METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
TRAYS
TO
PRODUCE
TOBACCO
TRANSPLANTS
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
Trays
to
Produce
Tobacco
Transplants
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
___________________
5
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
6
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
7
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________
8
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region____________________________________________________________________
8
Tobacco
Transplant
Trays
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.....................................
9
Tobacco
Transplant
Trays
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
__________________________________
9
Tobacco
Transplant
Trays
­
11.
Characteristics
of
Cropping
System
and
Climate
________
10
Tobacco
Transplant
Trays
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
11
TOBACCO
TRANSPLANT
TRAYS
­
PART
C:
TECHNICAL
VALIDATION
.......................................................................
12
Tobacco
Transplant
Trays
­
13.
Reason
for
Alternatives
Not
Being
Feasible
____________
12
Tobacco
Transplant
Trays
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
13
Tobacco
Transplant
Trays
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_____________________________________________
13
Tobacco
Transplant
Trays
­
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
___________________________________________________________
14
Tobacco
Transplant
Trays
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
14
Tobacco
Transplant
Trays
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
15
Tobacco
Transplant
Trays
­
Summary
of
Technical
Feasibility_______________________
15
PART
D:
EMISSION
CONTROL
................................................................................................................................
16
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
16
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
16
PART
E:
ECONOMIC
ASSESSMENT..........................................................................................................................
18
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
18
22.
Gross
and
Net
Revenue___________________________________________________
18
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
19
Summary
of
Economic
Feasibility
_____________________________________________
20
PART
F.
FUTURE
PLANS
........................................................................................................................................
21
iv
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
21
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
21
25.
Additional
Comments
on
the
Nomination
____________________________________
21
26.
Citations
______________________________________________________________
22
Citations
Reviewed
but
Not
Applicable
_________________________________________
22
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
Trays
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
..
8
Table
A.
2:
2005
Sector
Request
..................................................................................................
9
Table
A.
3:
2006
Sector
Nomination............................................................................................
9
TOBACCO
TRANSPLANT
TRAYS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...........
9
Tobacco
Transplant
Trays
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request.................................................................................................................
9
Tobacco
Transplant
Trays
­
Table
11.1:
Characteristics
of
Cropping
System
............................
10
Tobacco
Transplant
Trays
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
..............
10
Tobacco
Transplant
Trays
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
..................
11
TOBACCO
TRANSPLANT
TRAYS
­
PART
C:
TECHNICAL
VALIDATION
..................................................
12
Tobacco
Transplant
Trays
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
...............
12
Tobacco
Transplant
Trays
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion...........
13
Tobacco
Transplant
Trays
 
