METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
CUCURBITS
GROWN
IN
OPEN
FIELDS
ON
PLASTIC
TARPAULINS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Cucurbits
Grown
in
Open
Fields
on
Plastic
Tarpaulins
NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
ii
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
____________________________________________________________
7
1.
Nominating
Party
_________________________________________________________
7
2.
Descriptive
Title
of
Nomination______________________________________________
7
3.
Crop
and
Summary
of
Crop
System___________________________________________
7
4.
Methyl
Bromide
Nominated
_________________________________________________
7
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
7
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
10
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
10
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
12
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
14
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
______________
16
Michigan
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
16
Michigan
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
16
Michigan
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
18
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________
19
Michigan
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
19
Michigan
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
22
Michigan
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
22
Michigan
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___
23
Michigan
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
24
Michigan
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
24
Michigan
­
Summary
of
Technical
Feasibility
____________________________________
25
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________________________________________________________
26
Southeastern
USA
except
Georgia
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_______________________________
26
Southeastern
USA
except
Georgia
­
11.
Characteristics
of
Cropping
System
and
Climate__
26
Southeastern
USA
except
Georgia
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
28
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_______________
29
Southeastern
USA
except
Georgia
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_____
29
Southeastern
USA
except
Georgia
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_________________________________________________________________
32
iv
Southeastern
USA
except
Georgia
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________
33
Southeastern
USA
except
Georgia
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________________________________________
34
Southeastern
USA
except
Georgia
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
35
Southeastern
USA
except
Georgia
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
________________________________
36
Southeastern
USA
except
Georgia
­
Summary
of
Technical
Feasibility
________________
36
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
37
Georgia
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
37
Georgia
­
11.
Characteristics
of
Cropping
System
and
Climate_______________________
37
Georgia
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
39
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
40
Georgia
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________
40
Georgia
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
42
Georgia
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
43
Georgia
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___
44
Georgia
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
45
Georgia
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
45
Georgia
­
Summary
of
Technical
Feasibility
_____________________________________
46
PART
D:
EMISSION
CONTROL
___________________________________________________
47
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
47
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
48
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
49
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
49
22.
Gross
and
Net
Revenue___________________________________________________
51
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
53
Summary
of
Economic
Feasibility
_____________________________________________
59
PART
F.
FUTURE
PLANS
_______________________________________________________
63
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
63
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
64
v
25.
Additional
Comments
on
the
Nomination
____________________________________
64
26.
Citations
______________________________________________________________
65
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
__________________________________
74
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
7
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
7
Table
A.
1:
Executive
Summary
__________________________________________________
9
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
Michigan
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
12
Southeastern
USA
except
Georgia
­
Table
8.2:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
_____________________________________________________________
12
Georgia
­
Table
8.3:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________
13
Table
A.
2:
2005
Sector
Request­­
Cucurbit
________________________________________
14
Table
A.
3:
2006
Sector
Nomination­­
Cucurbit
_____________________________________
15
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
16
Michigan
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
16
Michigan
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
16
Michigan
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
17
Michigan
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
18
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION________________________________________
19
Michigan
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
19
Michigan
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________________
22
Michigan
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
22
Michigan
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
24
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________________________________________________________
26
Southeastern
USA
except
Georgia
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
26
Southeastern
USA
except
Georgia
­
Table
11.1:
Characteristics
of
Cropping
System
_______
26
Southeastern
USA
except
Georgia
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
27
Southeastern
USA
except
Georgia
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
__
28
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
__________________
29
Southeastern
USA
except
Georgia
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
29
Southeastern
USA
except
Georgia
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
_______________________________________________________________________
32
Southeastern
USA
except
Georgia
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_
33
Southeastern
USA
except
Georgia
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_____
35
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
37
Georgia
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
___
37
Georgia
­
Table
11.1:
Characteristics
of
Cropping
System
____________________________
37
Georgia
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_____________________
38
Georgia
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_______________________
39
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_________________________________________
40
Georgia
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible______________________
40
vi
Georgia
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________
42
Georgia
 
Table
15.1:
Present
Registration
Status
of
Alternatives_______________________
43
Southeastern
USA
except
Georgia
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_____
44
PART
D:
EMISSION
CONTROL
____________________________________________________
47
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
47
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
49
Table
21.1:
Michigan
­
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______________________________________________________________________
49
Table
21.2:
Southeastern
USA
except
Georgia
­
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______________________________________________
50
Table
21.3:
Georgia
­
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
50
Table
22.1:
Michigan
­
Year
1,
2,
and
3
Gross
and
Net
Revenues_______________________
51
Table
22.2:
Southeastern
USA
except
Georgia
­
Year
1,
2,
and
3
Gross
and
Net
Revenues
___
51
Table
22.3:
Georgia
­
Year
1,
2,
and
3
Gross
and
Net
Revenues
________________________
52
Michigan
Cucumber­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______
53
Michigan
Melon
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
53
Michigan
Winter
Squash
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
___
54
Michigan
Zucchini
­
Table
E.
4:
Economic
Impacts
of
Methyl
Bromide
Alternatives________
54
Michigan
Winter
Squash
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
___
55
Southeastern
USA
except
Georgia
Cucumber
­
Table
E.
5:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
55
Southeastern
USA
except
Georgia
Melons
­
Table
E.
6:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
56
Southeastern
USA
except
Georgia
Squash
­
Table
E.
7:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
56
Southeastern
USA
except
Georgia
Squash
­
Table
E.
7:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
57
Georgia
Cucumber
 
Table
E.
8:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______
57
Georgia
Melon
­
Table
E.
9:
Economic
Impacts
of
Methyl
Bromide
Alternatives___________
58
Georgia
Squash
­
Table
E.
10:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
58
Georgia
Squash
­
Table
E.
10:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
59
PART
F.
FUTURE
PLANS
________________________________________________________
63
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
69
Page
7
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Cucurbits
Grown
in
Open
Fields
on
Plastic
Tarpaulins
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Cucurbits
(
squash,
melons,
and
cucumber)
grown
in
Alabama,
Arkansas,
Georgia,
Kentucky,
Louisiana,
Michigan,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia.
These
crops
are
grown
in
open
fields
on
plastic
tarps,
often
followed
by
various
other
crops.
Harvest
is
destined
for
the
fresh
market.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
753,202
5,363
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
cucurbit
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
tomato
production.
­
geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
curcurbits
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
U.
S..
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
in
Georgia
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin,
and
in
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
Page
8
In
Michigan
cucurbits,
the
only
currently
available
methyl
bromide
(
MB)
alternative
that
is
technically
feasible
for
the
control
of
the
key
target
pests
is
1,3­
D
+
chloropicrin.
These
pests
are
the
soil
borne
fungi
Phytophthora
capsici
and
Fusarium
oxysporum,
both
of
which
can
easily
destroy
the
entire
harvest
from
affected
areas
if
left
uncontrolled.
At
least
one
of
these
pests,
P.
capsici,
has
recently
been
shown
to
occur
in
irrigation
water
in
Michigan
(
Gevens
and
Hausbeck
2003).
This
has
probably
contributed
to
the
spread
of
this
pathogen.
Due
to
widespread
pest
distribution,
virtually
all
of
the
cucurbit
acreage
in
Michigan
currently
uses
MB
(
plus
chloropicrin)
as
a
prophylactic
control
of
fungal
pests.
While
1,3
D
+
chloropicrin
provided
some
control
of
fungi
in
recent
small­
plot
trials
with
cucurbits
in
Michigan
(
Hausbeck
and
Cortwright
2003),
there
were
yield
losses
(
approximately
6
%)
relative
to
the
MB
+
chloropicrin
standard.

It
is
also
not
yet
clear
whether
these
small­
scale
results
accurately
reflect
efficacy
of
MB
alternatives
in
commercial
cucurbit
production.
Furthermore,
regulatory
restrictions
due
to
concerns
over
human
exposure
and
ground
water
contamination,
along
with
the
lower
yields,
result
in
potential
economic
infeasibility
of
this
formulation
as
a
practical
MB
alternative.
Key
among
these
factors
are
a
delay
in
planting
up
to
14
days
relative
to
MB,
due
to
a
combination
label
restrictions
and
the
low
soil
temperatures
typical
of
Michigan,
as
well
as
a
mandatory
30
m
buffer
for
treated
fields
with
1,3
D
+
chloropicrin
near
inhabited
structures.
Delays
in
planting
may
result
in
growers
missing
key
market
windows
and
premium
harvest
prices,
and
buffer
zones
will
result
in
some
areas
remaining
vulnerable
to
pests
in
the
absence
of
MB.

In
the
Southeastern
USA
(
including
Georgia),
nutsedges
are
the
primary
target
pest
of
concern.
Some
growers
in
this
region
also
face
root­
knot
nematodes
and
the
soil­
borne
fungal
pathogens
(
described
above)
as
key
pests.
Left
uncontrolled,
any
of
these
pests
could
completely
destroy
the
harvests
from
affected
areas.
Metam­
sodium
offers
some
control
of
nutsedges
and
nematodes,
while
1,3­
D
+
chloropicrin
provides
good
control
of
nematodes
(
e.
g.,
Eger
2000,
Noling
et
al.
2000).
However,
in
areas
where
nutsedge
infestations
are
moderate
to
severe
and
fungal
pathogens
are
present,
metam­
sodium
results
in
an
estimated
44
%
yield
loss
relative
to
MB.
In
such
areas,
use
of
1,
3
D
+
chloropicrin
is
likely
to
lead
to
allow
an
estimated
29
%
yield
loss
relative
to
MB.
In
addition
to
these
estimated
losses,
it
must
be
noted
that
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
USA
(
primarily
Kentucky
and
Georgia
as
regards
this
nomination)
due
to
the
presence
of
karst
geology.
1,3
D
cannot
be
used
on
such
soil
due
to
label
restrictions
created
in
response
to
concerns
over
groundwater
contamination.
Together,
these
yield
losses
and
regulatory
restrictions
render
these
promising
MB
alternatives
technologically
and
economically
infeasible.

It
should
be
noted
also
that
all
studies
of
yield
losses
for
metam­
sodium
and
1,3
D
+
chloropicrin
relative
to
methyl
bromide
are
based
on
small
plot
research
trials
done
on
non­
cucurbit
crops.
Large­
scale
on­
farm
trials
will
need
to
be
conducted
in
cucurbits
with
high
fungal
and
nutsedge
pest
pressure
to
determine
the
long
term
potential
for
these
alternatives.

Some
researchers
have
also
reported
that
these
MB
alternatives
are
degraded
more
rapidly
in
areas
where
they
are
applied
repeatedly,
due
to
enhanced
metabolism
by
soil
microbes.
This
phenomenon
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.
Page
9
In
sum,
neither
of
these
promising
MB
alternatives
is
presently
adequate
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
cucurbits.
in
the
southeastern
USA
also.

Michigan,
Southeastern
USA
(
except
Georgia),
and
Georgia
are
presented
as
separate
regions
in
this
nomination
to
reflect
the
separate
applications
from
growers
in
these
areas.

TABLE
A.
1:
EXECUTIVE
SUMMARY*

Region
Michigan
Southeastern
USA
except
Georgia
Georgia
AMOUNT
OF
NOMINATION
2006
Kilograms
27,656
461,257
257,985
Application
Rate
(
kg/
ha)
48
150
150
Area
(
ha)
574
3,071
1,718
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
27,656
928,739
405,837
Application
Rate
(
kg/
ha)
48
150
150
Area
(
ha)
574
6,184
2,702
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Technically
Feasible
Alternative(
s)
Best
Alternative
Best
Alternative
Best
Alternative
Yield
Loss
(%)
6%
29%
29%

Loss
per
hectare
(
US$/
ha)
$
2,232
$
2,883
$
7,230
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
46
$
19
$
48
Loss
as
%
of
Gross
Revenue
(%)
12%
23%
21%
Loss
as
%
of
Net
Revenue
(%)
55%
70%
52%

*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated
Page
10
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Our
review
of
available
research
on
all
other
MB
alternatives
discussed
by
MBTOC
for
cucurbits
suggests
that,
of
registered
(
i.
e.,
legally
available)
chemistries
only
metam
sodium
and
1,3
D
+
chloropicrin
have
shown
potential
as
commercially
viable
replacement
to
MB.
Non­
chemical
alternatives
are
either
unviable
for
U.
S.
cucurbits
or
require
more
research
and
commercial
development
before
they
can
be
technically
and
economically
feasible.

For
Michigan
pests
1,3
D
+
chloropicrin
is
the
only
key
alternative
with
efficacy
comparable
to
MB.
However,
it
has
regulatory
restrictions
due
to
human
exposure
concerns,
along
with
technical
limitations,
that
result
in
economic
infeasibility
of
this
formulation
as
a
practical
MB
alternative.
Key
among
these
factors
are
a
delay
in
planting
as
long
as
30
days,
due
both
to
label
restrictions
and
low
soil
temperatures,
and
a
mandatory
30
m
buffer
for
treated
fields
near
inhabited
structures.

