Page 1 of 17

RESPONSES TO QUESTIONS FROM MBTOC S ON 2011 CUNS FOR

USE IN 2013

– UNITED STATES

Received from MBTOC March 4, 2011

Last u pdate March 10 , 2010

MBTOC Question

1.. Please n ote that Ex.I/3(5) ; XVI/2(4) ; XVII/9(5) ), XVIII/13(6), XIX/9( 7), XX/5(7), X XI/11(6) and XXII/6(5) request Parties to submit by 1 Feb info on how criteria in IX/6(1) is met when licensing permitting or authorizing CUEs. Could you please provide clarification of your response to this Decision?

USG Response

This inf ormation was transmitted to the Ozone Secretariat on March 9 by the EPA. The package

included : 1) a table listing the updated registration status of methyl bromide alternatives, 2) a description of the methodology used in determining economic feasibility, 3) the 2010 allocation rule which contains a description of the USA application of IX/6 when licensing methyl bromide in 2010 and the manner in which inventories are managed, 4) a summary of the critical use nominations for calendar year 2013, and 5) the accounting framework for 2010 critical use methyl bromide.



### Vegetables General

MBTOC Question

1. In the previous nominations in past years, rates vary according to the crop: In the nominations for 2013, the rates are similar for all the vegetables (15 0 kg/ha). If these reported figures in the tables are correct, please explain why they are all now based on the same rate?

USG Response Starting in the 2010 nomination documents, for use of methyl bromide in 2012, the U.S. used similar rates for the vege table crops. We have used 125 kg MeBr/ha for all of the vegetables (see Appendix A) for corrected nomination tables. T here are some inconsistencies with the number presented in the chapters and we have recalculated the numbers for all of the nominated

se ctors

.

MBTOC Question

2. The transition rate is similar for all vegetables even though the availability of some chemical and non chemical alternatives appear to be apparently different. How was the transition rate for all vegetable nominations (80%) c alculated?

USG Response As part of the 201 1 methyl bromide Critical Use Exemption (CUE) process , for use in 2013, the U.S. government was contacted by several applicants who asserted that some alternatives were not providing consistently effective contro l or that it was too expensive to convert their fumigation equipment to use the alternatives. This information was provided at the end of the process for preparing the CUE nomination packages and supporting technical and economicPage 2 of 17

information had not been collected by those applicants. Therefore, the USG cut all these sectors by 80% while waiting for them to provide information to substantiate these claims. The applicants are collecting the information and the USG will provide this information to MBTOC pri or to the OEWG.

MBTOC Question

3. What is the registration status of DMDS on the different vegetables?

USG Response Dimethyl disulfide (Paladin TM and Paladin ECTM ) have federal registrations and are currently registered in 18 states (listed below). Registration is pending in three states that have requested Critical Use Exemptions in the past (CA, FL & NY). The registered use sites include: fruiting

v egetables (eggplant, pepper, t omato ), c ucurbit crops (cucumbers, melons [all], squash [all]),

small fruit crops (blueberry, caneberry, strawberry), field grown ornamentals, and forest nursery crops. Rates of the 98:2 formulation range from 310 to 455 pounds of Paladin formulation per

treated acre. One concern about the adoption of DMDS is the odor iss ue. The registrant and distributor are currently working on techniques to reduce the odor.

AR AZ GA IN

KY MD MI NC

NJ NM OH OR

PA SC TN TX

VA WA



### US Cucurbits

MBTOC Question

1. Are there any research trials being conducted for this sector?

USG Response Several studies have been conducted in recent years and many continue to be. To illustrate recent research not captured in previous years’ nominations, provided below is a selected list of research reports from the Proceedings of the 2010 Meth yl Bromide Alternatives Outreach (MBAO) Conference, which are available on the internet at http://mbao.org/2 010/Proceedings/Methyl%20Bromide%20Phaseout%20

-- %20Proceedings%20of%202010%20Alternatives%20Research%20Conference.htm

.

Bausher, M. G. and D. O. Chellemi. 2010. Performance of Grafted Tomatoes in Open Field Trials at

Two Locations in Florida. Driver, J.G . and F. J. Louws. Evaluation of non

- fumigant based and drip applied nematicides to

manage root

- knot nematode (Meloidogyne spp.) on yellow squash. Freeman, J., M. Paret, T. McAvoy, S. Olson, and S. Rideout. 2010. Utilization of grafted tomato seedlings for bacterial wilt resistance in open field production.

