Page
1
2003
Application
for
Methyl
Bromide
Critical
Use
Exemption
Florida
Tomatoes
(
CUE
02­
0046)
Florida
Strawberries
(
CUE
02­
0053)
Florida
Peppers/
Eggplants
(
CUE
02­
0054)

Submitted
to:

U.
S.
Environmental
Protection
Agency
Methyl
Bromide
Critical
Use
Exemption
Office
of
Pesticide
Programs
911
Bay,
BEAD
1921
Jefferson
Davis
Highway
Arlington,
VA
22202
Telephone:
(
703)
308­
8200
August
8,
2003
Florida
Fruit
and
Vegetable
Association
Page
2
2003
Application
for
Methyl
Bromide
Critical
Use
Exemption
Florida
Tomato,
Strawberry
and
Pepper/
Eggplant
1)
Introduction
Industry
Status
 
Tomato
 
Strawberry
 
Pepper/
Eggplant
2)
Crop
Production
Time
Lines
 
Tomato
 
Strawberry
 
Pepper
 
Eggplant
3)
Regulatory
Issues
 
Pebulate
 
Telone
 
Herbicide
Registration
Status
 
Emerging
Alternatives
4)
Pest
Complex
and
Economic
Thresholds
 
Tomato
 
Strawberry
 
Pepper
 
Eggplant
5)
Best
Available
Alternatives
 
Tomato
­
North
Florida,
Ruskin
Palmetto,
Southern
Florida
­
Dade
County
 
Strawberry
 
Pepper
 
Eggplant
Page
3
6)
Emission
Reduction
 
Virtually
Impermeable
Film
7)
Florida
Methyl
Bromide
Alternatives
Research
 
Historical
Perspective
 
Research
Priorities
 
Future
Research
Plans
8)
2003
Application
Forms
 
Tomato
­
North
Florida
­
Ruskin
Palmetto
­
Southern
Florida
 
Palm
Beach
­
Southern
Florida
­­
Southwest
­
Dade
County
 
Strawberry
 
Pepper
 
Eggplant
Page
4
Appendices
Appendix
I:
Methyl
Bromide
Alternatives
Research
A)
Funded
Research
2002/
2003
B)
Future
Research
Plans
C)
Bibliography
 
Methyl
Bromide
Alternatives
Research
D)
Methyl
Bromide
Alternatives
Research
Reports
Appendix
II:
Economic,
Crop
Production
and
Other
Supporting
Documentation
A)
Bibliography
of
Supporting
Documentation
B)
Supporting
Documents
1.
General
Information
2.
Economics/
Crop
Budgets/
Production
3.
Regulatory
Issues
Page
5
1)
Introduction
Florida
Fruit
and
Vegetable
Association
was
the
collection
point
and
submitter
for
petitions
pertaining
to
Critical
Use
Exemptions
for
Tomato
(
CUE
02­
0046),
Pepper
and
Eggplant
(
CUE
02­

0054),
and
Strawberry
(
CUE
02­
0053).
These
petitions
covered
preplant
soil
fumigation
use
of
methyl
bromide
as
currently
utilized
in
plastic
mulched
culture
of
vegetables
in
Florida
(
and
adjoining
counties
of
Georgia
for
tomatoes
packed
and
shipped
from
the
Quincy
area
in
north
Florida).
As
a
result
of
the
similarity
in
use
practice
and
common
issues
associated
with
the
introduction
of
alternatives,
the
Association
has
approached
the
updates
to
the
above
referred
petitions
for
quantities
requested
in
2005/
2006,
the
new
submission
to
cover
the
2006/
2007
request
period
as
outlined
in
the
FR
Notice,
and
Application
Forms,
as
a
single
package.
Each
industry
and
regional
subunits
will
be
handled
as
was
done
in
the
2002
petition.

Industry
Status
Tomato
No
major
status
number
changes
have
occurred
since
the
development
of
the
petition
in
2002.

The
general
acreage
relationships
have
not
changed
significantly
within
the
state
or
region
as
described
previously.
Table
1
provides
the
most
recent
acreage
available
for
tomato
production.

Table
1:
Florida
Tomato
Production
Acreage,
2002.
Farm
Gate
Values.

Region
2001/
2002
1
2000/
2001
2
2002
3
Including
Specialty
Tomatoes
Value
$
Millions
North
Florida
3,400
3,400
4,800
36
Ruskin
Palmetto
13,000
13,000
15,600
156
Southern
Florida
23,500
23,500
28,100
282
Dade
County
3,000
3,300
3,600
48
Total
42,900
43,200
52,100
522
1
Base
number
NASS
 
Regional
Numbers
 
FTGE
2
Base
number
NASS
 
Regional
Numbers
 
FTGE
3
Based
on
round
tomatoes,
and
cherry/
grapes
and
roma
 
Grower
and
Commodity
Group
Interviews
The
relative
stability
of
the
acreage
over
the
past
five
years
has
been
a
result
of
acreage
shifting
from
traditional
round
tomatoes
to
the
specialty
items,
i.
e.,
grapes,
romas
and
cherry
tomatoes.
Page
6
Table
2:
Florida
Statewide
Tomato
Production
and
Acreage,
2002*.
Farm
Gate
Values,
reflecting
values
for
round
tomatoes
ONLY.