For
Southeastern
USA
and
Georgia,
metam­
sodium
and
1,3
D
+
chloropicrin
are
the
most
promising
alternatives
for
nutsedges
and
nematodes,
respectively,
which
are
the
key
target
pests
in
these
regions.
However,
where
nutsedges
are
moderate
to
severe,
metam­
sodium
is
technically
and
economically
infeasible
due
to
planting
delays
and
yield
losses,
while
1,3
D
+
chloropicrin
is
infeasible
due
to
(
1)
its
use
being
prohibited
on
Karst
geology,
which
are
widespread
in
these
regions,
(
2)
a
21
day
planting
delay,
and
(
3)
yield
losses.
These
effects
have
been
discussed
in
Section
5
(
above).

There
is
also
evidence
that
the
pesticidal
efficacy
of
both
1,3
D
and
metam­
sodium
declines
in
areas
where
it
is
repeatedly
applied,
due
to
enhanced
degradation
of
methyl
isothiocyanate
by
soil
microbes
(
Ou
et
al.
1995,
Verhagen
et
al.
1996,
Dungan
and
Yates
2003,
Gamliel
et
al.
2003).

All
other
potential
or
available
MB
alternatives
are
also
technically
infeasible
for
U.
S.
cucurbits
(
see
Section
13
of
each
region
for
further
details).

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
AVERAGE
OF
2001
AND
2002
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Michigan
8,114
7%

Southeastern
USA
except
Georgia
21,489
24%

Georgia
25,191
11%

NATIONAL
TOTAL*:
181,552
5%
*
Includes
additional
states
not
requesting
methyl
bromide.
Page
11
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

In
Michigan,
only
acreage
that
has
pest
pressure
is
treated
with
MB.

In
Southeastern
USA
and
Georgia,
areas
not
treated
do
not
have
nutsedges,
or
nematodes
naturally
present
in
cucurbit
fields.
Simple
absence
of
all
pests
is
the
only
reason
these
areas
are
not
presently
treated
with
MB.

7.
(
iii)
WOULD
IT
BE
FEASIBLE
TO
EXPAND
THE
USE
OF
THESE
METHODS
TO
COVER
AT
LEAST
PART
OF
THE
CROP
THAT
HAS
REQUESTED
USE
OF
METHYL
BROMIDE?
WHAT
CHANGES
WOULD
BE
NECESSARY
TO
ENABLE
THIS?

The
primary
reason
that
some
cucurbits
may
be
grown
without
methyl
bromide
in
all
three
regions
is
the
absence
of
key
target
pests
(
i.
e.,
nutsedge
in
the
Southeast,
and
Georgia,
soil
pathogens
and
cold
soil
temperatures
in
Michigan,
and
karst
topography
in
Georgia.
Page
12
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
MICHIGAN
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Michigan
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
27,656
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
574
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
71.6
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
48
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
Information
not
available.

*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
TABLE
8.2:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Southeastern
USA
except
Georgia
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
928,739
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
6184
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
223.9
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
150
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
Information
not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
13
GEORGIA
­
TABLE
8.3:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Georgia
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
405,837
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
2,702
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
223.9
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
150
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
Information
not
available.

*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
14
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION
The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
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.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Not
applicable
in
this
sector.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
karst
topography,
unsuitable
terrain,
and
cold
soil
temperatures.

TABLE
A.
2:
2005
SECTOR
REQUEST­­
CUCURBIT*

2005
Cucurbit
Sector
Request
Michigan
Southeastern
USA
except
Georgia
Georgia
Requested
Hectares
(
ha)
585
6,022
2,702
Requested
Application
Rate
(
kg/
ha)
48
150
150
Applicant
Request
for
2005
Requested
Kilograms
(
kg)
28,187
904,426
405,837
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
15
TABLE
A.
3:
2006
SECTOR
NOMINATION­­
CUCURBIT*

2006
Cucurbit
Sector
Nomination
Michigan
Southeastern
USA
except
Georgia
Georgia
Requested
Hectares
(
ha)
574
6,184
2,702
Requested
Application
Rate
(
kg/
ha)
48
150
150
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
27,656
928,739
405,837
Nominated
Hectares
(
ha)
574
3,071
1,718
Nominated
Application
Rate
(
kg/
ha)
48
150
150
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
27,656
461,257
257,985
Overall
Reduction
(%)
45
2006
U.
S.
CUE
Nomination
(
kg)
752,261
Research
amount
(
kg)
941
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
753,202
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
16
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
MICHIGAN
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
MICHIGAN
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Michigan
Soilborne
fungal
diseases:
Phytophthora
capsici
and
Fusarium
oxysporum
No
effective
post­
emergence
control
available;
1,3­
D
+
chloropicrin
is
technically
but
not
economically
feasible
as
a
MB
alternative
due
to
regulatory
and
technical
restrictions
on
use.
Low
soil
temperatures
and
regulatory
restriction
also
means
that
use
of
1,3
D
will
delay
planting
and
prevent
growers
from
obtaining
premium
harvest
prices
in
a
narrow
market
window.

MICHIGAN
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
MICHIGAN
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
grown
for
curcubit
fruit
production.

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Corn,
soybeans,
tomatoes,
strawberries,
other
cucurbit
crops.
MB
is
not
used
for
the
other
crops
if
applied
once
already
in
a
given
year.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
to
medium
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
every
year
for
a
given
field
OTHER
RELEVANT
FACTORS:
Soil
temperatures
are
low
relative
to
the
rest
of
the
U.
S.
cucurbit
growing
regions
(
see
below)
Page
17
MICHIGAN
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
Temperate
USDA
Plant
Hardiness
Zone
5b
SOIL
TEMP.
(
°
C)
<
10
10
­
15
15­
20
20­
25
20­
25
20­
25
20
10­
15
<
10
<
10
<
10
<
10
RAINFALL
(
mm)
40
72
101
48
47
32
17
31
36
20
6
8
OUTSIDE
TEMP.
(
°
C)
0.2
7.4
12.1
17.5
20.6
20.9
18.1
8
2.4
­
2.9
­
8
­
7
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
X
X
KEY
MARKET
WINDOW
X
MICHIGAN
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Low
soil
temperatures
(
often
below
10
oC)
prior
to
the
typical
planting
window
inhibit
dissipation
of
1,3­
D
+
chloropicrin
(
Martin
2003),
which
can
delay
planting
due
to
phytotoxicity
to
crop
plants.
There
is
also
a
21­
day
planting
delay
as
per
registration
label
language.
Combined,
this
results
in
a
delay
as
long
as
30
days
in
planting
crops,
which
may
negatively
affect
the
economics
of
cucurbit
production
in
this
region.
Metam
sodium
transformation
into
the
active
ingredient,
methyl
isothiocyanate,
is
also
slowed
by
low
soil
temperatures
(
Ashley
et
al.
1963).
Page
18
MICHIGAN
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
MICHIGAN
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
381
417
427
508
567
589
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
strip
100%
strip
100%
strip
100%
strip
100%
strip
100%
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
18736
20093
20556
24502
27331
28403
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
71.6
71.6
71.6
71.6
71.6
71.6
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
48
48
48
48
48
48
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
29.1
29.1
29.1
29.1
29.1
29.1
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
19.5
19.5
19.5
19.5
19.5
19.5
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
19
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION
MICHIGAN
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
MICHIGAN
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3
D
+
chloropicrin
In
small
plot
trials
conducted
in
Michigan,
this
formulation
showed
some
efficacy
against
the
key
pests.
It
should
be
noted
that
these
trials
had
not
been
completed
at
the
time
results
were
submitted
to
the
U.
S.
EPA.
Plant
loss
was
about
6
%
as
compared
to
0
%
with
MB
(
Hausbeck
and
Cortwright
2003).
While
this
suggests
that
it
may
be
technically
feasible,
large­
scale
trials
have
not
been
conducted
to
confirm
the
results.
Furthermore,
regulatory
restrictions
and
Michigan's
cool
and
wet
soils
result
in
a
delay
of
up
to
30
days
in
planting
after
treatment
with
this
formulation.
This
results
in
growers
missing
key
harvest
windows,
with
consequent
negative
economic
impacts
(
detailed
in
other
sections
below).
No
Metam­
sodium
Control
of
the
key
pests
is
inconsistent
at
best.
A
small
plot
trial
in
progress
on
cucurbits
in
Michigan
indicates
that
plots
with
metam
sodium
had
higher
plant
loss
than
the
untreated
check
plots
(
Hausbeck
and
Cortwright
2003).
It
should
be
noted
that
these
trials
had
not
been
completed
at
the
time
results
were
submitted
to
the
U.
S.
EPA.
Another
trial
showed
control
of
Fusarium
in
tomato,
but
this
was
performed
in
the
much
warmer
conditions
of
southwest
Florida
(
Webster
et
al.
2001).
In
the
cool
conditions
of
Michigan,
metam­
sodium
is
likely
to
be
slow
to
transform
into
the
active
ingredient
(
methyl
isothiocyanate),
which
suggests
that
pest
control
will
not
be
as
effective
as
in
the
more
favorable
Florida
conditions.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
Michigan's
climate
is
typically
cool
(
less
than
11
oC
frequently
through
May)
and
cloudy,
particularly
early
in
the
growing
season
when
control
of
the
key
pests
is
particularly
important.
In
Michigan,
the
growing
season
is
particularly
short
(
May
to
September),
so
the
time
needed
to
utilize
solarization
is
likely
to
render
the
subsequent
growing
of
crops
impossible,
even
if
it
did
somehow
eliminate
all
fungal
pathogens.
No
Page
20
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Steam
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
the
open
cucurbit
crops
in
Michigan.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
that
afflict
cucurbits
in
Michigan.
The
bacterium
Burkholder
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
in
a
test
conducted
by
the
Michigan
applicants
(
included
in
the
2002
application
from
this
region),
P.
capsici
was
not
controlled
adequately
in
summer
squash,
a
cucurbit
crop,
by
either
of
these
beneficial
microorganisms.
No
Cover
crops
and
mulching
There
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
P.
capsici.
Control
of
P.
capsici
is
imperative
for
cucurbit
production
in
Michigan.
Plastic
mulch
is
already
in
widespread
use
in
Michigan
vegetables,
and
regional
crop
experts
state
that
it
is
not
an
adequate
protectant
when
used
without
methyl
bromide.
The
longevity
and
resistance
of
P.
capsici
oospores
renders
cover
crops
ineffective
as
a
stand­
alone
management
alternative
to
methyl
bromide.
No
Crop
rotation
and
fallow
land
The
crop
rotations
available
to
growers
in
Michigan
region
are
also
susceptible
to
these
fungi,
particularly
to
P.
capsici.
Fallow
land
can
still
harbor
P.
capsici
oospores
(
Lamour
and
Hausbeck
2003).
Thus
fungi
would
persist
and
attack
cucurbits
if
crop
rotation/
fallow
land
was
the
main
management
regime.
No
Endophytes
Though
these
organisms
(
bacteria
and
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
apparently
suppress
some
plant
pathogens
in
cucumber
(
MBTOC
1994),
there
is
no
such
information
for
the
other
cucurbit
crops
grown
in
Michigan.
Furthermore,
the
pathogens
involved
did
not
include
P.
capsici,
arguably
the
greatest
single
threat
to
Michigan
cucurbits.
No
Flooding/
Water
management
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
P.
capsici
(
Allen
et
al.
1999),
and
is
likely
to
be
impractical
for
Michigan
cucurbit
growers.
It
is
unclear
whether
irrigation
methods
in
this
region
could
be
adapted
to
incorporate
flooding
or
alter
water
management
for
cucurbit
fields.
In
any
case,
there
appears
to
be
no
supporting
evidence
for
its
use
against
the
hardy
oospores
of
P.
capsici.
No
Page
21
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
cucurbits,
they
have
been
grouped
together
for
discussion
in
this
document.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
cucurbit
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
fungi.
One
of
the
fungal
pests
listed
by
Michigan
can
spread
through
water
(
Gevens
and
Hausbeck
2003),
making
it
difficult
to
keep
any
sort
of
area
(
with
or
without
soil)
disease
free.
Various
aspects
of
organic
production
 
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Locascio
and
Dickson
1998,
Csinos
et
al.
1999).
Low
efficacy
in
even
small­
plot
trials
indicates
that
this
is
not
a
technically
feasible
alternative
for
commercially
produced
cucurbits
at
this
time.
These
studies
apparently
did
not
measure
yield
impacts,
and
did
not
involve
cucurbits.
No
1,3
D
+
Metam­
sodium
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Csinos
et
al.
1999).
Low
efficacy
in
even
small­
plot
trials
indicates
that
this
is
not
a
technically
feasible
alternative
for
commercially
produced
cucurbits
in
Michigan
at
this
time.
These
studies
apparently
did
not
measure
yield
impacts,
and
did
not
involve
cucurbits.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
22
MICHIGAN
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

MICHIGAN
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
those
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
belowground
portions
of
cucurbit
plants.
A
number
of
effective
fungicides
are
available
for
treatment
of
these
fungi
when
they
infect
aerial
portions
of
crops.
However,
these
infections
are
not
the
focus
of
MB
use,
which
is
meant
to
keep
newly
planted
transplants
free
of
these
fungi.

