## United Nations Environment Programme Methyl Bromide Technical Options Committee

Structures and Commodities (SC)

MBTOC Co

- Chair:

Ms Michelle Marcotte (Canada) email: marcotteconsulting@co geco.ca

February 12 , 2013

Mr Marco Gonzalez Executive Secretary

UNEP Ozone Secretariat

and

Dr. Federico San Martini, Ph.D. Foreign Affa irs Officer Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2657 Washington, D.C. 20520

U.S.A.

E

- mail: SanMartiniFM@state.gov

Dear Marco and Dear Frederico San Martini and colleagues,

MBTOC SC has completed its first level review of the US dates CUN. During this period some questions have been raised as described below. Part of the reason that MBTOC corresponds with Parties prior to making its recommendation is to ensure transparency and ensure the Party

understands our trend of thought ahead of our report

. Our letters are the result of a consensus

process.

All sections of MBTOC will meet in London in early April and if you could deliver the answers to these questions a head of that meeting we would appreciate it.

If any of our questions are unclear, or if you would like further information, please contact me. I will then confer with my colleagues and prepare an answer for you.

Questions concerning moisture content of dates:

Information concerning the moisture content of dates, and also how to stabilize it, is key to the quality of dates during a fumigation, and of the choice of a fumigant. Understanding the moisture content of dates leads to an understanding of the t rue restriction to fumigation with phosphine. That is why we really need to understand it thoroughly.

W hat is the range and the maximum Equilibrium Relative Humidity ( e.r.h ) or moisture content ( m.c. ) acceptable at harvest intake ? Does e.r.h or m.c. vary over the harvest period and if so what are the contributing factors to this variation?

Aerating the freshly harvested dates to even out differences in moisture content would avoid fumigation and allow phosphine to be used (with its longer treatment tim e). Do the dates ever have to be artificially dried to make the m dry enough for ambient air storage?Questions concerning comparative volumes of product to be MB treated:

EPA proposed rule (Federal Register, 77 FR 74435, December 14, 2012) describes the Limiting Critical Conditions for methyl bromide use in 2013. These conditions report, among other things, that MB use for dates is only for California dates in Riverside County. We are wondering if it is this Limiting Critical Condition which explains the variance we see in data on total date harvest.

For example, the CUN (Table 4) reports total date harvest of 19,396 tonnes. But, recently released data by USDA

- NASS gives 2012 California production as 31,100 tons (28,213 MT). Please provide the total harv est of dates for the entire State and/or county that is included in this

CUN.

To assist you to understand the reasoning for this request, the CUN requests MB for 15,500 m 3

of dates, which MBTOC has to convert to tonnes and then determine the percentage o f the total date harvest for which MB treatment is requested.

Converting dates from m3 to tonnage requires knowledge of the date storage bins and the stowage factors. The CUN requests MB for 15,500 cu m of dates. At this point, MBTOC

has estimated 400kg of dates in the storage boxes (assumed 1 m3 capacity) and assuming 'under tarp' fumigation

. With a 20% allowance for extra fumigated space for stacking and dunnage, 15,500 m3 of dates

, as handled

, is equivalent to about 5000 tonnes of dates. We

believe th e plastic boxes used for field storage of California dates may allow for more weight per cu m than does the wooden boxes used for other dried fruit in California, but seek confirmation of

this.

S ources in California can supply more accurate figures and if so, we would appreciate receiving

them.

Questions concerning the impact of market timing on fumigation needs:

The CUN notes, ‘Commodity fumigation with methyl bromide is used primarily at harvest time, when rapid fumigation is needed to keep up with t he large volumes of incoming commodities that need to be shipped to market in three days for maximum value.’

By this statement does the US actually mean that some portion of the harvest has to be quickly fumigated to get their crop to market within three days to achieve premium prices? When does the need for rapid marketing occur?

We ask this because other sources do not indicate a need for immediate marketing of dates, or a

short market window.

We are basing our statement on the following sources:

“Ha rvest Season: October 1

– December 15. This is reported in California Agricultural Statistics 2011 Crop Year. Issued by USDA National Agricultural Statistics Service, California Field Office, October 31, 2012. USDA

- NASS also reported the following in 2 006 for California dates: Usual Harvesting Dates Begins Aug 15

Most Active Oct1

– Dec 15

Ends Mar 1 Usual Marketing Dates Begins Aug 15

Most Active Oct 1

– Dec 20

Ends Mar 15 Source: Fruits and Tree Nuts: Blooming, Harvesting, and Marketing Dates

, Agriculture Handbook Number 729. USDA, National Agricultural Statistics Service

. December 2006.

Marketing Year: October 1 through September 30 of the following year. This is established by

the California Date Commission Law and is consistent with Fed eral Marketing Order 987:

California Dates.”Therefore we ask for more detailed substantiation of this CUN statement, since it forms a key

basis for the CUN.

Questions concerning treatment parameters:

Is fumigation with MB restricted to a particular tim e of year and/or variety?

What is the availability of

, and size of

, fixed fumigation structures ?

The CUN notes that phosphine treatment takes longer than sulfuryl fluoride to fumigate dates (5 to 7 days), and during this time the dates ferment, resulting in an off

- flavor and an unmarketable product . MBTOC needs to know the moisture content of the dates because it seems possible that the aspect of this statement pertaining to potential damage done by longer fumigation is incorrect. A visit by MBTOC members and Dr. Walse (USDA) observed that the California date processor kept dates under MB fumigation for at least for 15 days.

Questions concerning current and planned research on pest control for dates:

The CUN provides a bit of an indication of the plann ed research on MB alternatives for dates. However, we believe the CUN was written several months ago. At this time is it possible for the US to provide an update and more detail on the research being conducted this year and planned for next year on MB alte rnatives for dates?

Questions on fact checking

- economics :

The table on page 4 of the CUN indicates a gross revenue of >US$32 million per tonne. This seems unlikely. We note that the ‘ Non

- citrus Fruits and Nuts 2012 Preliminary Summary (January 2013). USDA ’s National Agricultural Statistics Service’ reports a 2011 price per tonne as US$1320 and a 2112 price per tonne of US$1340. Could the US please provide a correct

number?

Thank you for your consideration of our information request

.

Yours since rely,

Michelle Marcotte

MBTOC Co

- Chair