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Kinesha Allen 

The Smithfield Packing Co. Inc. 

601 North Church Street, 

Smithfield, VA 23430 

Dear Ms. Allen: 

MAR 2 'L" 1,fl OFFtCE OF 

A1R AND RADIATION 

This letter is to inform you that the United States government included your application submitted on 

behalf of the Smithfield Packing Company for the 2016 U.S. Nomination for a Critical Use Exemption 

(CUE). 

Since the start of the CUE application process in 2002, the EPA has worked with applicants to obtain the 

latest information to develop the most robust annual nomination possible. The success of these efforts to 

develop and defend credible and technically-based U.S. nominations is evidenced by the fact that the 

Parties have granted the United States 88 percent of our overall nomination over this period. Additional 

information regarding the basis of this nomination can be found on the EPA's website at 

http://www.epa.gov/ozone/mbr/2016—nomination.html. 

Beginning in early summer, the EPA will be accepting CUE applications for the use of inethyl bromide 

in 2017. Any future requests will be thoroughly evaluated against the nomination criteria of Decision 

IX/6 of the Montreal Protocol on Substances that Deplete the Ozone Layer. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.biIl@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arlingjeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

internet Address (URL) • httpJhvww.epa.gov 

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MAR t OFFICE ()F 

AIR AND RADIATION 

Dan Botts 

800 Trafalgar Court, Suite 200, 

Maitland, FL 3 2794 

Dear Mr. Botts: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the Florida Cut Flower Growers for the 2016 United States Nomination for a 

Critical Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a 

nomination for a critical use, the U.S. Government must determine that the use meets the criteria of 

Decision IX/6 under the Montreal Protocol on Substances that Deplete the Ozone Layer. Specifically, 

the lack of inethyl bromide must result in a significant market disruption and there are no technically 

and economically feasible alternatives in the circumstances of your application. In addition, applicants 

must show that they are taking steps to minimize their critical use of inethyl bromide and any associated 

emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. While no single alternative is effective for all pest problems, a review of 

multiple year data indicates that the alternatives in various combinations provide control equal or 

superior to methyl bromide plus chloropicrin. Research demonstrates that 1,3-D plus chloropicrin, the 

three way mixture of 1,3-D plus chloropicrin plus metam sodium, and dimethyl disulfide plus 

chloropicrin all show excellent results. There was no loss as a percent of gross revenue for the three way 

mixture. No loss data were provided for 1,3-D plus chloropicrin but the price is lower than methyl 

bromide. Further detail can be found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

Internet Address (URt.; • http./Jwevw.epa.gov 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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r~ AIR AND RADIATION 

David Riggs 

Quail Run Business Solutions, Inc. 

110 Chase Lane 

Aptos, CA 95003 

Dear Mr. Riggs: 

This letter is to inform you that the U.S. government was unable to include your application submitted 

on behalf of the California Cut Flower Commission for the 2016 United States Nomination for a Critical 

Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a nomination for 

a critical use, the U.S. Government must determine that the use meets the criteria of Decision IX/6 under 

the Montreal Protocol on Substances that Deplete the Ozone Layer. Specifically, the lack of inethyl 

bromide must result in a significant market disruption and there are no technically and economically 

feasible alternatives in the circumstances of your application. In addition, applicants must show that they 

are taking steps to minimize their critical use of inethyl bromide and any associated emissions and are 

undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. While no single alternative is effective for all pest problems, a review of 

multiple year data indicates that the alternatives in various combinations provide control equal or 

superior to methyl bromide plus chloropicrin. Research demonstrates that 1,3-D plus chloropicrin and 

the three way mixture of 1,3-D plus chloropicrin plus metam sodium show excellent results. There was 

no loss as a percent of gross revenue for 1,3-D plus chloropicrin and for the three way mixture. Further 

detail is found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Kasey Cronquist 

Internet Address (URL; • http:?/wrvvw.epa gov 

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MAR 2 ,j Z01.1 OFFICE OF 

AIR ANU RADIATION 

Marty Manion 

1 Meating Place, 

Elizabethtown, PA 17022 

Dear Ms. Manion: 

This letter is to inform you that the United States government included your application submitted on 

behalf of the American Association of Meat Processors for the 2016 U.S. Nomination for a Critical Use 

Exemption (CUE). 

