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

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:
ii
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
____________________________________________________________
7
1.
Nominating
Party
_________________________________________________________
7
2.
Descriptive
Title
of
Nomination______________________________________________
7
3.
Crop
and
Summary
of
Crop
System___________________________________________
7
4.
Methyl
Bromide
Nominated
_________________________________________________
7
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
8
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
9
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
10
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
11
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
12
Region
A
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
13
Region
A
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
13
Region
A
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
14
Region
A
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
16
REGION
A
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
17
Region
A
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
17
Region
A
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
19
Region
A
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
19
Region
A
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___
19
Region
A
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
20
Region
A
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
20
Region
A
­
Summary
of
Technical
Feasibility
____________________________________
21
Region
B
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
21
Region
B
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
21
Region
B
­
11.
Characteristics
of
Cropping
System
and
Climate______________________
22
Region
B
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
23
REGION
B
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
24
Region
B
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
24
Region
B
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
25
Region
B
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
26
iv
Region
B
­
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
___
26
Region
B
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
27
Region
B
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
28
Region
B
­
Summary
of
Technical
Feasibility
____________________________________
28
Region
C
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
28
Region
C
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
28
Region
C
­
11.
Characteristics
of
Cropping
System
and
Climate______________________
29
Region
C
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
30
REGION
C
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
31
Region
C
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
31
Region
C
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
33
Region
C
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
34
Region
C
­
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
___
36
Region
C
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
36
Region
C
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
37
Region
C
­
Summary
of
Technical
Feasibility
____________________________________
38
PART
D:
EMISSION
CONTROL
___________________________________________________
39
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
39
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
39
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
40
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
40
22.
Gross
and
Net
Revenue___________________________________________________
41
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
42
Summary
of
Economic
Feasibility
_____________________________________________
43
PART
F.
FUTURE
PLANS
_______________________________________________________
47
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
47
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
48
25.
Additional
Comments
on
the
Nomination
____________________________________
49
26.
Citations
______________________________________________________________
50
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.
v
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
7
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
7
Table
A.
1:
Executive
Summary
for
Tomatoes
_______________________________________
9
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
Region
A
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
11
Region
B
­
Table
8.2:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
11
Region
C
­
Table
8.3:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
12
Table
A.
2:
2006
Sector
Nomination
______________________________________________
13
REGION
A
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
13
Region
A
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
13
Region
A
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
14
Region
A
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
14
Region
A
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
16
REGION
A
­
PART
C:
TECHNICAL
VALIDATION
________________________________________
17
Region
A
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
17
Region
A
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________________
19
Region
A
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
19
Region
A
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
20
Region
A
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
20
REGION
B
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
21
Region
B
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
21
Region
B
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
22
Region
B
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
22
Region
B
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
23
REGION
B
­
PART
C:
TECHNICAL
VALIDATION
________________________________________
24
Region
B
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
24
Region
B
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________________
25
Region
B
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
26
Region
B
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
26
Region
B
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
27
REGION
C
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
28
Region
C
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
28
Region
C
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
29
Region
C
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
29
Region
C
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
30
REGION
C
­
PART
C:
TECHNICAL
VALIDATION
________________________________________
31
Region
C
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
31
Region
C
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________________
33
Region
C
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
34
Region
C
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
36
Region
C
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
36
PART
D:
EMISSION
CONTROL
____________________________________________________
39
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
39
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
40
vi
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
40
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
41
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________________________
41
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
41
California
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
42
Michigan
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
42
Southeastern
US
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
43
PART
F.
FUTURE
PLANS
________________________________________________________
47
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
52
Page
7
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Pre­
plant
Soil
Use
for
Tomato
Grown
in
Open
Fields
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Tomato
Crops
Grown
in
Open
Fields
for
Fruit.
In
California,
Michigan
and
South­
Eastern
United
States
(
Alabama,
Arkansas,
Florida,
Georgia,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee).
These
crops
are
grown
in
open
fields
on
plastic
tarps,
often
followed
by
various
other
crops.
Harvested
fruit
is
destined
for
the
fresh
market.

4.
METHYL
BROMIDE
NOMINATED:

TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
2,931,879
19,839
Page
8
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
Currently
registered
alternatives
to
methyl
bromide
do
not
consistently
provide
effective
control
of
nutsedge
weed
species
and
more
time
is
needed
to
evaluate
relationship
between
fumigant
alternatives,
various
mulches,
and
herbicide
systems
under
different
growing
conditions.

The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
tomato
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
tomato
production.
­
geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
US
is
only
nominating
a
CUE
for
tomato
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
townships
caps
and
in
Florida
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin,
and
in
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.
Page
9
TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
TOMATOES
*

Region
California
Region
Michigan
Region
South­
Eastern
United
States
AMOUNT
OF
NOMINATION
2006
Kilograms
102,058
10,745
2,799,236
Application
Rate
(
kg/
ha)
105
48
150
Area
(
ha)
971
223
18,645
AMOUNT
OF
APPLICANT
REQUEST
2005
Kilograms
102,058
32,214
4,640,896
Application
Rate
(
kg/
ha)
105
48
155
Area
(
ha)
971
668
29,959
2006
Kilograms
102,058
31,606
4,519,689
Application
Rate
(
kg/
ha)
105
48
150
Area
(
ha)
971
656
30,104
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Technically
Feasible
Alternative
(
s)
METAM
SODIUM
1,3­
D
+
PIC
1,3­
D
+
PIC
Production
Loss
(%)
15%
6%
6%

Loss
per
hectare
(
US$/
ha)
$
8,618
$
6,113
$
5,708
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
82
$
127
$
38
Loss
as
%
of
Gross
Revenue
(%)
10%
15%
14%

Loss
as
%
of
Net
Revenue
(%)
26%
65%
39%
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Research
results
confirm
that
methyl
bromide
alternatives
options
provide
inconsistent
control
of
nutsedge
weed
species.
Nutsedge
is
an
extremely
competitive
weed
in
tomato
and
can
cause
significant
yield
losses
in
the
Southeast.
Methyl
bromide
alternatives
also
provide
incomplete
control
of
soil
pathogens
in
Michigan.

In
addition,
there
is
a
regulatory
prohibition
on
the
use
of
1,3­
D
on
karst
topography
in
the
South­
Eastern
United
States.
In
Michigan,
1,3­
D
can
only
be
used
when
soil
temperature
are
higher
than
required
for
using
methyl
bromide,
and
this
results
in
a
planting/
harvesting/
marketing
delay.
In
California,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.
Page
10
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
AVERAGE
OF
2001
AND
2002
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
IN
2002
(%)
California
Region
15,479
6
Michigan
Region
749
88
South­
Eastern
United
States
31,270
99
NATIONAL
TOTAL
:
*
51,506
63
*
National
total
includes
other
regions
not
requesting
methyl
bromide
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

The
primary
reason
that
some
tomatoes
may
be
grown
without
methyl
bromide
in
all
three
regions
is
the
absence
of
key
target
pests
(
i.
e.,
nutsedge
in
the
Southeast,
soil
pathogens
in
Michigan,
and
pathogens
and
nematodes
in
California).

In
Florida,
areas
without
karst
geology
and
having
low
nutsedge
pressure
can
successfully
employ
a
fumigation
system
relying
on
1,3­
D
and
chloropicrin.

In
Michigan,
the
majority
of
tomato
producing
acres
do
not
have
Phytopthora
spp.,
and
do
not
use
methyl
bromide.

In
California,
areas
with
flat
terrain
successfully
employ
1,3­
D
with
chloropicrin
as
a
fumigant.

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,
areas
that
use
methyl
bromide
do
so
because
hilly
terrain,
cold
soil
temperatures,
and
heavy
pest
pressure
preclude
the
use
of
fumigants
that
are
employed
when
these
conditions
are
not
present.
Page
11
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
CALIFORNIA
REGION
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
California
Region
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
102,058
102,058
USE:
BROAD
ACRE
OR
STRIP/
BED
TREATMENT
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67/
33
67/
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
971
971
APPLICATION
RATE
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
105
105
APPLICATION
RATE
(
kg/
ha)
FOR
THE
FORMULATION
157
157
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
10.5
10.5
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
15.7
15.7
MICHIGAN
REGION
­
TABLE
8.2:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Michigan
Region
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
32,214
31,606
USE:
BROAD
ACRE
OR
STRIP/
BED
TREATMENT
Strip/
Bed
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67/
33
67/
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
668
656
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
48*
48*

APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
71.6*
71.6*

DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
13.1
13.1
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
19.5
19.5
*
Only
36.7%
percent
of
an
hectare
receives
this
amount
of
methyl
bromide
formulation.
Page
12
SOUTH­
EASTERN
UNITED
STATES*
­
TABLE
8.3:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
South­
Eastern
United
States
YEAR
OF
EXEMPTION
REQUEST
2005
2006
KILOGRAMS
OF
METHYL
BROMIDE
4,640,896
4,519,689
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Mostly
Strip/
Bed
Mostly
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
Mostly
67/
33
Mostly
67/
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
29,959
30,104
APPLICATION
RATE
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
155
150
APPLICATION
RATE
(
kg/
ha)
FOR
THE
FORMULATION
231
224
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
15.5
15.0
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
23.1
22.4
*
Includes
Alabama,
Arkansas,
Florida,
Georgia,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
and
Tennessee.

