1
U.
S.
A.
CUN2003/
058
­
PEPPERS
 
FIELD
PEPPERS
GROWN
OUTDOORS
ON
PLASTIC
MULCH
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide...............................................................................................
3
Economic
Impacts.......................................................................................................................
3
Response
to
Questions
From
MBTOC/
TEAP..............................................................................
5
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates
............................................
14
Virtually
Impermeable
Film
(
VIF)
Tarps
..................................................................................
15
Market
Window
Information.....................................................................................................
16
Definitions
................................................................................................................................
18
References
................................................................................................................................
19
LIST
OF
TABLES
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
..........................................
3
Table
2.
MEASURES
OF
ECONOMIC
IMPACT
OF
USING
1,3­
DICHLOROPROPENE
+
CHLOROPICRIN
IN
PLACE
OF
METHYL
BROMIDE
ON
BELL
PEPPERS
IN
THE
U.
S.
IN
AREAS
OF
MODERATE
TO
SEVERE
PEST
PRESSURE.
........................................................................................................................................
4
Table
3.
Measures
of
Economic
Impact
of
Using
Metam­
Sodium
in
Place
of
Methyl
Bromide
on
Bell
Peppers
in
the
U.
S.
...........................................................................................................................
5
TABLE
4.
METHYL
BROMIDE
ALTERNATIVES
IN
A
BELL
PEPPER
SQUASH
ROTATION
IN
1998­
99
.............
6
Table
5.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
(
Locascio
et
al.,
1997
.................................................................................................................................................
6
Table
6.
Historical
Use
of
Methyl
Bromide
in
the
Peppers
Sector..........................................................
10
Table
7.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Peppers
Sector
.....................
11
Table
8.
HERBICIDES
REGISTERED
IN
THE
UNITED
STATES
TO
CONTROL
NUTSEDGE
IN
CUCURBITS,
FRUITING
VEGETABLES,
AND
STRAWBERRIES
.................................................................................
13
2
INTRODUCTION
The
U.
S.
CUE
requested
methyl
bromide
(
MB)
for
field
grown
peppers
because
there
are
no
feasible
alternatives
available
for
moderate
to
severe
pest
pressure.
The
pests
of
most
concern
are:
diseases,
weeds,
and
nematodes
in
the
Southeastern
U.
S.,
Georgia,
and
Florida,
and
Phytophthora
capsici
and
nematodes
in
California
(
see
Table
1).
The
use
of
alternatives
is
also
restricted
by
regulatory
measures
taken
at
state
or
local
levels
(
e.
g.,
buffers
and
township
caps)
and
the
infeasibility
of
using
alternatives
in
karst
topography
in
Florida.
Economic
impacts
from
using
alternatives
are
aggravated
by
plant­
back
restrictions
that
may
cause
farmers
to
miss
high
value
market
windows
(
see
Market
Window
Information).

Because
of
these
factors,
alternatives
are
not
feasible
in
those
areas
requested
by
the
U.
S.
pepper
sector
for
the
continued
use
of
methyl
bromide.
Both
non­
chemical
and
chemical
alternatives
have
been
or
are
being
investigated
and
when
suitable,
incorporated
into
current
production
practices.
MB
will
be
needed
until
a
cost­
effective
alternative
regimen
is
in
place.
Since
MB
has
been
used
effectively
to
manage
minor
crop
production,
there
are
limited
pesticide
alternatives
due
primarily
to
the
small
market
share
and
the
high
cost
associated
with
pesticide
registration.
Registration
of
these
products
in
minor
crops
could
be
more
expensive
than
returns
from
potential
sales,
and
therefore
pesticide
manufactures
have
been
reluctant
to
register
pesticides
for
minor
crop
uses.

Nutsedge
management
has
proven
to
be
difficult
due
to
the
perennial
growth
habit
of
nutsedge
and
tubers
as
primary
means
of
propagation.
In
Georgia,
nutsedge
has
been
identified
as
the
most
troublesome
weed
in
vegetable
crops
and
viable
alternatives
have
not
been
identified.