Table
15.1:
Present
Registration
Status
of
Alternatives
.................
13
TOBACCO
TRANSPLANT
TRAYS
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1........................................................................................................................................
14
Tobacco
Transplant
Trays
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
.......................
14
PART
D:
EMISSION
CONTROL.......................................................................................................
16
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
................................
16
PART
E:
ECONOMIC
ASSESSMENT.................................................................................................
18
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period................
18
Table
22.1:
Year
1
Gross
and
Net
Revenue
...............................................................................
18
Table
22.2:
Year
2
Gross
and
Net
Revenue
...............................................................................
18
Table
22.3:
Year
3
Gross
and
Net
Revenue
...............................................................................
18
Tobacco
Transplant
Trays
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives......
19
PART
F.
FUTURE
PLANS
..............................................................................................................
21
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
..................................
24
Page
5
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Trays
to
Produce
Tobacco
Transplants
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Over
the
past
15
years,
most
tobacco
producers
in
the
U.
S.
have
transitioned
from
seedlings
produced
in
methyl
bromide­
fumigated
soil
beds
to
containerized­
seedling
production
in
greenhouses
and
outdoor
"
float
beds".
This
includes
production
in
the
states
of
North
Carolina,
South
Carolina,
Georgia,
Virginia,
Florida,
Missouri,
West
Virginia,
Alabama,
Arkansas,
Illinois
and
Kansas.
The
direct­
seeded
float
system,
using
polystyrene
trays,
provides
plants
with
water
and
nutrients
through
a
waterbed
and
is
the
most
common
method
of
tobacco
transplant
production.
Direct
seeded
systems
use
a
variety
of
commercially
prepared
and
sanitized
media.
The
most
common
media
contains
50%
peat
and
50%
vermiculite
and
are
generally
sterilized
using
steam
treatments.
Seedlings
are
germinated
in
the
same
polystyrene
trays
from
which
they
will
be
transplanted,
thereby
eliminating
the
task
of
seedling
transfer
from
a
starter
tray
to
the
float
tray.
Direct
seeding
is
also
less
labor
intensive
than
transferring
starter
plugs
into
a
tray.
When
plants
reach
transplant
size,
they
are
immediately
transplanted
to
the
field
to
avoid
disease
development.
Soil
contact
is
avoided
between
float
bed
and
trays
as
many
tobacco
diseases
are
soil­
borne.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
VOLUME
(
1000
M
3)
2006
4,112
86
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
Over
the
past
15
years,
tobacco
producers
have
transitioned
from
seedlings
produced
in
methyl
bromide­
fumigated
soil
beds
to
containerized­
seedling
production
in
greenhouses
and
outdoor
"
float
beds."
This
has
resulted
in
a
massive
reduction
in
methyl
bromide
use
for
tobacco
production.
However,
while
use
of
methyl
bromide
in
polystyrene
float
tray
tobacco
seedling
production
is
minimal,
it
is
a
critical
use.
As
a
result
of
high
plant
density
and
high
moisture
conditions
in
float
tray
systems,
which
favor
the
development
and
spread
of
seedling
diseases,
float
bed
trays
can
become
highly
contaminated
with
a
wide
range
of
fungal
pathogens.
Float
trays
must
be
disinfected
of
potentially
crop
threatening
pathogens
prior
to
reuse
during
a
subsequent
season.
Methyl
bromide
fumigation
of
the
trays
is
the
most
practical
and
effective
means
to
control
the
target
pathogens.
Page
6
TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
TOBACCO
TRAYS
Region
Tray
Tobacco
Amount
of
Nomination
2006
Kilograms
4,112
Application
Rate
(
kg/
1000
M
3)
48
Volume
(
1000
M
3)
86
Amount
of
Applicants
Request
2005
Kilograms
10,942
Application
Rate
(
kg/
1000
M
3)
48
Volume
(
1000
M
3)
228
2006
Kilograms
10,942
Application
Rate
(
kg/
1000
M
3)
48
Volume
(
1000
M
3)
228
Economics
Marginal
Strategy
Steam
Yield
Loss
(%)
0%*

Loss
per
hectare
(
US$/
ha)
$
1,142
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
340
Loss
as
%
of
Gross
Revenue
(%)
11%

Loss
as
%
of
Net
Revenue
(%)
12%
*
Additional
costs
are
due
to
price
of
conversion
to
steam.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Heat
treatment,
steaming,
commonly
deforms
polystyrene
trays
used
in
float
bed
seedling
production.
Tobacco
growers
tend
to
avoid
the
high
temperatures
and/
or
times
needed
for
heat
to
be
effective,
therefore,
efficacy
against
the
target
pathogens
cannot
be
guaranteed.
In
addition,
most
tobacco
farms
are
not
setup
to
use
heat
sterilization
to
sanitize
transplant
trays
and
would
incur
significant
costs
to
establish
such
a
system.
Bleach
and
disinfectants
are
much
less
effective
than
methyl
bromide
or
heat
treatment
and
can
result
in
serious
plant
phytotoxicity
issues,
worker
exposure
concerns,
and
environmental
concerns
(
disposal
of
disinfectant
solutions).
Discarding
and
purchasing
new
trays
each
year
presents
serious
environmental
disposal
problems
and
is
a
more
costly
alternative.
Routine
use
of
fungicides
is
not
a
sound
practice
because
of
resistance
management
issues
as
these
same
pathogens
are
also
major
field
pathogens.
Early
use
of
available
fungicides
during
seedling
production
could
limit
their
effectiveness
during
field
production
of
tobacco.
In
addition,
transplant
market
is
not
sufficiently
large
to
support
the
labeling
of
new
products
and
the
liability
is
high.
Minor
Crop­
Use
funding
is
not
allowed
to
pursue
registration.
Page
7
7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
(
2001
AND
2002
AVERAGE
(
HA))
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)

Tobacco
Transplant
Trays
Not
applicable.
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.

