METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
ORNAMENTALS
GROWN
IN
OPEN
FIELDS
OR
IN
PROTECTED
ENVIRONMENTS
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
Ornamentals
Grown
in
Open
Fields
or
in
Protected
Environments
NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
ii
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
____________________________________________________________
5
1.
Nominating
Party
_________________________________________________________
5
2.
Descriptive
Title
of
Nomination______________________________________________
5
3.
Crop
and
Summary
of
Crop
System___________________________________________
5
4.
Methyl
Bromide
Nominated
_________________________________________________
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
6
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
8
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
8
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
10
Ornamentals
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
____________
11
Ornamentals
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
11
Ornamentals
­
11.
Characteristics
of
Cropping
System
and
Climate
___________________
13
Ornamentals
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
16
ORNAMENTALS
­
PART
C:
TECHNICAL
VALIDATION
__________________________________
17
Ornamentals
­
13.
Reason
for
Alternatives
Not
Being
Feasible_______________________
17
Ornamentals
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
22
Ornamentals
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
23
Ornamentals
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___
23
Ornamentals
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
26
Ornamentals
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
27
Ornamentals
­
Summary
of
Technical
Feasibility
_________________________________
27
PART
D:
EMISSION
CONTROL
___________________________________________________
28
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
28
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
28
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
30
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
30
22.
Gross
and
Net
Revenue___________________________________________________
30
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
31
Summary
of
Economic
Feasibility
_____________________________________________
32
PART
F.
FUTURE
PLANS
_______________________________________________________
35
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
35
iv
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
36
25.
Additional
Comments
on
the
Nomination
____________________________________
36
26.
Citations
______________________________________________________________
37
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
_______________
Error!
Bookmark
not
defined.

Appendix
C
 
Key
Pests
of
Select
Cut
Flower
Species
_______________________________
44
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
5
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
6
Table
A.
1:
Executive
Summary
__________________________________________________
7
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
__________________________
8
Ornamentals
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________
10
Table
A.
2:
2005
Sector
Request­­
Ornamentals
_____________________________________
10
Table
A3:
2006
Sector
Nomination­­
Ornamentals
__________________________________
11
ORNAMENTALS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_______________
11
Ornamentals
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
11
Ornamentals
­
Table
11.1:
Characteristics
of
Cropping
System_________________________
13
Ornamentals
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
­
Caladium________
14
Ornamentals
­
Table
11.3
Characteristics
of
Climate
and
Crop
Schedule
­
Ranunculus
______
14
Ornamentals
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________
16
ORNAMENTALS
­
PART
C:
TECHNICAL
VALIDATION
____________________________________
17
Ornamentals
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
__________________
17
Ornamentals
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
_______________
22
Ornamentals
 
Table
15.1:
Present
Registration
Status
of
Alternatives___________________
23
Ornamentals
 
Ranunculus
­
Table
16.1:
Effectiveness
of
Alternatives
 
Weeds
___________
25
Ornamentals
 
Ranunculus
 
Table
16.2:
Effectiveness
of
Alternatives
 
Weeds___________
25
Ornamentals
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
______________________
26
PART
D:
EMISSION
CONTROL
____________________________________________________
28
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
28
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
30
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
30
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
30
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________________________
30
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
30
California
Nursery
Roses
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives___
31
PART
F.
FUTURE
PLANS
________________________________________________________
35
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
38
Page
5
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Cut
Flower
and
Bulb
Ornamentals
Grown
in
Open
Fields
or
in
Protected
Environments
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM:

In
the
United
States
cut
flowers,
cut
foliage
and
bulb
crops
are
grown
in
open
fields
and
under
cover
(
including
glass,
poly,
and
saran).
In
1997,
eight
percent
of
the
ornamentals
in
the
United
States
were
grown
under
cover
and
92
percent
were
grown
in
the
open.
There
are
three
basic
systems
in
place
for
ornamentals.
Annuals
are
shallow
rooted
crops
that
represent
50
to
60
percent
of
the
industry.
They
are
often
planted
to
a
depth
of
6
to
8
inches.
Fumigants
can
be
shanked
into
the
preformed
beds
or
dripapplied
from
drip
tapes
placed
on
tops
of
beds
under
plastic
mulch.
Bulb
crops
represent
about
30
percent
of
the
industry.
Fumigants
are
applied
on
the
flat
by
deep
shanking.
Bedding
up
generally
occurs
after
planting
the
bulbs.
Perennials
are
deep­
rooted
multi­
year
crops
and
represent
10
to
20
percent
of
the
industry
in
California.
Fumigation
needs
to
penetrate
to
a
depth
of
2
to
3
feet
and
may
require
multi­
level
shanking.

Methyl
bromide
is
used
in
almost
all
saran
house
production
 
snap
dragons,
asters,
gerbera
daisies,
mums,
etc,
as
a
broadcast
solid
tarp
treatment.
It
is
used
in
field
grown
statice
and
gypsophila
as
an
inbed
treatment.
In
some
gladiolus
production,
methyl
bromide
is
used
broadcast
solid
tarp
for
increase
of
cormels
and
tissue
culture
stock
(
Ragsdale,
2004).

This
nomination
is
for
multiple
species
(
see
Appendix
A)
but
two
species
will
be
used
as
examples
when
possible:
caladiums
and
ranunculus.

Caladiums
are
grown
in
Florida
on
either
sandy
or
muck
soils.
They
are
planted
from
the
middle
of
March
until
mid
April.
Caladiums
are
dug
annually
from
November
until
the
middle
of
March.
The
rhizomes
are
cleaned,
graded,
repacked,
and
stored
until
shipment
to
customers
throughout
the
world.
Methyl
bromide
is
applied
in
the
short
time
period
between
the
end
of
harvest
of
one
crop
and
the
planting
of
the
next.

Ranunculus
are
grown
as
annuals
in
the
field.
In
fall,
seeds
are
planted
on
beds.
Flowers
are
harvested
in
the
spring
and
the
tubers
are
harvested
in
July
and
August.
These
tubers
are
used
in
landscaping
and
planted
in
the
fall
(
Elmore
et
al.,
2003b).

Without
methyl
bromide,
growers
will
suffer
both
yield
and
quality
losses.
There
is
a
need
to
control
previous
planted
varieties
to
eliminate
contamination,
as
well
as
control
other
weeds
and
pathogens.
Some
of
the
alternatives
that
have
been
found
for
other
crops
are
not
be
feasible
for
some
floriculture
crops
because
of
high
cost,
difficulties
with
quickly
treating
and
replanting
fields
for
multi­
cropping,
and
buffer
zone
requirements.
In
California,
township
caps
limit
the
use
of
1,3­
D
as
an
alternative.
Although
some
alternatives
have
shown
potential
to
replace
methyl
bromide
use
in
some
situations,
the
in­
field
feasibility
of
the
alternatives
for
each
of
the
major
species
of
ornamentals
grown
in
the
United
States
Page
6
remains
to
be
demonstrated.
The
industry
has
made
progress
in
reducing
the
use
of
methyl
bromide
and
additional
research
in
ongoing.
Additional
time
is
needed
to
complete
the
phase­
out
of
methyl
bromide
in
this
sector
due
to
the
complexity
of
production
(
numerous
species,
each
with
its
own
pests
and
implementation
issues).

4.
METHYL
BROMIDE
NOMINATED:

TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
230,856
578
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.
ornamental
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
ornamental
production.
­
Key
target
pests:
the
U.
S.
is
only
nominating
a
CUE
where
the
key
pest
pressure
is
moderate
to
high.
­
Regulatory
constraints:
e.
g.,
in
some
areas
of
the
United
States
1,3­
Dichloropropene
use
is
limited
due
to
township
caps
in
California.
­
Delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin,
and
in
the
northern
parts
of
the
United
States
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.

Overall,
the
ornamentals
industry
has
hundreds
of
crop
species
and
thousands
of
varieties.
This
diversity
makes
finding
methyl
bromide
alternatives
for
each
crop
species
complex,
time
consuming
and
costly
(
Schneider,
2003).

As
part
of
the
overall
ornamentals
industry,
the
cut
flower,
foliage,
and
bulb
industry
is
very
complex.
For
example,
a
single
grower
in
California
may
grow
as
many
as
100
species
and/
or
varieties
in
a
single
year.
Growers
must
find
methyl
bromide
alternatives
that
will
control
previous
crops
grown
on
the
site,
as
well
as
a
diversity
of
key
pests,
which
vary
for
each
crop
variety.
For
example,
in
ranunculus,
residual
tubers,
bulbs,
and
seeds
from
the
previous
crop
must
be
killed
because
they
are
reservoirs
for
nematodes
and
soil
pathogens
and
considered
to
be
weeds
themselves
as
they
are
off­
variety.
Along
with
these
issues,
there
are
concerns
about
phytotoxicity
and
registration
with
alternative
chemicals
(
Schneider,
2003;
Elmore
et
al.,
2003b).
Recent
experiences
with
iodomethane
indicate
that
new
chemistries
can
take
several
years
to
be
registered
by
the
U.
S.
EPA
and
the
state
regulatory
agencies,
such
as
California
Department
of
Pesticide
Regulation.
In
addition,
township
caps
in
California
restrict
the
amount
of
1,3­
Page
7
Dichloropropene
that
can
be
used
in
a
given
area
(
Trout,
2001).
Buffer
zones
may
also
limit
the
adoption
of
alternatives.

