METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
FOREST
SEEDLINGS
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
Forest
Seedlings
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
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
ii
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............................................................................................................................................
9
1.
Nominating
Party
_________________________________________________________
9
2.
Descriptive
Title
of
Nomination______________________________________________
9
3.
Crop
and
Summary
of
Crop
System___________________________________________
9
4.
Methyl
Bromide
Nominated
________________________________________________
10
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
__________________
10
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
12
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
13
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.
______________
13
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?_____________________________________________________________________
14
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
14
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
18
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
....................................................................................
20
Region
A.
Southern
Forest
Nursery
Management
Cooperative.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________
20
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
11.
(
i)
Characteristics
of
Cropping
System
and
Climate
________________________________________________
20
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
11.
(
ii)
Indicate
if
any
of
the
above
characteristics
in
11.
(
i)
prevent
the
uptake
of
any
relevant
alternatives?
__________
21
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________
22
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.....................................................................................................................................................................
23
Region
B.
International
Paper.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
23
Region
B.
International
Paper.
11.
Characteristics
of
Cropping
System
and
Climate
______
23
Region
B.
International
Paper.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
25
REGION
C.
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.................................................................................
25
Region
C.
Illinois
Department
of
Natural
Resources.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request__________________
25
Region
C.
Illinois
Department
of
Natural
Resources.
11.
Characteristics
of
Cropping
System
and
Climate_______________________________________________________________
26
Region
C.
Illinois
Department
of
Natural
Resources.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________________
27
iv
REGION
D.
WEYERHAEUSER­
SOUTH.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.................................................................................................................................................
28
Region
D.
Weyerhaeuser­
South.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
28
Region
D.
Weyerhaeuser­
South.
11.
Characteristics
of
Cropping
System
and
Climate
____
28
Region
D.
Weyerhaeuser­
South.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
30
REGION
E.
WEYERHAEUSER­
WEST.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
...............
30
Region
E.
Weyerhaeuser­
West.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
30
Region
E.
Weyerhaeuser­
West.
11.
Characteristics
of
Cropping
System
and
Climate
_____
31
Region
E.
Weyerhaeuser­
West.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
32
Region
F.
Weyerhaeuser­
South.
Part
B:
Crop
Characteristics
and
Methyl
Bromide
Use
...............................
32
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request____
32
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
11.
Characteristics
of
Cropping
System
and
Climate
________________________________________________
33
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____________________________________________________
34
REGION
G.
MICHIGAN
SEEDLING
ASSOCIATION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
...............................................................................................................................
34
Region
G.
Michigan
Seedling
Association.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
34
Region
G.
Michigan
Seedling
Association.
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
35
Region
G.
Michigan
Seedling
Association.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
36
REGION
G.
MICHIGAN
HERBACEOUS
PERENNIALS.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
...............................................................................................................................
37
Region
G.
Michigan
Herbaceous
Perennials.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
37
Region
G.
Michigan
Herbaceous
Perennials.
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
37
Region
G.
Michigan
Herbaceous
Perennials.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
39
REGIONS
A­
G.
FOREST
SEEDLINGS.
PART
C:
TECHNICAL
VALIDATION
.............................................................
40
Regions
A­
G.
Forest
Seedlings.
13.
Reason
for
Alternatives
Not
Being
Feasible_________
40
Regions
A­
G.
Forest
Seedlings.
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_________________________________________________________________
43
Regions
A­
G.
Forest
Seedlings.
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
43
Regions
A­
G.
Forest
Seedlings.
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________________________________________
44
v
Regions
A­
G.
Forest
Seedlings.
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
49
Regions
A­
G.
Forest
Seedlings.
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
50
Regions
A­
G.
Forest
Seedlings.
Summary
of
Technical
Feasibility
___________________
51
PART
D:
EMISSION
CONTROL.....................................................................................................................
53
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
53
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
54
PART
E:
ECONOMIC
ASSESSMENT.......................................................................................................................
55
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
55
22.
Gross
and
Net
Revenue___________________________________________________
56
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
57
Summary
of
Economic
Feasibility
_____________________________________________
60
PART
F.
FUTURE
PLANS.......................................................................................................................................
63
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
63
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
64
25.
Additional
Comments
on
the
Nomination
____________________________________
64
26.
Citations
______________________________________________________________
64
APPENDIX
A.
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1..........................................................................................................................
68
APPENDIX
C.
SUMMARY
OF
NEW
APPLICANTS
__________________________________
74
vi
LIST
OF
TABLES
PART
A:
SUMMARY___________________________________________________________
9
Table
4.1:
Methyl
Bromide
Nominated
___________________________________________
10
Table
A.
1:
Executive
Summary_________________________________________________
12
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
13
Table
8.1.
Region
A
­
Southern
Forest
Nursery
Management
Cooperative:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________
14
Table
8.2.
Region
B
­
International
Paper:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
15
Table
8.3.
Region
C
­
Illinois
Department
of
Natural
Resources:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
_________________________________________________
15
Table
8.4.
Region
D
­
Weyerhaeuser­
South:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
16
Table
8.5.
Region
E
­
Weyerhaeuser­
West:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
16
Table
8.6.
Region
F
­
Northeastern
Forest
and
Conservation
Nursery
Association:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________
17
Table
8.7.
Region
G
­
Michigan
Seedling
Association:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________________________
17
Table
8.8.
Region
H
­
Michigan
Herbaceous
Perennials:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________________________
18
Table
A.
2:
2005
Sector
Nomination
_____________________________________________
19
Table
A.
3:
2006
Sector
Nomination
_____________________________________________
19
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________________
20
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________
20
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________
20
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
________________________________________________
21
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________________
22
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_________________________________________________________
23
Region
B.
International
Paper.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
23
Region
B.
International
Paper.
Table
11.1:
Characteristics
of
Cropping
System
___________
23
Region
B.
International
Paper.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
____
23
Region
B.
International
Paper.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______
25
Region
C.
Illinois
Department
of
Natural
Resources.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_________________________________________
25
Region
C.
Illinois
Department
of
Natural
Resources.
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________________
26
vii
Region
C.
Illinois
Department
of
Natural
Resources.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule___________________________________________________________
26
Region
C.
Illinois
Department
of
Natural
Resources.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________________________________________
27
Region
D.
Weyerhaeuser­
South.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
28
Region
D.
Weyerhaeuser­
South.
Table
11.1:
Characteristics
of
Cropping
System__________
28
Region
D.
Weyerhaeuser­
South.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
__
29
Region
D.
Weyerhaeuser­
South.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide_____
30
Region
E.
Weyerhaeuser­
West.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
30
Region
E.
Weyerhaeuser­
West.
Table
11.1:
Characteristics
of
Cropping
System___________
31
Region
E.
Weyerhaeuser­
West.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___
31
Region
E.
Weyerhaeuser­
West.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____
32
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____________________________
32
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
11.1:
Characteristics
of
Cropping
System
__________________________________________
33
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
______________________________________________
33
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________
34
Region
G.
Michigan
Seedling
Association.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__________________________________________________
34
Region
G.
Michigan
Seedling
Association.
Table
11.1:
Characteristics
of
Cropping
System__
35
Region
G.
Michigan
Seedling
Association.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
35
Region
G.
Michigan
Seedling
Association.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
36
Region
G.
Michigan
Herbaceous
Perennials.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_______________________________________________
37
Region
G.
Michigan
Herbaceous
Perennials.
Table
11.1:
Characteristics
of
Cropping
System
37
Region
G.
Michigan
Herbaceous
Perennials.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
38
Region
G.
Michigan
Herbaceous
Perennials.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
39
Regions
A­
G.
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
__________________
40
Regions
A­
G.
Forest
Seedlings.
Table
14.1:
Technically
Infeasible
Alternatives
Discussion__
43
Regions
A­
G.
Forest
Seedlings.
Table
15.1:
Present
Registration
Status
of
Alternatives
_____
43
Regions
A­
G.
Forest
Seedlings.
Table
16.1.
A:
Effectiveness
of
Alternatives
 
Weeds
_______
44
Regions
A­
G.
Forest
Seedlings.
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________
49
PART
D:
EMISSION
CONTROL_______________________________________________
53
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
54
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
55
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
55
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
56
viii
Region
A
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
57
Region
B
­
International
Paper
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
57
Region
C
­
Illinois
Department
of
Natural
Resources
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________
58
Region
d
­
Weyerhaeuser
South
­
Table
E.
4:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
58
Region
E
­
Weyerhaeuser
West
­
Table
E.
5:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
59
Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
­
Table
E.
6:
Economic
Impacts
of
Methyl
Bromide
Alternatives
______________________________________
59
Region
G
­
Michigan
Seedling
Association
­
Table
E.
7:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
60
Region
H
­
Michigan
Herbaceous
Perennials
­
Table
E.
8:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
60
PART
F.
FUTURE
PLANS
________________________________________________________
63
APPENDIX
B.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
_________________
70
Page
9
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Forest
Seedlings
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
The
Forest
Seedling
sector
in
the
U.
S.
supplies
conifer
and
hardwood
seedlings
that
are
used
for
reforestation,
forest
establishment,
fiber
production,
and
wildlife
and
conservation
uses.
In
1998,
there
were
1.6
billion
forest
seedlings
produced
in
the
U.
S.;
the
southern
region
produced
80%
of
these
seedlings
(
Ken
McNabb,
Director,
Southern
Forest
Nursery
Management
Cooperative,
personal
communication).
Nurseries
in
the
U.
S.
are
located
in
eight
climate
zones
(
Zones
3
to
10)
mostly
with
light
or
medium
soils.
The
majority
of
seedlings
are
species
of
conifers,
especially
pine.
In
addition,
30­
40
species
of
hardwoods,
such
as
oaks,
hickory,
poplars,
and
ash,
are
produced.
Nurseries
produce
seedlings
adapted
to
their
respective
regional
conditions,
such
as
climate
and
soil
type.
Overall,
forest
seedling
nurseries
include
those
operated
by
private
forest
industry,
state
and
federal
governments,
and
non­
industry
private
concerns.

Nurseries
produce
conifer
seedlings
that
are
typically
grown
for
one
or
two
years
followed
by
one
or
two
years
fallow
or
cover
crops.
Therefore,
managers
typically
fumigate
a
particular
conifer
seedling
bed
with
MB
only
once
every
3­
4
years,
i.
e.,
only
1/
3­
1/
4
of
the
total
nursery
land
is
fumigated
each
year
to
produce
two
or
three
harvestable
forest
seedling
crops
per
single
bed
fumigation.
Effective
fumigants
such
as
MB
permit
less
frequent
bed
fumigation
per
harvestable
seedling
crop.
For
hardwood
seedlings,
fumigation
is
usually
provided
prior
to
each
seedling
crop,
as
hardwood
species
are
generally
more
prone
than
conifers
to
root
rots
and
damping­
off
diseases.

Upon
maturity,
forest
seedlings
are
harvested
in
the
nursery,
packaged,
and
transported
to
the
planting
site.
Seedlings
may
or
may
not
be
culled
or
sized
during
harvesting
process,
with
cull
trees
discarded
and
typically
recycled
into
nursery
soil.
Those
nurseries
that
grade
their
seedlings
into
number
1
and
number
2
grades
can
sell
them
at
a
price
differential.
The
impact
of
seedling
quality
on
the
success
of
the
plantation
establishment
process
cannot
be
overstated.
The
production
of
large
and
healthy
planting
stock
is
essential
to
the
economic
viability
of
a
reforestation
process
that
typically
includes
soil
preparation
at
the
planting
site,
transportation
to
the
planting
site,
planting,
and
weed
control
after
planting.
The
quality
of
seedlings
is
strongly
correlated
with
the
success
of
the
regeneration
process
and
corresponding
long­
term
economic
and
use
benefits
where
a
higher
quality
seedling
implies
better
survival
and
faster
growth.
Nursery
soil
fumigation
is
the
backbone
of
an
integrated
pest
management
approach
to
produce
healthy
seedlings
that
is
the
foundation
for
economically
viable
plantation
establishment
and
management.
Page
10
Ornamental
herbaceous
crops
require
MB
to
address
problems
primarily
with
nematode
and
weed
pests.
This
industry
(
Michigan
Field
Grown
Herbaceous
Perennial
Growers)
has
adopted
alternative
pest
management
strategies
for
part
of
the
646
ha
of
nursery
land,
and
is
conducting
trials
to
assess
the
efficacy
of
alternatives
for
certain
crops,
such
as
hosta,
delphinium,
and
phlox.
Results
of
these
ongoing
trials
are
to
be
available
around
2006.
In
the
meantime,
growers
from
this
consortium
have
a
critical
need
for
MB.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
139,882
415
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
forest
seedling
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
forest
seedling
production.
­
Geographic
distribution
of
key
target
pests:
the
U.
S.
is
only
nominating
a
CUE
for
forest
seedlings
where
the
key
pest
pressure
is
moderate
to
high.

At
least
for
the
coming
three
growing
seasons,
use
of
MB
is
critical
to
forest
seedling
nurseries
in
the
U.
S.
Although
alternative
treatments
can
be
foreseen
as
likely
long­
term
solutions,
timing
will
depend
on
the
development
of
application
technologies
to
better
deliver
these
alternatives
to
soils
containing
target
pests.
In
addition,
because
of
MB
efficacy,
in
many
nurseries,
up
to
three
seedling
crops
can
be
grown
with
each
MB
application
 
generally
applied
only
once
in
four
years.
Alternative
treatments
will
require
more
frequent
applications
and
increase
costs
and
environmental
pesticide
burden.
Finally,
there
have
been
significant
outgassing
incidents
that
resulted
in
destruction
of
millions
of
nursery
seedlings
(
International
Paper
nursery).
Because
of
the
importance
placed
on
seedling
quality
(
due
to
the
high
correlation
of
quality
and
subsequent
forest
health
and
value),
failure
to
achieve
consistently
healthy
seedlings
in
even
a
fraction
of
the
production
beds
can
have
a
devastating
effect
on
this
sector's
ability
to
provide
acceptable
seedlings
for
reforestation.
In
addition,
1,3­
D
may
be
restricted
due
to
legal
or
geological
factors.
Non­
chemical
and
biological
control
methods
have
not
proven
to
be
reliable
independent
treatments,
although
in
some
nurseries
they
have
been
integrated
into
the
routine
seedling
production
system.

Forest
nurseries
throughout
the
U.
S.
must
contend
with
a
variety
of
pests,
but
effective
fumigation
is
primarily
relied
on
to
manage
fungal
pathogens
(
e.
g.,
Fusarium,
Alternaria,
Phytophthora,
Pythium,
Rhizoctonia,
Cylindrocladium
spp.,
and
Macrophomina)
and
especially,
yellow
and
purple
nutsedges
(
species
of
the
Cyperus
weed)
(
Cram
and
Fraedrich,
1997).
Nutsedges
are
generally
considered
the
major
pests
of
all
forest
seedling
nurseries
and
the
pests
most
difficult
to
manage.
Page
11
Inconsistency
in
pest
management
performance
by
chemical
alternatives
is
the
primary
concern
for
this
sector,
and
the
reason
that
MB
is
currently
critical
for
maintaining
high
quality
seedlings.
While
direct
yield
losses,
in
terms
of
seedlings/
hectare,
were
not
very
large
on
average,
intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
quality,
as
well
as
yield,
goals.
In
addition,
economic
issues
such
as
increased
application
costs
(
e.
g.,
costs
associated
with
application
of
metam­
sodium
and
a
separate
chloropicrin
application)
may
have
an
impact
on
overall
feasibility
of
these
alternatives
for
the
forest
seedlings
sector.
Page
12
TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
FOREST
SEEDLINGS*
A.
B.
C.
D.
E.
F.
G.
H.