In
Florida,
the
North
American
Vegetable
Model
was
used
to
estimate
impacts
of
a
ban
of
MB
for
pepper
production,
assuming
that
growers
switch
to
an
in­
row
application
of
1,3­
D
+
17%
chloropicrin
and
napropamide.
Pepper
yield
declines
of
10
to
25%
were
predicted
for
the
West
Central
and
Palm
Beach
areas.
Yield
losses
in
Dade
County
were
predicted
at
15
to
30%.
Other
areas
were
not
considered
to
use
MB
predominately
for
pepper
production.
Use
of
MB
will
be
needed
until
appropriate
combination
of
fumigants
and
herbicides
is
developed
for
areas
of
the
state
where
high
weed
and
disease
pressure
require
the
broad
spectrum
action
of
MB,
and
until
the
most
effective
delivery
systems
for
potential
alternatives
are
determined.
Yield
losses
in
Georgia
and
the
Southeast
are
considered
to
be
in
the
20%
range
and
California
yield
loss
estimates
are
for
a
5%
loss.
3
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE.

Region
Key
Pests
Critical
Need
for
Methyl
Bromide
California
Pepper
Commission
(
CUE02­
0017)
Diseases:
Phytophthora
blight
(
Phytophthora
capsici)

Nematodes:
Root­
knot
(
Meloidogyne
spp.)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
one
region
in
California.
Uses
of
alternatives
are
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
amount
of
1,3­
dichloropropene
that
can
be
used.
MB
applications
in
peppers
are
typically
made
using
67:
33
with
chloropicrin
under
plastic
mulch.

Southeastern
Peppers
Consortium
(
CUE
02­
0041)
(
Alabama,
Arkansas,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia)

Georgia
Fruit
and
Vegetable
Growers
Association
 
Peppers
(
CUE
02­
0049)

Florida
Fruit
and
Vegetable
Growers
Association
 
Peppers
(
CUE
02­
0054)
Diseases:
Phytophthora
blight
(
Phytophthora
capsici),
Pythium,
Phomopsis,
Rhizoctonia,
Sclerotinia,
Verticillium
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
Cyperus
rotundus
L.)

Nematodes:
Root­
knot
(
Meloidogyne
spp.)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
southeast
U.
S.
In
Florida,
the
use
of
alternatives
is
further
limited
by
the
presence
of
karst
topography
and
to
a
limited
extent
by
regulatory
constraints
such
as
buffers.
MB
applications
in
peppers
are
typically
made
using
67:
33
or
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.

ECONOMIC
IMPACTS
In
order
to
determine
whether
a
proposed
alternative
to
MB
is
considered
to
be
`
economically
feasible'
for
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
five
measures
was
assessed.
The
five
measures
selected
for
consideration
were:
loss
per
hectare;
loss
per
kilogram
of
MB;
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
MB
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.
4
Results
of
the
economic
evaluation
of
the
top
two
alternatives:
1,3­
dichloropropene
+
chloropicrin
and
1,3­
dichloropropene
+
metam­
sodium
are
presented
in
Tables
2
and
3.
Economic
losses
per
kilogram
of
MB
are
a
measure
of
the
marginal
contribution
of
MB.
Comparing
these
losses
provides
a
rough
measure
of
the
loss
in
economic
efficiency
associated
with
adoption
of
MB
alternatives.
Under
this
measure,
all
pepper
production
areas
suffer
efficiency
losses.
The
measures
of
gross
revenue
and
net
revenue
also
show
that
adoption
of
the
two
alternatives
pest­
control
regimes
in
all
pepper
production
areas
would
lead
to
substantial
declines
in
the
growers'
economic
profitability.
Given
the
competitive
nature
of
vegetable
production
in
the
U.
S.,
these
economic
impacts
render
the
use
of
alternatives
economically
infeasible
for
U.
S.
pepper
producers
in
areas
of
moderate
to
severe
pest
pressure.