Not
applicable
as
only
the
float
trays
are
treated
with
methyl
bromide.

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?

No,
methyl
bromide
is
critical
to
ensure
pathogen
free
transplants.
Page
8
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TRAY
TOBACCO
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
UNITED
STATES
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
10,942
10,942
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
TRANSPLANT
TRAYS
TRANSPLANT
TRAYS
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
(
1000
m3)
228
228
APPLICATION
RATE*
(
g/
m3
)
FOR
THE
FORMULATION
49.04
49.04
DOSAGE
RATE*
(
g/
m3)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
49.04
49.04
APPLICATION
RATE
(
g/
m3)
FOR
THE
ACTIVE
INGREDIENT
48.06
48.06
DOSAGE
RATE*
(
g/
m3)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
48.06
48.06
*
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
tobacco
acreage
using
float
tray
seedling
production
is
included
in
the
nomination.
 
Growth
or
increasing
production
(
the
amount
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
QPS
amounts
were
removed
from
the
request.
Page
9
TABLE
A.
2:
2006
SECTOR
REQUEST
 
TOBACCO
TRAYS*

2005
(
Sector)
Request
State/
Tobacco
Transplant
Trays
Kilograms
10,942
Application
Rate
(
kg/
1000
M
3)
48
Applicant
Request
for
2005
Volume
(
1000
M
3)
228
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

TABLE
A.
3:
2006
SECTOR
NOMINATION*

2006
(
Sector)
Nomination
State/
Tobacco
Transplant
Trays
Kilograms
10,942
Application
Rate
(
kg/
1000
M
3)
48
Applicant
Request
for
2006
Volume
(
1000
M
3)
228
Kilograms
4,112
Application
Rate
(
kg/
1000
M
3)
48
CUE
Nominated
for
2006
Volume
(
1000
M
3)
86
Overall
Reduction
(%)
62%
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
4,112
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

TOBACCO
TRANSPLANT
TRAYS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
TOBACCO
TRANSPLANT
TRAYS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
TOBACCO
TRANSPLANT
TRAYS
­
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
Page
10
Tobacco
Transplant
Trays
Rhizoctonia
spp.
Pytheium
and
Phytopthora
spp.
Thielaviopsis
basicola
Soil
fungi
and
bacteria
No
effective
alternative
controls
available.

TOBACCO
TRANSPLANT
TRAYS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
TOBACCO
TRANSPLANT
TRAYS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
TOBACCO
TRAYS
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.)
Hydroponic
(
50%
peat
and
50%
vermiculite)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Yearly
OTHER
RELEVANT
FACTORS:
Item
to
be
treated
is
polystyrene
transplant
trays.

TOBACCO
TRANSPLANT
TRAYS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
6a
and
6b
plant
hardiness
zones.

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
X
X
X
PLANTING
SCHEDULE
Not
relevant
KEY
MARKET
WINDOW
Not
relevant
*
Kentucky
data
provided
as
representative
of
the
growing
region
**
Not
applicable
to
transplant
tray
seedling
production.
Fumigation
may
occur
directly
prior
to
tray
use
or
at
the
end
of
the
previous
growing
season.

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

None
were
identified
as
being
relevant
factors.
Page
11
TOBACCO
TRAYS
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
TOBACCO
TRAYS
­
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
VOLUME
TREATED
(
1,000
cubic
meters)
185
197
227
226
216
216
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Not
relevant
(
Trays
are
fumigated).

AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
9,399
10,084
11,592
11,484
11,001
10,974
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
g/
m3
*
48.3
50.5
50.5
50.5
50.5
50.5
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
IN
g/
m3
*
48.3
50.5
50.5
50.5
50.5
50.5
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
g/
m3
*
47.4
49.5
49.5
49.5
49.5
49.5
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
IN
g/
m3
*
47.4
49.5
49.5
49.5
49.5
49.5
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
12
Tobacco
Trays
­
PART
C:
TECHNICAL
VALIDATION
TOBACCO
TRAYS
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
TOBACCO
TRAYS
 
