METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
EGGPLANT
GROWN
IN
OPEN
FIELDS
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
Eggplant
Grown
in
Open
Fields
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
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
8
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___________________________________________________________________
13
Florida
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_________________
15
Florida
­
11.
Characteristics
of
Cropping
System
and
Climate
_______________________
15
Florida
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
16
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
17
Florida
­
13.
Reason
for
Alternatives
Not
Being
Feasible
___________________________
17
Florida
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
18
Florida
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
18
Florida
­
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
___
19
Florida
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
21
Florida
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
21
Florida
­
Summary
of
Technical
Feasibility______________________________________
21
Georgia
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________________
23
Georgia
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
23
Georgia
­
11.
Characteristics
of
Cropping
System
and
Climate_______________________
23
Region
A
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
25
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
26
Georgia
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________
26
Georgia
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
27
Georgia
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
28
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
___
29
iv
Georgia
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
30
Georgia
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
30
Michigan
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
32
Michigan
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
32
Michigan
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
32
Michigan
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
33
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________
35
Michigan
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
35
Michigan
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
36
Michigan
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
37
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
___
37
Michigan
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
39
Michigan
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
39
Michigan
­
Summary
of
Technical
Feasibility
____________________________________
39
PART
D:
EMISSION
CONTROL
___________________________________________________
41
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
41
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
42
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
43
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
43
22.
Gross
and
Net
Revenue___________________________________________________
44
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
44
Summary
of
Economic
Feasibility
_____________________________________________
46
PART
F.
FUTURE
PLANS
_______________________________________________________
48
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
48
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
49
25.
Additional
Comments
on
the
Nomination
____________________________________
49
26.
Citations
______________________________________________________________
49
Citations
Reviewed
but
Not
Applicable
_________________________________________
51
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.
v
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
7
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
7
Table
A.
1:
Executive
Summary
_________________________________________________
10
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
Florida
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
______________
12
Georgia
­
Table
8.2:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________
12
Michigan
­
Table
8.3:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
13
Table
A.
2:
2005
Sector
Request
_________________________________________________
14
Table
A.
3:
2006
Sector
Nomination
______________________________________________
14
FLORIDA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
15
Florida
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____
15
Florida
­
Table
11.1:
Characteristics
of
Cropping
System
_____________________________
15
Region
B
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
16
Florida
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________
16
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION
_________________________________________
17
Florida
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
______________________
17
Florida
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion____________________
18
Florida
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_______________________
18
Southeastern
USA
except
Georgia
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_____
19
Table
5.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
(
Locascio
et
al.,
1997______________________________________________________________
19
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
23
Georgia
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
___
23
Georgia
­
Table
11.1:
Characteristics
of
Cropping
System
____________________________
23
Region
A
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
24
Region
A
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
25
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_________________________________________
26
Region
A
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
26
Georgia
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________
27
Georgia
 
Table
15.1:
Present
Registration
Status
of
Alternatives_______________________
28
Southeastern
USA
except
Georgia
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_____
29
Table
5.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
(
Locascio
et
al.,
1997______________________________________________________________
29
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
32
Michigan
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
32
Michigan
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
32
Region
A
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
33
Michigan
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
34
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION________________________________________
35
Michigan
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
35
Michigan
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
37
Michigan
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
37
PART
D:
EMISSION
CONTROL
____________________________________________________
41
vi
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
41
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
43
Table
21.1:
Michigan
­
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______________________________________________________________________
43
Table
22.1:
Michigan
­
Year
1,
2,
and
3
Gross
and
Net
Revenues_______________________
44
Georgia
Melon
­
Table
E.
9:
Economic
Impacts
of
Methyl
Bromide
Alternatives___________
44
Georgia
Cucumber
 
Table
E.
8:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______
45
Southeastern
U.
S.
A.
except
Georgia
Cucumber
­
Table
E.
5:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________
45
PART
F.
FUTURE
PLANS
________________________________________________________
48
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
52
7
PART
A:
SUMMARY
1.
NOMINATING
PARTY:
The
United
States
of
America
2.
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Eggplant
Grown
in
Open
Fields
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM:

This
is
a
request
for
eggplant
grown
in
the
States
of
Florida,
Georgia,
and
Michigan.
In
Florida,
eggplant
can
be
grown
year­
round,
and
are
often
double
cropped
with
pepper
or
cucumber
following
eggplant
harvest.
The
vegetable
crop
that
follows
eggplant
in
a
double
cropping
production
system
depends
upon
prevailing
environmental
and
economic
factors.
Growers
in
Florida
often
put
eggplant
in
as
an
extra
crop,
and
grow
okra,
squash,
or
cucumbers
after
the
eggplant
has
been
harvested.
A
spring
crop
of
eggplant
may
follow
as
a
second
crop
after
a
fall
crop
of
pepper
or
tomato.
Eggplant
does
best
on
well­
drained,
fertile,
sandy­
loam
soils
at
a
pH
of
6.0­
6.5.
Poorly
drained
soils
may
result
in
slow
plant
growth,
reduced
root
systems,
and
low
yields.
Eggplant
requires
a
long,
warm,
frost­
free
growing
season,
usually
of
14­
16
weeks.
Cold
temperatures
below
50oC
injure
this
crop.
The
best
temperatures
are
27­
32oC
during
the
day
and
21­
32oC
during
the
night.
Plant
growth
is
curtailed
at
temperatures
below
16oC.
Additionally,
soil
temperature
below
16oC
restricts
germination.
However,
most
eggplant
is
started
in
the
field
from
transplants.
Methyl
bromide
(
MB)
is
always
used
in
the
full­
bed
mulch
process.
Until
1999,
the
chemical
formulation
primarily
used
was
98
percent
methyl
bromide
and
two
percent
chloropicrin.
Since
then,
growers
have
shifted
to
formulations
with
lower
concentrations
of
methyl
bromide
and
higher
amounts
of
chloropicrin
due
to
the
phase­
out
schedule
of
methyl
bromide
(
USDA,
2002).

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2005
2006
106,193
758
8
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE:

The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
eggplant
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
eggplant
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
US
is
only
nominating
a
CUE
for
eggplants
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
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.

Methyl
bromide
is
the
only
fumigant
that
consistently
provides
reliable
control
of
target
weeds,
nematodes,
and
pathogens.
There
are
no
technically
or
economically
feasible
alternatives.
The
best
alternatives
(
e.
g.
1,3­
D
+
chloropicrin,
metam
sodium)
are
not
as
effective
in
controlling
nutsedge
and
have
a
long
waiting
period
for
planting
that
would
disrupt
planting
schedules
and
cause
growers
to
miss
key
market
windows.
Furthermore,
regulatory
restrictions
due
to
concerns
over
human
exposure
and
ground
water
contamination,
along
with
technical
limitations,
result
in
potential
economic
infeasibility
of
1,3­
D
alone
or
in
combination
as
a
practical
MB
alternative.
Key
among
these
factors
are
a
28
day
planting
delay
due
both
to
label
restrictions
and
low
soil
temperatures
and
a
mandatory
30.4
m
buffer
for
treated
fields
near
inhabited
structures.

5.1
Michigan
In
Michigan
eggplant,
no
currently
available
methyl
bromide
(
MB)
alternative
exists
that
is
technically
feasible
for
the
control
of
the
key
target
pathogen,
Phytophthora
capsici
except
1,3­
D
+
chloropicrin.
These
soil
fungi
can
easily
destroy
the
entire
harvest
from
affected
areas
if
left
uncontrolled.
While
1,3­
D
+
chloropicrin
provided
some
control
in
small
plot
trials
with
peppers
and
cucurbits
in
Michigan
(
Hausbeck
and
Cortright
2003),
the
level
of
control
was
lower
than
that
afforded
by
MB.
It
is
also
noteworthy
that
at
least
one
of
the
pests
in
question,
P.
capsici,
has
recently
been
shown
to
occur
in
irrigation
water
in
Michigan
(
Gevens
and
Hausbeck
2003).
This
will
increase
the
likelihood
of
spread
of
this
pathogen.
It
is
also
not
yet
clear
whether
these
small­
scale
results
accurately
reflect
efficacy
of
MB
alternatives
in
commercial
fresh
vegetable
(
peppers,
eggplant,
cucurbit)
production.
Furthermore,
regulatory
restrictions
(
e.
g.,
mandatory
30
m
buffer
zone
for
treated
fields
near
inhabited
structures)
due
to
concerns
over
human
exposure
and
ground
water
contamination,
along
with
technical
and
economic
limitations,
result
in
potential
infeasibility
of
this
formulation
as
a
practical
MB
alternative.
Also,
planting
delays
restrictions
(
21
to
30
days)
or
variations
in
soil
temperatures
or
rainfall
could
cause
delays
in
fumigation
events,
since
all
fumigations
must
be
completed
by
the
first
week
of
May.

Based
on
a
small­
plot
trial
conducted
on
Michigan
peppers
cited
above,
the
best­
case
yield
loss
estimate
for
Michigan
using
the
best
available
MB
alternative
(
1,3­
D
+
chloropicrin)
is
estimated
to
be
6%.
In
untreated
buffer
areas,
losses
could
approach
100
%
in
the
worst
case
scenario.
There
may
also
be
unpredictable
but
potentially
significant
economic
effects
created
by
the
planting
delays
(
described
above),
which
will
disrupt
the
schedule
of
delivery
of
fresh
pepper
harvest
to
wholesale
buyers.
9
Florida
and
Georgia
Nutsedges,
when
present
at
moderate
to
severe
infestations,
are
key
pests
which
require
MB
for
control
in
the
Southeastern
United
States,
including
Florida
and
Georgia.
Phytophthora
is
also
a
key
pest.
Of
MB
alternatives,
only
1,3­
D
+
chloropicrin
has
some
efficacy
against
Phytophthora.
However,
1,3­
D
cannot
be
applied
in
areas
overlying
karst
geology
which
is
common
throughout
the
Southeast.

Growers
in
this
region
also
face
root­
knot
nematodes
and
the
fungal
pathogens
described
above
as
key
pests.
Left
uncontrolled,
any
of
these
pests
could
completely
destroy
the
harvests
from
affected
areas.
Halosulfuron,
which
is
effective
against
nutsedges,
can
be
applied
only
in
row
middles,
but
cannot
be
applied
in
raised
beds,
where
nutsedge
competition
is
critical
(
Florida
CUE
#
03­
0054).