Table
2.
MEASURES
OF
ECONOMIC
IMPACT
OF
USING
1,3­
DICHLOROPROPENE
+
CHLOROPICRIN
IN
PLACE
OF
METHYL
BROMIDE
ON
BELL
PEPPERS
IN
THE
U.
S.
IN
AREAS
OF
MODERATE
TO
SEVERE
PEST
PRESSURE.

Loss
Measure
Florida
(
CUE
02­
0054)
Southeast
(
CUE
02­
0041)
Georgia
(
CUE
02­
0049)
California
(
CUE02­
0017)

Direct
yield
loss
20%
loss
20%
loss
20%
loss
5%
loss
(
higher
if
township
caps
and
buffers
limit
use
of
1,3­
D)

Change
in
production
costs
$
170/
ha
reduction
in
operating
costs
(
assuming
similar
to
CA)
$
170/
ha
reduction
in
operating
costs
(
assuming
similar
to
CA)
$
170/
ha
reduction
in
operating
costs
(
assuming
similar
to
CA)
$
170/
ha
reduction
in
operating
costs
1%
of
operating
costs
Economic
loss
per
hectare
$
6180
$
2064
$
2064
$
830
Economic
loss
per
kg
of
MB
$
20.02
$
6.69
$
6.69
$
4.15
Economic
loss
as
percent
of
gross
revenues
19%
18%
18%
4%

Economic
loss
as
percent
of
net
cash
revenues
unavailable
unavailable
unavailable
80%
loss
Note:
1
All
calculations
are
based
on
2001
NASS
and
California
information.
2
Production
cost
information
for
Florida,
Southeast,
and
Georgia
was
estimated
using
California
crop
budget
information.
5
Table
3.
MEASURES
OF
ECONOMIC
IMPACT
OF
USING
METAM­
SODIUM
IN
PLACE
OF
METHYL
BROMIDE
ON
BELL
PEPPERS
IN
THE
U.
S.

Loss
Measure
Florida
(
CUE
02­
0054)
Southeast
(
CUE
02­
0041)
Georgia
(
CUE
02­
0049)
California
(
CUE02­
0017)

Direct
yield
loss
30%
loss
20%
loss)
20%
loss
8%
loss
(
higher
if
township
caps
and
buffers
limit
use
of
1,3­
D)

Change
in
production
costs
$
1065/
ha
(
assuming
similar
to
CA)
$
1065/
ha
(
assuming
similar
to
CA)
$
1065/
ha
(
assuming
similar
to
CA)
$
1065/
ha
6%
of
operating
costs
Economic
loss
per
hectare
$
10591
$
4417
$
4417
$
2,666
Economic
loss
per
kg
of
MB
$
31.30
$
14.31
$
14.31
$
14.02
Economic
loss
as
percent
of
gross
revenues
33%
40%
40%
13%

Economic
loss
as
percent
of
net
cash
revenues
unavailable
unavailable
unavailable
250%
loss
Note:
1
All
calculations
are
based
on
2001
NASS
and
California
information.
2
Production
cost
information
for
Florida,
Southeast,
and
Georgia
was
estimated
using
California
crop
budget
information.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
detail
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
7.

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
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
incorporates
minimum
efficacious
use
rates,
mixtures
of
MB
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.
6
2.
Also
to
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
U.
S.).

A
list
of
herbicides,
with
some
activity
against
nutsedge
species
currently
registered
for
U.
S.
peppers
is
provided
in
Table
8
(
information
from
herbicide
labels
and
personal
communication
with
Dr.
Stanley
Culpepper,
Extension
Agronomist
and
Weed
Scientist
University
of
Georgia).
None
of
these
herbicides
provide
adequate
control
of
nutsedge
in
areas
of
high
pest
pressure.

The
study
shown
in
Table
4
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
4.
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%

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
growing
through
the
crop
hole.
Note:
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability.

