U.
S.
A.
CUN2003/
063
 
TURFGRASS
TURFGRASS
GROWN
OUTDOORS
AFTER
BROADCAST
FUMIGATION
UNDER
PLASTIC
TARPS
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide................................................................................................
2
Economic
Impacts.......................................................................................................................
3
Response
to
Questions
from
MBTOC/
TEAP...............................................................................
3
Examples
of
Turfgrass
Sod
Certification
Requirements
in
the
U.
S.:
.............................................
5
Definitions...................................................................................................................................
9
References
................................................................................................................................
10
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide.............................................
2
Table
2.
Historical
Use
of
Methyl
Bromide
in
the
Turf
Sector*...................................................
7
Table
3.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Turf
Sector.
...............
7
Page
2
INTRODUCTION
The
United
States
(
U.
S.)
nomination
for
turfgrass
and
golf
courses
(
CUN2003/
063)
is
for
a
critical
need
for
methyl
bromide
(
MB)
associated
with
areas
having
moderate
to
severe
pest
pressure
(
nematodes,
insects,
and
weeds)
(
see
Table
1)
because
there
are
no
technically
feasible
alternatives.
Basamid
(
dazomet)
is
the
sole
alternative
listed
by
MBTOC
as
a
potential
alternative
for
turf
grass
and
sod.
Dazomet
and
metam
sodium
alone
or
in
combinations
with
chloropicrin
for
turf
production
and
sod
installation
fail
to
provide
consistent
control
of
pests.
In
multiple
studies
of
these
alternatives,
across
sectors,
these
chemicals
fail
to
provide
consistent
pest
control
from
one
year
to
the
next.
Dazomet,
metam
sodium,
and
1,3­
dichloropropene
combinations
all
fail
to
provide
full
spectrum
pest
suppression
in
areas
with
moderate
to
heavy
pest
pressures.

CRITICAL
NEED
FOR
METHYL
BROMIDE
MB
is
critically
needed
on
turfgrass
sod
and
golf
courses
to
control
over
15
genera
of
parasitic
nematodes,
several
species
of
scarabaeid
beetle
larvae
(
white
grubs)
and
other
soil
insect
pests,
and
several
weeds,
including
purple
nutsedge,
yellow
nutsedge,
crabgrass,
goosegrass,
common
bermudagrass,
and
turfgrass
from
the
previous
crop
cycle.
These
pests
are
not
adequately
controlled
by
alternatives
in
areas
of
moderate
to
severe
pest
pressure.

TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
U.
S.
State
/
Region
Key
Pests
Critical
Need
for
Methyl
Bromide
Turfgrass
Producers
International
(
CUE
02­
0044)
Nematodes:
over
15
genera
of
parasitic
nematodes,
such
as
lance
nematodes
(
Hoplolaimus
spp.)
and
sting
nematodes
(
Belonolaimus
longicaudatus)

Insects:
white
grubs
(
several
species
of
scarabaeid
beetles)

Weeds:
purple
nutsedge
(
Cyperus
rotundus);
yellow
nutsedge
(
Cyperus
escullentus);
crabgrass
(
Digitaria
spp.);
goosegrass
(
Eleusine
indica);
common
bermudagrass
(
Cynodon
dactylon)
and
turfgrass
from
the
previous
crop
cycle.
At
moderate
to
severe
pest
pressure,
only
MB
can
effectively
control
the
target
pests
found
in
turfgrass
sod
operations.
MB
applications
in
sod
are
typically
made
using
67:
33
mixtures
with
chloropicrin
under
plastic
mulch.
Wherever
feasible,
50:
50
mixtures
are
already
in
use.

Golf
Course
Superintendents
Association
(
CUE
02­
0055)
Nematodes:
over
15
genera
of
parasitic
nematodes,
such
as
lance
nematodes
(
Hoplolaimus
spp.)
and
sting
nematodes
(
Belonolaimus
longicaudatus).

Insects:
soil
pests
(
white
grubs,
ants,
wireworms)

Weeds:
yellow
nutsedge
(
Cyperus
esculentus),
crabgrass
(
Digitaria
spp.),
goosegrass
(
Eleusine
indica),
purple
nutsedge
(
Cyperus
rotundus)
and
common
bermudagrass
(
Cynodon
dactylon).
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
golf
course
operations.
MB
applications
in
golf
courses
are
typically
made
using
67:
33
mixtures
with
chloropicrin
under
plastic
mulch.
Wherever
feasible,
50:
50
mixtures
are
already
in
use.
Page
3
ECONOMIC
IMPACTS
None
of
the
alternatives
were
found
to
be
technically
feasible
for
turfgrass;
therefore
no
economic
analysis
was
conducted.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
disaggregate
quantities
nominated
for
certified
turf
production
and
for
turf
maintenance
on
areas
such
as
golf
courses.