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
Etridizole
Etridizole
has
not
been
shown
to
be
effective
against
Rhizoctonia
spp.
and
does
not
provide
adequate
control
of
Phytophthora
spp.
(
major
cause
of
damping
off
in
tobacco
transplants).
No
Sanitizers
and
disinfectants
(
chlorine
and
quaternary
ammonia)
Not
as
effective
as
they
do
not
penetrate
the
spaces
with
the
polystyrene
trays
to
kill
fungal
pathogens.
Phytoxicity
problems.
Worker
safety
concerns.
Environmental
concerns.
No
NON
CHEMICAL
ALTERNATIVES
Biofumigation
Not
applicable
as
still
experimental.
No
Purchase
new
trays
Cost
prohibitive.
Environmental
problems
associated
with
disposal
of
large
quantities
of
polystyrene
trays
No
Steam
sterilization
Fixed
costs
for
the
average
grower
make
this
prohibitive.
Trays
are
easily
damaged
to
the
point
of
being
unusable
by
this
system.
No
Solarization
Unacceptable
tray
damage
and
unacceptable
disease
control.
No
Irradiation
No
data
has
been
found
which
indicates
that
irradiation
is
effective
and
does
not
damage
the
polystyrene
trays.
Economically
infeasible
due
to
high
cost
of
irradiation
plus
transportation
to
the
facility.
No
Resistant
cultivars
Already
used
but
not
sufficient
disease
control
by
themselves
against
any
of
these
pathogen
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
COMBINATIONS
OF
ALTERNATIVES
No
combinations
identified.

*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
13
TOBACCO
TRAYS
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

TOBACCO
TRAYS
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
There
are
no
available
alternatives
for
the
control
of
fungal
pathogens.

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

TOBACCO
TRAYS
 
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
registration
package
has
been
received.
N
Unknown
Propargyl
bromide
Not­
registered.
No
registration
package
has
been
received.
N
Unknown
Diallyl
sulfide
Registered
to
control
Sclerotinia
fungus,
but
label
does
not
include
float
bed
systems.
N
Unknown
Page
14
TOBACCO
TRAYS
­
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
TOBACCO
TRAYS
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
Rhizoctonia
spp.

KEY
PEST:
KEY
PEST
1
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
Methyl
bromide
(
5.07
g/
m3
,
gas)
1
0%
Gutierrez
et
al.
New
trays
1
0%
Gutierrez
et
al.
Heat
(
steam)
1
0%
Gutierrez
et
al.
Heat
(
dry)
1
56%
Gutierrez
et
al.
Disinfectants
(
chlorine)
1
56%
Gutierrez
et
al.

Gutierrez,
WA,
HD
Shew
and
TA
Melton.
1997.
Plant
Disease
81:
604­
606.

TOBACCO
TRAYS
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
New
trays
pathogen
0%
0%
Heat
(
steam)
pathogen
0%
0%
Heat
(
dry)
pathogen
55
­
100%
*
70%
Disinfectants
pathogen
55
­
100%
*
70%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
70%*
*
Though
Guitierrez
et
al
show
a
56%
yield
loss,
losses
can
reach
100%
as
producers
will
not
purchase
seedlings
from
float
bed
production
facilities
that
may
be
potentially
infected.

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

No.
Transplant
market
is
not
sufficiently
large
to
support
labeling
products
and
liability
is
high.
Minor
Crop­
Use
funding
is
not
allowed
for
tobacco.
Pesticide
companies
are
not
interested
in
labeling
pesticides
on
tobacco
for
disease
control
due
to
economic
and
image
issues.
Page
15
TOBACCO
TRAYS
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

Tobacco
farmers
have
reduced
methyl
bromide
use
by
over
95%
by
moving
from
field
transplant
production
to
greenhouse
float
systems.
The
remaining
methyl
bromide
use
is
to
sterilize
production
trays
to
prevent
pathogen
contamination
in
subsequent
years.
While
this
method
has
reduced
the
use
of
methyl
bromide,
it
has
not
eliminated
the
need
for
methyl
bromide.