In
addition
to
the
comparative
data
for
peppers,
there
are
also
relevant
data
for
yield
loss
in
other
solanaceous
crops.
Comparative
data
for
tomatoes
also
demonstrates
significant
yield
losses.

TABLE
5.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.,
1997
Chemicals
Rate
(/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Nontreated
­
300
a­
c
20.1
f
59.1%

MeBr
+
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%

Note:
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability.
7
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
steps
to
calculate
the
nominated
amount
are
shown
in
Table
7,
and
the
details
of
the
reasoning
and
assumptions
and
the
citations
for
these
conclusions
are
explained
in
the
footnotes
following
the
table,
as
well
as
in
the
responses
to
Question
1,
4
and
5.

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
by
pepper
growers
to
reduce
emissions
and
to
reduce
MB
dosages
described
in
the
section
below
titled,
"
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates."
Tables
6
and
7
demonstrate
notable
success
in
the
U.
S.
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."

Growers
requesting
this
exemption
have
routinely
used
plastic
tarpaulins
since
the
1980s
to
reduce
MB
emissions
and
maximize
MB
effectiveness.
Recent
efforts
have
continued
to
try
to
maximize
each
quantity
of
MB,
using
formulations
of
MB
plus
chloropicrin
with
lower
MB
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.
nomination
is
calculated
based
on
most
growers
continuing
to
use
a
67:
33
mixture
of
MB
with
chloropicrin.
Recalculation
of
the
nomination
was
not
performed
because
the
original
U.
S.
nomination
had
already
accounted
for
these
factors.

5.
The
Party
is
asked
to
provide
detail
on
why
key
alternatives
reported
by
MBTOC,
e.
g.
1,3­
D/
Pic,
are
not
effective
alternatives.

Alternatives
such
as
1,3­
D
with
chloropicrin
and
with
metam
sodium
are
currently
used
and
found
suitable
by
many
pepper
growers
in
the
United
States.
The
U.
S.
nomination
requests
MB
only
for
those
areas
where
alternatives
are
not
suitable
(
e.
g.
where
there
is
moderate
to
severe
nutsedge
or
Phytophthora
pressure,
or
where
there
are
regulatory
and
soil
restrictions).
Table
8
provides
additional
details
on
why
alternative
herbicides
are
not
considered
suitable
or
effective.

The
combination
of
1,3­
D
and
chloropicrin
has
shown
activity
in
suppressing
weeds,
but
control
of
nutsedge
has
not
been
as
consistent
or
as
effective
as
methyl
bromide
in
pepper
production
(
Webster
et
al.,
2001).
When
nutsedge
pressure
is
moderate
to
severe,
1,3­
D
+
chloropicrin
is
not
technically
feasible
because
it
needs
to
be
coupled
with
an
effective
herbicide
to
provide
season
long
control.
Currently,
there
are
no
herbicides
efficacious
against
nutsedge
registered
in
the
U.
S.
for
areas
of
moderate
to
8
severe
nutsedge
infestation.

A
bell
pepper­
squash
rotation
field
study
with
chisel
injected
applications
of
1,3­
D
+
chloropicrin
resulted
in
yield
losses
ranging
from
0
to
40
percent
compared
to
MB
(
see
Table
5).
However,
by
the
end
of
the
season,
only
MB
treatments
effectively
controlled
nutsedge
(
Webster
et
al.,
2001).
In
addition,
interviews
with
growers
reported
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
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
(
pebulate
is
not
registered
in
the
United
States
at
this
time)
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).

In
the
above
studies,
1,3­
D
+
chloropicrin
treatments
did
not
adequately
control
moderate
to
severe
nutsedge
infestations,
and
yield
losses
occurred
when
compared
to
MB
plus
chloropicrin
treatments.
Additional
research
on
this
alternative
to
demonstrate
efficacy
against
nutsedge
is
needed
in
areas
with
moderate
to
severe
nutsedge
pressure.
Lack
of
an
effective,
registered
herbicide
impairs
adoption
in
crops
such
as
pepper
(
Banks,
2002).

