U.
S.
A.
CUN2003/
057
­
CHRYSANTHEMUM
CUTTINGS/
ROSE
PLANTS
(
NURSERY)

ORNAMENTALS
GROWN
IN
GREENHOUSE
AFTER
BROADCAST
FUMIGATION
UNDER
PLASTIC
TARPAULINS.

ROSES
GROWN
OUTDOORS
AFTER
BROADCAST
FUMIGATION
UNDER
PLASTIC
TARPAULINS.

TABLE
OF
CONTENTS
Introduction
....................................................................................................................................
2
Critical
Need
For
Methyl
Bromide..................................................................................................
2
Economic
Impacts...........................................................................................................................
3
Response
to
Questions
from
MBTOC/
TEAP
..................................................................................
4
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates
..................................................
8
Virtually
Impermeable
Film
(
VIF)
Tarps
........................................................................................
8
Definitions
......................................................................................................................................
9
References
....................................................................................................................................
10
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
...............................................
2
Table
2.
Measures
of
Economic
Impact..........................................................................................
4
Table
3.
Historical
Use
of
Methyl
Bromide
in
the
Ornamental
Sector
............................................
6
Table
4.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Ornamental
Sector
.......
6
Page
2
INTRODUCTION
The
U.
S.
CUE
request
for
methyl
bromide
in
ornamental
flowers
is
to
allow
one
applicant
adequate
time
to
convert
to
steam
and
allow
the
other
applicant
access
to
methyl
bromide
since
they
are
limited
in
their
application
of
alternatives
because
of
California's
township
caps.
The
applicant,
the
key
pests
and
critical
need
are
briefly
described
in
Table
1.
The
economic
impact
of
the
best
alternative
is
reported
in
Table
2.

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

U.
S.
Region
/
States
Key
Pests
Critical
Need
for
Methyl
Bromide
Yoder
Brothers
(
CUE
02­
0020)
Florida
Diseases:
Erwinia
chrysanthemi;
E.
carotovora;
Agrobacterium
tumefaciens;
Fusarium
oxysporum;
F.
solani;
and
other
Fusarium
species;
Verticillium
alboatrum

Nematodes:
Radopholus
similes;
Rotolenchus
reniformis;
Globodera
spp.;
Heterodera
spp.

Weeds:
unspecified
Conversion
to
steam
will
take
several
years
for
this
applicant
to
complete
due
to
the
cost
of
capital
investments.
At
moderate
to
severe
pest
pressure
only
methyl
bromide
can
effectively
control
all
target
pests
found
in
Florida
for
the
certification
requirements.
Uses
of
alternatives
are
limited
by
regulatory
restrictions,
such
as
buffer
zones
around
habited
structures,
which
exclude
the
use
of
1,3­
dichloropropene.

California
Rose
Growers
Rep.
By
the
Garden
Rose
Council
(
CUE
02­
0028)
Diseases:
Verticillium
dahlia,
Pythium
spp.,
and
Agrobacterium
tumefaciens
Nematodes:
root
knot
(
Meloidogyne
spp),
lesion
(
Paratylenchus
vulnus),
pin
(
Paratylenchus
penetrans),
and
stubby
root
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus
L.);
purple
nutsedge
Cyperus
rotundus
L.)
At
moderate
to
severe
pest
pressure,
only
1,3­
D
or
MB
can
effectively
control
the
target
pest
in
California
roses.
Use
of
the
1,3­
D
is
limited
by
township
cap
regulatory
restrictions.
Methyl
bromide
applications
in
roses
are
typically
made
using
67:
33
with
chloropicrin
under
plastic
mulch.

For
chrysanthemum
propagation
material
production,
the
chemical
alternatives
are
not
technically
feasible.
Steam
sterilization
appears
to
be
a
viable
alternative,
from
a
technical
standpoint.
However,
the
applicant
does
not
have
sufficient
equipment
to
steam
all
the
production
beds,
and
wants
to
continue
to
use
methyl
bromide
on
a
decreasing
percentage
of
hectares
until
the
capital
needed
to
purchase
additional
equipment
can
be
acquired
(
an
additional
5­
6
years
are
projected).
A
description
of
the
applicant's
research
and
efforts
to
implement
alternatives
is
described
in
the
attachment
to
this
document
on
page
11.
The
standard
of
quality
for
plant
material
expected
by
this
industry
is
very
high.
There
is
considerable
risk
of
spreading
disease
into
many
growing
facilities
across
the
country
if
cuttings
shipped
to
growers
are
not
free
of
systemic
(
but
symptomless)
infections
caused
by
Erwinia
and
other
pathogens.
Page
3
For
rose
production,
it
appears
as
though,
according
to
the
available
research,
in
sandy
soils
where
the
soil
moisture
can
be
reduced
to
12%
or
below,
combinations
of
1,3­
D
products
and
metam
sodium
or
Basamid
could
be
used,
with
some
loss
of
size
(
based
on
results
in
walnut
and
peach
and
some
preliminary
rose
research)
and
an
increase
in
weed
control
costs.
This
treatment
is
unlikely
to
be
completely
effective
to
greater
depths
in
areas
where
soil
is
compacted.
While
1,3­
D
products
can
be
considered
at
least
moderately
effective
for
most
pest
problems
and
are
accepted
as
an
alternative
(
InLine
with
metam
sodium,
for
example),
the
issue
of
the
township
caps
that
affect
this
crop
must
be
addressed.

