2003 NOMINATION FOR A CRITICAL USE EXEMPTION FOR FOREST TREE SEEDLINGS 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 forest tree seedlings, like the nomination for all other crops included in the U. S. request, includes general background information that the U. S. believes is critical to enabling review of our nomination in a manner that meets the requirements of the Parties' critical use decisions. With that understanding, the fully integrated U. S. nomination for forest tree seedlings 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 forest tree seedlings, 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 forest tree seedlings is discussed later in this nomination.

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

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

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

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

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

The Essential Use exemption largely assumed that an alternative used in one place could, if approved by the government, be used everywhere. Parties clearly understood that this was not the case with methyl bromide because of the large number of variables involved, such as crop type, soil types, pest pressure and local climate. That is why the methyl bromide Critical Use exemption calls for an 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 Forest Tree Seedlings Work on the U. S. critical use exemption process began in early 2001. At that time, the U. S. Environmental Protection Agency ( U. S. EPA) initiated open meetings with stakeholders both to inform them of the Protocol requirements, and to understand the issues being faced in researching alternatives to methyl bromide. During those meetings, which were attended by State and associated 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 forest tree seedling growers from 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. Page 4 government.

5. Overview of Agricultural Production 5a. U. S. Agriculture The U. S. is fortunate to have a large land expanse, productive soils and a variety of favorable agricultural climates. These factors contribute to and enable the U. S. to be a uniquely large and productive agricultural producer. Indeed, the size and scope of farming in the U. S. is different than in most countries. Specifically, in 2001, U. S. farm land totaled 381 million hectares, a land mass larger than the size of many countries. There were 2.16 million farms, with average farm size across all farms of 176 hectares ( approximately 10 times larger than average farm sizes 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 impact on the way agriculture has developed in the U. S. Specifically, these factors have meant that greenhouse production has generally proven to be very costly ( in relative terms) and has as a consequence, been limited.

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

Farming in the U. S. 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 increased as the number of farms has fallen. The related yield increases per land area are almost exclusively related to nonlabor inputs, like the adoption of new varieties, and the application of new production practices, including plastic mulches, row covers, high density planting, more effective pesticide sprays, and drip irrigation, as well as increased water irrigation practices. Optimization of yields through these and other scientific and mechanized practices make U. S. agricultural output very sensitive to changes in inputs. Therefore, as evidenced by the U. S. nomination for critical uses of methyl bromide, the phaseout of methyl bromide can have a very significant impact on both the technical and economic viability of production of certain crops in certain areas. Page 5 5b. Forest Tree Seedling Nurseries U. S. forest tree seedling production exemplifies many of the characteristics of U. S. agriculture noted above. Specifically, forest tree seedlings are grown in most of the geographical areas of the U. S.. As a consequence, this nomination covers use in a variety of areas with differing soil and climactic characteristics. Specifically, it covers forest tree seedling production in three distinct regions, the north, south and west, that generally face different pests and grow slightly different species.

Forest tree nurseries in the U. S. supply seedlings of conifers and hardwoods that are used for reforestation, forest establishment, fiber production, and wildlife and conservation uses. A typical forest tree seedling nursery ranges in size from 40 80 hectares. About 55 hectares within a nursery is available for growing seedlings in any given year. Nurseries in the U. S. are located in eight climate zones ( Zones 3 to 10) mostly with either light soils with 0 2 percent organic matter or medium soils with 2 5 percent organic matter. These nurseries produce approximately 200 300 million bareroot seedlings each year. For example, in the southern region of the U. S., nurseries provide forest tree seedlings which are used each year to plant 600,000 hectares of forests. Nationally, the majority of seedlings are species of conifers, especially pine. In addition, 30 40 species of the seedlings produced annually are hardwoods, such as oaks, hickory, poplars, and ash. Nurseries produce seedlings adapted to their respective regional conditions, including climate and soil type. Forest tree nurseries are operated by state and federal governments, large commercial companies and small private entities. The high value of forest tree seedlings is reflected in the value of conifer production in the U. S. estimated at over US$ 402 million in 2000 ( USDA NASS, 2001).

Forest tree seedlings are valued according to their grade, which is a quality assessment that includes diameter, root volume, and seedling height. Seedlings are put into Grades: # 1, # 2, and culls. The quality of seedlings is correlated with the ultimate quality of the forest and corresponding long term economic and use benefits. A higher quality seedling implies better survival and faster growth. Seedling quality is reflected in the price received, with # 2 seedlings valued at about two thirds that of # 1 seedlings. Culls cannot be sold and may be recycled for organic matter. Seedling yield and quality can be improved by optimizing nursery management practices. Disease and weed management strategies, including fumigation, produce healthy seedlings that have to compete less for nutrients and sunlight while maintaining greater ability to survive under forest conditions.

6. Results of Review B Determined Need for Methyl Bromide for Forest Tree Seedling Nurseries For nurseries producing forest tree seedlings, weeds, especially two types of nutsedge, and fungal pathogens are the most serious concern. The critical use exemption nomination is primarily based on the lack of reliable alternatives to control nutsedge species and fungal pathogens. Nutsedge species interfere with the intensive production practices and high requirements for seedling quality of this sector. Tree seedlings, of course, are only the first step in the long term investment associated with the high valued forests, whether commercial or public. The implications associated with forest growth and health extend over a 20 40 year period. Seedling quality has been highly correlated with Page 6 productive and healthy forests impacting both commercial and public interests.

The majority of forest tree nurseries raise conifer seedlings for one or two years followed by one or two years of fallow or cover crops. Therefore, managers typically fumigate a particular conifer seedling bed with methyl bromide only once every 3 to 4 years, i. e., only 1/ 3 1/ 4 of the total nursery land is fumigated each year to produce two or three harvestable forest tree seedling crops per single bed fumigation. For hardwood seedlings, fumigation is usually provided prior to each seedling crop, as hardwood species are generally more prone to root rots and damping off diseases. Effective fumigants, such as methyl bromide permit less frequent bed fumigation per harvestable seedling crop.

Methyl bromide is commonly applied in combination with chloropicrin with a methyl bromide component of 67 percent or 98 percent ( e. g., Landis and Campbell, 1989). Rates of methyl bromide typically range between 115 160 kg/ ha, depending on the region, plant species, and soil type. In general, warmer and moister conditions in the southern U. S. promote increased pest populations and require higher fumigation rates while nurseries in the cooler, drier western and northern region can achieve adequate control with somewhat lower application rates. Methyl bromide provides consistent and broad control over the target pests, including severe infestations of weeds, pathogens, ( and where they are a problem) nematodes.

6a. Target Pests Controlled With Methyl Bromide Although forest nurseries in the U. S. contend with a variety of pests, methyl bromide is of particular importance in managing fungal pathogens and yellow and purple nutsedges ( species of the Cyperus weed) ( Cram and Fraedrich, 1997). Nutsedges are generally considered the major pests of the forest seedling nurseries. Nutsedge is propagated by tubers formed along underground rhizomes and corms. During tillage of the soil, the underground stems are broken and new plants are established from either single, or chains of, tubers. Weeds compete with the seedlings for light, nutrients, and water and reduce the quality and yield of seedlings reducing the ability of nurseries to provide acceptable seedlings for forest establishment.

