METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
TURFGRASS
SOD
GROWN
IN
OPEN
FIELDS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Turfgrass
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
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
_________________________________________________________
6
1.
Nominating
Party
_________________________________________________________
6
2.
Descriptive
Title
of
Nomination______________________________________________
6
3.
Crop
and
Summary
of
Crop
System___________________________________________
6
4.
Methyl
Bromide
Nominated
_________________________________________________
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
7
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
8
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
8
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.
_______________
9
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?______________________________________________________________________
9
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
10
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
_____
10
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
______________
12
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
____________________________________________________________
12
11.
Characteristics
of
Cropping
System
and
Climate_______________________________
12
11.
(
ii)
Indicate
if
any
of
the
above
characteristics
in
11.
(
i)
prevent
the
uptake
of
any
relevant
alternatives?
______________________________________________________________
13
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________________
13
PART
C:
TECHNICAL
VALIDATION
__________________________________________
14
13.
Reason
for
Alternatives
Not
Being
Feasible___________________________________
14
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
15
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives_______________________________________________________________
15
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
________________
16
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?________________________________________
18
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide
___________________________________________________________
18
Summary
of
Technical
Feasibility
_____________________________________________
18
PART
D:
EMISSION
CONTROL_______________________________________________
19
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
19
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
20
iv
PART
E:
ECONOMIC
ASSESSMENT
__________________________________________
21
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
21
22.
Gross
and
Net
Revenue___________________________________________________
21
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
22
Summary
of
Economic
Feasibility
_____________________________________________
22
PART
F.
FUTURE
PLANS____________________________________________________
24
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
24
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
24
25.
Additional
Comments
on
the
Nomination
____________________________________
24
26.
Citations
______________________________________________________________
25
Examples
of
Turfgrass
Sod
Certification
Requirements
in
the
U.
S.:
___________________
25
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
__________________________________
31
v
LIST
OF
TABLES
PART
A:
SUMMARY___________________________________________________________
6
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
6
Table
A.
1:
Executive
Summary__________________________________________________
8
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
__________________________
8
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
10
Table
A.
2:
2005
Sector
Nomination
_____________________________________________
11
TABLE
A.
2:
2005
AND
2006
SECTOR
NOMINATION
_________________________________
11
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE__________________
12
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
___________
12
Table
11.1:
Characteristics
of
Cropping
System
____________________________________
12
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_____________________________
13
Table
12.1:
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________________
13
PART
C:
TECHNICAL
VALIDATION
____________________________________________
14
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible______________________________
14
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________________
15
Table
15.1:
Present
Registration
Status
of
Alternatives
______________________________
15
Table
16.1:
Effectiveness
of
Alternatives
 
Nutsedge
(
Cyperus
spp.)
in
Florida1
__________
16
Table
16.2:
Effectiveness
of
Alternatives
 
Weedy
Grasses
in
Florida1__________________
17
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_________________________________
17
PART
D:
EMISSION
CONTROL
________________________________________________
19
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
19
PART
E:
ECONOMIC
ASSESSMENT
____________________________________________
21
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period_______
21
Table
22.1:
Year
1
Gross
and
Net
Revenue________________________________________
21
Table
22.2:
Year
2
Gross
and
Net
Revenue________________________________________
21
Table
22.3:
Year
3
Gross
and
Net
Revenue________________________________________
21
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
________________________
22
PART
F.
FUTURE
PLANS
_____________________________________________________
24
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
26
Page
6
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Turfgrass
Grown
in
Open
Fields
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
This
is
a
request
for
turfgrass
sod
grown
primarily
in
California,
Florida,
Georgia,
Alabama,
and
Texas.
There
are
at
least
1,143
turfgrass
sod
producers
across
the
U.
S.
who
farm
approximately
132,000
hectares,
with
a
wholesale
product
value
of
U.
S.
$
670
million.
Methyl
bromide
is
used
on
approximately
1
percent
of
the
total
certified
sod
area
in
a
single
year.
Methyl
bromide
fumigation
is
primarily
needed
for
areas
on
which
certified
turf
is
produced,
particularly
when
a
producer
is
shifting
the
species
or
variety
of
turf
to
response
to
market
conditions,
disease
or
pest
cycles,
or
other
reason.
In
such
cases,
the
ability
to
produce
certified
sod
depends
on
removing
all
remnants
of
off­
type
grasses.
On
average,
fumigation
of
the
affected
soil
occurs
once
every
three
years.
Sod
fields
are
flat
fumigated
with
methyl
bromide
when
first
establishing
a
new
sod
field;
as
a
pre­
plant
fumigation
when
pest
pressures
become
so
severe
that
sod
free
of
pests
and
off­
type
perennial
grasses
cannot
be
produced;
and
to
eliminate
pests
of
quarantine
importance
to
meet
the
official
requirement
of
the
destination
area.
Wholesale
buyers
for
most
certified
sod
producers
are
landscape
maintenance
contractors,
garden
centers,
building
contractors,
homeowners,
and
golf
course
and
athletic
field
superintendents.
Turfgrass
sod
yields
average
between
6,400
and
8,700
square
meters
per
hectare
per
cutting.
From
planting
to
harvest,
a
sod
crop
takes
between
9­
12
months
to
reach
maturity.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
129,672
432
Page
7
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
turf
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
The
efficacy
of
alternatives
is
not
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and
economically
infeasible
for
use
in
turfgrass
sod
production.