Information
from
California,
Michigan,
and
the
Southern
U.
S.
demonstrates
that
1,3­
D
+
chloropicrin
does
not
adequately
control
Phytophthora
under
their
conditions.
Research
in
Phytophthora
infested
fields
by
Goldy
et
al
2000
with
transplanted
peppers
showed
a
significant
reduction
in
harvest
weight
(
32
%
loss)
and
number
of
number
one
fruit
(
38%
loss)
when
comparing
methyl
bromide/
chloropicrin
to
1,3­
D/
chloropicrin
(
Telone
C­
35
EC).
Phytophthora
blight
is
one
of
the
most
destructive
diseases
and
there
are
few
effective
control
measures.
Resistance
to
metalaxyl
has
been
documented
in
the
United
States
for
Phytophthora
species.

Other
constraints
for
substituting
1­
3­
D
for
MB
include
soil
limitations,
township
caps,
buffer
zone
requirements,
and
worker
exposure
safeguards
(
EPA,
1998).
1,3­
D
is
restricted
in
key
pepper
growing
areas
of
the
U.
S.
which
have
soils
underlain
by
karst
topography
and
sandy
(
porous)
sub­
soils,
geological
features
that
could
lead
to
ground­
water
contamination.
Approximately
40
percent
of
Florida's
pepper
production
land
is
in
areas
facing
these
soil
constraints
(
Table
7).
Hence,
1,3­
D
is
prohibited
in
key
growing
areas
like
Dade
County,
Florida,
where
about
1,300
hectares
of
peppers
are
grown
each
year.
(
See
the
Reregistration
Eligibility
Decision
(
RED)
for
this
chemical;
available
on
the
Internet
at:
http://
www.
epa.
gov/
REDs/
0328red.
pdf).
9
Current
restrictions
in
the
State
of
California
limit
total
1,3­
D
use
within
93.32­
squarekilometer
areas
(
36­
square­
mile­
areas),
known
as
townships.
This
(
maximum)
amount
depends
on
the
depth
and
timing
of
the
applications,
with
a
total
of
40,936.7
kg
(
90,250
lb)
per
township
allowed
if
applications
are
made
to
a
depth
greater
than
45.72
cm
(
18
inches)
between
February
and
November.
The
limit
is
reduced
if
applications
are
made
at
shallow
depths
or
during
December
or
January.
Applied
at
160
kg/
H
(
140
lbs/
A)
a
maximum
of
261
H
(
645
A)
per
township,
just
under
3%
of
a
township's
hectares,
may
be
legally
fumigated
with
1,3­
D
in
a
year
Adoption
of
1,3­
D
is
hindered
for
some
farms
because
of
use
restrictions
that
require
buffer
zones
between
the
treated
area
and
inhabited
structures.
In
areas
where
1,3­
D
use
is
allowed,
set
back
restrictions
(~
100
meters
from
occupied
structures;
~
30
meters
for
emulsified
formulations
applied
via
chemigation)
may
limit
the
area
that
can
be
treated
with
this
MeBr
alternative.
Highly
restrictive
personal
protective
equipment
(
PPE)
requirements
for
1,3­
dichloropropene
applications,
that
limit
the
feasibility
of
use
in
the
very
warm
and
humid
climate
of
the
southeastern
U.
S.
during
the
typical
pepper­
growing
season.
For
example,
these
PPE
restrictions
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
usually
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity
rapidly
become
unbearable
for
a
typical
applicator.
Although
these
requirements
have
recently
been
eased
somewhat
so
that
fewer
people
are
subject
to
use
the
full
complement
of
PPE,
workers
who
come
in
close
contact
with
the
liquid
formulation
must
still
wear
heavy
layers
of
protective
equipment,
as
described
above.
These
buffer
zone
restrictions
are
expected
to
limit
1,3­
D
use
in
about
1
percent
of
Florida's
pepper
production
area.
(
U.
S.
EPA,
1998).

