Page
1
U.
S.
A.
CUN2003/
052
­
FOREST
SEEDLING
NURSERIES
FOREST
TREE
SEEDLINGS
GROWN
OUTDOORS
AFTER
BROADCAST
FUMIGATIONS
UNDER
PLASTIC
TARPS
TABLE
OF
CONTENTS
Introduction.......................................................................................................................................................
2
Critical
Need
for
Methyl
Bromide
.....................................................................................................................
2
Economic
Impacts
.............................................................................................................................................
3
Response
to
Questions
from
MBTOC/
TEAP
.....................................................................................................
5
Definitions
......................................................................................................................................................
11
References.......................................................................................................................................................
12
APPENDIX.
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1
.......................................................................................................................
13
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
...................................................................
3
Table
2.
Measures
of
Economic
Impact
of
Using
Dazomet
or
Metam­
Sodium
in
Place
of
Methyl
Bromide
on
Tree
Seedling
Nurseries
in
the
U.
S.
a..........................................................................................................
5
Table
3.
Average
Yearly
Height
Growth
and
Survival
of
Containerized
and
Bareroot
Seedlings
Planted
During
the
Winter
Period,
November
to
Marcha
....................................................................................................
7
Table
4.
Historical
Use
of
Methyl
Bromide
in
the
Forest
Seedling
Sector*
.......................................................
8
Table
5.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Forest
Seedling
Sector
.....................
8
D.
Analysis
of
Net
Costs:
Converting
10
million
Seedling
Nursery
from
Bareroot
to
Containerized,
Soilless
Culture.....................................................................................................................................................
14
Page
2
INTRODUCTION
The
United
States
is
providing
the
following
additional
information
to
clarify
several
issues
for
the
forest
seedling
nursery
CUE
nomination.
Millions
of
hectares
of
forestland,
which
are
planted
every
year
for
reforestation,
fiber
production,
and
conservation
uses,
require
efficient
nurseries
to
provide
seedlings.
The
large
size
of
U.
S.
forests,
many
of
which
are
publicly
owned,
also
requires
inexpensive
production
technologies
to
enable
a
vigorous,
plentiful,
and
cost
effective
product.
The
use
of
methyl
bromide
(
MB)
(
usually
applied
to
a
bed
only
once
in
three
to
four
years)
by
forest
seedling
nurseries
is
an
important
means
of
reducing
overall
costs
of
seedling
production
that
allows
the
20
to
40
year
investment
in
forests
to
be
worthwhile.
Additionally,
the
positive
environmental
value
of
reforestation
was
taken
into
consideration,
even
though
it
is
not
explicitly
reflected
in
the
economic
analysis.

CRITICAL
NEED
FOR
METHYL
BROMIDE
Forest
seedling
nurseries
face
numerous
pests
in
the
course
of
production,
most
importantly
nutsedge
weeds
and
certain
fungal
pathogens
(
Table
1).
While
alternative
technologies
currently
are
being
addressed
by
the
industry,
including
investigating
container
production,
in
the
near
future
MB
is
necessary
for
production
requirements.
Intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
yield
and
quality
goals,
while
minimizing
production
costs.
Because
of
the
importance
of
seedling
quality
(
due
to
the
high
correlation
of
quality
and
subsequent
forest
health
and
value),
a
failure
to
produce
consistently
healthy
seedlings
can
have
a
devastating
effect
on
the
nurseries'
abilities
to
provide
acceptable
seedlings
for
forestation.
The
adverse
economic
impact
of
using
metam­
sodium
or
dazomet
(
Table
2)
could
put
the
intensive
production
schedule
at­
risk,
leading
to
failures
in
providing
sufficient
numbers
of
high
quality
seedlings.
As
detailed
in
the
nomination,
significant
research
is
on
going
to
find
MB
alternatives
that
will
meet
the
needs
of
forest
seedling
nurseries,
but
this
industry's
requirement
for
MB
in
the
near
future
is
critical.
The
U.
S.
nomination
for
MB
for
the
forest
seedling
sector
is
only
for
those
areas
that
face
moderate
to
severe
pest
pressure
because
alternatives
are
not
feasible
in
these
areas.
Page
3
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
Region
Key
Pests
Critical
Need
for
Methyl
Bromide
South:
Alabama,
Arkansas,
Georgia,
Florida,
Louisiana,
Mississippi,
North
Carolina,
Oklahoma,
South
Carolina,
Tennessee,
Texas,
Virginia
Auburn
University
Southern
Forest
Nursery
Mgt.
Coop.
(
CUE
02­
0003)
International
Paper
(
CUE
02­
0007)
(
also
a
member
of
Auburn
University
consortium)
Weyerhaeuser­
South
(
CUE
02­
0021)
(
also
a
member
of
Auburn
University
consortium)
Diseases:
Plant
fungal
pathogens
such
as
species
of
Fusarium,
Alternaria,
Phytophthora,
Pythium,
Rhizoctonia,
and
Macrophomina,

Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
purple
nutsedge
(
Cyperus
rotundus)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Southern
U.
S.
MB
applications
in
forest
seedling
nurseries
are
typically
made
using
67:
33
or
50:
50
mixtures
with
chloropicrin
as
broadcast
application
with
plastic
tarps.

West:
California,
Idaho,
Kansas,
Nebraska,
Oregon,
Utah,
Washington
Western
Forest
and
Conservation
Public
Nursery
Association
(
CUE
02­
0008)
Nursery
Technology
Cooperative
(
CUE
02­
0009)
Weyerhaeuser­
West
(
CUE
02­
0022)
Diseases:
Plant
pathogens,
such
as
Pythium
spp.,
Fusarium
spp.,
Cylindrocladium
spp.,
Phytophthora
spp.,
and
a
newly
identified
disease,
Sudden
Oak
Death,
caused
by
Phytophthora
ramorum
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Western
U.
S.
MB
applications
in
forest
seedling
nurseries
are
typically
made
using
67:
33
or
50:
50
mixtures
with
chloropicrin
as
broadcast
application
plastic
tarps.

North:
Illinois,
Indiana,
Kentucky,
Maryland,
Michigan,
Missouri,
New
Jersey,
Ohio,
Pennsylvania,
West
Virginia,
Wisconsin
Illinois
Dept.
Nat.
Res.
Nursery
Program
(
CUE
02­
0011)
Northeastern
Forest
and
Conservation
Nursery
Association
(
CUE
02­
0032)
Michigan
Seedling
Association
(
CUE
02­
0039)
Diseases:
Plant
fungal
pathogens
such
as
species
of
Fusarium,
Alternaria,
Phytophthora,
Pythium,
Rhizoctonia,
and
Macrophomina,
which
can
cause
severe
outbreaks
of
root
rots
and
damping­
off
diseases.
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Northern
U.
S.
MB
applications
in
forest
seedling
nurseries
are
typically
made
using
67:
33
or
50:
50
mixtures
with
chloropicrin
as
broadcast
application
plastic
tarps.

ECONOMIC
IMPACTS
In
order
to
determine
whether
a
proposed
alternative
to
MB
is
economically
feasible
in
those
situations
where
technically
feasible
alternatives
exist,
the
U.
S.
took
a
`
weight
of
the
evidence'
or
`
portfolio'
approach.
Rather
than
rely
on
a
single
indicator
or
even
a
series
of
indicators,
each
with
a
`
bright
line',
the
situation
of
the
applicant
with
respect
to
three
measures
was
assessed.
The
three
measures
selected
for
consideration
were:
loss
per
hectare;
loss
per
kilogram
of
MB;
and
loss
as
a
percent
of
net
cash
returns
(
profit
loss
is
not
included
partly
because
many
nurseries
are
publicly
owned
and
seedling
prices
or
production
costs
are
subsidized).
These
measures
were
selected
because
information
needed
to
support
them
was
fairly
readily
available
and
because
they
describe
different
aspects
of
potential
loss.

When
evaluating
the
case
made
by
each
application,
expert
economic
judgement
was
used
to
determine
whether
each
loss
(
or
change
in
profit
margin)
was:
significant,
not
significant,
or
borderline.
Once
decisions
on
individual
measures
were
reached,
an
overall
assessment
was
made
which
included
the
individual
measures.