Methyl
bromide
(
MB)
is
the
only
treatment
that
consistently
provides
effective
control
of
offtype
perennial
grasses,
as
well
as
nutsedge
and
other
weeds,
nematodes,
and
insect
pests.
Preplant
fumigation
with
MB
is
often
required
when
sod
farms
are
first
established
on
land
previously
used
for
row
crop
farming
to
reduce
perennial
weeds
and
other
soil­
borne
pests.
It
is
used
when
sod
producers
shift
to
new
sod
varieties
or
species,
in
order
to
produce
a
uniform
turf
product.
MB
is
especially
useful
to
remove
off­
type
perennial
grass
varieties
that
are
phenotypically
indistinguishable
from
the
sod
crop,
but
possess
different
pest
resistance
traits,
rooting
characteristics,
leaf
textures,
or
different
temperature
and
humidity
requirements.
Offtype
perennial
grass
varieties
infesting
the
soil
from
the
previous
planting
cannot
be
targeted
for
spot
treatment
with
a
herbicides
by
visually
inspecting
the
crop.
Research
trials
have
shown
that
there
is
a
great
variability
in
efficacy
of
chemical
alternatives
(
Unruh
et
al.,
2002).

Most
"
warm
season"
certified
turfgrass
sod
production
utilizes
MB
when
a
new
sod
field
is
being
established
or
when
a
change
of
species
and
/
or
variety
is
desired
on
an
existing
sod
field.
Any
turfgrass,
particularly
"
warm­
season"
species,
may
become
an
"
off­
type"
grass
when
the
establishment
of
a
different
species
is
desirable.
With
some
aggressive
grasses,
a
single
off­
type
grass
plant
can
spread
rapidly
through
a
field,
resulting
in
a
revocation
of
certification
for
the
affected
field.
The
standards
for
purity
are
so
strict
that
even
a
very
small
proportion
of
"
offtype
blades
of
grass
will
lead
to
rejection
of
the
sod.
Thus,
industry
certification
programs
for
sod
guarantee
that
the
grasses
are
genetically
pure.
Uncertified
sod
can
only
be
sold
as
"
common"
or
"
field"
sod
used
for
soil
stabilization
at
25%
of
its
value
as
certified
sod
(
a
price
reduction
of
75%).
In
the
United
States,
sod
certification
programs
operate
on
a
state
or
regional
level,
some
of
which
specifically
require
methyl
bromide
fumigation
as
a
condition
for
certification.

Potential
alternatives,
such
as
dazomet
and
metam­
sodium,
are
unreliable
and
do
not
provide
the
degree
of
consistent
pest
control
needed
by
the
industry
to
meet
market
demands.
In
addition
to
providing
higher
rates
of
efficacy
and
more
consistent
results
than
the
other
alternatives
tested,
methyl
bromide
also
allows
for
quick
planting
after
treatment.
Page
8
TABLE
A.
1:
EXECUTIVE
SUMMARY
TURF
Turfgrass
Producers
International
AMOUNT
OF
NOMINATION*
2006
Kilograms
129,272
Application
Rate
(
kg/
ha)
300
Area
(
ha)
432
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
680,388
Application
Rate
(
kg/
ha)
480
Area
(
ha)
1,416
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Next
Best
Alternative
(
According
to
CUE
Application)
Dazomet
Yield/
Quality
Loss
(%)
25%

Loss
per
hectare
(
US$/
ha)
$
6,634
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
$
13.82
Loss
as
%
of
Gross
Revenue
(%)
33.81%