The
data
in
Table
3
disaggregate
the
quantities
of
MB
nominated
for
certified
turf
production
and
for
turf
maintenance
on
areas
such
as
golf
courses.

2.
Additionally
it
is
requested
that
information
be
supplied
on
performance
of
alternatives
compared
to
MB
for
these
applications.
Alternatives
include
dazomet
and
metam
sodium/
chloropicrin.

Dazomet
is
not
a
technically
feasible
alternative
because
it
does
not
provide
consistent
control
of
the
target
pests
shown
in
Table
1
for
either
application
that
is
the
subject
of
this
critical
use
exemption
request.
While
dazomet/
chloropicrin
and
metamsodium
chloropicrin
may
in
some
situations
provide
control
of
some
diseases
and
weeds,
research
data
suggest
that
these
products
cannot
be
relied
on
to
provide
necessary
consistency
of
results
(
Csinos
et
al.,
1997,
Unruh
and
Brecke,
2001,
Unruh
et
al.,
2002).
Specifically,
neither
chemical
consistently
provides
acceptable
control
of
nutsedge
under
moderate
to
severe
pest
pressure
conditions,
off
type
turfgrass,
or
nematodes.
MB
appears
to
be
the
only
treatment
that
consistently
provides
effective
control
of
off­
type
turfgrass,
disease,
and
nutsedge
weeds,
while
individual
research
trials
show
great
variability
in
efficacy
of
alternatives
(
Unruh
et
al.,
2002).
An
additional
disadvantage
of
the
methylisothiocyanate
(
MITC)
generators
metam
sodium
and
dazomet
is
that
they
have
long
residue
times
in
the
soil
and
this
has
resulted
in
phytotoxicity
(
Banks,
2002).

In
addition
to
providing
higher
rates
of
efficacy
and
more
consistent
results
than
the
other
alternatives
tested,
MB
also
allows
for
quick
planting
after
treatment.
A
MB
treated
field
can
be
planted
within
48
hours
after
the
plastic
cover
is
removed,
while,
depending
on
soil
temperature,
a
minimum
period
of
10
to
27
days
is
required
for
effective
fumigation
when
dazomet
is
used
to
treat
the
soil.
This
delay
is
unacceptable
for
golf
courses
where
it
would
represent
substantial
financial
losses
(
Unruh
and
Brecke,
2001).

1,3­
Dichloropropene
(
1,3­
D)
is
also
not
a
technically
feasible
alternative
because
it
does
not
control
the
entire
pest
complex
affecting
turfgrass
operations.
In
addition,
it
is
not
listed
on
the
MBTOC
list
of
alternatives
for
sod/
turf.
1,3­
D
has
good
activity
against
plant­
parasitic
nematodes,
but
not
against
other
pests.
1,3­
D
+
chloropicrin
has
added
efficacy
against
many
soil­
borne
fungi
resulting
from
the
activity
of
chloropicrin.
However,
none
of
these
products
controls
key
weed
species,
in
Page
4
particular
yellow
and
purple
nutsedge
under
moderate
to
severe
pest
pressure
conditions,
which
affect
turfgrass
production.
In
the
limited
circumstances
when
MB
is
necessary
(
approximately
1
percent
of
the
hectares
in
turfgrass
sod
production
in
a
year),
1,3­
D
will
not
adequately
control
the
target
pests.
In
research
conducted
with
tomatoes
comparing
MB
with
1,3­
D
and
chloropicrin
there
was
a
3.7
fold
increase
in
nutsedge
plants
(
90
to
340
plants/
m2)
between
the
two
treatments
(
Johnson
et
al.,
1999),
and
it
is
likely
that
similar
results
would
be
obtained
with
turf.

The
metam
sodium/
chloropicrin
combination
is
not
a
feasible
MB
alternative,
mainly
because
neither
chemical
is
effective
against
nutsedge
under
moderate
to
high
weed
pressure
conditions.
Metam­
sodium
alone
has
sometimes
been
used
by
sod
farms
and
in
the
establishment
and
renovation
of
golf
courses.
However,
metam­
sodium
does
not
provide
acceptable
levels
of
nutsedge
control,
and
in
that
respect,
it
is
similar
to
dazomet
in
effectiveness
(
Unruh,
et
al.,
2002).
Chloropicrin
is
effective
against
soil
pathogens,
but
ineffective
against
most
weeds.
The
U.
S.
analysis
confirmed
that
the
amount
of
MB
nominated
for
golf
courses
is
only
for
areas
where
there
is
moderate
to
high
pest
pressure
(
Table
3).

3.
Also,
it
is
requested
that
details
of
certification
schemes
be
supplied,
particularly
if
they
have
a
specific
requirement
for
use
of
MB.

