U.
S.
A.
CUN2003/
050
­
EGGPLANT­
FIELD
EGGPLANT
GROWN
OUTDOORS
ON
PLASTIC
MULCH
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide...............................................................................................
2
Economic
Impact
........................................................................................................................
2
Response
to
Questions
From
MBTOC/
TEAP..............................................................................
2
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates
............................................
10
Virtually
Impermeable
Film
(
VIF)
Tarps
..................................................................................
10
Market
Window
Information.....................................................................................................
11
Definitions
................................................................................................................................
13
References
................................................................................................................................
14
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
...........................................
2
Table
2.
Methyl
Bromide
Alternatives
in
a
Bell
Pepper
Squash
Rotation
in
1998­
99..................
4
Table
3.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
(
Locascio
et
al.
1997).
.........................................................................................................................
5
Table
4.
Historical
Use
of
Methyl
Bromide
in
the
Eggplant
Sector.............................................
7
Table
5.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Eggplant
Sector........
7
Table
6.
Herbicides
Registered
in
the
United
States
in
Eggplant..................................................
9
Page
2
INTRODUCTION
The
U.
S
nomination
for
methyl
bromide
(
MB)
for
use
on
eggplant
is
a
critical
need
only
for
an
amount
of
MB
associated
with
moderate
to
severe
pest
pressure,
because
there
are
no
feasible
alternatives
for
such
areas
(
see
Table
1).
The
nomination
notes
that
progress
has
been
made
in
adopting
emission
reduction
technologies
and
changing
formulations
and
application
rates
to
reduce
MB
dosage
rates
to
some
of
the
lowest
in
the
world,
and
that
further
trials
are
being
conducted
to
test
ways
of
overcoming
constraints
in
further
lowering
MB
formulations
and
adopting
tarps
with
higher
gas
impermeability
values.

CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE.

Region
Key
Pests
Critical
Need
for
MB
Georgia
Fruit
and
Vegetable
Growers
Association
 
Eggplant
(
CUE
02­
0050)

Florida
Fruit
and
Vegetable
Association
 
Eggplant
(
CUE
02­
0054)
Weeds:
The
weeds
yellow
nutsedge
(
Cyperus
esculentum),
and
purple
nutsedge
(
C.
rotundus),
root
damaging
nematodes
(
many
species)

Diseases:
Soil
inhabiting
fungal
pathogens
(
Phytophthora
capsici,
Rhizoctonia
spp.,
Pythium
spp,
and
Sclerotium
rolfsii
At
moderate
to
severe
pest
pressure
only
MB
can
currently
provide
effective
and
reliable
control
in
these
regions.
In
some
areas
the
use
of
alternatives
is
limited
due
to
a
number
of
factors,
including
inappropriate
soil
characteristics
(
e.
g.
karst
topography,
which
increases
the
chance
of
ground
water
contamination)
and
regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures.
MB
applications
in
eggplants
are
typically
made
using
a
67:
33
mixture
with
chloropicrin
under
plastic.

ECONOMIC
IMPACT
None
of
the
alternatives
were
considered
technically
feasible;
therefore
no
economic
analysis
was
conducted.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
Provide
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount.

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
5.

The
methodology
used
by
the
U.
S.
carefully
scrutinized
applications
from
the
user
community
and
took
out
(
1)
double
counting;
(
2)
any
requested
growth
beyond
historical
acreage
planted,
and
(
3)
requested
amounts
that
fall
under
QPS.
Furthermore,
the
USA
adjusted
the
requests
from
the
user
community,
when
they
had
not
already
done
so,
to
change
the
amount
of
methyl
bromide
nominated
to
account
for
(
1)
only
the
area
where
pest
pressure
cannot
be
controlled
by
alternatives,
(
2)
the
area
where
regulatory
Page
3
constraints
limit
adoption
of
alternatives,
such
as
buffers
near
inhabited
areas,
and
(
3)
the
area
where
soil/
geological
features
limit
use
of
alternatives,
such
as
groundwater
contamination
in
areas
with
karst
topography.
The
nominated
amount
incorporates
minimum
efficacious
use
rates,
mixtures
of
methyl
bromide
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.

2.
List
the
registration
status
of
herbicides
for
this
crop
and
provide
data
on
why
these
are
not
suitable
for
nutgrass
control
(
the
main
reason
why
MB
is
used
in
southeastern
USA).

A
list
of
herbicides
with
activity
against
nutsedge
species,
which
are
currently
registered
for
eggplants
in
the
United
States,
is
provided
in
Table
6.
Herbicides
not
currently
registered
for
eggplant,
but
which
have
shown
some
activity
against
nutsedge
in
vegetables,
are
also
listed.
None
of
the
herbicides
in
Table
6
provide
adequate
control
of
nutsedge
in
areas
of
moderate
to
severe
pest
pressure.

3.
As
the
CUN
specifically
requests
MB
for
areas
where
nutgrass
exists
in
heavy
infestations,
the
Party
is
requested
to
clarify
the
exact
amount
of
MB
required
for
this
use
and
to
validate
the
amount
of
MB
required
for
those
areas
where
1,3­
D
is
not
available
through
local
restrictions
(
e.
g.,
township
caps,
Karst
topography).

