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 1
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 2
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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 4
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 2 - Methyl Brom ide listed as Ozone Depleting Substance 1 9 9 5 – Agreem ent to phase out MeBr by 2 0 1 0 in developed countries 1 9 9 7 – Exem ption process created 2 0 0 9 – CUE requests subm itted for 2 0 1 1 2 0 1 5 – Developing countries Phase out MeBr 5
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. 6
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 7
Lesser Grain Borer 8
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 9
U.S. MeBr CUE Program Timeline U.S. MeBr CUE Program Timeline U.S. submits first Drafting 2010 CUE Final Rule, MeBr CUE Drafting 2011 CUE NPRM Nomination 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Developing Developed Countries (including U.S. 2012 CUE Countries end U.S.) end MeBr Consumption Nomination Due MeBr except for limited exemptions 1/25/10 Consumption 10
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) OAR issues Federal Register notice inviting CUE applications (Spring) OAR issues Federal Register notice inviting CUE applications (Spring) 1. 1. Applicants send in applications for critical use MeBr (Summer) Applicants send in applications for critical use MeBr (Summer) 2. 2. OPP reviews applications, including quantities and any new research on OPP reviews applications, including quantities and any new research on 3. 3. alternatives (Fall) alternatives (Fall) EPA, DOS, USDA, CEQ develop U.S. Critical Use Nomination document EPA, DOS, USDA, CEQ develop U.S. Critical Use Nomination document 4. 4. (Winter) (Winter) YEAR TWO (Two Years Prior to Allocation) YEAR TWO (Two Years Prior to Allocation) DOS submits nomination to UNEP Ozone Secretariat (January) DOS submits nomination to UNEP Ozone Secretariat (January) 1. 1. Montreal Protocol Methyl Bromide Technical Options Committee (MBTOC) Montreal Protocol Methyl Bromide Technical Options Committee (MBTOC) 2. 2. reviews developed country CUE Nominations and recommends amounts to the reviews developed country CUE Nominations and recommends amounts to the Parties (Summer) Parties (Summer) At MOP, Parties authorize authorize CUE nomination amounts (Fall) At MOP, Parties CUE nomination amounts (Fall) 3. 3. YEAR THREE (One Year Prior to Allocation) YEAR THREE (One Year Prior to Allocation) OAR publishes NPRM announcing OAR publishes NPRM announcing allocations allocations to sectors (Summer) to sectors (Summer) 1. 1. OAR reviews comment and makes any needed changes (Fall) OAR reviews comment and makes any needed changes (Fall) 2. 2. YEAR FOUR (Year of Allocation) YEAR FOUR (Year of Allocation) EPA publishes FRM (Spring) EPA publishes FRM (Spring) 1. 1. 11
MeBr Critical Use Exemption Application 2002 Biological and Economic Review by OPP, USDA, & Universities Initial Assessment of Alternatives by Review Panel Primary Economist Review Primary Biologist Review Fill in Analytical Database, write a brief Fill in Analytical Database, write a brief summary of key issues, include spreadsheet summary of key issues of 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 2 nd Discussion and Evaluate if Disagreements Occur Individuals submit their concerns in writing, they are summarized and distributed to reviewers 12
MeBr Critical Use Exemption Application 2009 Biological and Economic Review by OPP & USDA Initial Assessment of Alternatives by Review Panel Primary Economist Review Primary Biologist Review Fill in Analytical Database, write a brief Fill in Analytical Database, write a brief summary of key issues, include spreadsheet summary of key issues of 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 13
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 14
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