METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
TOBACCO
TRANSPLANT
SEED
BEDS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
(
U.
S.)

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

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
ii
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
.....................................................................................................................
5
1.
Nominating
Party
_________________________________________________________
5
2.
Descriptive
Title
of
Nomination______________________________________________
5
3.
Crop
and
Summary
of
Crop
System___________________________________________
5
4.
Methyl
Bromide
Nominated
_________________________________________________
5
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
6
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
7
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
7
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________
9
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region____________________________________________________________________
9
Tobacco
Transplant
Beds
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE........
11
Tobacco
Transplant
Beds
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
11
Tobacco
Transplant
Beds
­
11.
Characteristics
of
Cropping
System
and
Climate_________
11
Tobacco
Transplant
Beds
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
13
TOBACCO
TRANSPLANT
BEDS
­
PART
C:
TECHNICAL
VALIDATION..............................................
14
Tobacco
Transplant
Beds
­
13.
Reason
for
Alternatives
Not
Being
Feasible
____________
14
Tobacco
Transplant
Beds
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
15
Tobacco
Transplant
Beds
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_____________________________________________
16
Tobacco
Transplant
Beds
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________________________________________
16
Tobacco
Transplant
Beds
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
17
Tobacco
Transplant
Beds
­
Summary
of
Technical
Feasibility
_______________________
17
PART
D:
EMISSION
CONTROL
.....................................................................................................
18
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
18
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
18
PART
E:
ECONOMIC
ASSESSMENT...............................................................................................
20
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
20
22.
Gross
and
Net
Revenue___________________________________________________
20
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
21
Summary
of
Economic
Feasibility
_____________________________________________
21
PART
F.
FUTURE
PLANS
.............................................................................................................
24
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
24
iv
25.
Additional
Comments
on
the
Nomination
____________________________________
25
26.
Citations
______________________________________________________________
26
Citations
Reviewed
but
Not
Applicable
_________________________________________
26
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.

LIST
OF
TABLES
PART
A:
SUMMARY........................................................................................................................
5
Table
4.1:
Methyl
Bromide
Nominated
.......................................................................................
5
Table
A.
1:
Executive
Summary...................................................................................................
6
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide....................................................
7
Tobacco
Transplant
Beds
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
...
9
Table
A.
3:
2005
Sector
Nomination..........................................................................................
10
Table
A.
3:
2006
Sector
Nomination..........................................................................................
10
TOBACCO
TRANSPLANT
BEDS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE..........
11
Tobacco
Transplant
Beds
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request...............................................................................................................
11
Tobacco
Transplant
Beds
­
Table
11.1:
Characteristics
of
Cropping
System
.............................
11
Tobacco
Transplant
Beds
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
...............
12
Tobacco
Transplant
Beds
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
...................
13
TOBACCO
TRANSPLANT
BEDS
­
PART
C:
TECHNICAL
VALIDATION
...................................................
14
Tobacco
Transplant
Beds
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
................
14
Tobacco
Transplant
Beds
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion............
15
Tobacco
Transplant
Beds
 
Table
15.1:
Present
Registration
Status
of
Alternatives
..................
16
Tobacco
Transplant
Beds
 
Table
16.1:
Effectiveness
of
Alternatives
 
Phytophthora
parasitica
nicotianae
.........................................................................................................................
16
Tobacco
Transplant
Beds
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
........................
17
PART
D:
EMISSION
CONTROL.......................................................................................................
18
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
................................
18
PART
E:
ECONOMIC
ASSESSMENT.................................................................................................
20
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period................
20
Table
22.1:
Year
1
Gross
and
Net
Revenue
...............................................................................
20
Table
22.2:
Year
2
Gross
and
Net
Revenue
...............................................................................
20
Table
22.3:
Year
3
Gross
and
Net
Revenue
...............................................................................
20
Tobacco
Transplant
Beds
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives.......
21
PART
F.
FUTURE
PLANS
..............................................................................................................
24
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
..................................
28
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
Tobacco
Transplant
Seed
Beds
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Tobacco
is
seeded
into
soil
beds
or
cold
frames
and
later
transplanted
to
the
production
field
when
plants
reach
a
height
of
five
to
seven
inches.
Seedling
beds
are
located
on
well­
drained
sites
that
have
been
well
cleared
of
weeds
and
trash.
Sloping
beds
on
southern
exposure
produce
the
strongest
transplants.
The
seedling
bed
should
be
manured
the
previous
fall,
shallow­
tilled,
and
planted
to
a
cover
crop
if
possible.
This
cover
crop
should
be
incorporated
in
early
spring,
well
in
advance
of
seeding.