Since the start of the CUE application process in 2002, the EPA has worked with applicants to obtain the 

latest information to develop the most robust annual nomination possible. The success of these efforts to 

develop and defend credible and technically-based U.S. nominations is evidenced by the fact that the 

Parties have granted the United States 88 percent of our overall nomination over this period. Additional 

information regarding the basis of this nomination can be found on the EPA's website at 

http://www.epa.gov/ozone/mbr/2016_nomination.html. 

Beginning in early summer, the EPA will be accepting CUE applications for the use of inethyl bromide 

in 2017. Any future requests will be thoroughly evaluated against the nomination criteria of Decision 

IX/6 of the Montreal Protocol on Substances that Deplete the Ozone Layer. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arlingjeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Chris Young 

Internet Address (URL) • httpl.Miww.epa.gov 

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MAR 2 

pF"rICE CF 

F.IR ;,ND RADIAT;b\ 

Candace Cansler 

National Country Ham Association 

PO Box 948 

Conover, NC 28613 

Dear Ms. Cansler: 

This letter is to inform you that the United States government included your application submitted on 

behalf of the National Country Ham Association for the 2016 U.S. Nomination for a Critical Use 

Exemption (CUE). 

Since the start of the CUE application process in 2002, the EPA has worked with applicants to obtain the 

latest information to develop the most robust annual nomination possible. The success of these efforts to 

develop and defend credible and technically-based U.S. nominations is evidenced by the fact that the 

Parties have granted the United States 88 percent of our overall nomination over this period. Additional 

information regarding the basis of this nomination can be found on the EPA's website at 

http://www.epa.gov/ozone/mbr/2016 —nomination.html. 

Beginning in early summer, the EPA will be accepting CUE applications for the use of inethyl bromide 

in 2017. Any future requests will be thoroughly evaluated against the nomination criteria of Decision 

IX/6 of the Mvntreal Protocol on Substances that Deplete the Ozvne Layer. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arlingjeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Sam Edwards 

Internet Address (URi_) • http.!lwww.epa.gov 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

AIR AND RADIATION 

Lanry Pierce 

200 Bertie Pierce Road, 

Pikeville, NC 27863 

Dear Mr. Pierce: 

This letter is to inform you that the United States government included your application submitted on 

behalf of Nahunta Pork for the 2016 U.S. Nomination for a Critical Use Exemption (CUE). 

Since the start of the CUE application process in 2002, the EPA has worked with applicants to obtain the 

latest information to develop the most robust annual nomination possible. The success of these efforts to 

develop and defend credible and technically-based U.S. nominations is evidenced by the fact that the 

Parties have granted the United States 88 percent of our overall nomination over this period. Additional 

information regarding the basis of this nomination can be found on the EPA's website at 

http://www.epa.gov/ozone/mbr/2016 —nomination.html. 

Beginning in early summer, the EPA will be accepting CUE applications for the use of inethyl bromide 

in 2017. Any future requests will be thoroughly evaluated against the nomination criteria of Decision 

IX/6 of the Montreal Protocol on Substances that Deplete the Ozone Layer. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

Internet Address IURLj - http IJwww.epa.gov 

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UNITED STATES ENVIRONflAEIVTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

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OFFiCE OF 

r'.!? AND RAUTATION 

Dan Legard 

180 Westridge Drive, 

Watsonville CA 95076 

Dear Mr. Legard: 

This letter is to inform you that the United States government included your application submitted on 

behalf of the California Strawberry Commission for the 2016 U.S. Nomination for a Critical Use 

Exemption (CUE). 

The 2016 CUE nomination for California strawberry production was for production areas where 1) 

a transition period is needed for the use of broadcast 100% chloropicrin in fields with high pest pressure, 

in particular, with Macrophomina and Fusarium and 2) where 1,3-D is limited by township caps. 

Additional information regarding the basis of this nomination can be found on the EPA's website at 

http://www.epa.gov/ozone/mbr/2016 —nomination.html. 