MICHIGAN
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

MICHIGAN
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Methyl
iodide
Not
registered
in
the
USA
for
cucurbits.
Registration
is
currently
being
pursued
only
for
tomatoes,
strawberries,
peppers,
and
ornamental
crops.
No
(
for
cucurbits)
Unknown
Furfural
Not
registered
in
the
USA
for
cucurbits.
Registration
is
currently
being
pursued
only
for
non­
food
greenhouse
uses.
No
(
for
cucurbits)
Unknown
Sodium
azide
Not
registered;
no
registration
requests
submitted
to
USA
No
(
for
any
crop/
commodity)
Unknown
Propargyl
bromide
Not
registered;
no
registration
requests
submitted
to
USA
No
(
for
any
crop/
commodity)
Unknown
Page
23
MICHIGAN
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
As
far
as
the
U.
S.
can
ascertain,
virtually
none
of
the
studies
on
key
MB
alternatives
has
focused
on
cucurbits
as
the
crop
system.
One
exception
to
this
situation
can
be
summarized
first,
although
this
study
was
ongoing
at
the
time
it
was
submitted
to
U.
S.
EPA.
This
study
is
a
field
trial,
conducted
in
small
plots
in
2003
in
Michigan
by
M.
K.
Hausbeck
and
B.
D.
Cortwright
of
Michigan
State
University.
This
study
focused
on
a
number
of
vegetable
crops
including
the
cucurbits
zucchini,
winter
squash,
and
melons.
As
of
July
31,
2003,
results
indicated
that
1,3
D
+
35
%
chloropicrin
treatments
(
shank­
injected
at
56.7
liters/
ha)
showed
approximately
6
%
plant
loss
(
due
to
both
Phytophthora
and
Fusarium
combined)
 
less
than
the
7
%
loss
seen
in
the
untreated
control
plots.
Metam­
sodium
(
drip­
applied
at
58.7
kg/
ha)
showed
a
13
%
loss
(
MB
showed
no
loss).
Methyl
iodide
(
currently
unregistered
for
cucurbits)
with
either
50
%
or
33
%
chloropicrin
(
shank­
injected,
at
either
46.1
or
36.8
kg/
ha,
respectively)
showed
only
2
%
plant
loss.
It
should
be
noted
that
(
1)
since
the
trial
had
not
yet
ended,
statistical
analysis
on
these
figures
was
not
conducted,
and
(
2)
plant
loss
figures
are
for
all
vegetable
crops
combined.

In
studies
with
other
vegetable
crops,
1,3
D
+
chloropicrin
has
generally
shown
better
control
of
fungi
than
metam­
sodium
formulations
(
though
still
not
as
good
as
control
with
MB).
For
example,
in
a
study
using
a
bell
pepper/
squash
rotation
in
small
plots,
Webster
et
al.
(
2001)
found
significantly
lower
fungal
populations
with
1,3
D
+
35
%
chloropicrin
(
drip
applied,
146
kg/
ha
of
1,3
D),
as
compared
to
the
untreated
control.
However,
MB
(
440
kg/
ha,
shank­
injected)
lowered
fungal
populations
even
more.
It
should
be
noted
that
P.
capsici
was
not
present
in
test
plots,
though
Fusarium
spp.
were.
Methyl
iodide
had
no
significant
suppressive
effect,
as
compared
to
the
untreated
control.
However,
neither
of
these
MB
alternatives
increased
squash
fruit
weight
significantly
over
the
untreated
control.
Indeed,
as
compared
to
the
MB
standard
treatment
plots,
squash
fruit
weight
was
63
%
lower
in
the
1,3
D
plots,
and
41
%
lower
in
the
methyl
iodide
plots.
The
proportion
of
marketable
squash
fruit
(
defined
only
as
those
fruit
so
bad
as
to
have
to
be
discarded)
in
the
1,3
D
plots
was
30
%
lower
than
that
in
the
MB
plots,
though
in
the
methyl
iodide
plots
it
was
equivalent
to
MB.
In
another
study,
conducted
in
tomatoes,
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season;
again,
Fusarium
(
but
not
P.
capsici)
was
one
of
several
pests
present.
Page
24
MICHIGAN
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
D
+
Chloropicrin
Soil
borne
fungal
diseases
0
­
30
%
PLUS
loss
of
revenue
due
to
planting
delays
(
Note:
0
%
is
plausible
only
in
cases
where
the
initial
infestation
of
Fusarium
is
very
low,
and
P.
capsici
is
absent)
6
%
PLUS
loss
of
revenue
due
to
planting
delays
(
Hausbeck
and
Cortwright,
2003)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
6
%
likely
with
the
best
alternative
(
1,3
D
+
chloropicrin)

MICHIGAN
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

The
critical
use
exemption
applicant
states
that
1,3
D
+
chloropicrin,
metam­
sodium,
furfural,
propylene
oxide,
and
sodium
azide
will
continue
to
be
the
subjects
of
field
studies
of
utilization
and
efficacy
enhancement
where
Phytophthora
and
Fusarium
fungi
are
the
target
pests.
It
should
be
kept
in
mind
that
furfural,
propylene
oxide,
and
sodium
azide
are
currently
unregistered
for
use
on
cucurbits,
and
there
are
presently
no
commercial
entities
pursuing
registration
in
the
USA.
The
regulatory
restrictions
on
1,3
D
discussed
elsewhere
will
also
remain
as
negative
influences
on
the
economics
of
this
MB
alternative.
The
timeline
for
developing
the
above­
mentioned
MB
alternatives
in
Michigan
is
as
follows:
2003
 
2005:
Test
for
efficacy
(
particularly
against
the
more
prevalent
Phytophthora
fungi)
2005
 
2007:
Establish
on­
farm
demonstration
plots
for
effective
MB
alternatives
2008
 
2010:
Work
with
growers
to
implement
widespread
commercial
use
of
effective
alternatives.

Research
is
also
under
way
to
optimize
the
use
of
a
50
%
MB:
50
%
chloropicrin
formulation
to
replace
the
currently
used
67:
33
formulation.
In
addition,
field
research
is
being
conducted
to
optimize
a
combination
of
crop
rotation,
raised
crop
beds,
black
plastic,
and
foliar
fungicides.
Use
of
virtually
impermeable
film
(
VIF)
will
also
be
investigated
as
a
replacement
for
the
currently
used
low
density
polyethylene
(
LDPE).
All
research
is
to
be
conducted
by
Michigan
State
University
staff
in
collaboration
with
commercial
cucurbit
growers.

MICHIGAN
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

No.
Page
25
MICHIGAN
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
U.
S.
EPA
has
determined
that
only
1,3
D
+
chloropicrin
has
some
technical
feasibility
against
the
key
pests
of
cucurbits
in
this
region.
Metam­
sodium
alone
has
little
efficacy
against
these
pests;
when
combined
with
chloropicrin,
it
has
shown
better
efficacy
in
trials
with
other
vegetable
crops
(
e.
g,
peppers),
but
results
have
been
inconsistent
across
different
studies,
and
no
large­
plot
studies
have
been
performed
to
show
commercial
feasibility
in
cucurbits
(
e.
g.,
Martin
2003,
Hausbeck
and
Cortwright
2003,
Csinos
et
al.
1999).
Important
technical
constraints
on
both
1,3
D
and
metam­
sodium
formulations
must
also
be
kept
in
mind:
a
21
 
30
day
planting
delay,
mandatory
100
foot
buffers
(
for
1,3
D)
near
inhabited
structures
 
both
of
which
will
cause
negative
economic
impacts,
and
potentially
lower
dissipation
(
and
thus
efficacy)
in
the
cool
soils
of
this
region.

Currently
unregistered
alternatives,
such
as
furfural
and
sodium
azide,
have
shown
good
efficacy
against
the
key
pests
involved
in
small
plot
tests.
However,
even
if
registration
is
pursued
soon
(
and
the
U.
S.
EPA
has
no
indications
of
any
commercial
venture
planning
to
do
so),
these
options
will
need
more
research
on
how
to
adapt
them
to
commercial
cucurbit
production
in
Michigan.
There
are
also
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
cucurbit
growers.
In
sum,
while
the
potential
exists
for
a
combination
of
chemical
and
non­
chemical
alternatives
to
replace
MB
use
in
Michigan
cucurbits,
this
appears
to
be
at
least
a
few
years
away.
Page
26
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
"
Southeastern
USA
except
Georgia".
A
consortium
of
cucurbit
growers
in
Alabama,
Arkansas,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia
is
included
here
Nutsedges:
yellow
(
Cyperus
esculentum),
and
purple
(
Cyperus
rotundus);
to
a
lesser
extent:
fungal
diseases
(
Phytophthora,
Fusarium
spp.)
and
root
knot
nematodes
(
Meloidogyne
incognita)
No
effective
alternatives
exist
for
control
of
the
nutsedge,
due
to
either
lack
of
registration,
planting
delays
(
due
to
regulatory
restriction
or
phytotoxicity)
or
low
efficacy,
or
lack
of
registration
of
potentially
effective
herbicides,
all
of
which
result
in
significant
economic
loss.
In
part
of
this
region,
fungal
diseases
may
also
have
no
effective
control
in
the
absence
of
MB,
due
to
regulatory
restrictions
and
planting
delays
associated
with
1,3
D
+
chloropicrin
use.

SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHEASTERN
USA
EXCEPT
GEORGIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
grown
for
cucurbit
fruit
production.

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Other
cucurbits,
tobacco,
grains,
cotton
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Low
organic
content,
light
to
medium
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
every
year
OTHER
RELEVANT
FACTORS:
Page
27
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
Temperate
USDA
Plant
Hardiness
Zones
6b
 
8b
SOIL
TEMP.
(
°
C)
Not
available.

RAINFALL
(
mm)
163
124
109
87
78
146
113
202
109
116
54
76
OUTSIDE
TEMP.
(
°
C)
9.4
14.5
17.7
23.4
26
25.9
22.6
14.9
7.7
3.4
2.9
4.2
FUMIGATION
SCHEDULE
X
X
X
PLANTING
SCHEDULE
X
X
X
X
X
KEY
MARKET
WINDOW
X
SOUTHEASTERN
USA
EXCEPT
GEORGIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

In
some
areas
of
the
southeast,
alternatives
are
not
effective
against
the
key
pests
in
this
sector.
Page
28
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
3,237
3,541
3,976
4,532
5,034
5,253
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Not
applicable
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
711,414
777,910
597,177
680,751
756,120
788,942
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
APPLICATION
RATE
OF
FORMULATION
IN
kg/
ha*
224.5
224.5
223.9
223.9
223.9
223.9
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
220
220
150
150
150
150
ACTUAL
DOSAGE
RATE
OF
FORMULATION
(
g/
m2)*

ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
Information
not
available.