REGION
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
INTERNATIONAL
PAPER
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
WEYERHAEUSER
SOUTH
WEYERHAEUSER
WEST
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOC
MICHIGAN
SEEDLING
ASSOCIATION
MICHIGAN
HERBACEOUS
PERENNIALS
AMOUNT
OF
NOMINATION
Kilograms
(
kg)
87,348
13,455
1,911
8,981
7,943
12,970
4,477
2,381
Application
Rate
(
kg/
ha)
375
250
263
336
236
341
263
392
2006
Area
(
ha)
233
54
7
27
34
38
17
6
AMOUNT
OF
APPLICANT
REQUEST
Kilograms
(
kg)
246,032
27,305
4,264
17,962
24,752
33,112
9,144
5,619
Application
Rate
(
kg/
ha)
375
250
263
336
263
341
269
397
2005
Area
(
ha)
656
109
16
53
94
97
34
14
Kilograms
(
kg)
246,032
34,181
4,264
17,962
25,358
32,455
9,144
4,763
Application
Rate
(
kg/
ha)
375
250
263
336
263
341
269
392
2006
Area
(
ha)
656
137
16
53
96
95
34
12
ECONOMICS
Marginal
Strategy
1,3­
D
+
CHLOROPICRIN
Yield
Loss
(%)
3%
3%
3%
3%
3%
3%
3%
5%
Loss
per
hectare
(
US$/
ha)
$
3,055.73
$
3,694.51
$
14,141.56
$
1,709.73
$
2,368.40
$
6,546.88
$
6,228.70
$
28,359
Loss
per
kg
MB
(
US$/
kg)
$
32.59
$
59.14
$
53.69
$
20.34
$
27.03
$
38.37
$
69.46
$
145
Loss
as
%
of
Gross
Revenue
(%)
9%
11%
7%
6%
13%
20%
6%
20%
Loss
as
%
of
Net
Revenue
(%)
19%
20%
8%
15%
25%
66%
37%
28%
*
See
Appendix
B
for
a
complete
description
of
how
the
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Although
alternative
treatments
can
be
foreseen
as
likely
long­
term
solutions,
the
replacement
of
critical
uses
of
MB
will
depend
on
the
development
of
application
technologies
that
better
deliver
alternatives
to
soils
containing
target
pests.
While,
alternatives
to
MB
such
as
chloropicrin,
and
combinations
of
chloropicrin
with
metam­
sodium
or
1,3­
D
can
be
effective
in
reducing
pest
infestations,
including
some
weed
problems
(
e.
g.,
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96),
they
are
problematic
for
their
inconsistent
performances,
and
therefore,
unreliability,
for
nurseries
with
moderate
to
high
pest
(
especially
weed)
pressure.
Inconsistency
in
pest
management
performance
by
chemical
alternatives
is
the
primary
concern
for
this
sector,
and
the
reason
that
MB
is
currently
critical
for
maintaining
high
quality
seedlings.
Page
13
While
direct
yield
losses,
in
terms
of
seedlings/
hectare,
were
not
very
large
on
average,
intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
quality,
as
well
as
yield,
goals.
In
addition,
economic
issues
such
as
increased
application
costs
(
e.
g.,
costs
associated
with
application
of
metam­
sodium
and
a
separate
chloropicrin
application)
may
have
an
impact
on
overall
feasibility
of
these
alternatives
for
the
forest
seedlings
sector.
Because
of
the
importance
placed
on
seedling
quality
(
due
to
the
high
correlation
of
quality
and
subsequent
forest
health
and
value),
failure
to
achieve
consistently
healthy
seedlings
in
even
a
fraction
of
the
production
beds
can
have
a
devastating
effect
on
this
sector's
ability
to
provide
acceptable
seedlings
for
reforestation.
In
addition,
1,3­
D
may
be
restricted
due
to
legal
or
geological
factors.
Non­
chemical
and
biological
control
methods
have
not
proven
to
be
reliable
independent
treatments,
although
in
some
nurseries
they
have
been
integrated
into
the
routine
seedling
production
system.
Research
studies
with
organic
and
inorganic
soil
amendments
(
Fraedrich
and
Dwinell,
1998;
James
et
al.,
1997;
James
et
al.,
2001;
Lantz,
1997;
Stone
et
al.,
1998)
have
observed
some
reduction
in
reducing
populations
of
certain
pathogens,
but
the
effects
appear
to
be
variable
depending
on
the
nursery
locations
and
species
of
seedlings,
and
it
is
unclear
if
the
pathogen
population
is
correlated
with
disease
incidence.
More
research
is
required
before
there
can
be
commercial
application
of
these
methods
as
independent
treatments.

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
IN
2002
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
IN
2002
(%)
A.
Southern
Forest
Nursery
Management
Cooperative
Not
available
Not
available
B.
International
Paper
Not
available
Not
available
C.
Illinois
Dept
of
Natural
Resources
Not
available
Not
available
D.
Weyerhaeuser­
South
Not
available
Not
available
E.
Weyerhaeuser­
West
Not
available
Not
available
F.
Northeastern
Forest
and
Conservation
Nursery
Association
Not
available
Not
available
G.
Michigan
Seedling
Association
Not
available
Not
available
H.
Michigan
Herbaceous
Perennials
Not
available
Not
available
NATIONAL
TOTAL**:
51,506
2%
*
Typically,
only
a
fraction
of
a
nursery's
beds
are
fumigated
in
a
given
year.
**
National
average
may
include
states
not
requesting
methyl
bromide.

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.

Generally,
MB
is
the
product
used
in
this
industry,
which
allows
beds
to
be
fumigated
after
two
or
three
crops
(
as
opposed
to
after
every
crop)
because
of
the
effectiveness
of
MB,
which
usually
makes
a
second
year
treatment
unnecessary.
Moreover,
during
the
subsequent
two
years
an
unfumigated
cover
crop
is
planted
for
the
purposes
of
soil
organic
matter
maintenance.
Less
effective
alternative
products
require
fumigation
more
often,
and
consequently,
higher
management
costs
are
incurred.
Page
14
7.
(
iii)
WOULD
IT
BE
FEASIBLE
TO
EXPAND
THE
USE
OF
THESE
METHODS
TO
COVER
AT
LEAST
PART
OF
THE
CROP
THAT
HAS
REQUESTED
USE
OF
METHYL
BROMIDE?
WHAT
CHANGES
WOULD
BE
NECESSARY
TO
ENABLE
THIS?

The
use
of
alternative
methods
depends
on
further
research
to
establish
viable
alternatives
that
provide
the
same
benefits
as
MB.
Currently
research
is
being
conducted
by
all
parties
of
this
sector.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1.
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
A
­
Southern
Forest
Nursery
Management
Cooperative
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
246,032
246,032
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
656
656
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
375
375
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
37.5
37.5
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
383
383
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
38.3
38.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
15
TABLE
8.2.
REGION
B
­
INTERNATIONAL
PAPER:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
B
­
International
Paper
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
27,305
34,181
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
109
137
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
250
250
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
25
25
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
373
373
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
37.3
37.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

TABLE
8.3.
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
C
­
Illinois
Department
of
Natural
Resources
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
4,264
4,264
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
16
16
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
263
263
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
26.3
26.3
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
393
393
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
39.3
39.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
16
TABLE
8.4.
REGION
D
­
WEYERHAEUSER­
SOUTH:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
D:
Weyerhaeuser­
South
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
17,962
17,962
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
90:
10
90:
10
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
53
53
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
336
336
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
33.6
33.6
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
373
373
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
37.3
37.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

TABLE
8.5.
REGION
E
­
WEYERHAEUSER­
WEST:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
E
­
Weyerhaeuser­
West
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
24,752
25,358
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
94
96
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
263
263
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
26.3
26.3
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
393
393
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
39.3
39.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
17
TABLE
8.6.
REGION
F
­
NORTHEASTERN
FOREST
AND
CONSERVATION
NURSERY
ASSOCIATION:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
F
­
Northeastern
Forest
and
Conservation
Nursery
Association
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
33,112
32,455
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
97
95
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
341
341
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
34.1
34.1
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
348
348
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
34.8
34.8
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

TABLE
8.7.
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
G
­
Michigan
Seedling
Association
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
9,144
9,144
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
34
34
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
269
269
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
26.9
26.9
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
402
402
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
40.2
40.2
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
18
TABLE
8.8.
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
H
 
Michigan
Herbaceous
Perennials
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
MB
5,619
4,763
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
14
12
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
397
392
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
39.7
39.2
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
405
400
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
40.5
40
*
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
U.
S.
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop.
No
adjustment
was
made
for
this
sector.
 
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.
The
double
counted
hectares
were
removed.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
five
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
QPS
hectares
were
removed
from
each
application's
request.
 
Only
the
acreage
experiencing
moderate
to
heavy
key
pest
pressure
was
included
in
the
nominated
amount.
Page
19
TABLE
A.
2:
2005
SECTOR
NOMINATION*
REGION
A.
B.
C.
D.
E.
F.
G.
H.

2005
FOREST
SEEDLING
NOMINATION
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
INTERNATIONAL
PAPER
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
WEYERHAEUSER
SOUTH
WEYERHAEUSER
WEST
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOC
MICHIGAN
SEEDLING
ASSOCIATION
MICHIGAN
HERBACEOUS
PERENNIALS
Hectares
(
ha)
656
109
16
53
94
97
34
14
Application
Rate
(
kg/
ha)
375
250
263
336
263
341
269
397
Applicant
Request
Kilograms
(
kg)
246,032
27,305
4,264
17,962
24,752
33,112
9,144
5,619
*
See
Appendix
B
for
a
complete
description
of
how
the
nominated
amount
was
calculated.

TABLE
A.
3:
2006
SECTOR
NOMINATION*
REGION
A.
B.
C.
D.
E.
F.
G.
H.

2006
Forest
Seedlings
Nomination
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
INTERNATIONAL
PAPER
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
WEYERHAEUSER
SOUTH
WEYERHAEUSER
WEST
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOC
MICHIGAN
SEEDLING
ASSOCIATION
MICHIGAN
HERBACEOUS
PERENNIALS
Hectares
(
ha)
656
137
16
53
96
95
34
12
Application
Rate
(
kg/
ha)
375
250
263
336
263
341
269
392
Applicant
Request
Kilograms
(
kg)
246,032
34,181
4,264
17,962
25,358
32,455
9,144
4,763
Hectares
(
ha)
233
54
7
27
34
38
17
6
Application
Rate
(
kg/
ha)
375
250
263
336
236
341
263
392
CUE
Nominated
Kilograms
(
kg)
87,348
13,455
1,911
8,981
7,943
12,970
4,477
2,381
OVERALL
REDUCTION
(%)
63%
2006
SECTOR
NOMINATION
TOTALS
TOTAL
2006
U.
S.
SECTOR
NOMINATED
KILOGRAMS
(
KG)
139,882
*
See
Appendix
B
for
a
complete
description
of
how
the
nominated
amount
was
calculated.
Page
20
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi
[
100%
at
times]:
Fusarium,
Macrophomina,
Rhizoctonia,
Pythium,
Phytophthora;
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Weeds
[
100%
at
times]:
broadleaf,
grasses,
sedges
MB
allows
three
successive
seedling
crops
with
only
one
fumigation
treatment
(
one
treatment
every
four
years).
Alternative
treatments
will
require
more
frequent
fumigation
due
to
reduced
efficacy.

REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
bareroot
forest
seedlings
(
96%
pine,
4%
hardwood
species)
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
typically
grown
for
1
year
for
each
of
three
crops
before
fumigation
on
fourth
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Two
years
of
pine
or
hardwood
followed
by
two
years
of
cover
crop.
Fumigation
occurs
only
before
the
first
pine
crop
and
every
hardwood
crop.
Cover
crops
are
not
fumigated.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light
(
85%);
medium
(
15%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
typically,
fumigated
once
in
4
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
Page
21
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
7a,
7b,
8a,
8b
RAINFALL
a
(
mm)
125
128
155
135
91
100
141
118
76
52
87
131
OUTSIDE
TEMP.
(
°
C)
7.7
10.0
13.9
18.3
22.2
26.1
27.2
27.2
25.0
18.9
13.9
10.0
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
b
2nd
3rd
4th
years
aThe
rainfall
and
temperature
data
are
for
Alabama,
which
may
be
considered
typical
of
the
region.
bFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.

REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
four
year
cycle.
Therefore,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
a
10
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
Page
22
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
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)
not
available
not
available
not
available
656
656
656
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
not
available
not
available
not
available
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
not
available
not
available
not
available
246,032
246,032
246,032
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
not
available
not
available
not
available
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
not
available
not
available
not
available
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
not
available
not
available
not
available
375
375
375
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
not
available
not
available
not
available
37.5
37.5
37.5
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
not
available
not
available
not
available
383
383
383
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
not
available
not
available
not
available
38.3
38.3
38.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
23
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
B
­
INTERNATIONAL
PAPER
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
B
­
INTERNATIONAL
PAPER
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi:
Rhizoctonia
(
root
rot);
International
Paper
Weeds:
Cyperus
esculentus/
rotundus
(
purple/
yellow
nutsedge)
For
current
production
requirements,
only
methyl
bromide
acceptably
meets
goals.
Containerized
production
increases
costs
2.5­
3
times,
making
it
economically
unfeasible.

REGION
B
­
INTERNATIONAL
PAPER
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
B
 
INTERNATIONAL
PAPER
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
INTERNATIONAL
PAPER
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Forest
seedlings
(
all
pine
species)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
typically
grown
for
1
year
for
each
of
three
crops
before
fumigation
on
fourth
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light,
medium,
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
4
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
B
 
INTERNATIONAL
PAPER
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
6b,
7a,
7b,
8a,
8b
RAINFALL
(
mm)
Not
available,
but
varies
with
diverse
climates
OUTSIDE
TEMP.
(
°
C)
Not
available,
but
varies
with
diverse
climates
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
a
2nd
3rd
4th
years
aFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.
Page
24
REGION
B
­
INTERNATIONAL
PAPER
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
four
year
cycle.
Therefore,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
a
10
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
Page
25
REGION
B
­
INTERNATIONAL
PAPER
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
B
­
INTERNATIONAL
PAPER
­
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)
139
88
185
121
114
101
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
53,028
32,580
68,975
43,646
38,666
34,853
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
381
371
374
362
338
345
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
38.1
37.1
37.4
36.2
33.8
34.5
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
389
379
382
369
345
352
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
38.9
37.9
38.2
36.2
33.8
34.5
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Page
26
METHYL
BROMIDE
USE
IS
REQUESTED
Fungi:
Fusarium;

"
weeds";
Illinois
Department
of
Natural
Resources
"
nematodes"
Consistency
in
production
of
the
variety
of
nursery
plants
grown.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Hardwood
seedlings,
shrubs,
prairie
forbs
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
1
or
2
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
every
year
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
5b,
6b
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

For
this
small,
public
consortium,
fumigation
in
the
fall
followed
by
planting
is
the
most
effective
means
of
meeting
production
goals.
Alternatives
will
require
delays
due
to
increased
labor
costs
for
hand
weeding,
and
potential
outgassing
damage
to
already
planted
beds.
Page
27
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
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)
15
15
17
16
13
16
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
5,835
5,757
4,370
4,211
3,411
4,232
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
384
384
263
263
263
263
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
38.4
38.4
26.3
26.3
26.3
26.3
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
392
392
392
392
392
392
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
39.2
39.2
39.2
39.2
39.2
39.2
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
28
REGION
D
­
WEYERHAEUSER­
SOUTH
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
D
­
WEYERHAEUSER­
SOUTH
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi:
Fusarium,
Pythium,
Rhizoctonia;

WEYERHAEUSERSOUTH
Weeds:
Cyperus
(
nutsedges)
Only
number
1
grades
are
sold;
grade
2
and
culls
are
discarded.
To
economically
manage
the
range
of
pests,
especially
problematic
fungal
pathogens
and
nutsedges,
methyl
bromide
is
necessary
as
no
alternatives
provide
both
sufficient
control
and
economic
sustainability
for
high
grade
seedlings.

REGION
D
­
WEYERHAEUSER­
SOUTH
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
WEYERHAEUSER­
SOUTH
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Primarily
loblolly
pine;
some
hardwood
species
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
(
62%);
Medium
(
22%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
four
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
Page
29
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
7b,
8a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
a
2nd
3rd
4th
years
aFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.

