Methyl Bromide Methyl Bromide Critical Use Exemptions Critical Use - - PowerPoint PPT Presentation

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Methyl Bromide Methyl Bromide Critical Use Exemptions Critical Use Exemptions

Colwell Cook Colwell Cook KSU Methyl Bromide Alternatives Workshop KSU Methyl Bromide Alternatives Workshop May 11, 2009 May 11, 2009

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Topics Topics

 Montreal Protocol

Montreal Protocol

 Methyl Bromide under the Protocol

Methyl Bromide under the Protocol

 Critical Use Exemption Process

Critical Use Exemption Process

 Division of Labor

Division of Labor

 U.S. Technical Review Process

U.S. Technical Review Process

 International Review

International Review

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Montreal Protocol on Substances Montreal Protocol on Substances that Deplete the Ozone Layer that Deplete the Ozone Layer

 Stratospheric ozone layer shields Earth from UV radiation

Stratospheric ozone layer shields Earth from UV radiation

 Overexposure to UV radiation leads to

Overexposure to UV radiation leads to

 Melanoma and non

Melanoma and non-melanoma skin cancers melanoma skin cancers

 Other health effects: cataracts, immunosuppression

Other health effects: cataracts, immunosuppression

 Ecological and economic impacts

Ecological and economic impacts



International treaty International treaty

 196 ratified states

196 ratified states

 Only universally ratified treaty

Only universally ratified treaty



Phases out production of ODS Phases out production of ODS



Considered most successful environmental international agreement Considered most successful environmental international agreement

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Montreal Protocol Timeline Montreal Protocol Timeline

1 9 8 7 1 9 9 2 1 9 9 5 1 9 9 7 2 0 0 9 2 0 1 5

1 9 8 7 - Treaty to Protect Ozone Layer 1 9 9 5 – Agreem ent to phase out MeBr by 2 0 1 0 in developed countries 1 9 9 2 - Methyl Brom ide listed as Ozone Depleting Substance 2 0 0 9 – CUE requests subm itted for 2 0 1 1 1 9 9 7 – Exem ption process created 2 0 1 5 – Developing countries Phase out MeBr

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Methyl Bromide Methyl Bromide – – Use Categories Under Use Categories Under Montreal Protocol Montreal Protocol

 Implemented under Clean Air Act

Implemented under Clean Air Act

 Administered by Office of Atmospheric Programs

Administered by Office of Atmospheric Programs

 Critical Use Exemption Process

Critical Use Exemption Process

 No technically and economically feasible alternatives

No technically and economically feasible alternatives

 Loss of use will lead to a market disruption

Loss of use will lead to a market disruption

 Quarantine and PreShipment

Quarantine and PreShipment

 Official government agency established quarantine

Official government agency established quarantine

 Commodities, nursery plants, soil treatment for propagative material

Commodities, nursery plants, soil treatment for propagative material

 Preshipment is 21 days before shipment under regulations established before

Preshipment is 21 days before shipment under regulations established before 1995 (e.g. Kenya timber) 1995 (e.g. Kenya timber)  Emergency Exemption

Emergency Exemption

 One time use of up to 20 metric tons

One time use of up to 20 metric tons

 Not implemented in U.S.

Not implemented in U.S.

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Critical Need: Critical Need:

 Alternatives must be Technically and Economically

Alternatives must be Technically and Economically Feasible Feasible

 Alternatives lead to a Market Disruption

Alternatives lead to a Market Disruption

 Technical and economic review establishes the

Technical and economic review establishes the fundamentals of each applicant’s case fundamentals of each applicant’s case

 Information is used to derive numerical estimates (the

Information is used to derive numerical estimates (the BUNNI) on the amount of methyl bromide the U.S. BUNNI) on the amount of methyl bromide the U.S. will nominate will nominate