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

The
amount
of
methyl
bromide
nominated
by
the
US
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
three
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.
Not
applicable
in
this
sector.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
regulatory
impacts,
karst
topography,
buffer
zones,
unsuitable
terrain,
and
cold
soil
temperatures.
Page
13
TABLE
A.
2:
2006
SECTOR
NOMINATION
*

2006
(
Sector)
Nomination
California
Region
Michigan
Region
South­
Eastern
United
States
Requested
Hectares
(
ha)
971
656
31,104
Requested
Application
Rate
(
kg/
ha)
105
48
150
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
102,058
31,606
4,519,688
Nominated
Hectares
(
ha)
971
223
18,645
Nominated
Application
Rate
(
kg/
ha)
105
48
150
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
102,058
10,745
2,799,236
Overall
Reduction
(%)
37
Total
2006
U.
S.
CUE
Nominated
Kilograms
(
kg)
2,931,879
Research
Amount
(
kg)
5,501
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
2,937,380
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

CALIFORNIA
REGION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
REGION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
REGION
­
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
California
Fusarium
wilt
Verticillium
wilt
Root
Knot
nematodes
Pythium
spp.
Registered
alternatives
do
not
provide
consistent,
efficient
and
economical
control
of
listed
pests.
Page
14
CALIFORNIA
REGION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA
REGION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
REGION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
for
tomato
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Tomato
 
Strawberry
or
Barley
or
fallow
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
Loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
No
additional
information
was
provided
CALIFORNIA
REGION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
Plant
Hardiness
Zone)
9A,
9B,
10A
RAINFALL
(
mm)
0.25
0.00
0.25
3.05
51.8
2.29
OUTSIDE
TEMP.
(
°
C)*
17.8
20.5
22.2
20.0
14.4
11.7
FUMIGATION
SCHEDULE
(
DATES)
X
X
X
X
X
PLANTING
SCHEDULE
(
DATES)
X
X
X
X
KEY
MARKET
WINDOW
(
DATES)
X
X
X
X
X
X
*
Norton
et
al.,
2000.
Page
15
CALIFORNIA
REGION
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Telone
fumigation
controls
nematodes.
Chloropicrin
controls
fungal
pathogens.
A
combination
of
telone
and
chloropicrin
may
be
a
technically
feasible
alternative
for
methyl
bromide
on
flat
terrain.
However,
this
CUE
is
only
for
hilly,
rolling
terrain
where
these
alternatives
would
not
be
uniformly
distributed
by
the
irrigation
systems.

Metam
sodium
alone
or
metam
sodium
plus
chloropicrin
will
not
control
root
knot
nematodes.
In
addition,
rolling
field
topography
having
varied
soil
textures
does
not
allow
uniform
application
of
metam
sodium.
This
may
result
in
pockets
of
high
and
low
concentrations
of
metam
sodium.
High
concentrations
of
metam
sodium
can
be
phytotoxic
to
the
tomatoes,
limiting
its
usefulness
as
an
alternative
in
areas
of
hilly
or
rolling
terrain.
The
surviving
fungal
pathogen
populations
can
build
up
quickly
to
kill
tomato
plants
(
Burnette,
2003).
Page
16
CALIFORNIA
REGION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
REGION
­
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)
994
1,039
1,087
1,089
1,080
900
RATIO
OF
FLAT
FUMIGATION
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
125,359
125,318
125,964
126,236
123,783
97,775
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
126
121
116
116
115
109
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
188
181
173
173
172
163
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)
12.6
12.1
11.6
11.6
11.5
10.9
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
18.8
18.1
17.3
17.3
17.2
16.3
*
It
is
based
on
formulation
containing
67%
methyl
bromide.
Page
17
CALIFORNIA
REGION
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
REGION
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
REGION
 
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
Telone
Effective
against
nematodes
but
not
against
fungal
plant
pathogens.
Not
effective
on
hilly,
rolling
terrain.
No
Metam
sodium
Effective
against
fungal
plant
pathogen
if
applied
uniformly.
The
petitioner
states
that
metam
sodium
cannot
be
applied
uniformly
because
uneven
land
topography
and
soil
texture.
This
results
in
pockets
of
very
high
and
very
low
concentration
of
metam
sodium.
The
surviving
fungal
pathogen
populations
can
build
up
quickly
to
kill
tomato
plants
(
Burnette,
2003).
In
addition,
the
applicant
claims
that
high
concentration
can
be
phytotoxic
and
low
concentration
does
not
control
fungal
pathogens
(
data
not
submitted).
No
Chloropicrin
Chloropicrin
is
not
effective
when
it
is
applied
alone.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
The
CUE
is
for
tomatoes
grown
in
the
coastal
areas
of
California,
which
have
mild
weather
conditions
(
15
­
25
C
temperatures).
The
weather
conditions
restrict
soil
solarization
as
alternative
to
methyl
bromide.
No
Steam
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nematodes.
While
biological
control
may
have
utility
as
part
of
plant
pathogen
management
strategy,
it
can
not
be
a
methyl
bromide
alternative
No
Cover
crops
and
mulching
There
is
no
evidence
that
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
fungal
pathogens
and
nematodes.
No
Page
18
Crop
rotation
and
fallow
land
The
land
is
very
expensive
and
there
are
not
enough
hectares
in
tomato
growing
areas
to
rotate.
The
fungal
pathogen
survive
for
many
years
in
soil
and
therefore
it
is
not
a
viable
option.
No
Endophytes
No
information
is
available
on
tomato
endophytes
that
will
control
fungal
and
plant
pathogens.
No
Flooding/
Water
management
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
fungal
plant
pathogens
and
nematodes.
In
addition,
it
is
prohibitively
expensive
and
there
are
water
management
restrictions.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
target
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
fungal
pathogens
and
nematodes.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Undulating
land
topography
and
variable
soil
texture
will
result
in
uneven
concentration
of
metam
sodium
through
drip
irrigation
that
may
affect
field
performance
and
can
result
in
phytotoxicity
to
tomato
transplants.
This
mixture
will
not
control
nematodes.
No
Metam
sodium
+
Crop
rotation
Same
as
metam
sodium
No
1,3
D
+
Metam­
sodium
This
mixture
may
control
fungi
and
nematodes,
but
undulating
land
topography
will
result
in
uneven
concentration
of
metam
sodium
through
drip
irrigation
that
may
result
in
phytotoxicity
to
tomato
transplants.
No
1,3­
D
+
Chloropicrin
Telone
is
effective
against
nematodes.
Chloropicrin
is
effective
against
fungal
plant
pathogens.
The
combination
is
a
technically
feasible
alternative
to
methyl
bromide,
but
undulating
topography
can
reduce
its
uniformity
of
application
and,
hence,
its
effectiveness.
No
1,3­
D
+
metam
sodium
+
pebulate
This
mixture
cannot
be
used
as
a
methyl
bromide
alternative
because
pebulate
is
no
longer
registered
in
the
United
States
(
during
2002
its
registration
expired
and
the
manufacturer
went
out
of
business).
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
19
CALIFORNIA
REGION
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
REGION
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Foliar
fungicides
are
not
suitable
because
the
key
pests
are
soil
borne
and
afflict
the
belowground
portion
of
the
tomato
plant.
There
are
no
other
alternatives
that
exist
for
the
control
of
these
key
pests
on
hilly
or
rolling
terrain
when
they
are
present
in
the
soil.
A
number
of
fungicides
are
available
that
may
control
fungal
pathogenss
when
they
attach
aerial
plant
parts.
Fusarium
spp.
results
in
plant
wilting
and
there
is
no
remedy
once
plant
is
systemically
infected.