ECONOMIC
IMPACTS
In
order
to
determine
whether
a
proposed
alternative
to
methyl
bromide
is
considered
to
be
`
economically
feasible'
for
those
situations
where
technically
feasible
alternatives
exist,
the
United
States
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
five
measures
was
assessed.
The
five
measures
selected
for
consideration
were:
loss
per
hectare;
loss
per
kilogram
of
methyl
bromide;
loss
as
a
percent
of
gross
revenue;
loss
as
a
percent
of
net
cash
returns;
and
change
in
profit
margins.
These
measures
were
selected
because
the
information
was
fairly
readily
available,
they
describe
different
aspects
of
potential
loss
and
are
independent
of
each
other.
In
cases
where
information
was
not
available
for
one
or
more
of
the
measures,
the
remaining
measures
were
used.
In
cases
where
a
stream
of
benefits
was
derived
from
a
methyl
bromide
application,
net
present
value
was
used
in
the
calculations.

When
evaluating
the
case
made
by
each
application,
expert
economic
judgment
was
used
to
determine
whether
each
loss
(
or
change
in
profit
margin)
was
significant,
not
significant,
or
borderline
within
the
context
of
the
applicant's
market.
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.
An
example
is
the
value
in
ensuring
that
pests
are
not
transferred
to
areas
where
they
have
previously
been
unknown.
Introduction
of
pests
into
areas
where
they
are
not
likely
to
have
natural
checks
can
potentially
cause
a
great
deal
of
environmental
harm,
and
this
potential
is
likely
to
be
high
when
considering
nursery
plants,
which
might
be
dispersed
over
a
wide
geographic
area.
This
potential
for
damage,
which
is
not
reflected
in
the
nursery's
own
demand
for
methyl
bromide,
is
a
real
effect
and
something
to
be
considered
in
determining
a
'
critical
use'
of
methyl
bromide.

The
economics
of
steam
sterilization
in
chrysanthemum
production
are
presented
in
Table
2.
This
applicant
is
transitioning
to
steam.
The
United
States
estimates
that
forcing
the
company
to
convert
early
will
result
in
a
2%
loss
of
gross
revenue
and
an
18%
loss
of
net
cash
returns,
because
of
the
increased
costs
of
steam
sterilization
(
Table
2).
The
available
data
indicate
that
steam
sterilization
will
significantly
reduce
profits
although
profits
remain
positive.
However,
because
use
of
steam
requires
a
significant
capital
investment,
reported
economic
impacts
must
be
viewed
with
caution.
Results
in
Table
2
do
not
appropriately
account
for
the
time
needed
to
acquire
the
capital
requirements
for
steam
sterilization.
Because
of
the
capital
requirement
for
steam
sterilization,
the
applicant
will
need
time
to
acquire
the
financial
resources
and
purchase
and
install
the
needed
equipment
before
being
able
to
fully
convert
to
steam
sterilization.
The
California
Rose
Growers
Page
4
using
1,
3­
D
will
experience
a
5­
10%
yield
loss,
resulting
in
4­
9%
loss
of
gross
revenue
and
8­
16%
loss
of
net
cash
returns
(
see
Table
2).

TABLE
2.
MEASURES
OF
ECONOMIC
IMPACT.