*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
29
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTHEASTERN
USA
EXCEPT
GEORGIA
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3
D
+
chloropicrin
Effective
(
in
small
plot
studies)
in
controlling
disease
and
nematode
pests,
but
not
nutsedges
(
Locascio
et
al.
1997,
Csinos
et
al.
1999,
Noling
et
al.
2000).
Subject
to
regulatory
restrictions
in
some
areas
(
where
Karst
geology
exist).
No
Metam­
sodium
Provides
control
of
nutsedges
only
close
to
application
site
(
Dowler
1999,
Locascio
and
Dickson
1998).
Surviving
nutsedge
tubers
can
potentially
recolonize
the
crop
field
(
Webster
2002).
Not
effective
against
the
disease
or
nematode
pests
in
this
region.
Approximate
yield
losses
due
to
nutsedge
are
3
 
25
%;
losses
would
be
higher
in
areas
facing
the
other
key
pests
along
with
nutsedges.
Technically
and
economically
infeasible
due
to
these
yield
losses
(
see
economic
analyses
in
Part
E)
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
U.
S.
states,
solarization
is
unlikely
to
be
technically
feasible
as
a
methyl
bromide
alternative.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50
oC
or
higher
(
Chase
et
al.
1999).
While
this
may
be
achieved
for
some
portion
of
the
autumn
cropping
in
southern
cucurbit
growing
regions,
it
is
very
unlikely
for
any
portion
of
the
spring
crops.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43
oC
at
5
cm
depth.
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
reliably
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
cucurbit
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
cucurbit
crops.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Page
30
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nutsedges
that
afflict
cucurbits.
While
some
fungal
pathogens
showed
potential
as
control
agents
(
Phatak
1983),
no
work
has
yet
been
done
on
using
these
pathogens
as
reliable
pest
management
tools
in
open­
field
cucurbit
crops.
Season­
long
field
tests
have
shown
low
levels
of
pest
control
or
lack
of
persistence
of
the
control
agents
(
Kadir
et
al.
2000)
No
Cover
crops
and
mulching
Cover
crops
and
mulches
appear
to
control
many
weeds,
but
not
nutsedges
(
Burgos
and
Talbert
1996).
The
effect
of
cover
crops
on
cucurbit
crop
growth
and
yield
remains
unknown;
this
contributes
to
the
technical
obstacles
this
strategy
faces
as
a
methyl
bromide
alternative.
In
some
studies
cover
crops
have
delayed
crop
maturity
and
reduced
height
and
yield
of
plants
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
since
these
plants
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
Crop
rotation
and
fallow
land
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not,
by
itself,
provide
adequate
control
of
fungi
or
nutsedges.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores
(
Lamour
and
Hausbeck
2003).
As
regards
nutsedges,
tubers
of
these
perennial
species
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land
(
Thullen
and
Keeley
1975).
Furthermore,
nutsedge
plants
can
produce
tubers
within
2
weeks
after
emergence
(
Wilen
et
al.
2003).
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Endophytes
Though
these
organisms
(
bacteria
and
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
have
shown
potential
against
some
pathogens
in
cucumber
(
MBTOC
1994),
there
is
no
such
information
for
the
other
cucurbit
crops.
Similarly,
the
USA
found
no
evidence
that
endophytes
control
nutsedges
No
Page
31
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Flooding/
Water
management
As
with
many
of
the
other
alternatives
to
methyl
bromide,
flooding
has
been
shown
to
control
a
number
of
weeds,
but
not
nutsedge
species.
Nutsedge
is
much
more
tolerant
of
watery
conditions
than
many
other
weed
pests.
For
example,
Horowitz
(
1972)
showed
that
submerging
nutsedge
in
flowing
or
stagnant
water
(
for
8
days
and
4
weeks,
respectively)
did
not
affect
the
sprouting
capacity
of
tubers.
Another
practical
obstacle
to
implementing
flood
management
approaches
in
cucurbit
production
in
the
southern
and
southeastern
U.
S.
states
is
that
the
soil
composition
may
not
support
flooding
and
still
remain
productive.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
The
USA
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges
in
cucurbits.
While
in
theory
plant
breeding
may
improve
the
ability
of
cucurbits
to
compete
with
these
weeds
for
nutrients,
light,
etc.,
it
would
certainly
not
provide
alternatives
within
the
time
span
considered
in
this
critical
use
exemption
nomination.
The
effect
on
the
quality
of
the
crops
involved
is
unknown
also.
For
resistant
rootstock
at
least,
there
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
cucurbit
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives.
U.
S.
EPA
found
no
evidence
that
soilless
culture
or
substrates/
plug
plants
can
be
used
to
produce
cucurbit
crops
on
a
large
scale,
or
that
they
will
control
nutsedges,
which
like
soil
fungi
are
particularly
hardy.
Various
aspects
of
organic
production
 
organic
mulches,
cover
crops,
fallow
land,
steam
sterilization
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Would
possibly
be
more
effective
than
metam­
sodium
alone
where
fungal
pests
are
the
only
concern
(
see
Michigan
sections
for
more
discussion),
but
this
combination
may
not
prevent
yield
losses
due
to
nutsedges,
particularly
where
the
weed
pressure
is
high.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
No
1,3
D
+
Metam­
sodium
Controls
nematodes
but
not
nutsedges.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
Inconsistently
effective
against
fungal
pests
(
see
Michigan
sections
for
more
discussion).
1,3­
D
also
subject
to
regulatory
prohibition
of
use
on
Karst
geology
(
prevalent
in
Kentucky).
No
Page
32
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

SOUTHEASTERN
USA
EXCEPT
GEORGIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Halosulfuron­
methyl
Herbicide:
causes
potential
crop
injury;
has
plant
back
restrictions.
Efficacy
is
lowered
in
rainy
conditions
(
common
during
the
period
of
initial
planting
of
these
crops).
Also,
a
24­
month
plant
back
restriction
may
cause
significant
economic
disruption
if
growers
must
rely
on
this
control
option.
Halosulfuron
is
only
allowed
for
the
row
middles
for
cucurbits,
due
to
its
phytotoxicity.
This
would
result
in
nutsedges
surviving
close
to
crop
plants.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Glyphosate
Herbicide:
Is
non­
selective;
like
halosulfuron,
it
will
not
control
nutsedge
within
the
plant
rows;
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Paraquat
Herbicide:
Is
non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.
Page
33
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

SOUTHEASTERN
USA
EXCEPT
GEORGIA
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:
Methyl
iodide
For
nutsedges
and
fungi:
Not
registered
in
the
USA
for
cucurbits.
Registration
is
currently
being
pursued
only
for
tomatoes,
strawberries,
peppers,
and
ornamental
crops
No
(
for
cucurbits)
Not
applicable
Pebulate
For
nutsedges:
Was
registered
for
use
in
tomatoes
only,
but
even
this
registration
lapsed
December
31,
2002
(
registrant
corporation
went
out
of
business)
No
(
for
cucurbits)
Not
applicable
S­
metolachlor
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Terbacil
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Rimsulfuron
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Trifloxysulfuron
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Page
34
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
For
a
discussion
of
relative
effectiveness
of
MB
alternatives
against
fungal
pests,
please
see
Section
16
for
the
Michigan
region.
A
brief
discussion
of
this
topic
as
regards
the
other
key
pests
in
southeastern
USA
except
Georgia
follows
below.
As
with
fungal
pests,
virtually
all
research
on
this
topic
has
been
conducted
with
other
vegetable
crops
in
the
USA.

For
root
knot
nematodes,
both
metam­
sodium
and
1,3
D
+
35
%
chloropicrin
have
shown
good
efficacy
in
trials
with
tomato
and
pepper.
For
example,
Locascio
and
Dickson
(
1998)
reported
that
metam­
sodium
+
35
%
chloropicrin
(
295
l/
ha
of
metam­
sodium,
shankinjected
reduced
nematode
galls
significantly
over
untreated
control
plots,
though
not
as
much
as
did
MB
+
35
%
chloropicrin
treatments
(
500kg
MB/
ha,
shank­
injected),
in
Florida
tomatoes.
Analysis
of
35
tomato
and
5
pepper
trials
conducted
from
1993
 
1995
indicated
that
1,3
D
(
with
either
17
%
or
35
%
chloropicrin)
provided
control
of
nematodes
that
was
equal
or
superior
to
that
seen
with
MB,
in
95
%
of
the
tomato
and
100
%
of
pepper
trials
(
Eger
2000).
However,
it
is
not
clear
whether
yields
were
also
comparable
to
those
obtained
with
MB.
Noling
et
al
(
2000)
also
studied
the
effects
of
metam­
sodium
(
115
l/
ha,
syringe­
injected),
1,3
D
+
17
%
chloropicrin
(
53.6
l/
ha,
soil­
injected),
and
1,3
D
+
35
%
chloropicrin
(
39.8
l/
ha),
among
other
treatments,
in
tomato
plots.
Galls
inflicted
by
root
knot
nematodes
were
reduced
significantly
by
all
these
MB
alternatives,
as
compared
to
untreated
control
plots.
Yields
were
also
significantly
higher
as
compared
to
the
control
plots;
all
MB
alternatives
resulted
in
similar
high
yields.
However,
the
effects
of
MB
formulations
were
not
reported
in
this
study.
Further,
it
is
the
opinion
of
some
U.
S.
crop
experts
that
metam
sodium,
in
particular,
is
very
inconsistent
in
its
beneficial
effects
as
a
nematode
control
agent
(
Dr.
S.
Culpeper,
University
of
Georgia,
personal
communication).

For
nutsedges,
metam­
sodium
and
1,3
D
(
with
and
without
chloropicrin)
have
shown
inconsistent
efficacy
that
is
often
inferior
to
that
of
MB
formulations.
For
example,
Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
in
Florida.
Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pair
wise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville,
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering
1,3
D
results,
the
reader
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists.
No
farm
scale
trials
appear
to
have
been
done
to
validate
these
results
as
yet.
Page
35
SOUTHEASTERN
USA
EXCEPT
GEORGIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
D
+
chloropicrin
Nutsedges
0­
40
%
(
0
%
would
be
possible
only
in
lightly
infested
areas;
these
areas
are
not
included
in
this
request
for
MB)
29
%
(
Locascio,
et
al.,
1997)

Metam­
sodium
(
with
or
without
chloropicrin)
Nutsedges
0­
66
%
(
0
%
would
be
possible
only
in
lightly
infested
areas;
these
areas
are
not
included
in
this
request
for
MB)
44
%
(
Locascio,
et
al.,
1997)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
29
%
where
1,3
D
can
be
used;
44
%
where
only
metam
sodium
can
be
used
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

The
applicant
states
that
research
has
been
conducted
on
nutsedge
control
with
halosulfuron,
1,3
D
+
chloropicrin,
and
metam­
sodium.
Future
research
will
focus
on
halosulfuron
and
crop
rotation
for
control
of
nutsedges.
Approximately
3
to
5
years
are
expected
as
a
timeframe
for
developing
effective
MB
alternatives
for
nutsedge
control
in
cucurbits
produced
in
this
region.
Research
will
be
conducted
in
cooperation
with
commercial
cucurbit
growers,
by
faculty
and
extension
staff
at
various
land­
grant
universities
in
the
states
encompassed
by
this
region.
Also,
it
is
reasonable
to
expect
that
the
results
from
Michigan
research
on
fungicidal
alternatives
to
MB
will
be
used
to
develop
options
for
fungal
pests
of
southeastern
U.
S.
cucurbits.

Future
plans
to
minimize
MB
use
also
include:

(
1)
Using
research
and
on­
farm
evaluations
optimize
a
combination
of
nutsedge
control
in
fallow
fields,
crop
rotation,
and
use
of
post­
emergent
herbicide
in
crops.
Herbicides
will
include
halosulfuron,
sulfentrazone,
and
glyphosate.
(
2)
Optimize
the
combined
use
of
plastic
(
LDPE)
tarps
and
drip
irrigation
equipment
for
applying
at­
plant
herbicides.
Page
36
SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

No.
Areas
where
MB
is
not
used
in
this
region
do
not
face
moderate
to
severe
populations
of
the
key
pests.

SOUTHEASTERN
USA
EXCEPT
GEORGIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
As
regards
the
key
pests
cited
by
the
applicants
from
this
region,
technically
feasible
alternatives
appear
to
exist
for
root
knot
nematodes,
namely
1,3
D
+
chloropicrin
and
metamsodium
(
by
itself
or
with
chloropicrin).
1,
3
D
+
chloropicrin
also
shows
efficacy
against
the
fungal
pests
in
this
region.
However,
this
MB
alternative
has
significant
regulatory
and
technical
limitations
that
are
likely
to
result
in
negative
economic
impacts
(
please
see
the
summary
of
technical
feasibility
for
Michigan
for
a
discussion
of
these
limitations).
In
addition
to
the
limitations
faced
by
Michigan
growers,
farmers
in
the
southeastern
USA
who
farm
on
Karst
geology
are
prohibited
from
even
considering
this
option
due
to
regulatory
restrictions
intended
to
mitigate
groundwater
contamination.
When
1,3
D
cannot
be
used,
growers
in
this
region
will
have
no
technically
feasible
control
option
where
fungi
are
the
major
pests.

For
nutsedge
pests,
which
are
widespread
in
this
region,
cucurbit
growers
do
not
currently
have
technically
feasible
alternatives
to
MB
use
at
planting.
Metam­
sodium
and
1,3
D
+
chloropicrin
have
shown
some
efficacy
in
small­
plot
trials
in
other
vegetable
crops
(
e.
g,
tomato).
However,
at
best,
metam
sodium
may
allow
at
least
44
%
yield
loss,
while
1,3
D
may
allow
at
least
29
%
loss.
Both
often
show
less
control
than
MB
(
in
terms
of
population
suppression)
of
nutsedges.
These
factors
suggest
that
even
this
alternative
will
not
be
economically
feasible
even
in
the
best­
case
technical
scenario.
It
should
be
noted
that
there
is
evidence
that
both
1,3
D
and
methyl
isothiocynate
levels
decline
more
rapidly,
thus
further
compromising
efficacy,
in
areas
where
these
are
repeatedly
applied
(
Smelt
et
al.
1989,
Ou
et
al.
1995,
Gamliel
et
al.
2003).
This
is
due
to
enhanced
degradation
of
these
chemicals
by
soil
microbes
(
Dungan
and
Yates
2003).
Other
chemical
alternatives
to
MB
that
have
shown
promise
against
nutsedges
(
e.
g,
pebulate)
are
currently
unregistered
for
cucurbits,
and
are
often
not
being
developed
for
registration
by
any
commercial
entity.