Most
farms
have
moved
to
floating
transplant
tray
seedling
production,
however,
not
all
farms
have
adopted
transplant
tray
seedling
production
and
others
have
returned
to
soil
bed
production
after
encountering
serious
disease
losses
in
the
float
system.
Fall
seed
bed
fumigation
with
methyl
bromide
is
recommended
for
better
disease
control,
but
is
impractical
due
to
the
serious
problem
of
recontamination
of
the
beds
with
the
long
period
between
fumigation
and
seeding.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
16,431
27
Page
6
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
Methyl
bromide
is
still
important
for
tobacco
transplant
seedbeds
to
ensure
pathogen
free
crop
production.
Registered
alternative
fungicides
are
not
effective
against
the
full
range
of
pathogens
common
for
tobacco
production.
In
addition,
use
of
alternative
fungicides
during
transplant
production
could
potentially
limit
usefulness
in
field
production
due
to
fungicide
resistance
issues.
Loss
of
methyl
bromide
would
undermine
integrated
pest
management
strategies
aimed
at
resistance
management.
The
registered
alternative
soil
fumigants
have
constraints
that
could
jeopardize
production.
If
used
late
season,
after
harvest,
soil
borne
pathogens
have
very
high
potential
to
re­
infect
the
treated
area
through
the
uncontrollable
actions
of
wind,
rain,
and
wildlife.
Use
of
the
same
soil
fumigants
immediately
prior
to
seeding
is
compromised
by
cold
soil
temperature.
Due
to
the
long
aeration
period
required
when
using
the
alternative
soil
fumigants,
early
transplant
dates
are
not
possible
(
a
critical
tool
in
yield
and
disease
management).
Even
under
the
best
of
conditions,
spring
use
of
alternatives
will
delay
seeding
date
compared
with
methyl
bromide
by
three
weeks
and
almost
insures
a
June
transplanting
date
rather
than
a
May
transplanting
date.
Delayed
seeding
and
transplanting
results
in
crop
exposure
to
higher
disease
pressure
and
drought
conditions.

TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
Tobacco
Transplant
Beds
Amount
of
Nomination
2006
Kilograms
16,431
Application
Rate
(
kg/
ha)
611
Area
(
ha)
27
Amount
of
Applicant
Request
2005
Kilograms
16,431
Application
Rate
(
kg/
ha)
611
Area
(
ha)
27
2006
Kilograms
16,431
Application
Rate
(
kg/
ha)
611
Area
(
ha)
27
Economics
Marginal
Strategy
Metam
Sodium
Yield
Loss
(%)
46
Loss
per
hectare
(
US$/
ha)
4,612
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
1,371.62
Loss
as
%
of
Gross
Revenue
(%)
45%

Loss
as
%
of
Net
Revenue
(%)
71%
Page
7
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Most
of
these
are
small
farms
without
other
economically,
sustainable
cropping
options.
Spring
applications
of
dazomet
and
metam
sodium
are
not
acceptable
for
early
transplanting
dates
due
to
long
aeration
periods.
If
spring
applications
of
alternative
fumigants
are
made,
the
seeding
date
may
be
shifted
as
far
as
April
in
most
growing
regions
and
as
far
as
June
in
Kentucky.
The
later
the
crop
is
transplanted
the
greater
risk
from
drought
and
diseases.
Fall
fumigation
with
most
products
gives
better
control
of
some
pests,
and
would
be
desirable
if
not
for
the
recontamination
issue
with
pathogens
that
have
rapid
rates
of
reproduction
(
eg.
black
shank
pathogen).
Consequently,
growers
need
to
fumigate
using
methyl
bromide
within
a
week
of
seeding
the
bed
to
reduce
the
chance
of
recontamination.
Spring
weather
in
much
of
the
production
area
during
many
seasons
provides
only
short
windows
for
soil
conditions
to
favor
fumigation
and
seeding.
Therefore,
the
short
interval
between
fumigation
opportunity
and
seeding
opportunity
(
2
days
to
a
week)
requires
materials
with
a
short
fumigation­
aeration
period
to
fit
into
practical
farming
operations.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
(
if
particular
agricultural
or
political
regions
only
use
methyl
bromide,
provide
local
data
as
well
as
national
figures):

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

Tobacco
Transplant
Beds
Not
available.
Not
available
because
of
overlapping
use
of
field
and
tray
grown
transplants.