Other
impacts
on
the
environment
from
the
activity
were
also
taken
into
consideration,
at
least
qualitatively,
where
appropriate.
These
impacts
included
only
those
conferring
significant
social
benefits
in
the
form
of
environmental
improvements
which
were
not
otherwise
captured
in
the
application.
For
example,
a
major
use
Page
4
of
forest
seedlings
is
in
reforestation,
an
activity
with
significant
social
benefits
to
the
environment
which
are
not
reflected
in
applicant­
level
economic
indicators.
A
higher
cost
of
seedlings
would
reduce
the
overall
amount
of
reforestation
with
a
concomitant
reduction
in
air
quality,
stream
clarity,
habitat,
etc.

The
original
U.
S.
nomination
presented
data
showing
that
the
next
best
alternative
to
MB
is
not
economically
feasible
in
the
circumstances
of
each
of
the
nominated
states/
regions.
Total
losses
are
similar
for
both
dazomet
and
metam
sodium,
which
are
considered
the
next
best
alternatives
to
MB.
Quantifiable
losses
originate
from
yield
losses
and
cost
increases.
Dazomet
has
slightly
smaller
yield
losses
than
metam­
sodium,
but
slightly
higher
treatment
costs,
with
the
result
that
losses
are
equivalent
for
these
two
alternatives.

In
the
Southern
U.
S.,
a
yield
loss
of
5%
would
be
expected
from
using
metam
sodium
or
dazomet,
and
operating
costs
are
expected
to
increase
11­
15%.
This
translates
into
an
expected
revenue
loss
of
US$
3700
per
hectare,
a
12%
loss
in
gross
revenues,
and
a
27%
loss
in
net
cash
revenues,
indicating
a
critical
need.
Measured
as
a
loss
per
kilogram
of
MB
used,
the
loss
ranges
from
US$
3
to
US$
20,
with
a
likely
average
of
US$
10
per
kilogram.

In
the
Western
U.
S.,
a
yield
loss
of
5%
would
be
expected
from
using
metam
sodium
or
dazomet,
and
operating
costs
are
expected
to
increase
2­
5%.
This
translates
into
an
expected
revenue
loss
of
US$
3200
per
hectare,
a
6%
loss
in
gross
revenues,
and
a
16%
loss
in
net
cash
revenues,
indicating
a
critical
need.
Measured
as
a
loss
per
kilogram
of
MB
used,
the
likely
loss
is
US$
14
per
kilogram.

In
the
Northern
U.
S.,
a
yield
loss
of
3%
would
be
expected
from
using
metam
sodium
or
dazomet,
and
operating
costs
are
expected
to
increase
1­
2%.
Indirect
losses
occur
due
to
lengthening
of
the
production
cycle,
which
results
in
less
land
in
production
and
more
in
fallow
or
longer
time
for
seedlings
to
reach
appropriate
size.
Such
losses
represent
13%
of
production.
These
losses
translate
into
an
expected
revenue
loss
of
US$
11,120
per
hectare,
a
16%
loss
in
gross
revenues,
and
a
67%
loss
in
net
cash
revenues,
indicating
a
critical
need.
Measured
as
a
loss
per
kilogram
of
MB
used,
the
likely
loss
is
US$
32
per
kilogram.

While
direct
yield
losses
are
similar
across
the
regions,
mainly
because
the
same
studies
were
used
to
predict
impacts,
the
range
of
losses
in
the
studies
is
rather
large
because
both
dazomet
and
metam­
sodium
provide
inconsistent
pest
control.
Changes
in
production
costs
arise
due
to
differences
between
the
costs
of
MB
and
the
alternatives,
shifts
in
the
production
cycle
(
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period)
and
additional
expenses
such
as
supplementary
irrigation.
These
costs
vary
across
regions
and
within
the
Western
region,
which
is
highly
diverse,
because
of
differences
in
pests,
production
systems
and
regional
differences
in
costs
of
water
and
labor.
Costs
are
higher
in
the
South,
in
part
because
warmer
temperatures
increase
pest
pressure.
Page
5
TABLE
2.
MEASURES
OF
ECONOMIC
IMPACT
OF
USING
DAZOMET
OR
METAM­
SODIUM
IN
PLACE
OF
METHYL
BROMIDE
ON
TREE
SEEDLING
NURSERIES
IN
THE
U.
S.
A
Loss
Measures
South
Auburn
University
Southern
Forest
Nursery
Mgt.
Coop.
(
CUE
02­
0003)
International
Paper
(
CUE
02­
0007)
Weyerhaeuser­
South
(
CUE
02­
0021)
West
Western
Forest
and
Conservation
Public
Nursery
Association
(
CUE
02­
0008)
Nursery
Technology
Cooperative
(
CUE
02­
0009)
Weyerhaeuser­
West
(
CUE
02­
0022)
North
Illinois
Dept.
Nat.
Res.
Nursery
Program
(
CUE
02­
0011)
Northeastern
Forest
and
Conservation
Nursery
Association
(
CUE
02­
0032)
Michigan
Seedling
Association
(
CUE
02­
0039)