In addition to weed problems, forest tree seedling nurseries in the southern and northern U. S. are concerned with fungal pathogens such as species of Fusarium, Alternaria, Phytophthora, Pythium , Rhizoctonia, and Macrophomina, that can cause severe outbreaks of root rots and damping off diseases. Significant crop losses of conifers and hardwood seedlings can result if beds are not properly managed. Nurseries in the western U. S. contend with disease causing pathogens, such as Pythium spp., Fusarium spp., Cylindrocladium spp., Phytophthora spp., as well as yellow nutsedge. Of particular recent concern is a newly identified disease, Sudden Oak Death, caused by Phytophthora ramorum ( USDA APHIS, 2002). Federal and state quarantine restrictions for movement of nursery plant material are currently in effect in California and Oregon.

6b. Overview of Technical and Economic Assessments of Alternatives Intensive seedling production relies on the ability of nursery managers to meet yield and quality goals. Page 7 In spite of nearly 50 years experience with methyl isothiocyanate ( MITC) products B the breakdown active ingredient of both dazomet and metam sodium B their efficacy is still unpredictable. The inconsistency of MITC products ability to control pests may be due to the significantly lower vapor pressure of MITC compared to methyl bromide. The vapor pressure of a gas affects how it moves through soils. The uniform dispersion of a fumigant throughout the soil is necessary for consistent and predictable control of pests. MITC producing products, while at times effective, have been associated in the forest tree nursery industry with inconsistent production and reduced seedling quality with overall higher proportions of Grade # 2 and cull seedlings. Because of the importance placed on seedling quality ( due to the high correlation of quality and subsequent forest health and value), failure to achieve consistently healthy seedlings, in even a portion of production beds, can have a devastating effect on this sector's ability to provide acceptable seedlings for reforestation. Both dazomet and metam sodium can provide effective pest management in some situations, but they are unsuccessful in providing consistently high quality forest tree seedlings especially in circumstances with high nutsedge and pathogen pressure. Reduced efficacy for both dazomet and metam sodium requires production cycle compensation by increasing the frequency of fumigation or lengthening the fallow period in order to obtain better control of weeds and other pests. These strategies result in reduced seedling production. In addition, the analysis below demonstrates that both of these potential alternatives, when compared with methyl bromide, are not economically feasible.

6c. Technical Feasibility of In Kind ( Chemical) Alternatives We begin our technical and economic assessment by presenting the two in kind ( chemical) alternatives ( Table 1), dazomet and metam sodium, and then describe the attributes of the not in kind alternatives.

Table 1. Methyl bromide Alternatives Identified by the Methyl Bromide Technical Options Committee ( MBTOC) for Forest Tree Seedling Nurseries. Methyl Bromide Alternative Assessment of Technical Feasibility Assessment of Economic Feasibility Dazomet ( Basamid ® ) Yes No Metam sodium ( Vapam ® , Busan ® ) Yes No Biofumigation No N/ A Solarization No N/ A Crop rotation/ Fallow No N/ A Flooding and water management No N/ A General IPM ( Integrated Pest Management) No N/ A Organic amendments/ Compost No N/ A Physical removal/ Sanitation No N/ A Plowing and tillage No N/ A Note: Alternatives not found technically feasible were not assessed for economic viability. Page 8 Dazomet ( Basamid ® ) . Dazomet can be considered a technically feasible alternative by itself but does not provide consistent control of nutsedge or pathogens that cause root rot and damping off ( refer to Target Pests, Section 6a). Field trials using 400 kilogram per hectare of dazomet showed inconsistent, non uniform, and reduced seedling size ( diameter and height) and root volume. Using dazomet led to higher counts of Grade # 2 seedlings and culls compared to methyl bromide, which had higher counts of Grade # 1 seedlings.

Direct yield losses ( seedlings per hectare) were not very large on average, but there was a high degree of variability in yield loss estimates reported in trials. Average or expected yield losses with dazomet compared to methyl bromide are 4 percent ( with tarping) and 11 percent ( without tarping). Data from studies shows that yield losses range from none to 13 percent ( with tarping) and 6 percent to 21 percent ( without tarping) compared to methyl bromide. Reduced efficacy requires production cycle compensation by increasing the frequency of fumigation or lengthening the fallow period in order to obtain better control of weeds and other pests. These strategies result in reduced seedling production. Damage to seedlings growing adjacent to beds being fumigated with dazomet resulted in significant loss of seedlings due to fumigant drift. Soil temperature requirements ( above 6

C/ optimal 12 18

C) for dazomet, due to vapor pressure properties, constrains use in some areas ( north and west) ( Landis and Campbell, 1989).

Metam sodium ( e. g., Vapam ® , Busan ® ) . Metam sodium can be considered a technically feasible alternative but does not provide consistent nutsedge and pathogen control ( see dazomet alternative above). Average yield losses are approximately 6 percent with metam sodium compared to methyl bromide. Data from studies shows that the range of yield outcomes with metam sodium compared to methyl bromide is estimated to be between a gain of 2 percent to a loss of 11 percent. As with dazomet, seedling quality is inconsistent with metam sodium resulting in an overall higher proportion of Grade # 2 and cull seedlings. As with dazomet, reduced efficacy requires production cycle compensation by increasing the frequency of fumigation or lengthening the fallow period in order to obtain better control of weeds and other pests. These strategies result in reduced seedling production. Damage to seedlings growing adjacent to beds being fumigated with metam sodium results in significant loss of seedlings due to fumigant drift. Soil temperature requirements ( above 4

C) of metam sodium, due to vapor pressure properties, can constrain use in some areas ( north and west) ( Landis and Campbell, 1989).

6d. Economic Feasibility of In Kind ( Chemical) Alternatives An economic assessment was made for two technically feasible in kind ( chemical) alternatives for the forest tree seedling nursery sector, dazomet and metam sodium. A general cost analysis was done for the alternatives and is reported in Appendix B. The economic assessment of feasibility for pre plant uses of methyl bromide included an evaluation of economic losses from three basic sources: ( 1) yield losses, referring to reductions in the quantity produced, ( 2) quality losses, which generally affect the price received for the goods, and ( 3) increased production costs, which may be due to the higher cost of using an alternative, additional pest control requirements, and/ or resulting shifts in other production or harvesting practices. Page 9 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 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 forest tree seedling nurseries 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.

Economic reviewers analyzed potential economic losses from using dazomet and metam sodium because they are currently considered technically feasible alternatives for nursery tree seedling production.

Total losses are similar for both dazomet and metam sodium. Quantifiable losses originate from yield losses and cost increases. Dazomet has slightly smaller yield losses than metam sodium, but slightly higher treatment costs. Indirect yield losses occurred due to lengthening of the production cycle, which resulted in less land in production and more in fallow or longer time for seedlings to reach appropriate size. Additional losses may also arise due to a shift from high quality Grade # 1 seedlings to lower quality Grade # 2, which causes a loss of about 30 percent of value, and more seedlings that Page 10 must be culled. Unfortunately, data were lacking to measure this shift. Thus, total losses are underestimated.