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

CALIFORNIA
REGION
 
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:

Methyl
Iodide
Application
submitted
to
the
US­
EPA
during
February
2002.
Not
registered
Yes
Unknown
Sodium
azide
No
application
submitted
to
the
US­
EPA
till
date.
Not
registered
No
Unknown
Propargyl
bromide
No
application
submitted
to
the
US­
EPA
till
date.
Not
registered
No
Unknown
CALIFORNIA
REGION
­
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:

The
applicant
submitted
the
results
of
two
field
trials
conducted
in
San
Diego
and
Ventura
counties
on
the
efficacy
of
methyl
bromide
and
its
alternatives
in
controlling
listed
pests
(
Fusarium
wilt,
Verticillium
wilt,
Root­
knot
nematode,
and
Pythium
spp.).
Metam
sodium
and
1,3­
D
are
both
not
viable
options
because
of
hilly,
rolling
terrain.
Varied
soil
texture
and
undulating
land
topography
can
create
high
and
low
concentration
spots
of
metam
sodium
and
1,3­
D,
affecting
its
efficacy
in
controlling
the
pests
(
Burnette,
2003).
Low
concentrations
may
results
in
lower
efficacy
and
high
concentration
in
phytotoxicity.
The
growers
may
suffer
15­
20%
yield
losses.
The
applicant
did
not
submit
any
document
on
the
effect
of
low
and
high
concentration
spots
of
metam
sodium
on
tomato
yield.
Therefore,
we
are
unable
to
validate
whether
or
not
these
losses
are
reasonable.
Page
20
CALIFORNIA
REGION
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available
to
present.

CALIFORNIA
REGION
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
Metam
sodium
Fusarium
wilt
Verticillium
wilt
Root
Knot
nematodes
Pythium
spp.
15­
20%,
based
on
professional
opinion
15­
20%

1,3­
D
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.
1,3­
D
+
Chloropicrin
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.
1,3­
D
+
metam
sodium
+
Chloropicrin
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
15­
20%

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

Methyl
Iodide,
Sodium
Azide
and
Propargyl
Bromide
These
have
not
been
widely
tested
in
the
fields
or
registered
for
use
in
any
crop
by
the
United
States
Environmental
Protection
Agency.
The
above
fumigants
are
potential
alternatives
to
methyl
bromide
that
could
be
used
in
California
to
control
fungal
pathogens
and
nematodes.

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

Tomatoes
are
grown
in
fields.
It
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.
Page
21
CALIFORNIA
REGION
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
US
EPA
has
determined
that
in
flat
terrain,
only
1,3­
D
+
chloropicrin
and
metam
sodium
+
chloropicrin
can
be
technically
feasible
against
the
key
pests
of
tomatoes
grown
in
California.
Metam­
sodium
alone
will
not
control
nematodes
and
may
be
phytotoxic
to
plants
because
of
undulating
land
topography
of
tomato
fields.
A
mixture
of
metam
sodium
and
chloropicrin
will
not
control
nematodes.
In
addition,
this
mixture
may
also
be
phytotoxic
due
to
undulating
land
topography.
A
mixture
of
1,3­
D
and
chloropicrin
is
unreliable
in
undulating
topography
because
of
uneven
distribution
of
the
fumigant
through
drip
irrigation
systems.
Currently
unregistered
alternatives,
such
as
methyl
iodide,
sodium
azide
or
propargyl
bromide
have
shown
good
efficacy
against
the
key
pests.
However,
even
if
registration
is
pursued
soon
the
commercial
tomato
growers
will
need
transition
period
for
adoption
in
California.

There
are
also
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
tomato
growers.

MICHIGAN
REGION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
MICHIGAN
REGION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
MICHIGAN
REGION
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Michigan
Region
1.
Crown,
root
and
fruit
rot
caused
by
Phytophthora
capsici
2.
Fusarium
oxysporum
wilt
Methyl
bromide
is
currently
the
only
product
that
can
control
these
soil­
borne
pathogens
and
allow
MI
growers
to
deliver
their
produce
during
premium
priced
early
market
windows.
Other
control
measures
have
plant
back
restrictions
that
put
MI
tomatoes
outside
the
premium
priced
fresh
market.
Resistant
varieties
have
not
been
identified.
Page
22
MICHIGAN
REGION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
MICHIGAN
REGION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
REGION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
tomatoes
to
produce
fruit
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Squash,
cucumber,
eggplant
and
melons.
All
are
susceptible
to
Phytpphthora
capsici.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
Loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
Low
soil
temperatures
during
late
March
do
not
allow
effective
soil
fumigation
with
telone,
telone+
chloropicrin
or
metam
sodium
for
tomato
planting
in
April.

MICHIGAN
REGION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
Plant
Hardiness
Zone)
5B
SOIL
TEMP.
(
°
C)*
<
10
10­
15
15­
20
20­
25
20­
25
20­
25
20
10­
15
10
<
10
<
10
<
10
RAINFALL
(
mm)*
*
40
72
101
48
47
32
17
31
36
20
6
8
OUTSIDE
TEMP.
(
°
C)
*
*
0.2
7.4
12.1
17.7
20.6
20.9
18.1
8.0
2.4
­
2.9
­
8.0
­
7.0
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
KEY
MARKET
WINDOW
X
X
X
*
HAUSBECK
AND
CORTRIGHT
(
2003).
**
DATA
SOURCE
"
http://
www.
crh.
noaa.
gov/
grr/
climate/
f6/
preliminary.
php?
site=
LAN"

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

Low
soil
temperatures
during
late
March
to
early
April
make
the
use
of
in­
kind
(
metamsodium
1,3­
D
+
chloropicrin)
fumigants
impractical
because
soil
temperatures
may
be
below
the
labeled
minimums
or
plant
back
restrictions
are
too
long
(
15
to
30
days)
to
allow
April
transplanting
of
tomato
seedlings
in
the
field.
Page
23
MICHIGAN
REGION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
MICHIGAN
REGION
­
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)
435
476
487
581
648
673
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
strip
100%
strip
100%
strip
100%
strip
100%
strip
100%
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
21,001
22,964
23,493
28,003
31,235
32,461
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
48
48
48
48
48
48
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
71.6*
71.6
71.6
71.6
71.6
71.6
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
13.1
13.1
13.1
13.1
13.1
13.1
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
19.5
19.5
19.5
19.5
19.5
19.5
*
Only
36.7
percent
land
area
is
treated
in
the
form
of
beds
and
therefore
dosage
rate
(
g/
m2)
is
higher.
Page
24
MICHIGAN
REGION
­
PART
C:
TECHNICAL
VALIDATION
MICHIGAN
REGION
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
(
Give
list
of
all
relevant
chemical
and
non
chemical
alternatives,
and
their
combinations)

MICHIGAN
REGION
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
D
It
is
not
effective
against
fungal
plant
pathogens.
No
Metam
sodium
Metam
sodium
is
effective
against
soil
fungi.
Michigan
soil
temperature
during
April
are
too
low
to
use
this
fumigant
for
an
early
fresh
market
tomato
crop.
Product
label
states
that
transplant
cannot
be
planted
in
the
field
up
to
21
days
after
fumigation.
Technically,
it
is
methyl
bromide
alternative
but
economically
it
is
not
a
viable
alternative.
No
Chloropicrin
Chloropicrin
is
ineffective
as
soil
fumigant
when
applied
alone.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
Michigan
is
a
northern
state
with
cold
weather
conditions
and
therefore
it
is
not
a
viable
option.
No
Steam
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
the
open
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nematodes.
While
biological
control
may
have
utility
as
part
of
plant
pathogen
management
strategy,
it
can
not
be
a
methyl
bromide
alternative
No
Cover
crops
and
mulching
There
is
no
evidence
that
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
fungal
pathogens
and
nematodes.
No
Crop
rotation
and
fallow
land
The
land
is
very
expensive
and
there
are
not
enough
hectares
in
tomato
growing
areas
to
rotate.
The
fungal
pathogen
survive
for
many
years
in
soil
and
therefore
crop
rotation
and
fallow
are
not
a
viable
options
(
Lamour
and
Hausbeck,
2003*)
No
Page
25
Endophytes
No
information
is
available
on
tomato
endophytes
that
will
control
fungal
and
plant
pathogens.
No
Flooding/
Water
management
Flooding
is
not
technically
feasible
because
it
does
not
suppress
fungal
plant
pathogens
and
nematodes.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
target
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
fungal
pathogens
and
nematodes.
No
COMBINATIONS
OF
ALTERNATIVES
Telone
+
Chloropicrin
Telone
is
effective
against
nematodes.
Chloropicrin
is
effective
against
fungal
plant
pathogens.
Their
combination
is
a
technically
feasible
alternative,
but
Michigan's
low
soil
temperature
does
not
allow
soil
fumigation
during
April
months
for
early
fresh
market
tomato
crop.
No
Metam
sodium
+
Crop
rotation
Same
as
metam
sodium
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