Crop
Year
Total
Acres
Total
Cartons
Produced
(
x
1,000)
Yield
Per
Acre
(
25­
pound
cartons)
Value
Per
Carton
Value
Per
Harvested
Acre**
Total
Value
(
Millions)

2001­
02
43,500
58,750
1,351
$
8.07
$
10,903
$
474.3
2000­
01
43,800
60,152
1,373
$
9.26
$
12,714
$
557.0
1999­
00
43,200
62,185
1,439
$
6.67
$
9,598
$
414.8
1998­
99
43,400
61,922
1,427
$
7.50
$
10,702
$
464.2
1997­
98
39,300
56,091
1,427
$
9.05
$
12,914
$
507.5
1996­
97
37,300
54,750
1,468
$
8.08
$
11,861
$
442.4
1995­
96
45,500
56,866
1,250
$
7.82
$
9,775
$
444.5
1994­
95
49,000
65,183
1,330
$
7.25
$
9,642
$
472.8
*
Source:
Florida
Agricultural
Statistics
Service
Vegetable
Summary,
1994­
2003.

**
Value
Per
Acre
=
bushels
per
acre
X
value
per
bushel.

Strawberry
The
Florida
Strawberry
industry
is
concentrated
within
a
25­
mile
radius
around
Plant
City
in
Hillsborough
County.
The
acreage
planted
during
the
2002
production
season
increased
to
6,900
acres,
an
increase
of
6
percent
from
the
2001
production
season,
which
was
comprised
of
6,500
acres.

Table
3:
Florida
Strawberry
Production
and
Acreage,
2002*.
Farm
Gate
Values.

Crop
Year
Total
Acres
Total
Flats
Produced
(
x
1,000)
Yield
Per
Acre
(
12­
pound
flat)
Value
Per
Flat
Value
Per
Harvested
Acre**
Total
Value
(
Millions)

2001­
02
6,900
14,667
2,126
$
10.46
$
22,238
$
153.5
2000­
01
6,500
14,083
2,167
$
11.88
$
25,744
$
167.3
1999­
00
6,300
18,375
2,917
$
9.12
$
26,603
$
167.6
1998­
99
6,200
15,500
2,500
$
9.72
$
24,300
$
150.7
1997­
98
6,200
13,433
2,167
$
12.00
$
26,004
$
161.2
1996­
97
6,100
14,772
2,417
$
9.91
$
23,952
$
146.1
1995­
96
6,000
13,000
2,167
$
8.66
$
18,766
$
112.6
1994­
95
6,000
14,000
2,333
$
8.47
$
19,007
$
118.6
*
Source:
Florida
Agricultural
Statistics
Service
Vegetable
Summary,
1994­
2003.
**
Value
Per
Acre
=
flats
per
acre
X
value
per
flat.

Pepper
While
acreage
of
vegetable
crops
statewide
in
Florida
increased
overall,
acreage
producing
pepper
crops
(
bell
peppers,
jalapeno
peppers
and
other
miscellaneous
specialty
pepper
varieties)
Page
7
actually
declined
somewhat
during
2001­
02.
Similarly,
for
a
variety
of
reasons,
the
2001­
02
yield
per
acre
estimates
for
Florida
peppers
dropped
as
well.

Over
the
last
decade,
acres
planted
to
pepper
have
varied
from
a
high
of
25,200
acres
planted
in
1993­
94
to
a
low
of
20,250
planted
in
2001­
02.
Since
2000,
pepper
acreage
has
declined
approximately
11
percent,
primarily
because
of
issues
such
as
production
challenges
and
unfavorable
market/
pricing
values.
The
value
of
a
28­
pound
bushel
of
peppers
dropped
nearly
20
percent
between
2000
and
2002.
The
reduction
in
acreage
factor,
combined
with
the
lower
value
per
bushel
pricing
issue,
resulted
in
the
fact
that
the
overall
total
value
of
Florida
peppers
dropped
more
than
28
percent
over
the
last
two
production
seasons.
In
fact,
the
value
of
the
2002
crop
statewide
was
actually
worth
less
(
both
in
terms
of
value
per
bushel
and
total
value
of
the
state s
crop)
than
peppers
were
worth
predating
the
1993
values,
because
of
the
acreage
reduction
and
lower
value
paid
per
bushel.
Production
and
marketing
competition
issues
continue
to
plague
Florida s
pepper
production
industry,
and
could
threaten
the
state s
status
as
the
nation s
#
1
producer
of
peppers
if
the
trend
continues.