Loss
as
%
of
Net
Revenue
(%)
64.23%
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE
Registered
alternatives,
dazomet
and
metam
sodium,
are
unreliable
and
do
not
provide
the
degree
of
pest
control
efficacy
needed
by
the
industry.
The
U.
S.
consumer
market
generally
demands
turfgrass
consisting
of
pure
varieties
that
are
uniform,
vigorous,
densely
growing,
and
free
of
the
pests
and
pathogens
that
would
reduce
its
vigor,
impede
its
ability
to
control
erosion.
According
to
the
applicant,
Turfgrass
Producers
International,
the
standards
for
purity
are
so
strict
that
even
a
very
small
proportion
of
"
off­
type"
blades
of
grass
will
lead
to
rejection
of
the
sod.
Producers
of
certified
turfgrass
sod,
or
vegetative
propagules,
operate
under
zero­
tolerance
standards
for
pests
or
off­
type
perennial
grasses.
Certified
sod
produced
on
methyl
bromide
fumigated
plots
receives
a
higher
price
than
similarly
treated
sod.
The
loss
in
revenue
due
to
loss
of
certification,
yield
reduction,
and
unharvestable
fields
in
the
absence
of
MB
can
range
from
approximately
25%
to
75%
per
acre
per
year
(
TPI,
2003).
Because
of
the
differential
susceptibilities
of
turfgrass
varieties
to
drought,
temperature
extremes,
and
pathogens,
consumers
are
very
particular
about
the
turfgrass
variety
that
they
buy.
Off­
typing
is
of
particular
importance
in
growing
bermudagrass
sod
where
the
product
is
genetically
pure.
Contamination
with
off­
type
perennial
grasses
can
even
lead
to
legal
action
against
the
turfgrass
producer.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
­
2001­
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
Turfgrass
Producers
Not
Available
Not
Available
National
Total:
131,971
<
1
Page
9
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
Approximately
1.1%
of
turfgrass
sod
is
treated
with
MB
each
year,
the
affected
area
averaging
one
treatment
every
three
years.
MB
is
used
only
in
the
portion
of
the
turfgrass
sod
area
where
pest
problems
cannot
be
readily
controlled
using
conventional
pesticides.
For
instance,
some
broadleaf
weeds,
such
as
ragweed,
pigweed,
and
morningglory,
may
be
effectively
controlled
through
continuous
mowing
previous
to
seed
production
(
McCarty,
undated).
Spot
treatment
with
a
nonselective
herbicide,
such
as
glyphosate,
may
be
used
to
control
competitive
grasses
that
can
be
easily
distinguished
from
the
turfgrass
crop.
Relatively
low
pest
pressures
in
most
of
the
turfgrass
sod
production
area
make
it
possible
for
producers
to
use
alternative
pesticides
(
herbicides,
fungicides,
nematicides,
and
insecticides)
and
cultural
practices.

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?

Probably
not,
since
MB
is
already
being
used
only
in
crop
areas
that
require
MB
fumigation
to
achieve
certification,
either
because
the
certification
program
actually
requires
MB
use
or
because
alternatives
are
not
expected
to
provide
the
degree
of
pest
control
needed
by
growers
to
produce
high
quality,
certifiable
sod.
Page
10
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
U.
S.

YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
680,388
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Flat
Fumigation
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
Variable
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
1,416
ha
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
Not
Available
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
480
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
Not
Available
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
48
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:

 
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
applicant
included
growth
in
the
request
and
the
growth
amount
was
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
QPS
use
was
removed
in
this
sector.
 
Only
the
acreage
experiencing
moderate
to
heavy
key
pest
pressure
was
included
in
the
nominated.
Page
11
TABLE
A.
2:
2006
SECTOR
NOMINATION*

TURFGRASS
PRODUCERS
INTERNATIONAL
2006
Requested
Hectares
(
ha)
1,416
Requested
Application
Rate
(
kg/
ha)
480
Applicant
Request
Requested
Kilograms
(
kg)
680,388
Nominated
Hectares
(
ha)
432
Nominated
Application
Rate
(
kg/
ha)
300
CUE
Nominated
Nominated
Kilograms
(
kg)
129,672
Overall
Reduction
(%)
81%

2006
U.
S.
CUE
Nomination
(
kg)
129,672
Research
Amount
(
kg)
1928
2006
Sector
Nomination
Totals
Total
U.
S.
Sector
Nominated
Kilograms
(
kg)
131,600
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
12
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
TABLE
10.1:
KEY
PESTS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
AND
WEED
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Throughout
the
United
States
Weeds:
mainly
off­
type
perennial
grasses,
nutsedge
(
Cyperus
spp.
);
crabgrass
(
Digitaria
spp.);
goosegrass
(
Eleusine
indica);
common
bermudagrass
(
Cynodon
dactylon)
and
turfgrass
from
the
previous
crop
cycle.

Nematodes:
over
15
genera
of
parasitic
nematodes,
such
as
lance
nematodes
(
Hoplolaimus
spp.
)
and
sting
nematodes
(
Belonolaimus
longicaudatus)

Insects:
white
grubs
(
several
species
of
soilinhabiting
scarabaeid
beetle
larvae)
Producers
of
certified
turfgrass
sod
operate
under
zero­
tolerance
standards
for
contamination
with
off­
type
perennial
grasses,
other
weeds,
pests,
and
diseases.
For
approximately
1%
of
the
turfgrass
sod
growing
area,
this
degree
of
pest
control
can
only
be
achieved
through
MB
fumigation.
The
best
registered
alternatives,
dazomet
and
metam
sodium,
are
unreliable
and
do
not
provide
the
degree
of
consistent
pest
control
needed
by
the
industry.