Loss
Measure
Yoder
Brothers
(
CUE
02­
0020)
Steam
Sterilization
Compared
with
Methyl
Bromide
*
California
Rose
Growers
Rep.
By
the
Garden
Rose
Council
(
CUE
02­
0028)
1,3­
D
with
5%
Yield
Loss
Scenario
**
California
Rose
Growers
Rep.
By
the
Garden
Rose
Council
(
CUE
02­
0028)
1,3­
D
with
10%
Yield
Loss
Scenario
**

Per
hectare
per
crop
cycle
US$
7,700
US$
3,500
US$
7,400
Per
kg
methyl
bromide
US$
8.70
US$
10.30
US$
21.75
Percent
of
gross
revenue
2
%
4
%
9
%

Percent
of
net
cash
returns
18
%
8
%
16
%

*
All
economic
impacts
are
assumed
to
be
due
to
the
increased
costs
of
steam
sterilization.
**
Impacts
due
primarily
to
yield
losses.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
MBTOC
recommends
that
a
reduced
allocation
of
14.7
tons
be
approved
for
this
CUN,
on
the
basis
that
feasible
alternatives
are
available
for
chrysanthemum
cuttings
(
e.
g.
substrates)
and
adoption
of
reduced
dosages
with
emission
control
strategies.
MBTOC
noted
that
the
industry
is
aware
of
the
technically
available
alternatives
and
appears
to
be
making
an
effort
to
adopt
these
alternatives.
From
the
case
presented
MBTOC
is
unable
to
recommend
a
CUE
for
chrysanthemums
as
steaming
and
production
in
substrates
are
technically
and
economically
feasible.

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
4.

This
applicant
is
in
the
process
of
a
multi­
year
conversion
to
steam;
therefore,
a
discussion
of
substrate
as
an
alternative
in
chrysanthemum
production
is
unnecessary.
This
chrysanthemum
grower
has
already
converted
a
large
portion
of
the
operation
over
to
steam
with
a
detailed
plan
to
finish
the
transition
in
the
next
few
years.
But,
in
order
to
sell
a
product
that
meets
certification
and
grower
requirements,
the
capital
costs,
regulatory
permits,
and
construction
time
involved
require
that
additional
steam
capacity
be
phased
in
over
the
next
several
years.
We
note
that
CUE
recommendations
for
France
and
Spain
allow
several
years
to
make
their
transition
to
alternatives;
it
appears
that
the
United
States
has
not
been
granted
this
same
consideration
by
MBTOC.

2.
Roses
are
successfully
grown
in
substrates
worldwide.

The
cut
flower
rose
industry
has
determined
that
field
grown
roses
are
more
vigorous,
produce
more
flowers
and
are
longer
lived.
Starting
plants
in
substrate
has
resulted
in
reduced
vigor,
less
flowers,
and
shorter­
lived
plants.
Therefore,
the
cut
flower
rose
industry
in
the
U.
S.
will
only
buy
field
grown
plants.
(
Personal
communication
with
applicant)
Page
5
3.
The
Party
may
wish
to
recalculate
the
nomination
on
the
basis
of
use
of
reduced
MB
dosages
combined
with
emission
control
technologies,
and
availability
of
alternatives.

For
chrysanthemums,
the
company
has
conducted
research
for
many
years
on
the
use
of
lower
dosage
rates
(
see
attached
research
reports).
In
the
late
1980s,
the
company
tried
to
lower
the
methyl
bromide
dosage
rate
but
over
time
(
into
the
early
1990s)
there
was
an
increase
in
a
disease
that
was
damaging
the
propagative
material.
A
systemic
infection
of
Erswinia
was
effecting
the
cuttings
that
were
going
to
the
company's
own
rooting
stations
and
were
being
sent
to
customers,
with
terrible
losses.
It
took
several
investigations
from
1991
to
1999
to
identify
the
cause
of
the
problem
and
develop
a
solution.
Through
this
research,
the
company
found
that
the
lower
methyl
bromide
rates
were
not
effective
at
killing
the
Erwinia
in
the
chrysanthemum
crowns
left
in
the
soil.
Since
this
is
a
nursery
operation
cutting
and
selling
cuttings
from
the
field
for
propagation
 
systemic
infections
cannot
be
tolerated
and
higher
dosage
rates
of
methyl
bromide
were
the
only
effective
way
of
being
able
to
guarantee
the
cuttings
met
certification
requirements.

The
company
growing
chrysanthemums
has
already
minimized
their
methyl
bromide
use/
emissions
by
converting
30%
of
their
production
to
steam.

For
roses,
the
association
has
made
historical
efforts
to
reduce
emissions
and
to
reduce
methyl
bromide
dosages
that
are
further
detailed
in:
"
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates."
This
section
demonstrates
notable
success
in
the
United
States
at
efficiently
using
methyl
bromide
at
low
dosages
with
emission
control
technologies
to
control
key
pests.
As
the
2002
MBTOC
report
states,
"
in
some
countries
(
e.
g.,
the
USA)
the
potential
for
reducing
methyl
bromide
dosages
for
soil
fumigation
compared
to
many
other
countries
will
be
less
because
dosages
are
already
low."