The
CUN
is
meant
to
cover
areas
where
nutgrass
exists
in
moderate
to
severe
infestations
and/
or
where
1,3­
D
is
not
available
due
to
local
restrictions
and
soil
characteristics.
The
amounts
for
these
uses
are
noted
in
Table
5
and
followed
by
an
explanatory
note.

4.
It
is
also
requested
that
the
Party
consider
recalculating
the
quantity
nominated,
consistent
with
the
use
of
emission
control
technologies
coupled
with
minimizing
MB
dosages,
such
as
when
applied
in
conjunction
with
chloropicrin
where
feasible.

The
U.
S.
nomination
considered
the
historical
efforts
to
reduce
emissions
and
to
reduce
MB
dosages
described
in
the
section
below
titled,
"
Historical
Emission
Reductions
&
MB
Dosage
Rates."
This
section
demonstrates
notable
success
in
the
United
States
at
efficiently
using
MB
at
low
dosages
with
emission
control
technologies
to
control
key
pests.
As
the
2002
MBTOC
report
states,
"
in
some
countries
(
e.
g.,
the
U.
S.)
the
potential
for
reducing
MB
dosages
for
soil
fumigation
compared
to
many
other
countries
will
be
less
because
dosages
are
already
low."
The
U.
S.
nomination
already
assumes
reductions
in
use
rates
that
are
12­
16%
lower
than
2001
use
rates.
Because
the
original
U.
S.
nomination
for
eggplant
already
accounted
for
the
use
of
emission
control
technologies
and
minimizing
MB
dosages
to
15
­
16g/
m2,
no
recalculation
in
the
nomination
was
needed.

5.
The
nomination
did
not
give
comparative
data,
except
some
yields,
to
determine
the
technical
feasibility
of
many
alternatives
and
their
comparative
performance
compared
to
MB
under
the
circumstances
of
the
nomination.

A
bell
pepper­
squash
rotation
field
study
with
chisel
injected
applications
of
1,3­
D
+
chloropicrin
resulted
in
yield
losses
ranging
up
to
40
percent
compared
to
MeBr
(
see
Page
4
Table
2
below).
Further,
by
the
end
of
the
season,
only
MeBr
treatments
effectively
controlled
nutsedge
(
Webster
et
al.,
2001).
Interviews
with
growers
indicated
pepper
yield
losses
of
10
to
20
percent,
and
increases
of
nutsedge
and
nightshade
populations
of
approximately
30
percent
with
1,3­
D
treatments
compared
to
MB.
Another
field
study
on
tomatoes
(
see
Table
3
below)
with
high
nutsedge
pressure
(
300
plants/
m
²
for
the
nontreated
control)
showed
that
yield
losses
of
30
percent
could
be
expected
with
1,3­
D
+
17
%
chloropicrin
as
compared
to
MB
+
chloropicrin
(
67%:
33%).
Nutsedge
populations
were
also
significantly
higher
for
1,3­
D
+
chloropicrin
(
340
nutsedge
plants/
m
²
)
,
as
compared
to
MB
+
chloropicrin
(
90
nutsedge
plants/
m
²
)
.
It
should
be
noted
that
this
study
also
contained
a
treatment
with
1,3­
D
+
chloropicrin
+
Pebulate
(
an
herbicide
that
is
no
longer
registered
in
the
U.
S.),
and
that
the
results
were
not
significantly
different
from
MB
+
chloropicrin,
indicating
that
1,3­
D
+
chloropicrin
may
be
feasible
once
a
suitable
herbicide
alternative
is
found
and
registered
on
the
affected
crops
(
Locasio
et
al.,
1997).

Research
was
conducted
in
Florida
on
tomatoes
comparing
solarization
to
MB
and
1,3­
D
+
chloropicrin
+
Pebulate
(
Gilreath
et
al.,
2001).
In
the
original
research
report
on
tomatoes
there
is
no
quantitative
description
of
the
pest
pressure
other
than
to
say
there
was
a
"
low
population
of
root
knot
nematodes".
Based
on
additional
descriptions
of
the
pest
pressure
in
the
report
this
would
potentially
qualify
as
what
the
United
States
considers
a
low
level
of
pest
pressure
where
the
use
of
MB
would
not
be
recommended.

The
study
shown
in
Table
2
demonstrates
an
enhanced
yield
(
33%
higher)
to
a
95
%
yield
loss
when
comparing
methyl
bromide
to
Telone
+
C­
35.
This
test
illustrates
the
influence
of
pepper
cultivar
on
the
interaction
between
nutsedge
and
pepper
plants
and
possibly
disease
or
nematode
resistance
on
plant
productivity.
It
also
demonstrates
the
wide
variability
seen
with
field
studies
comparing
soil
fumigants.

TABLE
2.
METHYL
BROMIDE
ALTERNATIVES
IN
A
BELL
PEPPER
SQUASH
ROTATION
IN
1998­
99
(
Webster
et
al.,
2001).