TABLE
A.
1:
EXECUTIVE
SUMMARY*

Region
Ornamentals
AMOUNT
OF
NOMINATION
2006
Kilograms
230,856
Application
Rate
(
kg/
ha)
392
Area
(
ha)
578
AMOUNT
OF
APPLICANT
REQUEST
2005
Kilograms
226,796
Application
Rate
(
kg/
ha)
392
Area
(
ha)
578
2006
Kilograms
226,796
Application
Rate
(
kg/
ha)
392
Area
(
ha)
578
ECONOMICS
Marginal
Strategy
Metam
Sodium
Yield
Loss
(%)
20
%

Loss
per
hectare
(
U.
S.$/
ha)
4,980
Loss
per
kg
Methyl
Bromide
(
U.
S.$/
kg)
11.11
Loss
as
%
of
Gross
Revenue
(%)
19%

Loss
as
%
of
Net
Revenue
(%)
43%

*
See
Appendix
A
for
complete
description
of
how
nominated
amount
was
calculated.
Page
8
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

In
California,
township
caps
for
1,
3­
Dichloropropene
limit
the
number
of
growers
that
are
able
to
use
1,3­
D
+
chloropicrin.
Further,
because
the
ornamentals
industry
is
complex,
time
is
needed
to
determine
methyl
bromide
alternatives
for
all
species
and
varieties
grown,
including
determining
whether
there
are
any
phytotoxicity
issues
from
using
methyl
bromide
alternatives
(
Schneider,
2003).
Some
of
the
alternatives
that
have
been
found
for
other
crops
are
not
feasible
for
floriculture
because
of
their
high
cost,
difficulties
with
quickly
treating
and
replanting
fields
for
multi­
cropping,
and/
or
buffer
zone
requirements
(
Elmore,
2003a).
Ornamentals
have
a
high
value;
as
a
result
many
manufacturers
now
avoid
registering
materials
for
ornamental
crops
because
of
liability
due
to
potential
phytotoxicity
issues.

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
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Ornamentals
 
California*
10,054
6.3%
Caladiums
 
Florida**
648
85%

REGIONAL
TOTAL:
10,702
11%

NATIONAL
TOTAL:
Not
Available
Not
Available
*
2000
California
Department
of
Pesticide
Regulation
Data
**
Based
on
information
from
experts
in
Florida
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.

Given
the
number
and
diversity
of
species
grown
in
the
industry,
there
are
a
number
of
reasons
why
methyl
bromide
is
not
used.
Some
crops
have
been
able
to
switch
to
alternatives.
For
example,
growers
in
Oregon
are
now
using
1,3­
Dichloropropene
for
Easter
lilies.
Also,
some
species
may
not
need
methyl
bromide,
depending
on
their
key
pests
and
the
ability
to
use
alternatives.

Growers
are
also
maximizing
their
use
of
methyl
bromide.
Instead
of
fumigating
after
each
crop
(
more
than
once
a
year),
producers
may
grow
several
crops
over
1
to
2
years
on
the
same
piece
of
land,
using
methyl
bromide
only
when
necessary
instead
of
after
every
crop,
and
thus
reducing
the
amount
used.
Cropping
systems
have
been
changed
to
allow
most
sensitive
crops
to
be
planted
immediately
following
a
fumigation
followed
by
several
other
types
of
plants
in
decreasing
sensitivity
to
soil
pathogens.
Costs
of
fumigation
alone
made
this
a
critical
change
in
cut
flower
production.
In
addition,
some
perennials
may
be
grown
for
5
to
25
years.
Methyl
bromide
would
only
be
used
once
during
this
cycle.
Page
9
In
this
industry,
the
fumigation
situation
and
need
for
methyl
bromide
varies
by
species.
Although
there
are
some
potential
alternatives,
there
is
not
enough
grower
experience
for
all
crop
species
to
switch
to
alternatives
at
this
time.
One
major
difficulty
is
that
market
desires
require
a
high
degree
of
flexibility
in
scheduling
certain
species
and
new
cultivars.
Therefore,
the
information
on
the
sensitivity
of
each
crop
to
fumigant
alternatives
as
well
as
the
pests
is
not
known
until
crops
have
been
in
production
for
at
least
a
few
cycles.

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?

Not
all
of
the
above
methods
and
alternatives
being
used
are
feasible
for
other
crops.
However,
the
industry
is
working
to
find
alternatives
to
methyl
bromide.

Specifically,
township
caps
in
California
limit
the
use
of
1,3­
Dichloropropene.
Many
of
the
crops
are
grown
in
coastal
areas,
where
cut
flowers
are
also
grown.
It
is
expected
that
about
30
percent
of
the
2000
fumigated
cut
flower
acres
could
not
have
used
1,3­
D
at
the
current
2X
cap,
which
is
expected
to
apply
through
at
least
2006.
This
number
would
be
higher
with
the
standard
(
1X)
caps.
Affecting
some
rotations
are
plant
back
times,
which
can
be
1
to
2
weeks
longer
with
1,3­
D.
Combined
regulatory
and
plant
back
limitations
could
restrict
use
of
1,3­
D
in
California
to
less
than
50
percent
of
the
current
fumigated
area
(
Trout,
2003;
Ragsdale,
2004).
In
addition,
an
alternative
that
works
for
one
crop
species
may
not
control
the
key
pests
of
another
species
or
it
could
be
phytotoxic
to
the
other
species.
The
industry
needs
additional
time
to
complete
ongoing
research
to
find
and
implement
alternatives
for
each
species.
The
industry
needs
plans
to
complete
the
transition
by
the
end
of
2006.
Page
10
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
O
RNAMENTALS
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Ornamentals
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
226,796
226,796
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Flat
Fumigation
Flat
Fumigation
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
578
578
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
585
585
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
392
392
DOSAGE
RATE*
(
kg/
ha)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
585
585
DOSAGE
RATE*
(
kg/
ha)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
392
392
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

TABLE
A.
2:
2005
SECTOR
REQUEST­­
ORNAMENTAL*

2005
Ornamental
Sector
Request
Requested
Hectares
(
ha)
578
Requested
Application
Rate
(
kg/
ha)
392
Applicant
Request
Requested
Kilograms
(
kg)
226,796
*
See
Appendix
A
for
a
complete
discussion
of
how
the
nominated
amount
was
calculated.
Page
11
TABLE
A.
3:
2006
SECTOR
NOMINATION­­
ORNAMENTALS*

2006
Ornamentals
Sector
Nomination
Requested
Hectares
(
ha)
578
Requested
Application
Rate
(
kg/
ha)
392
Applicant
Request
Requested
Kilograms
(
kg)
226,796
Nominated
Hectares
(
ha)
578
Nominated
Application
Rate
(
kg/
ha)
392
CUE
Nominated
Nominated
Kilograms
(
kg)
226,796
Overall
Reduction
(%)
0%

2006
U.
S.
CUE
Nomination
(
kg)
226,796
Research
Amount
(
kg)
4060
Sector
Nomination
Totals
Total
U.
S.
Sector
Nominated
Kilograms
(
kg)
230,856
ORNAMENTALS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ORNAMENTALS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
ORNAMENTALS
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
(
e.
g.
Effective
herbicide
available,
but
not
registered
for
this
crop;
mandatory
requirement
to
meet
certification
for
disease
tolerance)

*
See
Appendix
A
for
complete
description
of
how
nominated
amount
was
calculated.
Page
12
Ornamentals
All
soil
borne
diseases,
weeds,
and
nematodes.
Includes
Fusarium
spp.,
Rhizoctonia
spp.,
Phytoplithora,
Stromatinia,
Pythium
spp.,
and
most
soil
nematodes
i.
e.
Meliodogyne
spp.,
and
previous
crop
propagules.
Specific
pest
problems
vary
by
individual
crop
and
variety.
See
Appendix
C
for
more
detailed
information.
Due
to
the
diversity
and
complexity
of
the
cut
flower
and
foliage
industry,
an
additional
4.5
years
are
needed
to
complete
ongoing
research
into
implementation
of
methyl
bromide
alternatives
and
to
allow
time
for
registering
materials.
Alternatives
have
not
been
found
for
all
species.
Some
of
the
alternatives
that
have
been
found
for
other
crops
may
not
be
feasible
for
floriculture
because
of
high
cost,
difficulties
with
quickly
treating
and
replanting
fields
for
multi­
cropping,
township
caps,
and
buffer
zone
requirements
(
Elmore
et
al.,
2003a).
Page
13
ORNAMENTALS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
(
Place
major
attention
on
the
key
characteristics
that
affect
the
uptake
of
alternatives):

ORNAMENTALS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
ORNAMENTALS
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Cuttings,
bulbs
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
and
perennial
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
A
California
cut
flower
producer
may
grow
more
than
20
ornamental
species
and
hundreds
of
individual
varieties.
Crops
are
grown
in
rotation
on
an
8
to
16
week
interval
per
year
on
the
same
parcel
of
land.
Although
species
are
rotated,
the
complex
nature
of
this
crop
makes
a
typical
crop
rotation
difficult
to
identify.
Instead,
examples
of
two
different
types
of
rotation
will
be
described
here.