Metam­
sodium
offers
erratic,
inconsistent
control
of
nutsedges
and
nematodes,
while
1,3­
D
+
chloropicrin
provides
adequate
control
of
nematodes
(
Eger
2000,
Noling
et
al.
2000).
However,
metamsodium
has
yield
losses
of
up
to
44
percent
compared
to
MB
where
weed
infestations
are
moderate
to
severe
(
Locascio
et
al.
1997).
Metam­
sodium
also
creates
a
planting
delay
as
long
as
28
days
to
avoid
risk
of
phytotoxic
injury
o
crops
compared
to
a
14­
day
delay
for
MB.
Further,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology.
There
is
a
21­
day
planting
delay
(
vs.
14
days
for
MB)
due
to
regulatory
restrictions
for
1,3­
D
+
chloropicrin
also.
Any
apparent
technical
feasibility
of
metam­
sodium
and
1,3
D
+
chloropicrin
(
and
various
combinations
thereof)
are
based
on
small
plot
research
trials
that
done
on
crops
other
than
eggplant.
For
fungi
and
nutsedge
pests
at
least,
no
on­
farm,
large
scale
trials
have
yet
been
done.
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
microorganisms.
This
phenomenon
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.

In
sum,
neither
of
these
MB
alternatives
is
presently
adequate
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
eggplant
in
the
Southeastern
United
States.

Implications
of
MB
loss
for
individual
growers
If
MB
were
to
be
removed
as
a
pest
control
option
for
U.
S.
eggplant,
the
particular
growers
in
each
region
cited
in
this
nomination
would
have
to
stop
crop
production
or
suffer
substantial
losses.
These
growers
would
either
leave
agriculture
entirely
or
switch
to
other
crops
that
do
not
rely
on
pre­
plant
fumigation
for
soil
pest
control.
The
extent
of
this
impact
on
the
affected
growers
is
debatable,
but
given
the
current
embryonic
state
of
commercial
deployment
of
MB
alternatives,
it
is
possible
that
growers
who
currently
treat
their
land
routinely
with
MB
would
face
this
outcome.
10
TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
EGGPLANT*
Region
Florida
Georgia
Michigan
AMOUNT
OF
NOMINATION
2006
Kilograms
73,716
27,769
3,951
Application
Rate
(
kg/
ha)
150
150
48
Area
(
ha)
491
185
82
AMOUNT
OF
APPLICANT
REQUEST
2005
Kilograms
97,250
48,868
4,027
Application
Rate
(
kg/
ha)
150
150
120
Area
(
ha)
647
325
36
2006
Kilograms
97,250
48,868
3,951
Application
Rate
(
kg/
ha)
150
150
48
Area
(
ha)
647
325
82
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Marginal
Strategy
1,3­
D
+
Pic
1,3­
D
+
Pic
1,3­
D
+
Pic
Yield
Loss
(%)
29
%
29
%
6%
Loss
per
hectare
(
US$/
ha)
$
5,252
$
7,593
$
4,076
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
35
$
51
$
84
Loss
as
%
of
Gross
Revenue
(%)
24%
18%
12%
Loss
as
%
of
Net
Revenue
(%)
82%
72%
44%

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

In
Florida
and
Georgia,
where
weeds,
especially
nutsedge,
are
the
main
methyl
bromide
target
pests
neither
1,3­
D
nor
metam
sodium,
alone
or
in
combination
with
chloropicrin,
adequately
control
moderate
to
high
nutsedge
populations.
In
Florida
and,
to
a
lesser
extent
in
Georgia,
the
use
of
1,3­
D
is
prohibited
in
areas
overlying
karst
geology
because
of
groundwater
contamination
concerns.
It
is
estimated
that
40%
of
the
Florida's
production
area
overlies
karst
geology.
The
1,3­
D
label
prohibits
its
use
in
Dade
County,
Florida.
Moreover,
for
Florida
and
Georgia
farmers,
using
products
containing
1,3­
D
and
metam
sodium
in
the
fall
may
be
impractical
because
of
the
required
longer
waiting
periods
for
planting
following
application,
28
days
for
1,3­
D
and
21
days
for
metam
sodium,
compared
to
14
days
for
methyl
bromide.
Such
delays
could
cause
Florida
and
Georgia
growers
to
miss
part
of
the
key
market
windows.

In
Michigan,
where
soil­
borne
pathogens
are
the
key
methyl
bromide
target
pests,
neither
1,3­
D
nor
metam
sodium
is
effective
against
soil­
borne
fungi.
Furthermore,
the
28
and
21
day
planting
delays
for
1,3­
D
and
metam
sodium,
respectively,
might
disrupt
this
state's
carefully­
timed
planting
and
harvesting
schedules,
causing
growers
to
miss
part
of
the
market
windows.
The
1,3­
D
+
chloropicrin
combination
may
be
as
effective
as
methyl
bromide
against
soil­
borne
pathogens.
However,
the
21­
day
planting
delay
would
hinder
grower
adoption
of
this
alternative.

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
2001­
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Florida
647
100
Georgia
497
64%

Michigan
Not
available
Not
available
NATIONAL
TOTAL:
2197
51
*
See
Appendix
A
for
a
complete
description
of
how
the
nominated
amount
was
calculated.
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
Georgia,
areas
not
treated
with
MB
do
not
have
nutsedges
or
nematodes
naturally
present
in
eggplant
fields.
Simple
absence
of
all
pests
is
the
only
reason
these
areas
are
not
presently
treated
with
MB.
In
Michigan,
areas
not
treated
apparently
do
not
have
any
infestation
(
i.
e.,
zero
oospores
or
chlamydospores
per
unit
soil)
of
the
key
fungal
pests.
The
applicant
states
that
soil
infestation
is
spreading
in
the
region
annually.

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?

Growers
have
the
option
to
use
halosulfuron
only
in
row
middles.
12
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
FLORIDA
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
FLORIDA
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
97,250
97,250
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Strip
Bed
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
or
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
647
ha
647ha
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
150
150
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
224
224
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
15
15
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

GEORGIA
­
TABLE
8.2:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
GEORGIA
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
48,868
48,868
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Predominantly
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)
325
325
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
224
224
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
150
150
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
22
22
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
15
15
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
13
MICHIGAN
­
TABLE
8.3:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
MICHIGAN
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
4,027
3,951
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Predominantly
Strip
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
or
50:
50
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
83
82
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
48
48
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
17.9
17.9
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
32.2
Strip
treatment
32.2
Strip
treatment
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
methyl
bromide
nominated
by
the
US
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
applicant
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,
regulatory
impacts,
karst
topography,
buffer
zones,
unsuitable
terrain,
and
cold
soil
temperatures.
14
TABLE
A.
2:
2005
SECTOR
REQUEST
­­
EGGPLANT*

2005
Eggplant
Sector
Request
Florida
Georgia
Michigan
Requested
Hectares
(
ha)
647
325
83
Requested
Application
Rate
(
kg/
ha)
150
150
48
Applicant
Request
for
2005
Requested
Kilograms
(
kg)
97,250
48,868
4,027
TABLE
A.
3:
2006
SECTOR
NOMINATION
­­
EGGPLANT
2006
Eggplant
Sector
Nomination
Florida
Georgia
Michigan
Requested
Hectares
(
ha)
647
325
82
Requested
Application
Rate
(
kg/
ha)
150
150
48
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
97,250
48,868
3,951
Nominated
Hectares
(
ha)
491
185
82
Nominated
Application
Rate
(
kg/
ha)
150
150
48
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
73,716
27,769
3,951
Overall
Reduction
(%)
29
2006
U.
S.
CUE
Nomination
(
kg)
106,193
Research
Amount
(
kg)
433
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
106,626
*
See
Appendix
A
for
a
complete
description
of
how
the
nominated
amount
was
calculated.
15
FLORIDA­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
FLORIDA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
FLORIDA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TARGET
PESTS
(
WEEDS,
PLANTPARASITIC
NEMATODES)
AND
PATHOGENS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Florida
Purple
and
Yellow
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus),
Root­
knot
nematodes
(
Meloidogyne
spp.),
Nightshade
(
Solanum
spp.),
Morningglory
(
Ipomoea
spp.),
Southern
blight
(
Sclerotium
rolfsii)
Methyl
bromide
is
the
only
fumigant
that
consistently
controls
key
target
weeds
affecting
eggplant
in
Florida.
Neither
1,3­
D
nor
metam
sodium
is
effective
under
high
nutsedge
population
pressures.
1,3­
D
cannot
be
applied
in
areas
overlying
karst
geology
(
about
40%
of
the
production
area
in
Florida).

FLORIDA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
FLORIDA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
FLORIDA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Vegetable
crop
for
fresh
market
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)
Peppers,
cucurbits
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
and
sandy­
loam
soils
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annually
OTHER
RELEVANT
FACTORS:
Double­
cropped
with
cucurbit;
may
be
preceded
by
pepper.

TABLE
11.2:
CHARACTERISTICS
OF
CLIMATE
AND
EGGPLANT
CROP
SCHEDULE:
NOT
DOUBLE­
CROPPED
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
Zones:
9a,
10a,
10b
­
In
1997,
80%
of
the
state's
eggplant
production
was
in
the
southeast;
remainder
of
about
20%
distributed
in
the
rest
of
the
state,
mostly
in
the
central
and
northern
regions.
RAINFALL
(
mm)
65.5
50.0
72.5
134.1
175.8
193.3
152.7
65.0
42.7
158.8
62.0
66.8
OUTSIDE
TEMP.(
°
C)
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16.0
16.9
FUMIGATION
SCHEDULE;
A
X
X
X
X
X
X
X
X
PLANTING
SCHEDULE
B
E
E
E
E
E
E
E
E
KEY
HARVEST
WINDOW;
C
E
E
E
E
E
E
E
E
E
ANon­
double
cropped.:
earliest
start
date:
June
15;
shaded
cells
represent
variation
in
fumigation
initiation
amongst
eggplant
growers.
C
For
Non­
Double
cropped
eggplant
production,
planting
eggplants
is
usually
initiated
around
July
1;
shaded
cells
represent
variation
in
transplanting
dates
EFor
Non­
Double
Cropped
Eggplants;
Harvest
Period
usually
begins
as
early
as
Nov.
1,
may
continue
until
July
31,
depending
on
when
planted
and
weather
conditions.
16
TABLE
11.3:
CHARACTERISTICS
OF
CLIMATE
AND
EGGPLANT
CROP
SCHEDULE;
DOUBLE­
CROPPED
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
Zones
9a,
10a,
10b
­
In
1997,
80%
of
the
state's
eggplant
production
was
in
the
southeast;
remainder
of
about
20%
distributed
in
the
rest
of
the
state,
mostly
in
the
central
and
northern
regions.
RAINFALL
(
mm)
65.5
50.0
72.5
134.1
175.8
193.3
152.7
65.0
42.7
158.8
62.0
66.8
OUTSIDE
TEMP.(
°
C)
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16.0
16.9
FUMIGATION
SCHEDULE
A
X
X
X
X
PLANTING
SCHEDULE
B
E
E
E
E
2C
KEY
HARVEST
WINDOW
F
E
E
2C
2C
2C
E
E
E
E
A
Double­
cropped;
assumed
to
be
with
cucurbits;
earliest
start
date
is
June
15;
shaded
cells
represent
variation
in
fumigation
initiation
among
eggplant
growers
who
double­
crop.
B
For
Double­
Cropped
eggplant
production,
planting
(
E)
is
typically
initiated
on
July
1;
variance
can
be
until
October
1,
as
represented
by
the
shaded
cells.
The
second
crop
of
cucurbits
transplants
would
typically
be
initiated
around
Feb
1,
and
may
vary
until
end
of
Feb,
or
1st
part
of
March.
C
For
Double
Cropped
Eggplants,
Harvest
Period
usually
begins
as
early
as
Nov.
15
(
E),
may
continue
until
April
15,
depending
on
when
planted
and
weather
conditions;
Harvesting
of
second
crop
(
2C)
may
start
around
May
1
and
continue
until
mid­
July
FLORIDA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