REGION
D
­
WEYERHAEUSER­
SOUTH
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
four
year
cycle.
Therefore,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
a
10
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
Page
30
REGION
D
­
WEYERHAEUSER­
SOUTH
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
D
­
WEYERHAEUSER­
SOUTH
­
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)
63
64
72
66
61
64
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
25,642
25,935
29,649
21,516
21,709
24,231
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
90:
10
90:
10
90:
10
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
407
405
412
327
355
379
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
40.7
40.5
41.2
32.7
35.5
37.9
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
415
413
420
363
394
421
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
41.5
41.3
42.0
36.3
39.4
42.1
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

REGION
E
­
WEYERHAEUSER­
WEST
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
E
­
WEYERHAEUSER­
WEST
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Page
31
USE
IS
REQUESTED
Fungi
[
100%
at
times]:
Pythium
(
damping­
off,
root
rot),
Fusarium
(
damping­
off,
root
rot),
Phoma,
Fusarium,
Botrytis
(
stem
cankers);
Weyerhaeuser­
West
Weeds:
Cyperus
(
yellow
nutsedge)
[
100%
at
times]
High
pathogen
populations
and
potential
for
contamination
with
Phytophthora
ramorum
(
sudden
oak
death)
leave
little
room
for
production
variability.

REGION
E
­
WEYERHAEUSER­
WEST
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
WEYERHAEUSER­
WEST
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pine,
Christmas
trees,
some
hardwoods
(?)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
one
year
seedling
bed,
one
year
transplant
bed;
transplants
can
be
grown
for
2,
3,
or
4
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
(
60%),
Medium
(
40%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
3
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
8a,
8b
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
1st
year
PLANTING
SCHEDULE
2nd
3rd
aTypically
fumigation
occurs
only
once
in
three
years
after
two
successive,
one
year
old
seedlings
are
harvested.

REGION
E
­
WEYERHAEUSER­
WEST
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
two
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
a
10
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
Page
32
REGION
E
­
WEYERHAEUSER­
WEST
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
E
­
WEYERHAEUSER­
WEST
­
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)
39
47
43
70
65
69
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
10,126
12,296
11,360
17,864
17,125
14,647
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
263
263
263
255
263
211
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
26.3
26.3
26.3
25.5
26.3
21.1
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
393
393
393
381
393
315
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
39.3
39.3
39.3
38.1
39.3
31.5
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
­
Part
B:
Crop
Characteristics
and
Methyl
Bromide
Use
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Page
33
Fungi:
Phytophthora
(
damping­
off,
root
rot)
[
80%],
Fusarium
(
damping­
off,
root
rot)
[
80%],
Cylindrocladium
[
50%];
Northeastern
Forest
&
Conservation
Nursery
Association
Weeds:
Cyperus
(
yellow
nutsedge)
[
40%],
Cirsium
(
Canada
thistle)
[
70%]
In
humid,
warm
conditions
damping­
off
is
significant
problem;
as
with
much
of
industry,
weed
problems,
especially
nutsedge
and
Canada
thistle
are
difficult
to
manage
without
MB.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
NORTHEASTERN
FOREST
AND
CONSERVATION
NURSERY
ASSOCIATION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Conifers
(
10­
15
spp.),
hardwoods
(
30­
50
spp.),
shrubs
and
forbs
(>
75
spp.)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Bareroot
cuttings,
and
transplants,
typically
grown
1­
3
years
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light,
Medium
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
typically
once
in
a
1­
3
year
rotation,
depending
on
species
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
3a,
4b,
5a,
5b,
6a,
6b,
7a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
X
PLANTING
SCHEDULE
a
X
X
X
X
X
X
aDue
to
the
large
number
of
species
and
wide
geographical
area
represented
in
this
consortium,
seedlings
can
be
planted
at
various
times
in
the
fall
or
spring.
Generally,
fumigation
occurs
once
in
two
or
three
years,
but
beds
for
certain
hardwood
species
may
be
treated
every
year.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
two
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
a
10
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
Page
34
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
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)
83
98
91
87
80
72
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
31,772
34,997
31,961
28,308
26,844
26,273
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
383
357
352
326
337
363
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
38.3
35.7
35.2
32.6
33.7
36.3
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
391
364
359
333
344
370
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
39.1
36.4
35.9
33.3
34.4
37.0
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Page
35
Michigan
Seedling
Association
fungal
pathogens,
annual
and
perennial
weeds
(
e.
g.,
nutsedge,
Canada
thistle);
nematodes
Soil­
borne
diseases
are
of
major
concern,
as
well
as
nutsedge;
best
alternatives
dazomet
and
metam­
sodium
are
not
effective
against
these
pests
in
this
climatic
region.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
SEEDLING
ASSOCIATION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Conifers,
hardwoods
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Bareroot
and
transplants,
typically
1,
2,
or
3
years
growth
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
every
3­
4
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
4b,
5b
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
(
sometimes)
Spring
(
usually)
Fall
(
usually)
Fall
PLANTING
SCHEDULE
usually
after
Fall
fumigation
aFumigation
schedules
depend
on
growth
as
annual
seedlings
or
additional
bed
requirements
as
transplants.
Generally,
fumigation
occurs
once
in
two
or
three
years,
but
beds
for
certain
hardwood
species
may
be
treated
every
year.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Michigan
Seedling
Association
working
with
Michigan
State
University
is
in
the
midst
of
conducting
research
(
with
grants
from
USDA
MB
Alternatives
program)
to
assess
the
efficacy
of
alternatives
with
an
economic
survey
conducted
to
define
costs
associated
with
alternatives.
Results
of
this
research
that
will
be
available
in
2006­
2007,
should
help
identify
true
alternatives
to
MB.
Until
this
time,
MB
is
critical
for
the
continuation
of
this
industry.
Because
of
MB
efficacy,
fumigation
generally
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
successive
crops
are
produced
for
each
fumigation
event.
Page
36
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
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)
52
55
46
51
34
34
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
14,043
14,914
12,301
13,825
8,954
8,954
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
269
269
269
269
263
263
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
26.9
26.9
26.9
26.9
26.3
26.3
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
401
401
401
401
401
401
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
40.1
40.1
40.1
40.1
40.1
40.1
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
37
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
MICHIGAN
Herbaceous
Perennials
Nematodes:
Meloidogyne
hapla,
Pratylenchus
spp.,
Ditylenchus
spp.;
Fungi:
Pythium
(
damping­
off,
root
rot),
Fusarium
(
damping­
off,
root
rot),
Phytophthora,
Rhizoctonia;
Weeds:
Cyperus
esculentus
(
yellow
nutsedge),
Inula
brittanica,
Oxalis
stricta,
Cirsium
arvense,
Rorippa
sylvestris
Research
for
effective
alternative
to
MB
is
ongoing
with
USDA
supported
research
due
to
be
analyzed
and
reported
after
2006
studies
end.
Until
this
time
when
field­
tested
alternatives
can
be
identified,
MB
is
critical
to
pest
management
for
this
industry.

REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
HERBACEOUS
PERENNIALS
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
ornamental
herbaceous
perennials
(
e.
g.,
Delphinium,
Hosta,
Phlox)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial:
2­
year
seeded
(
6%
of
treated
area)
and
2­
year
transplants
(
29%
of
treated
area)
are
on
a
2
year
replant/
fumigation
cycle;
3­
year
transplants
(
65%
of
treated
area)
are
on
a
3
year
replant/
fumigation
cycle
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
various,
light
to
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
2
to
3
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
identified.
Page
38
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
Year
1
of
two­
year
cycle.

MARYEAR
1
APRYEAR
1
MAY­
YEAR
1
JUNYEAR
1
JULYEAR
1
AUG­
YEAR
1
SEPT­
YEAR
1
OCT­
YEAR
1
NOVYEAR
1
DECYEAR
1
JANYEAR
1
FEBYEAR
1
CLIMATIC
ZONE
USDA
zones
5a,
5b,
6a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
2­
year
transplants
2­
year
seedlings;
3­
year
transplants
PLANTING
SCHEDULE
2­
year
transplants
3­
year
transplants
3­
year
transplants
Year
2
of
two­
year
cycle.

MARYEAR
2
APRYEAR
2
MAYYEAR
2
JUNYEAR
2
JULYEAR
2
AUGYEAR
2
SEPTYEAR
2
OCTYEAR
2
NOVYEAR
2
DECYEAR
2
JANYEAR
2
FEBYEAR
2
CLIMATIC
ZONE
USDA
zones
5a,
5b,
6a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
PLANTING
SCHEDULE
2­
year
seedlings
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Until
research
results
are
compiled
and
analyzed,
in
2006­
2007,
MB
is
the
only
proven
treatment
for
the
numerous
plant
species
grown
by
this
consortium.
Fumigation
schedule
with
MB
is
based
on
the
effectiveness
in
managing
the
numerous
pests.
With
alternatives,
fumigation
will
likely
have
to
be
increased
and
timing
of
seedling
and
transplant
production
will
be
affected.
Consequently,
the
ongoing
research
program
must
be
completed
to
address
implementation
of
production
processes
with
newly
identified
alternatives.
Page
39
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
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)
263
258
248
228
129
128
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
103,351
101,.
287
97,477
89,539
50,485
51,068
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
injected
injected
injected
injected
injected
injected
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
392
392
392
392
392
392
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
39.2
39.2
39.2
39.2
39.2
39.2
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
400
400
400
400
400
400
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
40
40
40
40
40
40
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
40
PART
C:
TECHNICAL
VALIDATION
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
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:
ALSO,
SEE
SECTION
14
FOR
ADDITIONAL
CHEMICALS
NOT
LISTED
BY
MBTOC.

Dazomet
(
400
kg/
ha)
Inconsistent
results
with
weeds,
especially
w/
moderate
to
high
weed
pressure.
Does
not
consistently
provide
acceptable
levels
of
nutsedge
control,
nor
does
it
manage
some
diseases
associated
with
fungal
pathogens
(
root
rot
and
damping­
off
pathogens).
Field
trials
show
that
seedling
size
(
diameter
and
height)
and
root
volume
were
inconsistent,
non­
uniform,
and
reduced
with
dazomet,
leading
to
higher
counts
of
Grade
#
2
seedlings
and
culls
compared
to
greater
numbers
of
Grade
#
1
seedlings
with
MB.
Reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
dazomet
has
resulted
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Soil
temperature
requirements
(
above
6
°
C/
optimal
12­
18
°
C)
of
dazomet,
due
to
vapor
pressure
properties,
constrains
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989);
(
Campbell
and
Kelpsas,
1988;
Carey,
1996;
Carey,
1994;
Enebak
et
al.,
1990;
Weyerhaeuser,
#
3,
1984­
87;
Weyerhaeuser,
#
4,
1985­
87;
Weyerhaeuser,
#
6,
1992;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
9,
1994­
95;
Weyerhaeuser,
#
10,
1994­
96)
no
Metam­
sodium
(
485
kg/
ha)
Inconsistent
results
with
weeds,
especially
w/
high
weed
pressure.
Average
yield
losses
are
estimated
to
be
approximately
5%
with
metam­
sodium,
although
the
addition
of
other
pesticides
to
provide
broader
control
could
reduce
losses.
As
with
dazomet,
reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
As
with
dazomet,
seedling
quality
is
inconsistent
resulting
in
less
predictable
seedling
production
factors.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
metam­
sodium
has
resulted
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Fumigant
drift
may
result
in
issues
related
to
human
safety
and
legal
liability.
Soil
temperature
requirements
(
above
4
°
C)
of
metam­
sodium,
due
to
vapor
pressure
properties,
can
constrain
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989);
(
Campbell
and
Kelpsas,
1988;
Carey,
1996;
Carey,
1994,
Darrow,
2002;
Weyerhaeuser,
#
4,
1985­
87;
Weyerhaeuser,
#
6,
1992)
no
Page
41
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
NON
CHEMICAL
ALTERNATIVES
Containerized
production
Containerization
of
nursery
production
would
(
1)
require
a
large
capital
investment
by
all
participants
in
the
sector,
(
2)
increase
seedling
production
costs
by
300
to
600%,
(
3)
reduce
reforestation
rates
as
public
nurseries
opt
out
of
reforestation
as
expenditures
go
up.
(
see
section
18
and
Appendix
A.).
Some
nurseries
with
specialized
markets
have
a
portion
of
their
production
in
containers
(
Barnett
and
McGilvrary,
1997;
Darrow,
2002;
Lowerts,
2003).
For
seedling
production
goals,
is
not
cost
effective
for
the
complex
production
system.
[
see
Section
18
and
Appendix
A.]

Virtually
Impermeable
Film
(
VIF)
Current
technology
does
not
allow
the
gluing
together
of
overlapping
sheets
and
therefore
makes
this
product
nonfunctional
for
flat
fumigation
treatments,
and
currently
available
products
are
relatively
weak
and
torn
by
wind
or
pressure.
Both
factors
combine
to
make
VIF
film
impractical
using
current
technology.
In
the
future,
VIF
might
have
a
role
in
reducing
MB
use
rates
while
maintaining
efficacy,
due
to
reduced
emissions.
Ongoing
studies
may
help
assess
value
of
VIF
with
MB
and
chemical
alternatives.
(
Guillino
et
al.,
2002;
Martin,
2003).
not
currently
cost
effective
Solarization
Not
able
to
generate
acceptable
heat
to
allow
spring
planting;
most
effective
time
for
solarization
is
not
compatible
with
timing
for
production;
uses
solar
radiation
to
heat
soil
under
clear
plastic,
and
under
certain
conditions
in
some
locations
in
the
summer,
soil
can
be
heated
to
as
high
as
60
C
to
a
depth
of
7.5
cm.
Effective
solarization
would
likely
require
several
months
of
covered
bed
treatments,
to
heat
soil
to
a
sufficient
depth
(
25­
30
cm)
in
order
to
affect
soil­
borne
pathogens.
Seeds
of
some
weed
species
are
resistant
even
to
higher
temperatures
obtained
with
solarization.
Nutsedges,
Fusarium
spp.,
Macrophomina
spp.
are
not
controlled,
or
unpredictably
controlled,
by
solarization
(
Elmore
et
al.,
1997).
Therefore,
this
alternative
is
not
considered
technically
feasible.
Conceivably,
solarization
could
be
optimized
for
efficacy
and
incorporated
into
an
integrated
pest
management
(
IPM)
program
that
would
help
reduce
chemical
use
for
bed
preparation,
but
because
of
intensive
scheduling
of
seedling
production,
solarization
is
inadequate
as
a
sole
replacement
for
MB
in
the
forest
seedling
industry
even
in
the
southern
U.
S.
(
Weyerhaeuser,
#
8,
1992­
95)
not
cost
effective
as
drop­
in
replacement
Page
42
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biofumigation
This
is
a
process
where
mustard
species
(
Brassica
spp.)
are
grown
and
ultimately
disked
into
soils.
A
bioactive
breakdown
product
of
some
of
these
species
is
MITC.
However,
this
alternative
is
not
considered
feasible
due
to
the
difficulty
in
obtaining
sufficient
biomass
to
produce
effective
amounts
of
MITC
to
manage
diseases
and
weeds
under
nursery
conditions.
11,500
kg
per
ha
of
Brassica
plants
 
an
amount
that
is
considered
very
high
production
 
is
only
equivalent
to
approximately
25
kg
dazomet,
an
amount
significantly
less
than
effective
fumigation
rates.
In
addition,
increased
Fusarium
populations
due
to
favorable
conditions
provided
by
Brassica
plants
have
been
reported
to
increase
seedling
diseases
after
biofumigation
treatments.
While
some
Petri
dish
studies
(
e.
g.,
Charron
and
Sams)
have
indicated
a
reduction
in
growth
of
some
fungal
pathogens
limited
field
studies
have
been
conducted
to
verify
effects.
not
able
to
provide
sufficient
biomass
Flooding/
Water
management
Nursery
beds
generally
are
designed
and
graded
for
good
drainage
to
prevent
standing
water.
Flooding
could
increase
incidence
of
Phytophthora
and
Pythium,
which
cause
important
damping­
off
and
root
rot
diseases.
Therefore,
this
alternative
is
not
considered
technically
feasible.
no
General
Integrated
Pest
Management
(
IPM)
Nurseries
currently
use
IPM
techniques,
but
these
measures
do
not
provide
adequate
weed
and
disease
control.
Therefore,
this
alternative
is
not
considered
technically
feasible.
not
as
drop­
in
replacement
Plowing/
Tillage
Nursery
beds,
especially
medium
type
soils
with
higher
clay
or
organic
matter
than
light
soil
beds,
are
susceptible
to
damage
to
soil
structure
and
development
of
an
impermeable
"
plow
pan"
layer.
Increased
plowing
can
result
in
less
productive
seedling
beds,
therefore,
this
alternative
is
not
considered
feasible.
no
Physical
Removal/
Sanitation
Appropriate
sanitation
practices
are
already
followed
by
nurseries
as
this
improves
productivity.
Weed
control
by
mechanical
means
would
not
be
technically
feasible
for
large­
scale
nursery
seedling
production.
Disease
problems
would
still
require
additional
measures,
and
therefore,
this
alternative
is
not
considered
feasible.
no
Organic
Amendments/
Compost
Not
acceptably
effective
alone
in
weed
management;
often
already
incorporated
as
part
of
general
ipm
program;
can
be
issue
with
weed
introduction
by
plant­
based
mulches
(
James
et
al.,
1997;
James
et
al.,
2001;
Stone
et
al.,
1998).
Most
nurseries
employ
various
soil
amendments
to
enhance
seedling
growth
and
quality,
but
these
measures
do
not
provide
adequate
weed
and
disease
control,
therefore,
this
alternative
is
not
considered
feasible.
no
COMBINATIONS
OF
ALTERNATIVES
See
Section
14
for
non­
MBTOC
alternatives
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
43
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

Chloropicrin
and
1,3­
D
were
not
listed
as
one
of
the
MB
alternatives
by
MBTOC.
These
have
been
investigated
by
the
industry
as
potential
alternatives,
and
in
certain
circumstances
(
e.
g.,
low
weed
pressure),
can
be
effective
in
reducing
weed,
fungi
and
nematode
populations.

TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Chloropicrin
(
340
kg/
ha)
A
good
fungicide,
but
not
acceptably
effective
with
moderate
or
high
weed
pressure,
some
reports
of
enhanced
weed
seed
germination
(
Carey,
2000;
Carey,
1996;
Enebak
et
al.,
1990;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
10,
1994­
96).
Weed
pressure
will
likely
increase
overtime.

Metam­
sodium
(
485
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
Can
be
effective
against
weeds
and
fungi,
especially
with
low
to
moderate
pressure
and
light
soils
(
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
10,
1994­
96).
There
is
a
history
of
outgassing
problems
and
significant
seedling
damage.

1,3­
D
(
260
kg/
ha)
+
chloropicrin
(
140
kg/
ha)
A
good
nematicide,
requires
light
soils
with
optimal
moisture
content.
Not
sufficiently
effective
against
weeds,
especially
with
even
moderate
weed
pressure;
may
have
legal
restrictions
on
use
(
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
10,
1994­
96)

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

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:

Sodium
Azide
Not
registered
in
U.
S.
No
registration
package
has
been
received.
No
Unknown
Propargyl
bromide
Not
registered
in
U.
S.
No
registration
package
has
been
received.
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
Page
44
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.

16.1.
A:
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDS
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
193b
[
2]
236a
[
3]
236a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
6b
[
2]
19ab
[
3]
45a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
3%

[
2]
8%

[
3]
19%
(#
Nutsedge
rhizomes
per
m2)

[
1]
91a
[
2]
43b
[
3]
5b
No
MB
trt
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
285
kg/
ha)

[
3]
Chloropicrin
(
285
kg/
ha)
+

metam
sodium
(
240
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
150b
[
2]
214ab
[
3]
246a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
8b
[
2]
15ab
[
3]
53a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
5%

[
2]
7%

[
3]
22%
(
Nutsedge
dry
wt,

kg/
ha)

[
1]
551a
[
2]
40b
[
3]
11b
No
MB
trt
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)

[
4]
MB
(
385
kg/
ha)
+
Pic
(
8
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
150b
[
2]
193a
[
3]
204a
[
4]
204a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
27b
[
2]
114ab
[
3]
150a
[
4]
131a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
18%

[
2]
59%

[
3]
74%

[
4]
64%
Not
reported
Not
reported
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)

[
4]
MB
(
385
kg/
ha)
+
Pic
(
8
kg/
ha)
1
(
W/

Slash
pine)
Average
Total
Yield
(
per
m2)

[
1]
107a
[
2]
150a
[
3]
150a
[
4]
129a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
63b
[
2]
109ab
[
3]
136a
[
4]
109ab
Quality
(%
Grade
#
1
compared
to
total)

[
1]
59%

[
2]
73%

[
3]
91%

[
4]
84%
Not
reported
Not
reported
Carey,

2000
"
Heavy"
soil
(
57%
silt,
14%
clay,

29%
sand)
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
285
kg/
ha)

[
3]
Metam
sodium
(
455
kg/
ha)

[
4]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
455
kg/
ha)

[
5]
1,3­
D
(
240
kg/
ha)
+
Pic
(
100
kg/
ha)

[
6]
Dazomet
(
285
kg/
ha)

[
7]
MB
(
265
kg/
ha)+
Pic(
130kg/
ha)
1
(
w/
Loblolly
pine
Average
Total
Yield
(
per
m2)

[
1]
194
[
2]
181
[
3]
204
[
4]
192
[
5]
238
[
6]
214
[
7]
188
[
LSD,
0.05=
20]
Average
Grade
#
1
Yield
(
per
m2)

[
1]
41
[
2]
31
[
3]
35
[
4]
31
[
5]
28
[
6]
25
[
7]
23
[
LSD,
0.05=
40]
Quality
(%
Grade
#
1
compared
to
total)

[
1]
21%

[
2]
17%

[
3]
17%

[
4]
16%

[
5]
12%

[
6]
12%

[
7]
12%
(#
Total
weeds/
m2;
53
days
after
treatment)

[
1]
37
[
2]
16
[
3]
25
[
4]
7
[
5]
12
[
6]
12
[
7]
6
[
LSD,
0.05=
14]
(%
Coverage
of
weeds
per
plot
(
30
m2);
53
days
after
treatment)

[
1]
39%
a
[
2]
14%
bc
[
3]
25%
ab
[
4]
11%
bc
[
5]
21%
bc
[
6]
22%
bc
[
7]
6%
c
Carey,

1996
Page
45
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
1,3­
D
(
240
kg/
ha)
+

chloropicrin
(
100
kg/
ha)

[
3]
Metam
sodium
(
455
kg/
ha)

[
4]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
455
kg/
ha)

[
5]
Dazomet
(
340
kg/
ha)

[
6]
Dazomet
(
170
kg/
ha)
+
Pic
(
130kg/
ha)

[
7]
MB
(
265
kg/
ha)+
Pic(
130kg/
ha)
Not
reported
Not
reported
Not
reported
Not
reported
(#
Nutsedge
/
m2;
7
months
after
treatment)

[
1]
85abc
[
2]
5c
[
3]
27bc
[
4]
15bc
[
5]
98abc
[
6]
127abc
[
7]
1c
[
LSD,
0.05=
38]
(%
Coverage
of
weeds
per
plot
(
175
m2)
7
months
after
treatment)

[
1]
100%
a
[
2]
35%
c
[
3]
36%
c
[
4]
38%
c
[
5]
95%
a
[
6]
46%
c
[
7]
29%
c
[
LSD,
0.05=
16]
Carey,

1994
[
1]
Metam­
sodium
(
485
kg/
ha)

[
2]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
[
spring
trt]

[
3]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
[
fall
trt]
1
(
1st
year
Ponderosa
pine)
Average
Total
Yield
(
per
m2)

[
1]
245/
m2
[
2]
221/
m2
[
3]
208/
m2
Not
reported
Not
reported
Not
reported
Not
reported
Weyerhaeuser
#
2,
1980
[
1]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)

[
2]
Metam­
sodium
(
485
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)
1
(
2nd
year
crop
Douglas
fir)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
54/
m2
[
3]
 
5/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
11%

[
3]
1%
Consortium
(
CUE
03­
0021)
Comment:

"
Height,
caliper,

shoot
weight
were
greater
w/
MBC
treated
soil"
Not
reported
Not
reported
Weyerhaeuser
#
4,
1985­

1987
[
1]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)

[
2]
Dazomet
(
285
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)

[
4]
Control
1
(
2nd
year
crop
w/

Douglas
fir)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
88/
m2
[
3]
 
13/
m2
[
4]
 
75/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
18%

[
3]
3%

[
4]
16%
Consortium
(
CUE
03­
0021)
Comment:

"
Seedling
size
not
significantly
different
between
MBC
and
dazomet
at
285
kg/
ha;
size
reduced
w/
dazomet
at
400
kg/
ha
(
toxicity?")
Not
reported
Not
reported
Weyerhaeuser
#
5,
1985­

1987
Page
46
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
10
kg/
ha)

[
2]
Metam
sodium
(
485
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)

[
4]
Control
1
(
1st
year
crop
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
27/
m2
[
3]
 
13/
m2
[
4]
 
27/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
6%

[
3]
3%

[
4]
6%
Consortium
(
CUE
03­
0021)
Comment:

"
Seedling
height
averaged
5
cm
shorter
for
dazomet
and
10
cm
shorter
for
metam
sodium
and
control."

"
Caliper
(
diameter)

was
reduced
by
1
mm
in
metam
sodium
and
control
seedlings."
Not
reported
Not
reported
Weyerhaeuser
#
6,
1992
[
1]
MB
(
390
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
MB
(
300
kg/
ha)
+
chloropicrin
(
100
kg/
ha)
)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[
tarped]

[
4]
Dazomet
(
400
kg/
ha)
[

untarped

[
5]
Pic­
chlor
(
400
kg/
ha)
[
tarped]

[
6]
Chloropicrin
(
340
kg/
ha)

[
tarped]

[
7]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

1st
year
crop:

[
1]
=[
2]

[
3]
 
64/
m2
[
4]
 
99/
m2
[
5]
+
11/
m2
[
6]
+
19/
m2
[
7]
 
88/
m2
2nd
year
crop:

[
1]
=[
2]

[
3]
 
83/
m2
[
4]
 
59/
m2
[
5]
 
59/
m2
[
6]
 
19/
m2
[
7]
Not
reported
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
1]
=[
2]

[
3]
13%

[
4]
21%

[
5]
2%
gain
[
6]
4%
gain
[
7]
18%

2nd
year
crop:

[
1]
=[
2]

[
3]
17%

[
4]
12%

[
5]
12%

[
6]
4%

[
7]
Not
reported
Consortium
(
CUE
03­
0021)
Comment:

[
1st
year
crop
reduction
with
dazomet
due
to
stunting,
and
reduced
root
volume]

[
2nd
year
crop
yield
reduction
due
to
stunting,
and
reduced
root
volume]
Not
reported
Not
reported
Weyerhaeuser
#
7,
1994­

1996
Page
47
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
1]
MB
(
390
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
Dazomet
(
400
kg/
ha)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[
tarped
&

solarized
3
mo.]

[
4]
Solarization
[
tarped,
solar.
3
mo]

[
5]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(
bare
fallow
from
harvest
Feb.,

1992
through
fumigation
and
tarp
(
3
mo.)
summer
1992
(#
Of
packable
seedlings
relative
to
MB
trt)

1st
year
crop:

[
2]
 
8/
m2
[
3]
 
5/
m2
[
4]
 
11/
m2
[
5]
=
[
1]

2nd
year
crop:

[
2]
 
8/
m2
[
3]
 
5/
m2
[
4]
 
11/
m2
[
5]
+
19/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
2]
2%

[
3]
1%

[
4]
2%

[
5]
no
loss
2nd
year
crop:

[
2]
2%

[
3]
1%

[
4]
2%

[
5]
4%
gain
[#
weeds/
m2
May,

1993;
dominant
species:
Amaranthaceae
spp.,

Mollugo
verticillata,

Euphorbia
supine]

[
1]
31b
[
2]
25b
[
3]
35b
[
4]
54ab
[
5]
104a
[#
weeds/
m2
June,

1993;
dominant
species:

Euphorbia
supine,

Digitaria
ciliaris,

Digitaria
ischaemun]

[
1]
13b
[
2]
10b
[
3]
17b
[
4]
28a
[
5]
36a
not
reported
Weyerhaeuser
#
8,
1992­

1995
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
Dazomet
(
400
kg/
ha)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[

untarped

[
4]
Control
1
(
1st
year
crop
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
19/
m2
[
3]
 
35/
m2
[
4]
 
5/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
4%

[
3]
7%

[
4]
1%
Consortium
(
CUE
03­
0021)
Comment:

Short
trees
and
poor
root
structure
were
main
cull
factors
Not
reported
Not
reported
Weyerhaeuser
#
9,
1994­

1995
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
8
kg/
ha)

[
2]
1,3­
D
(
260
kg/
ha)
+

chloropicrin
(
140
kg/
ha)

[
3]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
240
kg/
ha)

[
tarped]

[
4]
Dazomet
(
400
kg/
ha)[
tarped]

[
5]
Dazomet
(
400
kg/
ha)[
untarped]

[
6]
Chloropicrin
(
340
kg/
ha)

[
tarped]

[
7]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt
[
1])

1st
year
crop:

[
2]
 
40/
m2
[
3]
 
8/
m2
[
4]
+
3/
m2
[
5]
 
29/
m2
[
6]
 
13/
m2
[
7]
 
46/
m2
2nd
year
crop:

[
2]
 
3/
m2
[
3]
 
3/
m2
[
4]
+
3/
m2
[
5]
Not
reported
[
6]
+
3/
m2
[
7]
Not
reported
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
2]
8%

[
3]
2%

[
4]
no
loss
[
5]
6%

[
6]
3%

[
7]
10%

2nd
year
crop:

[
2]
No
loss
[
3]
No
loss
[
4]
No
loss
[
5]
Not
reported
[
6]
No
loss
[
7]
Not
reported
1st
year
crop:

Culls
were
short
with
small
diameters
2nd
year
crop:

Study
was
suspended
due
to
high
nutsedge
populations
Not
reported
Not
reported
Weyerhaeuser
#
10,
1994­

1996
Page
48
TABLE
16.1.
B:
EFFECTIVENESS
OF
ALTERNATIVES
 
DISEASE
Research
Results
for
Disease
(
Fusarium,
Pythium,
Rhizoctonia)
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Stand
density,

seedlings/
m2
(
fumigation
Sept.
1986,
seeding
Oct.,

1986)

Treatment
#
Trials
Yield
Percent
Survival
Average
Yield
Post
Emergence
(
per
m2)
Percent
Healthy
Root
Tips
(
1
year
old
seedlings)
May
1987
Sept
1987
Citation
Number
[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
196
kg/
ha)

[
3]
MB
(
392
kg/
ha]

[
4]
MB
(
263
kg/
ha)
+

chloropicrin
(
65
kg/
ha)

[
5]
MB
(
130
kg/
ha)
+

chloropicrin
(
131
kg/
ha)

[
6]
Dazomet
(
280
kg/
ha)

[
7]
Captan
(
6
kg/
ha)
[
soil
drench]

[
8]
Thiram
(
38
g/
kg
seed)

[
seed
trt.]

[
9]
Captan
(
6
kg/
ha)
[
soil
drench]
+
thiram
(
38
g/
kg
seed)
[
seed
trt.]