In
Florida,
caladiums
are
planted
between
the
middle
of
March
and
the
middle
of
April
each
year.
Caladiums
are
dug
annually
from
November
until
the
middle
of
March.
The
fields
are
fumigated
between
harvest
and
the
next
planting.

A
more
complex
crop
rotation
system
for
a
grower
may
involve
several
annuals.
The
first
annual
crop
is
planted
and
harvested
90
to
180
days
later.
A
different
species
is
planted
immediately
after
the
first
harvest.
Harvest
follows
approximately
90
to
180
days
later.
A
third
crop
is
then
planted.
Fumigation
would
occur
when
the
production
starts
to
decline,
which
may
be
an
interval
of
one
to
two
years.

Most
growers
produce
numerous
species,
including
annuals,
perennials,
and
bulbs,
throughout
the
farm.
The
rotation
involving
all
of
these
species
would
be
more
complex
than
the
examples
above.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
All.
For
example,
caladiums
are
grown
in
central
Florida,
mostly
on
muck
but
with
new
acreage
on
sand.
Cut
flowers
in
California
are
primarily
produced
in
the
coastal
environment
where
nearly
all
types
of
soil
are
present.

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
In
general,
once
every
year
although
it
may
occur
less
often
on
a
substantial
portion
of
the
acreage
in
this
sector
that
produce
perennials
and
gladiolus.

OTHER
RELEVANT
FACTORS:
None
identified.
Page
14
Tables
11.2
and
11.3
are
examples
of
the
characteristics
of
climate
and
crop
schedule
for
two
species
 
caladium
and
ranunculus.
These
characteristics
may
vary
for
other
species
and
other
growing
regions.

ORNAMENTALS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
CALADIUM
(
FLORIDA)

MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
9a
 
11
Plant
hardiness
zone
RAINFALL
(
mm)*
65.5
50.0
72.6
134.1
175.8
193.3
152.7
65.0
42.7
158.8
62.0
66.8
OUTSIDE
TEMP.
(
°
C)*
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16.0
16.9
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
HARVESTING
SCHEDULE
X
X
X
X
*
Date
based
on
Tampa,
Florida
records
for
1971
 
2000.

ORNAMENTALS
­
TABLE
11.3
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
RANUNCULUS
(
CALIFORNIA)

The
ranunculus
crop
is
different
from
other
cut
flower,
foliage,
and
bulb
crops
because
they
have
two
planting
sequences
to
ensure
long
season
availability
of
the
product.
The
first
sequence
occurs
on
a
very
small
percent
of
the
acreage
and
used
only
to
produce
cut
flowers.
It
begins
with
land
preparation
in
May
followed
by
fumigation
in
June.
Planting
occurs
in
June
and
July
and
flowers
are
harvested
from
September
through
February.
The
main
planting
is
used
to
produce
both
cut
flowers
and
bulbs.
Land
preparation
occurs
in
August
followed
by
fumigation
in
September
and
October.
Planting
occurs
from
September
through
December
with
harvesting
of
cut
flowers
occurring
from
February
through
May
(
possibly
into
June
in
some
years).

MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
9a
 
11
Plant
hardiness
zone.

RAINFALL
(
mm)*
16.0
72.1
17.3
0
Trace
1.0
Trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)*
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
X
Land
prep
X
X
PLANTING
SCHEDULE
X
(
very
small
area)
X
X
X
KEY
MARKET
WINDOW
X
X
X
X
X
X
X
X
X
X
*
Data
for
Jan­
Aug,
2003
and
Sep­
Dec
2002
for
Fresno,
California.
Page
15
ORNAMENTALS
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Caladium
Caladiums
are
dug
annually
from
November
through
March
15.
The
time
frame
between
lifting
the
previous
year's
crop
and
planting
the
new
crop
is
about
30
days,
or
possibly
shorter
when
severe
cold
temperatures
or
unexpected
rainfall
occurs.
Any
product
with
a
fallow
(
post­
treatment)
time
of
30
days
or
more
will
not
work
for
this
industry
as
fields
must
be
planted
before
April
15
each
year
and
cannot
be
prepared
for
planting
until
the
middle
of
March.
Page
16
ORNAMENTALS
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
ORNAMENTALS
­
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)
833
(
CA)
700
(
CA)
610
(
CA)
617
(
CA)
373
(
CA)
529
(
CA)

RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Nearly
all
Flat
Fumigation
Nearly
all
Flat
Fumigation
Nearly
all
Flat
Fumigation
Nearly
all
Flat
Fumigation
Nearly
all
Flat
Fumigation
Nearly
all
Flat
Fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
281,905
(
CA)
238,824
(
CA)
185,475
(
CA)
173,230
(
CA)
98,896
(
CA)
117,395
(
CA)

FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67:
33;
98:
2
67:
33;
98:
2
67:
33;
98:
2
67:
33;
98:
2
67:
33;
98:
2
67:
33;
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Chiseled
or
shanked
Chiseled
or
shanked
Chiseled
or
shanked
Chiseled
or
shanked
Chiseled
or
shanked
Chiseled
or
shanked
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
487
(
FL)
487
(
FL)
487
(
FL)
392
 
448
(
FL)
392
 
448
(
FL)
392
­
448
(
FL)

APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
338
(
CA)
340
(
CA)
304
(
CA)
281
(
CA)
264
(
CA)
222
(
CA)

ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
487
(
FL)
487
(
FL)
487
(
FL)
392
­
448
(
FL)
392
 
448
(
FL)
392
­
448
(
FL)

ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
338
(
CA)
340
(
CA)
304
(
CA)
281
(
CA)
264
(
CA)
222
(
CA)

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

The
California
(
CA)
application
rate
includes
both
outdoor
and
greenhouse
use.
The
outdoor
use
rate
is
lower
than
the
greenhouse
rate.
For
example,
in
2002
the
outdoor
use
rate
was
178
kg/
ha
and
the
greenhouse
rate
was
318
kg/
ha.
In
Florida
(
FL),
the
higher
rates
tend
to
be
used
on
muck
soils
and
the
lower
rates
on
sandy
soils.
Page
17
Growers
are
expected
to
use
a
67:
33
formulation
in
the
future,
although
this
may
vary
depending
on
the
crop
grown
and
the
pest
situation.
It
is
not
clear
that
a
50:
50
formulation
is
feasible.
In
Florida,
caladiums
are
grown
on
muck
and
sandy
soils.
The
majority
are
grown
on
muck
soils,
which
require
a
higher
application
rate
because
it
is
more
difficult
for
the
fumigant
to
be
distributed
evenly
in
this
soil
type.

ORNAMENTALS
­
PART
C:
TECHNICAL
VALIDATION
ORNAMENTALS
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
ORNAMENTALS
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
Dichloropropene
Township
caps
are
in
place
for
1,3­
D
that
limit
its
use
in
California.
Many
of
the
crops
are
grown
in
coastal
areas,
where
cut
flowers
are
also
grown.
It
is
expected
that
about
30
percent
of
the
2000
fumigated
cut
flower
acres
could
not
have
used
1,3­
D
at
the
current
2X
cap,
which
is
expected
to
apply
through
at
least
2006.
This
number
would
be
higher
with
the
standard
(
1X)
caps.
Affecting
some
rotations
are
plant
back
times,
which
can
be
1
to
2
weeks
longer
with
1,3­
D.
Combined
regulatory
and
plant
back
limitations
could
restrict
use
of
1,3­
D
in
California
to
less
than
50
percent
of
the
current
fumigated
area
(
Trout,
2003;
Ragsdale,
2004).
In
California,
buffer
zones
of
100
to
300
feet
make
using
this
alternative
difficult
because
often
flowers
are
produced
on
small
parcels
of
land.
1,3­
D
cannot
be
used
in
greenhouses.

For
caladiums,
chloropicrin
was
needed
in
addition
to
1,3­
D
to
reach
the
same
yield
as
methyl
bromide
plus
chloropicrin
(
Overman
and
Harbaugh,
1983).
The
plant­
back
window
for
caladiums
is
variable
and
the
1,3­
D
plant­
back
interval
will
limit
use
on
some
acres.
In
addition,
caladium
growers
are
reluctant
to
use
1,3­
D
because
it
does
not
control
weeds.
Growers
also
have
to
tarp
1,3­
D
and
do
not
have
the
equipment
to
do
it
themselves
(
they
can
apply
metam
sodium
themselves)
(
Gilreath,
2004).
No.
Page
18
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam
sodium
In
California,
buffer
zones
of
500
feet
make
using
this
alternative
difficult
because
flowers
are
produced
on
small
parcels
of
land.
Also,
this
alternative
is
not
labeled
for
greenhouse
use
in
California.
In
addition,
the
plant
back
restrictions
may
cause
some
growers
to
be
able
to
grow
fewer
crops
in
a
year.
Many
years
of
research
have
indicated
difficulty
achieving
consistent
efficacy
with
metam
sodium
on
high
value
crops.