Chemicals
Rate
(
kg
ai/
ha)
Nutsedge
(#/
plot)
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Plants
through
plastic
Plants
through
crop
hole
Cultivar
A
Cultivar
B
Cultivar
A
Cultivar
B
Nontreated
64
10
0.4
c
0.3
c
93.1%
95.7%

MeBr
440
0
0
5.7
b
7.6
a
­
­

Telone
+
C
35
(
chisel)
146
+
83
2
1
8.6
a
4.6
b
(
33.3%)
39.3%

Telone
+
C
35
(
drip)
146
+
83
40
8
1.6
c
0.4
c
72%
95.4%

Notes:
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability.
Nutsedge
notes:
Low
population
of
nutsedge
(
plot
size
=
27.4
m
²
)
.
First
number
for
weed
density
is
number
of
nutsedge
plants
growing
through
the
plastic.
The
second
nutsedge
number
is
for
the
number
of
plants
through
the
crop
hole.
Page
5
TABLE
3.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.,
1997).

Chemicals
Rate
(/
ha)
Nutsedge
(#/
m2)
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Nontreated
­
300
a­
c
20.1
f
59.1%

MB
+
Pic
67­
33
390
kg
90
e
49.1
a
­

Telone
+
Pic
(
C­
17)
327
L
340
a
34.6
bc
29.5%

Telone
+
Pic
(
C­
17)
+
Peb*
327
L
+
4.5
kg
150
de
42.5
ab
13.4%

Notes:
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability.

6.
The
nomination
does
not
discuss
key
alternatives
reported
by
MBTOC.

The
nomination
did
address
the
full
list
of
key
alternatives
that
MBTOC
had
provided
at
the
time
of
writing
(
in
December
2002
 
please
see
pages
7­
8
of
the
original
application).
Economic
feasibility
was
not
assessed
since
no
alternative
was
found
to
be
technically
feasible.
A
brief
synopsis
of
the
detailed
discussion
of
the
technical
feasibility
of
each
MBTOC
listed
alternative,
which
was
included
in
the
nomination,
follows
below.
Relevant
references
can
be
found
in
the
corresponding
sections
of
the
nomination.

Solarization
Solarization
is
a
weather
sensitive
process
that
requires
ideal
soil
moisture
and
sunlight
conditions.
This
treatment
is
most
successful
in
regions
with
continuous
high
temperature
periods
during
summer.
Temperatures
of
65
degrees
C
for
30
minutes
will
control
many
soil­
borne
fungi,
nematodes
and
weeds,
with
the
exception
of
Cyperus
species.
Response
of
Cyperus
species
to
solarization
is
not
well
understood.
Field
studies
indicate
that
raising
and
maintaining
soil
temperatures
throughout
the
soil
profile
to
levels
shown
to
control
nutsedge
is
extremely
difficult.
Nutsedges
have
shown
ability
to
emerge
from
deep
in
the
soil
profile
and
to
re­
invade
from
areas
outside
the
solarization
zone,
so
solarization
alone
will
not
be
an
effective
and
dependable
control
method
for
nutsedge.
Furthermore,
solarization
treatments
will
take
fields
out
of
production
since
solarization
would
be
conducted
during
the
spring
and
into
the
summer
months,
which
are
optimal
for
eggplant
production
in
the
USA.

Solarization/
Fungicides
Fungicides
are
not
effective
for
control
of
weeds
and
nematodes;
therefore,
their
use
in
combination
with
solarization
is
no
more
efficacious
than
solarization
alone.

Flooding
and
Water
Management
Flooding
is
not
a
technically
feasible
alternative
to
MB
for
several
reasons.
First,
eggplant
requires
well
drained,
sandy
loam
soil
and
so
planting
beds
must
be
designed
to
provide
good
drainage.
Also,
flooding
does
not
provide
adequate
control
of
the
total
pest
complex
affecting
USA
eggplants,
particularly
nematodes
and
nutsedge.
Cyperus
species
have
shown
tolerance
to
flooding.
In
one
study,
submergence
of
nutsedge
tubers
for
periods
of
8
days
to
4
weeks
had
no
effect
on
the
sprouting
capabilities
of
the
tubers.
Studies
in
Florida
showed
ineffective
nematode,
disease,
and
nutsedge
control
in
vegetable
crops.
Additionally,
federal
and
state
water
management
regulations,
land
Page
6
configuration,
the
frequency
and
severity
of
droughts,
and
the
economics
of
developing
and
managing
flood
capabilities
all
contribute
to
the
technical
infeasibility
of
using
flooding
as
a
pest
management
tool
in
U.
S.
eggplants.

Grafting/
Resistant
Rootstock/
Plant
Breeding
Grafting,
resistant
rootstock
and
plant
breeding
are
not
adequate
replacements
for
MB
use
on
the
pest
complex
in
eggplant.
Resistant
rootstock
and
plant
breeding
are
primarily
developed
for
nematode
control
and
disease
management.
However,
there
is
no
evidence
that
they
can
be
used
successfully
against
weed
competition.
Grafting
has
shown
some
promise
against
Fusarium
diseases
in
other
crops
(
though
not
eggplant)
(
Miguel
2002),
but
EPA
has
no
evidence
that
it
counteracts
the
effects
of
weeds,
nematodes,
or
the
fungal
pathogens
cited
as
key
pests
in
this
nomination.
Plant
breeding
may
be
adapted
for
the
management
of
soil­
borne
diseases
as
part
of
an
IPM
program,
though
this
has
not
been
fully
developed
for
USA
eggplants
yet.
Furthermore,
EPA
has
found
no
evidence
that
this
alternative
is
applicable
to
nutsedge
control
in
eggplants.