Direct
Yield
Loss
Likely
5%
loss
3%
gain
to
13%
loss
Likely
5%
loss
3%
gain
to
13%
loss
Likely
3%
loss
2%
gain
to
13%
loss
Loss
per
Hectare
Likely
US$
3700
loss
US$
1060­
6670
loss
Likely
US$
3200
loss
US$
150
gain
to
US$
7660
loss
Likely
US$
11,120
loss
US$
3330­
12600
loss
Loss
per
Kilogram
MB
Likely
US$
10
loss
US$
3­
20
loss
Likely
US$
14
loss
US$
1
gain
to
US$
26
loss
Likely
US$
32
loss
US$
9
to
US$
37
loss
Loss
as
a
%
of
Gross
Revenue
Likely
12%
loss
3
to
22%
loss
Likely
6%
loss
1%
gain
to
15%
loss
Likely
16%
loss
5
to
19%
loss
Loss
as
a
%
of
Net
Cash
Returns
Likely
27%

8
to
49%
loss
Likely
16%
loss
1%
gain
to
27%
loss
Likely
67%
loss
20
to
76%
loss
Change
in
Profit
Margins
Not
Available
Not
Available
Not
Available
aDazomet
and
metam­
sodium
have
similar
total
impacts.
cChange
results
from
different
costs
of
alternatives,
additional
pesticide
applications,
changes
in
production
patterns
and
additional
equipment.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
detail
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount.

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

The
methodology
used
by
the
U.
S.
to
calculate
the
nominated
amount
of
MB
carefully
scrutinized
applications
from
the
user
community
and
took
out
(
1)
double
counting,
(
2)
any
requested
growth
beyond
historical
hectares
planted
(
Table
4),
and
(
3)
requested
amounts
that
fall
under
QPS.
Furthermore,
the
U.
S.
adjusted
the
requests
from
the
user
community,
when
they
had
not
already
done
so,
to
change
the
amount
of
MB
nominated
to
account
for
(
1)
only
the
area
where
pest
pressure
cannot
be
controlled
by
alternatives,
(
2)
the
area
where
regulatory
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
Page
6
incorporates
minimum
efficacious
use
rates,
mixtures
of
MB
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.

2.
The
Party
is
requested
to
provide
information
on
what
proportion
of
the
MB
nominated
could
be
offset
by
use
of
non­
MB
alternatives
such
as
substrate
production
and
containerized
plants.

An
economic
analysis
suggests
that
costs
associated
with
changing
to
substrate
production
and
containerized
plants
are
prohibitive
and
therefore
the
proportion
of
MB
nominated
could
not
be
offset
by
using
these
alternatives
(
details
of
analysis
are
provided
in
the
Appendix
to
this
document).
Here,
the
U.
S.
is
providing
additional
information
on
a
MB
alternative,
the
production
of
forest
tree
seedlings
in
containers,
rather
than
in
outdoor
beds.
The
U.
S.
nomination
for
forest
tree
seedling
nurseries
addressed
the
two
chemical
and
eight
non­
chemical
MB
alternatives
that
were
identified
by
MBTOC
that
was
created
for
all
Parties
for
the
CUE
process.

The
forest
tree
nursery
industry
produces
millions
of
bareroot
seedlings
each
year
for
reforestation,
forest
establishment,
fiber
production,
and
wildlife,
conservation,
and
recreational
uses.
Generally,
use
of
containers
rather
than
nursery
beds
can
reduce
the
reliance
on
fumigants
through
the
use
of
sterile
medium
that
is
initially
free
of
pathogens,
insects,
nematodes,
and
weeds
(
Seymour,
2000).
During
the
growing
season
however,
there
is
a
critical
requirement
to
control
pests
in
containers,
including
weeds
(
Barnett
and
McGilvrary,
1997),
although
MB
would
not
be
required.
Production
costs
can
be
higher
for
container
growth
depending
on
nursery
location
and
conditions,
and
start­
up
costs
in
the
transition
of
bed
to
container
systems
are
high,
especially
considering
the
low
profit
margin
(
sometimes
negative
profits
for
public
nurseries)
for
forest
tree
seedling
nurseries.
Increased
costs
of
container
production
include
more
intensive
management
and
more
labor
than
bed
production.
Containerized
seedlings
are
most
effective
in
the
South
in
niche
environments,
such
as
reforestation
or
reclamation
of
harsh
sites,
including
mine­
spoil
reclamation
and
very
droughty
soils
(
Lowert,
2003,
personal
communication).
In
these
situations
containerized
seedlings
may
survive
and
grow
better
than
bareroot
seedlings.