Since the start of the CUE application process in 2002, the EPA has worked with applicants to obtain the 

latest information to develop the most robust annual nomination possible. The success of these efforts to 

develop and defend credible and technically-based U.S. nominations is evidenced by the fact that the 

Parties have granted the United States 88 percent of our overall nomination over this period. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-81 3 6 or by email at chism.bill@epa.gov . If you have 

questions on CUE process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Rick Tomlinson 

Interne; Address (URi.) • http.!;wvew.epa.gov 

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UNITED STATES ENVlRONMENTAL PROTECTION AGENCY 

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Or'FICE OF 

AIR ANJ RADIA710N 

David Riggs 

Quail Run Business Solutions, Inc. 

110 Chase Lane 

Aptos, CA 95003 

Dear Mr. Riggs: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the Florida Cut Flower Growers for the 2016 United States Nomination for a 

Critical Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a 

nomination for a critical use, the U.S. Government must determine that the use meets the criteria of 

Decision IX/6 under the Montreal Protocol on Substances that Deplete the Qzone Layer. Specifically, 

the lack of inethyl bromide must result in a significant market disruption and there are no technically 

and economically feasible alternatives in the circumstances of your application. In addition, applicants 

must show that they are taking steps to minimize their critical use of inethyl bromide and any associated 

emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. While no single alternative is effective for all pest problems, a review of 

multiple year data indicates that the alternatives in various combinations provide control equal or 

superior to methyl bromide plus chloropicrin. Research demonstrates that 1,3-D plus chloropicrin, the 

three way mixture of 1,3-D plus chloropicrin plus metam sodium, and dimethyl disulfide plus 

chloropicrin all show excellent results. There was no loss as a percent of gross revenue for the three way 

mixture. No loss data were provided for 1,3-D plus chloropicrin but the price is lower than methyl 

bromide. Further detail is found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 3 43-9055 or by email at 

arl ingj eremy@epa. gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Gary Obenauf 

Internet Address rURL; • httpJlw,vw.epa gov 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

o~ Q WASHINGTON, D.C. 20460 

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0 

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OFF!:;E OF 

:,IR AND RADIATION 

Carl Eidsath 

101 Parkshore Drive, Suite 250 

Folsom CA 95630 

Dear Mr. Eidsath: 

This letter is to inform you that the United States government was unable to include your applications 

submitted on behalf of the California Walnut Commission (pre-plant and post-harvest) for the 2016 

United States Nomination for a Critical Use Exemption (CUE) or a 2015 supplemental request for 

methyl bromide. To submit a nomination for a critical use, the U.S. Government must determine that the 

use meets the criteria of Decision IX/6 under the Montreal Protocol on Substances that Deplete the 

Ozone Layer. Specifically, the lack of inethyl bromide must result in a significant market disruption and 

there are no technically and economically feasible alternatives in the circumstances of your application. 

In addition, applicants must show that they are taking steps to minimize their critical use of inethyl 

bromide and any associated emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your applications, follow-up 

discussions, or published literature to indicate that your uses meet the nomination criteria in Decision 

IX/6 of the Montreal Protocol. Data indicate that sulfuryl fluoride is effective against key pests. The 

industry has mostly converted to sulfuryl fluoride and no market disruption has occurred. For this sector, 

rapid fumigation is not a critical condition, therefore, products can be treated with sulfuryl fluoride or 

phosphine and be held for relatively long periods of time without affecting industry. For the pre-plant 

application, numerous field trials indicate alternatives to methyl bromide are effective. Registered 

alternatives are available for individual-hole treatments and soil preparation procedures are available to 

enable effective treatment with alternatives even in soils with high moisture content. The economic 

returns with alternatives are at least as high as with methyl bromide because the alternatives are less 

expensive than methyl bromide. Further detail is in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arlingjeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Abhi Kulkarni, Michael McKenry 

Internet Address (URL; • http Ilwwwepa.gov 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

o Q WASHINGTON, D.C. 20460 

~(t o 

~~yTq4 PROS ~G~ k 

MAR 

OFFICE OF 

AIR AND RADIA?iON 

Chava McKeel 

Golf Course Superintendents Association of America 

1421 Research Park Drive 

Lawrence, KS 66049 

Dear Ms. McKeel: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the Golf Course Superintendents Association of America for the 2016 United 