MICHIGAN
REGION
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
those
options
discussed
above,
there
are
no
alternatives
that
may
control
the
key
pest.
Registered
fungicides
(
such
as
azoxystrobin,
mefenoxam
and
mancozeb)
may
control
aerial
infections
of
Phytophthora
capsici,
but
are
not
effective
against
collar
and
root
rot
phase
of
this
pathogen.
Soil
fumigation
with
methyl
bromide
kills
soil­
borne
primary
inoculum
of
this
pest
and
therefore
fungicide
use
is
also
reduced
(
Lamour
and
Hausbeck,
2003*)
Page
26
MICHIGAN
REGION
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

MICHIGAN
REGION
 
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:

Methyl
Iodide
Not
registered.
Yes
Unknown
Sodium
azide
Not
registered.
No
registration
package
has
been
received.
No
Unknown
Furfural
Not
registered
No
Unknown
Propargyl
Bromide
Not
registered.
No
registration
package
has
been
received.
No
Unknown
MICHIGAN
REGION
­
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:

The
applicant
submitted
the
results
of
one
small
scale
field
trial
on
the
efficacy
of
methyl
bromide
alternatives
in
controlling
the
pest
and
their
effect
on
tomato
yield
(
Hausbeck
and
Cortwright,
2003).
This
study
focused
on
tomato
and
a
number
of
vegetable
crops
(
cucurbits,
winter
squash,
and
melons).
As
of
July
2003,
results
showed
that
methyl
bromide+
chloropicrin
(
67/
33,
shank
injected
@
390
Kg/
Hectare),
metam
sodium
(
drip
applied)
@
355
KG
ai/
ha),
1,
3­
D+
chloropicrin
(
65/
35,
shank
injected
@
150
liters/
ha)
resulted
in
0,
12.9,
6.4
percent
plant
loss.
Untreated
control
suffered
7.1%
plant
loss.

The
fields
were
treated
on
May
15
and
16,
2003,
and
the
weather
was
unusually
cooler
than
normal
during
May
and
early
June
of
the
year
2003.
The
results
are
inconclusive.
This
study
may
be
repeated
during
2004
growing
season.
The
state
expert
claims
that
the
growers
may
suffer
6.4
and
12.9
percent
yield
losses
using
1,
3­
D
+
chloropicrin
and
metam
sodium.
The
expert
claims
that
these
losses
are
expected
if
the
grower
fumigate
their
fields
in
early
May
instead
of
April
(
using
methyl
bromide
+
chloropicrin).
In
addition,
the
growers
may
also
suffer
revenue
losses
if
they
miss
early
tomato
market
when
prices
are
higher.

MICHIGAN
REGION
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available.
Page
27
MICHIGAN
REGION
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
methyl
bromide+
chloropicrin
Phytophthora
capsici
0.0
 
0.0
0.0
metam
sodium
Phytophthora
capsici
0.0
 
12.9
12.9
1,
3­
D+
chloropicrin
Phytophthora
capsici
0.0
 
6.4
6.4
chloropicrin
Phytophthora
capsici
0.0
 
6.4
6.4
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
0
­
13
%
plus
revenue
losses
due
to
planting;
Most
likely
losses
are
6
%
using
1,3
D
+
chloropicrin
(
the
best
alternative)

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

In
Michigan
the
critical
use
exemption
application
states
that
telone
+
chloropicrin,
metamsodium
methyl
iodide,
sodium
azide,
and
furfural
will
continue
to
be
under
investigation
as
methyl
bromide
alternatives.
Most
of
these
alternatives
are
currently
unregistered
for
use
on
tomato,
and
there
are
presently
no
commercial
entities
pursuing
registration
in
the
United
States.
The
timeline
for
developing
the
above­
mentioned
MB
alternatives
in
Michigan
is
as
follows:
2003
 
2005:
Test
for
efficacy
(
particularly
against
the
more
prevalent
Phytophthora)
2005
 
2007:
Establish
on­
farm
demonstration
plots
for
effective
MB
alternatives
2008
 
2010:
Work
with
growers
to
implement
commercial
use
of
effective
alternatives.

Research
is
also
under
way
to
optimize
the
use
of
a
50
%
methyl
bromide:
50
%
chloropicrin
formulation
to
replace
the
currently
used
67:
33
formulation.
In
addition,
field
research
is
being
conducted
to
optimize
a
combination
of
crop
rotation,
raised
crop
beds,
black
plastic,
and
foliar
fungicides.
Use
of
virtually
impermeable
film
(
VIF)
will
also
be
investigated
as
a
replacement
for
the
currently
used
low
density
polyethylene
(
LDPE).
Page
28
MICHIGAN
REGION
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:
(
e.
g.
soilless
systems,
plug
plants,
containerized
plants.
State
proportion
of
crop
already
grown
in
such
systems
nationally
and
if
any
constraints
exist
to
adoption
of
these
systems
to
replace
methyl
bromide
use.
State
whether
such
technologies
could
replace
a
portion
of
proposed
methyl
bromide
use.)

Tomatoes
are
grown
in
fields.
In
michigan,
it
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.

MICHIGAN
REGION
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Although
the
U.
S.
E.
P.
A.
determined
that
metam
sodium
and
a
combination
of
telone
+
chloropicrin
can
control
the
key
pest,
Phytophthora,
the
planting
and
harvesting
delay
due
to
cold
soil
temperatures
and
longer
plant­
back
interval
lead
to
a
shorter
growing
season
and
missing
key
market
windows
when
commodity
prices
are
most
favorable.
These
alternatives
have
plant
back
restriction
of
14­
28
days.
The
plant
back
restriction
delays
tomato
harvest
by
14­
28
days.
The
delayed
harvest
results
in
lower
net
revenues
per
acre
because
tomato
prices
decline
as
season
progresses.

Currently
unregistered
alternatives,
such
as
methyl
iodide,
sodium
azide,
propargyl
bromide
and
furfural
have
good
efficacy
against
the
key
pests
involved.
However,
even
if
registration
is
pursued,
the
growers
will
need
transition
time
to
adopt
them.

SOUTH­
EASTERN
UNITED
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
SOUTH­
EASTERN
UNITED
STATES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTH­
EASTERN
UNITED
STATES
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
South­
Eastern
United
States
Nutsedges
(
Cyperus
rotundus
and
C.
esculentus)

Root­
Knot
nematodes
Phytophthora
Crown
and
Root
Rot.
Fusarium
Wilt
(
F.
oxysporum)
None
of
the
listed
MBTOC
alternative
is
effective
in
controlling
the
key
pests
in
the
South­
Eastern
United
States.
Page
29
SOUTH­
EASTERN
UNITED
STATES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
(
Place
major
attention
on
the
key
characteristics
that
affect
the
uptake
of
alternatives):

SOUTH­
EASTERN
UNITED
STATES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTH­
EASTERN
UNITED
STATES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
for
tomato
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Tomato.
Tomato­
Cucumber
or
Squash
or
Watermelon
or
Cantaloupe.
Tomato­
Cucurbits.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
loam,
over
karst
geology
in
many
areas
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
No
other
information
provided.

SOUTH­
EASTERN
UNITED
STATES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
Plant
Hardiness
Zone)
6b,
7a,
7b,
8a,
8b,
9b,
10a,
10b
SOIL
TEMP.
(
°
C)
**
17­
20
17­
21
21­
24
22­
26
25­
29
26­
29
27­
30
28­
32
27­
29
25­
27
21­
23
19­
21
RAINFALL
(
mm)*
51­
203
51­
203
51­
203
51­
203
102­
203
102­
203
51­
203
51­
203
25­
102
25­
102
25­
102
25­
102
OUTSIDE
TEMP.
(
°
C)*
11­
22
16­
23
21­
25
25­
28
26­
28
25­
28
23­
25
17­
25
10­
22
7­
19
7­
19
8­
19
FUMIGATION
SCHEDULE
X
X
X
X
X
X
X
X
PLANTING
SCHEDULE
X
X
X
X
X
X
X
KEY
MARKET
WINDOW
X
X
X
X
X
X
X
X
*
JACOB
(
1977).
**
FLORIDA
SOIL
TEMPERATUTES
SOURCE
IS
WWW.
IMOK.
UFL/
EDU/
WEATHER/
ARCHIVES/
200/
CLIM00
Page
30
SOUTH­
EASTERN
UNITED
STATES
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Karst
geology
inhibits
the
use
of
all
fumigants
that
contain
1,3­
D.