[
10]
Silica
sand
(
overlay
seeds)
6
reps
(
w/
white
pine
in
WI)
[
Yield
per
m2
at
seedling
emergence,
based
on
survival
from
damping­
off
diseases,

calculated
rate
of
720
seedlings/
m2
at
seeding
rate
of
14
g
seed/
m2]

[
1]
496b
[
2]
550a
[
3]
570a
[
4]
566a
[
5]
564a
[
6]
522ab
[
7]
474b
[
8]
404c
[
9]
408c
[
10]
366c
Percent
survival
from
dampingoff
at
seedling
emergence
[
1]
69%
ab
[
2]
76%
a
[
3]
79%
a
[
4]
79%
a
[
5]
78%
a
[
6]
73%
a
[
7]
66%
ab
[
8]
57%
c
[
9]
57%
c
[
10]
51%
c
[
Yield
per
m2
after
seedling
emergence
based
on
survival
from
damping­
off
diseases
at
cotyledon
or
primary
needle
stage]

[
1]
592d
[
2]
702a
[
3]
694ab
[
4]
710a
[
5]
682abc
[
6]
686ab
[
7]
580d
[
8]
646c
[
9]
670abc
[
10]
662bc
[
1]
20%
c
[
2]
55%
ab
[
3]
68%
a
[
4]
72%
a
[
5]
76%
a
[
6]
31%
bc
[
7]
8%
c
[
8]
18%
c
[
9]
16%
c
[
10]
38%
bc
[
1]
464
[
2]
464
[
3]
464
[
4]
464
[
5]
464
[
6]
464
[
7]
320
[
8]
360
[
9]
360
[
10]
320
[
1]
110
[
2]
464
[
3]
464
[
4]
464
[
5]
464
[
6]
250
[
7]
106
[
8]
106
[
9]
106
[
10]
80
Enebak
et
al.,
1990
[
1]
Control
(
no
fumigation)

[
2]
MB
(
266
kg/
ha)
+

chloropicrin
(
130
kg/
ha)

[
3]
Metam
sodium
(
485
kg/
ha)

[
4]
Dazomet
(
400
kg/
ha)
4
reps
(
w/

pon­
derosa
pine
in
Pacific
NW)
[%
Mortality
due
to
Pythium,

and
Fusarium,
during
1st
growing
season]

[
1]
25%
a
[
2]
12%
b
[
3]
8%
b
[
4]
10%
b
[#
Of
seedlings
after
1st
growing
season]
(
per
m2)

[
1]
150a
[
2]
300b
[
3]
343b
[
4]
300b
Campbell
and
Kelpsas,

1988
[
1]
Control
(
no
fumigation)

[
2]
MB
(
266
kg/
ha)
+

chloropicrin
(
130
kg/
ha)

[
3]
MB
(
580
kg/
ha)
+

chloropicrin
(
285
kg/
ha)

[
4]
Dazomet
(
400
kg/
ha)
1
(
with
Douglas
fir)
1st
crop
year:

Seedlings/
m2
[
1]
429
[
2]
482
[
3]
455
[
4]
469
Weyerhaeuser
#
3,
1984­

1987
Page
49
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
Yield
loss
estimates
for
the
forest
nursery
sector
do
not
adequately
address
the
even
greater
effect
that
less
than
optimally
healthy
seedlings
have
on
subsequent
forest
plantings.
Forests
planted
with
undersized
seedlings
will
have
reduced
survival
and
slowed
growth
if
initial
seedling
health
is
compromised.
No
alternatives
have
been
sufficiently
tested
to
currently
substitute
for
MB.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
(
COMPARED
TO
MB)
BEST
ESTIMATE
OF
YIELD
LOSS
Chloropicrin
Fungi
+
3%
to
 
13%
5%
loss
Metam­
sodium
Weeds
+
3%
to
 
13%
5%
loss
Dazomet
Weeds
+
3%
to
 
13%
5%
loss
1,3­
D
Nematodes,
Weeds
+
3%
to
 
13%
5%
loss
Metam­
sodium
+
chloropicrin
Weeds,
Fungi
+
5%
to
 
8%
0­
3%
loss
1,3­
D
+
chloropicrin
Weeds,
Fungi
+
5%
to
 
8%
0­
3%
loss
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
3­
5%

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

Combinations
of
chemicals,
such
as
chloropicrin
in
addition
to
metam­
sodium
or
1,3­
D
appear
to
be
effective
for
some
nurseries
in
reducing
pest
infestations,
including
some
weed
problems
(
e.
g.,
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96).
Combinations
of
these
compounds
and
application
techniques
(
such
as
deep
injection)
to
achieve
the
same
pest
control
efficiencies
as
MB
are
being
studied.
So
far,
none
have
proven
cost
effective
and
have
generally
resulted
in
an
increased
input
of
other
pest
control
products.
These
products
because
of
their
physical
limitations
(
e.
g.,
low
vapor
pressure
of
metam­
sodium)
are
criticized
by
nursery
managers
mostly
for
their
lack
of
consistency,
thus
individual
research
trials
are
said
to
be
skewed
since
large­
scale
production
will
result
in
more
glaring
differences
between
MB
and
many
alternatives.
As
previously
mentioned,
1,3­
D
may
be
restricted
due
to
legal
or
geological
factors.
In
addition,
economic
issues
may
have
an
impact
on
overall
acceptability
of
these
alternatives
for
the
forest
seedling
nursery
sector.
Tests
are
being
conducted
on
numerous
crops
on
methyl
iodide,
although
it
has
yet
to
complete
the
registration
process,
and
it
is
unknown
when
registration
might
occur.

The
use
of
virtually
impermeable
film
(
VIF)
may
offer
a
means
of
reducing
MB
use
rates
while
maintaining
efficacy
and
production
goals
.
Work
is
being
conducted
to
determine
if
this
type
of
film
is
feasible
in
the
U.
S.
from
a
technical
standpoint
(
e.
g.,
does
it
hold
up
physically
in
field
conditions?
can
it
be
glued
to
acceptable
specifications?,
etc.)
and
economically
feasible
(
e.
g.,
cost
of
material,
cost
of
application).
However,
the
efficacy
of
VIF
for
U.
S.
agriculture
may
be
different
than
that
for
Europe
(
Federal
Register,
1998;
).
There
is
also
interest
in
examining
the
effects
of
certain
fertilizer
salts
(
e.
g.,
ammonium
thiosulfate,
see
Gan
and
Yates,
1998),
which
may
act
as
barriers
to
volatile
compounds
(
e.
g.,
1,3­
D,
MB)
when
applied
to
the
soil
surface,
thus
reducing
emissions
and
improving
efficacy.
Also,
reduction
in
MB
formulations
from
98:
2
to
Page
50
50:
50,
reduction
in
use
rate,
and
additional
time
with
cover
crop
to
reduce
weed
populations,
and
additional
use
of
glyphosate
to
reduce
weeds
might
reduce
the
overall
use
of
MB.
Experiments
have
indicated
that
some
soil
amendments
can
reduce
adverse
growth
effects
of
some
alternatives
(
e.
g.,
dazomet).
Work
in
Wisconsin
(
Enebak
et
al.,
1990;
Iver,
?)
suggested
that
white
pine
seedlings
subjected
to
dazomet
but
supplied
with
various
nutrients,
could
reduce
chlorosis
sometimes
observed
in
dazomet
treated
beds.
Large
scale
trials
will
be
necessary
to
confirm
this
effect.
For
disease
control,
studies
(
James
et
al.,
1997)
comparing
cultivation
practices,
such
as
till
vs.
no­
till
and
organic
amendments
indicate
that
effects
vary
according
to
the
species
grown,
thus
each
nursery
may
have
to
consider
alternatives
with
species
and
local
environment
in
mind,
unlike
the
more
consistent
effects
of
MB
fumigation.
Promising
results
in
disease
management
have
been
observed
(
Lantz,
1997;
Stone
et
al.,
1998)
with
organic
amendments,
but
successful
weed
management
has
not
been
adequately
achieved.

A
major
limitation
with
respect
to
the
aforementioned
research
is
the
general
lack
of
information
to
accurately
assess
pest
control
in
large
scale,
compared
to
small
research
trials,
including
issues
such
as
outgassing
damage
as
a
result
of
metam­
sodium
applications
(
e.
g.,
see
Application
Request
Packages).
Technical
difficulties
in
extrapolating
research
scale
plots
to
"
real
world"
applications
make
it
difficult
to
transition
away
from
MB
and
calculate
implementation
timelines,
since
production
consistency
is
frequently
compromised.
As
discussed
in
Section
23
below,
considerable
research
dollars
have
been
spent
on
research
of
MB
alternatives.

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

Containerization
is
used
for
seedling
production
in
a
limited
capacity
throughout
the
forest
nursery
sector.
Its
use
is
limited,
however,
to
special
circumstances
where
species
survival
or
an
extreme
genetic
value
of
the
planting
stock
makes
it
economically
feasible.
Recent
surveys
indicate
that
of
the
1.2
billion
seedlings
grown
in
the
southeastern
U.
S.
in
the
2002­
2003
season,
fewer
than
5%
were
produced
in
containers
(
Mc
Nabb
and
VandersSchaaf,
2003)
An
estimate
can
be
made
that
fewer
than
10%
of
the
national
forest
seedling
production
is
containerized.
Containerization
is
mandated
by
species
or
site
requirements.
An
example
is
the
use
of
containerized
seedlings
to
reforest
mine­
spoil
sites
which
are
extremely
harsh
edaphic
environments
requiring
a
soil
plug
system
to
obtain
adequate
seedling
survival
(
Lowerts,
2003).

A
massive
infrastructure
investment
would
be
necessary
to
shift
the
national
production
to
containerization.
According
to
Darrow
(
2002)
(
also
see
Appendix
A)
the
transition
from
bed
to
container
production
would
require
additional
capital
and
operating
costs.
Investment
would
be
necessary
for
the
purchases
of
greenhouses,
container
filling
and
sowing
machines,
containers,
outdoor
holding
areas,
fertigation
systems,
and
new
seedling
transport
systems
both
in
the
nursery
and
in
the
field.
Not
all
sectors
of
seedling
production
would
have
this
capital
available
to
them.
It
is
likely
that
smaller
bareroot
operations
would
close
and
many
state­
run
nurseries
would
opt
to
close
rather
than
budget
state
funds
for
such
a
significant
capital
outlay.
There
is
little
doubt
that
seedling
prices
would
increase
by
at
least
250%
and
may
go
up
to
400%.
A
typical
one
year
old
bareroot
seedling
currently
sells
for
$
0.04
each,
while
the
typical
container
Page
51
seedling
of
the
same
species
begins
at
$
0.12
each.
In
addition
to
an
increase
in
seedling
costs,
there
are
significant
cost
increases
associated
with
transportation
and
planting
container
stock.
Fewer
container
plants
can
be
transported
per
truck
and
fewer
seedlings
can
be
carried
by
individual
tree
planters.
More
trucks
and
more
fuel
are
needed
to
get
seedlings
to
the
planting
site
and
more
labor
(
or
time)
are
needed
to
plant
a
given
area.
One
study
found
that
daily
production
decreased
from
9.7
ha
per
day
with
bareroot
seedlings
to
7.3
ha
per
day
with
containerized
seedlings,
a
decrease
of
25%,
without
increasing
planting
crew
size
(
Lowerts,
2003).

The
inevitable
result
of
containerization
would
be
a
significant
increase
in
reforestation
costs
and
a
decrease
in
the
rate
of
reforestation.
According
to
the
U.
S.
Forest
Service,
48%
of
all
reforestation
in
the
U.
S.
is
done
on
non­
industrial
private
lands,
an
additional
42%
is
done
on
industrial
lands,
and
only
10%
on
government
lands
(
Moulton
and
Hernandez,
2000).
It
is
well
established
that
non­
industrial
forest
owners
are
very
sensitive
to
reforestation
costs,
decreasing
their
investment
in
direct
proportion
to
increasing
costs
(
Hardie
and
Parks,
1991;
Royer,
1987).
Given
the
importance
of
non­
industrial
owners
on
the
general
timber
supply,
a
reduction
in
reforestation
efforts
by
this
group
may
have
serious
long­
term
negative
impacts
on
the
sustainability
of
the
forest
economy.
Industrial
owners
will
also
be
negatively
impacted
by
increased
reforestation
costs
as
raw
material
costs
will
increase
(
typically
about
40­
60%
of
the
cost
of
final
fiber
products),
impacting
the
competitiveness
of
their
industry.

Conclusion:
The
infrastructure
investment
necessary
for
containerization
is
enormous
and
would
probably
force
many
nurseries
out
of
business.
Seedling
production
costs
would
increase,
resulting
in
seedling
price
increases
of
over
250%.
New
transportation
and
planting
systems
would
have
to
be
adopted.
Reforestation
costs
would
go
up
significantly
and
probably
result
in
fewer
non­
industrial
forest
owners
reforesting
after
harvest.
The
potential
long­
term
effect
of
these
changes
on
the
forestry
economy
is
enormous.
Overall,
containerization
would
result
in
a
significant
increase
in
seedling
production,
transportation,
and
planting
costs
and
would
most
likely
decrease
reforestation
rates.

SUMMARY
OF
TECHNICAL
FEASIBILITY
Combinations
of
chemicals,
such
as
chloropicrin
in
addition
to
metam­
sodium
or
1,3­
D
appear
to
be
effective
for
some
nurseries
in
reducing
pest
infestations,
including
some
weed
problems
(
e.
g.,
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96).
However,
these
products
because
of
their
physical
limitations
(
e.
g.,
low
vapor
pressure
of
metam­
sodium)
are
criticized
by
nursery
managers
for
their
lack
of
consistency
and
outgassing
problems
of
seedling
destruction.
As
a
result,
individual
research
trials
are
said
to
be
skewed,
since
large­
scale
production
will
result
in
more
glaring
differences
between
MB
and
many
alternatives.
As
previously
mentioned,
1,3­
D
may
be
restricted
due
to
legal
or
geological
factors.
In
addition,
economic
issues
such
as
application
costs
may
have
an
impact
on
overall
acceptability
of
these
alternatives
for
the
forest
seedling
nursery
sector.
Page
52
Alternatives
of
chemical
combinations
with
chloropicrin
and
1,3­
D,
dazomet,
or
metam
sodium
can
be
feasible
alternatives
to
MB
in
managing
some
common
fungal
pests,
such
as
rot
diseases
(
e.
g.,
Fusarium,
Pythium,
and
Phytophthora
and
other
fungal
pathogens)
(
e.
g.,
Fraedrich
and
Dwinell,
1998;
James
et
al.,
2001).
Overall,
however,
they
have
not
been
successful
in
effectively
controlling
the
major
pest
problem
of
nurseries,
nutsedge
(
Fraedrich
and
Dwinell,
1998).
In
nurseries
that
have
a
significant
weed
(
usually
nutsedge)
problem,
dazomet
and
metam­
sodium
have
not
been
consistently
effective
in
acceptably
managing
the
pest
[
e.
g.,
compare
results
(
Carey,
1996;
Carey,
1994)
with
(
Weyerhaeuser
#
8,
1992­
95)].
1,3­
dichloropropene
(
1,3­
D)
is
an
effective
nematicide
that
may
have
some
efficacy
against
plant
pathogens,
but
its
efficacy
for
weed
management
is
unclear,
and
its
overall
use
may
be
limited
by
local
legal
restrictions
and
pest­
free
permit
requirements
(
e.
g.,
Carey,
1996;
Carey,
1994;
Weyerhaeuser
#
10,
1994­
96).

Statistically
analyzed
trials
measuring
quantity
and
quality
losses
due
to
specific
pests
(
e.
g.,
weeds
or
pathogens)
are
not
readily
available.
More
commonly
found
are
trials
indicating
overall
yield
(
and
sometimes
quality
assessments),
allowing
a
comparison
of
treatments
based
on
yield,
but
making
it
difficult
to
ascribe
losses
to
particular
pests.
This
is
particularly
a
problem
since
the
numerous
forest
seedling
nurseries
can
experience
various
problems
unique
to
the
combination
of
climate,
soil,
seedling
species,
market
forces,
and
customer
base
(
e.
g.,
public
vs.
private
nursery,
or
commercial
vs.
recreational
end
uses).
Overall
yield
losses
with
the
best
alternatives,
compared
to
MB,
were
estimated
at
0­
3%
based
on
research
data.
In
estimating
the
yield
of
alternatives
in
comparison
to
MB,
it
should
be
remembered
that
these
figures
are
for
the
general
case,
and
individual
nurseries
will
likely
experience
greater
or
lesser
efficacy
with
a
given
treatment,
depending
on
soil,
climate,
production
practices,
market
requirements,
species
of
seedling,
etc.
The
yield
estimates
listed
in
Table
C.
1
are
based
on
research
results
described
in
Section
16.
Quality
factors
are
as
important
in
this
industry
as
yield,
and
may
affect
the
efficacy
of
a
given
alternative
beyond
considerations
of
yield
alone
(
e.
g.,
"
Percent
`
Healthy
Root
Tips'"
in
Table
16.1B,
Enebak
et
al.,
1990).