Organic
Amendments/
Compost
The
use
of
compost
as
a
pest
control
tool
is
still
new
and
not
clearly
understood
for
eggplants.
Available
data
suggest
that
the
use
of
compost
is
a
viable
alternative
for
suppression
of
some
diseases,
especially
when
used
with
IPM.
However,
results
are
inconsistent
and
therefore
this
cannot
yet
be
considered
a
stand­
alone
alternative
to
MB
for
solanaceous
crop
production.
Furthermore,
organic
amendments
and
compost
do
not
control
nutsedge.

Resistant
Cultivars
Resistant
cultivars
are
not
technically
feasible
as
a
single
replacement
for
MB.
Resistant
cultivars
provide
little
control
against
weed
pressures
in
general
and
nutsedge
in
particular.
While
the
use
of
resistant
cultivars
as
an
alternative
to
MB
is
potentially
suited
for
the
management
of
soil­
borne
diseases
as
part
of
an
IPM
program,
this
has
not
been
developed
for
eggplant
crops
as
yet.
It
is
also
important
to
note
that
there
are
no
eggplant
cultivars
identified
with
resistance
to
Phytophthora
and
Meloidogyne
pathogens.

Substrates
and
Plug
Transplants
Substrates
(
alternative
growth
media)
and
plug
transplants
(
small
plugs
of
soil
containing
seedlings)
are
also
not
technically
feasible
as
stand­
alone
replacements
for
MB.
Plug
transplants
are
already
extensively
used
on
high
value
vegetable
crops
like
eggplants.
However,
even
with
plug
transplants
pre­
fumigation
with
MB
is
still
necessary
to
provide
control
of
the
pest
complex
in
the
US.
Plug
transplants
do
not
control
nutsedge.
Even
when
amended
with
biological
control
organisms,
substrates
and
plug
transplants
provide
limited
disease
resistance
and
control,
due
to
the
species­
specific
nature
of
the
beneficial
microorganisms
involved,
and
the
heterogeneous
distribution
of
pathogens
in
soils.
Page
7
TABLE
4.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
EGGPLANT
SECTOR*.

Historical
Use
Average
Use
Rates
(
kg/
ha)
Total
Amount
(
kg)
Area
Treated
(
ha)

1997
208
233,647
1,256
1998
208
191,131
1,058
1999
174
175,107
1,060
2000
156
165,891
1,061
2001
178
198,281
1,054
*
Acres
planted
in
U.
S.:
5,830
(
2,359
ha).
Percent
of
U.
S.
eggplant
acreage
requested:
45%
Source:
Rates,
amounts,
and
area
treated
are
from
applicant's
information.
Percent
of
U.
S.
acreage
is
from
USDA,
2001.
National
Agricultural
Statistics
Service,
Agricultural
Statistics
2001
TABLE
5.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
EGGPLANT
SECTOR
Calculation
of
Nominated
Amount
0050
 
Georgia
Fruit
and
Vegetable
Growers
Association
 
Eggplant
0054
 
Florida
Fruit
and
Vegetable
Growers
Association
 
Eggplant
Hectares
(
ha)
325
728
%
of
Regional
hectares
(
ha)(
A)
65
113
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
48,868
114,305
Double
Counted
hectares
(
ha)(
B)
 
 
Growth
/
Increasing
Production
hectares
(
ha)(
C)
 
 
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
 
 
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
325
728
Key
Pest
Impacts
(%)(
F)
30
30
Regulatory
Impacts
(%)(
G)
0
1
Soil
Impacts
(%)(
H)
0
40
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
30
50
Qualifying
Area
(
ha)(
J)
98
364
Use
Rate
(
kg/
ha)(
K)
150
157
CUE
Amount
Nominated
(
kg)(
L)
14,660
57,152
%
Reduction
from
Initial
Request
(
M)
70
50
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
71,812
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
73,565
Page
8
Footnotes
for
Table
5:

Values
may
not
sum
exactly
due
to
rounding.