Table 2 provides a summary of the estimated economic losses. A measure of profit loss is not included in Table 2 partly because many nurseries are publicly owned and seedling prices or production costs are subsidized. Although attempts were made to appropriately value the seedlings at a true market price, losses as a percentage of gross revenues and of net cash returns should be viewed with caution. Direct yield losses are similar across the regions, mainly because the same studies were used to predict impacts. The range of losses in the studies is rather large because both dazomet and metam sodium provide inconsistent pest control. Indirect losses arising from shifts in the production cycle were only quantified for the Northern region where the impact is expected to be more pronounced due to cooler temperatures and longer time required for production of a seedling crop. Changes in production costs arise due to differences between the costs of methyl bromide and the alternatives, shifts in the production cycle ( increasing the frequency of fumigation or lengthening the fallow period) and additional expenses such as supplementary irrigation. These costs vary across regions and within the Western region, which is highly diverse, because of differences in pests, production systems and regional differences in costs of water and labor. Costs are higher in the South, in part because warmer temperatures increase pest pressure. Page 11 Table 2. Economic Impact of Using Dazomet or Metam Sodium in Place of Methyl Bromide on Tree Seedling Nurseries in the U. S. a South West North Direct yield loss 3% gain to 13% loss likely 5% loss 3% gain to 13% loss likely 5% loss 2% gain to 13% loss likely 3% loss Indirect yield loss b none calculated none calculated 5 to 15% loss likely 13% loss Change in production costs c US$ 1930 to 2590/ ha ( US$ 780 1050/ Acre) 11 to 15% of operating costs US$ 370 to 1580/ ha ($ 150 640/ Acre) 2 to 5% of operating costs US$ 640 to 1010/ ha ( US$ 260 410/ Acre) 1 to 2% of operating costs Economic loss per area US$ 1060 6670/ ha loss likely US$ 3700/ ha loss ( US$ 430 2700/ acre loss) ( likely US$ 1500/ acre loss) US$ 150 gain to US$ 7660 ha/ loss likely US$ 3200/ ha loss ( US$ 60 gain to US$ 3,100/ acre loss) ( likely US$ 1,300/ acre loss) US$ 3330 12600/ ha loss likely US$ 11,120/ ha loss ( US$ 1350 5100/ acre loss) ( likely US$ 4500/ acre loss)

Economic loss per amount of methyl bromide US$ 3 20/ kg loss likely US$ 10/ kg loss ( US$ 1.30 8.20/ lb loss) ( likely US$ 4.40/ lb loss) < US$ 1 gain to US$ 26/ kg loss likely US$ 14/ kg loss ( US$ 0.10 gain to US$ 11.90/ lb loss) ( likely US$ 6.50/ lb loss) US$ 9 to US$ 37/ kg loss likely US$ 32/ kg loss ( US$ 4.30 16.60/ lb loss) ( likely US$ 14.70/ lb loss)

Economic loss as percent of gross revenues 3 to 22% loss likely 12% loss 1% gain to 15% loss likely 6% loss 5 to 19% loss likely 16% loss Economic loss as percent of net cash revenues 8 to 49% loss likely 27% 1% gain to 27% loss likely 16% loss 20 to 76% loss likely 67% loss aDazomet and metam sodium have similar total impacts. bIndirect yield losses arise from changes in the production cycle including longer growing periods and more frequent fallow. cChange results from different costs of alternatives, additional pesticide applications, changes in production patterns and additional equipment.

Losses per hectare are relatively large and are driven by yield losses and increased production costs, particularly in the southern region. Revenue losses are particularly sizeable in the northern region because cooler temperatures combine to drastically increase the length of the production cycle for conifers so that many fewer seedlings are ready for sale in any particular year. The western region Page 12 has a larger range, in part because it covers much more variable environmental conditions, from the Pacific Northwest to Great Plains states. Overall, the results are fairly consistent across the regions and suggest that the dazomet and metam sodium are not economically viable as alternatives for methyl bromide. We did not attempt to quantify the human health and environmental costs associated with these alternatives. Dazomet has raised concerns about potential genotoxicity and metam sodium has been classified as a potential human carcinogen ( US GAO, 1995). Concerns over groundwater contamination with methyl isothiocyanate are associated with the use of both chemicals.

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 forest tree seedling nurseries, non chemical alternatives. Table 1 contains a summary of the technical assessment, which is that none of the not in kind alternatives were found to be technically feasible, and therefore no economic assessment was conducted. A description of each not in kind alternative follows:

Biofumigation. Biofumigation is not technically feasible because of difficulty in obtaining sufficient biomass to produce effective amounts of MITC to manage diseases and weeds under nursery conditions. In some forest nurseries, trials have grown mustard species ( Brassica spp.) for disking into the soil to generate the bioactive breakdown product MITC. Eleven metric tons per hectare of Brassica plants B an amount that is considered high production B is equivalent to approximately 68 kg of dazomet, which is significantly less than effective dazomet fumigation rates. In addition, increased Fusarium populations due to favorable conditions provided by Brassica plants have been reported to increase seedling diseases after biofumigation treatments.

Solarization. Solarization is not technically feasible because it would require several months of covered beds to heat soil to a sufficient depth ( 25 30 cm) in order to affect soil borne pathogens. In addition, nutsedges, Fusarium spp., Macrophomina spp. are not controlled, or unpredictably controlled, by solarization ( Elmore et al., 1997). Seeds of some weed species are resistant to temperatures obtained with solarization. Conceivably, solarization could be optimized for efficacy and incorporated into an integrated pest management ( IPM) program that would help reduce chemical use for bed preparation, but because of intensive scheduling of seedling production, solarization is inadequate as a sole replacement for methyl bromide in the forest tree seedling nursery industry even in the southern U. S.

Crop rotation/ Fallow. Cover crops and mulching are not technically feasible alternatives because data do not support their use as stand alone alternatives to methyl bromide. The use of cover crops is a common practice to improve soil structure and suppress an array of soilborne pathogens. Cover crops and mulches have been integrated to forest tree seedling production management.

Some cover crops that have been shown to reduce weed populations also reduced or delayed crop maturity and/ or emergence, as well as yields ( Burgos et al., 1996; Galloway et al., 1996). Cowpea and sunn hemp have been shown to suppress nutsedge, but the effect is short lived, due to the weed's Page 13 capacity for rapid tuber production. Allelochemicals released by some cover crops or organic mulches can injure crops ( Johnson et al., 1993; Norsworthy, 2002).

Trials conducted in southern Florida with the leguminous crops sunn hemp, velvet bean, cowpea, and sorghum Sudan grass showed crop yields comparable to methyl bromide + chloropicrin treatments. However, nematode and disease densities were described as very low in the soils involved in these studies. Iron clay cowpea has been shown to reduce populations of northern root knot nematode, and to increase population of the sting nematode. Increased sting nematode populations have been reported as well with millet as a cover crop. Proper selection of cover crops can be very important in suppressing or promoting pest populations.

Flooding/ Water management. Flooding and water management are not technically feasible because nursery beds are generally designed and graded for good drainage to prevent standing water. Flooding could increase incidence of Phytophthora and Pythium, leading to damping off and root rot diseases. 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.

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 forest tree seedlings, 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 weeds, such as use of plastic or other mulches, cropping cycles, crop rotations, etc., are already in widespread use in forest tree seedlings in the southern U. S.. 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, methyl iodide ( iodomethane) or halosulfuron methyl, used with general IPM techniques, may be able to accomplish adequate control of soil fungi and nutsedges, but these fumigants are not register for use in the U. S. The use of IPM ( with these alternative fumigants) will require multi year, on farm study before the critical use exemption review group can confidently assert that it will be technically equivalent to the use of methyl bromide in growing forest tree seedlings.