Metam
sodium
is
used
by
some
growers
of
caladiums
in
rotation
with
methyl
bromide,
due
to
the
expense
of
methyl
bromide.
Growers
feel
that
they
can
use
metam
sodium
if
they
used
methyl
bromide
the
previous
year.
The
growers
that
have
tried
using
metam
sodium
2
years
in
a
row
had
bad
nematode
infestations
the
second
year
and
will
now
only
use
it
once
every
2
years.
Most
growers
will
not
use
metam
sodium
because
they
must
meet
certification
requirements
(
free
of
nematodes)
for
certain
markets
(
several
U.
S.
states
and
some
international
markets)
(
Gilreath,
2004).

This
fumigant
is
currently
used
and
will
continue
to
be
used
where
it
gives
adequate
pest
control.
It
is
unlikely
that
metam
sodium
will
replace
significant
portions
of
the
current
use
of
methyl
bromide.
No.

Dazomet
(
Basamid)
In
some
cut
flowers
(
carnation
and
chrysanthemum)
dazomet
was
effective
against
Fusarium,
Rhizoctonia,
Erwinia,
and
Pseudomonas.
Appropriate
aeration
times,
which
are
dependent
on
soil
temperature,
are
needed
to
avoid
phytotoxicity
(
Semer,
1987).
In
addition,
plant
back
restrictions
may
cause
some
growers
to
be
able
to
grow
fewer
crops
in
a
year.
No.

Chloropicrin
Chloropicrin
may
not
currently
be
used
in
greenhouses
in
California.
In
California,
buffer
zones
vary
with
county
and
condition
in
California.
Buffer
zones
of
100
feet
in
sensitive
areas
make
using
this
alternative
difficult
because
flowers
are
produced
on
small
parcels
of
land.
There
is
reluctance
to
use
chloropicrin
in
many
areas
due
to
the
proximity
of
cut
flower
fields
to
residences.
Several
California
counties
impose
large
buffers
(>
152
meters)
and
restrict
rates
to
less
than
224
kg/
ha.
Weed
control
is
also
poorer
than
with
methyl
bromide
(
Ragsdale,
2004).
No.

MITC
Same
issues
described
above
for
metam
sodium
and
dazomet.
No.

NON
CHEMICAL
ALTERNATIVES
Page
19
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biofumigation
Biofumigation
is
still
largely
in
the
experimental
stages.
(
Pizano,
2001).
Specific
brassicas
as
well
as
specific
years
yield
variable
amounts
of
activity.
While
this
alternative
may
provide
some
control,
the
control
of
all
target
pests
is
not
sufficient.
Also,
brassica
waste
must
be
available
in
huge
quantities
to
provide
at
best
minor
effects.
The
extremely
large
volume
of
raw
material
required
makes
this
impractical.
No.

Solarization
Solarization
takes
several
weeks
to
control
many
pests
to
a
depth
of
30
cm.
This
length
of
time
for
a
treatment
is
not
economically
feasible
in
the
intensive,
year­
round
production
situation
of
the
cut
flower
industry
(
Pizano,
2001).
Production
areas
in
California
are
mainly
coastal
where
solarization
is
not
feasible
due
to
cool
temperatures
and
solar
radiation
most
of
the
year.
No.

Steam
Steam
can
be
a
technically
effective
alternative
in
some
cases.
Reasons
cited
for
not
using
steam
for
this
crop
system
are
high
initial
cost
and
an
adverse
affect
on
soil
organic
matter
in
enclosed
structures.
Some
greenhouse
growers
have
adapted
this
approach
already
in
crops
where
it
works
better
(
such
as
Freesia).
In­
field
steaming
is
not
a
feasible
alternative
due
to
lack
of
machinery
that
can
deliver
the
steam,
differences
in
soil
type,
and
environmental
impact
of
fuel
use.
No.

Biological
control
Results
with
biological
control
agents
may
vary
with
field
or
environmental
conditions
(
Pizano,
2001).
Even
in
small
containers,
biological
control
is
not
reliable
for
soil­
borne
pathogens.
No.

Crop
residue
compost/
Crop
rotation/
fallow
Rotation
is
used
extensively
in
cut
flower
production.
However,
in
annual
cropping
they
are
generally
too
short
for
the
full
effects
of
rotating
schemes
to
be
effective.
The
previous
crop
(
bulbs,
corms)
often
contaminate
the
following
crop
or
may
harbor
pathogens.
In
addition,
crop
rotation
is
not
really
a
solution
to
pest
problems
in
floriculture
because
either
the
crop
cycle
is
too
long
(
perennials)
or
the
pests
persist
in
the
soil
for
a
long
time
(
Pizano,
2001).
Flower
rotations
are
generally
not
a
true
rotation
in
the
pest
control
sense.
No.

Flooding
and
water
management
Beds
are
generally
designed
and
graded
for
good
drainage
to
prevent
standing
water.
Flooding
could
increase
the
incidence
of
certain
diseases
and
is
also
time
restrictive.
(
Environmental
laws
prohibit
run­
off
in
the
most
of
the
state
of
California
making
use
(
and
often
access)
to
water
in
this
manner
impossible).
No.

General
IPM
Although
IPM
is
currently
practiced,
this
alone
will
not
control
weed
and
disease
pests.
No.

Grafting/
resistant
rootstock/
plant
breeding
Grafting/
resistant
rootstock/
plant
breeding
are
not
feasible
alternatives.
Given
the
thousands
of
varieties
of
ornamentals,
plant
breeding
for
the
variety
of
pests
is
not
practical.
No.

Organic
amendments/
compost
Not
effective
alone
in
weed
or
pest
management;
may
be
incorporated
as
part
of
an
IPM
program.
Does
not
provide
adequate
weed
and
disease
control.
No.
Page
20
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Physical
removal/
sanitation
Appropriate
sanitation
practices
are
already
used
extensively.
No.

Resistant
cultivars
Given
the
thousands
of
varieties
of
ornamentals,
developing
resistant
cultivars
for
each
variety,
each
with
unique
pest
problems,
is
not
practical.
Choices
are
often
market
driven.
No.

Soilless
culture
/
Substrates
/
plug
plants
Container
production
may
be
possible
in
higher
value
cut
flower
crops
but
it
not
generally
feasible,
especially
for
deeper
rooted
crops
and
on
large
acreage.
No.

COMBINATIONS
OF
ALTERNATIVES
1,3­
Dichloropropene
+
chloropicrin
In
California,
1,3­
D
use
is
limited
by
township
caps,
buffer
zones,
and
plant
back
times,
which
could
affect
some
rotations.
1,3­
D
cannot
be
used
in
greenhouses.

For
caladiums,
chloropicrin
was
needed
in
addition
to
1,3­
D
to
reach
the
same
yield
as
methyl
bromide
plus
chloropicrin
(
Overman
and
Harbaugh,
1983).
1,3­
D
is
also
limited
by
the
plant­
back
interval,
the
lack
of
weed
control,
and
the
lack
of
equipment
necessary
to
fumigate
with
1,3­
D
(
Gilreath,
2004).

In
California,
limitations
to
chloropicrin
include
buffer
zones,
poorer
weed
control
than
methyl
bromide,
and
that
it
may
not
currently
be
used
in
greenhouses.
There
is
reluctance
to
use
chloropicrin
in
many
areas
due
to
the
proximity
of
cut
flower
fields
to
residences.
No.

1,3­
Dichloropropene
+
chloropicrin
+
pebulate
Pebulate
is
currently
not
registered.

In
California,
1,3­
D
use
is
limited
by
township
caps,
buffer
zones,
and
plant
back
times,
which
could
affect
some
rotations.
1,3­
D
cannot
be
used
in
greenhouses.

For
caladiums,
chloropicrin
was
needed
in
addition
to
1,3­
D
to
reach
the
same
yield
as
methyl
bromide
plus
chloropicrin
(
Overman
and
Harbaugh,
1983).
1,3­
D
is
also
limited
by
the
plant­
back
interval,
the
lack
of
weed
control,
and
the
lack
of
equipment
necessary
to
fumigate
with
1,3­
D
(
Gilreath,
2004).