A.
Percent
of
regional
hectares
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
B.
Double
counted
hectares
is
the
area
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
MB.
There
was
no
double
counting
in
this
sector.
C.
Growth
/
increasing
production
acreage
is
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated
or
treated
at
a
higher
use
rate.
Values
in
parentheses
indicate
negative
values.
No
growth
was
requested.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
None
of
the
amount
requested
was
for
quarantine
or
pre­
shipment
purposes.
E.
Adjusted
hectares
requested
is
the
hectares
in
the
applicant's
request
minus
the
acreage
affected
by
double
counting,
growth
/
increasing
production,
and
quarantine
and
pre­
shipment.
F.
Key
pest
impacts
are
the
percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
both
Georgia
and
Florida
nutsedge
is
the
key
pest.
G.
Regulatory
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
An
estimated
1%
of
the
acreage
devoted
to
eggplant
production
is
impacted
by
a
buffer
requirement
of
30
meters
to
inhabited
structures.
H.
Soil
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance).
An
estimated
40%
of
the
eggplant
growing
regions
in
Florida
has
Karst
topography
and
the
use
of
1,3­
D
is
not
allowed
due
to
groundwater
impacts.
I.
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
or
soil
impacts.
In
each
case
the
total
area
impacted
is
the
area,
which
is
impacted
by
one
or
more
of
the
individual
impacts.
For
each
application
the
assessment
was
made
by
biologists
familiar
with
the
specific
situation
and
able
to
make
judgments
about
the
extent
of
overlap
of
the
impacts.
For
example,
in
some
situations
the
impacts
are
mutually
exclusive
 
in
heavy
clay
soils
1,3D
will
not
be
effective
because
it
does
not
penetrate
these
soils
evenly,
but
none
of
the
heavy
soil
areas
will
be
impacted
by
township
(
regulatory)
caps
because
no
one
will
use
1,3D
in
this
situation,
so
this
soils
impact
must
be
added
to
the
township
cap
regulatory
impact
in
a
California
application.
In
other
words
there
is
no
overlap.
In
other
situations
one
area
of
impact
might
be
a
subset
of
another
impact.
In
these
cases,
the
combined
impact
is
equal
to
the
largest
individual
impact.
J.
Qualifying
area
is
calculated
by
multiplying
the
adjusted
hectares
requested
by
the
total
combined
impacts.
K.
Use
rate
is
the
requested
use
rate
for
2005.
This
rate
may
be
adjusted
downward
based
on
historical
use
patterns.
L.
CUE
amount
nominated
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
M.
Percent
Reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
N.
Sum
of
all
CUE
nominations
in
sector.
Self­
explanatory.
O.
Multiplier
for
margin
of
error.
This
amount
is
one
percentage
point
of
the
original
(
1991)
baseline
amount.
This
factor
is
intended
to
compensate
for
the
compounding
influence
of
using
the
low
end
of
the
range
for
all
input
parameters
in
the
calculation
of
the
US
nomination
(
i.
e.,
using
the
lowest
percent
impact
on
the
lowest
number
of
acres
at
the
lowest
dosage
is
likely
to
result
in
values
that
are
unrealistically
too
small).
The
U.
S.
nominated
included
some
sectors
for
100%
of
the
amount
requested,
therefore
the
portion
of
the
multiplier
from
these
sectors
were
added
equally
across
all
other
sectors
resulting
in
a
final
multiplier
of
1.0244,
or
a
2.44%
increase
from
the
calculated
amount,
to
these
remaining
sectors.
P.
Total
U.
S.
sector
nomination
is
calculated
by
multiplying
the
summed
sector
nominations
by
the
margin
of
error
multiplier.
Page
9
TABLE
6.
HERBICIDES
REGISTERED
IN
THE
UNITED
STATES
IN
EGGPLANT.

Herbicide
U.
S.
Registration
Status*
Major
Comments
Halosulfuron­
methyl
Yes
Potential
crop
injury;
plant
back
restrictions
(
see
notes
below)

Pebulate
No
Was
registered
for
use
in
tomatoes
but
registration
lapsed
December
31,
2002
(
registrant
corporation
went
out
of
business)