Organic amendments/ Compost. Organic amendments and compost are not technically feasible because these measures by themselves do not provide adequate weed and disease control. However, most nurseries employ various soil amendments to enhance seedling growth and quality. Page 14 Physical removal/ Sanitation. Physical removal and sanitation are not technically feasible because weed control by mechanical means is impractical for large scale nursery seedling production and disease problems would still require additional measures. Appropriate sanitation practices are already followed by nurseries as this improves productivity.

Plowing/ Tillage. Plowing and tillage are not technically feasible because nursery beds, especially medium textured soils with higher clay or organic matter than light soil beds, are susceptible to damaged soil structure and development of an impermeable " plow pan" layer, resulting in less productive seedling beds. Plowing/ tillage is currently being used but by itself is not sufficient to adequately control the target pests.

7. Critical Use Exemption Nomination for Forest Tree Seedlings As noted above, this nomination is for a critical use exemption for methyl bromide for forest tree seedling production in three distinct regions of the U. S. B the South, West, and North ( Appendix A). The alternatives identified by MBTOC were regarded by reviewers, as reviewed in detail above, as technically and economically infeasible for acceptable management of the major forest tree seedling pests, most importantly, yellow and purple nutsedge and several nematode and fungal pathogens. The two alternatives deemed technically feasible, dazomet and metam sodium, although providing inconsistent results in controlling pests were, nevertheless, economically assessed and determined to be economically infeasible in comparison to methyl bromide.

The Southern request ( representing nurseries in 12 states, see Appendix A) is for 310,215 kg to fumigate 832 hectares annually for 2005, 2006, and 2007. Table 3 provides information on historical usage, including area treated, and the actual amount requested.

Table 3. Methyl Bromide Usage and Request for Forest Tree Seedling Nurseries in the Southern U. S.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 329,958 306,354 349,250 311,832 301,913 310,215 310,215 310,215 hectares 858 808 913 843 831 832 832 832 average rate ( kg/ ha) 400 391 395 356 339 364 364 364 The Western request ( representing nurseries in seven states, see Appendix A) is for 97,554 kg to fumigate 357 hectares for 2005. Historical usage and area treated are shown in Table 4, along with the actual amount of methyl bromide requested for 2005, 2006, and 2007. Page 15 Table 4. Methyl Bromide Usage and Request for Forest Tree Seedling Nurseries in the Western U. S.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 64,874 92,446 88,767 95,814 92,155 97,554 98,160 99,096 hectares 216 304 292 336 343 357 359 363 average rate ( kg/ ha) 309 312 311 300 284 286 286 286 The Northern request ( representing nurseries in 11 states, see Appendix A) is for 46,520 kg to fumigate 147 hectares for 2005. Historical usage and area treated are shown in Table 5, along with the actual amount of methyl bromide requested for 2005, 2006, 2007.

Table 5. Methyl Bromide Usage and Request for Forest Tree Seedling Nurseries in the Northern U. S.

1997 1998 1999 2000 2001 2005 2006 2007 kilograms 51,650 55,668 48,632 46,344 42,386 46,520 45,863 45,330 hectares 150 168 154 154 133 147 145 143 average rate ( kg/ ha) 345 337 295 286 291 291 291 292 The U. S. nomination has been determined based 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 Forest Tree Seedlings Year Total Request From Applicants ( kilograms) U. S. Sector Nomination ( kilograms)

2005 454,289 192,515 8. Availability of Methyl Bromide from Recycled or Stockpiled Sources In accordance with the criteria of the critical use exemption, Parties must discuss the potential that the continued need for methyl bromide can be met from recycled or stockpiled sources. With regard to Page 16 recycling of methyl bromide, it is fair to say that the U. S. concurs with earlier TEAP conclusions that recycling of methyl bromide used in soil fumigation is not currently feasible. The U. S. has been investigating the level of the existing stockpile, and we believe that whatever stock pile may now exist will likely be fully depleted by 2005 when the need for the critical use exemption will start.

9. Minimizing Use/ Emissions of Methyl Bromide in the United States 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 B years, the price of methyl bromide has increased substantially. As Chart 1 in Appendix D demonstrates, the application of these policies has led to a more rapid U. S. phasedown in methyl bromide consumption than required under the Protocol. This accelerated phasedown on the consumption side may also have enabled methyl bromide production to be stockpiled to some extent to help mitigate the potentially significant impacts associated with the Protocol's 2003 and 2004 70% reduction. We are currently uncertain as to the exact quantity of existing stocks going into the 2003 season that may be stockpiled in the U. S. We currently believe that the limited existing stocks are likely to be depleted during 2003 and 2004. This factor is Page 17 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 18 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 19 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.

Considerable resources have been spent examining methods to reduce costs and improve efficiency in forest seedling production because of relatively high nursery production costs. The Auburn University consortium, which includes commercial and public forest tree seedling nurseries, has spent US$ 1.2 million on methyl bromide alternatives since 1992. An investment of this magnitude is significant considering several member nurseries are publicly owned and have limited resources for independent research. Research included trials to assess effectiveness of the most likely chemical and non chemical methyl bromide alternatives, including some potential alternatives that are not currently listed by MBTOC for forest tree seedlings, such as: combinations of chemicals such as 1,3 dichloropropene ( 1,3 D, manufactured as Telone ® ) , chloropicrin, and methyl iodide ( not currently registered in the U. S.).

Non chemical procedures have been adopted widely in the industry and methods such as IPM, mulching, solarization, biofumigation, are being examined as part of an overall strategy to improve seedling production. Modification of fertilization regimes may help to compensate for reduced seedling quality that can occur when MITC producing fumigants are used; results have been inconclusive thus far.

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

In addition, there have been many studies done on yield comparing alternatives in the forest tree seedling sector to methyl bromide. Sources for the studies are The Methyl Bromide Alternatives Conference, applications for critical use exemption, and case studies. For each alternative, the number of studies done is as follows: bare fallow and combinations ( 22); dazomet and combinations ( 76); cedar sawdust ( 2); chloropicrin and combinations ( 56); compost ( 3); Eptam ( EPTC) ( 12); fallow ( 41); formaldehyde ( 1); grafting ( 1); hot water ( 3); MBR 200 ( 1); MBR 300 ( 8); metamsodium and combinations ( 19); Nemagon ( 2); other non chemical ( 1); silica sand ( 1); solarization ( 1); Page 20 1,3 D and combinations ( 6); thiram ( 1); triform and combinations ( 8).

Government funded studies related to U. S. forest tree seedling production that are currently on going include the following:

1. Factors Affecting the Production and Processing of Small Fruit Or Nursery Crops in the Pacific Northwest ( U. S.) ( Sep 1999  Sep 2003) The objective of this cooperative research project is to determine factors that can improve the production and processing practices used for horticultural crops ( especially nursery crops and small fruit crops) grown in the Pacific Northwest, including cultural practices, propagation methods, environmental stresses, diseases, insects ( and mites), soil fertility and fertilization, organic amendments, irrigation, and pruning.