NATIONAL
TOTAL:
Not
available.
Not
available.

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.

Methyl
bromide
is
only
used
to
eliminate
pathogens
in
transplant
seedbeds.
A
typical
farm
is
4
acres
in
size
with
only
0.06
acres
of
transplant
beds
treated
with
methyl
bromide.
Only
seedbeds
are
fumigated
to
ensure
healthy
seedlings
for
transplant
into
production
fields.
Since
1990
the
burley
and
dark
tobacco
industry
has
been
transitioning
transplant
production
from
traditional
ground
beds
to
containerized
production
in
a
float
system.
Page
8
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?

Even
if
there
were
no
restrictions
on
methyl
bromide
use,
traditional
plant
beds
use
would
have
already
completely
disappeared
and
been
replaced
with
containerized
transplants
if
the
increased
disease
potentials
were
not
already
a
serious
threat
to
the
sustainability
of
that
method
of
transplant
production.
Some
growers
that
abandoned
plant
beds
for
the
float
system
are
returning
to
ground
beds
for
all
or
a
portion
of
the
crop.
The
industry
is
still
trying
to
sort
this
issue
out,
while
under
going
serious
economic
pressures
unrelated
to
the
issue
of
fumigation
and
transplants.
Therefore,
if
acceptable
methods
are
developed
to
greatly
reduce
the
greater
disease
potential
of
containerized
transplants
produced
in
the
float
system
while
maintaining
the
feasibility
of
the
float
system,
the
traditional
ground
beds
should
disappear
as
a
production
method.
Page
9
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TOBACCO
TRANSPLANT
BEDS
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Tobacco
Transplant
Beds
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
16,431
16,431
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Bed
Bed
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
98/
2
98/
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
27
ha
27
ha
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
623
623
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
62.3
62.3
APPLICATION
RATE
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
611
611
DOSAGE
RATE*
(
G/
M2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
61.1
61.1
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

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

The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:

 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure
and
cold
soil
temperatures
in
limited
production
regions.
 
All
other
adjustments
to
the
methyl
bromide
nominated
amount
(
e.
g.,
growth,
regulatory
impacts,
etc.)
did
not
apply
to
this
sector.
Page
10
TABLE
A.
2:
2005
SECTOR
NOMINATION*

2005
(
Sector)
Nomination
Tobacco
Transplant
Beds
Requested
Hectares
(
ha)
27
Requested
Application
Rate
(
kg/
ha)
611
Applicant
Request
for
2005
Requested
Kilograms
(
kg)
16,431
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
TABLE
A.
3:
2006
SECTOR
NOMINATION*

2006
(
Sector)
Nomination
Tobacco
Transplant
Beds
Requested
Hectares
(
ha)
27
Requested
Application
Rate
(
kg/
ha)
611
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
16,431
Nominated
Hectares
(
ha)
27
Nominated
Application
Rate
(
kg/
ha)
611
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
16,431
Overall
Reduction
(%)
0%
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
16,431
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
11
TOBACCO
TRANSPLANT
BEDS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
TOBACCO
TRANSPLANT
BEDS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
TOBACCO
TRANSPLANT
BEDS
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Tobacco
Transplant
Beds
Phytophthora
parasitica
nicotianae
Pythium
spp.

Rhizoctonia
spp.
No
effective
fungicides
registered*

*
Mefenoxam­
containing
fungicides
which
were
used
in
seedbeds
for
many
years
to
aid
in
Phytophthora
and
Pythium
control
were
removed
from
the
labels
in
recent
years
due
to
resistance
issues.

TOBACCO
TRANSPLANT
BEDS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
TOBACCO
TRANSPLANT
BEDS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
TOBACCO
TRANSPLANT
BEDS
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
(
1
year)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Not
Applicable
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Medium
organic
sandy
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Yearly
OTHER
RELEVANT
FACTORS:
Growers
normally
prepare
the
bed
site
only
a
few
days
prior
to
fumigating,
plant
within
a
week,
and
harvest
transplants
6­
12
weeks
later,
depending
upon
growing
conditions.
This
is
done
to
reduce
the
risk
of
contaminating
the
seedbed
due
to
a
relatively
long
interval
between
fumigation
and
seeding.
Page
12
TOBACCO
TRANSPLANT
BEDS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
CLIMATIC
ZONE
USDA
plant
hardiness
zone
5a­
8b.