Additionally,
a
3­
week
time
interval
before
planting
is
recommended
to
avoid
phytotoxic
levels
after
1,3­
D
application.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
fetch
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.

6.
The
Party
is
requested
to
review
Table
8
of
the
CUN.
It
states
224.
t
MB
were
used
for
peppers
in
California
in
2001,
whereas
PUR
data
reports
only
63.9
t
MB
was
used
in
2001,
or
73.9t
total
if
spice
peppers
are
included
(
Trout
2003).
Some
adjustment
of
the
nominated
quantity
may
be
appropriate.

The
California
Department
of
Pesticide
Regulation
reports
that
63,546.8
kg
or
63.5
metric
tons
(
140,120.6
lb)
of
MB
were
applied
to
fruiting
peppers
in
2001.
The
report
also
indicates
that
9,641.2
kg
or
9.6
metric
tons
(
21,258.8
lb)
were
applied
to
spice
pepper
during
that
same
year
(
Cal
DPR,
2001).
However,
approximately
340,500
kg
or
340
metric
tons
(
750,000
lb)
are
listed
as
preplant
use
and
are
not
directly
linked
to
any
crop.
After
careful
review
of
the
available
data
and
consulting
with
regional
experts,
we
have
concluded
that
some
of
the
pepper
hectares
were
classified
as
unspecified
preplant.
There
is
no
need
to
adjust
the
U.
S.
nomination
for
this
sector
since
the
original
U.
S.
nomination
of
224
t.
is
critically
needed
to
address
those
areas
where
there
are
no
technically
or
economically
viable
alternatives.
10
7.
MBTOC
notes
that
a
number
of
alternatives
are
in
commercial
use
for
this
crop
and
seeks
further
information
on
the
applicability
of
these
alternatives,
noting
that
the
availability
may
be
restricted
by
local
regulations.

See
the
response
above
to
MBTOC/
TEAP
question
5.

TABLE
6.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
PEPPERS
SECTOR*.

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

1997
209
2,307,214
12,035
1998
215
2,290,736
11,782
1999
181
2,347,378
12,766
2000
160
2,062,858
12,747
2001
183
2,252,633
12,632
*
Peppers
acres
planted
in
U.
S.:
58,500
(
23,674
ha).
Percent
of
U.
S.
peppers
hectares
requested:
54%.
Source:
Rates,
amounts,
and
area
treated
are
from
applicant's
information.
Percent
of
U.
S.
hectares
is
from
U.
S.
DA,
2001.
National
Agricultural
Statistics
Service,
Agricultural
Statistics
2001
11
Table
7.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
PEPPERS
SECTOR.

Calculation
of
Nominated
Amount
0017
 
California
Peppers
0041
 
Southeastern
Peppers
0049
 
Georgia
 
Peppers
0054
 
Florida
 
Peppers
Hectares
(
ha)
1,012
749
2,252
8,741
%
of
Regional
hectares
(
ha)(
A)
11
23
88
135
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
181,437
112,445
338,248
1,371,662
Double
Counted
hectares
(
ha)(
B)
0
0
0
0
Growth
/
Increasing
Production
(
ha)(
C)
121
0
0
0
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
0
0
0
0
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
891
749
2,252
8,741
Key
Pest
Impacts
(%)(
F)
100
100
30
30
Regulatory
Impacts
(%)(
G)
45
0
0
1
Soil
Impacts
(%)(
H)
0
0
0
40
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
30
50
Qualifying
Area
(
ha)(
J)
890
749
676
4,371
Use
Rate
(
kg/
ha)(
K)
179
150
150
157
CUE
Amount
Nominated
(
kg)(
L)
159,664
112,445
101,474
685,832
%
Reduction
from
Initial
Request
(
M)
12
0
70
50
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
1,059,415
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
1,085,265
12
Footnotes
for
Table
7:

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
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.
One
applicant
requested
growth.
This
amount
was
removed
from
the
nomination.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
There
was
no
quarantine
or
pre­
shipment
request
in
this
sector.
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.
In
California
the
key
pest
is
Phytophthora
and
root
knot
nematode;
for
the
remaining
applicants
in
this
sector
the
key
pests
are
Phytophthora
and
nutsedge.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
A
small
impact
due
to
buffers
to
inhabited
structures
is
assumed
for
Florida.
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).
For
Florida,
40%
of
the
hectares
where
peppers
are
grown
have
karst
topography
and
1,3­
D
cannot
be
used
due
to
potential
for
groundwater
contamination.
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.
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
U.
S.
nomination
(
i.
e.,
using
the
lowest
percent
impact
on
the
lowest
number
of
hectares
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
summed
sector
nominations
by
the
margin
of
error
multiplier.
13
Table
8.
HERBICIDES
REGISTERED
IN
THE
UNITED
STATES
TO
CONTROL
NUTSEDGE
IN
CUCURBITS,
FRUITING
VEGETABLES,
AND
STRAWBERRIES
Herbicide
U.
S.
Registration
Status*
Major
Comments
Halosulfuronmethyl
Yes
Plant
back
restrictions
exist
(
see
notes
below),
potential
crop
injury
Pebulate
No
Registration
lapsed,
not
available
for
growers,
registration
lapsed
December
31,
2002
S­
metolachlor
Yes
Registered
ONLY
in
tomato;
suppression
of
yellow
nutsedge,
no
activity
on
purple
nutsedge
Glyphosate
Yes
Suppression
of
nutsedge
only,
row
middle
application
only,
no
residual
weed
activity,
limited
use
because
of
potential
drift
to
crop
from
row
middle
application,
crop
injury
from
drift
can
be
severe
Paraquat
Yes
Poor
nutsedge
control,
row
middle
application
only,
no
residual
weed
activity
Terbacil
No
Registered
ONLY
in
strawberries,
plant
back
restrictions
exist,
registrant
claims
ONLY
partial
control
of
yellow
nutsedge,
no
activity
on
purple
nutsedge
Rimsulfuron
Yes
Registered
ONLY
in
tomato;
plant
back
restrictions
exist,
registrant
claims
ONLY
partial
control
of
yellow
nutsedge,
no
activity
on
purple
nutsedge
Trifloxysulfuron
No
Registration
pending
ONLY
in
tomato,
FL
only,
Third
Party
Registration
likely
required,
crop
injury
issues
exist
*
Yes:
Registered
for
use;
No:
Not
registered
for
use
Additional
notes
on
specific
herbicides
listed:
Halosulfuron­
methyl:
Halosulfuron
obtained
registration
for
SPECIFIC
uses
in
tomato,
pepper,
eggplant,
and
cucurbits
during
December
of
2002.
This
recent
registration
was
not
on
the
list
of
alternatives
from
MBTOC
and
several
years
are
required
to
determine
grower
acceptance.
There
are
several
limitations
to
halosulfuron
which,
when
combined,
may
limit
its
technical
feasibility
and
adoption
by
growers
in
the
U.
S..
These
include
the
following:
 
Application
for
pepper,
eggplant,
and
squash
is
for
ROW
MIDDLE
application
only
and
would
provide
no
control
of
nutsedge
in
the
pepper
bed
where
competition
from
nutsedge
is
most
critical.
 
This
herbicide
has
plant
back
restrictions
from
3
to
36
months
for
most
vegetables.
Additionally,
most
of
the
vegetable
crops
fall
within
the
9
to
36
month
range.
These
plant
back
restrictions
clearly
limit
the
use
of
this
product.
 
Not
all
hybrids/
varieties
have
been
tested
for
sensitivity
to
halosulfuron­
methyl.
Halosulfuron
may
also
delay
maturity
of
treated
crops.
 
Excessive
amounts
of
water
(
greater
than
2.54
cm)
soon
after
a
preemergent
application
may
cause
crop
injury.
Rainfall
within
four
hours
after
a
postemergence
application
may
also
reduce
effectiveness.
Sudden
storms
with
greater
than
2.54
cm
of
rainfall
are
not
uncommon,
especially
in
the
southeastern
U.
S..
 
