the efficacy of pesticides with emphasis on benefits of pesticide use. She earned her Ph. D. ( Entomology) from Purdue University ( West Lafayette) and has a Master of Science ( Entomology) from Louisiana State University ( Baton Rouge). Dr. Cook is a 1979 graduate of Clemson University. Prior to joining EPA Dr. Cook held several faculty positions at Wabash College ( Crawfordsville) and University of Evansville ( Evansville).

Julie B. Fairfax ( Biologist) Julie has been with the U. S. Environmental Protection Agency since 1989. She currently serves as a senior biologist in the Biological and Economics Analysis Division, and has previously served as a Team Leader in other divisions within the Office of Pesticides Programs. She has held several technical positions specializing in the registration, re registration, special review and regulation of fungicidal, antimicrobial, and wood preservative pesticides. Ms. Fairfax is a 1989 graduate of James Madison University ( Harrisonburg, VA) where she earned her degree in Biology. Prior to joining EPA, Julie worked as a laboratory technician for the Virginia Poultry Industry.

John Faulkner ( Economist) John has been with the U. S . Environmental Protection Agency since Page 40 1989. He serves in the Office of Pesticide Programs analyzing the costs imposed by the regulation of pesticides. He earned his Ph. D. ( Economics) from the University of Colorado ( Boulder) and holds a Master's of Business Administration from The University of Michigan ( Ann Arbor). Dr. Faulkner is a 1965 graduate of the University of Colorado ( Boulder). Prior to joining EPA was a member of the economics faculty of the Rochester Institute of Technology ( Rochester), The University of Colorado ( Boulder) and of the Colorado Mountain College ( Aspen).

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

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

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

Frank Hernandez ( Economist). Frank has been with the U. S. Environmental Protection Agency since 1991. He is a staff economist at the Biological and Economic Analysis Division of the Office of Pesticide Programs. He holds degrees in Economics and Political Science from the City University of Page 41 New York.

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

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

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

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

Nikhil Mallampalli ( Biologist). Nikhil has been with the U. S. Environmental Protection Agency since 2001. He is an entomologist in the Herbicide and Insecticide Branch of the Biological and Economic Analysis Division. His primary duties include the assessment of pesticide efficacy in a variety of crops, and analysis of the impacts of risk mitigation on pest management. Dr. Mallampalli earned his Ph. D. ( Entomology) from The University of Maryland ( College Park) and holds a Master of Science ( Entomology) from the samr institution. Prior to joining the EPA, he worked as a postdoctoral research fellow at Michigan State University ( East Lansing) on IPM projects designed to reduce reliance on pesticides in small fruit production. Page 42 Tom Melton ( Biologist). Tom has been a member of the Plant Pathology faculty at North Carolina State University since 1987. Starting as an assistant professor and extension specialist, Tom has become the Philip Morris Professor at North Carolina State University. His primary responsibilities are to develop and disseminate disease management strategies for tobacco. Dr. Melton earned his Ph. D. ( Plant Pathology) from The University of Illinois ( Urbana Champaign) and holds a Master of Science ( Pest Management) degree from North Carolina State University ( Raleigh). He is a 1978 graduate of Norht Carolina State University ( Raleigh) Prior to joining the North Carolina State faculty, Dr. Melton was a member of the faculty at The University of Illinois ( Urbana Champaign).

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

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

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

Jack Norton( Biologist). Jack has worked for the U. S. Department of Agriculture Interregional research Project # 4 ( IR 4) as a consultant since 1998. The primary focus of his research is the investigation of potential methyl bromide replacement for registration on minor crops. He is an active member of the USDA/ EPA Methyl Bromide Alternatives Working Group. Dr, Norton earned his Ph. D. ( Horticulture) from Texas A& M University ( College Station) and holds a Master of Science ( Horticultural Science) from Oklahoma State University( Stillwater). He is a graduate of Oklahoma State University ( Stillwater). Prior to joining the IR 4 program, Dr. Norton worked in the crop protection industry for 27 years where he was responsible for the development and registration of a number of important products. Page 43 Olga Odiott ( Biologist) Olga has been with the U. S. Environmental Protection Agency since 1989. She has held several technical positions and currently serves as a Senior Biologist within the Office of Science Coordination and Policy. In this position she serves as Designated Federal Official and liaison on behalf of the Office of Pesticide Programs and the FIFRA Scientific Advisory Panel, an independent peer review body that provides advice to the Agency on issues concerning the impact of pesticides on health and the environment. She holds a Masters of Science ( Plant Pathology) from the University of Puerto Rico ( San Juan). Prior to joining EPA, Ms. Odiott worked for the U. S. Department of Agriculture.

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

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

Erin Rosskopf ( Biologist). Erin received her PhD from the Plant Pathology Department, University of Florida, Gainesville in 1997. She is currently a Research Microbiologist with the USDA, ARS and has served in this position for 5 years.

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

Judith St. John ( Biologist). Judy has been with the USDA's Agricultural Research Service since 1967. She currently serves as Associate Deputy Administrator and as such she is responsible for the Department's intramural research programs in the plant sciences, including those dealing with pre and post harvest alternatives to methyl bromide. Dr. St. John earned her Ph. D. ( Plant Physiology) from The University of Florida ( Gainesville). Page 44 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 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 Page 45 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 46 Appendix D: CHARTS ( See separate electronic file for CHART 1 and CHART 2)