RAINFALL
(
mm)
60.7
34.8
192.5
134.1
109.0
68.7
44.7
74.2
138.2
165.6
126.7
103.6
OUTSIDE
TEMP.
(
°
C)
3.2
3.2
6.9
14.3
16.2
23.6
26.2
25.6
22.3
13.3
5.9
2.0
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
X
*
Kentucky
data
provided
as
representative
of
the
growing
region
TOBACCO
TRANSPLANT
BEDS
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

The
cold
temperatures
during
February
through
April
constrain
the
use
of
metam
sodium
and
dazomet
as
soil
fumigants.
Cold
soil
temperature
prevents
early
transplanting
dates
due
to
the
long
aeration
period
required
for
full
activity
and
to
avoid
major
phytotoxicity
issues
with
residual
fumigant.
Spring
application
of
metam
sodium
and
dazomet
shifts
seeding
date
from
February
to
April.
The
later
the
crop
is
transplanted,
the
greater
the
risk
from
drought
and
diseases.
Page
13
TOBACCO
TRANSPLANT
BEDS
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
TOBACCO
TRANSPLANT
BEDS
­
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)
427
204
122
52
37
30
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100
%
Bed
100
%
Bed
100
%
Bed
100
%
Bed
100
%
Bed
100
%
Bed
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
260,815
124,738
74,843
31,751
22,680
18,144
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Gas
Gas
Gas
Gas
Gas
Gas
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
623
623
626
623
626
617
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
62.3
62.3
62.6
62.3
62.6
61.7
APPLICATION
RATE
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
611
611
611
612
611
610
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
61.1
61.1
61.1
61.2
61.1
61
 
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
14
TOBACCO
TRANSPLANT
BEDS
­
PART
C:
TECHNICAL
VALIDATION
TOBACCO
TRANSPLANT
BEDS
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
TOBACCO
TRANSPLANT
BEDS
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3
D
Chloropicrin
Effective
against
nematodes
but
not
pathogens
associated
with
U.
S.
tobacco
production.
Only
effective
when
used
in
combination.
No
Dazomet
(
Basamid)
Fall
use
allows
for
recontamination
before
the
following
spring.
Spring
application
delays
seeding
due
to
the
extended
aeration
period.
Delayed
planting
can
result
in
greater
disease
and
drought
conditions.
No
Chloropicrin
Chloropicrin
would
control
the
fungal
pathogens
involved,
and
in
combinations
with
methyl
bromide
give
superior
control.
However,
chloropicrin
also
has
a
long
fumigation
and
waiting
interval
equal
to
Basamid
and
metam
sodium
and
therefore
the
same
limitations.
No
Metam
sodium
Fall
use
allows
for
recontamination
before
the
following
spring.
Spring
application
delays
seeding
due
to
the
extended
aeration
period.
Delayed
planting
can
result
in
greater
disease
and
drought
conditions.
No
Dithane
No
feasible
as
only
provides
mild
suppression
of
Rhyzocontia
spp.
No
NON
CHEMICAL
ALTERNATIVES
Biofumigation
Not
applicable
as
still
experimental.
No
Solarization
of
soil
No
consistent
effectiveness
as
is
dependent
upon
meteorological
conditions.
There
is
inadequate
sunlight
during
the
period
immediately
preceding
seedbed
establishment,
so
solarization
must
be
done
the
previous
summer/
fall
and
recontamination
issue
are
equal
or
worse
than
those
with
fall
fumigation.
No
Steam
sterilization
of
soil
Not
readily
available
for
farm
use
and
the
equipment
is
expensive.
No
Biological
Control
Not
applicable
as
still
experimental.
No
Cover
crops
and
Mulching
Not
applicable
due
to
the
soil
borne
nature
of
the
pathogens
No
Page
15
Crop
rotation/
fallow
Is
strongly
recommended
and
usually
practiced,
which
is
why
the
list
of
soil­
borne
pathogens
is
not
larger.
However,
it
alone
is
not
adequate
to
control
Pythium
and
Rhizoctonia
spp.
as
rotated
sites
also
become
recontaminated.
The
population
of
these
pathogens
must
still
be
reduced
to
near
zero
immediately
ahead
of
seeding.
No
Endophytes
Not
applicable.
No
Organic
amendments/
Compost
Not
applicable
due
to
the
soil
borne
nature
of
the
pathogens.
No
Physical
removal/
sanitation
Not
applicable
as
completely
disease
free
beds
are
required
for
crop
production.
No
Resistant
cultivars
Already
used
but
not
sufficient
disease
control
by
themselves
against
any
of
the
key
pathogens
in
a
seed
situation.
In
fact,
using
resistant
varieties
for
this
purpose
could
result
in
widespread
field
development
of
the
disease
by
harboring
the
pathogens
at
low
levels
in
a
hidden
state.
It
is
more
desirable
for
black
shank
to
appear
prior
to
transplanting
so
that
infected
plants
will
not
be
transferred
into
the
production
fields.
No
Non­
soil
culture
Already
used
but
methyl
bromide
is
still
needed
to
sterilize
trays.
No
Substrates/
Plug
plants
Already
used
but
methyl
bromide
is
still
needed
to
sterilize
trays.
No
COMBINATIONS
OF
ALTERNATIVES
1,3
D,
Brush
burning
Not
applicable.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