2. Biological Control of Fusarium Wilt and Other Soilborne Plant Pathogenic Fungi ( Nov 2002  Nov 2007) The objective of this research is to assess the potential of microbes to control soil borne plant pathogenic fungi and determine biological, environmental and ecological factors affecting performance of these microbes. The research will help to characterize biological, ecological and genetic relationships among and within pathogenic, saprophytic and biological control soil borne microorganisms, as well as elucidate mechanisms of action of biological control agents used against soil borne plant pathogens; where previous work identified a general mechanism of action, the research will identify the specific underlying basis of the mechanism. Work will include, but is not limited to, the nature of resistance to Fusarium wilt in tomato, induced by Fusarium oxysporum strain CS 20, which can serve as a model for other systems including forest tree seedling nurseries.

3. Evaluation of Fumigant Efficacy with Virtually Impermeable Film ( VIF) Plastic ( Sep 2002  Mar 2005) The objective of this research is to evaluate the effect of methyl bromide replacement soil fumigants applied under standard polyethylene plastic of virtually impermeable film on pathogen control and plant health in production fields.

4. Evaluation of Fumigant Efficacy with Virtually Impermeable Film ( VIF) Plastic ( UC Davos/ CSREES Sep 2002  Sep 2004) The objective of this research is to identify methods to maximize the effects of alternative fumigants on soil borne pests, while minimizing environmental risk. To determine the minimum effective doses of chloropicrin and 1,3 dichloropropene plus chloropicrin on soil borne pathogens, weeds and alla lily bulbs under virtually impermeable film ( VIF).

5. Replacement of Herbicides and Methyl Bromide by Microbiological Control of Weeds ( May 2000  Apr 2003) The objective of this research is to discover and evaluate pathogens as bioherbicides of agronomic weeds and horticultural weeds formerly controlled by methyl bromide. To develop new formulations/ adjuvants/ synergists which overcome constraints that limit biocontrol potential such as Page 21 moisture requirements and narrow host ranges. To optimize bioherbicide mass production. To conduct biochemical studies of weed pathogenesis by bioherbicides. To discover/ identify/ produce phytotoxins that could be used to produce safer herbicides.

6. Improving Efficacy of Fumigants by Promoting Uniform Dispersion in Soil and Minimizing Emissions to the Atmosphere ( Dec 2002  Dec 2007) The objective of this research is to determine the efficiency of various barrier films, and absorbents, catalysts, and/ or reactants applied to the film or soil surface, alone or in combination, for decreasing emissions or preplant soil fumigants to the atmosphere. Improve the efficacy of methyl bromide alternative fumigants ( 1,3 dichloropropene, chloropicrin, and MITC) by promoting uniform dispersion and solubilization in the liquid phase in soil. Develop microemulsion methodologies for reduced volatilization and improved dispersion of alternative fumigants from drip tube application or shank injection traces.

The following are some examples of additional research supported by public and private forest tree nurseries:

In addition to the research that is ongoing under the U. S. Department of Agriculture, applicants have cited the following research plans as ones they are funding or otherwise participating in. They are: Illinois Prairie Forbs which includes a submitted research plan to test dazomet at the Mason State Tree Nursery in 2003; Michigan Seedlings includes a study planned for methyl bromide alternatives and research and education for herbaceous perennials, woody ornamentals and vegetables in Michigan, New York and Rhode Island. The tests are planned for 2003 2004 in Michigan. The alternatives to be tested are 1,3 dichloropropene 1,3 dichloropropenewith 17 percent chloropicrin, 1,3 dichloropropenewith 35 percent chloropicrin, metam sodium, metam sodium/ 1,3 dichloropropenecombinations, methyl iodide, halosulfuron, flumioxazin, sulfentrazone, carfentrazone, cover crop and composting; Additional trials associated with USDA projects are being done with organic acids, and screening of biological organisms for use as methyl bromide alternatives in nursery production systems. So far, US$ 13,000 has been spent on research; Other research includes a system of growing that involves using plug culture in retractable roof greenhouses allowing seedlings to be grown without methyl bromide B however, costs run about US$, 250,000/ hectare.

Western U. S. Seedling Industry includes various studies to be done by the USDA Forest Service and State nursery cooperators. The testing was planned for 2002 and continues in various nurseries throughout the region ( CA, ID, KS, NE, OR, UT, WA). The alternatives to be tested include: dazomet, metam sodium, and organic amendments/ cover crops/ sowing alternatives. Studies plan to test methyl bromide alternatives in 2003 in nurseries in Oregon and Washington. Studies plan to further test chloropicrin, possibly in combination with metam sodium, and test the efficacy of methyl iodide. So far, US$ 0,000 has been spent on research; Weyerhauser Company ( NW U. S.) conducts studies planned to test alternatives to methyl bromide in Mima Nursery, Little Rock, WA. To be tested were: MBC ( operational control), chloropicrin ( untreated weeds), and metam sodium + chloropicrin ( tarped). Additional testing is planned for spring, 2003, when methyl iodide + chloropicrin will be compared to methyl bromide for spring fumigation. So far, about US$ 25,000 has Page 22 been spent on research.

Southeastern Seedling Industry includes research by The Auburn University Southern Forest Nursery Management Cooperative. The testing was planned starting in Fall, 2002 and continuing in several locations throughout the southern U. S.. The alternatives to be tested include methyl iodide, chloropicrin, EPTC and probably azides. So far, US$, 266,673 has been spent on research. International Paper conducts studies planned to evaluate potential chemical and integrated pest management alternatives. The studies were planned to begin in 2002, and continue at nine international paper nurseries. Alternatives to be tested are methyl iodide, chloropicrin, EPTC, azides, integrated pest management techniques such as crop rotations, fallow field soil management, herbicides, solarization and allopathic interactions of crops and weeds. So far, US$, 005,000 has been spent on research. Other investments include dues for International Paper's membership in the Auburn University Nursery Cooperative which are US$, 300 per year. Weyerhauser Company ( SE U. S.) plans to study 1,3 dichloropropene chloropicrin and MITC agent combinations. Tests are planned for 2003 2007. Alternatives to be tested are 1,3 dichloropropene+ 17% chloropicrin ( 1,3 dichloropropenewith 17 percent chloropicrin) 1,3 dichloropropene 25% chloropicrin, or 1,3 dichloropropene+ 35% chloropicrin in combination with MITC agent ( Vapam); also pebulate ( Tillam ® in combination with 1,3 dichloropropene+ 17% chloropicrin if permission to use pebulate can be obtained for pine. So far, US$ 00,000 has been spent on this research.

While the U. S. government's role to find alternatives is primarily in the research arena, we know that research is only one step in the process. As a consequence, we have also invested significantly in efforts to register alternatives, as well as efforts to support technology transfer and education activities with the private sector.

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

The U. S. EPA regulates the use of pesticides under two major federal statutes: the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) and the Federal Food, Drug, and Cosmetic Act ( FFDCA), both significantly amended by the Food Quality Protection Act of 1996 ( FQPA). Under FIFRA, U. S. EPA registers pesticides provided its use does not pose unreasonable adverse effects to humans or the environment. Under FFDCA, the U. S. EPA is responsible for setting tolerances ( maximum permissible residue levels) for any pesticide used on food or animal feed. With the passage of FQPA, 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. Page 23 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, U. S. EPA has made the registration of alternatives to methyl bromide a high registration priority. Because U. S. EPA currently has more applications pending in its review than the resources to evaluate them, U. S. EPA prioritizes the applications in its registration queue. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review. The average processing time for a new active ingredient, from date of submission to issuance of a registration decision, is approximately 38 months. In most cases, the registrant ( the pesticide applicant) has spent approximately 7 10 years developing the data necessary to support registration.