11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
U.
S.

CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Turfgrass
sod
grown
from
seeds
or
rhizomes
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)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Varies
from
clayish­
loam
to
sandy­
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
The
affected
turfgrass
sod
area
is
treated
with
methyl
bromide
approximately
once
every
3
years.
On
average,
1.1%
of
the
total
turfgrass
sod
crop
production
area
in
the
U.
S.
is
fumigated
in
any
one
year.

OTHER
RELEVANT
FACTORS:
None
identified.
Page
13
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
Range
from
temperate
to
subtropical
(
USDA
Plant
Hardiness
Zones
5b
through
11)

SOIL
TEMP.
(
°
C)

RAINFALL
(
mm)

OUTSIDE
TEMP.
(
°
C)
Variable,
since
turfgrass
sod
is
grown
throughout
the
United
States.

FUMIGATION
SCHEDULE
1
x
x
PLANTING
SCHEDULE
x
x
KEY
MARKET
WINDOW
Variable
1
On
average,
1%
of
the
area
is
fumigated
once
every
three
years.

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

None
were
identified
as
being
relevant
factors.

12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
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)
1,221
1,232
1,874
1,563
1,029
612
AMOUNT
OF
MB
ACTIVE
INGREDIENT
USED
(
total
kilograms)
595,489
600,619
913,557
762,021
501,568
274,514
FORMULATIONS
OF
MB
(
MB
/
chloropicrin)
According
to
the
applicant,
the
typical
formulation
used
on
turfgrass
sod
is
98:
2.

METHOD
BY
WHICH
MB
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Liquid
MB
is
shank
injected
into
soil
at
a
depth
of
20­
80
cm
and
covered
with
polyethylene
tarpaulin.

APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
498
498
497
498
497
458
APPLICATION
RATE
FOR
THE
ACTIVE
INGREDIENT
IN
kg/
ha*
488
488
488
488
488
448
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
49.8
49.8
49.7
49.8
49.7
45.8
ACTUAL
DOSAGE
RATE
FOR
THE
ACTIVE
INGREDIENT
(
g/
m2)*
48.8
48.8
48.8
48.8
48.8
44.8
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
14
PART
C:
TECHNICAL
VALIDATION
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
CHEMICAL
ALTERNATIVES
Dazomet
Dazomet
is
not
a
technically
feasible
alternative
because
it
does
not
provide
consistent
control
of
the
target
pests
listed
in
Table
10.1.
While
dazomet
may
at
times
control
some
diseases
and
weeds,
research
data
suggest
that
the
effectiveness
of
this
chemical
is
inconsistent
(
Csinos
et
al.,
1997;
Unruh
and
Brecke,
2001;
Unruh
et
al.,
2002).
Specifically,
dazomet
does
not
consistently
provide
acceptable
control
of
off­
type
perennial
grasses;
other
weeds,
such
as
nutsedge;
or
nematodes.
Another
disadvantage
of
the
methyl­
isothiocyanate
generators,
such
as
dazomet,
is
that
they
have
long
residue
times
in
the
soil,
and
this
has
resulted
in
phytotoxicity
(
Banks,
2002).

In
addition
to
providing
higher
rates
of
efficacy
and
more
consistent
results
than
other
alternatives
tested,
methyl
bromide
also
allows
for
quick
planting
after
treatment.
A
methyl
bromide
treated
field
can
be
planted
within
48
hours
after
the
plastic
cover
is
removed,
while,
depending
on
soil
temperature,
a
minimum
period
of
14
to
21
days
is
required
for
effective
fumigation
when
dazomet
is
used
to
treat
the
soil.
No
1,3­
D
and
1,3­
D
+
Chloropicrin
1,3­
Dichloropropene
(
1,3­
D)
is
not
a
technically
feasible
alternative
because
although
it
has
good
activity
against
plant­
parasitic
nematodes,
it
does
not
control
target
weeds,
such
as
off­
type
perennial
grasses.

1,3­
D
+
chloropicrin
has
added
efficacy
against
many
soil­
borne
fungi
resulting
from
the
activity
of
chloropicrin,
but
this
combination
does
not
control
off­
type
perennial
grasses
and
other
key
weeds
affecting
turfgrass
production
in
the
limited
circumstances
where
MB
is
necessary
for
certification
(
approximately
1%
of
the
turfgrass
production
area
in
any
one
year).