Total
costs
can
be
2.5
times
higher
for
container
seedlings
(
versus
bareroot
plants),
and
may
be
even
higher
when
shipping
costs
are
included
(
Appendix,
below).
According
to
one
source
(
Darrow,
2002
personal
communication
­
see
Appendix)
the
transition
from
bed
to
container
production
requires
additional
capital
and
operating
costs.
High
production
nurseries
may
also
have
higher
material
costs,
e.
g.,
the
need
to
use
more
expensive
multi­
pot
containers,
which
reduce
air
circulation
around
roots
and
require
technology
to
provide
additional
air
(
Barnett
and
McGilvrary,
1997).
According
to
another
source
(
Lowert,
2003,
personal
communication),
shipping
costs
alone
can
increase
the
cost
of
containerized
seedlings
by
10%
($
3.70
per
thousand).

The
majority
of
forest
seedlings
are
produced
using
bareroot
systems.
The
high
cost
of
containerized
seedlings
combined
with
no
growth
or
survival
advantage
(
see
Appendix
Table
D)
results
in
little
demand
from
seedling
buyers.
This
lack
of
demand
is
reflected
in
the
composition
of
one
major
seedling
producer's
2003­
04
seedling
crop,
in
which
only
3.2
million
seedlings
(
1%)
out
of
a
302
million
crop
are
containerized
(
Lowerts,
2003,
personal
communication).
In
2000,
the
U.
S.
Forest
Service
reported
that
production
at
its
Coeur
d'Alene
ID
nursery
was
16
million
bareroot
seedlings
annually
in
beds
from
52
hectares,
and
4
million
seedlings
annually
from
containers
in
17
greenhouses
on
14
hectares
(
http://
www.
fs.
fed.
us/
ipnf/
nurs/
wwwpages/
wwwpage.
htm
).
Page
7
TABLE
3.
AVERAGE
YEARLY
HEIGHT
GROWTH
AND
SURVIVAL
OF
CONTAINERIZED
AND
BAREROOT
SEEDLINGS
PLANTED
DURING
THE
WINTER
PERIOD,
NOVEMBER
TO
MARCH
A
Age
Years
%
Bareroot
Survival
Average
Height
(
ft)
Bareroot
%
Containerized
Survival
Average
Height
(
ft)
Containerized
1
95
3.8
96
3.3
2
95
8.5
95
7.7
3
94
13.6
95
12.8
aIn­
house
research
conducted
by
International
Paper
(
personal
communication
from
George
Lowerts,
2003)

The
use
of
container
plants
in
forestry
is
limited
by
terrain,
and
the
feasibility
and
cost
of
transporting
seedlings
to
the
planting
site.
In
many
forests
areas
in
the
U.
S.,
planting
is
done
by
hand
on
challenging
terrain,
with
seedlings
carried
in
by
individuals
who
transport
the
seedling
in
backpacks
to
planting
sites.
Using
container
seedlings
would
require
much
greater
transportation
and
labor
costs;
compared
to
bareroot
seedlings
and
can
raise
planting
costs
in
a
large
number
of
areas.
One
study
found
that
daily
planting
decreased
from
9.7
hectares
per
day
with
bareroot
seedlings
to
7.3
hectares
per
day
with
containerized
seedlings
without
increasing
planting
crew
size
(
Lowert,
2003,
personal
communication).
As
a
result,
the
overall
cost
of
planting
containerized
seedlings
could
increase
by
25%
due
to
lower
production
rates
or
increased
planting
crew
size.
Table
3
demonstrates
similar
survival
and
height
between
container
and
bareroot
plants
with
the
additional
negative
impact
of
increased
costs
due
to
transportation
and
planting.