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

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

Since 1997, EPA has registered the following chemical/ use combinations as part of its commitment to expedite the review of methyl bromide alternatives: Page 24 1999: Pebulate to control weeds in tomatoes 2000: Phosphine to control insects in stored commodities 2001: Indian Meal Moth Granulosis Virus to control Indian meal moth in stored grains 2001: Terrazole to control pathogens in tobacco float beds 2001: Telone applied through drip irrigation  all crops 2002: Halosulfuron methyl to control weeds in melons and tomatoes EPA is currently reviewing several additional applications for registration as methyl bromide alternatives, with several registration eligibility decisions expected within the next year, including:

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

Alternatives must be field tested and found technically and economically feasible before finally being adopted. Testing alternatives requires sufficient time for consideration of efficacy of the products for managing the pest problems. As noted by TEAP, a specific alternative, once available may take two or three cropping seasons of use before efficacy can be determined for the specific circumstances of the user. In an effort to speed adoption, the U. S. government has also been involved in these steps by promoting technology transfer, experience transfer, and private sector training.

Some alternatives under review by EPA may be available for forest tree seedling nurseries in the future. These include: methyl iodide and propargyl bromide, which currently look promising in field studies. Although methyl iodide is chemically similar to methyl bromide, it photodegrades before it reaches the stratosphere, and therefore is not a significant ozone depleter. While methyl iodide and propargyl bromide are not currently registered for use as pesticides in the U. S., research on these and other alternatives is on going.

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 Page 25 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 described in this document provides all of the information that has been requested by the Parties. On the basis of an exhaustive review by a large, multi disciplinary team of sector and general agricultural experts, we have determined that the potential alternatives identified by MBTOC for forest tree seedling nurseries are not technically or economically feasible as covered by the exemption nomination for the forest tree seedling nursery sector. Certain MBTOC alternatives ( dazomet and metam sodium) were only effective against major pests ( particularly nutsedges) in limited situations and were inconsistent in their effectiveness in acceptable pest management. Forests in the U. S. are extremely valuable for economic and environmental reasons. Forest tree nurseries in the U. S. supply seedlings of conifers and hardwoods that are used for reforestation, forest establishment, fiber production, and wildlife and conservation uses. Because of the high correlation between healthy seedlings and the health of a forest over its 20 to 40 ( or more) year life, consistently high quality seedling production in the forest tree seedling nursery sector is of prime importance to the U. S. As a result, methyl bromide is being supported for use by the forest tree seedling nursery sector to maintain the consistent production of high quality forest trees.

The U. S. expends significant efforts to find and commercialize alternatives, and potential alternatives to the use of methyl bromide for forest tree seedling nurseries. However, the registration process, which is designed to ensure that new pesticides do not pose unreasonable adverse effects on human health or the environment, is a long and rigorous one. The U. S. need for methyl bromide for forest tree seedling nurseries will be maintained for the period being requested.

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

a. Request for Aggregate Exemption for All Covered Methyl Bromide Uses: As mandated by Decision XIII/ 11, the nomination information that is being submitted with this package includes information requested on historic use and estimated need in individual sectors. That said, we note our agreement with past MBTOC and TEAP statements which stress the dynamic nature of agricultural markets, uncertainty of specific production of any one crop in any specific year, the difficulty of projecting several years in advance what pest pressures might prevail on a certain crop, and, the difficulty of estimating what a particular market for a specific crop might look like in a future year. We also concur with the MBTOC's fear that countries that have taken significant efforts to reduce methyl bromide use and emissions through dilution with chloropicrin may be experiencing only short term efficacy in addressing pest problems. On the basis of those factors, we urge the MBTOC and Page 26 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 B about 40% above usage B and then went down to 30% range after 4 years. Only after 5 years of experience did the request come down to about 10% above usage. While our experience with the Essential Use process has aided the U. S. in developing its Critical Use nomination, we ask the MBTOC, the TEAP and the Parties to recognize that the complexities of agriculture make it difficult to match our request exactly with expected usage when the nomination is made two to three years in advance of the time of actual use.

Chart 2 in Appendix D also demonstrates that, even though MDI requests included a significant margin of safety, the nominations were approved and the countries receiving the exemption for MDIs did not produce the full amount authorized when there was not a patient need. As a result, there was little or no environmental consequence of approving requests that included a margin of safety, and the practice can be seen as being normalized over time. In light of the similar significant uncertainty surrounding agriculture and the out year production of crops which use methyl bromide, we wish to urge the MBTOC and TEAP to take a similar, understanding approach for methyl bromide and uses found to otherwise meet the critical use criteria. We believe that this too would have no Page 27 environmental consequence, and would be consistent with the Parties aim to phaseout methyl bromide while ensuring that agriculture itself is not phased out.

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

12. Contact Information:

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

John E. Thompson, Ph. D. Office of Environmental Policy US Department of State 2201 C Street NW Rm 4325 Washington, DC 20520 tel: 202 647 9799 fax: 202 647 5947 e mail: ThompsonJE2@ state. gov Alternate Contact: Denise Keehner, Director Biological and Economic Analysis Division Office of Pesticides Programs US Environmental Protection Agency, 7503C Washington, DC 20460 tel: 703 308 8200 fax: 703 308 8090 e mail: methyl. bromide@ epa. gov Page 28 13. References Adams, R. S. and Hawkes, C. L. 1978. Planting California Forest Land. Univ. California, Div. Agricultural Sciences, Berkeley, CA. Leaflet No. 2925. pp. 43.

Auburn University. 1992. Soil solarization. Ecological Alternatives, Forest Nursery Notes ( 4/ 92). www. forestry. auburn. edu/ sfnmc/ class/ fy614/ eco492. html.

Buzzo, R. J. 2002. Phytotoxicity with metam sodium. In: Riley, L. E., Dumroese, R. K., and Landis, T. D. ( tech. coord.), Nat. Proc. Forest and Conservation Nursery Associations. Ogden, UT. USDA, Forest Service, Ft. Collins, CO.

Carey, W. A. 2000. Fumigation with chloropicrin, metam sodium, and EPTC as replacements for methyl bromide in southern pine nurseries. Southern J. Applied Forestry 24: 135 139.

Carey, W. A. 2000. Seedling production and weed control by a potential replacement for methyl bromide at the Flint River Nursery. Auburn University Southern Forest Nursery Management Cooperative, Research Report 00 3.

Carey, W. A. 1999. A comparison of chloropicrin, metham sodium, and EPTC combinations as methyl bromide alternatives at three nurseries. Auburn University Southern Forest Nursery Management Cooperative, Research Report 99 2.

Carey, W. A. 1998. Loblolly seedling production, soil fungi and nematodes in the first two crops after fumigation at the Texas Supertree Nursery. Auburn University Southern Forest Nursery Management Cooperative, Research Report 98 3.

Carey, W. A. 1997. A single nursery test of hot water, 1,3 D, and metham sodium as alternatives to methyl bromide. Auburn University Southern Forest Nursery Management Cooperative, Research Report 97 7.