Larger
seedling
size
and
improved
seedling
vigor
translate
to
improved
reforestation
success
and
increased
growth
rate
of
young
plantations.
This
positive
contribution
to
reforestation
is
well
documented
for
seedlings
produced
in
MB
fumigated
soil.
Increases
in
seedling
size
and
quality
resulting
from
fumigation
with
MB
alternatives
have
been
highly
variable
at
best.
The
long­
term
impact
on
reforestation
success
with
alternatives
is
not
known.
An
important
factor
that
should
be
considered
for
this
industry
is
the
long­
term
implication
associated
with
forest
growth
and
health
over
a
20­
40
year
period
of
forest
life.
Seedling
quality
has
been
highly
correlated
with
productive
and
healthy
forests
impacting
both
commercial
and
public
interests.
The
forest
seedlings
sector
has
made
a
strong
case
that
MB
is
currently
critical
for
production
of
healthy,
high
quality
(
and
high
value)
forest
seedlings
in
many
nursery
situations.

The
industry
is
continuing
to
research
alternatives
and
test
improved
chemical
application
technologies
to
increase
the
efficacy
of
some
of
the
most
viable
alternatives.
MB
is
considered
to
be
critical
in
the
short­
term,
with
chemical
alternatives
the
likely
long­
term
solution.
Nonchemical
and
biological
control
are
not
advanced
enough
to
rely
on
in
the
foreseeable
future.
Research
with
organic
and
inorganic
soil
amendments
(
Fraedrich
and
Dwinell,
1998;
James
et
al.,
1997;
James
et
al.,
2001;
Lantz,
1997;
Stone
et
al.,
1998)
have
had
some
successes
under
Page
53
certain
conditions,
but
the
effects
appear
to
be
variable
depending
on
the
nursery
locations
and
species
of
seedlings.

PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
The
Forest
Seedlings
sector
has
reduced
its
MB
consumption
through
several
techniques
developed
over
the
past
several
years.
First,
the
sector
has
incorporated
the
use
of
high­
density
polyethylene
(
HDPE)
tarping
material
that
has
helped
increase
fumigation
efficiencies
and
reduced
application
rates.
HDPE
increases
MB
soil
residence
time,
increasing
efficiency
and
reducing
application
rates.
VIF
would
be
considered
a
feasible
means
of
further
reducing
emissions
if
a
method
could
be
developed
to
efficiently
glue
overlapping
sheets
of
VIF
film.
VIF
film
becomes
impractical
if
adjacent
overlapping
sheets
cannot
be
glued.
In
addition,
there
is
a
problem
with
film
breakage
during
application.
Hopefully,
current
research
underway
can
eliminate
both
these
problems.

Second,
MB
fumigation
in
the
forest
seedlings
sector
increasingly
has
been
made
using
deep
injection
that
places
the
material
deeper
into
the
soil
than
previously.
Deeper
placement
contributes
to
longer
residence
time
in
the
soil
and
greater
application
efficiency.
This
has
been
accomplished
at
considerable
capital
investment
on
the
part
of
applicators.

Third,
forest
seedlings
nurseries
have
increased
the
percentage
of
chloropicrin
in
fumigation
mixtures.
While
98%
MB
and
2%
chloropicrin
was
the
most
widely
used
compound
a
few
years
ago,
a
66:
33
ratio
is
now
more
common.
Some
efficiency
in
weed
control
has
been
sacrificed
by
this
change
in
procedure,
however,
and
higher
concentrations
of
chloropicrin
become
increasingly
less
satisfactory
as
weed
pressure,
particularly
nutsedge,
increases.

Fourth,
forest
seedlings
nurseries
routinely
use
integrated
pest
management
(
IPM)
techniques
to
develop
their
fumigation
strategies.
Nurseries
fumigate
only
once
every
four
years,
growing
two
seedling
crops
and
two
cover
crops
from
one
fumigation.
Soil
organic
matter
content,
weed
populations,
and
disease
incidence
are
carefully
monitored
during
the
crop
rotation
to
ensure
the
correct
timing
and
rate
of
MB
application.
Monitoring
pest
populations
is
an
integral
part
of
an
IPM
approach
and
helps
ensure
MB
efficiency.
Page
54
Finally,
the
forest
seedlings
sector
has
devoted
considerable
resources
to
investigating
MB
alternatives
and
continues
to
search
for
methodologies
to
reduce
MB
use
rates.
The
industry
is
committed
to
continuing
research
to
address
the
issue
of
improved
consistency
(
especially
for
nutsedge
control)
with
available
chemical
alternatives
and
to
test
new
products
in
order
to
determine
efficacy
and
obtain
the
information
necessary
for
U.
S.
registrations.

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.
No
trend
was
identified.
No
trend
was
identified.
No
trend
was
identified.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
high
barrier
films.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
lower
MB
dosage
rates.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
increasing
the
chloropicrin
percentage
in
formulations.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.
OTHER
MEASURES
(
please
describe)
Unknown
Unknown
Unknown
Unknown
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS:

As
stated
previously,
emission
reduction
technologies
are
being
addressed
by
the
sector
(
e.
g.,
VIF,
reduced
MB
component
of
formulation,
use
of
advanced
delivery
techniques
to
make
alternative
chemicals
more
effective
at
deeper
soil
levels).
Page
55
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
REGION
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
U.
S.
$/
ha)
COST
IN
YEAR
2
(
U.
S.
$/
ha)
COST
IN
YEAR
3
(
U.
S.
$/
ha)

Methyl
Bromide
100
$
17,819.99
$
17,819.99
$
17,819.99
Dazomet
95
$
20,750.22
$
20,750.22
$
20,750.22
1,3­
D
+
Chloropicrin
97
$
19,865.27
$
19,865.27
$
19,865.27
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Metam
Sodium
+
Chloropicrin
97
$
20,258.16
$
20,258.16
$
20,258.16
Methyl
Bromide
100
$
15,198.04
$
15,198.04
$
15,198.04
Dazomet
95
$
17,834.62
$
17,834.62
$
17,834.62
1,3­
D
+
Chloropicrin
97
$
17,890.23
$
17,890.23
$
17,890.23
REGION
B
­
INTERNATIONAL
PAPER
Metam
Sodium
+
Chloropicrin
97
$
18,199.16
$
18,199.16
$
18,199.16
Methyl
Bromide
100
$
46,233.38
$
46,233.38
$
46,233.38
Dazomet
95
$
53,883.26
$
53,883.26
$
53,883.26
1,3­
D
+
Chloropicrin
97
$
53,883.26
$
53,883.26
$
53,883.26
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Metam
Sodium
+
Chloropicrin
97
$
53,883.26
$
53,883.26
$
53,883.26
Methyl
Bromide
100
$
15,509.50
$
15,509.50
$
15,509.50
Dazomet
95
$
16,421.86
$
16,421.86
$
16,421.86
1,3­
D
+
Chloropicrin
97
$
16,400.54
$
16,400.54
$
16,400.54
REGION
D
­
WEYERHAEUSER
SOUTH
Metam
Sodium
+
Chloropicrin
97
$
16,320.23
$
16,320.23
$
16,320.23
Methyl
Bromide
100
$
9,445.43
$
9,445.43
$
9,445.43
Dazomet
95
$
11,250.12
$
11,250.12
$
11,250.12
1,3­
D
+
Chloropicrin
97
$
11,250.12
$
11,250.12
$
11,250.12
REGION
E
­
WEYERHAEUSER
WEST
Metam
Sodium
+
Chloropicrin
97
$
9,844.09
$
9,844.09
$
9,844.09
Methyl
Bromide
100
$
23,535.53
$
23,535.53
$
23,535.53
Dazomet
95
$
30,009.19
$
30,009.19
$
30,009.19
1,3­
D
+
Chloropicrin
97
$
29,077.80
$
29,077.80
$
29,077.80
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
Metam
Sodium
+
Chloropicrin
97
$
29,077.80
$
29,077.80
$
29,077.80
Methyl
Bromide
100
$
88,948.96
$
88,948.96
$
88,948.96
Dazomet
95
$
89,095.00
$
89,095.00
$
89,095.00
1,3­
D
+
Chloropicrin
97
$
91,778.48
$
91,778.48
$
91,778.48
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
Metam
Sodium
+
Chloropicrin
97
$
88,919.97
$
88,919.97
$
88,919.97
Methyl
Bromide
100
$
12,195.67
$
12,195.67
$
12,195.67
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
Various
Alternatives*
95
$
52,172.45
$
52,172.45
$
52,172.45
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.
**
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.
Page
56
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.
$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.
$/
ha)
Methyl
Bromide
$
33,681.79
$
15,861.80
Dazomet
$
31,997.70
$
11,247.48
1,3­
D
+
Chloropicrin
$
32,671.34
$
12,806.07
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Metam
Sodium
+
Chloropicrin
$
32,671.34
$
12,413.18
Methyl
Bromide
$
33,410.60
$
18,212.57
Dazomet
$
31,740.07
$
13,905.45
1,3­
D
+
Chloropicrin
$
32,408.29
$
14,518.06
REGION
B
­
INTERNATIONAL
PAPER
Metam
Sodium
+
Chloropicrin
$
32,408.29
$
14,209.13
Methyl
Bromide
$
216,389.24
$
170,155.86
Dazomet
$
205,569.78
$
151,686.52
1,3­
D
+
Chloropicrin
$
209,897.56
$
156,014.30
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Metam
Sodium
+
Chloropicrin
$
209,897.56
$
156,014.30
Methyl
Bromide
$
27,289.61
$
11,780.11
Dazomet
$
25,925.13
$
9,503.28
1,3­
D
+
Chloropicrin
$
26,470.92
$
10,070.38
REGION
D
­
WEYERHAEUSER
SOUTH
Metam
Sodium
+
Chloropicrin
$
26,470.92
$
10,150.69
Methyl
Bromide
$
18,790.12
$
9,344.69
Dazomet
$
17,850.62
$
6,600.50
1,3­
D
+
Chloropicrin
$
18,226.42
$
6,976.30
REGION
E
­
WEYERHAEUSER
WEST
Metam
Sodium
+
Chloropicrin
$
18,226.42
$
8,382.33
Methyl
Bromide
$
33,486.87
$
9,951.34
Dazomet
$
31,812.52
$
1,803.33
1,3­
D
+
Chloropicrin
$
32,482.26
$
3,404.46
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
Metam
Sodium
+
Chloropicrin
$
32,482.26
$
3,404.46
Methyl
Bromide
$
105,266.80
$
16,317.84
Dazomet
$
100,003.46
$
10,908.46
1,3­
D
+
Chloropicrin
$
102,108.80
$
10,330.31
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
Metam
Sodium
+
Chloropicrin
$
102,108.80
$
13,188.83
Methyl
Bromide
$
139,837.54
$
101,527.78
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
Various
Alternatives*
$
132,945.66
$
73,169.07
*
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.
Page
57
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
YIELD
LOSS
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
Pine
Spp
779,617
740,636
756,228
756,228
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.04
$
0.04
$
0.04
$
0.04
Gross
Revenue
per
Proportion
(
88%)
$
27,442.51
$
26,070.39
$
26,619.24
$
26,619.24
Yield
(
seedling)
per
Hectare
Longleaf
Pine
423,785
402,596
411,072
411,072
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.06
$
0.06
$
0.06
$
0.06
Gross
Revenue
per
Proportion
(
3%)
$
762.81
$
724.67
$
739.93
$
739.93
Yield
(
seedling)
per
Hectare
Hardwood
243,399
231,229
236,097
236,097
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.25
$
0.25
$
0.25
$
0.25
Gross
Revenue
per
Proportion
(
9%)
$
5,476.47
$
5,202.64
$
5,312.17
$
5,312.17
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
33,681.79
$
31,997.70
$
32,671.34
$
32,671.34
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
17,819.99
$
20,750.22
$
19,865.27
$
20,258.16
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
15,861.80
$
11,247.48
$
12,806.07
$
12,413.18
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
4,614.32
$
3,055.73
$
3,448.63
2.
Loss
per
Kilogram
of
MB
(
U.
S.
$)
$
0
$
49.21
$
32.59
$
36.78
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
14%
9%
10%

4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
29%
19%
22%

REGION
B
­
INTERNATIONAL
PAPER
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
B
­
INTERNATIONAL
PAPER
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
812,976
772,327
788,587
788,587
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.04
$
0.04
$
0.04
$
0.04
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
33,410.60
$
31,740.07
$
32,408.29
$
32,408.29
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
15,198.04
$
17,834.62
$
17,890.23
$
18,199.16
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
18,212.57
$
13,905.45
$
14,518.06
$
14,209.13
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
4,307.11
$
3,694.51
$
4,003.44
2.
Loss
per
Kilogram
of
MB
(
U.
S.
$)
$
0
$
68.94
$
59.14
$
64.08
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
13%
11%
12%

4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
24%
20%
22%
Page
58
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
­
Tree
281,507
267,431
273,062
273,062
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.63
$
0.63
$
0.63
$
0.63
Gross
Revenue
per
Proportion
(
82.5%)
$
145,539.00
$
138,262.05
$
141,172.83
$
141,172.83
Yield
(
shrub)
per
Hectare
­
Shrub
Seedling
259,032
246,081
251,261
251,261
*
Price
per
Unit
(
U.
S.
$/
shrub)
$
0.37
$
0.37
$
0.37
$
0.37
Gross
Revenue
per
Proportion
(
12.5%)
$
11,872.30
$
11,278.69
$
11,516.14
$
11,516.14
Yield
per
Hectare
­
Forb
Root
Stock
369,683
351,199
358,592
358,592
*
Price
per
Unit
(
U.
S.
$/
root
stock)
$
0.04
$
0.04
$
0.04
$
0.04
Gross
Revenue
per
Proportion
(
5%)
$
739.37
$
702.40
$
717.18
$
717.18
Yield
(
kilograms)
per
Hectare
­
Forb
Seed
669
635
649
649
*
Price
per
Unit
(
U.
S.
$/
kilogram)
$
87.08
$
87.08
$
87.08
$
87.08
Gross
Revenue
per
Proportion
$
58,238.57
$
55,326.64
$
56,491.41
$
56,491.41
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
216,389.24
$
205,569.78
$
209,897.56
$
209,897.56
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
46,233.38
$
53,883.26
$
53,883.26
$
53,883.26
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
170,155.86
$
151,686.52
$
156,014.30
$
156,014.30
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S
$)
$
0
$
18,469.34
$
14,141.56
$
14,141.56
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
70.12
$
53.69
$
53.69
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
9%
7%
7%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
11%
8%
8%

REGION
D
­
WEYERHAEUSER
SOUTH
­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
D
­
WEYERHAEUSER
SOUTH
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
586,621
557,290
569,022
569,022
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.05
$
0.05
$
0.05
$
0.05
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
27,289.61
$
25,925.13
$
26,470.92
$
26,470.92
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
15,509.50
$
16,421.86
$
16,400.54
$
16,320.23
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
11,780.11
$
9,503.28
$
10,070.38
$
10,150.69
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
2,276.84
$
1,709.73
$
1,629.42
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
27.08
$
20.34
$
19.38
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
8%
6%
6%

4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
19%
15%
14%
Page
59
REGION
E
­
WEYERHAEUSER
WEST
­
TABLE
E.
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
E
­
WEYERHAEUSER
WEST
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
(
seedling)
per
Hectare
62,634
59,502
60,755
60,755
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.30
$
0.30
$
0.30
$
0.30
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
18,790.12
$
17,850.62
$
18,226.42
$
18,226.42
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
9,445.43
$
11,250.12
$
11,250.12
$
9,844.09
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
9,344.69
$
6,600.50
$
6,976.30
$
8,382.33
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
2,744.20
$
2,368.40
$
962.37
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
31.32
$
27.03
$
10.98
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
15%
13%
5%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
29%
25%
10%