TOBACCO
TRANSPLANT
BEDS
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
There
are
no
available
alternatives
for
the
control
of
fungal
pathogens.
Page
16
TOBACCO
TRANSPLANT
BEDS
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

TOBACCO
TRANSPLANT
BEDS
 
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
Y
Unknown
Fosthiazate
Not­
registered
Y
Unknown
Furfural
Not­
registered
Y
Unknown
Sodium
azide
Not­
registered,
no
request
submitted
to
US
N
Unknown
Propargyl
bromide
Not­
registered,
no
request
submitted
to
US
N
Unknown
Diallyl
sulfide
Registered
to
control
Sclerotinia
fungus,
but
not
on
tobacco
seed
beds.
N
Unknown
*
Pesticide
companies
are
not
interested
in
labeling
pesticides
on
tobacco
for
disease
control
due
to
economic
and
image
issues.

TOBACCO
TRANSPLANT
BEDS
­
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
DITHANE
IS
RECOMMENDED
FOR
RHIZOCTONIA
CONTROL
IN
PLANT
BEDS
(
U
KY)

TOBACCO
TRANSPLANT
BEDS
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
Phytophthora
parasitica
nicotianae
KEY
PEST:
Phytophthora
parasitica
nicotianae
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
Methyl
bromide
100
1
Nesmith*
Vapam
(
Metam
sodium)
fumigation
54
1
*
Nesmith,
W.
1992/
93.
On
Farm
Test
in
Powell
County,
Ky.
Not
published.
Page
17
TOBACCO
TRANSPLANT
BEDS
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
Metam
Sodium
(
Vapam)
Fumigation
pathogens
46
46
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
46
TOBACCO
TRANSPLANT
BEDS
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

No.
The
tobacco
market
is
not
sufficiently
large
to
support
labeling
products
and
liability
is
high.
Further,
minor
crop
funding
is
not
allowed
for
tobacco.
Pesticide
companies
are
not
interested
in
labeling
pesticides
on
tobacco
for
disease
control
due
to
economic
and
public
perception
issues.

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

No.
While
most
of
the
larger
operations
have
moved
to
soil­
less
media
float
bed
transplant
production,
methyl
bromide
is
still
essential
to
ensure
healthy
transplants.

TOBACCO
TRANSPLANT
BEDS
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Methyl
bromide
is
still
essential
to
ensure
healthy
transplants
for
field
production
of
tobacco.
While
there
are
other
fumigants
registered,
dazomet
and
metam
sodium,
their
use
is
compromised
by
field
conditions
whether
applied
in
the
fall
or
spring.
Until
float
tray
production
of
seedlings
in
small
farm
operations
can
be
guaranteed
to
produce
pathogen
free
seedlings
or
acceptable
alternative
fumigants
are
registered
for
use
on
tobacco,
methyl
bromide
is
essential
to
field
tobacco
transplant
production.
KEY
PEST:
Pythium
spp.
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
Page
18
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE:
(
State
%
adoption
or
describe
change)

TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Currently
some
growers
use
HDPE
tarps.
No
No
No
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
high
barrier
films.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
lower
dosage
rates.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
increasing
chloropicrin
percentages.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
Not
available.
Examination
of
promising
but
presently
unregistered
alternative
fumigants,
alone
or
in
combination
with
nonchemical
methods,
is
planned
Not
available.
Research
is
underway
to
develop
float
bed
transplant
production
systems
which
will
ensure
pathogen
free
seedlings
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION
STATE
REASONS:

In
accordance
with
the
criteria
of
the
critical
use
exemption,
each
party
is
required
to
describe
ways
in
which
it
strives
to
minimize
use
and
emissions
of
methyl
bromide.
The
use
of
methyl
bromide
in
the
growing
of
tobacco
seedlings
in
plant
beds
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
Page
19
to
the
lowest
level
possible,
methyl
bromide
application
is
most
often
machine
injected
into
soil
to
specific
depths.

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

Tarpaulin
(
high
density
polyethylene)
is
also
used
to
minimize
use
and
emissions
of
methyl
bromide.

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.
Page
20
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Methyl
Bromide
100%
$
84
$
84
$
84
Floating
Trays
100%
$
14
$
14
$
14
Metam
Sodium
54%
$
84
$
84
$
84
*
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
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
10,210
6,477
Floating
Trays
10,210
6,568
Metam
Sodium
5,514
1,865
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
ALTERNATIVES
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
10,210
6,477
Floating
Trays
10,210
6,568
Metam
Sodium
5,514
1,865
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
10,210
6,477
Floating
Trays
10,210
6,568
Metam
Sodium
5,514
1,865
Page
21
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TOBACCO
TRANSPLANT
BEDS
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TOBACCO
TRANSPLANT
BEDS
METHYL
BROMIDE
FLOATING
TRAYS
METAM
SODIUM
(
VAPAM)
YIELD
LOSS
(%)
0%
0%
46%

YIELD
PER
HECTARE
2,316
2,316
1,250
*
PRICE
PER
UNIT
(
US$)
4.41
4.41
4.41
=
GROSS
REVENUE
PER
HECTARE
(
US$)
10,210
10,210
5,514
­
OPERATING
COSTS
PER
HECTARE
(
US$)
3,733
3,642
3,649
=
NET
REVENUE
PER
HECTARE
(
US$)
6,477
6,568
1,865
Loss
Measures
1.
LOSS
PER
HECTARE
(
US$)
$
0
+$
91
4,612
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
+$
27.12
$
1,371.62
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
+
1%
45%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
+
1%
71%

SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
compared
the
costs
of
two
alternative
control
scenarios
to
the
baseline
costs
for
controlling
tobacco
pests
with
methyl
bromide
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
The
two
alternatives
are
floating
trays
and
Vapam
or
metam
sodium.
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.
Page
22
(
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
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
tobacco
beds
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.

One
of
the
issues
tobacco
beds
growers
are
facing
is
whether
or
not
it
will
be
financially
prudent
to
convert
from
a
bed
system
that
requires
fumigation
of
the
soil
to
a
floating
tray
system.
A
floating
tray
system
uses
trays
floating
in
shallow
pools
to
grow
seedlings.
After
the
seedlings
are
removed
the
trays
are
fumigated,
stored
and
reused
again.
Although
it
is
seen
as
an
alternative,
seedling
producers
using
the
floating
tray
system
are
starting
to
move
back
to
soil
beds
for
a
couple
of
reasons.
For
starters,
if
the
water
becomes
contaminated
the
entire
stock
of
seedlings
is
lost
as
pathogens
spread
unabated.
Secondly,
there
is
virtually
no
insurance
crop
available
as
growers
cannot
keep
seedlings
floating
in
trays
beyond
transplant
maturity
whereas
with
a
bed
system
growers
can
maintain
insurance
or
back
up
stock.
In
fact,
some
seedling
producers
are
now
converting
from
floating
trays
back
to
beds
even
though
the
management
costs
are
higher.
This
analysis
considers
the
floating
tray
system
and
fumigation
with
Vapam
as
alternatives
to
fumigation
with
methyl
bromide.