The
karst
geology
prevalent
in
Florida
and,
to
a
lesser
extent,
Georgia
severely
limits
the
use
of
I,
3­
D
in
those
States.
There
are
no
atypical
characteristics
identified
in
the
nomination
which
might
prevent
the
utility
of
Devrinol
 
(
napromide)
and
trifluralin
for
nutsedge
control
and
for
control
of
broad­
leaved
weed
species,
such
as
morningglory.
Halosulfuron,
however
has
several
label
limitations
(
e.
g.,
reduced
effectiveness
if
rain
events
follow
within
4
hours
of
application),
and
plant­
back
restrictions
(
0
to
36
months)
(
U.
S.
EPA,
CUN
2003/
050).

FLORIDA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
FLORIDA
­
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)
971
890
809
728
728
728
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
63,335
149,723
127,384
114,646
114,623
114,623
FORMULATIONS
OF
METHYL
BROMIDE
MB
/
chloropicrin)
98:
2
98:
2
67:
33
or
98:
2
67:
33
or
98:
2
67:
33
or
98:
2
67:
33
or
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Sweptback
chisel­
shank,
25­
30.5
cm
deep
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
159­
182
159­
182
159­
182
159­
182
159­
182
159­
182
DOSAGE
RATE*(
G/
M
2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
251
251
235
235
235
235
APPLICATION
RATE
FOR
THE
ACTIVE
INGREDIENT
IN
kg/
ha*
168
168
157
157
157
157
ACTUAL
DOSAGE
RATE
FOR
THE
ACTIVE
INGREDIENT
(
g/
m2)*
16.8
16.8
15.7
15.7
15.7
15.7
APPLICATION
RATE
OF
STRIP/
BED
(
g/
m2)
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
17
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION
FLORIDA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
FLORIDA
 
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
(
Telone
 
)
Limestone
solution
channels
potentially
leading
to
groundwater
("
karst
geology)
underlies
a
portion
of
FL
production
area;
estimated
to
be
about
40%
in
2002
for
eggplant
area;
Telone
is
not
labeled
for
use
in
Dade
County.
No
Halosulfuron
Registered
for
use
on
eggplant
(
Dec.
2002,
US
EPA,
Aug.
2003);
use
restricted
to
the
middle
row
only;
potential
crop
injury;
severe
plant
back
restrictions
from
3
to
36
months
for
most
vegetables;
severe
restrictions
when
used
in
pest
management
strategy
that
includes
soil­
applied
organophosphates.
No
Metam­
sodium
(
Vapam
 
)
Does
not
work
under
high
pest
pressure.
Limited
niche
as
a
complementary
treatment
with
other
fumigants
and
herbicides,
never
stand
alone
(
Noling,
2003).
Considered
as
best
available
alternative
for
Dade
County
only
(
Aerts,
2003)
No
Napromide
(
Devrinol
 
)
Weak
in
terms
of
nutsedge
efficacy;
does
not
control
established
weeds
(
CUE
03­
0017);
waste
of
money
(
Noling,
2003)
No
Trifluralin
Aids
in
control
of
annual
grasses;
does
not
manage
broadleaf
weeds.
May
cause
excessive
crop
stress
leading
to
reductions
in
stands
and
yields.
No
NON
CHEMICAL
ALTERNATIVES
Solarization
Weed
density
(
yellow
and
purple
nutsedge
was
greater
in
the
solarized
treatments
compared
to
the
methyl
bromide
treatment.
Worked
for
the
1st
year
in
FL
peppers;
if
pest
threshold
is
low
(
Chellemi,
et
al.,
1997)
No
Myrothecium
verrucaria(
Ditera
 
)
Biological
nematicide;
registered
on
broad
range
of
crops,
field
efficacy
is
untested
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
(
Telone
II
or
Telone
C­
35)
+
Devrinol
+
trifluralin
Strategy
involves
applying
1,3­
D
Flat
Fumigation,
followed
by
chloropicrin
3­
4
wks
post
fumigation
+
both
herbicides
before
laying
plastic.
Chloropicrin
may
not
be
efficacious
in
managing
white
mold
(
Sclerotium
rolfsii).
Producers
in
Dade
County
are
prohibited
from
using
Telone
products.
Yes,
except
for
areas
with
underlying
karst
geology.

Solarization
+
1,3­
D
May
work
in
areas
with
low
weed,
pest
or
disease
pressure.
Eliminated
root
galling
and
high
density
of
root­
knot
nematodes.
(
Chellemi,
D.
O.,
et
al.
1997.
Application
of
soil
solarization
to
Fall
Production
of
cucurbits
and
pepper.
Proc.
Fla.
State
Hort.
110:
333­
336.)
No
Solarization
+
biocontrol
fungus,
Gliocladium
virens
Ristaino,
J.
B.,
Perry,
K.
B.
and
R.
D.
Lumsden.
1996.
Soil
solarization
and
Gliocladium
virens
reduce
the
incidence
of
southern
blight
(
Sclerotium
rolfsii)
in
bell
pepper
in
the
field.
Biocon.
Sci.
and
Tech.
6:
583­
593.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
18
FLORIDA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

FLORIDA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
below
ground
portions
of
eggplants.

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

FLORIDA
 
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:
Iodomethane
Pre­
plant
soil
fumigant.
Not
registered
yet.
Yes
Unknown
Trifloxysulfuron
sodium
Herbicide.
Registration
pending
ONLY
in
tomato,
FL
only.
Crop
Injury
issues
exist.
Yes
Unknown
Fosthiazate
OP
nematicide.
Not
registered.
Yes
Unknown
Furfural
(
Multigard

)
Not
registered.
Yes
Unknown
Sodium
azide
Not
registered.
Registration
application
not
yet
submitted.
No
Unknown
Propargyl
bromide
Not
registered.
Registration
application
not
yet
submitted.
No
Unknown
Paecilomyces
lilacinus
Biological
nematicide.
Registration
pending.
Yes
Unknown
19
FLORIDA
­
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:

FLORIDA
 
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,
fungal
pathogens
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,
fungal
pathogens
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
Data
(
narrative
only)
and
information
are
bridged
for
eggplants
from
the
best
available
information
(
Locascio
et
al.
1997).

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations.
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%)
chiselinjected
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
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metam­
sodium
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,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists.

TABLE
16.1.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)

Chemicals
Rate
(/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Untreated
(
control)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­
1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
20
Notes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.

Yield
loss
estimates
could
likely
be
lower
for
growers
who
can
legally
use
1,3­
D
products.
For
example,
evidence
from
one
tomato
and
bell
pepper
grower
using
Telone
II
on
30
percent
of
his
total
area
suggests
that
average
yields
declined
6.16
%
across
all
fields,
while
average
yield
declines
were
15.77
%
in
sideby
side
plantings
(
FFVA,
2002).
The
standard
deviation
on
these
yields
did
not
change,
which
resulted
in
an
increase
in
the
coefficient
of
variation
from
32.7
percent
on
fields
planted
to
methyl
bromide
to
38.3
percent
on
fields
planted
to
Telone
II.
These
results
suggest
that
alternatives
to
methyl
bromide
reduce
yields
by
as
much
as
15.7
%
and
that
risk
associated
with
yield
variability
would
likewise
increase.
Page
21
FLORIDA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:

Iodomethane
is
under
consideration
for
potential
methyl
bromide
replacement.
Although
it
is
currently
being
considered
for
registration
by
regulatory
authorities,
it
is
unknown
when
it
will
be
registered.
Please
refer
to
Table
15.1
for
detailed
information.

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

The
U.
S.
Government
is
presently
unaware
of
large
scale,
commercial
greenhouse
operations
for
eggplants.
It
might
be
expected,
however
that
there
are
local
(
or
small
community)
operations
of
organic
eggplant
production
that
target
fresh
market
and/
or
temporal
(
seasonal)
sectors.

FLORIDA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
In
Florida
neither
1,3­
D
nor
metam
sodium,
alone
or
in
combination
with
chloropicrin,
adequately
control
moderate
to
high
nutsedge
populations.
In
addition,
1,3­
D
cannot
be
applied
in
areas
overlying
karst
geology,
estimated
to
be
40%
of
the
production
area
in
the
State.
Furthermore,
using
products
containing
1,3­
D
and
metam
sodium
in
the
fall
would
mean
longer
waiting
periods
for
planting
following
application,
28
days
for
1,3­
D
and
21
days
for
metam
sodium,
compared
to
14
days
for
methyl
bromide.
Such
delays
may
cause
Florida
growers
to
miss
part
of
the
key
market
windows.

The
top
priority
of
control
associated
with
each
major
segment
of
pest
management
across
Florida
eggplant
production
regions
remained
weeds,
especially
the
nutsedges,
because
of
the
lack
of
registered
herbicides
that
do
not
cause
crop
injury,
or
have
severe
plant­
back
restrictions.
When
nutsedge
pressure
is
moderate
to
severe,
the
1,3­
D
+
chloropicrin
combination
is
not
technically
feasible
because
it
needs
to
be
coupled
with
an
effective
herbicide
to
provide
control
for
the
entire
growing
season
(
U.
S.
EPA,
2002).
There
are
no
herbicides
which
control
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041).