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
E.
6:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
per
Hectare
Conifer
Seedling
1­
0
247,105
234,750
239,692
239,692
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.20
$
0.20
$
0.20
$
0.20
Gross
Revenue
per
Proportion
(
8%)
$
3,887.79
$
3,693.40
$
3,771.15
$
3,771.15
Yield
per
Hectare
Conifer
Seedling
2­
0
185,329
176,062
179,769
179,769
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.20
$
0.20
$
0.20
$
0.20
Gross
Revenue
per
Proportion
(
4%)
$
1,457.92
$
1,385.02
$
1,414.18
$
1,414.18
Yield
per
Hectare
Conifer
Seedling
3­
0
123,553
117,375
119,846
119,846
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.28
$
0.28
$
0.28
$
0.28
Gross
Revenue
per
Proportion
(
14%)
$
4,900.92
$
4,655.87
$
4,753.89
$
4,753.89
Yield
per
Hectare
Deciduous
Tree
Seedling
1­
0
123,553
117,375
119,846
119,846
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.25
$
0.25
$
0.25
$
0.25
Gross
Revenue
per
Proportion
(
55%)
$
16,988.48
$
16,139.06
$
16,478.83
$
16,478.83
Yield
per
Hectare
Deciduous
Tree
Seedling
2­
0
123,553
117,375
119,846
119,846
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.31
$
0.31
$
0.31
$
0.31
Gross
Revenue
per
Proportion
(
9%)
$
3,410.05
$
3,239.55
$
3,307.75
$
3,307.75
Yield
per
Hectare
Decid.
Shrub
Seedling
1­
0
123,553
117,375
119,846
119,846
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.23
$
0.23
$
0.23
$
0.23
Gross
Revenue
per
Proportion
(
10%)
$
2,841.71
$
2,699.62
$
2,756.46
$
2,756.46
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
33,486.87
$
31,812.52
$
32,482.26
$
32,482.26
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
23,535.53
$
30,009.19
$
29,077.80
$
29,077.80
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
9,951.34
$
1,803.33
$
3,404.46
$
3,404.46
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
8,148.00
$
6,546.88
$
6,546.88
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
47.75
$
38.37
$
38.37
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
24%
20%
20%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
82%
66%
66%
Page
60
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
E.
7:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
G
­
Michigan
Seedling
Association
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
per
Hectare
Conifer
Seedlings
535,395
508,625
519,333
519,333
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.16
$
0.16
$
0.16
$
0.16
Gross
Revenue
per
Proportion
(
60%)
$
51,397.87
$
48,827.98
$
49,855.94
$
49,855.94
Yield
per
Hectare
Conifer
Transplants
74,132
70,425
71,908
71,908
*
Price
per
Unit
(
U.
S.
$/
transplants)
$
0.60
$
0.60
$
0.60
$
0.60
Gross
Revenue
per
Proportion
(
10%)
$
4,447.89
$
4,225.50
$
4,314.46
$
4,314.46
Yield
per
Hectare
Deciduous
Transplants
329,474
313,000
319,589
319,589
*
Price
per
Unit
(
U.
S.
$/
transplants)
$
0.50
$
0.50
$
0.50
$
0.50
Gross
Revenue
per
Proportion
(
30%)
$
49,421.03
$
46,949.98
$
47,938.40
$
47,938.40
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
105,266.80
$
100,003.46
$
102,108.80
$
102,108.80
­
Fixed
Costs
per
Hectare
(
U.
S.
$)
$
88,948.96
$
89,095.00
$
91,778.48
$
88,919.97
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
16,317.84
$
10,908.46
$
10,330.31
$
13,188.83
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
5,168.20
$
6,228.70
$
2,887.84
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
57.64
$
69.46
$
32.21
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
5%
6%
3%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
33%
37%
19%

REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
E.
8:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
H
­
Michigan
Herbaceous
Perennials
Methyl
Bromide
Various
Alternatives**
Yield
Loss
(%)
0%
5%
Yield
per
Hectare
Conifer
Seedlings
144,942
137,694
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.96
$
0.96
Gross
Revenue
per
Proportion
(
60%)
$
139,838
$
132,846
=
Operating
Cost
per
Hectare
(
U.
S.
$)
$
38,310
$
59,677
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
101,528
$
73,169
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
28,359
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
145
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
20%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
28%
**
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.

SUMMARY
OF
ECONOMIC
FEASIBILITY
An
economic
assessment
was
made
for
three
technically
feasible
in­
kind
(
chemical)
alternatives
for
the
forest
seedlings
sector:
dazomet,
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin.
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices.
Page
61
The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
Losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
Absolute
losses
per
hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
3)
Losses
per
kilogram
of
methyl
bromide
requested.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production
but
is
also
useful
for
structural
and
post­
harvest
uses.

(
4)
Losses
as
a
percent
of
net
cash
revenues.
We
define
net
cash
revenues
as
gross
revenues
minus
operating
costs.
This
is
a
very
good
indicator
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
owners
or
operators
of
an
enterprise.
However,
operating
costs
can
often
be
difficult
to
measure
and
verify.

(
5)
Changes
in
profit
margins.
We
define
profit
margin
to
be
profits
as
a
percentage
of
gross
revenues,
where
profits
are
gross
revenues
minus
all
fixed
and
operating
costs.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
forest
seedling
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

Economic
reviewers
analyzed
potential
economic
losses
from
using
dazomet,
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin
because
they
are
currently
considered
technically
feasible
alternatives
for
nursery
seedlings
production.

Total
losses
are
similar
for
both
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin.
Quantifiable
losses
originate
from
yield
losses
and
cost
increases.
Dazomet
has
slightly
higher
yield
losses
than
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin,
but
similar
treatment
costs.
Indirect
yield
losses
occurred
due
to
lengthening
of
the
production
cycle,
which
resulted
in
less
land
in
production
and
more
in
fallow
or
longer
time
for
seedlings
to
reach
appropriate
size.
Additional
losses
may
also
arise
due
to
a
shift
from
high
quality
Grade
#
1
seedlings
to
lower
quality
Grade
#
2,
which
causes
a
loss
of
about
30
percent
of
value,
and
more
seedlings
Page
62
that
must
be
culled.
Unfortunately,
data
were
lacking
to
measure
this
shift.
Thus,
total
losses
are
underestimated.

Tables
E.
1
~
E.
8
provides
a
summary
of
the
estimated
economic
losses.
A
measure
of
operating
profit
loss
may
not
be
completely
accurate
partly
because
many
nurseries
are
publicly
owned
and
seedling
prices
or
production
costs
are
subsidized.
Although
attempts
were
made
to
appropriately
value
the
seedlings
at
a
true
market
price,
losses
as
a
percentage
of
gross
revenues
and
of
net
cash
returns
should
be
viewed
with
caution.
Direct
yield
losses
are
similar
across
the
regions,
mainly
because
the
same
studies
were
used
to
predict
impacts.
The
range
of
losses
in
the
studies
is
rather
large
because
both
dazomet
and
metam­
sodium
provide
inconsistent
pest
control.
Indirect
losses
arising
from
shifts
in
the
production
cycle
were
only
quantified
for
the
Northern
region
where
the
impact
is
expected
to
be
more
pronounced
due
to
cooler
temperatures
and
longer
time
required
for
production
of
a
seedling
crop.
Changes
in
production
costs
arise
due
to
differences
between
the
costs
of
methyl
bromide
and
the
alternatives,
shifts
in
the
production
cycle
(
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period)
and
additional
expenses
such
as
supplementary
irrigation.
These
costs
vary
across
regions
and
within
the
Western
region,
which
is
highly
diverse,
because
of
differences
in
pests,
production
systems
and
regional
differences
in
costs
of
water
and
labor.
Costs
are
higher
in
the
South,
in
part
because
warmer
temperatures
increase
pest
pressure.

Michigan
Herbaceous
Perennials
Michigan
herbaceous
perennials,
labeled
Region
H
above,
comprises
three
categories
of
production
systems
with
numerous
plant
varieties
grown
within
each
category.
These
categories
are
2­
year
seeded
(
6%
of
plants),
2­
year
transplanted
(
29%
of
plants),
and
3­
year
transplanted
(
65%
of
plants).
To
represent
growing
conditions
on
a
typical
hectare
of
production,
and
to
account
for
the
fact
that
each
category
has
different
revenues
and
costs
of
production,
the
above
measures
were
calculated
using
representative
revenues
and
costs
for
each
category;
these
were
weighted
by
the
proportion
of
total
production.
In
addition,
various
combinations
of
alternative
pest
control
measures
would
need
to
be
employed
to
accomplish
the
most
effective
and
lowest
cost
pest
control
without
MB.
These
various
alternative
pest
control
measures
include
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.

Using
alternatives
to
MB
would
lead
to
an
estimated
yield
loss
of
5%
and
an
approximate
100%
increase
in
operating
costs.
This
will
result
in
losses
as
a
percent
of
gross
and
net
revenue
of
20%
and
28%,
respectively.
If
growers
switch
to
MB
alternatives,
their
losses,
in
terms
of
MB
per
kilogram
no
longer
used,
will
be
approximately
$
145.
Based
on
the
economic
impact
of
switching
to
MB
alternatives,
the
U.
S.
believes
that
currently,
alternatives
to
MB
are
not
economically
feasible
and
growers
of
herbaceous
perennials
have
a
critical
need
for
MB.
Page
63
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Because
of
high
costs
associated
with
forest
seedlings
considerable
resources
have
been
spent
examining
methods
to
reduce
costs
and
improve
efficiency
in
seedling
production.
The
Southern
Forest
Nursery
Management
Cooperative
includes
commercial
interests,
has
spent
$
1.2
million
on
MB
alternatives
since
1992.
This
is
significant,
considering
several
of
the
nurseries
are
publicly
owned
and
have
limited
resources
for
independent
research.
Research
has
included
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
(
two
year
cover
crops
 
see
International
Paper
request
CUE
03­
0007)
to
MB,
including
some
potential
alternatives
that
are
not
currently
listed
by
MBTOC,
including
combinations
of
chemicals
such
as
1,3­
D,
chloropicrin,
metam­
sodium,
and
methyl
iodide
(
not
currently
registered
in
the
U.
S.).
Development
of
technologies
to
improve
efficacy
of
alternatives
are
underway
and
include
work
with
deep
injection
application
methods,
soil
moisture
management
by
improving
drip
technologies,
and
trials
with
VIF
to
increase
efficacy
and
decrease
emissions
while
allowing
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
The
Michigan
Field
Grown
Herbaceous
Perennial
Growers
is
currently
assisting
in
field
trials
with
Michigan
State
University
in
research
supported
in
part
by
the
USDA
MB
Alternatives
Grant
Program.
For
2002­
2004,
$
68,979
has
been
allocated
for
weed
and
nematode
studies
and
$
370,701
has
been
granted
for
a
study
that
runs
from
2003­
2006.
This
work
is
a
large
investment
in
identifying
alternatives
for
Michigan
growers.
9
One
difficulty
in
identifying
alternatives
to
MB
is
the
problem
of
applicability
of
information
obtained
from
research
plots
to
large­
scale
commercial
production
requirements.
Fumigants
applied
to
small
plots
may
not
exhibit
similar
effects
when
applied
to
commercial
seedling
beds.
Overall,
especially
under
high
pest
pressure,
alternative
chemicals
have
not
demonstrated
consistently
effective
results
compared
to
MB.
Continued
research
into
methods
adaptable
to
large­
scale
application
will
shift
the
industry
to
MB
alternatives.

Weyerhaeuser
Corporation,
one
of
the
largest
growers
of
forest
seedlings,
suggested
their
preference
for
MB
alternatives
(
in
descending
order):
1)
chloropicrin,
340
kg/
ha;
2)
1,3­
D
at
260
kg/
ha
+
chloropicrin
at
140
kg/
ha;
3)
metam­
sodium,
(
485
kg/
ha)
and
chloropicrin
(
115
kg/
ha);
4)
dazomet,
400
kg/
ha;
5)
non­
chemical
treatments
such
as
steam;
6)
biological
control
agents.
Page
64
24.
ARE
THERE
PLANS
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

Plans
to
reduce
MB
in
formulations
to
50%
mixed
with
chloropicrin
are
already
underway,
even
though
nurseries
currently
use
MB
only
once
in
three
to
four
years
on
a
particular
bed.
Weed
management
is
the
issue
of
most
concern
by
most
nurseries
and
work
is
ongoing
to
study
the
strategic
use
of
herbicides
(
e.
g.,
$
370,701
USDA
grant
for
methyl
bromide
alternatives
research
by
Michigan
State
University
that
will
test
numerous
herbicides
and
other
weed
control
methods).
Also
cultural
practices
are
being
examined
to
increase
mechanical
cultivation
and/
or
soil
amendments
and
fertilizers
to
maximize
productivity
and
reduce
reliance
on
MB.
Development
of
predictive
models
to
strategically
determine
when
fumigation
is
appropriate
can
reduce
overall
use
of
fumigants
(
e.
g.,
Fraedrich
and
Dwinell,
1998).
As
stated
in
Section
23,
minimizing
use
of
MB
can
be
achieved
through
the
development
of
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
experience
with
virtually
impermeable
films
to
increase
efficacy
and
decrease
emissions,
and
still
have
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

The
methyl
bromide
critical
use
exemption
nomination
for
Forest
Seedlings
has
been
reviewed
by
the
U.
S.
Environmental
Protection
Agency
and
the
U.
S.
Department
of
Agriculture
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
use
is
considered
critical
because
there
are
conditions
in
some
nurseries
within
this
sector
with
high
pest
pressure
where
no
feasible
alternatives
or
substitutes
are
currently
effective.
While
some
alternatives
appear
to
offer
an
alternative
to
MB
for
some
pests
in
some
research
trials,
the
high
production
nursery
industry
demands
a
consistent
and
reliable
pre­
plant
fumigation
treatment
that
can
allow
production
goals
to
be
met.
Currently
MB
is
the
only
consistent
provider
of
this
requirement.

26.
CITATIONS
Barnett,
J.
P.
and
McGilvrary,
J.
M.
1997.
Practical
guidelines
for
producing
longleaf
pine
seedlings
in
containers.
Gen.
Tech.
Rep.
SRS­
14.
Asheville,
NC.
U.
S.
Department
of
Agriculture,
Forest
Service,
Southern
Research
Station.
28
p.
http://
www.
bugwood.
org/
container/
guidelines.
html
Campbell,
S.
J.
and
Kelpsas,
B.
R.
1988.
Comparison
of
three
soil
fumigants
in
a
bareroot
conifer
nursery.
Tree
Planters'
Notes
39
(
4):
16­
22.

Carey,
W.
A.
2000.
Fumigation
with
chloropicrin,
metham
sodium,
and
EPTC
as
replacements
for
methyl
bromide
in
southern
pine
nurseries.
Southern
Journal
of
Applied
Forestry
24:
135­
139.
Page
65
Carey,
W.
A.
1996.
Testing
alternatives
to
methyl
bromide
fumigation
at
the
Winona
Nursery.
Southern
Forest
Nursery
Management
Cooperative
Research
Report
96­
2.

Carey,
W.
A.
1994.
Chemical
alternatives
to
methyl
bromide.
In:
Landis,
T.
D.,
Dumroese,
R.
K.,
tech.
cords.
National
Proceedings,
Forest
and
Conservation
Nursery
Associations.
Gen.
Tech.
Rep.
RM­
257.
Fort
Collins,
CO.
U.
S.
Department
of
Agriculture,
Forest
Service,
Rocky
Mountain
Forest
and
Range
Experiment
Station:
4­
11.

Charron,
C.
S.
and
Sams,
C.
E.
Macerated
Brassica
leaves
suppress
Pythium
ultimum
and
Rhizoctonia
solani
mycelial
growth.
see
CUE­
0066
request
Michigan
Field
Grown
Herbaceous
Perennial
Growers
consortium
in
2003
submission.