S­
metolachlor
No
Registered
ONLY
in
tomatoes;
does
not
control
purple
nutsedge
Glyphosate
Yes
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Paraquat
Yes
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Terbacil
No
Registered
ONLY
in
strawberries;
rotation
restrictions
Rimsulfuron
No
Registered
ONLY
in
tomatoes;
rotational
restrictions
Trifloxysulfuron
No
Registration
pending
ONLY
in
tomatoes
*
Yes
=
Registered
for
use;
No
=
Not
registered
for
use
Additional
notes
on
specific
herbicides
listed:
Halosulfuron­
methyl
In
December
2002,
halosulfuron­
methyl
(
Sandea
®
)
was
registered
to
control
nutsedge
in
tomatoes,
peppers,
eggplant,
and
cucurbits.
This
recent
registration
was
not
on
the
list
of
alternatives
from
MBTOC.
There
are
several
limitations
to
halosulfuron
which,
when
combined,
may
limit
its
technical
feasibility
and
adoption
by
growers
in
the
United
States.
Given
these
limitations,
several
years
will
be
needed
to
see
if
it
can
be
adopted
for
even
a
portion
of
the
US
request.
Limitations
include:
°
Excessive
amounts
of
water
(
greater
than
1
inch)
soon
after
a
pre­
emergent
application
may
cause
crop
injury.
Rainfall
within
four
hours
after
a
post­
emergence
application
may
reduce
effectiveness.
Sudden
storms
with
greater
than
1
inch
of
rainfall
are
not
uncommon,
especially
in
the
southeastern
United
States.
°
Not
all
hybrids/
varieties
have
been
tested
for
sensitivity
to
halosulfuron­
methyl.
Halosulfuron
may
also
delay
maturity
of
treated
crops.
°
This
herbicide
has
plant
back
restrictions
from
0
to
36
months.
Many
of
the
vegetable
crops
fall
within
the
4
to
12
month
range,
although
some
are
longer.
°
Halosulfuron
should
not
be
applied
if
the
crop
or
target
weeds
are
under
stress
due
to
drought,
water
saturated
soils,
low
fertility,
or
other
poor
growing
conditions.
°
This
herbicide
cannot
be
applied
to
crops
treated
with
soil
applied
organophosphate
insecticides.
Foliar
applications
of
organophosphate
insecticides
may
not
be
made
within
21
days
before
or
7
days
after
halosulfuron
application.
Note:
All
the
limitations
above
are
listed
in
the
US
registration
label
for
halosulfuron,
which
in
turn
is
based
on
proprietary
data
submitted
to
EPA
by
the
registrant
company.
Glyphosate
Glyphosate
is
a
non­
selective
herbicide
that
only
suppresses,
but
does
not
control,
nutsedge
development.
Additionally,
glyphosate
provides
no
residual
(
long­
term)
weed
control.
Glyphosate
may
be
applied
prior
to
planting
or
ONLY
between
vegetable
rows.
Contact
of
glyphosate
with
the
crop
will
likely
cause
severe
injury.
Row
middle
application
use
is
limited
because
of
the
potential
of
glyphosate
drift
to
the
crop
causing
severe
injury.
Paraquat
Paraquat
is
a
non­
selective
herbicide
that
provides
poor
control
of
nutsedge.
Additionally,
paraquat
does
not
provide
residual
weed
control.
Paraquat
may
be
applied
prior
to
planting
or
ONLY
between
vegetable
rows.
Contact
of
paraquat
with
the
crop
can
cause
severe
injury.
Page
10
HISTORICAL
EMISSION
REDUCTIONS
&
METHYL
BROMIDE
DOSAGE
RATES
In
Georgia,
data
was
gathered
on
the
MB
dosage
rate
under
tarped
beds
since
1992.
In
1992,
the
MB
dosage
rate
below
tarped
beds
was
34
g/
m2.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
15
g/
m2.
All
areas
growing
fresh
vegetables
in
the
Georgia
inject
MB+
Pic
formulation
approximately
30
centimeters
below
the
surface
of
the
tarped
bed.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
to
a
67:
33
formulation,
but
also
was
accomplished
through
a
reduction
in
application
rates
since
1992.

In
the
Florida,
the
MB
dosage
rate
under
tarped
beds
in
1997
was
22
g/
m2.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
16
g/
m2.
All
areas
in
the
Florida
inject
MB+
Pic
formulation
31
 
46
centimeters
below
the
soil
surface
and
beds
are
built
above
the
soil
surface
and
tarped,
so
the
formulation
is
injected
46
 
61
centimeters
below
the
surface
of
the
tarped
bed.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
formulation
to
a
67:
33
formulation,
but
is
also
due
to
a
reduction
in
application
rates.

VIRTUALLY
IMPERMEABLE
FILM
(
VIF)
TARPS
Although
many
sectors
are
continuing
to
test
VIF
tarps
in
trials
throughout
the
country,
at
this
time
VIF
tarps
are
generally
not
technically
and
economically
feasible
for
the
following
reasons
(
U.
S.
EPA,
January
26,
1998):

Disposal
Issues

Landfill
disposal
of
VIF
and
VIF
burning
have
come
under
increasing
restrictions
in
some
jurisdictions
(
e.
g.,
California,
Department
of
Pesticide
Regulation,
00­
001;
Florida
 
62­
256.300
F.
A.
C.)


Landfill
and
other
disposal
methods
are
labor­
intensive
and
costly.


Ingredients
in
VIF
limit
recycling
into
end­
use
products.

Cost

Average
cost
of
VIF
tarps
is
$
580/
acre,
whereas
average
cost
of
low­
density
polyethylene
(
LDPE)
tarps
is
$
275/
acre,
and
high­
density
polyethylene
(
HDPE)
tarps
is
$
393/
acre.


Farmers
in
some
regions
report
VIF
tarp
removal
and
disposal
costs
of
more
than
$
240
per
acre
compared
to
removal
and
disposal
costs
of
approximately
$
60
per
acre
for
tarps
used
in
flat
fumigation.

Environmental
Consequences

Inorganic
bromide
residues
in
soil
are
higher
when
VIF
tarps
are
used;
further,
the
hydrolysis
of
MB
in
water
may
result
in
the
accumulation
of
bromide
ions,
thus
increasing
the
chances
for
groundwater
contamination.


Evidence
suggests
that
VIF
tarping
could
actually
lead
to
increased
levels
of
emissions
when
the
tarps
are
removed,
thus
increasing
exposure
to
workers
and
nearby
structures.

VIF
Supply
&
Demand
Logistics

VIF
tarps
are
currently
manufactured
only
in
Europe,
and
current
VIF
tarp
production
capacity
in
Europe
is
not
high
enough
to
meet
U.
S.
demands.