In
research
conducted
with
tomatoes
comparing
methyl
bromide
with
1,3­
D
and
chloropicrin
there
was
a
3.7
fold
increase
in
nutsedge
plants
(
90
to
340
plants/
m2)
between
the
two
treatments
(
Johnson
and
Mullinix,
1999),
suggesting
that
similar
results
might
be
obtained
with
turf.
No
Page
15
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam­
Sodium
/
Chloropicrin
The
metam­
sodium
+
chloropicrin
combination
is
not
a
feasible
methyl
bromide
alternative
because
it
does
not
provide
consistent
control
of
target
weeds,
off­
type
perennial
grasses
or
nematodes
(
Csinos
et
al.,
1997,
Unruh
and
Brecke,
2001,
Unruh
et
al.,
2002).
Furthermore,
a
minimum
waiting
period
of
14
to
21
days
is
required
before
planting
when
metam­
sodium
is
used
to
treat
the
soil.
Chloropicrin
is
effective
against
soil
pathogens,
but
ineffective
against
most
weeds,
while
metam­
sodium
does
not
always
provide
acceptable
levels
of
nutsedge
control
(
Unruh,
et
al.,
2002).
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Selective
Pre­
or
Post­
Emergent
Herbicides
Please
refer
to
Item
13
above.

15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Iodomethane
(
Methyl
Iodide)
Iodomethane
is
undergoing
registration
reviews
in
the
U.
S.,
but
not
for
use
on
turfgrass.
Not
for
turfgrass
Unknown
Potassium
Azide
This
soil
fumigant
is
as
effective
as
MB
for
controlling
key
target
weeds.
However
the
manufacturer
has
not
requested
its
registration
in
the
U.
S.
No
Unknown
Page
16
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
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
NUTSEDGE
(
CYPERUS
SPP.)
IN
FLORIDA
1
%
NusedgeControl2
Site
1
Site
2
Treatment
Rates
Application
Methods
6
WAT3
44
WAT3
3
WAT3
15
WAT3
Methyl
Bromide
+
Chloropicrin
549
kg/
ha
+
11
kg/
ha
Shank
injected
100a
89a
100a
83a
1,3­
D
+
oxadiazon
140
L/
ha
+
168
kg/
ha
Shank
injected
+
surface
broadcast
0f
86ab
0c
74ab
Dazomet
392
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
80abc
57de
78b
58bcd
Dazomet
+
Chloropicrin
392
+
168
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
81ab
63bcd
81b
48cd
Dazomet
+
1,3­
D
392
kg/
ha
+
140
L/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
51de
31f
76b
41d
Metam­
sodium
748
L/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
43e
26f
71b
73ab
Metam­
sodium
+
Chloropicrin
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
+
shank
injected
55cde
38ef
72b
76ab
Metam­
sodium
+
Chloropicrin
tarped
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
+
shank
injected
64b­
e
56de
100a
79ab
Metam­
sodium
+
1,3­
D
748
+
140
L/
ha
Surface
spray
followed
by
rototill
+
shank
injected
69bcd
50def
87ab
70abc
Untreated
Control
0f
0g
0c
0e
LSD
(
0.05)
25
24
17
23
1
Modified
from
Unruh
and
Brecke
(
2001)
and
Unruh
et
al.
(
2002)
2
Numbers
followed
by
the
same
letter(
s)
are
not
significantly
different.
3
Number
of
weeks
after
treatment
Page
17
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDY
GRASSES
1
IN
FLORIDA
2
%
Weed
Control3
Site
1
Site
2
Treatment
Rates
Application
Methods
6
WAT3
44
WAT3
3
WAT3
15
WAT3
Methyl
Bromide
+
Chloropicrin
549
kg/
ha
+
11
kg/
ha
Shank
injected
100a
98a
100a
74ab
1,3­
D
+
oxadiazon
140
L/
ha
+
168
kg/
ha
Shank
injected
+
surface
broadcast
0b
53b
13c
71ab
Dazomet
392
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
98a
93a
83b
44cd
Dazomet
+
Chloropicrin
392
+
168
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
96a
93a
91ab
38d
Dazomet
+
1,3­
D
392
kg/
ha
+
140
L/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
100a
95a
90ab
54bcd
Metam­
sodium
748
L/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
98a
88a
87b
65abc
Metam­
sodium
+
Chloropicrin
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
+
shank
injected
100a
89a
92a
69abc
Metam­
sodium
+
Chloropicrin
tarped
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
+
shank
injected
100a
94a
100a
70abc
Metam­
sodium
+
1,3­
D
748
+
140
L/
ha
Surface
spray
followed
by
rototill
+
shank
injected
96a
94a
95ab
59a­
d
Untreated
Control
0b
0c
0c
0d
LSD
(
0.05)
35
13
13
27
1
Grass
species
include
coastal
bermudagrass
at
Site
1
and
alexandergrass,
broadleaf
signalgrass,
and
common
bermudagrass
at
Site
2.
2Modified
from
Unruh
and
Brecke
(
2001)
and
Unruh
et
al.
(
2002)
3
Numbers
followed
by
the
same
letter(
s)
are
not
significantly
different.
4
Number
of
weeks
after
treatment
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
QUALITY
LOSS
BEST
ESTIMATE
OF
QUALITY
LOSS
1
Dazomet,
alone
or
in
combination
with
chloropicrin
Metam
sodium,
alone
or
in
combination
with
chloropicrin
Weeds,
primarily
off­
type
perennial
grasses;
secondary
target
pests
include
nutsedge,
nematodes
and
insects
Turfgrass
sod
not
fumigated
with
MB
would
likely
not
be
certified.
The
market
value
of
uncertified
sod
is
approximately
25%
that
of
certified
sod.