3.
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
applied
in
conjunction
with
chloropicrin
where
feasible.

The
nomination
submitted
considered
the
use
of
emission
control
technologies
applied
in
conjunction
with
chloropicrin.
Forest
seedling
growers
in
the
regions
requesting
this
exemption
routinely
produce
these
crops
using
plastic
tarpaulins,
which
reduce
MB
emissions.
Although
data
are
not
available
for
the
entire
US,
in
California
93%
of
MB
pre­
plant
applications
are
made
under
plastic
tarps
(
personal
communication,
Paul
Niday,
TriCal
Corp.).
The
7%
of
usage
that
is
not
tarped
is
applied
by
deep
shank
injection
for
orchard
replant.
Also,
the
nominated
amount
assumes
that
growers
would
continue
to
use
mixtures
of
MB
with
chloropicrin
(
typically
67:
33
or
50:
50;
see
Table
1),
a
reduction
in
the
amount
of
MB
used.
Recalculation
of
the
nomination
amount
was
not
necessary
because
the
original
U.
S.
nomination
already
accounts
for
these
factors
4.
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.

There
is
limited
data
available
reporting
quality
reduction
in
nurseries
from
the
use
of
MB
alternatives.
Yield
data
comparing
performance
for
identified
chemical
alternatives,
such
as
Telone
and/
or
chloropicrin
are
strong
indicators
of
the
effect
of
these
alternatives
compared
with
MB.
Economic
analysis
provided
in
the
original
nomination
for
this
sector
and
highlighted
in
this
document
(
Table
2)
suggests
that
economic
losses
would
be
significant
if
alternatives
were
to
replace
MB.
As
previously
mentioned,
in
at
least
one
set
of
trials
for
chloropicrin
efficacy,
beds
had
to
be
abandoned
due
to
nutsedge
infestation
(
Littke,
2003,
personal
communication).
These
trials
also
required
increased
use
of
herbicides
to
control
nutsedge,
and
were
not
uniformly
successful
in
doing
so.

5.
The
CUN
finds
that
two
chemical
alternatives
are
considered
technically
feasible,
but
does
not
discuss
the
feasibility
of
utilizing
substrates
and
containerized
plants
for
forest
seedling
production.
Containerized
plant
systems
are
quite
widely
in
use.
Page
8
The
U.
S.
response
to
the
comment
that
containerized
plant
systems
are
in
wide
use
is
elaborated
in
Comment/
Response
#
2,
above,
and
in
the
Appendix
to
this
document.

TABLE
4.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
FOREST
SEEDLING
SECTOR*

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

1997
351
446,481
1,224
1998
346
454,468
1,280
1999
333
486,650
1,358
2000
314
453,990
1,333
2001
305
436,452
1,307
*
Acres
planted
in
U.
S.
and
percent
of
U.
S.
acreage
requested
is
not
available.
Source:
Rates,
amounts,
and
area
treated
are
from
applicants'
information.

TABLE
5.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
FOREST
SEEDLING
SECTOR
Calculation
of
Nominated
Amount
0003
 
Auburn
Southern
Forest
Nursery
0007
 
International
Paper
0008
 
Western
Forest
&
Conservation
Public
Nursery
Assoc.
0009
 
Nursery
Technology
Cooperative
0011
 
Gale
Rampley
Hectares
(
ha)
656
109
61
202
16
%
of
Regional
hectares
(
ha)(
A)
Not
Available
Not
Available
Not
Available
Not
Available
Not
Available
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
246,032
41,730
20,412
52,390
4,264
Double
Counted
hectares
(
ha)(
B)
176
 
 
 
 
Growth
/
Increasing
Production
hectares
(
ha)(
C)
 
 
 
(
14)
3
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
240
54
30
101
6
Adjustment
s
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
240
55
31
101
7
Key
Pest
Impacts
(%)(
F)
100
100
100
100
100
Regulatory
Impacts
(%)(
G)
 
 
 
 
 
Soil
Impacts
(%)(
H)
 
 
 
 
 
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
100
100
100
Qualifying
Area
(
ha)(
J)
240
55
31
101
7
Use
Rate
(
kg/
ha)(
K)
375
382
336
259
263
CUE
Amount
Nominated
(
kg)(
L)
90,005
20,865
10,206
26,195
1,706
%
Reduction
from
Initial
Request
(
M)
63
50
49
50
56
Page
9
TABLE
5.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
FOREST
SEEDLING
SECTOR
(
CONTINUED)