In
California,
limitations
to
chloropicrin
include
buffer
zones,
poorer
weed
control
than
methyl
bromide,
and
that
it
may
not
currently
be
used
in
greenhouses.
There
is
reluctance
to
use
chloropicrin
in
many
areas
due
to
the
proximity
of
cut
flower
fields
to
residences.
No.
Page
21
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Dazomet
(
Basamid)
+
chloropicrin
In
some
cut
flowers
(
carnation
and
chrysanthemum)
dazomet
was
effective
against
Fusarium,
Rhizoctonia,
Erwinia,
and
Pseudomonas.
Appropriate
aeration
times,
which
are
dependent
on
soil
temperature,
are
needed
to
avoid
phytotoxicity
(
Semer,
1987).
In
addition,
plant
back
restrictions
may
cause
some
growers
to
be
able
to
grow
fewer
crops
in
a
year.

In
California,
limitations
to
chloropicrin
include
buffer
zones,
poorer
weed
control
than
methyl
bromide,
and
that
it
may
not
currently
be
used
in
greenhouses.
There
is
reluctance
to
use
chloropicrin
in
many
areas
due
to
the
proximity
of
cut
flower
fields
to
residences.
No.

Metam
sodium
+
chloropicrin
In
California,
limitations
to
metam
sodium
include
buffer
zones,
greenhouse
uses
are
not
labeled,
and
plant
back
restrictions.
In
addition,
many
years
of
research
have
indicated
difficulty
achieving
consistent
efficacy
with
metam
sodium
on
high
value
crops.

Metam
sodium
is
used
by
some
growers
of
caladiums
in
rotation
with
methyl
bromide.
The
growers
that
have
tried
using
metam
sodium
2
years
in
a
row
had
bad
nematode
infestations
the
second
year
and
will
now
only
use
it
once
every
2
years.
Most
growers
will
not
use
metam
sodium
because
they
must
meet
certification
requirements
(
free
of
nematodes)
for
certain
markets
(
several
U.
S.
states
and
some
international
markets)
(
Gilreath,
2004).

This
fumigant
is
currently
used
and
will
continue
to
be
used
where
it
gives
adequate
pest
control.
It
will
be
unlikely
to
replace
significant
portions
of
current
use
of
methyl
bromide.

In
California,
limitations
to
chloropicrin
include
buffer
zones,
poorer
weed
control
than
methyl
bromide,
and
that
it
may
not
currently
be
used
in
greenhouses.
There
is
reluctance
to
use
chloropicrin
in
many
areas
due
to
the
proximity
of
cut
flower
fields
to
residences.
No.
Page
22
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam
sodium
+
crop
rotation
In
California,
limitations
to
metam
sodium
include
buffer
zones,
greenhouse
uses
are
not
labeled,
and
plant
back
restrictions.
In
addition,
many
years
of
research
have
indicated
difficulty
achieving
consistent
efficacy
with
metam
sodium
on
high
value
crops.

Metam
sodium
is
used
by
some
growers
of
caladiums
in
rotation
with
methyl
bromide.
The
growers
that
have
tried
using
metam
sodium
2
years
in
a
row
had
bad
nematode
infestations
the
second
year
and
will
now
only
use
it
once
every
2
years.
Most
growers
will
not
use
metam
sodium
because
they
must
meet
certification
requirements
(
free
of
nematodes)
for
certain
markets
(
several
U.
S.
states
and
some
international
markets)
(
Gilreath,
2004).

This
fumigant
is
currently
used
and
will
continue
to
be
used
where
it
gives
adequate
pest
control.
It
will
be
unlikely
to
replace
significant
portions
of
current
use
of
methyl
bromide.

In
annual
cropping
they
are
generally
too
short
for
the
full
effects
of
rotating
schemes
to
be
effective.
The
previous
crop
(
bulbs,
corms)
often
contaminate
the
following
crop
or
may
harbor
pathogens.
In
addition,
crop
rotation
is
not
really
a
solution
to
pest
problems
in
floriculture
because
either
the
crop
cycle
is
too
long
(
perennials)
or
the
pests
persist
in
the
soil
for
a
long
time
(
Pizano,
2001).
No.

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

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

ORNAMENTALS
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Herbicides
and
fumigation
with
methyl
bromide,
1,3­
D
and
chloropicrin,
metam
sodium
and
chloropicrin
Caladium
­
All
were
effective
for
weeds
but
positive
results
may
have
been
influenced
by
previous
years
of
MB
fumigation
(
Gilreath,
et
al,
1999).
However,
there
was
control
on
Fusarium
and
only
MB
reduced
Pythium.
Herbicides
are
more
feasible
for
perennials
if
they
are
registered.
The
short
time
interval
between
crops
(
a
crop
may
only
take
90
days)
often
restricts
the
use
of
herbicides
due
to
replant
intervals
or
phytotoxicity.
Also,
herbicides
are
often
selective
and
there
are
a
limited
number
registered.

Hot
water
dips
Caladium
rhizomes
are
cleaned
with
hot
water
dips
(
121­
122F
for
30
minutes).
A
fungicide/
bactericide
dip
may
follow.
Some
growers
may
spray
the
rhizomes
with
a
fungicide
to
protect
them
from
diseases.
The
hot
water
dip
is
effective
at
reducing
root
knot
nematode
on
the
rhizomes
but
fumigation
is
needed
to
maintain
the
control.
Controlling
Fusarium
on
the
rhizomes
will
not
control
losses
if
the
soil
is
contaminated
by
the
previous
year's
pests.
Page
23
Sodium
azide
Preliminary
results
in
a
calla
trial
suggest
that
sodium
azide
may
not
be
a
feasible
alternative
in
this
crop
due
to
reduced
crop
vigor
and
increased
mortality
(
Gerik,
2003).

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

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

Iodomethane
Not
registered
Yes
Unknown
Sodium
azide
Not
registered
Registration
package
not
submitted
Unknown
Propargyl
bromide
Not
registered
Registration
package
not
submitted
Unknown
ORNAMENTALS
­
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
Preplant
Pest
Management
in
Ranunculus
Production
(
Elmore
et
al.,
2003b):
Results
from
this
study
do
not
compare
most
of
the
alternatives
to
methyl
bromide
because
most
of
the
alternatives
were
used
in
higher
moisture
fields
and
methyl
bromide
was
used
in
lower
moisture
fields.
In
lower
moisture
areas,
the
plots
were
treated
with
methyl
bromide/
chloropicrin
or
iodomethane/
chloropicrin.
In
the
higher
moisture
areas,
the
plots
were
treated
dazomet
or
metam
sodium.
In
addition,
these
treatments
were
followed
with
either
Telone
C­
35
or
1,3­
D
plus
chloropicrin.
Controls
were
used
in
both
the
low
and
high
moisture
areas.
Other
treatments
included
drip
applied
metam
sodium,
iodomethane/
chloropicrin,
chloropicrin,
sodium
azide,
or
1­
3­
D
+
chloropicrin,
but
yield
results
are
not
available.
In
all
studies
there
were
no
statistical
differences
between
treatments
in
either
weed
pressure
or
yield
among
the
alternatives.
In
the
lower
moisture
treatments,
there
was
a
34
percent
yield
loss
between
methyl
bromide
and
the
untreated
control.
See
Table
16.1
below
for
more
detail.
The
lack
of
differences
in
the
treatments
is
likely
due
to
the
lack
of
pest
pressure
in
the
higher
moisture
fields.
The
higher
moisture
fields
needed
for
certain
alternatives
were
only
available
in
areas
not
previously
planted
to
ranunculus,
and
therefore
there
was
not
a
buildup
of
pest
pressure
over
time
(
Mellano,
2003).

Evaluation
of
Alternatives
to
Methyl
Bromide
for
Floriculture
Crops
(
Gerik,
2003):
In
Trial
1,
the
following
chemical
treatments
were
evaluated:
untreated
control;
sodium
azide
(
112
kg
ai/
ha);
furfural
50%
+
metam
sodium
50%
(
672
kg
ai/
ha);
1,3­
dichloropropene
(
272
kg/
ha);
1,3­
dichloropropene
65%
+
chloropicrin
35%
(
627
kg/
ha);
iodomethane
50%
+
chloropicrin
50%
(
336
kg/
ha);
iodomethane
33%
+
chloropicrin
66%
(
448
kg/
ha);
chloropicrin
(
448
kg/
ha).
Drip
applications
were
used
in
all
treatments.
Sachets
with
malva
and
mustard
seed,
and
nutsedge
and
calla
rhizomes
were
buried
in
the
plots
before
treatment
to
evaluate
weed
control
efficacy.
None
of
the
treatments
killed
the
malva
seeds.
Chloropicrin
controlled
the
nutsedge
and
calla
rhizomes.
Mustard
seed,
Pythium
spp.
and
Fusarium
oxysporum
were
controlled
or
reduced
by
all
treatments
compared
to
the
untreated
control,
in
addition
to
overall
weed
emergence.
Sodium
azide
was
the
only
chemical
treatment
that
did
not
reduce
Phytophthora
spp.
populations
and
resulted
in
reduced
crop
vigor
and
mortality
in
the
planted
calla.
At
the
time
of
the
report,
there
were
plans
to
collect
additional
data
in
the
fall.
Page
24
In
Trial
3,
the
following
treatments
were
evaluated:
1)
untreated
control;
2)
Multiguard
Protect/
Metham
50/
50
672
kg/
ha;
3)
Sodium
Azide
112
kg/
ha;
4)
Multiguard
FFA;
5)
Vapam
935
L/
ha;
6)
Chloropicrin
336
kg/
ha;
7)
Inline
468
L/
ha;
8)
Iodomethane/
Chloropicrin
30/
70
448
kg/
ha
(
Midas).
The
crop
in
this
trial
was
Liatris.
With
the
exception
of
iodomethane/
chloropicrin
and
the
control,
the
alternatives
controlled
Pythium.
The
alternatives,
except
iodomethane/
chloropicrin,
chloropicrin,
and
the
control,
controlled
Fusarium.
Weed
control
was
comparable
among
the
alternatives
in
most
cases,
with
Multiguard
FFA
and
the
control
providing
the
least
level
of
control.
Although
iodomethane/
chloropicrin
did
not
control
pathogens,
it
is
suspected
that
it
may
be
due
to
an
application
malfunction.
At
harvest,
there
was
no
significant
difference
in
yield
(
stems/
m
²
)