 Present Nomination Range for Interagency Negotiation

Present Nomination Range for Interagency Negotiation

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Lesser Grain Borer

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MeBr CUE MeBr CUE – – U.S. Review Process Since 2001 U.S. Review Process Since 2001

 OAP

OAP

 Receives applications

Receives applications

 Allocation rule

Allocation rule

 OPP

OPP

 Technical & Economic assessment of need

Technical & Economic assessment of need

 Estimates amount to request

Estimates amount to request

 Provides technical support at International meetings

Provides technical support at International meetings

 USDA

USDA

 Reviews

Reviews

 Research

Research

 Universities

Universities

 Reviews

Reviews

 Research

Research

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U.S. MeBr CUE Program Timeline U.S. MeBr CUE Program Timeline

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Developing Countries end MeBr Consumption Drafting 2010 CUE Final Rule, Drafting 2011 CUE NPRM Developed Countries (including U.S.) end MeBr Consumption except for limited exemptions U.S. submits first MeBr CUE Nomination U.S. 2012 CUE Nomination Due 1/25/10

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Timeline of a Single CUE Allocation Timeline of a Single CUE Allocation

YEAR ONE (Three Years Prior to Allocation) YEAR ONE (Three Years Prior to Allocation)

1. 1.

OAR issues Federal Register notice inviting CUE applications (Spring) OAR issues Federal Register notice inviting CUE applications (Spring)

2. 2.

Applicants send in applications for critical use MeBr (Summer) Applicants send in applications for critical use MeBr (Summer)

3. 3.

OPP reviews applications, including quantities and any new research on OPP reviews applications, including quantities and any new research on alternatives (Fall) alternatives (Fall)

4. 4.

EPA, DOS, USDA, CEQ develop U.S. Critical Use Nomination document EPA, DOS, USDA, CEQ develop U.S. Critical Use Nomination document (Winter) (Winter) YEAR TWO (Two Years Prior to Allocation) YEAR TWO (Two Years Prior to Allocation)

1. 1.

DOS submits nomination to UNEP Ozone Secretariat (January) DOS submits nomination to UNEP Ozone Secretariat (January)

2. 2.

Montreal Protocol Methyl Bromide Technical Options Committee (MBTOC) Montreal Protocol Methyl Bromide Technical Options Committee (MBTOC) reviews developed country CUE Nominations and recommends amounts to the reviews developed country CUE Nominations and recommends amounts to the Parties (Summer) Parties (Summer)

3. 3.

At MOP, Parties At MOP, Parties authorize authorize CUE nomination amounts (Fall) CUE nomination amounts (Fall) YEAR THREE (One Year Prior to Allocation) YEAR THREE (One Year Prior to Allocation)

1. 1.

OAR publishes NPRM announcing OAR publishes NPRM announcing allocations allocations to sectors (Summer) to sectors (Summer)

2. 2.

OAR reviews comment and makes any needed changes (Fall) OAR reviews comment and makes any needed changes (Fall) YEAR FOUR (Year of Allocation) YEAR FOUR (Year of Allocation)

1. 1.

EPA publishes FRM (Spring) EPA publishes FRM (Spring)

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MeBr Critical Use Exemption Application 2002 Biological and Economic Review by OPP, USDA, & Universities

Initial Assessment of Alternatives by Review Panel Primary Biologist Review Fill in Analytical Database, write a brief summary of key issues Primary Economist Review Fill in Analytical Database, write a brief summary of key issues, include spreadsheet

• f analysis

Secondary Review Biologists and Economists review database information, key issues, spreadsheets Discussion and Evaluate on CUE Primary reviewers lead discussion, all reviewers vote Later review all crops within a group for consist analysis of issues 2nd Discussion and Evaluate if Disagreements Occur Individuals submit their concerns in writing, they are summarized and distributed to reviewers

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MeBr Critical Use Exemption Application 2009 Biological and Economic Review by OPP & USDA