Kokalis

- Burelle, N., E. N. Rosskopf, and M. G. Bausher. 2010. Grafting for control of Meloidogyne incognita on bell pepper, tomato, and melons. MacRae, A. W. , G.Vallad, and J. W. Noling. 2010. Evaluatio n of all Components of the 3

- WAY Fumigant System for use in Central Florida Tomato.Page 3 of 17

Vallad. G., A. W. MacRae, T. Jacoby, and J. W. Noling. 2010. Sustainability of methyl bromide

alternatives

– tomato and pepper initial crop. Welker, R.M., J.G. Driver, C. L. Rivard and F. J. Louws.2010. Outreach and new approaches for methyl bromide alternatives through the USDA area

- wide project.

Studies done in southern U.S. tomato and pepper production systems are also included in the list above, because these systems are similar to southern U.S. cucurbit production in terms of soil environment, key pests, etc. Research done prior to 2010 was summarized in the USG nominations submitted in 2009 and earlier. Therefore, it is not reproduced here.

MBTOC Question

2. What specific alternatives other efforts are there to adopt alternatives for the remaining

nomination?

USG Response As indicated by the partial list of studies described in the response to the previous question, there are ongoing efforts to evaluate and eventu ally adopt several alternatives in commercial U.S. cucurbit production. These include the use of alternative fumigants, alone and in combination. These approaches appear to be the most feasible, and include 1,3

- D + chloropicrin, metam

sodium, and the seque ntial application of these materials known as the “Georgia 3

- way”. Iodomethane formulated with chloropicrin and DMDS are other newly available alternatives that the industry is working to adopt as methyl bromide alternatives.

There is also ongoing work t o explore the use of grafting resistant cultivars and drip

- applied nematicides as methods to control specific pests in specific conditions. While these are not apparently ready for large

- scale commercial utilization, they are part of the long

- term effort t o adopt a variety of methyl bromide alternatives.



### US Peppers
MBTOC Question

1. The proposed rate for 2013 (150 kg/ha) is higher than the proposed rate for 2012 (125 kg/ha). MBTOC wonders whether this rate increase result from spelling mistak e or an ac tual

increased rate.

USG Response MBTOC is correct the rate should be listed as 125 kg MeBr/ha for all of the vegetables (see Appendix A) for corrected nomination tables. There are some inconsistencies with the number presented in the chapters and we ha ve recalculated the numbers for all of the nominated sectors.Page 4 of 17



### US Eggplant
MBTOC Question

1. When is Iodomethane is expected to be registered on eggplant?

USG Response While early research has suggested that this may be a suitable use for this fumigant t he

EPA /Office of Pesticide Programs has not received a request to register iodomethane for this

crop.

MBTOC Question

2. Are there any research trials being conducted for this sector?

USG Response Several studies in vegetable production sy stems similar to eggplant have been conducted in recent years and many continue to be. To illustrate recent research not captured in previous years’ nominations, provided below is a selected list of research reports from the Proceedings of the 2010 Methyl Bromide Alternatives Outreach (MBAO) Conference, which are available on

the internet at http://mbao.org/2010 /Proceedings/Methyl%20Bromide%20Phaseout%20

-- %20Proceedings%20of%202010%20Alternatives%20Research%20Conference.htm

.

While these studies have not been done in eggplant specifically, the USG believes they are relevant to the portion of U.S. eggplant crops that are included in the nomination. This is because the growing conditions and the pest spectrum included in these studies appears to be similar to those in the eggplant sector under consideration here.

Bausher, M. G. and D. O. Chellemi. 2010. Performa nce of Grafted Tomatoes in Open Field Trials at

Two Locations in Florida. Driver, J.G. and F. J. Louws. Evaluation of non

- fumigant based and drip applied nematicides to

manage root

- knot nematode (Meloidogyne spp.) on yellow squash.
Freeman, J., M. Paret, T . McAvoy, S. Olson, and S. Rideout. 2010. Utilization of grafted tomato seedlings for bacterial wilt resistance in open field production.

Kokalis

- Burelle, N., E. N. Rosskopf, and M. G. Bausher. 2010. Grafting for control of Meloidogyne incognita on bell pe pper, tomato, and melons. MacRae, A. W. , G.Vallad, and J. W. Noling. 2010. Evaluation of all Components of the 3

- WAY Fumigant System for use in Central Florida Tomato. Vallad. G., A. W. MacRae, T. Jacoby, and J. W. Noling. 2010. Sustainability of methyl bromide

alternatives

– tomato and pepper initial crop. Welker, R.M., J.G. Driver, C.L. Rivard and F. J. Louws.2010. Outreach and new approaches for methyl bromide alternatives through the USDA area

- wide project.