In
the
study
reported
in
Item
16
(
Table
16.1
),
1,3­
D
+
chloropicrin
treatments
did
not
adequately
control
moderate
to
high
nutsedge
populations,
and
yield
losses
occurred
when
compared
to
MB
plus
chloropicrin
treatments.
Additional
research
on
this
alternative
to
improve
efficacy
against
nutsedge
is
needed
in
areas
with
moderate
to
high
nutsedge
pressure.
Lack
of
an
effective,
registered
herbicide
impairs
adoption
in
crops
such
as
eggplant
(
Banks,
2002).

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Phytophthora
spp.,
Verticillium
spp.,
Pythium
spp.
and
Rhizoctonia
solani)
may
be
curtailed
if
weather
conditions
are
detrimental
for
disease
development.
These
pathogens
commonly
reside
in
many
production
areas,
since
many
eggplant
production
areas
are
old
tomato
production
fields.
Fungicides
such
as
chlorothalonil,
and
azoxystrobilurin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp.
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck,
2003).

Nematode
pests,
such
as
the
root
knot
nematode
species
of
Meloidogyne,
were
third
to
weed
pests
in
terms
of
priority
of
pest
management
strategies
in
Florida
eggplant
production.
Pre­
plant
control
of
Page
22
nematodes
is
critical
since
nematode
root
feeding
and
damage
may
predispose
plant
tissues
to
invasion
by
fungal
pathogens,
potentially
leading
to
wilt,
loss
of
plant
vigor,
and
significant
yield
losses.
Fumigant
alternatives
such
as
metam­
sodium
have
proven
inconsistent
(
Noling,
2003;
FFVA,
2002).

Approximately
40
percent
of
the
eggplant
production
area
in
Florida
has
karst
geology.
Because
it
is
illegal
for
producers
to
use
1,3­
D
products
(
Telone
II,
Telone
C­
35)
on
these
soils,
growers
would
likely
use
a
combination
of
metam­
sodium
+
a
herbicide,
such
as
halosulfuron
or
napropamide.
Page
23
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
TARGET
PESTS
(
WEEDS,
PLANT­
PARASITIC
NEMATODES)
AND
PATHOGENS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Georgia
1.
Yellow
and
Purple
Nutsedge
(
Cyperus
esculentus,
C.
rotundus)
[
100%]
2.
Crown
and
Root
rot
(
Phytophthora
capsici)
[
40%]
3.
Plant­
parasitic
nematodes
(
Meloidogyne
incognita;
Pratylenchus
sp)
[
70%]
4.
Southern
Blight
(
Sclerotium
rolfsii)
[
70%]
5.
Pythium
root
and
collar
rots
(
P.
irregulare,
P.
myriotylum,
P.
ultimum,
P.
aphanidermatum)
[
100%]
Registered
alternatives
are
not
as
effective
as
methyl
bromide.
Methyl
bromide
is
needed
for
timely
management
of
targeted
pests
and
pathogens.
Using
products
containing
1,3­
D
and
metam
sodium
in
the
fall
is
impractical
because
of
the
long
waiting
periods
for
planting
following
application
under
plastic
mulch.
For
1,3­
D
there
is
a
28
day
waiting
period;
for
metam
sodium,
there
is
a
21­
day
waiting
period.
Such
delays
could
cause
growers
to
miss
part
of
the
higher
market
windows.

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)
Vegetable
crop
for
the
fresh
market
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual;
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Eggplants,
followed
by
a
cucurbit
crop
(
cucumbers,
or
squash)
or
pepper.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam;
clay
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
per
year;
(
either
in
spring
or
fall)

OTHER
RELEVANT
FACTORS:
The
grower
may
complete
two,
three
or
even
four
crops
in
one
fumigation
cycle.
Page
24
GEORGIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
"
PLANT
HARDINESS
ZONE"
(
e.
g.
temperate,
tropical)
Climate
zones
7a,
7b,
8a,
and
8b
noted
in
the
application.
Zone
7a:
­
15.0
to
 
17.7
°
C
(
0
to
5
°
F):
Oklahoma
City,
OK;
South
Boston,
VA
Zone
7b:
­
12.3
to
14.9
°
C
(
5
to
10
°
F);
Griffin,
GA
Zone
8a:
­
9.5
to
­
12.2
°
C
(
10
to
15
°
F);
Tifton,
GA
Zone
8b:
­
6.7
to
 
9.4
°
C
(
15
to
20
°
F);
Austin,
TX;
Gainesville,
FL
Portions
of
GA
fall
into
all
four
of
these
zones.

SOIL
TEMP.
(
°
C)
64.1
72.5
80.8
85.9
87.8
86.8
82.2
73.9
34.0
54.0
51.1
55.5
RAINFALL
(
mm)
5.0
3.8
3.5
4.5
5.6
4.8
3.4
2.3
2.3
4.5
4.5
4.2
AMBIENT
TEMP.
(
°
C)
)
69.8
77.7
84.7
89.4
90.7
90.5
87.3
79.3
69.8
63.1
61.5
64.0
FUMIGATION
SCHEDULE
A


PLANTING
SCHEDULE
A,
B




KEY
HARVEST
(
MARKET)
WINDOW
A,
B




Shaded
areas
represent
typical
duration
of
activity
.
Darker
shaded
areas
represent
duration
of
activities
for
the
second
crop.
AFumigation,
a
fall
application
only.
Methyl
bromide
applied
either
in
the
spring
or
fall
allows
the
grower
to
economically
produce
at
least
two
crops
(
sometimes
3
or
4),
the
second
crop
usually
cucumbers,
from
one
fumigation
event.
BTwo
crops
are
represented
from
one
fumigation
event.

=
initiation
of
planting
and/
or
harvest
of
first
crop;

=
termination
of
planting
and/
or
harvest
of
first
crop.

=
initiation
of
planting
and/
or
harvest
of
second
crop;

=
termination
of
planting
and/
or
harvest
of
second
crop.

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

Nearly
all
of
the
vegetable
production
occurs
on
Coastal
Plain
Soils
are
subject
to
high
temperatures
and
excess
heat.
In
addition
to
weed
pests,
soil­
borne
fungal
pathogens
and
plant­
parasitic
nematodes
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thereby
necessitating
annual
treatment
with
a
soil
fumigant.
Page
25
GEORGIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
EGGPLANTS,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
GEORGIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
EGGPLANTS
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
284
168
251
333
315
321
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
70312
41,407
47,723
50,023
47,288
48,139
FORMULATIONS
OF
METHYL
BROMIDE
(
e.
g.
methyl
bromide
98:
2;
methyl
bromide
/
chloropicrin
70:
30)
98:
2
98:
2
98:
2
(
15%
of
area
)
67:
33
(
85%
of
area)
67:
33
67:
33
67:
33
METHODS
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
APPLICATION
RATE
(
KG/
HA)
FOR
THE
FORMULATION
252
252
194/
283
224
224
224
APPLICATION
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
247
247
191
150
150
150
DOSAGE
RATE*(
G/
M
2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
25.2
25.2
19.4/
28.3
22.4
22.4
22.4
ACTUAL
DOSAGE
RATE
FOR
THE
ACTIVE
INGREDIENT
(
g/
m2)*
24.7
24.7
19.1
15.0
15.0
15.0
APPLICATION
RATE
OF
STRIP/
BED,
G
MB/
M
2
Approximately
58%
of
the
total
area
is
covered
with
plastic
mulch
and
treated
with
methyl
bromide
in
each
acre.

For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same
Page
26
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
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
CHEMICAL
ALTERNATIVES
1,3­
D
products
(
includes
Telone
II,
Telone
EC,
&
Telone
C­
35)
Products
will
not
adequately
control
nutsedge.
Label
restriction
states
that
these
products
cannot
be
used
where
karst
geology
exists
(~
8%
of
the
production
area).
Up
to
2
applications
of
Telone
II,
in­
line,
or
EC
formulations
may
be
needed
to
manage
moderate
to
severe
pest
population
levels.
Also,
there
is
a
28­
day
waiting
period
at
the
time
of
application
until
planting,
which
could
cause
loss
of
over
half
of
the
harvest
season
and
the
higher­
end
market
windows
to
be
missed.
These
are
plantings
made
in
July
and
harvested
in
the
fall
(
Georgia
CUE
#
03­
0049;
Kelley,
2003).
This
only
applies
to
light
to
moderate
infestations
and
only
with
Telone
C­
35.
No
Metam­
sodium
Product
does
not
adequately
control
nutsedge.
Also,
there
is
a
21­
day
waiting
period
at
the
time
of
application
until
planting
(
40%
of
harvest
season
missed),
which
may
cause
part
of
the
higher­
end
market
windows
to
be
missed.
These
are
plantings
made
in
July
and
harvested
in
the
fall.
Beginning
the
application
cycle
earlier
is
not
an
option,
since
crops
from
the
previous
fumigation
cycle
must
be
terminated
and
cleaned
up
prior
to
metam
application
(
Georgia
CUE
#
03­
0049;
Kelley,
2003).
Repeated
applications
of
MITC
(
the
breakdown
product
of
metam
sodium)
are
known
to
enhance
its
biodegradation
as
a
result
of
adapted
microorganisms
(
Duncan
and
Yates,
2003).
No
Page
27
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Halosulfuron
Registered
for
specific
uses
in
eggplant
(
Dec.
2002,
US
EPA,
Aug.
2003);
application
for
eggplant
is
for
ROW
MIDDLE
application
and
would
not
provide
control
of
nutsedge
in
the
eggplant
bed;
potential
crop
injury;
severe
plant
back
restrictions
from
3
to
36
months
for
most
vegetables.
No
COMBINATIONS
OF
ALTERNATIVES
­­­

1.
1,3­
D
products
and
a
herbicide,
e.
g.
napropamide
2.
Metam­
sodium
and
a
herbicide,
e.
g.
napropamide
3.
Iodomethane
and
a
herbicide,
e.
g.
napropamide
4.
Glyphosate
treatment
of
plots
between
the
first
and
second
crops
(
Webster,
et
al.
2001)

5.
Pest­
resistant
cultivars
combined
with
alternative
fumigant
strategies
1,
2,
and
3
Currently,
there
are
no
data
to
substantiate
transition
toward
a
suitable
alternative
to
annual
methyl
bromide
fumigation.
Alternative
chemicals
and
cultural
practices
that
are
under
consideration
include
various
combinations
of
currently
registered
and
unregistered
fumigants
and/
or
herbicides.

