Thank you Mr. Co-Chair. The Parties to the Montreal Protocol have committed to reducing the production and consumption of methyl bromide because it is a potent ozone depleting substance. The United States takes this commitment seriously, and has worked extremely hard to facilitate the adoption of feasible alternatives across all sectors that use methyl bromide.
We have made considerable progress in this regard. Our current critical use nomination is only 4.3 percent of our 1991 baseline. This is nearly a 90 percent decrease from our first exemption request for 2005. In only 8 years, we have completely eliminated nominating the use of methyl bromide in several sectors: turf, tobacco, and ginger. And in the sectors that are continuing to transition, we have seen a number of sub-sectors eliminate the critical use of methyl bromide, including: bakeries, dried beans, California peppers and tomatoes, vegetables in Michigan, and raspberry nurseries. We have also made significant progress in the areas of largest use of methyl bromide, with current critical use exemptions for tomatoes, peppers, cucurbits, eggplants, orchard replant, and commodities demonstrating more than a ten fold decrease over the last 6 years.
The development and adoption of alternatives to methyl bromide has been an important priority for the United States. Since 1995, we have spent about $300 million on research and development of alternatives to methyl bromide. Since 1994, the U.S. government has sponsored the Methyl Bromide Alternatives Outreach conference (MBAO) as an international forum for research on alternatives to methyl bromide.
While this progress makes clear the U.S. commitment to a responsible transition, by establishing the critical use exemption (CUE), the Parties to the Montreal Protocol recognized that eliminating the use of methyl bromide is difficult. In the United States, there are several areas where a complete elimination of methyl bromide has proved extremely challenging. In particular, California strawberry growers have faced an uphill battle in obtaining the tools they need to protect their crops. New pest problems have emerged and concerns over worker and community safety have led to state regulatory restrictions which impede the use of alternatives. Without the proper tools in their toolbox, growers in California continue to have a critical need for methyl bromide. At the same time, they are committing considerable resources toward transitioning to other alternatives.
In light of these constraints, we stand firmly by our CUE nomination for 2012. Each year we have made demonstrable progress toward reducing critical uses of methyl bromide. Yet, the reduced recommendations from the Methyl Bromide Technical Options Committee (MBTOC) are at odds with our domestic assessment of our methyl bromide needs. This gives rise to several concerns.
First, there is a critical need for transparency in the calculations on which MBTOC bases its recommendations. In a number of cases it has been difficult for us to understand the basis for MBTOC’s cuts, in particular in the post-harvest sectors. In other cases we have worked hard to provide additional data to MBTOC and have still been unable to understand the basis for its final recommendations.
Second, we believe that the process MBTOC follows for arriving at a recommendation should not only be transparent, but should be achieved through a robust consensus among all members of the committee. We are concerned at the continuing tendency in MBTOC to sometimes meet separately with regard to different uses.
Finally, we are particularly concerned with the use of a new economic feasibility threshold to determine when, in MBTOCs view, the adoption of alternatives should be considered. In our view, a 15 to 20 percent threshold for economic damage is arbitrary. Worse, the use of any such threshold seeks to impose a mechanistic approach to factors and circumstances that naturally vary from Party to Party where a more careful analysis is required. In our view, the approach followed here by MBTOC is not consistent with the annex to Decision XVI/4, which instructs MBTOC to consult with the Parties on the criteria of standard presumptions applied to their individual countries CUE nominations.
We appreciate the opportunity to raise these concerns and hope that we can reach a common understanding. As critical uses of methyl bromide continue to decline, it is important to our process that it remain transparent, fair, and responsive to the legitimate problems Parties face. At the same time we remain fully committed to making progress in reducing our reliance on methyl bromide, as we have demonstrated over the past 8 years. We look forward to working with you at this meeting to address methyl bromide.