Large­
scale,
on­
farm
demonstrations
of
optimal
application
methodology
in
a
commercial
setting
are
lacking
for
cucurbit
crops,
adding
to
the
current
lack
of
viability
of
MB
alternatives
in
this
crop
system.
While
a
combination
of
alternatives
may
replace
MB
in
future
cucurbit
production
in
this
region,
it
remains
some
years
away
from
technical
feasibility.
Page
37
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
GEORGIA
 
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
GEORGIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Georgia
Nutsedges:
yellow
(
Cyperus
esculentum),
and
purple
(
Cyperus
rotundus);
fungal
diseases
(
mainly
Pythium
spp.);
to
a
lesser
extent:
root
knot
nematodes
(
Meloidogyne
incognita)
No
effective
alternatives
exist
for
control
of
the
nutsedge,
due
to
either
lack
of
registration,
planting
delays
(
due
to
regulatory
restriction
or
phytotoxicity)
or
low
efficacy,
both
of
result
in
significant
economic
loss,
or
lack
of
registration
of
potentially
effective
herbicides.
In
part
of
this
region,
fungal
diseases
may
also
have
no
effective
control
in
the
absence
of
MB,
due
to
regulatory
restrictions
on
the
only
effective
alternative
(
1,3
D
+
chloropicrin).
Georgia
may
have
a
higher
level
of
nematode
pressure
than
the
other
southeastern
states.

GEORGIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
GEORGIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
GEORGIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
grown
for
cucurbit
fruit
production.

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
(
one)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Other
cucurbits,
bell
pepper,
squash,
eggplant
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
to
medium
loam,
low
organic
matter
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
every
year
OTHER
RELEVANT
FACTORS:
Karst
geology
are
widespread
in
Georgia.
Page
38
GEORGIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
Temperate
USDA
Plant
Hardiness
Zones
7a
 
8b
SOIL
TEMP.
(
°
C)
Not
available
RAINFALL
(
mm)
206
108
148
248
0
158
84
122
109
137
37
131
OUTSIDE
TEMP.
(
°
C)
15
17.7
22.9
25.6
27.2
27.5
25.1
20
11.4
7.5
6.2
9.7
FUMIGATION
SCHEDULE
X
X*

PLANTING
SCHEDULE
X
X
X
KEY
MARKET
WINDOW
X**
X**

Notes:
(
1)
*
=
This
fumigation
period
is
for
a
cantaloupe
typically
double
cropped
with
squash,
which
is
typically
a
spring
application
cycle;
the
other
fumigation
period
shown
is
for
cucumber
usually
double
cropped
with
bell
peer
and
squash
usually
double
cropped
with
cabbage,
both
typically
a
fall
cycle.
(
2)
**
=
U.
S.
EPA
assumes
these
are
the
key
market
windows
based
on
harvest
schedule
supplied
by
the
applicant.
According
to
the
applicant,
harvests
for
fall
cycle
crops
occur
in
October
&
November,
those
for
spring
cycle
crops
occur
in
May
through
July.
(
3)
Planting
schedule
is
July
and
August
for
crops
with
a
fall
application
cycle;
March
for
those
with
a
spring
cycle.

GEORGIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Karst
geology
prevent
widespread
application
of
1,3
D
+
chloropicrin
as
an
alternative
for
disease
and
nematode
control,
because
regulatory
restrictions
prohibit
use
of
this
chemical
on
the
overlying
soils.
Page
39
GEORGIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
GEORGIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
1345
1873
2408
2062
2872
Not
available.

RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
Strip
100%
Strip
100%
Strip
100%
Strip
100%
Strip
100%
Strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
344859
462779
449691
317177
431487
Not
available.

FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide/
chloropicrin)
98:
2
98:
2
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
Shank
injected
APPLICATION
RATE
OF
FORMULATION
IN
kg/
ha*
252
252
285.1
230
223.9
Not
available.

APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
247
247
191
154
150
Not
available.

ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*

ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
Information
not
available.

*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
40
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
GEORGIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
GEORGIA
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3
D
+
chloropicrin
Effective
(
in
small
plot
studies)
in
controlling
disease
and
nematode
pests,
but
not
nutsedges
(
Locascio
et
al.
1997,
Csinos
et
al.
1999,
Noling
et
al.
2000).
Subject
to
regulatory
restrictions
in
some
areas
(
where
Karst
geology
exist).
No
Metam­
sodium
Provides
control
of
nutsedges
only
close
to
application
site
(
Dowler
1999,
Locascio
and
Dickson
1998).
Surviving
nutsedge
tubers
can
recolonize
the
crop
field
(
Webster
2002).
Not
effective
against
the
disease
or
nematode
pests
in
this
region.
Approximate
yield
losses
due
to
nutsedge
are
3­
66%;
losses
would
be
higher
in
areas
facing
the
other
key
pests
along
with
nutsedges.
This
alternative
is
both
technically
and
economically
infeasible
due
to
these
yield
losses
(
see
economic
analyses
in
Part
E)
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
U.
S.
states,
solarization
is
unlikely
to
be
technically
feasible
as
a
methyl
bromide
alternative.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50
oC
or
higher
(
Chase
et
al.
1999).
While
this
may
be
achieved
for
some
portion
of
the
autumn
cropping
in
southern
cucurbit
growing
regions,
it
is
very
unlikely
for
any
portion
of
the
spring
crops.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43
oC
at
5
cm
depth.
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
reliably
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
cucurbit
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
cucurbit
crops.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Page
41
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nutsedges
that
afflict
cucurbits.
While
some
fungal
pathogens
showed
potential
as
control
agents
(
Phatak
1983),
no
work
has
yet
been
done
on
using
these
pathogens
as
reliable
pest
management
tools
in
open­
field
cucurbit
crops.
Season­
long
field
tests
have
shown
low
levels
of
pest
control
or
lack
of
persistence
of
the
control
agents
(
Kadir
et
al.
2000)
No
Cover
crops
and
mulching
Cover
crops
and
mulches
appear
to
control
many
weeds,
but
not
nutsedges
(
Burgos
and
Talbert
1996).
The
effect
of
cover
crops
on
cucurbit
crop
growth
and
yield
remains
unknown;
this
contributes
to
the
technical
obstacles
this
strategy
faces
as
a
methyl
bromide
alternative.
In
some
studies
cover
crops
have
delayed
crop
maturity
and
reduced
height
and
yield
of
plants
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
since
these
plants
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
Crop
rotation
and
fallow
land
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not,
by
itself,
provide
adequate
control
of
fungi
or
nutsedges.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores.
As
regards
nutsedges,
tubers
of
these
perennial
species
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land.
Furthermore,
nutsedge
plants
can
produce
tubers
within
8
weeks
after
emergence.
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Endophytes
Though
these
organisms
(
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
have
been
shown
to
suppress
some
plant
pathogens
in
cucumber,
there
is
no
such
information
for
the
other
cucurbit
crops.
Similarly,
the
USA
found
no
evidence
that
endophytes
control
nutsedges
No
Flooding/
Water
management
As
with
many
of
the
other
alternatives
to
methyl
bromide,
flooding
has
been
shown
to
control
a
number
of
weeds,
but
not
nutsedge
species.
Nutsedge
is
much
more
tolerant
of
watery
conditions
than
many
other
weed
pests.
For
example,
Horowitz
(
1972)
showed
that
submerging
nutsedge
in
flowing
or
stagnant
water
(
for
8
days
and
4
weeks,
respectively)
did
not
affect
the
sprouting
capacity
of
tubers.
Another
practical
obstacle
to
implementing
flood
management
approaches
in
cucurbit
production
in
the
southern
and
southeastern
U.
S.
states
is
that
the
soil
composition
may
not
support
flooding
and
still
remain
productive.
No
Page
42
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
The
USA
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges
in
cucurbits.
While
in
theory
plant
breeding
may
improve
the
ability
of
cucurbits
to
compete
with
these
weeds
for
nutrients,
light,
etc.,
it
would
certainly
not
provide
alternatives
within
the
time
span
considered
in
this
critical
use
exemption
nomination.
The
effect
on
the
quality
of
the
crops
involved
is
unknown
also.
For
resistant
rootstock
at
least,
there
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
cucurbit
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives.
The
USA
found
no
evidence
that
soilless
culture
or
substrates/
plug
plants
can
be
used
to
produce
cucurbit
crops
on
a
large
scale,
or
that
they
will
control
nutsedges,
which
like
soil
fungi
are
particularly
hardy.
Various
aspects
of
organic
production
 
organic
mulches,
cover
crops,
fallow
land,
steam
sterilization
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Would
be
more
effective
than
metam­
sodium
alone
where
fungal
pests
are
the
only
concern
(
see
Michigan
sections
for
more
discussion),
but
this
combination
may
not
prevent
yield
losses
due
to
nutsedges,
particularly
where
the
weed
pressure
is
high.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
Technically
but
not
economically
feasible
due
to
these
yield
losses
(
see
economic
analyses
elsewhere)
No
1,3
D
+
Metam­
sodium
Controls
nematodes
but
not
nutsedges.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
Inconsistently
effective
against
fungal
pests
(
see
Michigan
sections
for
more
discussion).
1,3­
D
also
subject
to
regulatory
prohibition
of
use
on
Karst
geology
(
prevalent
in
Kentucky).
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

GEORGIA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

GEORGIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
Page
43
NAME
OF
ALTERNATIVE
DISCUSSION
Halosulfuron­
methyl
For
nutsedges:
potential
crop
injury;
plant
back
restrictions.
Efficacy
is
lowered
in
rainy
conditions
(
common
during
the
period
of
initial
planting
of
these
crops).
Also,
a
24­
month
plant
back
restriction
may
cause
significant
economic
disruption
if
growers
must
rely
on
this
control
option.
Halosulfuron
is
only
allowed
on
the
row
middles
for
cucurbits,
due
to
its
phytotoxicity.
This
would
result
in
weeds
surviving
close
to
crop
plants.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Glyphosate
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Paraquat
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

GEORGIA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

GEORGIA
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:
Methyl
iodide
For
nutsedges:
Not
registered
in
the
USA
for
cucurbits.
Registration
is
currently
being
pursued
only
for
tomatoes,
strawberries,
peppers,
and
ornamental
crops
No
(
for
cucurbits)
Not
applicable
Pebulate
For
nutsedges:
Was
registered
for
use
in
tomatoes
only,
but
even
this
registration
lapsed
December
31,
2002
(
registrant
corporation
went
out
of
business)
No
(
for
cucurbits)
Not
applicable
S­
metolachlor
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Terbacil
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Rimsulfuron
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Trifloxysulfuron
For
nutsedges:
registered
for
crops
other
than
cucurbits
No
(
for
cucurbits)
Not
applicable
Page
44
GEORGIA
­
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
For
a
discussion
of
relative
effectiveness
of
MB
alternatives
against
fungal
pests,
please
see
Section
16
for
the
Michigan
region.
Though
the
fungal
pest
cited
by
Georgia
growers
is
in
a
different
genus
(
Pythium),
the
relative
effectiveness
of
relevant
MB
alternatives
is
likely
to
be
similar
to
that
where
the
other
soil
borne
fungal
pests
are
concerned.
For
a
discussion
of
relative
effectiveness
of
MB
alternatives
against
root
knot
nematodes
and
nutsedges,
please
see
Section
16
for
the
Southeastern
USA
region.

G
EORGIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
D
+
chloropicrin
Nutsedges
0­
40
%
(
0
%
would
be
possible
only
in
lightly
infested
areas;
these
areas
are
not
included
in
this
request
for
MB)
29
%
(
Locascio
et
al.,
1997)

Metam­
sodium
(
with
or
without
chloropicrin)
Nutsedges
0­
66
%
(
0
%
would
be
possible
only
in
lightly
infested
areas;
these
areas
are
not
included
in
this
request
for
MB)
44
%
(
Locascio
et
al.,
1997)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
29
%
where
1,3
D
can
be
used;
44
%
where
only
metam
sodium
can
be
used
Page
45
GEORGIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

For
Georgia
cucurbits,
research
focusing
on
the
deployment
of
MB
alternatives
for
control
of
nutsedges
and
Phytophthora
fungi
is
planned.
Field
trials
will
include
treatments
with
methyl
iodide
in
combination
with
halosulfuron,
1,3
D
in
combination
with
chloropicrin
and
halosulfuron,
and
a
combination
of
metam­
potassium,
1,3
D,
and
halosulfuron.
The
Georgia
applicants
provided
no
specific
timeline
for
development
and
deployment,
but
it
is
reasonable
to
expect
that
the
3­
5
year
timeframe
cited
by
cucurbit
growers
in
the
other
southeastern
U.
S.
states
will
probably
apply.
University
of
Georgia
research
and
extension
staff
will
conduct
trials,
presumably
in
collaboration
with
cooperating
growers.