The
costs
for
the
first
alternative
are
based
on
using
a
floating
tray
system
to
minimize
pathogen
transfer
while
the
costs
for
the
second
alternative
is
based
on
the
cost
of
applying
and
metam
sodium
(
Vapam)
in
place
of
methyl
bromide.
The
baseline
costs
were
based
on
the
average
number
of
applications
to
treat
tobacco
beds
with
methyl
bromide
per
year
(
one)
with
3
pounds
methyl
bromide
per
1,000
cubic
feet.

The
loss
per
hectare
measures
the
value
of
methyl
bromide
based
on
changes
in
operating
costs
and/
or
changes
in
yield.
The
loss
as
a
percentage
of
the
gross
revenue
is
based
on
the
ratio
of
the
loss
to
the
gross
revenue.
Likewise
for
the
loss
as
a
percentage
of
net
revenue.
The
profit
Page
23
margin
percentage
is
the
ratio
of
net
revenue
to
gross
revenue
per
hectare.

The
differences
in
the
cost
of
production
were
primarily
from
the
cost
of
the
capital
investments
and/
materials
costs
for
the
floating
tray
system
when
compared
to
a
bed
system
using
methyl
bromide.
The
basis
for
the
fumigation
alternative
costs
and
differences
in
net
revenue
are
from
the
estimated
yield
loss
if
metam
sodium
is
used
in
place
of
methyl
bromide.
Labor
was
assumed
to
cost
$
6.50
per
hour.
Yield
losses
ranged
from
0%
to
46%.

Under
Alternative
1
(
floating
tray
system),
yield
losses
were
estimated
to
be
0%
compared
to
methyl
bromide.
Operating
costs
in
U.
S.
dollars
per
hectare
were
estimated
to
be
$
3,643
per
year.
The
estimated
net
revenue
was
$
6,568
per
hectare.
The
gain
per
hectare
is
estimated
to
be
$
91
due
to
the
estimated
reduced
cost
of
a
tray
system
compared
to
soil
fumigation
with
methyl
bromide.
The
gain
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
27.12
per
kilogram.
If
growers
are
going
from
floating
tray
systems
back
to
seedbeds
because
of
performance
problems,
the
economic
consequence
of
using
a
system
that
doesn't
work
is
that
revenue
falls
to
zero
in
some
cases
for
seedling
growers
that
experience
pathogen
problems
as
their
entire
stock
is
lost.
The
probability
of
this
loss
is
not
known
but
converting
to
a
different
production
technology
is
an
indication
that
the
risk
of
loss
is
too
great.
It
is
understood
that
in
some
cases
floating
trays
do
work,
but
the
economic
consequences
of
float
tray
failure
impacts
and
the
financial
risk
avoidance
can
be
measured
by
the
cost
of
converting
back
to
seedbeds.
Conversion
costs
were
not
available
for
this
analysis.

Under
alternative
2
Vapam
(
metam
sodium),
yield
losses
were
estimated
to
be
46%
compared
to
methyl
bromide.
Operating
costs
in
U.
S.
dollars
per
hectare
were
estimated
to
be
$
3,649
per
year.
The
estimated
net
revenue
was
$
1,865
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
4,612.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
1,371.62
per
kilogram.
Page
24
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

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

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

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.
Page
25
25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

While
most
tobacco
producers
have
moved
to
the
float
tray
system
for
seedling
transplant
production,
methyl
bromide
is
still
critical
to
ensure
pathogen
free
seedlings.
In
recent
years,
a
number
of
producers
have
abandoned
the
float
tray
system
and
returned
to
small
plot
field
production
of
tobacco
transplants.
This
move
has
occurred
due
to
the
greater
potential
for
disease
production
in
the
greenhouse
float
tray
system.
This
indicates
that
float
tray
systems
still
have
problems
which
must
be
eliminated
before
they
can
be
considered
a
viable
alternative
for
seedling
production
in
the
United
States.
Page
26
26.
CITATIONS
Nesmith,
W.
1992/
93.
On
Farm
Test
in
Powell
County,
Ky.
Not
published.

Gutierrez,
WA,
HD
Shew
and
TA
Melton.
1997.
Sources
of
Inoculum
and
Management
for
Rhizoctonia
solani
Damping­
off
on
Tobacco
Transplants
under
Greenhouse
Conditions.
Pla.
Science
81:
604­
606
CITATIONS
REVIEWED
BUT
NOT
APPLICABLE
Hensley
Sr.,
R
and
DJ
Fowlkes.
The
Float
System
for
Producing
Tobacco
Transplants.