Research done prior to 2010 was summarize d in the USG nominations submitted in 2009 and earlier. Therefore, it is not reproduced here.Page 5 of 17

MBTOC Question

3. What specific alternatives other efforts are there to adopt alternatives for the remaining

nomination?

USG Response As indicated by the partial list of studies described in the response to the previous question, there are ongoing efforts to evaluate and eventually adopt several alternatives in commercial U.S. eggplant production. These include the use of alternative fumigants, alone and in combination. These approaches appear to be the most feasible, and include 1,3

- D + chloropicrin, metam

sodium, and the sequential application of these materials known as the “Georgia 3

- way”.

Work on drip

- applied nematicides as methods to control specific pests in specific conditions conducted in other vegetable crops may also be applicable to U.S. eggplant production. While these are not apparently ready for large

- scale commercial utilization, they are part of the long

term effort to adopt a variety of me thyl bromide alternatives.



### U.S. Fruit, Nut, and Flower Nurseries
No questions



### USA Orchard Replant

MBTOC Question

1 Iodomethane has been registered in California since December 2010. Can the USG give reasons why MI has not been considered as an alter native in the CUN for 2013?

USG Response Iodomethane, which may be an effective alternative, was registered in December 2010 in California but at lower use rates than the rest of the U.S. and with buffer distances up to 10 fold greater (e.g. Browne et al ., 2010, Cabrere et al., 2010). We didn’t calculate, for use in 2013 what the effectiveness of lower rates might be or the impact of the buffers.

Browne, G., Lampinen, B. , Doll, D., Holtz, B., Updahyaya, S., Schmidt, L., Wang, D., Fennimore, S.,

Hanson , B., Gao, S., Klonsky, K., and Johnson, S. 2010. Integrated pre

- plant alternatives to methyl bromide for almonds and other stone fruits. Annual International Research Conference on Methyl Bromide Alternatives (2010). Available online at http://mbao.org/2010/Proceedings/028BrowneG.pdf

. Cabrera, J.A., Gan, J., Hanson, B.D., Wang, D. 2010 Factors affecting the nematicidal activity of dimethyl disulfide. Annual International Research Confe rence on Methyl Bromide Alternatives (2010). Available online at http://mbao.org/2010/Proceedings/005CabrereaA.pdf

.

MBTOC Question

2 MBTOC acknowledges the substantial reduction in the u se of methyl bromide for replant

p articularly for 2012 and 2013. Can the USG indicate what alternatives/methods will be employed to effect the final transition and can these not now be extended to eliminate or further reduce the dependence of MB for Repla nt?Page 6 of 17

USG Response Presumably the final transition will involve the incorporation of io domethane and possibly (if registered) DMDS in addition to adoption of some non

- fumigated methods (steam) that will require use of specialized equipment and extensive ed ucation. Ongoing research (e.g. steam, iodomethane, DMDS, tarp technologies, individual tree

- hole applications) should support the future adoption by growers after 2013

.



### USA Ornamentals

MBTOC Question

1. What is the justification for use of a 20 g/m2 for Florida when t he growers are using "hot gas"

and VIF? Why is there a need for this dose? Do you have data to sup port use of this dose?

USG Response The US rates are based on information from the applicants. This rate covers uses in a wide

va riety of sites (greenhouses, shade houses, open fields, etc.) and a wide range of uses from pathogen control, to removal of the previous crop. The researchers in Florida have been focused on testing the alternatives (e.g. iodomethane, DMDS, steam, biofumi gation, etc.) and not on testing reduced rates.

MBTOC Question

2 · The total treated area in the nomination was reduced from 322 ha to 241 ha, however the amount of MB required is the same. Is this correct? Is the information in table 4 (Nomination am ount) correct?

USG Response The nomination is for a total of 48, 164 kg and 241 ha which is the same request as for 2010 (for use in 2012). There are some inconsistencies with the number presented in the chapters and we

have recalculated the numbers for all of the nominated sectors (see Appendix A).



### USA Strawberry fruit

MBTOC Question

1. · Is it possible for the USG to provide a possible transition plan for phase out for this

nomination.

USG Response

A t this time the USG does not have sufficient i nformation to make this type of assessment.