Several
trials
were
in
progress
at
the
time
of
the
report
and
not
all
of
the
trials
are
discussed
here.
Page
25
ORNAMENTALS
 
RANUNCULUS
­
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDS
KEY
PEST:
WEEDS
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
REPS
WEED
CONTROL
(
WEED
COUNTS
PER
5
SQUARE
FEET)
#
OF
REPS
ACTUAL
YIELDS
(
TOTAL
BUNCHES)

Lower
moisture
areas
Malva
Clover
Methyl
bromide/
chloropicrin
(
50:
50)
358
kg/
ha
4
0.8
b
55.5
4
431.8
a
Iodomethane/
chlorpicrin
(
50:
50)
336
kg/
ha
4
0.5
b
61.1
4
457.6
a
Iodomethane/
chloropicrin
(
50:
50)
392
kg/
ha
4
0.5
b
43.6
4
426.5
a
Untreated
 
tarped
4
2.1
a
62.5
4
287.0
b
Higher
moisture
areas
Metam
sodium
+
Telone
C­
35
358
kg/
ha
+
327
L/
ha
4
2.0
b
6.2
4
353.2
Metam
sodium
+
1,3­
D
+
chloropicrin
358
kg/
ha
+
140
L/
ha
+
224
kg/
ha
4
2.1
b
4.5
4
357.0
Metam
sodium
358
kg/
ha
4
3.1
b
3.2
4
357.3
Dazomet
+
Telone
C­
35
224
kg/
ha
+
327
L/
ha
4
2.8
b
6.1
4
358.3
Dazomet
+
1,3­
D
+
chloropicrin
224
kg/
ha
+
140
L/
ha
+
224
kg/
ha
4
2.1
b
5.5
4
332.5
Untreated
 
tarped
4
7.8
a
6.8
4
348.3
Elmore
et
al.,
3003b
ORNAMENTALS
 
RANUNCULUS
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDS
KEY
PEST:
WEEDS
IN
RANUNCULUS
WEED
CONTROL
AND
RANUNCULUS
VIGOR
AFTER
PREPLANT
DRIP
APPLICATION
OF
PESTICIDES
IN
SANDY
SOIL
DISEASE
(%
OR
RATING)
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
REPS
CLOVER
(#/
LINEAR
M)
TOTAL
WEEDS
(#/
LINEAR
M
#
OF
REPS
PLANT
VIGOR*

Metam
sodium
364
kg/
ha
6
13.5
a
13.7
a
6
9.2
ab
Iodomethane/
chloropicrin
392
kg/
ha
6
15.3
a
15.3
a
6
8.7
b
Chloropicrin
168
kg/
ha
6
9.7
a
10.3
a
6
9.7
ab
Chloropicrin
336
kg/
ha
6
12.8
a
13.3
a
6
9.7
ab
Sodium
azide
112
kg/
ha
6
12.2
a
12.2
a
6
8.7
b
1,3­
D/
chloropicrin
168
kg/
ha
6
11.5
a
11.5
a
6
10.0
a
1,3­
D/
chloropicrin
336
kg/
ha
6
8.3
a
8.3
a
6
9.5
ab
Untreated­
tarped
6
15.3
a
16.8
a
6
6.0
c
(
Elmore
et
al.,
2003a)
*
Visual
evaluation:
10
=
vigorous,
0
=
dead
Page
26
ORNAMENTALS
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
Yield
losses
will
vary
by
species
but,
based
on
expert
opinion
for
the
two
representative
crops,
ranunculus
and
caladiums,
an
estimate
has
been
determined.
The
experts
are
a
cut
flower
producer
and
a
researcher
located
in
different
areas
of
the
country.
Based
on
grower
experience,
it
is
estimated
that
10
to
35
percent
yield
losses
could
occur
without
methyl
bromide.
These
yield
losses
may
be
higher
in
highly
diseased
fields.
Quality
is
also
a
major
concern
for
the
industry.
In
addition,
ranunculus
exported
to
Japan,
Canada,
and
Europe
need
a
certificate
stating
that
it
has
been
grown
in
manner
not
conducive
to
certain
diseases,
which
generally
means
in
a
field
fumigated
with
methyl
bromide.
Even
in
crops
without
these
regulations,
consumers
expect
a
high
quality
product.
Selling
a
product
that
is
not
of
high
quality
will
cause
growers
to
lose
customers.
There
are
some
promising
alternatives
for
many
crops,
but
more
time
is
needed
to
determine
what
particular
alternatives
will
work
with
individual
crops
to
meet
customer
standards
and
avoid
yield
losses
if
methyl
bromide
can
no
longer
be
used
(
Mellano,
2003).
In
ranunculus,
a
50
percent
yield
loss
(
flowers
and
tubers)
can
occur
due
to
soil
pathogens
(
Elmore
et
al.,
2003b).
The
situation
is
similar
for
caladiums.
Studies
conducted
on
caladiums
did
not
necessarily
show
yield
or
quality
losses
but
any
losses
would
depend
on
pest
populations.
Herbicides
were
also
used
to
control
weeds
that
wouldn't
be
controlled
by
the
fumigant
alone.
In
the
first
year,
growers
may
experience
a
5%
reduction
in
the
number
of
tubers
in
the
most
desirable
size
grades,
with
a
30%
reduction
in
production
in
the
second
year
possible.
Losses
are
not
likely
to
exceed
35
to
40%.
Growers
will
likely
find
successful
alternatives
but
more
time
is
needed
to
transition
to
these
alternatives
(
Gilreath,
2004).

Currently,
the
applicants
do
not
consider
any
alternative
to
be
a
feasible
replacement
for
methyl
bromide
in
this
diverse
sector.
However,
in
an
attempt
to
provide
an
estimate
the
potential
impacts
from
the
adoption
of
the
most
common
methyl
bromide
alternatives,
the
following
table
presents
likely
yield
losses.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
plus
chloropicrin
Nematodes
and
Diseases
(
no
control
of
weeds
or
previous
crop)
10
to
25
%
25%

Dazomet
Multiple
25%
Metam
Sodium
Multiple
20%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
20
to
25%

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

Research
is
currently
being
conducted
to
identify
potential
alternatives.
Page
27
ORNAMENTALS
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

A
number
of
technologies
are
currently
being
used
in
this
sector,
including
integrated
pest
management,
crop
rotation,
fallow
periods,
hand
weeding,
etc.
However,
these
practices
are
still
not
sufficient
to
control
the
key
target
pests
without
the
use
of
methyl
bromide.

ORNAMENTALS
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Without
methyl
bromide,
certain
growers
will
suffer
both
yield
and
quality
losses.
In
addition
growers
who
rotate
several
species
of
ornamentals
on
a
particular
field,
need
to
kill
crop
residue
from
previous
crops
to
eliminate
contamination,
as
well
as
control
other
weeds
and
pathogens.
Due
to
the
diversity
and
complexity
of
the
cut
flower
and
foliage
industry,
an
additional
2
to
3
years
are
needed
to
complete
ongoing
research
into
implementation
of
methyl
bromide
alternatives.
Alternatives
have
not
been
found
for
all
species.
Some
of
the
alternatives
that
have
been
found
for
other
crops
(
such
as
1,3­
D
for
Easter
lilies
in
Oregon)
may
not
be
feasible
for
floriculture
in
general
because
of
high
cost,
difficulties
with
quickly
treating
and
replanting
fields
for
multi­
cropping,
and
buffer
zone
requirements.
In
addition,
township
caps
limit
the
use
of
1,3­
Dichloropropene
in
California.
Other
alternatives
provide
inconsistent
control
or
have
restrictions
that
limit
their
use
at
this
time.
Growers
also
need
time
to
transition
to
the
alternatives.

