Comment submitted by B. Gray

12/16/2009 To: J. Arling From: B. Gray Subject: Protection of Stratospheric Ozone: The 2010 Critical Use Exemption From the Phaseout of Methyl Bromide. Docket ID No. EPA-HQ-OAR-2009-0351. Federal Register: Nov. 23, 2009 (volume 74, number 224) I support the proposed changes to the critical use exemptions for methyl bromide for 2010 outlined in EPA–HQ–OAR–2009–0351. The changes seem quite reasonable as overall EPA is either reducing the total use of methyl bromide or does not allow it to change from the previous year, and certainly does not allow it to increase from the previous year, which makes sense due to the fact that there was a complete phaseout of the compound scheduled for 2005, which was obviously not met since critical use exemptions exist. I am in support of the fact that EPA is gradually suggesting and requiring certain producers to switch to viable substitutes such as iodomethane since the Methyl Bromide Technical Options Committee (MBTOC) has stated that this substitute is economically and technologically viable in certain situations. It is also understandable that growers in certain areas be allowed a critical use exemption for methyl bromide when there has been a limit placed on the use of certain substitutes such as 1,3-dichloropropene in California for strawberry growers. Also, it is quite favorable that EPA is getting rid of the section allowing ‘‘export to countries which do not allow the use of sulfuryl fluoride’’ since this section was mainly stemming from the fact that some countries were disallowing this substitute and have recently set maximum residue standards for sulfuryl fluoride for use as a substitute to methyl bromide. This is a step in the right direction because it promotes a phaseout of methyl bromide by other countries as well. More of this comment can be found in the attached document.