Remarks
Daniel A. Reifsnyder
Deputy Assistant Secretary, Bureau of Oceans and International Environmental and Scientific Affairs
24th Meeting of the Parties to the Montreal Protocol on Substances that Deplete the Ozone Layer
Geneva, Switzerland
November 12, 2012


Thank you, Mr. Chair. We have made considerable progress in reducing our reliance on methyl bromide, and are now requesting less than 2% of our baseline level of consumption. This progress has been made through painstaking research and testing of new alternatives, different application methods, and changes to cropping systems. This progress has not been easy or inexpensive, but it has been worth the effort to get there.

U.S. agriculture is vital in providing our citizens with a diverse, nutritious, and affordable food supply and is a central pillar of our economy. We need to ensure the progress we are making does not impede our efforts to provide food to millions of people.

In this context, this year we are faced with a particular challenge with the withdrawal of iodomethane from the U.S. market. This represents the loss of a significant new alternative that was already reducing our reliance on methyl bromide. As we indicated at the Open-Ended Working Group (OEWG), losing this alternative is a substantial change, and it may require us to submit a supplemental CUE nomination for consideration next year to address its loss. We are also interested in exploring how Parties might be able to have MBTOC review their needs in the event of a loss of a key alternative.

We are still assessing the impacts of the loss of iodomethane, and will do so in a comprehensive manner. We reserve our right to submit a 2014 supplemental CUE because of the loss of iodomethane.

Turning to recommendations of the Methyl Bromide Technical Options Committee (MBTOC), we have two substantial concerns with its recommendations. First, MBTOC acknowledges there are no feasible alternatives for ham, but has nevertheless imposed cuts on our nomination. U.S. food safety regulations have zero tolerance for mites in this product, so reliable fumigation with the only available alternative is needed, and we do not agree with MBTOCs recommended cut to this nomination.

Similarly, we do not agree with MBTOC's recommendations regarding our California 2

strawberry nomination. The basis for MBTOC's cuts is unclear. For example, our nomination represents our most critical needs for those fields that have high pest pressures. There is no research to support the notion that organic production of strawberries in California on fields with high pest pressures is technically and economically feasible. Quite the contrary, it seems like a recipe for failure.

Similarly, fields with high pest pressures may need to use sufficiently high rates of alternatives that would cause our farmers to exceed regulatory constraints that are set by the State of California.

We therefore request that for both our artisanal ham and strawberry nominations the Parties approve the full amount of our nomination, and we are submitting a draft decision to this effect.

We intend to meet bilaterally with those MBTOC members here this week to discuss technical issues raised in its recommendations.

We appreciate MBTOC’s efforts in revising the MB CUE Handbook. We agree that the Handbook should be updated to reflect the decisions of the Parties, without interpretation. EX/MOP Decision I/4 allows MBTOC to make factual updates of the handbook incorporating the specific language of the decisions of the Parties. Otherwise, updates require approval from the Parties.

This is directly relevant to two issues of concern we have with the Handbook. First, MBTOC is altering the economic guidelines, which were carefully negotiated at an Extraordinary Meeting of the Parties. Those should not be interpreted by MBTOC. They should not be changed for the revised handbook. Second, we do not agree with language in the second paragraph on page 14 in Section 2.6.1 suggesting that MBTOC recommendations are made at the subcommittee level. While we fully agree that it is appropriate for MBTOC to bring together experts to review nominations in particular areas of expertise, MBTOC is one committee and ultimately needs to come to a recommendation of the full committee.

MBTOC has flagged that the dates for CUN submissions need to be updated to reflect the Article 5 schedule. We agree.

Thank you, Mr. Co-Chair.