Future
plans
to
minimize
MB
use
also
include:

(
3)
Using
research
and
on­
farm
evaluations
optimize
a
combination
of
nutsedge
control
in
fallow
fields,
crop
rotation,
and
use
of
post­
emergent
herbicides
in
crops.
Herbicides
will
include
halosulfuron,
sulfentrazone,
and
glyphosate.
(
4)
Optimize
the
combined
use
of
plastic
(
LDPE)
tarps
and
drip
irrigation
equipment
for
applying
at­
plant
herbicides.

It
is
also
reasonable
to
expect
that
growers
in
this
region
will
adopt
measure
shown
in
Michigan
to
be
successful
in
minimizing
MB
use
where
fungal
pests
are
the
only
key
pests
involved.

GEORGIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

No.
Areas
where
MB
is
not
used
in
this
region
do
not
face
moderate
to
severe
populations
of
the
key
pests.
Page
46
GEORGIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
As
regards
the
key
pests
cited
by
the
applicants
from
this
region,
technically
feasible
alternatives
appear
to
exist
for
root
knot
nematodes,
namely
1,3
D
+
chloropicrin
and
metamsodium
(
by
itself
or
with
chloropicrin).
1,
3
D
+
chloropicrin
also
shows
efficacy
against
the
fungal
pests
in
this
region.
However,
this
MB
alternative
has
significant
regulatory
and
technical
limitations
that
are
likely
to
result
in
negative
economic
impacts
(
please
see
the
summary
of
technical
feasibility
for
Michigan
for
a
discussion
of
these
limitations).
In
addition
to
the
limitations
faced
by
Michigan
growers,
farmers
in
Georgia
who
farm
on
Karst
geology
are
prohibited
from
even
considering
this
option
due
to
regulatory
restrictions
intended
to
mitigate
groundwater
contamination.
When
1,3
D
cannot
be
used,
growers
in
this
region
will
have
no
technically
feasible
control
option
where
fungi
are
the
major
pests.

For
nutsedge
pests,
which
are
widespread
in
this
region,
cucurbit
growers
do
not
currently
have
technically
feasible
alternatives
to
MB
use
at
planting.
Metam­
sodium
and
1,3
D
+
chloropicrin
have
shown
some
efficacy
in
small­
plot
trials
in
other
vegetable
crops
(
e.
g,
tomato).
However,
at
best,
metam
sodium
may
allow
at
least
44
%
yield
loss,
while
1,3
D
may
allow
at
least
29
%
loss.
Both
often
show
less
control
than
MB
(
in
terms
of
population
suppression)
of
nutsedges.
These
factors
suggest
that
even
this
alternative
will
not
be
economically
feasible
even
in
the
best­
case
technical
scenario.
It
should
be
noted
that
there
is
evidence
that
both
1,3
D
and
methyl
isothiocynate
levels
decline
more
rapidly,
thus
further
compromising
efficacy,
in
areas
where
these
are
repeatedly
applied
(
Smelt
et
al.
1989,
Ou
et
al.
1995,
Gamliel
et
al.
2003).
This
is
due
to
enhanced
degradation
of
these
chemicals
by
soil
microbes
(
Dungan
and
Yates
2003).
Other
chemical
alternatives
to
MB
that
have
shown
promise
against
nutsedges
(
e.
g,
pebulate)
are
currently
unregistered
for
cucurbits,
and
are
often
not
being
developed
for
registration
by
any
commercial
entity.

Large­
scale,
on­
farm
demonstrations
of
optimal
application
methodology
in
a
commercial
setting
are
lacking
for
cucurbit
crops,
adding
to
the
current
lack
of
viability
of
MB
alternatives
in
this
crop
system.
While
a
combination
of
alternatives
may
replace
MB
in
future
cucurbit
production
in
this
region,
it
remains
some
years
away
from
technical
feasibility.
Page
47
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Currently
some
growers
use
HDPE
tarps.
Growers
have
switched
from
a
98%
MB
formulation
to
a
67
%
formulation.
Between
1997
and
2001,
the
U.
S.
has
achieved
a
36
%
reduction
in
use
rates.
From
2
%
to
33
%
No
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
is
underway
to
develop
use
in
commercial
production
systems
Research
is
underway
to
develop
use
of
a
50
%
MB
formulation
in
Michigan
commercial
production
systems.
Not
known
if
other
regions
are
planning
similar
work.
Research
is
underway
to
develop
use
of
a
50
%
MB
formulation
in
Michigan
commercial
production
systems.
Not
known
if
other
regions
are
planning
similar
work.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
Examination
of
promising
but
presently
unregistered
alternative
fumigants
and
herbicides,
alone
or
in
combination
with
nonchemical
methods,
is
planned
in
all
regions
(
Please
see
Section
17
for
each
region
for
details)
Measures
adopted
in
Michigan
will
likely
be
used
in
the
other
regions
when
fungi
are
the
only
key
pests
involved
Measures
adopted
in
Michigan
will
likely
be
used
in
the
other
regions
when
fungi
are
the
only
key
pests
involved
Unknown
Page
48
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
In
accordance
with
the
criteria
of
the
critical
use
exemption,
each
party
is
required
to
describe
ways
in
which
it
strives
to
minimize
use
and
emissions
of
methyl
bromide.
The
use
of
methyl
bromide
in
the
growing
of
cucurbit
nurseries
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
application
for
cucurbits
is
most
often
machine
injected
into
soil
to
specific
depths.

As
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
95%
methyl
bromide
and
5%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
at
low
to
moderate
levels
of
infestation,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.

Tarpaulin
(
high
density
polyethylene)
is
also
used
to
minimize
use
and
emissions
of
methyl
bromide.
Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.
Page
49
PART
E:
ECONOMIC
ASSESSMENT
The
following
economic
assessment
is
organized
by
MB
critical
use
application.
Individual
crops
within
each
application
are
examined
first
and
are
followed
by
aggregate
measures
for
each
application.
Cost
of
MB
and
alternatives
are
given
in
table
21.1.
Table
22.1
lists
net
and
gross
revenues.
Expected
losses
when
using
MB
alternatives
are
further
decomposed
in
tables
E1
through
E13.

Reader
please
note
that
in
this
study
net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
should
be
smaller
than
the
net
revenue
measured
in
this
study.
We
did
not
include
fixed
costs
because
it
is
often
difficult
to
measure
and
verify.

21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
21.1:
MICHIGAN
CUCURBITS
­
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Cucumber
Methyl
Bromide
100%
$
3,385
$
3,385
$
3,385
1,3­
D
+
Chloropicrin
94%
$
3,422
$
3,422
$
3,422
Melon
Methyl
Bromide
100%
$
1,342
$
1,342
$
1,342
1,3­
D
+
Chloropicrin
94%
$
1,354
$
1,354
$
1,354
Winter
Squash
Methyl
Bromide
100%
$
3,385
$
3,385
$
3,385
1,3­
D
+
Chloropicrin
94%
$
3,422
$
3,422
$
3,422
Zucchini
Methyl
Bromide
100%
$
1,342
$
1,342
$
1,342
1,3­
D
+
Chloropicrin
94%
$
1,354
$
1,354
$
1,354
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.
Page
50
TABLE
21.2
:
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
CUCURBITS
­
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Cucumber
Methyl
Bromide
100%
$
2,214
$
2,214
$
2,214
1,3­
D
+
Chloropicrin
71%
$
2,585
$
2,585
$
2,585
Metam­
sodium
54%
$
2,585
$
2,585
$
2,585
Melons
Methyl
Bromide
100%
$
2,214
$
2,214
$
2,214
1,3­
D
+
Chloropicrin
71%
$
2,585
$
2,585
$
2,585
Metam­
sodium
54%
$
2,585
$
2,585
$
2,585
Squash
Methyl
Bromide
100%
$
2,214
$
2,214
$
2,214
1,3­
D
+
Chloropicrin
71%
$
2,585
$
2,585
$
2,585
Metam­
sodium
54%
$
2,585
$
2,585
$
2,585
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.

TABLE
21.3
:
GEORGIA
CUCURBITS
­
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Cucumber
Methyl
Bromide
100%
$
3,642
$
3,642
$
3,642
1,3­
D
+
Chloropicrin
71%
$
3,242
$
3,242
$
3,242
Metam­
sodium
54%
$
3,027
$
3,027
$
3,027
Melon
Methyl
Bromide
100%
$
3,642
$
3,642
$
3,642
1,3­
D
+
Chloropicrin
71%
$
3,242
$
3,242
$
3,242
Metam­
sodium
54%
$
3,027
$
3,027
$
3,027
Squash
Methyl
Bromide
100%
$
3,642
$
3,642
$
3,642
1,3­
D
+
Chloropicrin
71%
$
3,242
$
3,242
$
3,242
Metam­
sodium
54%
$
3,027
$
3,027
$
3,027
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.
Page
51
22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
MICHIGAN
CUCURBITS
 
YEAR
1,
2,
AND
3
GROSS
AND
NET
REVENUES
YEAR
1,
2,
AND
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Cucumber
Methyl
Bromide
$
25,656
$
7,926
1,3­
D
+
Chloropicrin
$
24,116
$
5,797
Melon
Methyl
Bromide
$
14,069
$
6,150
1,3­
D
+
Chloropicrin
$
13,224
$
4,570
Winter
Squash
Methyl
Bromide
$
13,282
$
1,970
1,3­
D
+
Chloropicrin
$
12,485
$
227
Zucchini
Methyl
Bromide
$
13,484
­
$
2,880
1,3­
D
+
Chloropicrin
$
12,675
­
$
3,423
All
Michigan
Cucurbits
Methyl
Bromide
$
19,149
$
17,100
1,3­
D
+
Chloropicrin
$
17,100
$
1,825
NOTE:
Year
1
equals
year
2
and
3.

TABLE
22.2:
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
CUCURBITS
 
YEAR
1,
2,
AND
3
GROSS
AND
NET
REVENUES
YEAR
1,
2,
AND
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Cucumber
Methyl
Bromide
$
11,589
$
1,468
1,3­
D
+
Chloropicrin
$
8,228
$
1,581
Metam­
sodium
­
$
6,490
­
$
2,848
Melon
Methyl
Bromide
$
12,775
$
3,608
1,3­
D
+
Chloropicrin
$
9,070
­
$
5
Metam­
sodium
$
7,154
­
$
1,640
Squash
Methyl
Bromide
$
7,628
$
1,777
1,3­
D
+
Chloropicrin
$
5,416
­
$
755
Metam­
sodium
$
4,272
­
$
1,754
All
Southeastern
USA
Cucurbits
Methyl
Bromide
$
12,315
$
4,131
1,3­
D
+
Chloropicrin
$
8,744
$
1,249
Metam­
sodium
$
6,896
$
23
NOTE:
Year
1
equals
year
2
and
3.
Page
52
TABLE
22.3:
GEORGIA
CUCURBITS
 
YEAR
1,
2,
AND
3
GROSS
AND
NET
REVENUES
YEAR
1,
2,
AND
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Cucumber
Methyl
Bromide
$
34,491
$
6,565
1,3­
D
+
Chloropicrin
$
24,488
­
$
103
Metam­
sodium
$
19,315
­
$
2,992
Melon
Methyl
Bromide
$
27,915
$
9,201
1,3­
D
+
Chloropicrin
$
19,820
$
3,560
Metam­
sodium
$
15,633
$
668
Squash
Methyl
Bromide
$
32,603
$
11,522
1,3­
D
+
Chloropicrin
$
23,148
$
5,440
Metam­
sodium
$
18,258
$
2,251
All
Georgia
Cucurbits
Methyl
Bromide
$
34,621
$
13,840
1,3­
D
+
Chloropicrin
$
24,581
$
6,610
Metam­
sodium
$
19,388
$
2,969
NOTE:
Year
1
equals
year
2
and
3.
Page
53
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
CUCUMBER
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
CUCUMBER
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
2,018
1,897
*
PRICE
PER
UNIT
(
US$)
$
13
$
12
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
25,656
$
22,911
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
17,730
$
17,113
=
NET
REVENUE
PER
HECTARE
(
US$)
$
7,926
$
5,797
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
2,128
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
44
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
8%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
27%

MICHIGAN
MELON
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
MELON
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
145
136
*
PRICE
PER
UNIT
(
US$)
$
97
$
92
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
14,069
$
12,563
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
7,919
$
7,994
=
NET
REVENUE
PER
HECTARE
(
US$)
$
6,150
$
4,570
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
1,580
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
33
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
11%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
26%
Page
54
MICHIGAN
WINTER
SQUASH­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
WINTER
SQUASH
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
1,063
999
*
PRICE
PER
UNIT
(
US$)
$
13
$
12
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
13,282
$
11,861
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
11,312
$
11,634
=
NET
REVENUE
PER
HECTARE
(
US$)
$
1,970
$
227
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
1,743
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
36
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
13%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
89%