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
25
%

1
Based
on
quality
and
yield
loss
estimates
provided
by
the
applicant.
Certified
sod
produced
on
methyl
bromide
fumigated
plots
receives
a
higher
price
than
similarly
treated
sod.
The
loss
in
revenue
due
to
loss
of
certification,
yield
reduction,
and
unharvestable
fields
in
the
absence
of
MB
is
approximately
25%
per
acre
per
year
(
TPI,
2003).
Page
18
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Covering
plots
treated
with
metam
sodium
+
chloropicrin
with
plastic
tarpaulin
increased
the
nutsedge
control
effectiveness
of
this
combination
in
southern
Florida,
but
not
in
a
western
Florida
site
(
Unruh
et
al.,
2002).

18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
No
such
technologies
are
available
at
present
for
turfgrass
sod.

SUMMARY
OF
TECHNICAL
FEASIBILITY
At
present,
none
of
the
registered
alternatives,
dazomet
and
metam
sodium,
is
as
effective
as
MB
as
pre­
plant
soil
fumigants
for
control
of
off­
type
perennial
grasses
and
other
target
weeds
on
certified
turfgrass
in
approximately
1%
of
the
turfgrass
sod
area
each
year.
Dazomet
and
metamsodium
applied
alone
or
in
combination
with
chloropicrin,
may
provide
fair
control
of
wild
and
off­
type
perennial
grasses
and
broad
leaf
weeds
and
fair
to
poor
control
of
nutsedge,
but
their
effectiveness
is
inconsistent,
and
sporadic
failures
have
been
observed
with
both
chemicals
(
Unruh
and
Brecke,
2001).
Hence,
the
turfgrass
sod
industry
cannot
rely
on
their
use
to
satisfy
certification
program
requirements
that
demand
zero
tolerance
for
weeds,
diseases,
and
pests.
A
recent
study
in
a
southern
Florida
site
has
shown
that
using
metam­
sodium
+
chloropicrin
under
polyvinyl
tarp
can
be
as
effective
as
MB
for
controlling
target
weeds.
However,
these
results
were
not
duplicated
in
a
northern
Florida
site,
where
this
combination
did
poorly
relative
to
MB
(
Unruh
et
al.,
2002).
Thus,
neither
chemical
is
a
suitable
MB
alternative
on
a
crop
that
must
be
declared
pest­
free
to
be
certified.
Page
19
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
MB
applied
under
polyethylene
film.
Unidentified
Unidentified
No
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
is
underway
to
develop
use
in
commercial
production
systems
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
lower
application
rates.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
increasing
the
percentage
of
chloropicrin.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
MB
applied
under
polyethylene
film.
Unidentified
Unidentified
Only
fumigated
once
every
three
years
Page
20
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
turfgrass
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
that
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
application
for
turfgrass
is
most
often
machine
injected
into
soil
to
specific
depths
under
tarps.

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%
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
turf
growers.

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.
Page
21
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD/
QUALITY*
COST
IN
YEAR
1
(
U.
S.$/
ha)
COST
IN
YEAR
2
(
U.
S.$/
ha)
COST
IN
YEAR
3
(
U.
S.$/
ha)
Methyl
Bromide
100%
$
1,235
$
1,235
$
1,235
Dazomet
75%
$
2,964
$
2,964
$
2,964
*
As
percentage
of
typical
or
3­
year
average
yield
and
quality,
compared
to
methyl
bromide.