MBTOC Question

2. · Rate for 2013 CUN is 120 kg/ha, not 170 kg/h a as mentioned in the table 4. Rate for 2012 is shown 152 kg/ha as well. How was a rate reduction from 152 kg/ha for 2012 to 120 kg/ha for

2013 ac hieved?Page 7 of 17

USG Response The USG intention is to request a use rate of 170 kg of MeBr/ha for strawberry fruit for 2011, for use in 2013. This is the same use rate of methyl bromide that was requested in 2010, for use in 2012. Please see Appendix A for upda ted BUNNI information.

MBTOC Question

3. · Is it possible to provide a table of which alternatives have been adopted in past years to reduce the nominations? What kinds of alternatives do growers use in the area where methyl

bromide of critical use nomi nation is not used? And can you also list for each region why the

alternative cannot be used?

USG Response

The USG does not have information on the rate of adoption of individual alternatives for strawberry fruit. The California Strawberry Commission p lans on presenting updated information on the suitability of alternatives at the MBTOC meeting in Antalya.

Table 1. California Strawberry Commission Adoption of Alternatives, June 2010

MBTOC Question

4. · The CUN mentions excellent results of researc h with DMDS. What is the expected time path for registration of DMDS for strawberry in California? What transition to DMDS could be expected in the coming years?

USG Response The USG does not have information on the registration timing in California for DMDS.

MBTOC Question

5. · Please indicate the expected adoption rate for Methyl Iodide on strawberry fruit over the years since registration (in Dec 2010)?Page 8 of 17

USG Response

The USG estimated a 7% adoption rate for iodomethane per year for 2011 through 2013. The uncertain nature of iodomethane performance at lower rates, the price compared to alternatives

, the concerns of county agricultural commissions, and the impacts of larger buffers in California make it very difficult to estimate a transition time for this chemical.

MBTOC Question

6. · Will growers in California transition to use Methyl Iodide instead of 1,3

- D on non

- strawberry crops and if so, how is this expected to affect the township caps on 1,3

- D for strawberry

fruit?

USG Response

The USG has n ot estimated transition time for iodomethane use in non

- CUE crops. Several factors would probably affect such a transition, including the performance of iodomethane compared to their current 1,3

- D standard mixture(s), the price of iodomethane compared to alternatives, restrictions placed on iodomethane by county

- level agricultural commissioner s
, and the impacts of larger buffers mandated by California regulators. These issues make it very

difficult at this time to make an accurate, reliable estimate of the extent to which California growers will transition to iodomethane.



### USA Strawberry RUNNERS

MBTOC Question

1. On Page 1 the CUN states that use is requested for 19 ha where 1,3

- D is not an approved treatment, is not economically feasible o r is limited by township caps. On page 5 it says

becau se of soil type, and moisture? Could you please be more specific? Where is the 19 ha situated and what is the specifi c restriction on 1,3D/Pic use? (Page 1 also states use is for 22

ha but we assume this is a typographical error) as it does not match the table.)

USG Response The constraint to 1,3

- D use is based on label descriptions of conditions to make 1,3

- D effective: soil moisture (<12% at 1 meter) and not heavy clay soils. Effective rates under those c onditions would be greater than the label rate allowance. In addition, any regulatory restriction based on township caps would come into play. The 19 ha were considered to have at least one of these

constraints. The exact acres fumigated change each yea r and the USG does not have information on which specific fields will be fumigated in 2013.

MBTOC Question

2. In the nomination on page 1 it states that ‘Based on this assessment the transition rate has been greatly increased for this sector’ yet the n ominated amount has been the same for several ye ars. Could you please clarify?

USG Response The nomination document should have stated that the nomination amount requested is unchanged.Page 9 of 17

MBTOC Question

3. The CUN states that certification covers zero tolerance for damaging diseases and plant

parasitic nematodes in order to minimize the spread of these pests to production fields. If so, how are the 19 has surveyed for damaging d iseases and nematode presence? What are the specific diseases referred to?

USG Response California regulations particularly apply to nematodes. California regulations specify that inspectors issue certification of successful nematode treatment according to the regulations (based on soil type and treatment type). This appears to be a quarantine questions and the USG wonders why it was submitted with CUE questions

.

MBTOC Question

4. Can you provide the trial data that specifically relates to the ineffectiveness of alternatives against the diseases and parasitic nematodes fo r which the request is made?

USG Response Again, 1,3

- D is listed as an acceptable treatment for nurseries, within certain soil type specifications. The 19 ha were considered to have some constraint (soil type, moisture, cap) that precluded its effective use. The nomination has considered 1,3

- D effective in areas that are not constrained by the above. This, again, is a land calculation issue

-- what acreage is affected by clay soils/high moisture, or regulatory caps.