VIF
tarps
manufactured
in
Europe
do
not
meet
U.
S.
application
size
and
criteria.
Page
11

European
firms
are
unlikely
to
make
the
investment
necessary
to
ensure
a
viable
supply
of
adequate
VIF
tarps
to
U.
S.
farmers
before
the
2005
phase
out
date.

VIF
Challenges
to
Agricultural
Practices

A
glue
to
join
sheets
of
VIF
is
still
not
available.


Increasing
cover
times
with
VIF
to
between
10­
20
days
can
disrupt
double­
cropping
schedules
and
cause
growers
to
miss
optimum
marketing
windows.


Photo­
degradation
of
VIF
makes
it
brittle
and
ineffective
at
controlling
weeds
over
months
of
double
cropping
systems
(
current
non­
VIF
tarps
remain
on
beds
for
12­
15
months
after
one
MB
fumigation).

MARKET
WINDOW
INFORMATION
The
series
below
indicate
the
importance
of
considering
market
windows,
and
the
concomitant
large
difference
in
prices
that
accompany
them,
when
deciding
if
alternatives
to
methyl
bromide
are
economically
feasible.
Although
such
detailed
series
are
not
available
for
all
crops,
both
tomatoes
and
strawberries
demonstrate
large
fluctuations
in
prices
over
three
week
intervals
from
peak
price
to
the
midseason
price.
This
pattern
is
also
observable
for
other
fresh
fruit
and
vegetable
crops,
and
it
is
likely
to
prevail
for
eggplant.

Prices
received
by
strawberry
growers
rapidly
decline
from
their
early
season
peak.
The
average
price
received
by
Florida
Strawberry
growers
dropped
30%
between
February
and
March
in
1999,
37%
in
2000,
and
40%
in
2001.
In
California
strawberry
prices
declined
in
this
time
period
19%
in
1999,
29%
in
2000,
and
23%
in
2001.

The
existence
of
these
sharp
declines
in
prices
which
occur
after
a
short
period
of
high
prices
(
a
period
know
as
`
the
market
window')
ensure
that
revenue
losses
caused
by
the
longer
plant­
back
periods
required
when
using
certain
alternatives
will
not
be
proportional
to
the
lost
production
time
but
will,
rather,
be
amplified
by
the
lower
commodity
price
of
the
post­`
market
window'.
The
result
is
a
decline
in
crop
revenue,
which
in
the
case
of
Florida
strawberries
would
be
approximately
40%
of
gross
revenue
apart
from
any
losses
due
to
reduced
production.

Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
01
Feb­
01
Mar­
01
Apr­
01
May­
01
Jun­
01
Jul­
01
Aug­
01
Sep­
01
Oct­
01
Nov­
01
Dec­
01
FL
CA
Page
12
Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
1999
­
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
99
Mar­
99
May­
99
Jul­
99
Sep­
99
Nov­
99
Jan­
00
Mar­
00
May­
00
Jul­
00
Sep­
00
Nov­
00
Jan­
01
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
Though
the
pattern
is
not
as
well
defined,
prices
for
eggplant
follow
a
similar
cycle.
Three
weeks
is
the
added
plant­
back
time
required
when
using
1,3­
D
or
chloropicrin.
When
using
MITC
generators,
recommended
plant­
back
can
increase
to
six
weeks.

Fresh
tomatoes,
prices
received
per
cwt,
monthly,
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
10.00
$
20.00
$
30.00
$
40.00
$
50.00
$
60.00
Jan­
01
Feb­
01
Mar­
01
Apr­
01
May­
01
Jun­
01
Jul­
01
Aug­
01
Sep­
01
Oct­
01
Nov­
01
Dec­
01
FL
CA
Fresh
tomatoes,
prices
received
per
cwt,
monthly,
1999
­
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
10.00
$
20.00
$
30.00
$
40.00
$
50.00
$
60.00
Jan
­
99
Mar­
99
May­
99
Jul­
99
Sep­
99
Nov­
99
Jan­
00
Mar­
00
May­
00
Jul­
00
Sep
­
00
Nov­
00
Jan
­
01
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
Page
13
DEFINITIONS
THAT
MAY
BE
RELEVANT
TO
THIS
CUN
Source
of
yield
loss
estimates
Where
published
studies
of
yield
losses
under
conditions
of
moderate
to
severe
key
pest
pressure
were
not
available
(
the
situation
for
which
the
U.
S.
is
requesting
continued
use
of
methyl
bromide),
the
U.
S.
developed
such
estimates
by
contacting
university
professors
conducting
experiments
using
methyl
bromide
alternatives
in
the
appropriate
land
grant
institutions.
The
experts
were
asked
to
develop
such
an
estimate
based
on
their
experience
with
methyl
bromide
and
with
alternatives.
The
results
of
this
process
were
used
when
better
data
were
not
available.