In
this
industry,
the
fumigation
situation
and
need
for
methyl
bromide
varies
by
species.
Although
there
are
some
potential
alternatives,
there
is
not
enough
grower
experience
and
research
to
justify
to
switching
to
alternatives
by
the
2006
growing
season.
Page
28
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE:

TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Currently
some
growers
use
HDPE
tarps.
Some
growers
have
switched
from
a
98%
MB
formulation
to
a
67
%
formulation.
Unknown.
unknown
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
density
films.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
lowering
methyl
bromide
dosages..
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
increasing
the
chloropicrin
percentage.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
Water
seals
of
newer
products
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
In
accordance
with
the
criteria
of
the
critical
use
exemption,
each
party
is
required
to
describe
ways
in
which
it
strives
to
minimize
use
and
emissions
of
methyl
bromide.
The
use
of
methyl
bromide
in
ornamental
production
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
that
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
application
is
most
often
machine
injected
into
soil
to
specific
depths.

As
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
95%
Page
29
methyl
bromide
and
5%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
at
low
to
moderate
levels
of
infestation,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.

Tarpaulin
(
high
density
polyethylene)
is
also
used
to
minimize
use
and
emissions
of
methyl
bromide.
In
addition,
cultural
practices
are
utilized
by
ornamental
growers.

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.
Page
30
PART
E:
ECONOMIC
ASSESSMENT
Please
note
that
in
this
study
net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
for
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
is
smaller
than
the
net
revenue
measured
in
this
study,
often
substantially
so.
We
did
not
include
fixed
costs
because
they
are
difficult
to
measure
and
verify.

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
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
3,607
3,607
3,607
Dazomet
75
3,900
3,900
3,900
1,3­
d
+
pic
75
3,500
3,500
3,500
Metam
Sodium
80
3,607
3,607
3,607
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
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
25,918
11,257
Dazomet
18,467
3,933
1,3­
d
+
pic
18,459
4,425
Metam
Sodium
20,735
6,547
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
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
25,918
11,257
Dazomet
18,467
3,933
1,3­
d
+
pic
18,459
4,425
Metam
Sodium
20,735
6,547
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
Page
31
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
25,918
11,257
Dazomet
18,467
3,933
1,3­
d
+
pic
18,459
4,425
Metam
Sodium
20,735
6,547
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CUT
FLOWERS
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CUT
FLOWERS
METHYL
BROMIDE
Dazomet
1,3­
D
+
Pic
Metam
Sodium
YIELD
LOSS
(%)
0
25
%
25%
20%

YIELD
PER
HECTARE
187
157
157
168
*
PRICE
PER
UNIT
(
U.
S.$)
138.38
131.46
131.46
138.38
=
GROSS
REVENUE
PER
HECTARE
(
U.
S.$)
25,918
18,467
18,459
20,735
­
OPERATING
COSTS
PER
HECTARE
(
U.
S.$)
14,391
14,534
14034
14,188
=
NET
REVENUE
PER
HECTARE
(
U.
S.$)
11,527
3,933
4,425
6,547
1.
LOSS
PER
HECTARE
(
U.
S.$)
$
0
7,594
7,102
4,980
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
U.
S.$)
$
0
16.94
15.84
11.11
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
29%
27%
19%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
66%
62%
43%
Page
32
SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
evaluated
methyl
bromide
alternative
control
scenarios
for
cut
flower
production
for
Florida,
and
California
by
comparing
the
economic
outcomes
of
methyl
bromide
oriented
production
systems
to
those
using
alternatives.
However,
due
to
the
fact
that
there
are
over
100
species
of
ornamentals
grown
in
all
regions
of
the
country,
the
data
from
these
two
examples
are
used
to
derive
a
proxy
estimate
for
the
entire
industry.

The
economic
factors
that
most
influence
the
feasibility
of
methyl
bromide
alternatives
for
fresh
cut
flower
production
are:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
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,
and
(
3)
missed
market
windows
due
to
plant
back
time
restrictions,
which
also
affect
the
quantity
and
price
received
for
the
goods.

The
economic
reviewers
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)
Loss
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.

(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
nominal
marginal
value
of
methyl
bromide
to
crop
production.

(
3)
Loss
as
a
Percentage
of
Gross
Revenue.
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.

(
4)
Loss
as
a
Percentage
of
Net
Operating
Revenue.
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)
Operating
Profit
Margin.
We
define
operating
profit
margin
to
be
net
operating
revenue
divided
by
gross
revenue
per
hectare.
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,
therefore
fixed
costs
were
not
included
in
the
analysis.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
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
Page
33
determination.

Several
methodological
approaches
will
help
interpret
the
findings.
Economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
Costs
for
alternatives
are
based
on
market
prices
for
the
control
products
multiplied
by
the
number
of
pounds
of
active
ingredient
that
would
be
applied.
Baseline
costs
were
based
on
the
average
number
of
annual
applications
necessary
to
treat
cut
flowers
with
methyl
bromide.

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

Loss
per
hectare
measures
the
value
of
methyl
bromide
based
on
changes
in
operating
costs
and/
or
changes
in
yield.
Loss
expressed
as
a
percentage
of
the
gross
revenue
is
based
on
the
ratio
of
the
revenue
loss
to
the
gross
revenue.
Likewise
for
the
loss
as
a
percentage
of
net
revenue.
The
profit
margin
percentage
is
the
ratio
of
net
revenue
to
gross
revenue
per
hectare.
The
values
to
estimate
gross
revenue
and
the
operating
costs
for
each
alternative
were
derived
for
three
alternative
control
scenarios
for
Florida
and
California,
relative
to
methyl
bromide:
1)
Dazomet;
2)
1,3­
d
+
chloropicrin;
and
3)
metam
sodium.
Yield
loss
estimates
were
based
on
data
from
the
CUE's
and
U.
S.
EPA
data,
as
well
as
expert
opinion.

Regulatory
constraints.
In
California,
1,3­
d
plus
chloropicrin
would
also
be
the
primary
replacement
for
methyl
bromide.
California
restricts
total
use
of
1,3­
d,
at
the
local
level
(
township
cap).
In
Florida,
the
use
of
1,3­
d
also
requires
a
100­
foot
buffer
around
inhabited
structures.
This
would
reduce
the
production
acreage
an
estimated
10%.
Nematodes
and
weeds
and
pathogens
are
key
pests
in
Florida
and
California
bulb
grower
and
are
controlled
with
methyl
bromide.
Chloropicrin
is
not
as
effective
in
controlling
weeds
as
methyl
bromide.
Using
chloropicrin
adds
to
production
costs
through
increased
chemical,
weeding
and
labor
costs.

Alternative
1
(
Dazomet),
yield
loss
was
estimated
to
be
25%,
and
gross
revenues
are
expected
to
decline
29%
and
prices
offset
by
05%,
if
growers
miss
key
market
windows.
Buffer
restrictions
would
also
reduce
gross
revenues
but
the
number
of
acres
affected
to
estimate
the
impact
is
not
available.
The
estimated
net
revenue
is
estimated
to
decline
more
than
66%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
16.94
per
kilogram.

Under
alternative
2
(
1,3­
d
plus
chloropicrin),
the
yield
loss
was
also
estimated
to
be
25
%
and
prices
offset
by
05%,
if
growers
miss
key
market
windows
due
to
increased
re­
entry
interval
time.
Buffer
restrictions
would
also
reduce
gross
revenues
but
the
number
of
acres
affected
to
estimate
the
impact
is
not
available.
Gross
revenue
is
expected
to
decline
27%.
The
net
revenue
is
expected
to
decline
by
more
than
62%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
15.84
per
kilogram.
Page
34
Under
alternative
3
(
metam
sodium),
there
is
no
expected
plant
back
restriction
as
the
re­
entry
interval
increases
by
2
days
so
the
yield
loss
was
estimated
to
be
20%,
and
the
gross
revenue
loss
was
estimated
to
by
19%.
The
net
revenue
is
expected
to
decline
by
more
than
43%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
11.11
per
kilogram.

Note:
Market
price
data
was
not
available
for
the
United
States
cut
flower
industry
but
it
is
assumed
that
the
net
effect
of
shifting
from
methyl
bromide
to
any
of
the
alternatives
other
than
metam
sodium
would
result
in
additional
revenue
reductions
due
fluctuations
in
market
price
due
to
changes
in
production
and
harvesting
times.

It
should
be
noted
that
the
applicants
do
not
consider
any
alternative
to
be
feasible
and
that
these
estimates
are
an
attempt
to
measure
potential
impacts.
Page
35
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Between
1992
and
2003,
the
California
Cut
Flower
Commission
has
spent
$
260,000
in
research
related
to
methyl
bromide
alternatives
in
addition
to
hundreds
of
thousands
of
dollars
spent
by
individual
growers
trying
to
find
workable
alternatives.
Future
research
will
focus
on
the
following
pests:
weeds,
Fusarium
oxysporum,
Pythium
spp.,
Meloidogyne
spp.,
and
previous
crop
debris,
such
as
bulblets,
cormlets,
etc.
from
crops
such
as
callas,
caladiums,
and
gladiolus.
1,3­
D,
metam
sodium,
dazomet,
chloropicrin,
and
methyl
iodide
have
already
been
tested.
Future
research
will
focus
on
methyl
iodide,
sodium
azide,
combinations
of
1,3­
D,
metam
sodium,
and
chloropicrin,
and
drip
applied
chloropicrin.
The
reason
to
transition
away
from
methyl
bromide
has
been
ongoing
for
10
years
and
should
be
completed
by
the
end
of
2006.