SOUTH­
EASTERN
UNITED
STATES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTH­
EASTERN
UNITED
STATES
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
22,269
24,002
25,814
27,831
28,931
28,572
RATIO
OF
FLAT
FUMIGATION
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
4,484,413
4,747,976
4,491,580
4,462,390
4,514,006
4,370,645
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
Chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
201
196
175
163
158
154
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
20.1
19.6
17.5
16.3
15.8
15.4
Page
31
SOUTH­
EASTERN
UNITED
STATES
­
PART
C:
TECHNICAL
VALIDATION
SOUTH­
EASTERN
UNITED
STATES
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTH­
EASTERN
UNITED
STATES
 
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
Telone
Effective
against
nematodes,
but
not
against
fungal
plant
pathogens
and
nutsedge
weeds.
Approximately
40%
of
tomato
land
has
Karst
geology.
Growers
with
Karst
topography
can
not
use
telone
because
of
underground
water
contamination.
No
Metam
sodium
It
will
control
many
weeds
but
control
of
nutsedge
is
very
inconsistent.
It
is
not
very
effective
against
nematode
population.
No
Chloropicrin
Chloropicrin
controls
soil
fungi
only.
It
also
stimulates
nutsedge
weed
growth
and
therefore
it
is
not
a
viable
option.
It
occasionally
stimulates
nutsedge
emergence
but
also
occasionally
controls
nutsedge
as
noted
in
the
literature.
Again
the
issue
is
its
inability
to
get
consistent
control
(
Culpepper,
2004).
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
U.
S.
states,
solarization
is
unlikely
to
be
technically
feasible
as
a
methyl
bromide
alternative.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50oC
or
higher
(
Chase
et
al.
1999).
While
this
may
be
achieved
for
some
portion
of
the
autumn
cropping
in
southern
cucurbit
growing
regions,
it
is
very
unlikely
for
any
portion
of
the
spring
crops.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43oC
at
5
cm
depth,
not
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
tomato
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens,
nematodes
and
nutsedges.
No
Page
32
Cover
crops
and
mulching
Cover
crops
and
mulches
appear
to
reduce
weed
population,
but
not
nutsedges
(
Burgos
and
Talbert
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
since
these
plants
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
Crop
rotation
and
fallow
land
It
is
not
a
technically
or
economically
(
can
not
afford
to
take
land
out
of
production)
feasible
alternative
to
methyl
bromide
because
it
does
not,
by
itself,
provide
adequate
control
of
fungi
and/
or
nutsedges.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores.
As
regards
nutsedges,
tubers
of
these
perennial
species
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land.
Furthermore,
nutsedge
plants
can
produce
tubers
within
8
weeks
after
emergence.
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Endophytes
It
is
not
a
technically
viable
option
because
it
has
never
been
shown
to
work
against
the
key
pests
in
tomato
or
similar
crops.
No
Flooding/
Water
management
Flooding
has
never
been
shown
to
control
nutsedge
species.
Nutsedges
are
much
more
tolerant
of
watery
conditions
than
many
other
weed
pests.
For
example,
Horowitz
(
1972)
showed
that
submerging
nutsedge
in
flowing
or
stagnant
water
(
for
8
days
and
4
weeks,
respectively)
did
not
affect
the
sprouting
capacity
of
tubers.
There
are
also
serious
practical
obstacles
to
implementing
flood
management
approaches
in
cucurbit
production
in
the
southern
and
southeastern
U.
S.
states.
Droughts
are
common
in
many
parts
of
these
regions,
and
the
soil
composition
may
not
support
flooding
and
still
remain
productive.
No
Grafting/
resistant
rootstock/
plant
breeding/
soil­
less
culture/
organic
production/
substrates/
plug
plants.
These
technologies
have
never
been
shown
to
control
listed
key
pests
under
field
conditions.
Resistant
root
stock
or
cultivars
may
control
one
pest,
but
not
the
other.
It
is
almost
impossible
to
breed
or
genetically
engineer
tomato
cultivars
that
has
all
agronomic
characters
and
is
resistant
to
all
key
pests.
This
has
no
effect
on
managing
nutsedge
weeds.
No
COMBINATIONS
OF
ALTERNATIVES
1,3
D
+
chloropicrin+
herbicide
(
such
as
pebulate)
This
combination
is
the
most
promising
alternative
for
the
control
of
all
key
pests
in
southeastern
region.
The
executive
summary
of
dozens
of
research
trials
show
that
the
growers
may
harvest
tomato
yield
that
is
near
equal
to
the
yield
obtained
using
methyl
bromide
and
chloropicrin.
Using
this
combination
the
growers
may
lose
an
average
of
6.2%
yield
in
areas
where
this
combination
can
be
used
(
Chellemi
et
al.,
2001).
May
be
Page
33
Metam
sodium
+
Chloropicrin
This
mixture
may
be
more
effective
than
metam
sodium
alone
in
controlling
fungal
pests,
but
this
combination
would
not
prevent
yield
losses
caused
by
nutsedges
and
some
species
of
nematodes.
This
mixture
along
with
a
herbicide
(
for
controlling
nutsedge
weeds)
may
be
a
viable
methyl
bromide
alternative
in
the
South­
Eastern
United
States
where
the
growers
can
not
use
telone
due
to
karst
topography.
Further
experiments
need
to
be
done
on
this
mixture
to
find
out
whether
or
not
it
is
technically
and
economically
viable.
May
be
Telone
+
Chloropicrin
It
is
effective
against
nematodes
and
fungal
plant
pathogens,
but
not
against
nutsedge
and
other
weeds.
Approximately
40
and
8.0%
of
tomato
land
in
Florida
and
Georgia,
respectively,
has
Karst
geology.
Growers
with
Karst
topography
can
not
use
telone
because
of
state
regulations
and
underground
water
contamination
issues.
No
Telone
+
metam
sodium
+
herbicide
(
such
as
pebulate)
This
mixture
could
provide
reasonable
control
of
pests
if
weed
pressure
is
low
to
moderate
and
land
does
not
have
Karst
geology.
Pebulate
is
no
longer
registered
because
the
manufacturer
went
out
of
business
during
2002.
Growers
will
need
to
use
one
of
the
newly
registered
herbicides
if
they
use
this
combination,
and
will
be
constrained
by
certain
limitations
(
described
below).
No
Metam
sodium
+
Crop
rotation
Same
as
metam
sodium.

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

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

SOUTH­
EASTERN
UNITED
STATES
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Glyphosate
For
nutsedges:
Non­
selective
herbicide
that
will
not
control
nutsedge.
It
is
not
labeled
for
row
middle
application.
In
addition,
it
does
not
provide
residual
control.
It
is
a
non­
selective
herbicide
used
to
control
weeds
in
row
middles.
Application
to
the
rows
would
cause
injury
to
the
tomato
crop.
As
a
preplant
treatment
glyphosate
will
not
provide
season
long
control
of
yellow
and/
or
purple
nutsedge
in
tomatoes.

Paraquat
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Its
repetitive
applications
are
required
to
achieve
fair
control
in
the
row
middle
(
Culpepper,
2003).
Paraquat
is
a
non­
selective
herbicide
that
controls
annual
weeds
in
row
middles.
It
may
also
be
applied
preemergence
to
the
crop.
Application
to
the
rows
would
cause
injury
to
the
tomato
crop.
For
perennial
weeds,
such
as
nutsedge,
it
will
burn
down
the
top
portion
of
the
plant
but
the
tubers
remain
viable,
allowing
the
weed
to
grow
again.
Therefore,
paraquat
will
not
provide
season
long
control
because
the
weed
can
regrow
during
the
growing
season.
Page
34
SOUTH­
EASTERN
UNITED
STATES
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

SOUTH­
EASTERN
UNITED
STATES
 
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:

Halosulfuronmethyl
There
are
a
number
of
restrictions
limiting
the
potential
to
use
this
herbicide
in
tomatoes
in
the
Southeast
(
see
additional
notes
below).
Among
these
are
potential
crop
injury
and
plant
back
restrictions
for
rotational
crops.
Efficacy
is
lowered
in
rainy
conditions
(
which
are
common
in
this
region).
Need
more
time
to
experiment
under
field
conditions.
Yes
Recently
registered
Pebulate
For
nutsedges:
Was
registered
for
use
in
tomatoes
only,
its
registration
expired
during
December,
2002
(
the
manufacturer
went
out
of
business)
No
Unknown
S­
metolachlor
For
nutsedges:
Not
registered
in
some
states
of
concern.
It
is
effective
against
yellow
nutsedge
and
not
effective
against
purple
nutsedge
(
Culpepper,
2004).
Yes
Already
registered
Terbacil
For
nutsedges:
Registered
ONLY
in
strawberries.
The
manufacturer
claims
that
it
is
partially
effective
against
yellow
nutsedge
and
does
not
control
purple
nutsedge.
No
Unknown
Rimsulfuron
Registered
for
the
control
of
nutsedge
weeds
in
tomatoes.
The
product
label
states
that
it
is
partially
effective
against
nutsedges.
Y
Already
registered
Trifloxysulfuron
For
nutsedges:
Newly
Registrated
for
use
in
tomato.
Efficacy
needs
to
be
tested
under
large
scale
field
trials.
Labeled
for
use
in
Florida
only.
It
provides
good
control
of
nutsedge
but
rotational
restrictions
may
limit
its
large
scale
adoption.
Y
Already
registered
Methyl
Iodide
Not
yet
registered
in
the
United
States
Y
unknown
Sodium
azide
Not
registered
in
the
United
States
No
unknown
Sulfuryl
Floride
It
is
not
registered
for
preplant
soil
treatment.
It
is
registered
for
postharvest
treatment
of
agricultural
produce
(
tomato
not
included)
The
registrant
has
not
contacted
USEPA
for
its
use
as
a
preplant
soil
fumigant.
unknown
Additional
notes
on
specific
herbicides
listed:
Halosulfuron­
methyl
In
December
2002,
halosulfuron­
methyl
(
Sandea
®
)
was
registered
for
weed
control
(
including
nutsedge)
in
tomatoes,
peppers,
eggplant,
and
cucurbits.
This
recent
registration
was
not
on
the
list
of
alternatives
from
Page
35
MBTOC
and
several
years
are
needed
to
see
if
it
will
be
adopted.
Historically,
in
the
United
States
it
has
taken
three
to
five
years
for
an
herbicide
to
be
adopted
by
a
significant
number
of
vegetable
crop
growers.

Halosulfuron­
methyl
has
a
number
of
limitations
which
may
affect
its
widespread
adoption,
that
include:
(
1)
phyto­
toxicity
with
moderate
rainfall
immediately
after
application;
(
2)
cool
temperatures,
(
3)
susceptible
varieties,
and
(
4)
plant
back
restrictions.
Specifically:
 
Rainfall
or
sprinkler
irrigation
greater
than
2.5
cm,
soon
after
a
pre­
emergent
application
of
halosulfuronmethyl
may
cause
crop
injury.
Sudden
storms
with
greater
than
2.5
cm
of
rainfall
are
common
in
Florida
and
other
areas
of
the
southeastern
United
States.
In
addition,
rainfall
within
four
hours
after
a
postemergence
application
of
halosulfuron­
methyl
may
reduce
effectiveness
and
cause
crop
injury.
 
Under
cool
temperatures
that
can
delay
early
seedling
emergence
or
growth,
halosulfuron
methyl
can
cause
injury
or
crop
failure.
This
is
especially
likely
to
occur
during
the
first
planting
of
the
season.
In
addition,
not
all
hybrids/
varieties
of
tomatoes
have
been
tested
for
sensitivity
to
halosulfuron­
methyl.
Halosulfuron
may
also
delay
maturity
of
treated
crops.
 
Halosulfuron
methyl
plant
back
restrictions
are
up
to
36
months.
Many
of
the
vegetable
crops
fall
within
the
4
to
12
month
range,
although
some
are
longer.
There
are
label
limitations
for
halosulfuron
methyl.
As
per
product
label,
halosulfuron
methyl
should
not
be
applied
if
the
crop
or
target
weeds
are
under
stress
due
to
drought,
water
saturated
soils,
low
fertility,
or
other
poor
growing
conditions.
This
herbicide
can
not
be
applied
to
soil
that
has
been
treated
with
organophosphate
insecticides.
Foliar
applications
of
organophosphate
insecticides
may
not
be
made
within
21
days
before
or
7
days
after
halosulfuron
methyl
application.
Note:
All
the
limitations
above
are
listed
in
the
US
registration
label
for
halosulfuron,
which
in
turn
is
based
on
proprietary
data
submitted
to
EPA
by
the
registrant
company.

S­
metolachlor
It
was
registered
for
use
in
tomatoes
in
April
2003.
However,
it
is
not
registered
in
states
of
concern,
and
does
not
control
purple
nutsedge
or
nightshade
species.
Further,
it
does
not
provide
commercially
acceptable
weed
control
in
plasticulture
systems.
Rimsulfuron
There
is
evidence
that
rimsulfuron
only
provides
suppressive
control
of
yellow
nutsedge
(
40
to
70
percent
control)
(
Nelson
et
al,
2002).
In
addition,
the
label
warns
against
tank
mixing
with
organophosphate
insecticides
because
injury
to
the
crop
may
occur.
Also,
for
most
of
the
vegetable
crops
besides
tomatoes
there
is
a
12­
month
plant
back
restriction.
This
plant
back
restriction
can
seriously
compromise
the
needed
rotational
interval
needed
for
IPM
programs.
Page
36
SOUTH­
EASTERN
UNITED
STATES
­
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
Telone
C35
(
1,3
D
+
35
%
chloropicrin)
plus
pebulate
herbicide
has
been
found
to
be
the
best
alternative
to
methyl
bromide
in
controlling
listed
key
pests
under
Florida
growing
conditions
(
Chellemi
et
al.,
2001).
Pebulate
is
no
longer
registered
in
the
U.
S.,
however,
so
another
herbicide
would
have
to
be
substituted
into
the
fumigation
mixture.
The
results
of
many
trials
showed
that
growers
may
harvest
tomato
yield
that
is
near
equal
to
the
yield
obtained
using
methyl
bromide
and
chloropicrin.
Assuming
that
an
herbicide
is
used
that
is
as
effective
as
pebulate,
growers
using
a
1,3­
D
+
chloropicrin
+
herbicide
mixture
may
suffer
an
average
of
6.2
percent
yield
losses
(
Chellemi
et
al.,
2001).
Florida
and
Georgia
experts
claim
the
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
herbicides
will
be
higher
than
6.2
percent
because
pebulate
is
no
longer
registered
and
other
herbicides
have
limitations.
The
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials.
The
experts
claim
that
more
time
is
needed
to
evaluate
various
methyl
bromide
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.

SOUTH­
EASTERN
UNITED
STATES
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available.

SOUTH­
EASTERN
UNITED
STATES
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
D
+
chloropicrin
+
herbicide
Fungi,
Nematodes
and
Nutsedges
2.3
 
10.1
(
Chellemi
et
al.,
2001)
6.2
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
6.2%

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

A
combination
of
1,3
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
herbicide
is
no
longer
available
then
the
growers
will
have
to
substitute
another
herbicide,
listed
in
table
14.1
and
15.1
(
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
to
achieve
similar
pest
control).
Florida
and
Georgia
state
expert
claim
the
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
herbicides
will
be
higher
than
6.2
losses
because
pebulate
is
no
longer
registered
and
other
herbicides
have
limitations.
The
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials.
The
experts
claim
that
more
time
is
needed
to
evaluate
various
methyl
bromide
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.
Page
37
SOUTH­
EASTERN
UNITED
STATES
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?
(
e.
g.
soilless
systems,
plug
plants,
containerized
plants.
State
proportion
of
crop
already
grown
in
such
systems
nationally
and
if
any
constraints
exist
to
adoption
of
these
systems
to
replace
methyl
bromide
use.
State
whether
such
technologies
could
replace
a
portion
of
proposed
methyl
bromide
use.)

Tomatoes
are
grown
in
fields.
In
South­
eastern
united
states,
it
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.
Page
38
SOUTH­
EASTERN
UNITED
STATES
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
submitted
data
showed
that
using
the
above
best
alternative
the
growers
are
expected
to
suffer
6.2%
yield
losses
(
Chellemi,
Botts
and
Noling.
2001).
A
combination
of
1,3­
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
is
no
longer
available
then
the
growers
will
need
to
substitute
another
herbicides
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
to
control
nutsedge
weeds.
But,
these
herbicides
have
significant
limitations,
as
described
in
the
notes
to
Table
15.1.
In
addition,
losses
will
be
higher
in
areas
of
Karst
geology,
where
1,3­
D
may
not
be
used.

Florida
and
Georgia
state
expert
claim
that
the
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
other
herbicides
will
be
higher
than
6.2
losses
because
of
limitations
of
other
herbicides
(
see
table
14.1
and
15.1).
The
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials.
The
experts
claim
that
more
time
is
needed
to
evaluate
various
methyl
bromide
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.
Page
39
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?
Start
research
during
2004
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future.
Between
1997
and
2002,
the
US
has
achieved
a
27
%
reduction
in
use
rates.
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
The
US
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Start
research
during
2004
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
Not
applicable
OTHER
MEASURES
(
please
describe)
Not
applicable
Not
applicable
Not
applicable
Not
applicable
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS:

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

As
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
95%
Page
40
methyl
bromide
and
5%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
at
low
to
moderate
levels
of
infestation,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.