TOBACCO
TRAYS
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
biological
analysis
of
alternatives
to
methyl
bromide
to
control
target
pathogens
in
float
tray
tobacco
seedling
production
indicates
no
acceptable
alternatives
that
can
provide
the
necessary
efficacy
at
this
time.
It
is
essential
in
float
tray
tobacco
seedling
production
to
produce
a
totally
pathogen
free
crop
for
transplantation
into
tobacco
fields.
Disinfectants,
chlorine
bleach,
can
be
used
but
are
less
effective
than
methyl
bromide
and
require
extreme
care
and
expertise
to
achieve
acceptable
control
and
avoid
plant
phytotoxicity.
Most
farmers
do
not
have
the
expertise
to
ensure
repeatable
results
using
disinfectants.
In
addition,
disinfectants
also
have
issues
pertaining
to
worker
and
environmental
safety,
which
limit
their
adoption
by
tobacco
producers.
Heat
sterilization
using
steam
is
as
effective
as
methyl
bromide.
However,
the
polystyrene
trays
used
in
float
bed
tobacco
seedling
production
are
easily
misshapen
or
deformed
by
heat
and
producers
tend
to
avoid
the
high
temperatures
and
exposure
times
required
to
ensure
tray
sterilization.
In
addition,
very
few
farms
have
equipment
available
for
steam
sterilization
and
would
incur
significant
costs
to
establish
a
steam
sterilization
program.
Page
16
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.
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
increase
the
percentage
of
chloropicrin.
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.
Not
available.

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.
Page
17
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
18
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
$
612
$
612
$
612
Steam
100
$
1752
$
1752
$
1752
10%
Chlorine
bleach
30
$
340
$
340
$
340
*
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
$
9,600
Steam
$
10,206
$
8,458
10%
Chlorine
bleach
$
3,063
$
2,725
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
$
9,600
Steam
$
10,206
$
8,458
10%
Chlorine
bleach
$
3,063
$
2,725
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
$
9,600
Steam
$
10,206
$
8,458
10%
Chlorine
bleach
$
3,063
$
2,725
Page
19
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TOBACCO
TRANSPLANT
TRAYS
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TOBACCO
TRANSPLANT
TRAYS
METHYL
BROMIDE
STEAM
BLEACH
YIELD
LOSS
(%)
0
0
70%

YIELD
PER
HECTARE
2,379
2,379
695
*
PRICE
PER
UNIT
(
US$)
2
2
2
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
4,758
$
4,758
$
3,063
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
612
$
1,752
$
339
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4,146
$
3,006
$
2,725
Loss
Measures
1.
LOSS
PER
HECTARE
(
US$)
$
0
$
1,142
6,875
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
340
2,045
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
11%
67%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
12%
72%
Page
20
SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
compared
the
costs
of
two
alternative
control
scenarios
to
the
baseline
costs
for
methyl
bromide.
The
economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
The
costs
for
the
first
alternative
are
based
on
using
portable
steam
equipment
to
sterilize
tobacco
polystyrene
trays
while
the
costs
for
the
second
alternative
are
based
on
the
cost
for
dipping
polystyrene
trays
into
a
10%
chlorine
solution.
The
chlorine
costs
were
derived
from
CUE
applicant
data
and
the
steam
from
U.
S.
EPA
data.
The
baseline
costs
were
based
on
the
average
number
of
applications
to
treat
tobacco
trays
with
methyl
bromide
per
year,
which
was
1,
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
margin
percentage
is
the
ratio
of
net
revenue
to
gross
revenue
per
hectare.
The
values
to
derive
gross
revenue
and
the
operating
costs
for
each
alternative
were
averaged
from
the
three
tobacco
polystyrene
tray
CUE's
(
numbers,
03­
25,
63
and
65).
Tobacco
beds
will
be
discussed
under
a
separate
review.
The
differences
in
the
cost
of
production
were
primarily
from
the
cost
of
the
capitol
investments
and/
materials
costs.
Labor
was
assumed
to
cost
$
6.50
per
hour.
The
estimated
cost
of
a
portable
steam
generator
was
depreciated
over
10
years.
One
gallon
of
chlorine
was
assumed
to
cost
$
1
per
gallon.
Yield
loss
estimates
were
based
on
data
from
the
CUE,
and
U.
S.
EPA
data
as
well
as
expert
opinion.
Yield
losses
for
steam
was
estimated
to
be
0%
and
70%
for
the
10%
chlorine
bleach
solution.