Initial Assessment of Alternatives by Review Panel Primary Biologist Review Fill in Analytical Database, write a brief summary of key issues Primary Economist Review Fill in Analytical Database, write a brief summary of key issues, include spreadsheet

• f analysis

Discussion and Evaluate on CUE Primary reviewers lead discussion, all reviewers vote Later review all crops within a group for consist analysis of issues Discussions and Evaluate if Disagreements Occur

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Post Post-Harvest CUEs Harvest CUEs

 Post

Post-harvest applications received: harvest applications received:

 in 2001 for MeBr use in 2005: 18

in 2001 for MeBr use in 2005: 18

 in 2009 for MeBr use in 2012: 13

in 2009 for MeBr use in 2012: 13

 U.S. Post

U.S. Post-harvest nominated: harvest nominated:

 For 2005: 906,754 kg

For 2005: 906,754 kg

 For 2012: 161,301 kg

For 2012: 161,301 kg

 Percent of U.S. Nomination

Percent of U.S. Nomination

 in 2005 9% of nomination

in 2005 9% of nomination

 In 2012 14% of nomination

In 2012 14% of nomination

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Amount of Methyl Bromide to Amount of Methyl Bromide to Nominate Nominate

Technical Recommendation Technical Recommendation

 Developed by OPP

Developed by OPP

 Based on technical and economic feasibility of alternatives

Based on technical and economic feasibility of alternatives

 Technical feasibility of alternatives (e.g. efficacy and time lost)

Technical feasibility of alternatives (e.g. efficacy and time lost)

 Regulatory constraints on alternatives

Regulatory constraints on alternatives

 Loss as % gross revenue, loss as % net revenue, % profit loss

Loss as % gross revenue, loss as % net revenue, % profit loss

 2012 Nomination = 4.63% of 1991 baseline

2012 Nomination = 4.63% of 1991 baseline

 Nominated amount based on negotiations between EPA, State,

Nominated amount based on negotiations between EPA, State, and USDA and USDA

 Technical range is 6.45 to 4.54% of baseline

Technical range is 6.45 to 4.54% of baseline

 U.S. nomination has always fallen inside technical range

U.S. nomination has always fallen inside technical range

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Indianmeal Moth Adult

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Reduced MeBr CUE Based On Reduced MeBr CUE Based On

 Technical Reasons

Technical Reasons

 Alternatives

Alternatives - sulfuryl fluoride (Profume), phosphine, heat sulfuryl fluoride (Profume), phosphine, heat

 Better sanitation

Better sanitation

 Applicants do not reapply

Applicants do not reapply

 Economic Reasons

Economic Reasons

 Increased downtime

Increased downtime

 Net revenues by facility

Net revenues by facility

 Losses from pests can lead to lower production

Losses from pests can lead to lower production

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0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

2005 2006 2007 2008 2009 2010 2011 2012 Year Percent of 1991 Baseline

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Nominated Technical Range Approved by Parties

Methyl Bromide Nomination History Soil and Post-Harvest Uses

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Current Status of CUEs Current Status of CUEs

 2010 Final Rule

2010 Final Rule

 Allocates 11.7% of baseline

Allocates 11.7% of baseline

 Applies existing framework, but caps new production at 2009

Applies existing framework, but caps new production at 2009 amounts amounts

 Recently signed and should be published soon

Recently signed and should be published soon

 2011 Proposed Rule

2011 Proposed Rule

 Parties authorized 8.1% of baseline

Parties authorized 8.1% of baseline

 Drafting proposed rule implementing that authorization

Drafting proposed rule implementing that authorization

 2012 Critical Use Nomination

2012 Critical Use Nomination

 1,181 MT (4.6% of baseline)

1,181 MT (4.6% of baseline)

 Submitted in January 2010

Submitted in January 2010

 Currently addressing second round of MBTOC questions

Currently addressing second round of MBTOC questions

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Colwell Cook Colwell Cook 703 703-308 308-8146 8146 cook.colwell@epa.gov cook.colwell@epa.gov