For
both
chrysanthemums
and
roses,
the
growers
have
routinely
used
plastic
tarpaulins
since
the
1980s
to
reduce
methyl
bromide
emissions
and
maximize
methyl
bromide
effectiveness.
They
have
continued
their
efforts
to
try
to
maximize
each
quantity
of
methyl
bromide,
using
formulations
of
methyl
bromide
plus
chloropicrin
with
lower
methyl
bromide
proportions
and
continued
testing
of
virtually
impermeable
film
(
VIF)
tarps.
The
difficulties
and
impediments
in
adopting
VIF
tarps
are
being
investigated
in
the
U.
S.
and
are
described
in
the
section
below
titled,
"
Virtually
Impermeable
Film
(
VIF)
Tarps."
The
U.
S.
CUE
nomination
has
already
accounted
for
the
use
of
reduced
methyl
bromide
dosages
and
emission
control
technologies
and
therefore
does
not
need
to
be
recalculated.
Page
6
TABLE
3.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
ORNAMENTAL
SECTOR*.

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

1997
608
248,339
660
1998
608
245,979
650
1999
608
239,934
649
2000
608
257,622
693
2001
611
256,125
687
Ornamental
acres
planted
in
U.
S.
are
not
available.
Request
represents
90%
of
the
chrysanthemum
propagation
material
and
60%
of
roses.

TABLE
4.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
ORNAMENTAL
SECTOR.

Calculation
of
Nominated
Amount
0018
 
California
Cut
Flower
Commission
Application
Withdrawn
0020
 
Yoder
Brothers
0028
 
California
Rose
Growers
Rep.
By
the
Garden
Rose
Council
Hectares
(
ha)
 
35
680
%
of
Regional
hectares
(
ha)(
A)
 
N/
A
N/
A
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
 
31,593
235,868
Double
Counted
hectares
(
ha)(
B)
 
0
0
Growth
/
Increasing
Production
(
ha)(
C)
 
(
6)
34
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
 
28
581
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
 
7
65
Key
Pest
Impacts
(%)(
F)
 
100
0
Regulatory
Impacts
(%)(
G)
 
0
100
(
Q)

Soil
Impacts
(%)(
H)
 
0
0
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
 
100
100
Qualifying
Area
(
ha)(
J)
 
7
65
Use
Rate
(
kg/
ha)(
K)
 
892
347
CUE
Amount
Nominated
(
kg)(
L)
 
6,319
22,393
%
Reduction
from
Initial
Request
(
M)
 
80
90
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
28,711
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
29,412
Page
7
Footnotes
for
Table
4:

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.
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
methyl
bromide.
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.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
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
is
the
percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
methyl
bromide
alternatives.
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
that
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
is
typically
based
on
historical
averages.
In
some
cases,
the
use
rate
has
been
adjusted
downward
to
reflect
current
conditions.
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.
Q.
The
exact
California
regulatory
impacts
are
not
known
precisely,
but
in
Kern
County
alone
1732
hectares
will
be
over
the
township
cap
(
185342
kg
over
Kern
cap
/
107
kg/
ha
nursery
rate
=
1732
hectares
potentially
over
cap
for
all
crops)
from
Carpenter
et
al
2001.
Page
8
HISTORICAL
EMISSION
REDUCTIONS
&
METHYL
BROMIDE
DOSAGE
RATES
For
California
rose
growers
,
the
methyl
bromide
dosage
rate
under
HDPE
tarped
beds
in
1997
was
33
g/
m2.
By
2002,
the
methyl
bromide
dosage
rate
under
HDPE
tarped
beds
had
dropped
to
31
g/
m2.
The
MB+
Pic
formulations
are
generally
injected
about
25
centimeters
below
the
soil
surface
in
a
broadcast
application
before
the
area
is
tarped.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
formulation
to
a
lower
formulations,
such
as
75:
25
and
67:
33
and
to
lower
overall
application
rates
of
these
formulations.

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.)


Both
landfilling
and
burning
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
methyl
bromide
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.


European
firms
are
unlikely
to
make
the
investment
necessary
to
ensure
a
viable
supply
of
Page
9
adequate
VIF
tarps
to
U.
S.
farmers
before
the
2005
phaseout
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
methyl
bromide
fumigation)

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,
cited
below,
supplemented
by
discussions
with
Dr.
Trout
to
ensure
that
any
Page
10
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.

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
Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3­
D
will
Impact
Adjustment
to
Methyl
Bromide
Phase­
out.
California
Agriculture,
Volume
55,
Number
3.
Page
11
Attachment
regarding
Yoder
Brothers
Application
This
document
summarizes
the
research
and
investments
conducted
by
this
applicant,
a
large
horticultural
firm
specializing
in
the
production
of
starter
plants,
to
transition
to
steam
sterilization.
The
applicant
submitted
a
detailed
attachment
that
the
United
States
will
forward
to
MBTOC
if
more
information
is
required.
In
the
interest
of
brevity
we
have
summarized
that
information
here.