States Nomination for a Critical Use Exemption (CUE) or a 2015 supplemental request for methyl 

bromide. To submit a nomination for a critical use, the U.S. Government must determine that the use 

meets the criteria of Decision IX/6 under the Montreal Protocol on Substances that Deplete the Ozone 

Layer. Specifically, the lack of inethyl bromide must result in a significant market disruption and there 

are no technically and economically feasible alternatives in the circumstances of your application. In 

addition, applicants must show that they are taking steps to minimize their critical use of inethyl 

bromide and any associated emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. Specifically, EPA is unable to find that a significant market disruption 

would occur in the golf industry in the absence of inethyl bromide. Further detail is found in the 

summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: David Riggs 

Internei Address (URL) • http.11www.epa.gov 

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UNlTED STATES ENVIRONMENTAL PROTECTION AGENCY 

o~ Q WASHINGTON, D.C. 20460 

PROjEG( 

0 

MAR 2 ~: ZD 14 

UFFICE OF 

AIR ANC RADIAT:ON 

Gary Obenauf 

6556 N. Dolores Ave., 

Fresno, CA 93711 

Dear Mr. Obenauf: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the California Dried Plum Board for the 2016 U.S. Nomination for a Critical Use 

Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a nomination for a 

critical use, the U.S. Government must determine that the use meets the criteria of Decision IX/6 under 

the Montreal Protocol on Substances that Deplete the Ozone Layer. Specifically, the lack of inethyl 

bromide must result in a significant market disruption and there are no technically and economically 

feasible alternatives in the circumstances of your application. In addition, applicants must show that they 

are taking steps to minimize their critical use of inethyl bromide and any associated emissions and are 

undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. Data indicate that sulfuryl fluoride is effective against key pests. The 

industry has mostly converted to sulfuryl fluoride and no market disruption has occurred. For this sector, 

rapid fumigation is not a critical condition, therefore, products can be treated with sulfuryl fluoride or 

phosphine and be held for relatively long periods of time without affecting industry. Further detail is 

found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Donn Zea 

Interriet Address (URL) • http:/hvww.epa gov 

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UNiTED STATES ENVIRONiVIENTAL PROTECTiON AGENCY 

o~ Q WASHINGTON, D.C. 20460 

R. 

PRO'G~ 

0 

MAR r4 

OFF!CE OF 

;;fR ANC RADIATION 

Kelly Covello 

Almond Hullers & Processors Association 

467 N. Wilma Ave, Suite 11 

Ripon, CA 95366 

Dear Ms. Covello: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the Almond Hullers & Processors Association and the California Grape and Tree 

Fruit League for the 2016 U.S. Nomination for a Critical Use Exemption (CUE) or a 2015 supplemental 

request for methyl bromide. To submit a nomination for a critical use, the U.S. Government must 

determine that the use meets the criteria of Decision IXJ6 under the Montreal Protocol on Substances 

that Deplete the Ozone Layer. Specifically, the lack of inethyl bromide must result in a significant 

market disruption and there are no technically and economically feasible alternatives in the 

circumstances of your application. In addition, applicants must show that they are taking steps to 

minimize their critical use of inethyl bromide and any associated emissions and are undertaking research 

into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. Numerous field trials indicate alternatives to methyl bromide are 

effective. Registered alternatives are available for individual-hole treatments and soil preparation 

procedures are available to enable effective treatment with alternatives even in soils with high moisture 

content. The economic returns with alternatives are at least as high as with methyl bromide because the 

alternatives are less expensive than methyl bromide. Further detail is found in the summary that EPA 

emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the appl'zcation process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arlingjeremy@epa.gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Marcy Martin 

Interr,et Address IURL) • http.!/www.epa.gov 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

2r4t PR01EG,C 

MAR 2 _ :'^I t OFFICE OF 

A.IR AND RADIATION 

Jim Wells 

1415 L St., Ste 460 

Sacramento, CA 95814 

Dear Mr. Wells: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the California Strawberry Nursery Association for the 2016 U.S. Nomination for 

a Critical Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a 

nomination for a critical use, the U.S. Government must determine that the use meets the criteria of 