In
Florida,
research
trials
for
2003
are
in
place
for
caladiums
in
muck,
aster,
and
snapdragons,
and
caladiums
in
sand
are
planned
for
2004.
Several
alternatives
will
be
tested,
including
metam
sodium,
1,3­
D/
chloropicrin,
iodomethane/
chloropicrin,
and
sodium
azide.
In
California,
trials
are
in
place
or
planned
for
callas,
myrtle,
ranunculus,
liatris,
freesia,
and
wax
flower
(
at
a
minimum)
for
several
alternatives.
Additional
funds
($
90,000
for
California
researchers
and
an
unknown
amount
for
Florida)
have
just
been
made
available
via
the
IR­
4
program
to
support
new
work
in
2004.

The
Agricultural
Research
Service
(
United
States
Department
of
Agriculture)
has
two
full
time
employees
(
since
2000)
working
on
methyl
bromide
alternatives
for
flowers
and
ornamentals.
This
represents
about
a
$
600,000
annual
investment.
In
addition,
a
recent
grant
and
other
money,
about
$
100,000
has
provided
two
CCC
grants
for
flower
alternatives.

The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
ornamentals
research
will
require
4060
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
the
research
is
a
five
year
field
study
testing
the
comparative
performance
of
methyl
bromide,
1,3­
D,
metam
sodium,
and
new
reduced
risk
chemicals
for
control
of
soilborne
pests
with
emphasis
on
nematodes
and
weeds.
Page
36
24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

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

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?
Page
37
26.
CITATIONS
Elmore,
C.,
J.
MacDonald,
H.
Ferris,
I.
Zasada,
S.
Tsjvold,
K.
Robb,
C.
Wilen,
L.
Bolkin,
L.
Yahaba,
J.
Roncoroni,
2003a,
Alternatives
to
Methyl
Bromide
for
Control
of
Weeds,
Nematodes,
and
Soil­
Borne
Fungi,
Bacteria
in
Coastal
Ornamental
Crops
 
Draft.

Elmore,
C.,
J.
Roncoroni,
K.
Robb,
C.
Wilen,
and
H.
Ajwa,
2003b,
Preplant
Pest
Production
in
Ranunculus
Production,
Proceeding
from
the
2003
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions,
Web
address:
www.
mbao.
org
Gerik,
J.,
2003,
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Floriculture
Crop
 
Progress
Report
submitted
by
USDA­
ARS.

Gilreath,
J.
P.,
R.
McSorley,
and
R.
J.
McGovern,
1999,
Soil
Fumigant
and
Herbicide
Combinations
for
Soilborne
Pest
Control
in
Caladium,
Proc
Fla
State
Hort
Soc
112:
285­
290.

Gilreath,
J.,
2004,
University
of
Florida
 
IFAS,
Personal
communication.

Mellano,
M,
Mellano
and
Company,
2003,
Personal
communication.

Overman,
A.
J.
and
B.
K.
Harbaugh,
1983,
Soil
Fumigation
Increases
Caladium
Tuber
Production
on
Sandy
Soil,
Proc
Fla
State
Hort
Soc
96:
248­
250.

Pizano,
M.,
2001,
Floriculture
and
the
Environment:
Growing
Flowers
without
Methyl
Bromide,
United
Nations
Environment
Programme.

Ragsdale,
N.,
USDA­
ARS
National
Program
Staff,
2004,
Personal
communication.

Schneider,
S.,
E.
Rosskopf,
J.
Leesch,
D.
Chellemi,
C.
Bull,
and
M.
Mazzola,
2003,
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
Research
on
Alternatives
to
Methyl
Bromide:
Pre­
plant
and
Post­
harvest,
Pest
Manag
Sci
59:
814­
826.

Semer,
C.
R.
IV,
1987,
Basamid
and
Methyl
Bromide
Compounds
as
Fumigants
in
Carnation
and
Chrysanthemum
Production
in
Selected
Propagation
Media,
Proc
Fla
State
Hort
Soc
100:
330­
334.

Trout,
T.,
2001,
Impact
of
Township
Caps
on
Telone
Use
in
California.

Trout,
T.,
2003,
Impact
of
Township
Caps
on
Telone
Use
in
California,
Proc.
Annual
International
Research
Conference
on
MB
Alternatives
and
Emission
Reductions,
p.
109.
Page
38
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2000
Data
%
of
2000
Data
10,702
11%

10,702
11%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
226,796
578
392
0%

226,796
578
392
0%

0%
0%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
392
392
0
0
0
0
44
31
0
0
0
0
Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Conversion
Units:
1
Pound
=
Kilograms
Hectare
20%
or
25%
or
25%
Metam­
Sodium
or
1,3­
D+
Pic
or
Dazomet
HIGH
100%
LOW
100%

Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
Combined
Impacts
(%)

Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
Regional
Hectares**

%
of
Requested
Hectares
MOST
LIKELY
IMPACT
VALUE
0%
0%
5%
5%

226,796
226,796
226,796
%
Reduction
from
Initial
Request
0%
0%
0%
0%
0%
0%

226,796
226,796
226,796
226,796
CUT
FLOWERS
AND
FOLIAGE
0.453592
1
Acre
=
0.404686
HIGH
LOW
226,796
­
­
­
­
226,796
226,796
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

392
60,747
150
404
REGION
REGION
CUT
FLOWERS
AND
FOLIAGE
CUT
FLOWERS
AND
FOLIAGE
Nomination
Amount
Other
Considerations
Adjustments
to
Requested
Amounts
150
404
0%

392
60,747
CUT
FLOWERS
AND
FOLIAGE
226,796
578
2006
Request
REGION
TOTAL
OR
AVERAGE
226,796
578
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
not
available
Date:
2/
26/
2004
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:
not
available
Sector:
ORNAMENTALS
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:
Page
39
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
40
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
41
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
42
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
43
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
Page
44
APPENDIX
C
 
KEY
PESTS
OF
SELECT
CUT
FLOWER
SPECIES
The
following
list
is
not
comprehensive,
but
is
intended
to
demonstrate
the
complexity
of
the
industry.
In
addition
to
the
diseases
and
nematodes
listed
below,
there
are
numerous
weed
species
that
are
major
problems
in
cut
flower
production.
These
species
include
the
bulbs,
tubers,
or
cormlets
from
a
previous
crop,
yellow
nutsedge
(
Cyperus
esculentus),
little
mallow
(
Malva
parviflora),
and
common
sow
thistle
(
Sonchus
oleracea).

Diseases
and
Nematodes
of
cut
flower
crops
currently
controlled
with
Methyl
Bromide.
Crop
Key
Pests
Scientific
name
Nematodes
Belanolaimus
longidorus,
Criconomella
spp.,
Dolichodorus
heterocephalus
Antirrhinum
Pythium
root
rot
Pythium
irregulare
(
documented
resistance
to
mefenoxam
is
25­
50%)
Erwinia
soft
rot
Erwinia
carotovora
Calla
lily
Pythium
root
rot
Pythium
spp.
(
resistance
to
mefenoxam
suspected
to
be
widespread
Delphinium
Sclerotinia
stem
rot
Sclerotinia
spp.
Dianthus
Fusarium
wilt
Fusarium
oxysporum
fsp.
dianthii
Eustoma
Fusarium
wilt,
root
rot,
and
stem
rot
Fusarium
oxysporum,
F.
solani,
and
F.
avenaceaum
Freesia
Fusarium
wilt
Fusarium
spp.
Fusarium
wilt
Fusarium
oxysporum
fsp.
gladioli
Gladiolus
Stromatinia
neck
rot
Stromatinia
gladioli
Helianthus
Downy
mildew
Plasmopara
halstedii
(
this
is
a
soil­
borne
pathogen)
Root
knot
nematode
Meloidogyne
spp.
Hypericum
Pythium
root
rot
Pythium
spp.
Iris
Fusarium
wilt
Fusarium
oxysporum
fsp.
iridis
Larkspur
Sclerotinia
stem
rot
Sclerotinia
sclerotiorum
Liatris
spicata
Sclerotinia
stem
rot
Sclerotinia
sclerotiorum
Lilium
Pythium
root
rot
Pythium
spp.
Sclerotinia
stem
rot
Sclerotinia
sclerotiorum
Matthiola
Xanthomonas
leaf
spot
Xanthomonas
campestris
pv.
campestris
Pythium
root
rot
Pythium
spp.
Ranunculus
Xanthomonas
leaf
spot
Xanthomonas
campestris