Calculation
of
Nominated
Amount
0021
 
Weyerhaeuser
(
SE)
0022
 
Weyerhaeuser
(
NW)
0032
 
N.
E.
Forest
&
Conservation
Nursery
Assoc.
0039
 
Michigan
Seedling
Association
Hectares
(
ha)
67
94
97
34
%
of
Regional
hectares
(
ha)(
A)
Not
Available
Not
Available
Not
Available
Not
Available
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
22,453
24,752
33,112
9,144
Double
Counted
hectares
(
ha)(
B)
 
 
 
 
Growth
/
Increasing
Production
hectares
(
ha)(
C)
1
29
11
 
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
33
33
43
17
Adjustmen
ts
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
33
32
43
17
Key
Pest
Impacts
(%)(
F)
100
100
100
100
Regulatory
Impacts
(%)(
G)
 
 
 
 
Soil
Impacts
(%)(
H)
 
 
 
 
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
100
100
Qualifying
Area
(
ha)(
J)
33
32
43
17
Use
Rate
(
kg/
ha)(
K)
336
263
341
269
CUE
Amount
Nominated
(
kg)(
L)
11,090
8,562
14,728
4,572
%
Reduction
from
Initial
Request
(
M)
51
66
56
50
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
187,929
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
192,515
Page
10
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.
In
this
sector
two
firms
submitted
individual
applications
and
had
portions
of
their
operations
included
in
a
consortium
application.
This
double
counting
has
been
removed.
C.
Growth
/
increasing
production
hectares
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
and
are
shown
to
demonstrate
a
trend,
but
are
not
used
in
further
calculations.
Growth
has
been
removed.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Up
to
50%
of
the
requested
amount
has
been
deducted
as
falling
under
the
quarantine/
preshipment
exemption.
E.
Adjusted
hectares
requested
is
the
hectares
in
the
applicant's
request
minus
the
hectares
affected
by
double
counting,
growth
/
increasing
production,
and
quarantine
and
pre­
shipment.
F.
Key
pest
impacts
is
the
percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
Because
this
activity
is
provision
of
nursery
stock
it
is
considered
vital
that
the
plants
be
pest­
free.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
H.
Soil
impacts
is
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).
I.
Total
combined
impacts
is
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
1,3­
D
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
1,3­
D
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
is
typically
based
on
historical
averages.
In
some
cases,
the
use
rate
has
been
adjusted
downward
to
reflect
current
conditions.
Half
of
the
applications
have
had
their
use
rate
adjusted
down.
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.
nomination
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
sum
of
all
nominations
in
this
sector
by
the
margin
of
error
multiplier.
Page
11
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
MB),
the
U.
S.
developed
such
estimates
by
contacting
university
professors
conducting
experiments
using
MB
alternatives
in
the
appropriate
land
grant
institutions.
The
experts
were
asked
to
develop
such
an
estimate
based
on
their
experience
with
MB
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
MB
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
MB
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
MB
requested
has
been
the
extent
of
area
infested
with
`
key
pests',
that
is,
pests
which
cannot
be
controlled
by
alternatives
to
MB
when
such
pests
are
present
at
moderate
to
severe
levels.
Because
there
are
few
surveys
that
cover
substantial
portions
of
the
areas
for
which
MB
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
MB
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
MB
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
12
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
complete
description
is
found
in
the
footnotes
to
the
`
calculation'
table
REFERENCES
Barnett,
J.
P.
and
McGilvrary,
J.
M.
1997.
Practical
guidelines
for
producing
longleaf
pine
seedlings
in
containers.
Gen.
Tech.
Rep.
SRS­
14.
Asheville,
NC.
U.
S.
Department
of
Agriculture,
Forest
Service,
Southern
Research
Station.
28
p.
http://
www.
bugwood.
org/
container/
guidelines.
html
Darrow,
K.
2002.
Personal
communication
(
see
Appendix)

Littke,
W.
2003.
Personal
communication.

Lowerts,
G.
2003.
Personal
communication.