22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
Page
22
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
METHYL
BROMIDE
DAZOMET
YIELD/
QUALITY
LOSS
(%)
0
25%

YIELD
PER
HECTARE
(
IN
HA/
HA)
1
Not
Available
*
PRICE
PER
UNIT
(
U.
S.$)
$
19,619
Not
Available
=
GROSS
REVENUE
PER
HECTARE
(
U.
S.$)
$
19,619
$
14,714
­
OPERATING
COSTS
PER
HECTARE
(
U.
S.$)
$
9,292
$
11,021
=
NET
REVENUE
PER
HECTARE
(
U.
S.$)
$
10,327
$
3,693
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
U.
S.$)
$
0
$
6,634
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
U.
S.$)
$
0
$
13.82
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
33.81%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
64.24%

SUMMARY
OF
ECONOMIC
FEASIBILITY
The
primary
economic
loss
that
would
be
expected
in
turfgrass
is
price
reduction
associated
with
the
inability
to
market
sod
as
certified,
which
results
in
up
to
a
75%
reduction
in
gross
revenue.
The
small
proportion
of
turf
production
represented
by
this
nomination
is
intended
for
sod
growers
producing
certified
sod.

In
addition
to
price
reductions
from
downgraded
quality,
there
are
also
expected
to
be
some
losses
from
off­
type
grasses
rendering
some
areas
simply
unharvestable,
either
from
the
presence
of
off­
type
grasses,
or
the
required
destruction
of
all
grass
in
a
particular
area
(
to
prevent
the
spreading
of
off­
types).
The
losses
are
much
smaller
than
the
impact
of
not
being
able
to
certify
the
sod.

The
CUE
reviewers
analyzed
crop
budgets
data
for
turfgrass
to
determine
the
likely
economic
impact
if
methyl
bromide
were
not
available.
The
four
economic
measures
in
Table
E.
1
were
used
to
quantify
the
economic
impacts
to
pre­
plant
uses
for
turfgrass.
The
four
economic
measures
are
not
independent
in
such
a
way
that
they
can
be
calculated
from
the
same
crop
budget
data.
The
measures
are,
however,
supplementary
to
each
other
in
evaluating
the
CUE
applicant's
economic
viability.
These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users.

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
Page
23
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.

As
stated
earlier
in
the
application,
the
price
of
non­
certified
sod
is
75%
lower
than
the
price
of
certified
sod.
For
production
areas
that
would
otherwise
fumigate
with
methyl
bromide,
it
is
possible
that
some
areas
will
be
able
to
continue
producing
certified
seed
for
a
limited
time,
as
long
as
they
do
not
attempt
to
change
variety
or
species.
But,
as
mentioned
earlier
in
the
application,
changing
variety
or
species
is
one
primary
reason
for
needed
to
control
off­
types
of
grass.

To
reflect
a
lower
bound
on
impacts,
under
the
assumption
that
some
areas
covered
by
the
nomination
would
delay
their
shift
in
grass
type,
or
delay
their
control
of
other
key
pests,
the
economic
analysis
used
25%
as
the
yield/
price
effect.
It
is
important
to
recognize
that
in
some
areas,
the
loss
could
be
as
high
as
75%.
Using
the
lower
bound,
we
estimate
that
a
representative
grower
would
suffer
$
6,634
loss
per
hectare
per
year
due
to
inferior
product
and
a
lower
proportion
of
harvestable
acreage,
and
an
increase
of
fumigation
costs
with
dazomet
(
TPI,
2003).
The
loss
as
a
percentage
of
gross
revenue
was
estimated
at
33.81%
and
the
loss
as
a
percentage
of
net
revenue
at
64.24%.
These
changes
are
estimated
to
have
a
significant
economic
impact
to
the
sod
industry.
The
results
suggest
that
dazomet
is
not
economically
viable
as
an
alternative
for
methyl
bromide.
Page
24
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Iodomethane,
a
soil
fumigant
not
registered
in
the
U.
S.,
has
shown
to
be
as
effective
as
MB
for
controlling
target
weeds
in
turfgrass
sod
and
is,
therefore,
a
promising
alternative.
Although
iodomethane
is
currently
undergoing
registration
reviews
in
the
U.
S.,
it
is
still
too
early
to
anticipate
the
outcome
of
this
process.

Research
into
MB
alternatives
began
in
1998.
Dr.
Bryan
Unruh,
Extension
Turfgrass
Specialist
at
the
University
of
Florida
has
conducted
several
field
trials
comparing
methyl
bromide
to
several
U.
S.
registered
and
non­
registered
fumigants,
alone
and
in
combination,
for
efficacy
against
target
weeds,
including
off­
type
perennial
grasses.
The
results
indicate
that
all
alternatives
tested
to
date
are
inferior
to
MB.
This
line
of
research
continues.

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
turf
research
will
require
1928
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
This
research
will
compare
the
comparative
performance
of
methyl
bromide
to
alternative
fumigants.

