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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

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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

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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
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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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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

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### iAQ 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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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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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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## 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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## MAR 2

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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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## 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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## 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

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## 4 AIR ANC RADIATION 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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### i 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

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