In
the
U.
S.,
industry
certification
programs
for
sod
require
a
guarantee
that
the
grasses
are
genetically
pure.
Thus,
producers
of
certified
turfgrass
sod,
or
vegetative
propagules,
operate
under
zero­
tolerance
standards
for
pests
or
off­
type
grasses.
For
this
purpose,
state
sod
and
seed
certification
agencies
require
fumigation
and
inspection
of
sod
fields
before
a
pest
free
"
certified"
label
is
issued.
The
use
of
MB
for
this
purpose,
although
not
required
under
the
certification
program,
is
implied
because
of
its
effectiveness
in
satisfying
the
zero­
tolerance
pest
standard
required
by
industry
where
no
other
treatment
does.

Infested
fields
lose
certification
status
and
the
sod
on
those
fields
can
no
longer
be
sold.
Since
there
is
no
secondary
market
for
contaminated
sod,
a
crop
that
cannot
be
sold
leads
to
a
complete
loss
for
the
grower.
The
off­
typing
issue
is
of
particular
importance
in
growing
bermudagrass
sod
where
the
product
is
a
specific
genetically
pure
species.
Contamination
with
off­
type
grasses
may
lead
to
legal
action
against
the
turfgrass
producer.
Examples
of
turfgrass
sod
certification
programs
are
provided
below.

4.
The
Party
may
wish
to
remove
the
quantity
of
MB
used
for
fire
ant
control
from
this
CUN
if
its
control
is
a
requirement
of
state
or
federal
quarantine
and
the
use
falls
under
the
QPS
exemption.

In
the
original
U.
S.
CUE
nomination
fire
ants
were
erroneously
considered
as
MB
target
pests.
This
is
incorrect.
MB
is
not
one
of
the
chemicals
recommended
by
USDA/
APHIS
or
the
states
for
fire
ant
quarantine
treatment.
This
issue,
therefore,
does
not
affect
the
original
CUE
request.
Page
5
5.
The
nomination
covers
several
uses
of
MB,
including
the
establishment
and
maintenance
of
golf
courses,
and
production
of
turfgrass
sod.
Some
of
the
sod
may
be
certified,
although
no
supporting
documentation
was
provided
about
the
certification
tolerance
requirements.
An
unspecified
quantity
of
MB
is
reported
to
be
used
as
a
quarantine
treatment
for
red
fire
ants
in
sod.
Insufficient
information
was
provided
to
enable
MBTOC
to
judge
whether
this
might
be
a
QPS
treatment.
It
is
requested
that
these
differing
uses
of
MB
be
disaggregated
and
the
amounts
presented
as
separate
CUNs.

The
responses
above
to
MBTOC/
TEAP
specific
comments
and
below
in
the
attached
tables
address
these
issues
of
certification
of
sod,
documentation
for
certification
tolerance
requirements,
and
disaggregation
of
amounts.
As
noted
in
Comment
No.
4,
the
U.
S.
request
does
not
include
any
MB
for
the
purpose
of
controlling
imported
fire
ants
on
sod
for
quarantine
purposes.

6.
In
the
case
of
golf
course
maintenance,
some
technically
feasible
alternatives
have
been
reported.

Please
see
the
response
to
Question
2
above
regarding
the
feasibility
of
specific
alternatives.
The
U.
S.
government
contacted
the
MBTOC
co­
chair
in
July
to
request
clarification
on
whether
it
would
like
us
to
address
alternatives
beyond
those
addressed
in
our
response
to
Question
2.
We
were
told
that
no
additional
alternatives
need
be
considered.

7.
The
nominated
quantity
may
be
revised
in
consideration
of
adoption
of
emission
reduction
strategies.

Plastic
tarping
is
already
the
standard
practice
in
this
industry.
In
fact,
for
the
United
States
in
general,
MB
fumigation
is
carried
out
using
plastic
tarps.
Although
data
are
not
available
for
the
entire
U.
S.,
in
California
93%
of
MB
pre­
plant
applications
are
made
under
plastic
tarps
(
personal
communication,
Paul
Niday,
TriCal
Corp.),
with
the
remaining
7%
deep
shank
injection
for
orchard
re­
plant
uses.
We
believe
these
factors
to
be
typical
of
all
sectors
and
states,
including
those
covered
in
this
CUE.
The
U.
S.
nomination
already
takes
these
factors
into
consideration.
As
noted
above,
turf
grass
and
golf
course
uses
in
U.
S.
currently
apply
mixtures
of
67:
33,
and
where
ever
feasible
50:
50.
Further
reductions
are
not
deemed
feasible.