Using
steam
(
Under
Alternative
1),
operating
costs
in
U.
S.
dollars
per
hectare
was
$
1,752.
The
estimated
net
revenue
was
$
8,458
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
1,142.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
340
per
kilogram.

Under
alternative
2
(
bleach),
the
10%
chlorine
bleach
treatment
was
based
on
dipping
trays
into
a
solution
of
1gallon
of
chlorine
bleach
and
9
gallons
of
water
and
allowing
to
air
dry.
EPA
estimated
that
a
70%
yield
loss
would
result
with
the
use
of
chlorine
bleach.
Operating
costs
in
U.
S.
dollars
per
hectare
was
$
340.
The
estimated
net
revenue
was
$
2,725
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
6,875.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
2,045
per
kilogram.

It
should
be
noted
that
the
applicants
do
not
consider
any
alternative
to
be
feasible
and
that
these
estimates
are
a
first
draft
attempt
to
measure
potential
impacts.
The
final
numbers
and
economic
feasibility
conclusions
will
not
be
decided
until
the
accuracy
of
the
data
used
in
the
calculation
of
the
economic
measures
are
thoroughly
examined.
Page
21
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.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?
Page
22
26.
CITATIONS
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.

Gutierrez,
WA,
HD
Shew
and
TA
Melton.
2001.
Rhizoctonia
Diseases
in
Tobacco
Greenhouses.
Plant
Pathology
Extension/
North
Carolina
State
University.
TB07­
Tobacco
Disease
Note
7.
http://
www.
ces.
ncsu.
edu/
depts/
pp/
notes/
Tobacco/
tdin007/
tb07.
html
Clemson
Extension.
South
Carolina
Tobacco
Growers
Guide
2003.
http://
www.
clemson.
edu/
peedeerec/
Tobacco/
2003%
20tableof.
htm
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
Page
23
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
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
24
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Date:
not
available
Sector:
not
available
Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
Kilograms
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
2001
Volume
%
of
Volume
10,942
228
48
10,987
216
51
60%
not
available
not
available
10,942
228
48
10,987
216
51
60%
not
available
not
available
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
HIGH
LOW
Amount
(
kgs)
Volume
(
1000m
3)
Use
Rate
(
kg/
1000m
3)
%
Reduction
10,942
­
634
28
6,168
4,112
4,112
4,112
86
48
62%

10,942
10,942
10,308
10,281
4,112
4,112
4,112
4,112
86
48
62%

0%
0%
6%
6%
62%
62%
62%
62%
62%

2006
Low
High
Low
High
Low
HIGH
LOW
48
48
100
100
0
0
100%
100%
70%

Other
Considerations
Currently
Use
Alternatives?
Research
/

Transition
Plans
Pest­
free
Market
Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MeBr
Use
/
State
Frequency
of
Treatment
/
Yr
Loss
per
1000
m
3
(
US$/
1000m)
Loss
per
Kg
of
MeBr
(
US$/
kg)
Loss
as
a
%
of
Gross
Revenue
No
?
Yes
0
No
1/
year
Conversion
Units:
1
Pound
=
0.453592
Kilograms
1,000
cu
ft
=
0.028316847
1,000
cubic
meters
Loss
as
a
%
of
Net
Revenue
Economic
Analysis
Steam
Methyl
Bromide
Critical
Use
Exemption
Process
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)

Subtractions
from
Requested
Amounts
(
kgs)

2006
Amount
of
Request
MOST
LIKELY
IMPACT
VALUE
Marginal
Strategy
2/
26/
2004
TOBACCO
TRAYS
Average
Volume
in
the
US:

(%)
Combined
Impacts
Time,
Quality,

or
Product
Loss
Combined
Impacts
Adjustment
(
kgs)

2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
(%)
Adopt
New
Fumigants
REGION
TOBACCO
TRAYS
TOBACCO
TRAYS
REGION
TOBACCO
TRAYS
TOTAL
OR
AVERAGE
2006
Nomination
Options
REGION
TOBACCO
TRAYS
Regional
Volume
REGION
%
of
Average
Volume
Requested:

Dichotomous
Variables
(
Y/
N)
Other
Issues
Nomination
Amount
%
Reduction
from
Initial
Request
Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
1000m
3)
(%)
Key
Pest
Distribution
Page
25
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
26
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
27
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
28
APPENDIX
C.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
29
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