MBTOC Question

5. The specific cert ification text shown in the CUN states that ‘All nursery stock shall be kept ‘commercially’ clean with respect to established pests of general distribution. Commercially clean shall mean that pests are under effective control, are present only to a light degree, and that only a few of the plants in any lot or block of nursery stock or on the premises show any infestation or infection, and of these none show more than a few individuals of any insect, animal or weed pests, or more than a few individual infe stations of any plant disease.”

USG Response

See # 4 above

-- i.e., the nomination is for the small area of nursery land that is constrained in its effective use of 1,3

- D by one of the limits as described previously (soil type/moisture, regulatory caps). This appears to be a quarantine questions and the USG wonders why it was submitted with CUE questions

.

MBTOC Question

6. Can you please describe how this criteria is not met with the alternatives to methyl bromide?

USG Response

See # 4 above

-- i.e., th e nomination is for the small area of nursery land that is constrained in its effective use of 1,3

- D by one of the limits as described previously (soil type/moisture, regulatoryPage 10 of 17

caps). This appears to be a quarantine questions and the USG wonders why it w as submitted with CUE questions

.

MBTOC Question

7. The CUN uses references up till 2 008 to support the nomination. Could you please describe what efforts are being made to uptake alternatives, particularly MI which is considered a

su itable alternative since 2008? Specifically what efforts are being made to test and conduct

economic assessment of MI at lower rates?

USG Response The USG has been informed that trials are being developed to test iodomethane and the label

rates allowed in California. We have no further information on those trials. Those tests are only in the design stage and it will take several years to demonstrate consistent pest control before this alternative will be recommended by researchers, crop consultants and then adopted by gr owers.

MBTOC Question

8. The CUN also states that lower rates of MI and large buffer zones restrict its use? Could you please provide the evidence to support this statement?

USG Response This information is based on an EPA, Office of Pesticide Prog rams assessment. In general the

assessment indicated that smaller blocks would be treated, or lower rates needed, to avoid large (untreated) buffer areas

, provide growers more time to fumigate a field, as well as to account for

increased difficulties cont rolling soil moisture, and increased management time to plan and conduct fumigations.

Analysis of Soil Fumigant Risk Management Requirements using Geographic Information Systems: Case Studies based on a Forest Seedling Nursery (DP# 363546). Available o nline at: http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

- 2005

- 0123

- 0465

.



### USA Tomatoes

– FIELD

No questions



### USA Research Request

MBTOC Question

1. MBTOC finds difficulty in preliminary assessment of this nomination as there have been no details provided on the use (description of trials, rese arch plans, treatments, etc.). Are these

available?

USG Response Research projects are ongoing as funded by grower groups, the USDA Agricultural Research

Se r vice, and the USDA National Institutes for Food & Agriculture (NIFA)

. NIFA grants arePage 11 of 17

provided via the Integrated Pest Management Crops at Risk (CAR), Risk Avoidance and Mitigation (RAMP), and Methyl Bromid e Transitions (MBT) Competitive Grants Programs.

USG is providing a partial list of ongoing research projects which begin in the year 2010 and some continuing into 2013. Given the short timeframe, we were not able to provide a detailed description of tri als, research plans, treatments, etc. We plan to provide the requested information upon our return to the states and forward the information for consideration before the Open

- Ended Working Group. We expect that research details for 2012 and 2013 trials w ill be dependent upon the outcome of 2011 studies. Because of this the amounts of methyl bromide

for research provided in our nomination request were only estimates from research ers and may or may not be the final amounts used.

Table 2. Example of In dividual Research Program: Dr. Joseph W Noling 2009, Florida Project # Title Start Date End Date

FLA

- LAL

- 04776 Grower field demonstration Trialing of Gas

Impermeable plastic mulches, Reduced Rates of Soil Fumigants, and Optimized Irrigation and