EXAMPLES
OF
TURFGRASS
SOD
CERTIFICATION
REQUIREMENTS
IN
THE
U.
S.:

Turfgrass
sod
certification,
Georgia:
http://
www.
pikecreekturf.
com/
turfcert.
php
Turfgrass
sod
certification,
New
Jersey:
http://
www.
rce.
rutgers.
edu/
pubs/
pdfs/
fs738.
pdf
Turfgrass
sod
certification,
Tennessee:
http://
www.
state.
tn.
us/
sos/
rules/
0080/
0080_
06/
0080_
06_
04.
pdf
Page
6
Turfgrass
sod
certification,
Virginia:
http://
www.
virginiacrop.
org/
vcia.
sodstd.
html
Page
7
TABLE
2.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
TURF
SECTOR*.

Historical
Use
Average
Use
Rates
(
kg/
ha)
Total
Amount
(
kg)
Area
Treated
(
ha)
1997
550
695,461
1,385
1998
524
702,326
1,414
1999
549
1,043,661
2,087
2000
550
840,961
1,692
2001
549
598,296
1,187
*
302,930
acres
(
122,592
ha)
of
Sod
planted
in
the
U.
S.;
Percent
of
U.
S.
sod
acreage
requested:
1%.
1,800,000
acres
(
728,435
ha)
in
Golf
Courses
in
the
U.
S.;
Percent
of
U.
S.
Golf
Course
acreage
requested:
0.03%.
Source:
Use
rates,
amount,
and
area
treated
are
from
the
Critical
Use
Exemption
Applications.
Area
of
sod
and
turfgrass
are
2001
estimates
from
the
applicants.

TABLE
3.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
TURF
SECTOR.

Calculation
of
Nominated
Amount
0044
 
Turfgrass
Producers
International
0055
 
Golf
Course
Superintendents
Association
Hectares
(
ha)
1,416
182
%
of
Regional
hectares
(
ha)(
A)
1
0.03
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
680,388
111,039
Double
Counted
hectares
(
ha)(
B)
0
0
Growth
/
Increasing
Production
(
ha)(
C)
388
23
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
514
0
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
514
159
Key
Pest
Impacts
(%)(
F)
100
100
Regulatory
Impacts
(%)(
G)
0
0
Soil
Impacts
(%)(
H)
0
0
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
Qualifying
Area
(
ha)(
J)
514
159
Use
Rate
(
kg/
ha)(
K)
480
610
CUE
Amount
Nominated
(
kg)(
L)
247,078
96,728
%
Reduction
from
Initial
Request
(
M)
64
13
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
343,805
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
352,194
Page
8
Footnotes
for
Table
3:

Values
may
not
sum
exactly
due
to
rounding.
NA
=
not
available.

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.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request
but
were
not
included
in
NASS
surveys)
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.
Both
applicants
requested
growth,
but
these
requests
were
not
included
in
the
U.
S.
CUE
nomination.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Quarantine/
pre­
shipment
use
has
been
subtracted
from
the
applicants'
requests.
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
MB
alternatives.
Nutsedge
and
off­
type
turf
grasses
are
the
key
pests.
The
entire
are
is
affected
by
key
pests
because
only
that
proportion
of
acreage
where
alternatives
do
not
provide
adequate
control
(
0.03
to
1.0)
were
included
in
the
nomination.
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
1,3D
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
1,3
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
may
be
adjusted
downward
based
on
historical
use
patterns.
L.
CUE
amount
nominated
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
The
use
rate
was
reduced
for
one
of
the
applicants.
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
sum
of
all
nominations
in
the
sector
by
the
margin
of
error
multiplier.
Page
9
DEFINITIONS
THAT
MAY
BE
RELEVANT
TO
THIS
CUE
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
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
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
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
Page
10
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
Banks,
H.
J.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.
Pg
46.

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.

Csinos,
A.
S.,
W.
C.
Johnson,
A.
W.
Johnson,
D.
R.
Sumner,
R.
M.
McPherson,
and
R.
D.
Gitaitis.
1997.
Alternative
Fumigants
for
Methyl
Bromide
in
Tobacco
and
Pepper
Transplant
Production.
Crop
Prot.
16:
585­
594.

Johnson,
W.
C.,
III,
B.
G.
Mullinix,
Jr.
1999.
Cyperus
esculentus
interference
in
Cucumis
sativus.
Weed
Sci.
47:
327­
331.

Unruh,
J.
B.
and
B.
J.
Brecke.
2001.
Seeking
Alternatives
for
Methyl
Bromide.
Golf
Course
Management.
69(
3):
65­
72.

Unruh,
J.
B.,
B.
J.
Brecke,
J.
A.
Dusky
and
J.
S.
Godbehere.
2002.
Fumigant
Alternatives
for
Replacement
of
Methyl
Bromide
in
Turfgrass.
Weed
Technology,
16:
379­
387,
pp
379­
387.