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

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.

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

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

21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
REGION
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Methyl
Bromide
100
$
50,240
$
50,240
$
50,240
Metam
Sodium
85
$
46,353
$
46,353
$
46,353
CALIFORNIA
Metam
Sodium
80
$
44,626
$
44,626
$
44,626
Methyl
Bromide
100
$
30,559
$
30,559
$
30,559
1,3
 
D
+
Chloropicrin
78
$
29,555
$
29,555
$
29,555
Metam
Sodium
78
$
29,739
$
29,739
$
29,739
MICHIGAN
Chloropicrin
78
$
29,555
$
29,555
$
29,555
Methyl
Bromide
100
$
26,380
$
26,380
$
26,380
SOUTHEASTERN
US
1,3
 
D
+
Chloropicrin
83
$
24,946
$
24,946
$
24,946
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
e.
g.
10%
more
yield,
write
110.
Page
41
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%
loss)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
loss
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%
loss)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
loss
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%
loss)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
loss
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
Page
42
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
METAM
SODIUM
PRODUCTION
LOSS
(%)
0%
15%
20%

PRODUCTION
PER
HECTARE
11,106
9,440
8,885
*
PRICE
PER
UNIT
(
US$)
$
8
$
8
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
83,367
$
70,862
$
66,694
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
50,240
$
46,353
$
44,626
=
NET
REVENUE
PER
HECTARE
(
US$)
$
33,127
$
24,509
$
22,068
LOSS
MEASURES
*
1.
LOSS
PER
HECTARE
(
US$)
$
­
$
8,618
$
11,059
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
82
$
105
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
10%
13%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
26%
33%

MICHIGAN
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
METHYL
BROMIDE
1,3­
D
+
PIC
METAM
SODIUM
CHLOROPICRIN
PRODUCTION
LOSS
(%)
0%
6%
6%
6%
PRODUCTION
PER
HECTARE
4,248
3,976
3,976
3,976
*
PRICE
PER
UNIT
(
US$)
$
9
$
8
$
9
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
39,996
$
32,880
$
34,931
$
32,880
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
30,559
$
29,555
$
29,739
$
29,555
=
NET
REVENUE
PER
HECTARE
(
US$)
$
9,438
$
3,325
$
5,192
$
3,325
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
­
$
6,113
$
4,246
$
6,113
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
127
$
88
$
127
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
15%
11%
15%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
65%
45%
65%
Page
43
SOUTHEASTERN
US
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
US
METHYL
BROMIDE
1,3­
D
+
PIC
PRODUCTION
LOSS
(%)
0%
6%
PRODUCTION
PER
HECTARE
4,382
4,110
*
PRICE
PER
UNIT
(
US$)
$
9
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
40,914
$
33,772
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
26,380
$
24,946
=
NET
REVENUE
PER
HECTARE
(
US$)
$
14,533
$
8,825
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
­
$
5,708
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
38
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
14%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
OPERATING
REVENUE
(%)
0%
39%

SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
of
the
tomato
application
compared
data
on
yields,
crop
prices,
revenues
and
costs
using
methyl
bromide
and
using
alternative
pest
control
regimens
in
order
to
estimate
the
loss
of
methyl
bromide
availability.
The
alternatives
identified
as
technically
feasible
­
in
cases
of
low
pest
infestation
­
by
the
U.
S.
are:
(
a)
1,3­
Dichloropropene
+
Chloropicrin;
(
b)
Metam
sodium;
and
(
c)
Chloropicrin.
Changes
in
pest
control
costs
for
tomatoes
are
less
than
4
percent
of
total
variable
costs
therefore
they
would
have
little
impact
on
any
of
the
economic
measures
used
in
the
analysis.

The
economic
factors
that
really
drives
the
feasibility
analysis
for
fresh
market
tomato
uses
of
methyl
bromide
are:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices
(
3)
quality
losses,
which
generally
affect
the
quantity
and
price
received
for
the
goods,
and
(
4)
missed
market
windows
due
to
plant
back
time
restrictions,
which
also
affect
the
quantity
and
price
received
for
the
goods.

The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
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.
Page
44
(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production.

(
3)
Loss
as
a
Percentage
of
Gross
Revenue.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

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

(
5)
Operating
Profit
Margin.
We
define
operating
profit
margin
to
be
net
operating
revenue
divided
by
gross
revenue
per
hectare.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult,
therefore
fixed
costs
were
not
included
in
the
analysis.

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

California
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
California
tomato
production.
Yield
loss
in
California
tomato
production
is
expected
to
be
15~
20%
when
using
MeBr
alternatives.
Growers
will
experience
loss
on
a
per
hectare
basis
of
approximately
US$
8,618
to
US$
11,059
and
approximately
10%
and
35%
losses
in
gross
and
net
operating
revenues,
respectively.
These
measures
clearly
indicate
that
Metam­
Sodium
is
not
an
economically
feasible
alternative
to
MeBr.

We
have
quantified
the
economic
conditions
of
tomato
growers
as
best
as
possible
but,
primarily
due
to
limited
data
availability,
are
unable
to
capture
every
aspect
of
the
economic
picture
in
our
numeric
analysis.
Factors
not
accounted
for
in
this
analysis
are
distribution
of
yield
loss
across
individual
growers
and
the
yield
risk
associated
with
using
MeBr
alternatives.

Michigan
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Michigan
tomato
production.
Three
factors
have
proven
most
important
in
our
conclusion.
These
are
yield
loss,
quality
loss,
and
missed
market
windows,
which
are
discussed
individually
below.
Page
45
1.
Yield
Loss
­
Expected
yield
losses
of
6%
are
anticipated
throughout
Michigan
tomato
production.

2.
Quality
Loss
 
Expected
quality
losses
of
7%
are
anticipated
throughout
Michigan
tomato
production.
The
quality
losses
are
translated
into
a
reduction
in
the
season
average
price
by
1~
3%.

3.
Missed
Market
Windows
­
We
agree
with
Michigan's
assertion
that
growers
will
likely
receive
significantly
lower
prices
for
their
produce
if
they
switch
to
1,3­
D
+
chloropicrin
or
Metam­
Sodium
or
Chloropicrin.
This
is
due
to
changes
in
the
harvest
schedule
caused
by
the
above
described
soil
temperature
complications
and
extended
plant
back
intervals
when
using
these
alternatives.

Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
tomato
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
tomatoes
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
tomato
operations.

To
describe
these
conditions
in
Michigan
tomato
production,
we
used
daily
tomato
sales
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
year
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
we
assume
that
if
tomato
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin
or
Metam­
Sodium
or
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
accumulate
gross
revenues
reduced
by
approximately
4~
11%.
We
reduced
the
season
average
price
by
4~
11%
in
our
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
we
believe
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Michigan.

Southeastern
US
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Southeastern
US
tomato
production.
Two
factors
have
proven
most
important
in
our
conclusion.
These
are
yield
loss
and
missed
market
windows,
which
are
discussed
individually
below.

1.
Yield
Loss
­
Expected
yield
losses
of
6%
are
anticipated
throughout
Michigan
tomato
production.

2.
Missed
Market
Windows
­
We
agree
with
Southeastern
US's
assertion
that
growers
will
likely
receive
significantly
lower
prices
for
their
produce
if
they
switch
to
1,3­
D
+
chloropicrin.
This
is
Page
46
due
to
changes
in
the
harvest
schedule
caused
by
the
above
described
soil
temperature
complications
and
extended
plant
back
intervals
when
using
these
alternatives.

Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
tomato
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
tomatoes
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
tomato
operations.

To
describe
these
conditions
in
Southeastern
US
tomato
production,
we
used
weekly
tomato
sales
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
three
years
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
we
assume
that
if
tomato
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
accumulate
gross
revenues
reduced
by
approximately
12%.
We
reduced
the
season
average
price
by
12%
in
our
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
we
believe
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Southeastern
US.
Page
47
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?
(
Based
on
responses
to
Question
13,
the
answer
should
include
activities
that
would
be
undertaken
to
overcome
the
difficulties
that
resulted
in
the
alternatives
being
considered
unsuitable.
Include
a
timetable
for
completion
of
key
activities.):

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

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

As
per
Culpepper
(
2004),
over
50
vegetable
trials,
focusing
on
weed
management,
were
conducted
by
the
University
of
Georgia.
Four
of
these
trials
compared
methyl
bromide
alternatives
and
another
30
trials
searched
for
the
development
and
labeling
of
new
herbicides
for
vegetables.
During
2004,
these
experiments
will
be
continued
to
find
methyl
bromide
alternatives.