Cultural P ractices 9/19/2009 9/31/2010

FLA

- LAL

- 04553 Large Scale Field Demonstration Validation trials

in Florida Strawberry 9/19/2007 9/31/2011

FLA

- LAL

- 04575 Biology, Interaction, and Management of

Nematodes and Weeds of Florida Vegetable Crops 8/1/2006 7/31/201 1

FLA

- LAL

- 04553

- Large Scale Field Demonstration Validation

trials in Florida Strawberry

Table 3. Example of USDA Sponsored Research Programs

Project Cooperator Dates Grant

Amount

ADVANCED DEVELOPMENT AND IMPLEMENTATION OF ANAEROBIC

SOIL DISINFEST ATION TECHNOLOGY AS AN ALTERNATIVE TO

METHYL BROMIDE http://cris.nifa.usda.gov/cgi

bin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=41020&format=

WEBFMT6NT UNIV

. OF

TENNESSEE START: 01

SEP 2010

TERM: 31

AUG 2013 $643,177

MULTI

- STATE EVALUATI ON OF CARBONATED FUMIGANTS

AND LOW PERMEABLE TARPS TO REDUCE APPLICATION RATE, INCREASE EFFICACY, AND MINIMIZE EMISSIONS http://cris.nifa.usda.gov/cgi

bin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=40658&f

ormat=WEBFMT6NT UNIV. OF

FLORIDA STA RT: 01

SEP 2010

TERM: 31

AUG 2013

GRANT

YR: 2011 $ 0

ENERGY EFFICIENT STEAM SOIL DISINFESTATION SYSTEMS

FOR FLOWER AND STRAWBERRY http://cris.nifa.usda.gov/cgi

bin/starfinder/0?path=fastlink1.txt&id=anon&pass=&search=R=40815&f

ormat=WEBLINK UNIV OF

CALIFO RNIA , DAVIS START: 01

SEP 2010

TERM: 31

AUG 2013

GRANT

YR: 2010 $500,000

STRAWBERRY AND ORNAMENTAL PRODUCTION WITHOUT

METHYL BROMIDE EMPLOYING GROWER

- DIRECTED

ALTERNATIVE PEST MANAGEMENT RESEARCH AND

OUTREACH http://cris.nifa.usda.gov/cgi

bin/starfinder /0?path=fastlink1.txt&id=anon&pass=&search=R=270&for UNIV OF

CALIFORNIA , DAVIS START: 01

SEP 2008

TERM: 31

AUG 2011

FY: 2009

GRANT $674,595Page 12 of 17

mat=WEBFMT6NT YR: 2008 South Atlantic Areawide Pest Management (Awpm) Project for Methyl

Bromide Alternatives http: //www.ars.usda.gov/research/projects/projects.htm?accn_no=411360 Subtropical

Plant Pathology

Research Start Date:

Oct 01,

2006

End Date: Sep 30,

2011 not listed

Alternatives to Mebr for California Cropping Systems http://www.ars.usda.gov/research/projec ts/projects.htm?accn_no=412732 Water Management

Research Start Date:

Dec 26,

2007

End Date:
Dec 25,

2012 not listed

MBTOC Question

2. The details above would specifically need to show how the remaining challenges in each sector are being addressed un der Decision IX/6 particularly attempts to reduce emissions and efforts made to adopt alternatives, including the number of trials from which data is required

to support reg istration of alternatives etc. Are you able to provide such information?

USG Resp onse

The USG is working to compile information to address this request and will submit this to MBTOC as soon as it is available. Can MBTOC provide the USG with the specific sectors they are interested in when they posed this question? Knowing this could h elp the USG provide the most relevant details.Page 13 of 17

APPENDIX A. 2013 Methyl Bromide Usage Newer Numerical Index (BUNNI)

We have attached the tables for the nominated amounts because there were some inconsistencies in the rates presented in our nomination d ocuments

. These inconsistencies did not change the amount requested except in cucurbits which was increased by 1 kg (11,899 to 11,900 kg).

N OMINATION A MOUNT

– F OR C OMMODITIES

N OMINATION A MOUNT

– F OR D RIED , C URED P ORK P RODUCTSPage 14 of 17

N OMINATION A MOUNT

– F OR S TRUCTURES

– F OOD P ROCESSORS

N OMINATION A MOUNT

– F OR C UCURBITS

N OMINATION A MOUNT

– F OR E GGPLANTPage 15 of 1 7

N OMINATION A MOUNT

– F OR P EPPER

N OMINATION A MOUNT

– F OR S TRAWBERRY F RUITPage 16 of 17

N OMINATION A MOUNT

– F OR T OMATO

N OMINATION A MOUNT

– F OR N U RSERY S TOCK

N OMINATION A MOUNT

– F OR O RCHARD R EPLANTPage 17 of 17

N OMINATION A MOUNT

– F OR O RNAMENTALS

N OMINATION A MOUNT

– F OR S TRAWBERRY N URSERY