Currently
the
facility
uses
steam
on
30%
of
its
acreage,
but
because
of
high
investment
and
capital
costs
associated
with
this
methyl
bromide
alternative,
it
is
estimated
that
the
transition
will
take
approximately
5­
6
years.
This
plan
is
consistent
with
the
Technical
and
Economic
Assessment
Panel's
Handbook
on
Critical
Use
Exemptions
for
Methyl
Bromide;
Section
3.1.1,
no.
17,
which
requires
a
"
Plan
to
switch
to
alternatives:
Provide
a
plan
to
switch
to
non­
MB
alternatives
in
the
near
future
for
MB
use
for
which
a
critical
exemption
is
sought."

During
the
1990s,
Erwinia
soft
rot
had
severely
damaged
the
quality
of
chrysanthemum
cuttings.
Between
1994­
95,
Erwinia
incidence
ranged
from
30%­
100%,
according
to
data
provided
by
the
company
based
on
internal
audits.
Plant
pathology
researchers
eventually
learned
that
the
primary
source
of
infection
was
infested
crop
debris,
and
the
problem
has
successfully
been
controlled
through
the
appropriate
use
of
methyl
bromide
or
steam
sterilization
to
decontaminate
debris
that
remains
in
ground
beds
when
a
crop
is
discarded.

Reduced
Dosage
Rates
of
Methyl
Bromide
The
applicant
has
attempted
to
reduce
the
formulation
of
active
ingredient
methyl
bromide
from
99.5:.
5
to
75:
25
(
chloropicrin).
The
following
summarizes
the
research
trials
conducted
to
achieve
a
lower
dosage
rate
while
controlling
the
target
pests.
However,
the
applicant
is
unable
to
use
25%
chloropicrin
because
of:
 
The
high
rate
of
chloropicrin
needed
to
control
soilborne
fungi
(
125
lbs/
acre)
causes
unacceptable
injury
to
crops
in
adjacent
production
areas.
 
Severe
phytotoxicity
resulted
in
adjacent
untreated
fields.
 
Worker
safety
was
compromised,
as
several
employees
sought
first
aid
treatment
after
working
in
non­
treated
areas
near
the
25%
application.
 
Chloropicrin
does
not
provide
effective
control
of
nematodes
and
many
U.
S.
states
require
stock
be
certified
as
nematode­
free.

Date
Results
1/
25/
99
Damage
up
to
12
beds
away
(
19meteres)
2/
11/
99
Damage
up
to
14
beds
away
(
23meteres)
2/
18/
99
Damage
up
to
17
beds
away
(
28meteres)
3/
1/
99
Damage
up
to
18
beds
away
(
31meteres)
3/
18/
99
Damage
7
beds
away
(
11
meteres)

The
significant
damage
to
other
beds
outside
the
treatment
area,
and
worker
protection
issues,
render
further
dilution
infeasible.
Page
12
Investments
made
in
alternatives
to
methyl
bromide
In
addition
to
research
efforts
directed
at
dosage
reduction,
the
company
has
also
made
significant
investments
in
its
planned
transition
to
steam
sterilization.
The
following
is
a
list
of
investments
made
for
the
transition
to
steam
sterilization,
from
1992­
present.

Type
of
Equipment
Cost
(
USD)
Boilers
$
629,322
Blankets/
hood
$
92,560
Pipes/
hoses
$
10,000
Additional
equipment
(
locks,
chains,
etc.)
$
19,200
Fuel
$
61,800
Labor
$
166,400
TOTAL:
$
981,502
Other
alternative
trial
work:

Alternative
Cost
(
USD)
Basamid
$
4,000
MC­
25
$
5,000
Sectagon
$
1,000
VIF
$
1,000
MIDAS
$
1,000
TOTAL:
$
12,000
This
brings
the
applicant's
total
investment
in
methyl
bromide
alternatives
to
$
1,005,502.00.
An
additional
investment
of
$
1.1
million
USD
in
capital
equipment
is
required
to
expand
steam
technology
to
the
entire
production
area,
and
time
is
needed
to
raise
monies
for
this
venture.
In
addition,
operating
costs
are
expected
to
rise
by
as
much
as
45%.
Nonetheless,
the
applicant
remains
committed
to
this
transition,
but
needs
interim
availability
of
some
methyl
bromide
in
order
to
successfully
complete
the
change.