Bateman
K.
2002.
Tobacco
Greenhouse
Float
Tray
Sanitation.
NC
State
University
Cooperative
Extension
Service.
http://
www.
utextension.
utk.
edu/
tobaccoinfo/
2002TOC.
htm
Reed,
TD.
1998.
Float
Greenhouse
Tobacco:
Transplant
Production
Guide.
Virginia
Cooperative
Extension.
Publication
Number
436­
051.
http://
www.
ext.
vt.
edu/
pubs/
tobacco/
436­
051/
436­
051.
html
Vani
Muller,
J
J.
2000.
Brazilian
Tobacco
Growers
Choose
Floating
Seed
Trays
as
Methyl
Bromide
Replacement.
RUMBA
April
2000.
http://
www.
uneptie.
org/
ozonaction/
compliance/
rumba/
00april.
html
Dimock,
WJ,
CS
Johnson,
TD
Reed,
PJ
Semtner,
RL
Jones
and
MJ
Weaver.
2001.
Crop
Profile
for
Tobacco
in
Virginia.
USDA/
NASS.
http://
cipm.
ncsu.
edu/
cropprofiles/
docs/
vatobacco.
html
Mulrooney,
B.
1998.
Weekly
Crop
Update
 
Sanitation
of
Greenhouse
Trays.
University
of
Delaware
Cooperative
Extension.
Volume
1,
Issue
1
March
13,
1998.
http://
www.
rec.
udel.
edu/
Update98/
upd31398.
html
Hensley,
DD.
Disease
Management
in
Transplant
Production.

Nesmith,
W.
1995.
New
Harvest
­
Disinfect
Planter
Flats
and
Materials
for
Growing
Transplants.
University
of
Kentucky
Cooperative
Extension
Service.
http://
www.
ext.
vt.
edu/
news/
periodicals/
commhort/
1995­
07/
commhort­
35.
html
Salles,
LA,
DA
Sosa
and
A
Valeiro.
2001.
Alternatives
for
the
Replacement
of
Methyl
Bromide
in
Argentina.
FAO
Plant
Production
and
Protection
Paper,
No.
166:
3­
11.
http://
fao.
org/
DOCREP/
004/
Y1809E/
y1809e02.
htm
Page
27
Salles,
LA.
2001.
Effective
Alternatives
to
Methyl
Bromide
in
Brazil.
FAO
Plant
Production
and
Protection
Paper,
No.
166:
13­
24.
http://
fao.
org/
DOCREP/
004/
Y1809E/
y1809e02.
htm
The
mentioned
articles
were
reviewed
but
not
cited
because
either
they
contained
material
only
outlining
the
production
methodology
or
did
not
include
relevant
scientific
methods
and
data
in
support
of
the
conclusions.
Page
28
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
%
of
2001
&

2002
Average
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
16,431
27
611
0%

16,431
27
611
0%

0%
0%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
611
611
0
0
0
0
100
100
0
0
0
0
0
0
Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
No
?
Yes
Yes
+
No
?

Conversion
Units:
1
Pound
=
Kilograms
Hectare
Marginal
Strategy
54%
Metam­
Sodium
Combined
Impacts
(%)

HIGH
100%
LOW
100%

Regional
Hectares**

%
of
Requested
Hectares
MOST
LIKELY
IMPACT
VALUE
not
available
not
available
TOBACCO
TRANSPLANT
BEDS
REGION
TOBACCO
TRANSPLANT
BEDS
Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
0.453592
1
Acre
=
0.404686
Quality/
Time/
Market
Window/
Yield
Loss
(%)

REGION
REGION
REGION
TOBACCO
TRANSPLANT
BEDS
TOBACCO
TRANSPLANT
BEDS
Cold
Soil
Temp
(%)

Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
ha)
Economic
Analysis
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)

(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
0%
0%
0%
0%

%
Reduction
from
Initial
Request
0%
0%
0%
16,431
16,431
16,431
16,431
Nomination
Amount
16,431
16,431
16,431
(­)
QPS
HIGH
LOW
16,431
­
­
­
­
16,431
16,431
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

0%

33
611
0%

TOTAL
OR
AVERAGE
16,431
27
611
20,412
33
611
16,431
27
611
20,412
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)
not
available
Date:
2/
26/
2004
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:
not
available
Sector:
TOBACCO
BEDS
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:
Page
29
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
30
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
31
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
32
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
33
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