Cram,
M.
M.
and
Fraedrich,
W.
1997.
Survey
of
southern
forest
nurseries:
fumigation
practices
and
pest
management
concerns.
www.
epa.
gov/
spdpublic/
mbr/
airc/
1997/
096cram.
pdf
Darrow,
K.
2002.
Personal
communication
(
see
Appendix
A)

Elmore,
C.
L.,
Stapleton,
J.
J.,
Bell,
C.
E.,
DeVay,
J.
E.
1997.
Soil
Solarization.
Univ.
California,
Div.
Agriculture
and
Natural
Resources,
Publ.
21377.
Oakland,
CA.
pp.
13.

Enebak,
S.
A.,
Palmer,
M.
A.,
and
Blanchette,
R.
A.
1990.
Managing
soilborne
pathogens
of
white
pine
in
a
forest
nursery.
Plant
Disease
74:
195­
198.

Federal
Register,
February
5,
1998,
40
CFR,
part
82.
Control
of
methyl
bromide
emissions
through
use
of
tarps.
http://
frwebgate5.
access.
gpo.
gov/
cgibin
waisgate.
cgi?
WAISdocID=
826484320000+
6+
0+
0&
WAISaction=
retrieve.

Fraedrich,
S.
W.
and
Dwinell,
L.
D.
1998.
Evaluation
of
fumigants
for
pest
management
and
seedling
production
in
southern
pine
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
1998).
http://
mbao.
org/

Gan,
J.
and
Yates,
S.
R.
1998.
Ammonium
thiosulfate
fertilizer
reduces
methyl
bromide
emissions
from
soil.
Methyl
Bromide
Alternatives,
USDA,
ARS.
vol
4
(
3),
July,
1998.
http://
www.
ars.
usda.
gov/
is/
np/
mba/
july98/
ammonium.
htm
Hardie
I.
W.
and
Parks,
P.
J.
1991.
Individual
choice
and
regional
acreage
response
to
costsharing
in
the
South,
1971­
1981.
Forest
Science
37(
1)
175­
190.

Iver,
J.
G.
(?).
Nursery
fertility
and
related
problems
 
yellowing
of
white
pine.
Wisconsin
Department
of
Natural
Resources
State
Nursery
Managers
(
cooperators).
in
CUE
03­
0032
application.

James,
R.
L.,
Stone,
J.
K.,
Hildebrand,
D.
M.,
Frankel,
S.
M.,
and
Gemandt,
D.
S.
1997.
Alternatives
to
chemical
soil
fumigation
in
western
federal
bareroot
conifer
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
1997).
http://
mbao.
org/
Page
66
James,
R.
L.,
Stone,
J.
K.,
Hildebrand,
D.
M.,
Frankel,
S.
M.,
and
Harris,
J.
L.
2001.
Alternatives
to
pre­
plant
soil
fumigation
in
western
bareroot
forest
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2001).
http://
mbao.
org/

Landis,
T.
D.
and
Campbell,
S.
J.
1989.
Soil
fumigation
in
bareroot
tree
nurseries.
In:
Landis,
T.
D.,
(
tech.
coord.),
Proc.
Intermountain
Forest
Nursery
Association,
Bismarck,
ND.
USDA,
Forest
Service,
Ft.
Collins,
CO.
http://
www.
fcnanet.
org/
proceedings/
1989/
landis.
pdf
Lantz,
C.
W.
1997.
Alternatives
to
methyl
bromide
in
southern
forest
tree
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
1997).
http://
mbao.
org/

Lowerts,
G.
2003.
Personal
communication.

Mc
Nabb,
K.
and
VanderSchaaf,
C.
2003.
A
survey
of
forest
tree
seedling
production
in
the
South
for
the
2003­
2003
planting
season.
Southern
Forest
Nursery
Management
Cooperative
Technical
Note
03­
02.

Moulton,
R.
J.
and
Hernandez,
G.
2000.
Tree
planting
in
the
United
States,
1998.
Tree
Planters
Notes
V49(
2).
USDA
Forest
Service.
pp
1­
36.

Royer,
J.
P.
1987.
Determinants
of
reforestation
behavior
among
southern
landowners.
Forest
Science
33(
3)
654­
667.

Stone,
J.
K.,
Hildebrand,
D.
M.,
James,
R.
L.,
Frankel,
S.
M.
1998.
Alternatives
to
methyl
bromide
fumigation
for
control
of
soil
borne
diseases
in
bareroot
forest
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
1998).
http://
mbao.
org/

USDA­
APHIS
(
Animal
and
Plant
Health
Inspection
Service),
Plant
Protection
and
Quarantine.
2002.
Sudden
Oak
Death.
http://
www.
aphis.
usda.
gov/
ppq/
ispm/
sod/

Weyerhaeuser
In­
house
Research
Study
2
(
Bonanza
Nursery,
Molin,
Oregon).
1980.
MBchloropicrin
(
spring
and
fall),
Vorlex
(
MITC+)
and
Vapam
(
metam
sodium)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
3
(
Mima
Nursery,
Olympia,
Washington).
1984­
1987.
MB­
chloropicrin,
Basamid
(
dazomet)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
4
(
Mima
Nursery,
Olympia,
Washington).
1985­
1987.
MB­
chloropicrin,
Basamid
(
dazomet),
soil
preparation
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
5
(
Mima
Nursery,
Olympia,
Washington).
1985­
1987.
MB­
chloropicrin,
Basamid
(
dazomet)
rate
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
6
(
Aiken
Nursery,
Aiken,
South
Carolina).
1992.
MBchloropicrin
Basamid
(
dazomet),
Busan
(
metam­
sodium)
trial.
2002
CUE
request
package.
Page
67
Weyerhaeuser
In­
house
Research
Study
7
(
Fort
Towson
Nursery,
Ft.
Towson,
Oklahoma).
1994­
1996.
MB­
chloropicrin
alternatives
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
8
(
Magnolia
Nursery,
Magnolia,
Arkansas).
1992­
1995.
MB­
chloropicrin
alternatives
trial.
2002
CUE
request
package
and
Appendices
A
and
C,
2003
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
9
(
G.
H.
W.
Nursery,
Washington,
North
Carolina).
1994­
1995.
Basamid
(
dazomet)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
10
(
G.
H.
W.
Nursery,
Washington,
North
Carolina).
1994­
1996.
Alternative
fumigant
trial.
2002
CUE
request
package.
Page
68
APPENDIX
A.
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1
The
costs
below
are
based
on
the
conversion
of
a
10
million
bareroot
seedling,
soil­
based,
nursery
[
typical
nurseries
in
the
southern
U.
S.
can
produce
20­
60
million
bareroot
seedlings]
to
a
container,
soilless,
nursery
for
the
raising
of
Loblolly
pine
seedlings
in
the
southern
USA.
The
cost
estimates
include
estimates
of
additional
expenditures
(
over
and
above
$.
04
per
seedling
cost
for
soil­
based
system)
for:

A.
Capital
Infrastructure
B.
Operating
Costs
Limitations
of
analysis:
There
are
also
expected
to
be
additional
shipping
costs,
due
to
the
larger
size
and
weight
of
containerized
plants,
but
estimating
these
costs
were
beyond
the
scope
of
this
analysis.
Economy
of
scale
can
be
significant
and
regional
costs
vary,
making
it
difficult
to
provide
a
precise
cost.

Additional
note:
The
capital
costs
associated
with
conversion
from
a
soil­
based
to
a
soilless
nursery
are
much
less
than
the
capital
costs
of
establishing
a
new
soilless
nursery.
All
of
the
basic
infrastructure
and
much
of
the
equipment
would
already
be
in
place
with
a
soil­
based
nursery.

A.
Capital
Infrastructure:
Many
of
the
facilities
required
for
the
operation
of
a
soil­
based
seedling
nursery
are
required
for
a
soilless
nursery,
so
conversion
costs
and
the
conversion
costs
are
Conversion
cost:
Water
supply
$
0
Power
$
0
Buildings
$
0
Landscaping/
leveling/
roads
$
0
Equipment
­
assuming
no
trade­
ins
$
100,000
Nursery
structures
+
irrigation
$
130,000
B.
Operating
costs:
Working
capital
requirements
are
greater
in
a
soilless
nursery
than
a
soil­
based
nursery
as
more
labor
is
used.
The
cost
of
conversion
from
a
soil­
based
nursery
to
a
soilless
nursery
should
include
the
need
for
additional
working
capital.

Working
capital:
Additional
container
system
cost
$
150,000
(
Over
and
above
~$
50,000
cost
for
soil­
based
system)
Containers
$
410,000
Page
69
C.
Land
The
soil­
based
nursery
requires
13.3
hectares
exclusive
of
buildings,
storage
and
administrative
area.
The
soilless
nursery
requires
4
hectares
for
the
same
production.

Assuming
the
soil­
based
nursery
owner
is
able
to
sell
or
exchange
the
surplus
land,
the
change
from
soil­
based
to
soilless
will
be
a
source
of
revenue.
A
review
of
land
prices
in
the
southern
USA,
in
localities
where
forest
tree
nurseries
are
situated
reveals
an
average
of
$
12,350
per
hectare.

Land
Savings:
Land
(
9.3
hectares
at
$
12,350
per
hectare)
($
114,855)

D.
Analysis
of
Net
Costs:
Converting
10
million
Seedling
Nursery
from
Bareroot
to
Containerized,
Soilless
Culture
Capital
Cost
Years
of
Use*
Annual
Cost
Cost
per
Seedling
EQUIPMENT
$
100,000
10
$
11,723
$
0.0012
Nursery
Structures
$
130,000
10
$
15,240
$
0.0015
Running
Container
System
$
150,000
$
0.015
Containers
$
410,000
$
0.041
Total
Additional
Cost**
$
586,963
$
0.059
Land
rent
savings***
($
3,450)
($
0.0003)

Net
additional
cost
$
0.0583
Base
production
cost
(
for
bareroot
and
soilless
system)
$
0.04
Total
Cost
per
Seedling
$
0.0983
*
Incorporates
real
interest
cost
at
3%
per
year.
**
Does
not
include
additional
cost
of
shipping
due
to
larger
and
heavier
containers.
***
Using
land
capitalization
rate
of
3%.

Conclusion:
Converting
to
a
soilless
containerized
system
would
increase
the
cost
of
production
by
approximately
250%,
and
could
be
higher
when
the
increased
cost
of
shipping
containerized
seedlings
is
included.

1
Based
on
communication
with
Kevin
Darrow,
Sept.
2002
Page
70
APPENDIX
B.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
%
of
Average
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
87,348
233
375
64%

13,455
54
250
61%

1,911
7
263
55%

8,981
27
336
50%

7,943
34
236
69%

12,970
38
341
60%

4,477
17
263
51%

2,381
6
392
50%

139,882
415
337
63%

63%
62%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
375
375
0
0
0
0
100
100
0
0
0
0
0
0
250
250
0
0
0
0
100
100
0
0
0
0
0
0
263
263
0
0
0
0
100
100
0
0
0
0
0
0
336
336
0
0
0
0
100
100
0
0
0
0
0
0
263
236
0
0
0
0
100
100
0
0
0
0
0
0
341
341
0
0
0
0
100
100
0
0
0
0
0
0
269
263
0
0
0
0
100
100
0
0
0
0
0
0
392
392
0
0
0
0
100
100
0
0
0
0
0
0
Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MB
Use
/

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MB
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
No
Yes
Yes
Tarp
Yes
0
No
3,056
$
33
$
9%
19%

No
Yes
Yes
Tarp
Yes
­
No
3,695
$
59
$
11%
20%

No
Yes
Yes
Tarp
Yes
0
No
14,142
$
54
$
7%
8%

No
Yes
Yes
Tarp
Yes
­
No
1,710
$
20
$
6%
15%

No
Yes
Yes
Tarp
Yes
0
No
2,368
$
27
$
13%
25%

No
Yes
Yes
Tarp
Yes
0
No
6,547
$
38
$
20%
66%

No
Yes
Yes
Tarp
Yes
0
No
5,988
$
67
$
6%
37%

No
Yes
Yes
Tarp
N/
A
No
Notes:
Conversion
Units:
1
Pound
=
Kilograms
Hectare
100%
100%
100%
100%
100%
100%

100%
100%
100%
100%
Combined
Impacts
(%)

HIGH
100%
100%
not
available
MOST
LIKELY
IMPACT
VALUE
Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
100%
100%
LOW
100%
100%

not
available
not
available
not
available
not
available
Regional
Hectares**

%
of
Requested
Hectares
not
available
not
available
not
available
not
available
1
Acre
=
0.404686
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
Michigan
Herbaceous
Perennials
0.453592
*
International
Paper
and
Weyerhaeuser
(
SE)
were
included
in
the
Southern
Forest
Nursery
Management
Cooperative,
therefore
they
were
removed
from
the
Southern
Forest
Nursery
Mgmt.
Coop.

Application
as
double
counting.
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)

NE
Forest
&
Conservation
Nursery
Assoc.

Michigan
Seedling
Association
Michigan
Herbaceous
Perennials
Southern
Forest
Nursery
Mgmt
Coop.

International
Paper
Illinois
Department
of
Natural
Resources
Michigan
Seedling
Association
Michigan
Herbaceous
Perennials
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)

NE
Forest
&
Conservation
Nursery
Assoc.

Illinois
Department
of
Natural
Resources
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)

NE
Forest
&
Conservation
Nursery
Assoc.

Michigan
Seedling
Association
Southern
Forest
Nursery
Mgmt
Coop.

International
Paper
Illinois
Department
of
Natural
Resources
2006
Nomination
Options
TOTAL
OR
AVERAGE
REGION
REGION
REGION
Southern
Forest
Nursery
Mgmt
Coop.

International
Paper
Other
Considerations
Adjustments
to
Requested
Amounts
%
Reduction
from
Initial
Request
Nomination
Amount
Michigan
Herbaceous
Perennials
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
3
~
5%
Yield
Loss
metam/
Pic
or
1,3­
D/
Pic
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
Southern
Forest
Nursery
Mgmt
Coop.

International
Paper
Illinois
Department
of
Natural
Resources
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)

NE
Forest
&
Conservation
Nursery
Assoc.

Michigan
Seedling
Association
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
139,467
0%
19%
25%
25%
63%
63%
63%

2,381
2,381
2,381
139,467
139,467
374,159
302,823
280,926
278,933
4,763
­
­
­
12,970
12,970
12,970
9,144
­
­
191
4,477
4,477
4,477
32,455
­
6,514
­
8,981
8,981
8,981
25,358
­
7,669
1,803
7,943
7,943
7,943
17,962
­
­
­

4,264
­
442
­
1,911
1,911
1,911
13,455
13,455
13,455
34,181
­
7,271
­
(­)
QPS
HIGH
LOW
246,032
71,336
­
­
87,348
87,348
87,348
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

411,704
1,147
323
50%

374,159
1,100
311
34
263
50%

4,763
12
392
50,723
129
392
50%

9,144
34
269
8,954
67
236
50%

32,455
95
341
26,558
76
349
50%

25,358
96
263
15,886
15
263
50%

17,962
53
336
22,970
63
367
50%

4,264
16
263
3,822
656
375
50%

34,181
137
250
36,759
108
341
50%

246,032
656
375
246,032
2006
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

REGION
2%

Date:
2/
26/
2004
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:
51,506
Sector:
FOREST
SEEDLINGS
2006
Methyl
Bromine
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:
Page
71
Footnotes
for
Appendix
B:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
72
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2006
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
Page
73
32.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
33.
Tarps/
Deep
Injection
Used
 
Because
all
pre­
plant
methyl
bromide
use
in
the
US
is
either
with
tarps
or
by
deep
injection,
this
variable
takes
on
the
value
`
tarp'
when
tarps
are
used
and
`
deep'
when
deep
injection
is
used.
34.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
35.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
36.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
37.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
38.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
39.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
40.
Loss
per
Hectare
 
This
measures
the
total
loss
per
hectare
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
41.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
42.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
43.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
This
item
is
also
called
net
cash
returns.
44.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
45.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
Page
74
APPENDIX
C.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
75
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