Carey, W. A. 1996. Testing alternatives to methyl bromide fumigation at the Winona Nursery. Auburn University Southern Forest Nursery Management Cooperative, Research Note 96 2.

Carey, W. A. 1995. Testing Alternatives to methyl bromide fumigation at New Kent Nursery. Auburn University Southern Forest Nursery Management Cooperative, Research Note 95 1.

Carey, W. A. 1994. Chemical alternatives to methyl bromide In: Landis, T. D. and Dumroese, R. K. ( tech. coord.), Nat. Proc. Forest and Conservation Nursery Associations, Williamsburg, VA. Gen. Tech. Report RM 257, USDA, Forest Service, Ft. Collins, CO. www. fcnanet. org/ proceedings/ 1994/ carey. pdf. Page 29 Carey, W. A. and Enebak, S. 1998. Pine seedling production as affected by fumigation and plant growth promoting Rhizobacteria at a Georgia nursery. Auburn University Southern Forest Nursery Management Cooperative, Research Note 98 2.

Carey, W. A. and McNabb, K. 1996. The loss of methyl bromide as a fumigant in forest tree nurseries and the impact on reforestation programs. Auburn University Southern Forest Nursery Management Cooperative, Research Report 96 2.

Cordell, C. E., Kelly, W. D., and Smith, R. S. 1989. Integrated nursery pest management. In: Forest Nursery Diseases in the United States. USDA, Forest Service, Agriculture Handbook No. 680. www. forestpests. org/ nursery/ inpm. html.

Cram, M. M. and Fraedrich, W. 1997. Survey of southern forest nurseries: fumigation practices and pest management concerns. www. epa. gov/ spdpublic/ mbr/ airc/ 1997/ 096cram. pdf Elmore, C. L., Stapleton, J. J., Bell, C. E., DeVay, J. E. 1997. Soil Solarization. Univ. California, Div. Agriculture and Natural Resources, Publ. 21377. Oakland, CA. pp. 13.

Enebak, S. A. 1990. Managing soilborne pathogens of white pine in a forest nursery. Plant Disease 74: 195 198.

Gilreath, J. P. 2002. Methyl bromide alternatives and their current limitations in Florida. Technical Report, USDA Methyl Bromide Alternatives 8 ( 1) 8 12.

James, R. L. 1989. Effects of fumigation on soil pathogens and beneficial microorganisms. In: Landis, T. D., ( tech. coord.), Proc. Intermountain Forest Nursery Association, Bismarck, ND. USDA, Forest Service, Ft. Collins, CO. www. fcnanet. org/ proceedings/ 1989/ james. pdf.

Juzwik, J. and Allmaras, R. 1998. Moving toward integrated management of root diseases in northern forest nurseries. USDA Agricultural Research Service. www. ars. usda. gov/ is/ np/ mba/ april98/ root. htm.

Landis, T. D. and Campbell, S. J. 1989. Soil fumigation in bareroot tree nurseries. In: Landis, T. D., ( tech. coord.), Proc. Intermountain Forest Nursery Association, Bismarck, ND. USDA, Forest Service, Ft. Collins, CO. http:// www. fcnanet. org/ proceedings/ 1989/ landis. pdf Marx, D. H., Cordell, C. E., and Kormanik, P. 1989. Mycorrhizae: benefits and practical application in forest tree nurseries. In: Forest Nursery Diseases in the United States. USDA, Forest Service, Agriculture Handbook No. 680. www. forestpests. org/ nursery/ mycorrhizae. html.

Peterson, G. W. and Smith, R. S. 1975. Forest Nursery Diseases in the United States. USDA, Forest Service, Agriculture Handbook No. 470. pp. 125. Page 30 Scholtes, J. R. 1989. Soil fumigation at J. Herbert Stone nursery. In: Landis, T. D., ( tech. coord.), Proc. Intermountain Forest Nursery Association, Bismarck, ND. Gen. Tech. Report RM 184, USDA, Forest Service, Ft. Collins, CO.

Smith, R. S. and Cordell, C. E. 1989. Evaluation of nursery losses due to pests. USDA, Forest Service, Agriculture Handbook No. 680. www. forestpests. org/ nursery/ evaluation. html.

South, D. B., Carey, W. A., and Enebak, S. A. 1997. Chloropicrin as a soil fumigant in forest nurseries. The Forestry Chronicle 73: 489 494.

USDA. 2002. The status of methyl bromide alternatives. Methyl Bromide Alternatives 8 ( 1): 1 6.

USDA APHIS ( Animal and Plant Health Inspection Service), Plant Protection and Quarantine. 2002. Sudden Oak Death. http:// www. aphis. usda. gov/ ppq/ ispm/ sod/

USDA NASS ( United States Department of Agriculture National Agricultural Statistics Service). 2001. Nursery Crops C 2000 ( August) Summary.

US GAO ( General Accounting Office). 1995. Potential alternatives to methyl bromide for agricultural uses. Appendix II, pg. 30, In: The Phaseout of Methyl Bromide in the United States. GAO/ RCED 96 16.

Webster, T. M., Csinos, A. S., Johnson, A. W., Dowler, C. C., Sumner, D. R., Fery, R. L. 2001. Methyl bromide alternatives in a bell pepper squash rotation. Crop Protection 20: 605 614.

14. Appendices Appendix A. List of Critical Use Exemption Requests for the Forest Tree Seedling Nursery Sector in the U. S.

South: Alabama, Arkansas, Georgia, Florida, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia CUE 02 0003, Auburn University Southern Forest Nursery Management Cooperative CUE 02 0007, International Paper ( also a member of the Auburn University consortium) CUE 02 0021, Weyerhaeuser South ( also a member of the Auburn University consortium)

West: California, Idaho, Kansas, Nebraska, Oregon, Utah, Washington CUE 02 0008, Western Forest and Conservation Public Nursery Association CUE 02 0009, Nursery Technology Cooperative CUE 02 0022, Weyerhaeuser West Page 31 North: Illinois, Indiana, Kentucky, Maryland, Michigan, Missouri, New Jersey, Ohio, Pennsylvania, West Virginia, Wisconsin CUE 02 0011, Illinois Department of Natural Resources Nursery Program CUE 02 0032, Northeastern Forest and Conservation Nursery Association CUE 02 0039, Michigan Seedling Association Page 32 Appendix B. Spreadsheets Supporting Economic Analysis * Numbers in the tables reflect most likely loss estimates.

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 Page 34 # Notes 1 Seedling price is much lower in the southern region according to applicants. This could be due to a number of reasons including better growing conditions and accounting practices of major growers in the timber and paper industries.

2 Applicant is also a member of the Auburn consortium.

3 Applicant is also a member of the Auburn consortium. Revenue losses due to yield losses and shift in production from 4 year cycle with 1 year fallow to 3 year cycle with 1 year fallow.

4 Analysis was revised to make it consistant with others in sector, specifically, a 3 year fumigation cycle was assumed. Price and yield are a composite of several products. Costs are underestimated due to data limitations.

5 Price and yield are a composite of several products. Revenue losses due to yield losses and shift in production of some species from 2 year production to 3 year production.