The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
tomatoes
research
will
require
5501
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
research
request
also
includes
the
amounts
for
asparagus,
cabbage,
ginseng,
and
Page
48
nutsedge
for
74
kg
per
year.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
the
research
is
a
field
study
testing
the
comparative
performance
of
methyl
bromide,
host
resistance,
cultural
practices,
pest
management
approaches
for
control
of
root­
knot
nematodes.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
D
combined
with
biologically
based
materials
including
transplant
treatments
for
control
of
weeds,
root­
knot
nematodes
and
soil
borne
fungal
pathogens.

24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?
(
Include
a
plan
of
the
stepwise
reduction
schedule
for
methyl
bromide
as
alternatives
are
phased
in
and/
or
additional
emission
controls
are
implemented):

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.
Georgia
experts
(
Culpepper,
2004)
note
that
the
ability
to
reduce
the
use
of
methyl
bromide
will
rely
on
the
interaction
of
fumigant
alternatives,
plastic
mulches
and
herbicide
systems
under
specific
growing
conditions.
More
time
is
needed
to
develop
these
systems.
Page
49
25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?)

Research
efforts
began
in
the
early
1990'
s
to
find
out
methyl
bromide
alternatives
in
various
crops
including
tomato.
With
each
year
of
experimentation
the
researchers
became
more
familiar
and
efficient
with
methyl
bromide
fumigant
alternatives
for
nutsedge
management.
The
researchers
learned
strengths
and
weakness
of
each
fumigant
system,
plastic
film
types,
herbicide
system,
and
various
production
environments.
The
researchers
need
more
time
to
evaluate
and
refine
these
systems
in
large
scale
trials
prior
to
large
scale
implementation
at
growers
field
level.
Page
50
26.
CITATIONS
Chellemi,
D.,
Botts,
D.
A.
and
Noling,
J.
W.
2001.
Field
scale
demonstration/
validation
studies
of
methyl
bromide
in
plastic
mulch
culture
in
Florida,
USDA
ARS
specific
co­
operative
agreement
SCA
#
58­
6617­
6­
013,
Executive
Summary
(
1996­
2001)
submitted
to
the
USEPA

Burnette,
G.
2003.
Personal
communication,
November
25,
2003.

Culpepper,
Stanley.
2004.
Faculty,
University
of
Georgia,
Athens,
GA.
Comments
on
methyl
bromide
Critical
use
nomination
for
preplant
soil
use
for
tomato
grown
in
open
fields.

Florida.
2000.
Florida
soil
temperatures.
Web
address:
www.
imok.
ufl/
edu/
weather/
archive/
200/
clim00
Hausbeck,
M.
and
Cortright,
B.
2003.
Soil
temperature
data
submitted
to
BEAD
(
OPP,
US­
EPA)
in
support
of
methyl
bromide
critical
use
exemption
application.

Jacob,
W.
C.
1977.
Range
of
mean
outside
temperature
and
rainfall
in
South­
Eastern
United
States.
Climatic
Atlas
of
the
United
States.
Published
by
the
US
Department
of
Commerce.

Lamour,
H.
H.
and
Hausbeck,
M.
2003.
Effect
of
crop
rotation
on
the
survival
of
Phytophthora
capsici
in
Michigan.
Plant
Disease
87:
841­
845.

Locasio,
S.
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.,
Kucharek,
T.
A.,
Jones,
J.
P.
and
Noling,
J.
W.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene­
mulched
tomato.
HortScience
32(
7)
1208­
1211.

Morales,
J.
P.,
Santos,
B.
M.,
Stall,
W.
M.
and
Bewick.
T.
A.
1997.
Effects
of
purple
nutsedge
(
Cyprus
rotundus)
on
tomato
and
bell
pepper
vegetative
growth
and
fruit
yield.
Weed
Science
Technology
11:
672­
676.

Nelson,
K.
A.
and
Renner,
K.
A.
2002.
Yellow
nutsedge
(
Cyprus
esculentus)
control
and
tuber
production
with
glyphosate
and
ALS­
inhibiting
herbicides.
Weed
Technology
16(
3):
512­
519.

Norton,
J.,
Nelson,
R.
D.,
Nelson,
M.
D.,
Olson,
B.
O.,
Mey,
B.
V.
and
Lepez,
G.
2000.
Field
evaluation
of
alternatives
to
methyl
bromide
for
pre­
plant
soil
fumigant
in
California
tomatoes.
USDA
IR­
4
methyl
bromide
alternatives
program
for
minor
crop.
Report
submitted
to
the
US­
EPA
during
2003
in
support
of
methyl
bromide
critical
use
exemption.

Stall,
W.
M.
and
Morales­
Payan,
J.
P.
2003.
The
critical
period
of
nutsedge
interference
in
tomato,
Florida.
Web
address:
http://
www.
imok.
ufl.
edu/
liv/
groups/
ipm/
weed_
con/
nutsedge.
htm
Page
51
U.
S.
Environmental
Protection
Agency.
1998.
Re­
registration
Eligibility
Decision
(
RED)
1,3
dichloroprppene.
Available
at
http://
www.
epa.
gov/
REDs/
0328red.
pdf
U.
S.
Environmental
Protection
Agency.
1998.
Feasibility
of
using
gas
permeable
tarps
to
reduce
methyl
bromide
emissions
associated
with
soil
fumigation
in
the
United
States.
Page
52
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).

Date:
Sector:
2001
&
2002
Average
%
of
2001
&
2002
Average
%
of
Request
749
88%
88%

15,479
6%
6%

29,672
97%
101%

45,900
67%
69%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
10,745
223
48
66%

102,058
971
105
0%

2,799,236
18,645
150
38%

2,931,879
19,839
101
37%

37%
37%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
48
48
0%
0%
0%
0%
34%
34%
0%
0%
0%
0%
34%
34%
34%
34%

105
105
0%
0%
0%
0%
0%
0%
9%
1%
100%
100%
0%
0%
100%
100%

150
150
32%
32%
0%
0%
50%
29%
0%
0%
0%
0%
0%
0%
66%
53%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
Tarp
No
­
Yes
4,730
$
98
$
12%
50%

Yes
Yes
Yes
Tarp
No
­
Yes
8,618
$
82
$
10%
26%

Yes
Yes
Yes
Tarp
No
­
Yes
5,708
$
38
$
14%
39%

Conversion
Units:
1
Pound
=
Kilograms
Hectare
Methyl
Bromide
Critical
Use
Exemption
Process
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
1
Acre
=
Combined
Impacts
Adjustment
(
kgs)

HIGH
LOW
2006
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Use
Rate
(
kg/
ha)

31,606
656
48
31,848
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)

102,058
971
105
110,779
28,887
154
0%

661
48
0%

990
112
0%

4,519,688
30,104
150
4,442,326
TOTAL
OR
AVERAGE
4,653,353
31,731
101
2,079,698
30,537
105
0%

2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
(­)
QPS
31,606
­
­
2
2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
102,058
­
­
­
­
2,910,861
­
10,745
­
102,058
4,519,688
­
137,191
­

TOTAL
4,653,353
4,653,353
4,516,161
4,516,159
4,516,159
3,023,665
3%
3%
35%

REGION
Michigan
California
Southeastern
US
%
Reduction
from
Initial
Request
0%
0%
Regulatory
Issues
(%)

3%

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
(%)
Key
Pest
Distribution
REGION
Michigan
Unsuitable
Terrain
(%)

Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
California
Southeastern
US
Adjustments
to
Requested
Amounts
47%
1,3­
D
+
Pic
Combined
Impacts
(%)

15%
Yield
Loss,
Range
15
to
20%

Cold
Soil
Temp
(%)
10,745
102,058
2,352,736
2,465,540
0.453592
0.404686
REGION
Michigan
California
Southeastern
US
California
Southeastern
US
REGION
Michigan
MOST
LIKELY
IMPACT
VALUE
Regional
Hectares**

2/
26/
2004
TOMATOES
Average
Hectares
in
the
US:

%
of
Average
Hectares
Requested:
51,506
62%

21%,
6.2%
Yield
Loss
+
14.8%
delay
Quality/
Time/
Market
Window/
Yield
Loss
(%)
Marginal
Strategy
22%,
6%
Yield
Loss
+
16%
delay
1,3­
D+
Pic+
herbicide
Metam­
Sodium
Page
53
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
54
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
55
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
56
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Page
57
Michigan
Herbaceous
Perennials
4,200
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
.