MICHIGAN
ZUCCHINI
­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
ZUCCHINI
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
2,368
2,226
*
PRICE
PER
UNIT
(
US$)
$
6
$
5
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
13,484
$
12,041
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
16,364
$
15,464
=
NET
REVENUE
PER
HECTARE
(
US$)
­
$
2,880
­
$
3,423
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
543
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
11
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
4%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
19%
Page
55
ALL
MICHIGAN
CUCURBITS
­
TABLE
E.
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
ALL
MICHIGAN
CUCURBITS
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
1,708
1,606
*
PRICE
PER
UNIT
(
US$)
$
11
$
11
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
19,149
$
17,100
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
15,091
$
15,275
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4,058
$
1,825
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
2,232
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
46
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
12%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
55%

SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
CUCUMBER
­
TABLE
E.
6:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEAST
USA
(
EXCEPT
GEORGIA)
CUCUMBER
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
828
588
464
*
PRICE
PER
UNIT
(
US$)
$
14
$
14
$
14
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
11,589
$
8,228
$
6,490
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
10,121
$
9,809
$
9,338
=
NET
REVENUE
PER
HECTARE
(
US$)
$
1,468
­
$
1,581
­
$
2,848
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
3,049
$
4,316
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
20
$
29
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
26%
37%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
208%
294%
Page
56
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
MELONS
­
TABLE
E.
7:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEAST
USA
(
EXCEPT
GEORGIA)
MELON
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
815
579
457
*
PRICE
PER
UNIT
(
US$)
$
16
$
16
$
16
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
12,775
$
9,070
$
7,154
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
9,168
$
9,076
$
8,795
=
NET
REVENUE
PER
HECTARE
(
US$)
$
3,608
­
$
5
­
$
1,640
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
3,613
$
5,248
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
24
$
35
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
28%
41%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
100%
145%

SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
SQUASH
­
TABLE
E.
8:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEAST
USA
(
EXCEPT
GEORGIA)
SQUASH
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
311
221
174
*
PRICE
PER
UNIT
(
US$)
$
25
$
25
$
25
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
7,628
$
5,416
$
4,272
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
5,851
$
6,171
$
6,025
=
NET
REVENUE
PER
HECTARE
(
US$)
$
1,777
­
$
755
­
$
1,754
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
2,532
$
3,531
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
17
$
24
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
33%
46%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
142%
199%
Page
57
ALL
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
CUCURBITS
­
TABLE
E.
9:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
ALL
SOUTHEAST
USA
(
EXCEPT
GEORGIA)
CUCURBITS
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
749
532
420
*
PRICE
PER
UNIT
(
US$)
$
16
$
16
$
16
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
12,315
$
8,744
$
6,896
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
8,184
$
7,495
$
6,874
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4,131
$
1,249
$
23
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
2,883
$
4,108
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
19
$
27
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
23%
33%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
70%
99%

GEORGIA
CUCUMBER
­
TABLE
E.
10:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
CUCUMBER
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
4,122
2,926
2,308
*
PRICE
PER
UNIT
(
US$)
$
8
$
8
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
34,491
$
24,488
$
19,315
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
27,926
$
24,592
$
22,307
=
NET
REVENUE
PER
HECTARE
(
US$)
$
6,565
­
$
103
­
$
2,992
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
6,668
$
9,557
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
44
$
64
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
19%
28%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
102%
146%
Page
58
GEORGIA
MELON
­
TABLE
E.
11:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
MELON
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
2,975
2,112
1,666
*
PRICE
PER
UNIT
(
US$)
$
9
$
9
$
9
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
27,915
$
19,820
$
15,633
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
18,714
$
16,260
$
14,965
=
NET
REVENUE
PER
HECTARE
(
US$)
$
9,201
$
3,560
$
668
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
5,641
$
8,533
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
38
$
57
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
20%
31%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
61%
93%

GEORGIA
SQUASH
­
TABLE
E.
12:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
SQUASH
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
4,448
3,158
2,491
*
PRICE
PER
UNIT
(
US$)
$
7
$
7
$
7
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
32,603
$
23,148
$
18,258
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
21,081
$
17,708
$
16,007
=
NET
REVENUE
PER
HECTARE
(
US$)
$
11,522
$
5,440
$
2,251
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
6,082
$
9,271
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
41
$
62
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
19%
28%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
53%
80%
Page
59
ALL
GEORGIA
CUCURBITS
­
TABLE
E.
13:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
ALL
GEORGIA
CUCURBITS
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAM­
SODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
3,502
2,486
1,961
*
PRICE
PER
UNIT
(
US$)
$
10
$
10
$
10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
34,621
$
24,581
$
19,388
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
20,781
$
17,971
$
16,419
=
NET
REVENUE
PER
HECTARE
(
US$)
$
13,840
$
6,610
$
2,968
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
7,230
$
10,871
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
48
$
72
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
21%
31%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
52%
79%

SUMMARY
OF
ECONOMIC
FEASIBILITY
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
cucurbits.
Furthermore,
there
are
several
factors
that
limit
possible
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
The
two
most
promising
alternatives
to
methyl
bromide
in
Georgia
and
the
Southeastern
USA
for
control
of
nut­
sedge
in
cucurbits
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
resulting
expected
yield
losses.
Economic
data
representing
Georgia
and
Southeastern
USA
cucurbit
growing
conditions
are
thus
included
in
the
economic
assessment
as
a
supplement
to
the
biological
review
to
illustrate
the
impacts
of
using
MB
alternatives,
not
to
gauge
them
with
respect
to
economic
feasibility.
In
Michigan
1,3­
D
+
chloropicrin
is
considered
technically
feasible.

Michigan
The
U.
S.
concludes
that,
at
present,
no
economically
feasible
alternatives
to
MB
exist
for
use
in
Michigan
cucurbit
production.
The
U.
S.
has
arrived
at
this
conclusion
by
examining
the
individual
crops
within
the
Michigan
cucurbit
sector
and
then
examining
the
sector
as
a
whole.
Two
factors
have
proven
most
important
in
reaching
that
conclusion:.
These
are
yield
loss
and
missed
market
windows,
which
are
discussed
individually
below.

1.
Yield
Loss
Expected
yield
losses
of
6%
are
anticipated
throughout
Michigan
cucurbit
production.
Page
60
2.
Missed
Market
Windows
The
U.
S.
agrees
with
Michigan's
assertion
that
growers
will
likely
receive
significantly
lower
prices
for
their
produce
if
they
switch
to
1,3­
D
+
chloropicrin.
This
is
due
to
changes
in
the
harvest
schedule
caused
by
the
above
described
soil
temperature
complications
and
extended
plant
back
intervals
when
using
1,3­
D
+
chloropicrin.

The
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
cucurbits
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
cucurbits
are
harvested,
the
supply
is
at
its
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
cucurbit
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
cucurbits
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
cucurbit
operations.

To
describe
economic
conditions
in
Michigan,
U.
S.
EPA
used
weekly
and
monthly
cucurbit
sales
and
production
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
three
years
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
was
limiting,
analysts
assumed
that
if
cucurbit
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
gross
revenues
will
decline
by
approximately
5%
over
the
course
of
the
growing
season,
due
solely
to
price
effects.
The
season
average
price
was
reduced
by
5%
in
the
analysis
of
the
alternatives
to
reflect
this
effect.
Based
on
currently
available
information,
the
U.
S.
believes
this
reduction
in
price
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MB
alternatives
are
used
in
Michigan.

Southeastern
USA
Except
Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MB
are
presently
available
to
the
effected
cucurbit
growers.
As
such,
the
U.
S.
concludes
that
use
of
MB
is
critical
in
Southeastern
USA
cucurbit
production.

Analytical
Notes
The
applicant
provided
no
data
on
the
operating
costs
of
alternatives.
Analysts
assumed,
however,
that
these
costs
were
similar
to
those
of
methyl
bromide
with
slight
upward
adjustments
for
the
costs
of
applying
the
alternatives
and
a
slight
downward
adjustment
for
the
cost
of
the
alternative
product.
In
addition,
the
applicant
did
not
provide
data
for
second
crops
(
including
revenues
and
operating
costs).
Analysts
assumed
that
Southeastern
cucurbits
are
grown
in
a
single
crop
production
system.
However,
if
double
cropping
is
practiced
in
the
actual
production
system,
this
assumption
could
make
the
critical
need
for
MB
appear
smaller
than
it
actually
is,
because
the
value
the
second
crop
derives
from
methyl
bromide
is
not
included
in
the
analysis
Page
61
Other
potentially
significant
economic
factors,
such
as
price
reductions
due
to
missed
market
windows,
were
not
analyzed
for
this
region,
as
the
case
for
critical
use
of
MB
is
sufficiently
strong
based
solely
on
yield
loss.

Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MB
are
presently
available
to
the
effected
cucurbit
growers.
As
such,
the
U.
S.
concludes
that
use
of
MB
is
critical
in
Georgia
cucurbit
production.

Analytical
Notes
Other
potentially
significant
economic
factors,
such
as
price
reductions
due
to
missed
market
windows,
were
not
analyzed
for
this
region,
as
the
case
for
critical
use
of
MB
is
sufficiently
strong
based
solely
on
yield
loss.

Economic
analysis
of
Georgia
growing
conditions
included
cost
and
production
data
representing
a
second
cucurbits
or
peppers
crop.
Page
62
Page
63
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Registration
Since
1997,
the
United
States
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
U.
S.
EPA
to
initiate
its
review.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
Agency
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
Agency's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
Agency
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
Agency
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
drinking
water
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
U.
S.$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
U.
S.
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
U.
S.$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.

Research
The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
cucurbits
research
will
require
941
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
the
research
is
a
field
study
testing
the
comparative
performance
of
methyl
bromide,
host
resistance,
cultural
practices,
pest
management
approaches
for
control
of
rootknot
nematodes.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
Page
64
D
combined
with
biologically
based
materials
including
transplant
treatments
for
control
of
weeds,
root­
knot
nematodes
and
soil
borne
fungal
pathogens.

24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

The
U.
S.
wants
to
note
that
our
usage
rate
is
among
the
lowest
in
the
world
in
requested
sectors
and
represents
efforts
of
both
the
government
and
the
user
community
over
many
years
to
reduce
use
rates
and
emissions.
We
will
continue
to
work
with
the
user
community
in
each
sector
to
identify
further
opportunities
to
reduce
methyl
bromide
use
and
emissions.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?
(<
500
Words)
Page
65
26.
CITATIONS
Allen,
L.
H.,
S.
J.
Locascio,
D.
W.
Dickson,
D.
J.
Mitchell,
and
S.
D.
Nelson.
1999.
Flooding
(
soil
anoxia)
for
control
of
pests
of
vegetables.
Research
Summary,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.

Ashley,
M.
G.,
B.
L.
Leigh,
and
L.
S.
Lloyd.
1963.
The
action
of
metham­
sodium
in
soil
II.
Factors
affecting
removal
of
methyl
isothiocyanate
residues.
J.
Sci.
Food
Agric.
14:
153­
161.

Burgos,
N.
R.
and
R.
E.
Talbert.
1996.
Weed
control
and
sweet
corn
(
Zea
mays
var.
rugosa)
response
in
a
no­
till
system
with
cover
crops.
Weed
Sci.
44
(
2):
355
 
361.

Chase,
C.
A.,
T.
R.
Sinclair,
D.
G.
Shilling,
J.
P.
Gilreath,
and
S.
J.
Locascio.
1998.
Light
effects
on
rhizome
morphogenesis
in
nutsedges
(
Cyperus
spp):
Implications
for
control
by
soil
solarization.
Weed
Sci.
46:
575­
580.

Culpepper,
S.
and
Langston
2001.
Fumigant/
herbicide
combinations
in
tomato.
Unpublished
study
conducted
by
researchers
at
the
University
of
Georgia,
Atehns,
GA.
Included
in
CUE
package
03­
0042.

Csinos,
A.
S.,
D.
R.
Sumner,
R.
M.
McPherson,
C.
Dowler,
C.
W.
Johnson,
and
A.
W.
Johnson.
1999.
Alternatives
for
methyl
bromide
fumigation
of
tobacco
seed
beds,
pepper,
and
tomato
seedlings.
Proc.
Georgia
Veg.
Conf.
Available
on
the
Web
at
http://
www.
tifton.
uga.
edu/
veg/
Publications/
Gfvga99.
pdf
Dowler,
C.
C.
1999.
Herbicide
activity
of
metham,
methyl
iodide,
and
methyl
bromide
applied
through
irrigation
systems.
Proc.
Southern
Weed
Sci.
Soc.
52:
77
 
78.