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
U.
S.
registration
label
for
halosulfuron,
which
in
turn
is
based
on
proprietary
data
submitted
to
EPA
by
the
registrant
company.
14
Glyphosate:
Glyphosate
is
a
non­
selective
herbicide
that
usually
only
suppresses
nutsedge
development.
Additionally,
glyphosate
provides
no
residual
weed
control
and
repetitive
applications
would
be
required
to
manage
nutsedge.
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.
Pebulate:
Pebulate
is
no
longer
registered
for
use
in
the
U.
S.
Growers
cannot
obtain
this
herbicide.
Rimsulfuron:
Registrant
claims
only
suppression
of
yellow
nutsedge.
Research
supports
registrants'
claim
(
11).
Does
not
suppress
development
of
purple
nutsedge.
Tank
mixing
with
organophosphate
insecticides
may
cause
crop
injury.
Plant
back
restrictions
are
12
months
or
greater
for
many
vegetable
crops.
S­
Metolachlor:
Registered
for
use
in
tomato
during
2003.
S­
Metolachlor
applied
under
plastic
mulch
offers
only
suppression
of
yellow
nutsedge
development.
It
does
not
impact
purple
nutsedge
development
or
control
nightshade
species.
Both
nutsedge
species
are
present
in
most
vegetable
fields.
Further
work
is
required
to
address
potential
crop
tolerance
issues
with
this
new
tomato
label.

HISTORICAL
EMISSION
REDUCTIONS
&
METHYL
BROMIDE
DOSAGE
RATES
All
states/
regions
are
continuing
to
test/
trial
formulations
with
lower
proportions
of
MB,
as
well
as
methods
for
using
higher
barrier
tarps
(
see
VIF
discussion
below).

In
California,
the
soil
injection
of
MB
under
tarps
has
increased
from
approximately
68%
of
the
area
using
this
fumigant
in
1997
to
93%
in
2003.
Methyl
bromide
applications
are
injected
approximately
26
centimeters
below
tarps.
The
current
MB
dosage
rate
under
tarps
is
approximately
26
g/
m2.
This
low
MB
dosage
rate
is
due
in
large
part
to
a
shift
by
all
growers
to
formulations
lower
than
the
98:
2
ratio
that
was
used
in
the
mid­
1990s.

In
the
Southeastern
U.
S.,
the
MB
dosage
rate
under
tarped
beds
in
1997
was
21
g/
m2.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
15
g/
m2.
All
areas
in
the
southeastern
U.
S.
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.

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
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
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
15
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.)


Both
landfilling
and
disposal
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.


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
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
MB
fumigation)
16
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
MB
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,
including
peppers.

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
17
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
tomatoes
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
0
1
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
18
DEFINITIONS
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
hectares
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
the
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
landgrant
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.

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
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
19
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
Banks,
H.
J.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.
Pg
46.

California
Department
of
Pesticide
Regulation.
2002.
Summary
of
Pesticide
Use
Report
Data
2001
­
Indexed
by
Chemical
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.

Environmental
Protection
Agency,
1998.
Reregistration
Eligibility
Decision
(
RED)
1,3
Dichloropropene.
Available
at
http://
www.
epa.
gov/
REDs/
0328red.
pdf
Locascio,
Salvadore
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.
Kucharek,
T.
A.,
Jones,
J.
P.
and
Noling
J.
W.
1997.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
mulched
Tomato.
HortScience,
vol.
32(
7),
1997.

Norton,
Jack,
R.
D.
Nelson,
M.
D.
Nelson,
and
R.
R.
Johnson.
2000.
Field
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Pre­
Plant
Soil
Fumigation
in
Florida
Tomatoes.
USDA
IR­
4
Methyl
Bromide
Alternatives
Program
for
Minor
Crops.

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.
Jour.
Crop
Protection
20:
605­
614