24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

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

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

MB
is
currently
used
by
the
turfgrass
sod
industry
in
approximately
1%
of
the
crop
area
each
year
for
preplant
control
of
off­
type
perennial
grasses
and
other
target
weeds
on
certified
turfgrass
sod.
Because
the
market
demands
high
quality
turfgrass
sod,
certification
programs
maintain
a
zero
tolerance
policy
for
these
contaminants,
and
producers
cannot
afford
to
rely
on
alternatives
that
provide
inconsistent
results.
Page
25
26.
CITATIONS
Banks,
H.
J.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.
Pg
46.

Csinos,
A.
S.,
W.
C.
Johnson,
A.
W.
Johnson,
D.
R.
Sumner,
R.
M.
McPherson,
and
R.
D.
Gitaitis.
1997.
Alternative
Fumigants
for
Methyl
Bromide
in
Tobacco
and
Pepper
Transplant
Production.
Crop
Prot.
16:
585­
594.

Johnson,
W.
C.,
III
and
B.
G.
Mullinix,
Jr.
1999.
Cyperus
esculentus
interference
in
Cucumis
sativus.
Weed
Sci.
47:
327­
331.

McCarty,
L.
B.
undated.
Sod
Production
in
Florida.
University
of
Florida
Cooperative
Extension
Service,
29
pp.
http://
edis.
ifas.
ufl.
edu/
LH066
Turfgrass
Producers
International
(
TPI).
2003.
Methyl
Bromide
Critical
Use
Exemption
application
for
Turfgrass
Sod,
August
5,
2003.

Unruh,
J.
B.
1998.
Methyl
bromide
is
coming
soon.
Golf
Course
Management.
http://
www.
gcsaa.
org/
gcm/
1998/
nov98/
11methylban.
html
Unruh,
J.
B.
and
B.
J.
Brecke.
2001.
Seeking
Alternatives
for
Methyl
Bromide.
Golf
Course
Management.
69(
3):
65_
72.

Unruh,
J.
B.,
B.
J.
Brecke,
J.
A.
Dusky
and
J.
S.
Godbehere.
2002.
Fumigant
Alternatives
for
Replacement
of
Methyl
Bromide
in
Turfgrass.
Weed
Technology,
16:
379­
387,
pp
379­
387.

EXAMPLES
OF
TURFGRASS
SOD
CERTIFICATION
REQUIREMENTS
IN
THE
U.
S.:

Turfgrass
sod
certification,
Georgia:
http://
www.
pikecreekturf.
com/
turfcert.
php
Turfgrass
sod
certification,
New
Jersey:
http://
www.
rce.
rutgers.
edu/
pubs/
pdfs/
fs738.
pdf
Turfgrass
sod
certification,
Tennessee:
http://
www.
state.
tn.
us/
sos/
rules/
0080/
0080_
06/
0080_
06_
04.
pdf
Turfgrass
sod
certification,
Virginia:
http://
www.
virginiacrop.
org/
vcia.
sodstd.
html
Page
26
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
131,971
1%

2001
&
2002
Average
%
of
2001
&

2002
Average
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
129,672
432
300
81%

129,672
432
300
81%

81%
69%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
480
300
0
0
0
0
100
100
0
0
0
0
0
0
Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
No
Yes
Yes
Tarp
Yes
0
No
1
/
3
years
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Quality/
Time/

Market
Window/

Yield
Loss
(%)

25%
Dazomet/
Dazomet+
Pic/
Metam­
Sodium/
Metam+
Pic
Marginal
Strategy
Date:
2/
26/
2004
Average
Hectares
in
the
US:

Methyl
Bromide
Critical
Use
Exemption
Process
Sector:
TURF
%
of
Average
Hectares
Requested:

2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)

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

REGION
680,388
1,416
480
388,041
821
473
50%

0.453592
1
Acre
=
0.404686
473
50%

TOTAL
OR
AVERAGE
680,388
1,416
480
2006
Request
(­)
Double
Counting
388,041
821
(­)
QPS
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

(­)
Use
Rate
Difference
137,949
137,949
LOW
HIGH
96,564
Turfgrass
Producers
International
680,388
­
286,249
118,242
137,949
137,949
96,564
Nomination
Amount
Adjustments
to
Requested
Amounts
59%

0%
0%
42%

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
Economic
Analysis
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)
86%

275,897
REGION
REGION
Turfgrass
Producers
International
%
Reduction
from
Initial
Request
Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
REGION
80%
80%

Turfgrass
Producers
International
Turfgrass
Producers
International
2006
Nomination
Options
680,388
680,388
394,139
(­)
Growth
or
2002
CUE
Comparison
Regional
Hectares**

%
of
Requested
Hectares
MOST
LIKELY
IMPACT
VALUE
not
available
not
available
Cold
Soil
Temp
(%)
Combined
Impacts
(%)

HIGH
100%
LOW
70%
Page
27
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
28
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
29
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
30
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

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

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

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

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

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

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
31
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