Decision IX/6 under the Montreal Protocol on Substances that Deplete the Ozone Layer. Specifically, 

the lack of inethyl bromide must result in a significant market disruption and there are no technically 

and economically feasible alternatives in the circumstances of your application. In addition, applicants 

must show that they are taking steps to minimize their critical use of inethyl bromide and any associated 

emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. A Special Local Need label allows Telone II to be used in accordance 

with certification standards for propagative material. Growers can also use a combination of inethyl 

bromide for quarantine situations and 1,3-D plus chloropicrin for non-quarantine situations to meet 

certification requirements. Further detail is found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Kim Hensley 

Internet Address IURL) • http./lwww.epa.gov 

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Jim Wells 

1415 L St., Suite 460 

Sacramento, CA 95814 

Dear Mr. Wells: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of the California Association of Nurseries and Garden Centers for the 2016 U.S. 

Nomination for a Critical Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To 

submit a nomination for a critical use, the U.S. Government must determine that the use meets the 

criteria of Decision IX/6 under the Montreal Protocol on Substances that Deplete the Ozone Layer. 

Specifically, the lack of inethyl bromide must result in a significant market disruption and there are no 

technically and economically feasible alternatives in the circumstances of your application. In addition, 

applicants must show that they are taking steps to minimize their critical use of inethyl bromide and any 

associated emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. A Special Local Need label allows Telone II to be used in accordance 

with certification standards for propagative material. Growers can also use a combination of inethyl 

bromide for quarantine situations and 1,3-D plus chloropicrin for non-quarantine situations to meet 

certification requirements. Further detail is found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

cc: Kim Hensley 

Internet Address (URL? - http:llvrww.epa.gov 

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OFFICE OF 

AIR AND RADIATION 

Dr. Mary Hausbeck 

Department of Plant, Soil and Microbial Sciences, 

1066 Bogue St. 

A286 Plant and Soil Science Bldg., 

East Lansing, MI 48824 

Dear Dr. Hausbeck: 

This letter is to inform you that the United States government was unable to include your application 

submitted on behalf of Michigan Vegetable Growers for the 2016 United States Nomination for a 

Critical Use Exemption (CUE) or a 2015 supplemental request for methyl bromide. To submit a 

nomination for a critical use, the U.S. Government must determine that the use meets the criteria of 

Decision IX/6 under the Montreal Protocol on Substances that Deplete the Ozone Layer. Specifically, 

the lack of inethyl bromide must result in a significa.nt market disruption and there are no technically 

and economically feasible alternatives in the circumstances of your application. In addition, applicants 

must show that they are taking steps to minimize their critical use of inethyl bromide and any associated 

emissions and are undertaking research into alternatives. 

After careful review the EPA, in conjunction with the Department of State and the U.S. Department of 

Agriculture, determined that there was not sufficient evidence presented in your application, follow-up 

discussions, or published literature to indicate that your use meets the nomination criteria in Decision 

IX/6 of the Montreal Protocol. While no single alternative is effective for all pest problems, a review of 

multiple year data indicates that the alternatives in various combinations provide control equal or 

superior to methyl bromide plus chloropicrin. Several research studies show that the three way mixture 

of 1,3-D plus chloropicrin plus metam sodium can effectively suppress key pathogens (P. capsici, F. 

oxysporum) and nematodes. Research trials in Michigan indicate acceptable yield/quality with dimethyl 

disulfide plus chloropicrin. Further detail is found in the summary that EPA emailed on March 21, 2014. 

If you have questions on the technical aspects of the CUE program, please contact Dr. Bill Chism, 

Office of Pesticide Programs, at (703) 308-8136 or by email at chism.bill@epa.gov . If you have 

questions on the application process, please contact Mr. Jeremy Arling at (202) 343-9055 or by email at 

arling.jeremy@epa.gov . 

Sincerely, 

~ 

Sarah Dunham, Director 

Office of Atmospheric Programs 

Internet Address (URI) • http l/www.epa.gov 

Recycled/Recyclable • Printed with Vegetabte Oil Based Irtks on 100% Postconsumer. Process Chlorine Free Recycled Paper