Iodomethane
is
not
registered
in
the
U.
S.
Please
refer
to
question
15
for
detailed
and
specific
information
regarding
the
alternatives.
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
NAME
OF
ALTERNATIVE
DISCUSSION
none
Other
than
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
below
ground
portions
of
eggplants.
Page
28
The
U.
S.
EPA
only
considered
those
technically
feasible
registered
alternatives
which
are
relevant
for
managing
severe
pathogen
and
pest
pressures.
Therefore
research
or
data
presented
in
the
CUN2003/
050
 
Eggplant
Grown
Outdoors
on
Plastic
Mulch
are
not
included
in
the
present
eggplant
sector
analysis
are
irrelevant.
For
example,
Table
2
(
page
4)
represented
data
extracted
from
a
field
study
conducted
under
low
nutsedge
pressure.

Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041).

Fumigation
of
products
containing
1,3­
D
and
metam
sodium
(
Vapam
and/
or
K­
pam)
in
the
summer
or
fall
is
practically
impossible
because
of
the
waiting
periods
for
planting
following
application
under
plastic
mulch.
For
1,3­
D
there
is
a
28­
day
waiting
period;
for
metam
sodium,
there
is
a
21­
day
waiting
period.
Such
delays
may
cause
reduction
in
yields
and
market
windows
missed.
Thus,
since
the
fall
crop
is
dependent
upon
timely
planting,
a
long
waiting
period
(
e.
g.,
28
days)
would
cost
growers
at
least
half
of
the
harvest
season,
thereby
missing
the
higher
market
windows
(
Kelley,
2003).

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:
Iodomethane
Not
registered
Yes
Unknown
Fosthiazate
Not
registered.
Yes
Unknown
Furfural
(
Multigard

)
Not
registered
Yes
Unknown
Sodium
azide
Not
registered.
Registration
application
not
yet
submitted.
No
Unknown
Propargyl
bromide
Not
registered.
Registration
application
not
yet
submitted.
No
Unknown
Paecilomyces
lilacinus
Not
registered.
Registration
pending.
Yes
Unknown
Page
29
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:
(
Use
same
groups
as
in
Question
10
and
provide
a
separate
table
for
each
target
group
for
which
methyl
bromide
is
considered
essential.
Omit
pathogen
and/
or
weed
tables
if
these
are
not
the
reason
why
critical
use
is
requested.)
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
Data
(
narrative
only)
and
information
are
bridged
for
eggplants
from
the
best
available
information.

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations.
Various
treatments
were
tested
on
plots
that
had
multiple
pests
(
Table
16.1).
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;
metamsodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metam­
sodium
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,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists.

TABLE
16.1.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)

Chemicals
Rate
(/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Untreated
(
control)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­

1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
Notes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
Page
30
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.

GEORGIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:
(
If
so,
please
specify.)

Iodomethane
is
under
consideration
for
potential
methyl
bromide
replacement.
Although
it
is
currently
being
considered
for
registration
by
regulatory
authorities,
it
is
currently
unknown
when
it
will
be
registered.
Please
refer
to
Table
15.1
for
detailed
information.

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

No.
Any
organic
production
of
eggplants
is
presumed
insignificant
and
probably
not
cost­
effective
because
of
the
intensive
management
of
pests
(
for
organic
production)
and
the
long
growing
season.
Page
31
GEORGIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Neither
1,3­
D
nor
metam
sodium,
alone
or
in
combination
with
chloropicrin,
adequately
control
moderate
to
high
nutsedge
populations
in
Georgia.
In
addition,
1,3­
D
cannot
be
applied
in
areas
overlying
karst
geology
(~
8
%
of
the
eggplant
area;
CUE
#
03­
0050).
Furthermore,
using
products
containing
1,3­
D
and
metam
sodium
in
the
fall
is
impractical
because
of
the
required
long
waiting
periods
for
planting
following
application,
28
days
for
1,3­
D
and
21
days
for
metam
sodium.
Such
delays
would
cost
Georgia
farmers
at
least
half
of
the
harvest
season,
thereby
missing
key
market
windows.

In
studies
on
peppers
(
Csinos
et
al.
1999,
Noling
et
al.
2000),
1,3­
D
+
chloropicrin
treatments
did
not
adequately
control
moderate
to
high
nutsedge
populations,
and
yield
losses
occurred
when
compared
to
MB
plus
chloropicrin
treatments.
Additional
research
on
this
alternative
to
demonstrate
efficacy
against
nutsedge
is
needed
in
areas
with
moderate
to
high
nutsedge
pressure,
considered
to
be
approximately
58%
of
the
current
eggplant
production
area
(
Culpepper,
2004).
Lack
of
an
effective,
registered
herbicide
impairs
adoption
in
crops
such
as
pepper
(
Banks,
2002),
and
probably
other
high
value
vegetable
crops
for
the
fresh
market
(
Monks,
Southeast
Peppers
Consortium,
CUE
03­
0041).

Nematode
pests,
such
as
the
root
knot
nematode
species
of
Meloidogyne,
were
third
to
nutsedge
in
terms
of
priority
of
pest
management
strategies
in
Georgia
eggplant
production.
Pre­
plant
control
of
nematodes
is
critical
since
nematode
root
feeding
and
damage
may
predispose
plant
tissues
to
invasion
by
fungal
pathogens,
potentially
leading
to
wilt,
loss
of
plant
vigor,
and
significant
yield
losses.
Fumigant
alternatives
such
as
metam­
sodium
have
proven
inconsistent
(
Noling,
2003;
FFVA,
2002).

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Phytophthora
spp.,
Pythium
spp.
and
Sclerotium
rolfsii)
may
be
curtailed
if
weather
conditions
are
detrimental
for
disease
development.
These
pathogens
are
endemic
in
many
vegetable
production
areas
in
Georgia.
Fungicides
such
as
chlorothalonil,
and
azoxystrobilurin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck,
2003)

The
use
of
products
containing
1,3­
D
and
metam
sodium
in
the
fall
is
impractical
because
of
the
long
waiting
periods
for
planting
following
application
under
plastic
mulch.
For
1,3­
D
there
is
a
28
day
waiting
period;
for
metam
sodium,
there
is
a
21­
day
waiting
period.
Such
delays
would
cost
growers
at
least
half
of
the
harvest
season,
thereby
missing
the
higher
market
windows.
Thus,
since
the
fall
crop
is
dependent
upon
timely
planting,
the
required
waiting
period
would
cost
growers
at
least
half
of
the
harvest
season,
thereby
missing
the
higher
market
windows
(
Kelley,
2003).
Page
32
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
TARGET
PESTS
(
WEEDS,
PLANTPARASITIC
NEMATODES)
AND
PATHOGENS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Michigan
Crown
and
root
rots
caused
by
Soilborne
Fungus
­
Phytophthora
capsici.

Wilts
caused
by
Soil­
borne
Fungi
­
Verticillium
spp.
Methyl
bromide
alone
allows
growers
to
fumigate
and
plant
early
in
order
to
capture
the
key
market
window
(
July
­
September)
and
have
their
product
available
for
premium
prices,
as
well
as
ensuring
demand
for
their
crop
during
the
entire
growing
season,
especially
during
the
mid
and
late
season.
The
fumigation
and
planting
schedule
allow
growers
to
maintain
market
diversity,
as
well.

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)
Vegetable
crop
for
the
fresh
market
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
­­
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Rotation
sequence
commonly
followed
by
a
pepper
or
cucurbit
crop
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam,
clayish
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
every
2
years
OTHER
RELEVANT
FACTORS:
Michigan's
diversified
vegetable
crop
production
is
designed
to
meet
key
late
spring
and
summer
market
demands
in
Midwestern
states.
Page
33
MICHIGAN
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
FOR
EGGPLANTS
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
"
PLANT
HARDINESS
ZONE"
(
e.
g.
temperate,
tropical)
Generally
characterized
as
5b
according
to
the
USDA
Hardiness
Zone
Map,
with
annual
minimum
temperature
ranges
(
average)
as
 
23.4
to
 
26.1
°
C
(­
15
to
 
10
°
F).
Example
cities:
Columbia,
Missouri
and
Mansfield,
Pennsylvania.

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

­

PLANTING
SCHEDULE

­

KEY
HARVEST
(
MARKET)
WINDOW


Shaded
areas
represent
typical
duration
of
activity;

=
typical
initiation
of
activity,

=
typical
termination
of
activity
MICHIGAN
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Michigan
experiences
heavy
rainfall
events
across
the
entire
state
at
any
given
moment
of
the
growing
season.
Heavy
rain
events
(
over
25
mm)
can
trigger
rapid
root
and
crown
rot
development,
and
promote
dissemination
of
Phytophthora
capsici
via
irrigation
sources.
Generally,
there
is
no
difference
in
the
amount
of
infection
depending
on
soil
type
or
production
area.
The
pathogen
is
widespread
and
indigenous
on
almost
all
soil
types
in
Michigan
(
Cortwright,
2003;
Gevens
and
Hausbeck,
2003).

All
fumigation
practices
need
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
(
July­
September).

Significant
rainfall
events
(>
25.4
mm)
or
cold
soil
temperatures
(<
4.4
°
C)
could
delay
fumigation
and
planting.

Lighter
soil
types
may
make
drip
application
difficult
(
Cortwright,
2003).

MICHIGAN
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
Michigan's
use
of
methyl
bromide
for
vegetable
production
has
declined
steadily
since
the
mid­
1990s,
when
growers
switched
to
different
application
methods
(
i.
e.
from
Flat
Fumigation
to
tarped
beds)
and
formulations,
from
98:
2
to
67:
33
(
methyl
bromide:
chloropicrin).
Since
1997,
all
methyl
bromide
is
applied
to
tarped
beds,
with
100%
of
low
density
polyethylene
sheeting
and
95%
of
the
area
was
treated
Page
34
with
the
67:
33
formulation.
Since
2000,
about
5%
of
the
area
used
the
50:
50
methyl
bromide:
chloropicrin
formulation.
Growers
are
using
anti­
drip
valves
to
eliminate
loss
of
MB
at
the
end
of
rows
when
the
machinery
is
removed
from
the
ground.

Please
see
Table
12.1
for
further
information.