Seymour,
N.
G.
2000.
Guide
to
establishing
a
nursery
in
Alberta
 
container
growing.
Alberta
(
Canada).
http://
www.
agric.
gov.
ab.
ca/
crops/
trees/
nursery8.
html.
Page
13
APPENDIX
:
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1
The
costs
below
are
based
on
the
conversion
of
a
10
million
bare­
root
seedling,
soil­
based,
nursery
to
a
container,
soilless,
nursery
for
the
raising
of
Loblolly
pine
seedlings
in
the
southern
USA.
The
cost
estimates
include
estimates
of
additional
expenditures
(
over
and
above
$.
04
per
seedling
cost
for
soil­
based
system)
for:

A.
Capital
Infrastructure
B.
Operating
Costs
Limitations
of
Analysis:
There
are
also
expected
to
be
additional
shipping
costs,
due
to
the
larger
size
and
weight
of
containerized
plants,
but
estimating
these
costs
were
beyond
the
scope
of
this
analysis.
Economy
of
scale
can
be
significant
and
regional
costs
vary,
making
it
difficult
to
provide
a
precise
cost.

Additional
Note:
The
capital
costs
associated
with
conversion
from
a
soil­
based
to
a
soilless
nursery
are
much
less
than
the
capital
costs
of
establishing
a
new
soilless
nursery.
All
of
the
basic
infrastructure
and
much
of
the
equipment
would
already
be
in
place
with
a
soil­
based
nursery.

A.
Capital
Infrastructure:
Many
of
the
facilities
required
for
the
operation
of
a
soil­
based
seedling
nursery
are
required
for
a
soilless
nursery,
so
conversion
costs
and
the
conversion
costs
are
Conversion
cost:
Water
supply
$
0
Power
$
0
Buildings
$
0
Landscaping/
levelling/
roads
$
0
Equipment
­
assuming
no
trade­
ins
$
100,000
Nursery
structures
+
irrigation
$
130,000
B.
Operating
costs:
Working
capital
requirements
are
greater
in
a
soilless
nursery
than
a
soil­
based
nursery
as
more
labor
is
used.
The
cost
of
conversion
from
a
soil­
based
nursery
to
a
soilless
nursery
should
include
the
need
for
additional
working
capital.

Working
Capital:
additional
container
system
cost
$
150,000
(
over
and
above
~$
50,000
cost
for
soil­
based
system)
containers
$
410,000
Page
14
C.
Land
The
soil­
based
nursery
requires
13.3
hectares
exclusive
of
buildings,
storage
and
administrative
area.
The
soilless
nursery
requires
4
hectares
for
the
same
production.

Assuming
the
soil­
based
nursery
owner
is
able
to
sell
or
exchange
the
surplus
land,
the
change
from
soil­
based
to
soilless
will
be
a
source
of
revenue.
A
review
of
land
prices
in
the
southern
USA,
in
localities
where
forest
tree
nurseries
are
situated
reveals
an
average
of
$
12,350
per
hectare.

Land
Savings:
Land
(
9.3
hectares
at
$
12,350
per
hectare)
($
114,855)

TABLE
D.
ANALYSIS
OF
NET
COSTS:
CONVERTING
10
MILLION
SEEDLING
NURSERY
FROM
BAREROOT
TO
CONTAINERIZED,
SOILLESS
CULTURE
Capital
Cost
Years
of
Use*
Annual
Cost
Cost
per
Seedling
Equipment
$
100,000
10
$
11,723
$
0.0012
Nursery
Structures
$
130,000
10
$
15,240
$
0.0015
Running
Container
System
$
150,000
$
0.015
Containers
$
410,000
$
0.041
Total
Additional
Cost**
$
586,963
$
0.059
Land
rent
savings***
($
3,450)
($
0.0003)

Net
additional
cost
$
0.0583
Base
production
cost
(
for
bare­
root
and
soilless
system)
$
0.04
Total
Cost
per
Seedling
$
0.0983
*
Incorporates
real
interest
cost
at
3%
per
year.
**
Does
not
include
additional
cost
of
shipping
due
to
larger
and
heavier
containers.
***
Using
land
capitalization
rate
of
3%.

Conclusion:
Converting
to
a
soilless
containerized
system
would
increase
the
cost
of
production
by
approximately
250%,
and
could
be
higher
when
the
increased
cost
of
shipping
containerized
seedlings
is
included.

1
(
Based
on
communication
with
Kevin
Darrow,
Sept.
2002)