6 Costs are likely underestimated due to data limitations. Page 35 Page 36 Page 37 * kg ai that would be applied per hectare = application rate for the alternatives or requested application rate for MeBr.

* Other pest control costs are those other than methyl bromide or its alternatives. Page 38 Page 39 Page 40 Appendix C: U. S. Technical and Economic Review Team Members Christine M. Augustyniak ( Technical Team Leader). Christine has been with the U. S. Environmental Protection Agency since 1985. She has held several senior positions, both technical and managerial, including Special Assistant to the Assistant Administrator for Prevention, Pesticides, and Toxic Substances, Chief of the Analytical Support Branch in EPA's office of Environmental Information and Deputy Director for the Environmental Assistance Division in the Office of Pollution Prevention and Toxics. She earned her Ph. D. ( Economics) from The University of Michigan ( Ann Arbor). Dr. Augustyniak is a 1975 graduate of Harvard University ( Cambridge) cum laude ( Economics). Prior to joining EPA, Dr. Augustyniak was a member of the economics faculty at the College of the Holy Cross ( Worcester).

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

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

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

Greg Browne ( Biologist). Greg has been with the Agricultural Research Service of the U. S. Department of Agriculture since 1995. Located in the Department of Plant Pathology of the University of California ( Davis), Greg does research on soilborne diseases of crop systems that currently use methyl bromide for disease control, with particular emphasis on diseases caused by Phytophthora species. He is the author of numerous articles on the use of alternatives to methyl Page 41 bromide for the control of diseases in fruit and nut crops He earned his Ph. D. ( Plant Pathology) from the University of California ( Davis) and a Master of Science ( Plant Pathology) from the same institution. Dr. Browne is a graduate of The University of California ( Davis). Prior to joining USDA was a farm advisor in Kern County.

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

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

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

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

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

Tara Chand Goyal ( Biology). Tara has been with the U. S. Environmental Protection Agency since 1997. He serves in the Office of Pesticide Programs as a plant pathologist and specializes in analyzing the efficacy of pesticides with emphasis on risk reduction. He earned his Ph. D. ( Mycology and Plant Pathology) from The Queen's University ( Belfast) and a Master of Science ( Plant Pathology and Mycology) from Punjab University ( Ludhiana). Dr. Chand Goyal is a graduate of Punjab University. Prior to joining EPA Dr. Chand Goyal was a member of the faculty of The Oregon State University ( Corvallis) and of The University of California ( Riverside). His areas of Page 42 research and publication include: the biology of viral, bacterial and fungal diseases of plants; biological control of plant diseases; and, genetic manipulation of microorganisms.

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

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

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

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

John Faulkner ( Economist) John has been with the U. S . Environmental Protection Agency since 1989. He serves in the Office of Pesticide Programs analyzing the costs imposed by the regulation of pesticides. He earned his Ph. D. ( Economics) from the University of Colorado ( Boulder) and holds a Master's of Business Administration from The University of Michigan ( Ann Arbor). Dr. Faulkner is a 1965 graduate of the University of Colorado ( Boulder). Prior to joining EPA was a member of the economics faculty of the Rochester Institute of Technology ( Rochester), The University of Colorado ( Boulder) and of the Colorado Mountain College ( Aspen). Page 43 Clara Fuentes ( Biologist). Clara has been with the U. S. Environmental Protection agency since 1999, working in the Philadelphia, Pennsylvania ( Region III) office. She specializes in reviewing human health risk evaluations to pesticides exposures and supporting the state pesticide programs in Region III. She earned her Ph. D. ( Entomology) from The University of Maryland ( College Park) and a Master of Science ( Zoology) from Iowa State University ( Ames). Prior to joining EPA, Dr. Fuentes worked as a research assistant at U. S. Department of Agriculture, Agricultural Research Service ( ARS) ( Beltsville), Maryland, and as a faculty member of the Natural Sciences Department at InterAmerican University of Puerto Rico. Her research interest is in the area of Integrated Pest Management in agriculture.

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

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

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

Arnet W. Jones ( Biologist). Arnet has been with the U. S. Environmental Protection Agency since 1990. He has had several senior technical and management positions and currently serves as Chief of the Herbicide and Insecticide Branch, Biological and Economic Analysis Division, Office of Pesticide Programs. Prior to joining EPA he was Senior Agronomist at Development Assistance Corporation, a Washington, D. C. firm that specialized in international agricultural development. He holds a Master of Science ( Agronomy) from the University of Maryland ( College Park). Page 44 Hong Jin Kim ( Economist). Jin has been an economist at the National Center for Environmental Economics at the U. S. Environmental Protection Agency ( EPA) since 1998. His primary areas of research interest include environmental cost accounting for private industries He earned his Ph. D. ( Environmental and Resource Economics) from The University of California ( Davis) and holds a Master of Science from the same institution. Dr. Kim is a 1987 graduate of Korea University ( Seoul) with a Bachelor of Arts ( Economics). Prior to joining the U. S. EPA, Dr. Kim was an assistant professor at the University of Alaska ( Anchorage) and an economist at the California Energy Commissions. Dr. Kim is the author of numerous articles in the fields of resource and environmental economics.

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

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

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

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

Richard Michell ( Biologist). Rich has been with the U. S. Environmental Protection Agency since 1972. He is a nematologist/ plant pathologist in the Herbicide and Insecticide Branch of the Biological and Economic Analysis Division. His primary duties include the assessment of pesticide efficacy in a Page 45 variety of crops, with special emphasis on fungicide and nematicide use and the development of risk reduction options for fungicides and nematicides. Dr. Michell earned his Ph. D. ( Plant Pathology/ Nematology) from The University of Illinois ( Urbana Champaign) and holds a Master of Science degree ( Plant Pathology/ Nematology) from The University of Georgia ( Athens).

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

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

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

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

Craig Osteen( Economist). Craig has been with the U. S. Department of Agriculture for over 20 years. He currently is with the Economic Research Service in the Production Management and Technology Branch, Resource Economics Division. He primary areas of interest relate to issues of pest control, including pesticide regulation, integrated pest management, and the methyl bromide phase out. Dr. Osteen earned his Ph. D. ( Natural Resource Economics) from Michigan State University ( East Lansing). Page 46 Elisa Rim ( Economist). Elisa is an Agricultural Economist interning with the Office of Pesticide Programs of the U. S. Environmental Protection Agency. She earned her Master of Science ( Agricultural Economics) from The Ohio State University ( Columbus) and holds a Bachelor of Arts ( Political Science) from the same institution. She has conducted research in environmental economics and developed a cost analysis optimization model for stream naturalization projects in northwest Ohio.

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

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

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

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

Thomas J. Trout ( Agricultural Engineer). Tom has been with the U. S. Department of Agriculture, Agricultural Research Service since 1982. He currently serves 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. Page 47 Prior to joining the ARS, Dr. trout was a member of the engineering faculty of Colorado State University ( Fort Collins). He is the author of numerous publications on the subject of methyl bromide alternatives.

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

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

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

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

Istanbul Yusuf ( Economist). Istanbul has been with the U. S . Environmental Protection Agency since 1998. She serves in the Office of Pesticide Programs analyzing the costs imposed by the regulation of pesticides. She earned her Master= s degree in Economics from American University Page 48 ( 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 49 Appendix: CHARTS ( See the separate electronic files for CHART 1 and CHART 2.)