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)
22
24
25
29
33
34
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
2,625
2,870
2,937
3,500
3,905
4,057
FORMULATIONS
OF
METHYL
BROMIDE
(
e.
g.
methyl
bromide
98:
2;
methyl
bromide/
Chloropicrin
70:
30)
67:
33
67:
33
67:
33
67:
33
or
50:
50
67:
33
or
50:
50
67:
33
or
50:
50
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
180
180
180
180
180
180
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
17.9
17.9
17.9
17.9
17.9
17.9
APPLICATION
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
120
120
120
120
or
90
120
or
90
120
or
90
ACTUAL
DOSAGE
RATE
FOR
THE
ACTIVE
INGREDIENT
(
g/
m2)*
12
12
12
12
or
9
12
or
9
12
or
9
APPLICATION
RATE
OF
STRIP/
BED,
G
MB/
M
2
32.2
32.2
32.2
32.2
or
27.0
32.2
or
27.0
32.2
or
27.0
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
35
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
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
Dichloropropene
(
1,3­
D)
Not
effective
against
soil­
borne
fungi.
Several
bacteria
genera
appear
to
be
capable
of
degrading
1,3­
D
(
Duncan
and
Yates,
2003).
There
is
a
Federal
label
restriction
of
a
30.4
m
buffer
zone
between
treated
fields
and
inhabited
structures.
28­
day
waiting
period
for
planting
may
be
disruptive
to
timely
eggplant
production
and
marketing.
No
Chloropicrin
Does
not
distribute
evenly
throughout
the
soil
profile
when
used
by
itself,
resulting
in
poor
efficacy.
Does
not
control
Phytophthora
capsici
when
used
at
maximum
label
rates.
(
California
Pepper
Commission,
CUE
02­
0017;
CUE03­
0017)
No
Metam
Sodium
Poor
fumigant
with
erratic
results
and
inconsistent
distribution
in
soil
profiles;
does
not
control
Phytophthora
capsici
nor
Verticillium
spp.
(
California
Pepper
Commission,
CUE
02­
0017;
CUE03­
0017).
Repeated
applications
of
MITC
(
the
breakdown
product
of
metam
sodium)
are
known
to
enhance
its
biodegradation
as
a
result
of
adapted
microorganisms
(
Duncan
and
Yates,
2003).
Phytotoxicity
has
been
reported
with
this
fumigant.
21­
day
day
waiting
period
for
planting
may
be
disruptive
to
timely
eggplant
production
and
marketing.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
(
Telone
C­
35)
The
28­
day
waiting
period
for
planting
could
disrupt
the
eggplant
production
and
marketing
timing.
Regulatory
restrictions
due
to
concerns
over
human
exposure
and
ground
water
contamination,
along
with
technical
limitations,
result
in
potential
economic
infeasibility
of
this
formulation
as
a
practical
MB
alternative.
No
Metam
Sodium/
Crop
Rotation
Metam
sodium
is
a
poor
fumigant
that
provides
erratic
control.
Repeated
applications
of
MITC
(
the
breakdown
product
of
metam
sodium)
are
known
to
enhance
its
biodegradation
as
a
result
of
adapted
microorganisms
(
Duncan
and
Yates,
2003).
Because
of
high
land
costs,
very
few
crops
are
of
high
enough
economic
value
to
be
rotated
with
eggplants.
A
4­
5
year
rotation
is
necessary
to
reduce
inoculum
levels.
The
economic
threshold
of
Phytophthora
capsici
is
presumed
to
be
1
oospore/
ft2
(
Michigan
CUE
03­
0061).
21­
day
day
waiting
period
for
planting
may
be
disruptive
to
timely
eggplant
production
and
marketing.
No
Page
36
Metam
Sodium/
Furfural
(
Multigard

)
Results
of
a
2003
small
plot
field
study
demonstrated
practically
equivalent
soil
pest
control
of
targeted
pests
(
plot
vigor)
and
slightly
lesser
yields
than
methyl
bromide.
(
Cortwright
and
Hausbeck,
2003).
Please
refer
to
Table
16.2
(??).
Although
furfural
is
not
yet
registered
by
the
U.
S.
EPA,
it
is
under
consideration
by
federal
authorities.
Insufficient
data
and
trials
to
estimate
cost­
effectiveness
at
this
time.

*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

Potential
yield
losses
to
Phytophthora
capsici
could
be
up
to
10%
of
the
production
area,
especially
if
the
plants
are
affected
early
in
the
growing
season.
This
is
explained
by
the
widespread
occurrence
of
indigenous
populations
of
P.
capsici,
(
Michigan
CUE
#
03­
0061;
Gevens
and
Hausbeck.,
2003),
significant
rainfall
events
(
greater
than
254
mm)
which
trigger
rapid
disease
development
(
Cortwright,
2003),
metalaxyl
and
mefanoxem­
insensitivity
reported
among
Phytophthora
spp.
populations
in
several
vegetable
production
areas
(
Lamour
and
Hausebeck,
2003;
Parra
and
Ristaino,
1998),
and
planting
restrictions
of
registered
alternative
fumigants
(
e.
g.
1,3­
D
+
chloropicrin
and
metam­
sodium).

Wilts
caused
by
species
of
soil­
borne
fungi
such
as
Verticillium
are
endemic
to
many
vegetable­
producing
areas
of
Michigan.
These
fungi
have
an
extensive
plant
host
range,
typically
forming
survival
structures
(
microsclerotia)
which
are
resistant
to
fungicides
and
periods
of
drought,
overwintering
in
colonized
plant
tissue.

Planting
restrictions
on
1,3­
D
and
metam­
sodium
labels,
rather
than
lack
of
effectiveness,
curtail
Michigan
grower
use
of
these
fumigants.
Potential
yield
losses
associated
with
regulatory
restrictions
could
be
higher
because
fumigation
needs
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
(
July
­
September)
and
have
their
product
available
for
premium
prices,
as
well
as
ensuring
demand
for
their
crop
during
the
entire
growing
season
(
especially
during
the
mid
and
late
season).
According
to
the
applicant,
Michigan's
diversified
vegetable
crop
industry,
designed
to
meet
market
demands
in
the
late
spring
and
through
the
summer
for
Midwestern
markets,
require
carefully­
timed
planting
and
harvesting
schedules.
The
fumigation
with
methyl
bromide
and
planting
schedule
allow
growers
to
maintain
market
diversity,
as
well.
Fumigation
with
1,3­
D
+
chloropicrin
might
be
an
effective
alternative,
except
in
certain
years
when
climatic
conditions
(
e.
g.,
wet
soils)
may
delay
planting
schedules.
Page
37
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:

Iodomethane
Not
registered.
Yes
unknown
Fosthiazate
OP
nematicide.
Under
review.
Yes
Unknown
Furfural
(
Multigard

)
Not
registered.
Yes
Unknown
Sodium
azide
Not
registered.
Yes
Unknown
Diallyl
sulfide
Registered
to
control
Sclerotinia
spp.
(
plant­
pathogenic
fungi).
Very
limited
and
narrow
spectrum
of
uses.
Uses
may
be
expanded
Unknown
Metam
sodium
Registered
Yes
Reregistration
scheduled
for
2005­
06
Propargyl
bromide
Not
registered.
Yes
Unknown
Paecilomyces
lilacinus
Not
registered.
Registration
pending.
Yes
Unknown
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:

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
5­
95
%
PLUS
loss
of
revenue
due
to
planting
delays
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)
Page
38
Small
plot
field
trial
conducted
in
summer,
2003:
Evaluation
of
fumigants
for
managing
Phytophthora
crown
and
fruit
rot
of
solanaceous
and
cucurbit
crops.
The
following
are
the
results
of
the
eggplant
trials
(
Cortrwright
and
Hausbeck,
2003).

In
a
randomized
complete
block
design
with
4
replicates
per
treatment,
no
significant
differences
were
noted
for
eggplant
yields
for
plots
treated
with
metam
sodium
(
Vapam),
methyl
bromide
+
chloropicrin,
1,3­
D
+
chloropicrin
or
Iodomethane
(
Midas
 
)
+
chloropicrin.
Eggplant
yields
obtained
from
plots
treated
with
the
50%
formulation
of
iodomethane
+
chloropicrin
were
practically
equivalent,
whereas
eggplant
yields
from
plots
treated
with
the
33%
formulation
of
iodomethane
+
pic
were
appreciably
higher
than
yields
from
plots
treated
with
MB.
The
vegetable
plots
(
portion
of
relevant
results
in
Table
16.2)
were
constructed
on
a
sandy
loam
soil
(
72.4%
sand,
14.2%
silt,
13.4%
clay)
with
a
known
history
of
Phytophthora,
and
pumpkin
planting
in
2002,
followed
by
a
rye
cover
crop.
Fumigant
treatments
were
injected
at
80
psi;
all
treatment
beds
were
covered
with
1.25­
mil
black­
plastic
embossed
mulch.
Beds
were
6
in.
high
and
spaced
5
ft
apart.
Two
drip
tubes
were
installed
just
under
the
plastic
during
bed
formation
and
mulch
laying,
dividing
the
bed
into
thirds.
During
the
first
week
of
August,
2003,
several
heavy
rain
events
saturated
the
soil
(
101­
262
mm
during
a
span
of
3
days,
Oceana,
MI).
There
was
a
quick
disease
epidemic
which
spread
rapidly
and
uniformly
across
the
replicates
with
significant
differences
in
plant
death
noted
for
the
tested
Curcurbitacae.
There
was
no
plant
death,
and
no
difference
in
plant
vigor
for
the
eggplant
plots.
There
were
no
significant
weed
rating
differences
for
the
tested
treatments.

Table
16.2
Summary
of
field
trials
conducted
by
Cortrwright
and
Hausbeck
(
2003)

ALTERNATIVE
APPLICATION
RATE,
METHOD
TARGET
PEST(
S)
A
YIELDS
OF
EGGPLANTS
(
numbers
of
fruit)

Untreated
14.3
Multigard
 
Protect
+
metam­
sodium
HL
Multigard
 
37
gal
+
20
gal
Preplant
Drip
5.8
gal
Postplant
Drip
14.4
Multigard
 
Protect
+
metam
sodium
HL
Multigard
 
56
gal
+
30
gal
Preplant
Drip
5.8
gal
Postplant
Drip
13.1
Metam­
sodium
HL
75
gal;
Preplant
Drip
10.5
MB
+
chloropicrin
(
67:
33)
350
lb;
Preplant
Shank
16.2
1,3­
D
+
chloropicrin
C35
35
gal;
Preplant
Shank
17.0
Iodomethane/
chloropicrin
(
50:
50)
250
lb;
Preplant
Shank
13.3
Iodomethane/
chloropicrin
(
33/
67)
200
lb;
Preplant
Shank
Phytophthora
capsici
Verticillium
spp.