Source
of
buffer
restriction
implications
for
methyl
bromide
use
Estimates
of
the
impact
of
buffers
required
when
using
some
methyl
bromide
alternatives
on
the
proportion
of
acreage
where
such
alternatives
could
be
used
were
developed
from
confidential
information
submitted
to
EPA
in
support
of
a
registration
application
for
a
methyl
bromide
alternative.
Because
at
the
time
of
the
analysis,
a
request
to
reduce
the
size
of
the
required
buffer
for
some
alternatives
was
under
consideration,
a
smaller
buffer
was
selected
for
the
analysis.
Since
that
time
the
size
of
the
regulatory
buffer
has
been
reduced
so
that
it
now
conforms
to
the
buffer
selected
for
this
analysis.

Source
of
area
impacted
by
key
pests
estimates
One
of
the
important
determinants
of
the
amount
of
methyl
bromide
requested
has
been
the
extent
of
area
infested
with
`
key
pests',
that
is,
pests
which
cannot
be
controlled
by
alternatives
to
methyl
bromide
when
such
pests
are
present
at
moderate
to
severe
levels.
Because
there
are
few
surveys
that
cover
substantial
portions
of
the
areas
for
which
methyl
bromide
is
requested,
we
have
relied
on
a
variety
of
sources
in
addition
to
the
surveys.
These
sources
include
websites
of
land
grant
universities;
discussions
with
researchers,
both
those
employed
by
USDA
in
the
Agricultural
Research
Service
(
ARS)
and
those
at
land
grant
universities;
discussions
with
growers
whose
operations
cover
widely
different
locations
encompassing
different
incidences
of
key
pests;
information
from
pesticide
applicators;
and,
information
taken
from
the
applications
themselves.

Source
of
area
impacted
by
regulations
estimates
There
are
two
main
sources
used
to
develop
the
estimate
of
area
impacted
by
regulations.
First,
for
the
impact
of
Township
caps
in
California
we
have
used
a
series
of
papers
by
Carpenter,
Lynch,
and
Trout,
supplemented
by
discussions
with
Dr.
Trout
to
ensure
that
any
recent
regulatory
changes
have
been
properly
accounted
for.
Second,
the
estimate
of
the
area
impacted
by
buffers,
is
described
above.

Source
of
area
impacted
by
soil
type
estimates
First,
for
the
area
impacted
by
karst
topography,
estimates
were
developed
and
mapped
by
he
Florida
Department
of
Environmental
Protection.
The
area
of
California
used
for
agriculture
and
which
is
made
of
clay
soils
unsuitable
for
pest
control
with
a
methyl
bromide
alternative
has
been
determined
by
discussions
with
agricultural
researchers
and
agricultural
extension
agents
in
California,
and
discussion
with
other
knowledgeable
individuals
such
as
pesticide
applicators.
The
estimates
for
California
understate
the
areas
in
which
alternatives
to
methyl
bromide
are
not
suitable
because
no
effort
was
made
to
estimate
the
extent
of
hilly
terrain
where
currently
available
substitutes
cannot
be
applied
at
uniform
dosages.
Page
14
Source
of
area
impacted
by
combined
impacts
estimate
Combined
impacts
were
determined
on
a
case
by
case
basis
for
each
specific
crop/
location
combination
after
consultation
with
individuals
knowledgeable
with
the
specific
circumstances.
The
nature
of
the
individual
impacts
is
such
that
in
some
situations
they
are
independent
of
each
other,
in
some
they
are
mutually
exclusive,
and
in
some
cover
identical
areas.
It
was
not,
therefore,
possible
to
have
a
formula
that
would
arrive
at
an
appropriate
estimate
of
combined
impacts.
A
more
detailed
description
is
found
in
the
footnotes
to
the
`
calculation'
table.

REFERENCES
Gilreath,
J.
P.,
Noling,
J.
W.,
Jones,
J.
P,
Locascio,
S.
J.,
and
Chellemi,
D.
O.
2001.
Three
years
of
soil
borne
pest
control
in
tomato
with
1,2­
D
+
chloropicrin
and
solarization.
Proceedings
of
the
Annual
International
Research
Conference
on
Methyl
Bromide
Alternative
and
Emissions
Reductions.
Nov
5­
9,
2001,
San
Diego.

Locascio,
S.
J.,
J.
P.
Gilreath,
D.
W.
Dickson,
T.
A.
Kucharek,
J.
P.
Jones,
and
J.
W.
Noling.
1997.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato.
HortScience
32
(
7):
1208­
1211.

MBTOC.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.
Pg
368­
371.

Miguel.
A.
2002.
Grafting
as
a
non­
chemical
alternative
to
MB
for
tomatoes
in
Spain.
In:
Proceedings
of
International
Conference
on
Alternatives
to
Methyl
Bromide.
T.
A.
Batchelor
and
J.
M.
Bolivar
(
eds).
Available
on
the
Web
at:
http://
europa.
eu.
int/
comm/
environment/
ozone/
conference
U.
S.
Environmental
Protection
Agency,
January
26,
1998,"
Feasibility
of
Using
Gas
permeable
Tarps
to
Reduce
Methyl
Bromide
Emissions
Associated
with
Soil
Fumigation
in
the
United
States."

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2001.
Methyl
Bromide
Alternatives
in
a
Bell
Pepper­
Squash
Rotation.
Crop
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20:
605­
614