Dungan,
R.
S.
and
S.
R.
Yates.
2003.
Degradation
of
fumigant
Pesticides.
1,3­
Dichloropropene,
methyl
isothiocyanate,
and
methyl
bromide.
Vodose
Zone
Jour.
2:
279­
286.

Eger,
J.
E.
2000.
Efficacy
of
Telone
products
in
Florida
crops:
a
seven
year
summary.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro00.
html.

Galloway,
B.
A.
and
L.
A.
Weston.
1996.
Influence
of
cover
crop
and
herbicide
treatment
on
weed
control
and
yield
in
no­
till
sweet
corn
(
Zea
mays
L.)
and
pumpkin
(
Cucurbita
maxima
Duch.).
Weed
Technol.
10
(
2):
341
 
346.

Gamliel,
A.,
S.
Triki,
M.
Austerweil,
P.
DiPrimo,
I.
Peretz­
Alon,
O.
Heiman,
M.
Beniches,
B.
Steiner,
and
J.
Katan.
2003.
Aceelerated
degradation
of
metam
sodium
in
the
field
and
its
management.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro03.
html.
Page
66
Gevens,
A.,
and
M.
K.
Hausbeck.
2003.
Phytophthora
capsici
in
irrigation
water
and
isolation
of
P.
capsici
from
snap
beans
in
Michigan.
Michigan
State
Univ.
Vegetable
Crop
Advisory
Team
Alert
Vol.
18
(
19).
Available
on
the
Web
at
www.
ipm.
msu.
edu/
CAT03_
veg/
V09­
24­
03.
htm.

Gilreath,
J.,
J.
P.
Jones,
and
A.
J.
Overman.
1994.
Soil­
borne
pest
control
in
mulched
tomato
with
alternatives
to
methyl
bromide.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro94.
html.

Hausbeck,
M.
K.
and
B.
D.
Cortwright.
2003.
Evaluation
of
fumigants
for
managing
Phytophthora
crown
and
fruit
rot
of
solanaceous
and
cucurbit
crops,
plot
two,
2003.
Unpublished
study
supplied
with
CUE
package
03­
0005.

Horowitz,
M.
1972.
Effects
of
desiccation
and
submergence
on
the
viability
of
rhizome
fragments
of
bermudagrass,
johnsongrass,
and
tubers
of
nutsedge.
Israel
J.
Agric.
Res.
22(
4):
215­
220.

Kadir,
J.
B.,
R.
Charudattan,
W.
M.
Stall,
and
B.
J.
Brecke.
2000.
Field
efficacy
of
Dactylaria
higginsii
as
a
bioherbicide
for
the
control
of
purple
nutsedge
(
Cyperus
rotundus).
Weed
Technol.
14
(
1):
1
 
6.

Lamour,
K.
H.,
and
M.
K.
Hausbeck.
2003.
Effect
of
crop
rotation
on
the
survival
of
Phytophthora
capsici
in
Michigan.
Plant
Disease
87:
841­
845.

Larkin,
R.
P.,
and
Fravel,
D.
R.
1998.
Efficacy
of
various
fungal
and
bacterial
biocontrol
organisms
for
control
of
Fusarium
wilt
of
tomato.
Plant
Dis.
82:
1022
­
1028.

Locascio.
S.
J.,
and
D.
W.
Dickson.
1998.
Metam
sodium
combined
with
chloropicrin
as
an
alternative
to
methyl
bromide.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro98.
html.

Locascio,
S.
J.,
J.
P.
Gilreath,
D.
W.
Dickson,
T.
A.
Kucharek,
J.
P.
Jones,
and
J.
W.
Noling.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene
mulched
tomato.
HortSci.
32:
1208­
1211.

Martin,
F.
N.
2003.
Development
of
alternative
strategies
for
management
of
soilborne
pathogens
currently
controlled
with
methyl
bromide.
Ann.
Rev.
Phytopathol.
41:
325
­
350.

MBTOC
(
1994):
1994
Report
of
the
Methyl
Bromide
Technical
Options
Committee
for
the
1995
Assessment
of
the
UNEP
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer.
Nairobi
Page
67
Munn.
D.
A.
1992.
"
Comparison
of
shredded
newspaper
and
wheat
straw
as
crop
mulches."
Hort
technol.
2:
361
­
366.

Noling,
J.
W.,
E.
Rosskopf,
and
D.
L.
Chellemi.
2000.
Impacts
of
alternative
fumigants
on
soil
pest
control
and
tomato
yield.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro00.
html.

Ou,
L.­
T.,
K.
Y.
Chung,
J.
E.
Thomas,
T.
A.
Obreza,
and
D.
W.
Dickson.
1995.
Degradation
of
1,3­
dichloropropene
(
1,3­
D)
in
soils
with
different
histories
of
field
applications
of
1,3­
D.
J.
Nematol.
25:
249
 
257.

Phatak,
S.
C.,
D.
R.
Sumner,
H.
D.
Wells,
D.
K.
Bell,
and
N.
C.
Glaze.
1983.
Biological
control
of
yellow
nutsedge,
Cyperus
esculentus,
with
the
indigenous
rust
fungus
Puccinia
canaliculata.
Science.
219:
1446
 
1448.

Patterson,
D.
T.
1998.
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch.
Weed
Technology,
12:
275­
280.

Schneider
S.
M.,
E.
N.
Rosskopf,
J.
G.
Leesch,
D.
O.
Chellemi,
C.
T.
Bull,
and
M.
Mazzola.
2003.
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
research
on
alternatives
to
methyl
bromide:
pre­
plant
and
post­
harvest.
Pest
Manag
Sci.
59:
814­
826.

Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.

Smelt,
J.
H.,
S.
J.
H.
Crum,
and
W.
Teinissen.
1989.
Accelerated
transformation
of
the
fumigant
methyl
isocyanate
in
soil
after
repeated
application
of
metam
sodium.
J.
Environ.
Sci.
Health
B24:
437­
455.

UNEP
(
United
Nations
Environment
Programme).
1998.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
1998
assessment
of
alternatives
to
methyl
bromide.
p.
49.

Verhagen,
C.,
G.
Lebbink,
and
J.
Bloem.
1996.
Enhanced
biodegradation
of
the
nematicides
1,3­
dichloropropene
and
methyl
isothiocyanate
in
a
variety
of
soils.
Soil
Biol.
Biochem.
28:
1753
 
1756.

Webster,
T.
M.
2002.
Nutsedge
eradication:
impossible
dream?
National
Nursery
Proc.
RMRS­
P­
000.
USDA
Forest
Service,
Rocky
Mtn
Res.
Station,
Ogden,
Utah.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2001.
Methyl
bromide
alternatives
in
a
bell
pepper
 
squash
rotation.
Crop
Prot.
20
(
7):
605
 
614.
Page
68
Wilen,
C.
A.,
M.
E.
McGiffen,
and
C.
L.
Elmore.
2003.
Nutsedge:
Integrated
Pest
Management
for
Home
Gardeners
and
Landscape
Professionals.
University
of
California
IPM
Publication
#
4732.
Available
on
the
Web
at
www.
ipm.
ucdavis.
edu
Page
69
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
181,552
5%

2001
&
2002
Average
%
of
2001
&

2002
Average
8,114
7%

21,489
24%

25,191
11%

54,794
16%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
27,656
574
48
0%

461,257
3,071
150
50%

257,985
1,718
150
36%

752,261
5,363
140
45%

45%
43%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
48
48
0%
0%
0%
0%
100%
100%
0%
0%
0%
0%
100%
100%

150
150
0%
0%
0%
0%
66%
42%
0%
0%
0%
0%
0%
0%

150
150
8%
8%
0%
0%
64%
42%
0%
0%
0%
0%
0%
0%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

Requirement
Change
from
Prior
CUE
Request
(+/­

)
Verified
Historic
MeBr
Use
/

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kg
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
Tarp
No
0
Yes
Yes
Yes
Yes
Tarp
No
+
Yes
Yes
Yes
Yes
Tarp
No
0
Yes
Notes
Conversion
Units:
1
Pound
=
Kilograms
Hectare
1,3­
D
+
Pic
or
Metam­
Sodium
+
Pic
1,3­
D
+
Pic
or
Metam­
Sodium
+
Pic
42%
46%

Quality/
Time/
Market
Window/

Yield
Loss
(%)

6
%
Yield
Loss
Marginal
Strategy
1,3­
D+
Pic
Combined
Impacts
(%)

HIGH
LOW
100%

MICHIGAN
SOUTHEASTERN
US
GEORGIA
11%
17%

MOST
LIKELY
IMPACT
VALUE
Regional
Hectares**

%
of
Requested
Hectares
7%
29%

1
Acre
=
0.404686
MICHIGAN
SOUTHEASTERN
US
GEORGIA
0.453592
*
SE
Cucurbit
Consortium
requested
a
greater
quantity
of
MB
from
their
2002
CUE
application,
but
adjustments
are
attributed
to
growth
estimates
due
to
two
factors:
(
1)
the
inclusion
of
2
new
states
(
Kentucky
&

Louisiana)
in
the
2003
CUE
Application,
(
2)
29%
or
44%
Yield
Loss
29%
or
44%
Yield
Loss
2006
Nomination
Options
TOTAL
OR
AVERAGE
REGION
REGION
GEORGIA
REGION
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
Cold
Soil
Temp
(%)

Adjustments
to
Requested
Amounts
REGION
MICHIGAN
SOUTHEASTERN
US
Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
MICHIGAN
SOUTHEASTERN
US
GEORGIA
100%

66%
68%

13%
13%
41%
61%

%
Reduction
from
Initial
Request
0%
0%
13%
1,187,120
1,187,120
801,139
529,933
Nomination
Amount
1,362,231
1,362,231
1,187,120
­
497,434
316,549
405,837
­
61
­
­
276,049
185,728
928,739
­
175,050
­
(­)
QPS
HIGH
LOW
27,656
­
­
­
­
27,656
27,656
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)
0%

1,362,231
9,460
116
1,231,094
8,589
116
2,868
150
0%

405,837
2,702
150
430,696
578
48
0%

928,739
6,184
150
772,531
5,144
150
0%

27,656
574
48
27,867
2006
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

Sector:
CUCURBITS
%
of
Average
Hectares
Requested:

2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Date:
2/
26/
04
Average
Hectares
in
the
US:

Methyl
Bromide
Critical
Use
Exemption
Process
Page
70
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
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.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
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.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
71
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
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)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2006
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
Page
72
32.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
33.
Tarps/
Deep
Injection
Used
 
Because
all
pre­
plant
methyl
bromide
use
in
the
US
is
either
with
tarps
or
by
deep
injection,
this
variable
takes
on
the
value
`
tarp'
when
tarps
are
used
and
`
deep'
when
deep
injection
is
used.
34.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
35.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
36.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
37.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
38.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
39.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
40.
Loss
per
Hectare
 
This
measures
the
total
loss
per
hectare
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
41.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
42.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
43.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
This
item
is
also
called
net
cash
returns.
44.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
45.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
Page
73
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

For
the
latter,
there
are
two
large
requests:
cut
flower
and
foliage
production
in
Florida
and
California
(`
Ornamentals')
and
a
group
of
structures
and
process
foods
that
we
have
termed
`
Post­
Harvest
NPMA'
which
includes
processed
(
generally
wheat­
based
foods),
spices
and
herbs,
cocoa,
dried
milk,
cheeses
and
small
amounts
of
other
commodities.
There
was
also
a
small
amount
requested
for
field­
grown
tobacco.

The
details
of
the
case
that
there
are
no
alternatives
which
are
both
technically
and
economically
feasible
are
presented
in
the
appropriate
sector
chapters,
as
are
the
requested
amounts,
suitably
adjusted
to
ensure
that
no
double­
counting,
growth,
etc.
were
included
and
that
the
amount
was
only
sufficient
to
cover
situations
(
key
pests,
regulatory
requirements,
etc.)
where
alternatives
could
not
be
used.

The
amount
requested
by
new
applicants
is
approximately
2.5%
of
the
1991
U.
S.
baseline,
or
about
1,400,000
pounds
of
methyl
bromide,
divided
40%
for
pre­
plant
uses
and
60%
for
postharvest
needs.

The
methodology
for
deriving
the
nominated
amount
used
estimates
that
would
result
in
the
lowest
amount
of
methyl
bromide
requested
from
the
range
produced
by
the
analysis
to
ensure
that
adequate
amounts
of
methyl
bromide
were
available
for
critical
needs.
We
are
requesting
additional
methyl
bromide
in
the
amount
of
about
500,000
Kg,
or
2%
or
the
1991
U.
S.
baseline,
to
provide
for
the
additional
critical
needs
in
the
pre­
plant
and
post­
harvest
sector.

Applicant
Name
2005
U.
S.
CUE
Nomination
(
lbs)

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
74
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