23.9
AOther
pests
(
e.
g.,
weeds
and
nematodes)
were
most
likely
present;
however
population
densities
were
not
determined
in
this
study.
Ratings
of
plant
health
and
severe
disease
pressure
were
based
on
typical
symptoms
of
Phytopthora
crown
and
fruit
rots
on
peppers
From
these
small
plot
studies,
the
yield
results
indicate
that
1,3­
D
+
chloropicrin
(
65:
35
formulation)
and
methyl
bromide
(
67:
33)
were
very
effective
in
managing
pest
populations
for
eggplants.
Yields
of
eggplants
were
appreciably
higher
in
the
plots
treated
with
the
33/
67
iodomethane/
chloropicrin
(~
66
lbs
iodomethane
formulation,
however
eggplant
yields
were
practically
equivalent
in
the
higher
rate
of
iodomethane
(
50:
50
formulation;
125
lbs
iodomethane).
However,
yields
of
eggplants
from
the
metam­
sodium­
treated
plots
were
somewhat
lower
than
for
the
plots
treated
with
Page
39
methyl­
bromide,
demonstrating
the
inconsistency
of
metam­
sodium
in
pesticidal
efficacy.
Multigard
 
(
furfural)
applied
post­
plant
seemed
to
slightly
improve
eggplant
yield
compared
to
metam­
sodium
alone.
Yields
were
lower
than
those
obtained
with
methyl
bromide,
however.
Soils
treated
with
repeated
applications
of
metam­
sodium
(
or
metam­
potassium)
are
known
to
enhance
its
biodegradation
through
adapted
microorganisms.
Preliminary
evidence
suggests
that
the
microorganisms
responsible
for
enhanced
degradation
of
MITC
specifically
target
the
isothiocyanate
functional
group
(
Duncan
and
Yates,
2003).
Other
field
researchers
have
alluded
to
metam­
sodium's
limited
niche
as
a
complementary
treatment
with
other
fumigants
and
herbicides,
indicating
that
this
chemical
should
not
be
used
as
a
standalone
treatment
(
Noling,
2003).

At
present,
no
data
directly
attribute
yield
losses
to
alternative
management
of
pest
pressures.
Results
of
the
above
small
study
also
suggest
that
yield
losses
can
be
mitigated
if
careful
attention
is
given
to
preplant
fumigation
methods
and
bed
preparation.
Efficacy
depends
on
proper
application
and
can
vary
from
site
to
site.
In
a
similar
trial,
conducted
in
another
Michigan
location,
with
a
lighter
soil
type,
lower
disease
pressure
was
reported.
However
the
lighter
soil
type
reportedly
made
drip
application
difficult.
(
Cortwright,
2003).

Expert
opinion
in
the
production
area,
U.
S.
EPA
analyses
(
August,
2003),
and
nomination
packages
(
CUE#
s
02­
0017­
California
&
03­
0017­
Florida)
provide
a
yield
loss
range
of
8
to
15%,
depending
on
the
extent
of
pathogen
infestation,
location
of
the
fields
and
weather
or
climatic
conditions
that
favor
disease
development.
In
some
years,
yield
losses
can
be
much
greater.

An
upper
bound
of
6%
yield
loss
(
for
high
pest
pressures
only)
is
estimated
because
of
100%
field
infestation
with
the
soil­
borne
fungus,
Phytophthora
capsici.
Chloropicrin
does
not
provide
control
of
Phytophthora
capsici
or
other
soil
pathogens,
such
as
Verticillium
spp.
Since
metalaxyl­
resistant
strains
of
Phytophthora
capsici
have
been
documented
on
solanaceous
crops
(
Lamour
and
Hausbeck,
2003;
Parra
and
Ristaino,
1998),
growers
do
not
rely
on
Ridomil
 
,
Ridomil
Gold
 
,
or
Quadric
 
.

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

The
Agency
is
presently
unaware
of
large
scale,
commercial
greenhouse
operations
for
eggplants.
It
might
be
expected,
however
that
there
are
local
(
or
small
community)
operations
of
both
organic
and
hothouse
eggplant
production
that
target
fresh
market,
and/
or
temporal
(
seasonal)
sectors,
e.
g.,
farmers'
markets.
Large
scale
production
is
probably
not
cost­
effective,
because
of
the
intensive
management
of
pests
and
the
long
growing
season
for
eggplants.

MICHIGAN
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
MICHIGAN
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:

Iodomethane
is
under
consideration
for
potential
methyl
bromide
replacement.
Date
of
registration
is
not
known.

Please
refer
to
Table
15.1
for
a
listing
of
other
alternatives,
currently
under
consideration
and/
or
registration
status,
as
of
December,
2003.
Page
40
Results
depicted
in
Table
16.1
suggest
practically
equivalent
pest
management
at
the
pre­
plant
stage
(
plant
vigor
ratings)
and
harvestable
eggplant
yields
from
plots
treated
with
1,3­
D
+
chloropicrin.
However,
yields
of
eggplants
from
the
metam­
sodium­
treated
plots
were
somewhat
lower
than
for
the
plots
treated
with
methyl­
bromide,
demonstrating
the
inconsistency
of
metam­
sodium
in
pesticidal
efficacy.
Multigard
 
(
furfural)
applied
post­
plant
seemed
to
slightly
improve
eggplant
yield,
than
with
metam­
sodium
alone.
Yields
were
lower
than
those
obtained
with
methyl
bromide,
however.
Soils
treated
with
repeated
applications
of
metam­
sodium
(
or
metam­
potassium)
are
known
to
enhance
their
biodegradation
as
a
result
of
adapted
microorganisms.
Preliminary
evidence
suggests
that
the
microorganisms
responsible
for
enhanced
degradation
of
MITC
specifically
target
the
isothiocyanate
functional
group
(
Duncan
and
Yates,
2003).
Other
field
researchers
have
alluded
to
metam­
sodium's
limited
niche
as
a
complementary
treatment
with
other
fumigants
and
herbicides,
and
this
chemical
should
never
be
used
as
a
stand­
alone
treatment
(
Noling,
2003).

It
should
be
noted
that,
these
plots
were
carefully
monitored
and
managed;
post­
plant
prophylactic
foliar
fungicide
(
chlorothalonil,
myclobutanil,
Cabrio
 
)
and
herbicide
treatments
were
necessary
to
manage
and
prevent
seasonal
fluctuations
of
pest
pressures.

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Phytophthora
spp.,
Verticillium
spp.,
Pythium
spp.
and
Rhizoctonia
solani
)
may
be
curtailed
if
weather
conditions
are
detrimental
for
disease
development.
These
pathogens
are
indigenous
in
many
vegetable
production
areas
in
Michigan.
Fungicides
such
as
chlorothalonil,
and
azoxystrobilurin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck,
2003).

Rather
than
lack
of
effective
alternative
fumigants,
planting
restrictions
on
the
labels
of
1,3­
D
and
metamsodium
prevent
their
adoption
by
Michigan
growers.
Michigan's
diversified
vegetable
crop
production
practices
are
designed
to
meet
key
late
spring
and
summer
market
demands
in
Midwestern
states
in
a
timely
fashion.
Fumigation
practices
need
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
(
July
­
September)
and
have
their
product
available
for
premium
prices,
as
well
as
ensuring
demand
for
their
crop
during
the
entire
growing
season
(
especially
during
the
mid
and
late
season).
The
fumigation
with
methyl
bromide
and
planting
schedule
allow
growers
to
maintain
market
diversity,
as
well.
Fumigation
with
1,3­
D
+
chloropicrin
might
be
an
effective
alternative,
except
in
certain
years
or
climatic
conditions
(
e.
g.,
wet
soils)
which
may
delay
planting
schedules.
Page
41
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
US
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
US
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
non­
chemical
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
42
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.
In
addition,
cultural
practices
are
utilized
by
cucurbit
growers.

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
43
PART
E:
ECONOMIC
ASSESSMENT
The
economic
assessment
is
organized
by
MB
critical
use
application.
Cost
of
MB
and
alternatives
are
given
first
in
table
21.1.
This
is
followed
in
table
22.1
by
a
listing
of
net
and
gross
revenues
by
applicant.
Expected
losses
when
using
MB
alternatives
are
then
further
decomposed
in
tables
E1
through
E3.

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:
EGGPLANTS
­
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
U.
S.$/
ha)
COST
IN
YEAR
2
(
U.
S.$/
ha)
COST
IN
YEAR
3
(
U.
S.$/
ha)
Florida
Methyl
Bromide
100%
$
3,010
$
3,010
$
3,010
1,3­
D
+
Chloropicrin
71%
$
3,719
$
3,719
$
3,719
Metam­
Sodium
56%
$
3,519
$
3,519
$
3,519
Georgia
Methyl
Bromide
100%
$
3,642
$
3,642
$
3,642
1,3­
D
+
Chloropicrin
71%
$
3,242
$
3,242
$
3,242
Metam­
Sodium
56%
$
3,027
$
3,027
$
3,027
Michigan
Methyl
Bromide
100%
$
1,475
$
1,475
$
1,475
1,3­
D
+
Chloropicrin
94%
$
1,772
$
1,772
$
1,772
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
e.
g.
10%
more
yield,
write
110.
Page
44
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
EGGPLANT
 
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
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Florida
Methyl
Bromide
$
21,730
$
6,408
1,3­
D
+
Chloropicrin
$
15,428
$
1,156
Metam­
Sodium
$
12,169
­
$
1,388
Georgia
Methyl
Bromide
$
42,857
$
10,491
1,3­
D
+
Chloropicrin
$
30,428
$
2,899
Metam­
Sodium
$
24,000
­
$
493
Michigan
Methyl
Bromide
$
34,074
$
9,344
1,3­
D
+
Chloropicrin
$
29,627
$
5,268
NOTE:
Year
1
equals
year
2
and
3.

MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
EGGPLANT
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
EGGPLANT
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
1,893
1,344
1,060
*
PRICE
PER
UNIT
(
US$)
$
11
$
11
$
11
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
21,730
$
15,428
$
12,169
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
15,322
$
14,272
$
13,557
=
NET
REVENUE
PER
HECTARE
(
US$)
$
6,408
$
1,156
­
$
1,388
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
5,252
$
7,796
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
35
$
52
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
24%
36%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
82%
122%
Page
45
GEORGIA
EGGPLANT
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
EGGPLANT
METHYL
BROMIDE
1,3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
6,326
4,491
3,542
*
PRICE
PER
UNIT
(
US$)
$
7
$
7
$
7
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
42,857
$
30,428
$
24,000
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
32,365
$
27,530
$
24,493
=
NET
REVENUE
PER
HECTARE
(
US$)
$
10,491
$
2,899
­
$
493
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
7,593
$
10,985
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
51
$
73
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
18%
26%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
72%
105%

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

YIELD
PER
HECTARE
3,665
3,445
*
PRICE
PER
UNIT
(
US$)
$
9.30
$
8.60
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
34,074
$
29,627
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
24,730
$
24,359
=
NET
REVENUE
PER
HECTARE
(
US$)
$
9,344
$
5,268
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
4,076
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
84
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
12%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
44%
Page
46
SUMMARY
OF
ECONOMIC
FEASIBILITY
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
eggplant.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
As
described
above,
the
two
most
promising
alternatives
to
methyl
bromide
in
Florida
and
Georgia
for
control
of
nutsedge
in
eggplant
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
expected
yield
losses
when
they
are
used.
Economic
data
representing
the
Florida
and
Georgia
eggplant
growing
conditions
are
thus
included
in
this
section
as
a
supplement
to
the
biological
review
to
illustrate
the
impacts
of
using
MB
alternatives,
not
to
gauge
them
with
respect
to
economic
feasibility.
However,
in
Michigan
1,3­
D
+
chloropicrin
is
considered
technically
feasible.

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

Analytical
Notes
Florida's
application
for
MB
critical
use
indicated
that
more
than
one
crop
is
typically
grown
per
growing
season
but
did
not
provide
specific
production
and
sales
data
for
this
crop.
As
and
result
of
this
gap
in
data,
economic
assessment
of
Florida
eggplant
production
was
based
on
a
single
crop
production
system.
This
characterization
of
growing
conditions
could
result
in
the
critical
need
for
MB
appearing
smaller
than
it
actually
is,
because
the
value
the
second
crop
derives
from
methyl
bromide
is
not
included
in
the
analysis.

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
eggplant
growers.
As
such,
the
U.
S.
concludes
that
use
of
MB
is
critical
in
Georgia
eggplant
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.

Michigan
The
U.
S.
concludes
that,
at
present,
no
economically
feasible
alternatives
to
MB
exist
for
use
in
Michigan
eggplant
production.
Two
factors
have
proven
most
important
in
this
conclusion.
These
are
yield
loss
and
missed
market
windows,
which
are
discussed
individually
below.
Page
47
1.
Yield
Loss
The
U.
S.
anticipates
yield
losses
of
6%
throughout
Michigan
eggplant
production.

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
eggplants
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
eggplants
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
eggplant
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
eggplants
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
eggplant
operations.

Specific
data
representing
these
market
fluctuations
are
not
available
for
Michigan
eggplant.
However,
because
of
the
similar
production
system
and
growing
conditions,
Michigan
pepper
price
data
were
used
to
represent
price
fluctuations
in
Michigan
eggplant
and
their
impact
on
growers'
gross
revenues.
Though
data
availability
is
limiting,
it
was
assumed
that
if
eggplant
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
chloropicrin,
they
will,
over
the
course
of
the
growing
season,
receive
gross
revenues
reduced
by
approximately
7.5%.
The
season
average
price
was
reduced
by
7.5%
in
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
the
U.
S.
believes
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MB
alternatives
are
used
in
Michigan
eggplant
production.
Page
48
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Since
1997,
the
United
States
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
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
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
U.
S.
DA/
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
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.

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
eggplant
research
will
require
433
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
root­
knot
nematodes.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
D
combined
with
biologically
based
materials
including
transplant
treatments
for
control
of
weeds,
root­
knot
nematodes
and
soil
borne
fungal
pathogens.
Page
49
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?

Aerts,
M.
2003.
Asst.
Director,
Environmental
and
Pest
Management
Division,
Florida
Fruit
and
Vegetable
Association.
Personal
Communication
with
G.
Tomimatsu,
December
2,
2003.

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

Chellemi,
D.
O.,
R.
C.
Hochmuth,
T.
Winsberg,
W.
Guetler,
K.
D.
Shuler,
L.
E.
Datnoff,
D.
T.

Kaplan,
R.
McSorley,
R.
A.
Dunn,
and
S.
M.
Olson.
1997.
Application
of
soil
26.
CITATIONS
Page
50
solarization
to
fall
production
of
cucurbits
and
pepper.
Proc.
Fla.
State
Hort.
Soc.
10:
333­
336.

Cortwright,
B.
2003.
Field
Research
Associate
University
of
Michigan.
Personal
Communication
with
G.
Tomimatsu,
November
24,
2003.

Cortwright,
B.
D.
and
M.
K.
Hausbeck.
2003.
Evaluation
of
fumigants
for
managing
Phytophthora
crown
and
fruit
rot
of
solanaceous
and
cucurbit
crops,
plot
two,
2003.
Unpublished
study
(
MI
CUE
#
03­
0061).

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
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Proc.
Georgia
Veg.
Conf.
Available
on
the
Web
at
http://
www.
tifton.
uga.
edu/
veg/
Publications/
Gfvga99.
pdf
Duncan,
R.
S.
and
S.
R.
Yates.
2003.
Degradation
of
fumigant
pesticides:
1,3­
Dichloropropene,
Methyl
isothiocyanate,
chloropicrin,
and
methyl
bromide.
Vadose
Zone
Journal
2:
279­
286.

Florida
Fruit
and
Vegetable
Association
(
FFVA).
2002.
Application
for
the
Methyl
Bromide
Critical
Use
Exemption
on
Solanaceous
Crops
(
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than
tomato).
September
9,
2002.

Frank,
J.
R.,
P.
H.
Schwartz
and
W.
E.
Potts.
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Modeling
the
effects
of
weed
interference
periods
and
insects
on
bell
peppers
(
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308­
312.

Gevens,
A.
J.
and
M.
K.
Hausbeck.
2003.
A
first
report
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Phytophthora
capsici
in
irrigating
water
near
cucurbit
fields
in
Michigan
(
Abstr).

Kelley,
W.
T.
2003,
Professor,
University
of
Georgia.
Personal
communication
with
G.
Tomimatsu,
November
24,
2003.

Lamour,
K.
H.
and
M.
Hausbeck.
2003.
Effect
of
Crop
Rotation
on
the
survival
of
Phytophthora
capsici
in
Michigan.
Plant
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87:
841­
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Lewis,
C.
2003
(
President,
Hy­
Yield
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communication
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Toth
(
steve_
toth@
ncsu.
edu)
,
Extension
Entomologist
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North
Carolina
State
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message
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electronically
to
G.
Tomimatsu,
December
29,
2003.

Melban,
K.
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Noling,
J.
W.
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Noling,
J.
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L.
Chellemi.
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on
soil
pest
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Emissions
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Available
on
the
web
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Stall,
W.
M.
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Morales­
Payan.
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weed_
con/
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htm
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edu/
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EPA.
2002.
Peppers­
Field.
Peppers
Grown
Outdoors
on
Plastic
Mulch.
CUN2003/
058
Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
R.
L.
Fery.
2001.
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Protection
20:
605­
614.

CITATIONS
REVIEWED
BUT
NOT
APPLICABLE
Jones,
J.
2003.
Regulatory
Status
of
Soil
Fumigants.
Plenary
Session
1.
Presentation
at
the
2003
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions,
San
Diego,
CA.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
R.
L.
Fery.
2001.
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Protection
20:
605­
14.
Page
52
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2,197
48%

2001
&
2002
Average
%
of
2001
&

2002
Average
497
64%

not
available
not
available
647
113%

1,145
99%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
27,769
185
150
43%

3,951
82
48
0%

73,716
491
150
24%

106,193
758
116
29%

29%
28%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
150
150
8
8
0
0
58
39
0
0
0
0
0
0
62%
43%

48
48
0
0
0
0
75
75
0
0
0
0
100
100
100%
100%

150
150
40
40
1
1
58
39
0
0
0
0
0
0
80%
59%

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
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
Tarp
No
0
Yes
1/
year
7,593
$
51
$
18%
72%

Yes
Yes
Yes
Tarp
No
0
Yes
1/
year
1,674
$
35
$
5%
18%

Yes
Yes
Yes
Tarp
No
­
Yes
1/
year
5,252
$
35
$
24%
82%

Conversion
Units:
1
Pound
=
Kilograms
Hectare
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Sector:
EGGPLANT
%
of
Average
Hectares
Requested:

Methyl
Bromide
Critical
Use
Exemption
Process
Date:
2/
26/
04
Average
Hectares
in
the
US:

2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

2006
Amount
of
Request
REGION
48,868
325
150
47,713
318
150
0%

3,951
82
48
3,981
83
48
0%

97,250
647
150
114,623
728
157
0%

TOTAL
OR
AVERAGE
150,069
1,055
116
166,317
1,129
119
0%

Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
HIGH
LOW
48,868
­
1,155
­
­
29,582
20,517
3,951
­
­
­
­
3,951
3,951
97,250
­
­
­

148,914
­
77,800
57,378
148,914
111,333
81,845
1%
26%
45%

%
Reduction
from
Initial
Request
0%
0%
1%
1%
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)

Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
MICHIGAN
FLORIDA
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Combined
Impacts
(%)

Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
Quality/
Time/
Market
Window/
Yield
Loss
(%)

29%
yield
loss
+
planting
delay
44%
yield
loss
+
planting
delay
Marginal
Strategy
1,3­
D
+
Pic
Metam­
Sodium
+
Pic
29%
yield
loss
+
planting
delay
44%
yield
loss
+
planting
delay
6%
Yield
Loss
1,3­
D+
Pic
0.404686
1,3­
D
+
Pic
Metam­
Sodium
+
Pic
REGION
REGION
REGION
GEORGIA
MICHIGAN
FLORIDA
GEORGIA
MICHIGAN
FLORIDA
2006
Nomination
Options
0.453592
1
Acre
=
148,914
GEORGIA
MICHIGAN
FLORIDA
GEORGIA
Nomination
Amount
150,069
150,069
MOST
LIKELY
IMPACT
VALUE
%
of
Requested
Hectares
Regional
Hectares**
65%

not
available
100%

92%
Page
53
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
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
Page
54
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.
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.
Page
55
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
56
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
Ozark
Country
Hams
240
Page
57
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