Table
4:
Florida
Pepper
Production
and
Acreage,
2002*.
Farm
Gate
Values.

Crop
Year
Total
Acres
Total
Bushels
Produced
(
x
1,000)
Yield
Per
Acre
(
28­
pound
bushel)
Value
Per
Bushel
Value
Per
Harvested
Acre**
Total
Value
(
Millions)

2001­
02
20,250
19,532
1,142
$
8.72
$
9,958
$
170.3
2000­
01
21,600
21,742
1,195
$
10.75
$
12,846
$
233.7
1999­
00
22,300
21,901
1,190
$
10.68
$
12,709
$
233.9
1998­
99
22,200
21,620
1,138
$
11.21
$
12,757
$
242.4
1997­
98
22,000
20,165
1,073
$
13.70
$
14,700
$
276.2
1996­
97
22,300
22,148
1,119
$
9.91
$
11,089
$
219.5
1995­
96
24,000
19,021
937
$
9.76
$
9,145
$
185.7
1994­
95
24,700
16,018
789
$
12.03
$
9,492
$
192.7
*
Source:
Florida
Agricultural
Statistics
Service
Vegetable
Summary,
1994­
2003.

**
Value
Per
Acre
=
bushels
per
acre
X
value
per
bushel.

Eggplant
The
crop
of
eggplants
harvested
off
of
producing
acreage
in
the
state
of
Florida
during
2001­
02
was
valued
at
more
than
$
14
million.
While
the
value
of
the
eggplant
crop
is
significant,
overall,
the
eggplant
acreage
and
value
may
be
considered
minor
in
comparison
to
certain
other
Florida
vegetable
crops.
Even
with
decreases
in
acreage
experienced
since
the
mid­
1990s,
Florida
still
ranks
first
in
all
states
with
respect
to
eggplant
production,
with
more
than
twice
the
acreage
of
the
next
largest
eggplant­
growing
state.
Production
confrontations
have
resulted
in
net
yields
dropping
at
a
fairly
consistent
rate
in
recent
years,
with
produced
bushels
per
acre
dropping
from
842
in
1999
down
to
766
in
2001­
02.
This
reduction
equates
to
nearly
a
10
percent
decline
in
attainable
yields
per
acre
for
eggplant
fruits.
Page
8
Table
5:
Florida
Eggplant
Production
and
Acreage,
2002*.
Farm
Gate
Values.

Crop
Year**
Total
Acres
Total
Production
(
x
1,000)
Yield
Per
Acre
(
33­
pound
bushel)
Value
Per
Bushel
Value
Per
Harvested
Acre***
Total
Value
(
millions)

2001­
02
1,600
1,242
766
$
11.33
$
8,679
$
14.1
2000­
01
1,600
1,242
766
$
11.33
$
8,679
$
14.1
1999­
00
1,800
1,515
842
$
10.02
$
8,437
$
15.2
1998­
99
2,000
1,622
811
$
10.35
$
8,394
$
16.8
1997­
98
2,200
1,700
773
$
9.32
$
7,204
$
15.8
1996­
97
2,400
1,696
707
$
8.63
$
6,101
$
14.6
1995­
96
2,400
1,533
639
$
9.02
$
5,564
$
13.8
1994­
95
2,300
1,500
652
$
9.00
$
5,868
$
13.5
*
Source:
Florida
Agricultural
Statistics
Service
Vegetable
Summaries,
1994­
2001.
**
Updated
production/
value
information
not
available
yet
for
2001­
02
cycle.
***
Value
Per
Acre
=
bushels
per
acre
X
value
per
bushel.
Page
9
2)
Crop
Production
Time
Lines
During
the
review
of
the
analysis
performed
under
the
2002
application,
it
became
apparent
to
those
versed
in
crop
production
that
there
had
been
a
misunderstanding
relative
to
the
 
double
cropped 
scenario
as
described
in
the
application.
This
section
is
being
provided
in
order
to
clarify
the
crop
production
scenario
and
to
provide
a
more
accurate
description
template
of
the
crop
production
sequences.

Tomato
Production
Timeline
This
description
of
the
production
timeline
for
Florida
tomatoes
is
presented
from
a
perspective
that
should
be
considered
 
typical .
Variations
to
suggested
intervals
do
and
will
occur
on
either
side
of
proposed
timeline
boundaries,
which
is
distinctive
of
an
activity
that
is
highly
dependent
upon
uncontrollable
characteristics
such
as
weather
and
marketing
opportunities.
These
timelines
are
designed
to
provide
specific
information
on
normally
expected
crop
production
activities
associated
with
Florida s
fresh
market
tomato
crop.

It
needs
to
be
made
clear
that
the
vast,
inclusive
fresh
market
tomato
industry
is
extremely
competitive
towards
Florida
from
both
the
domestic
and
worldwide
standpoints.
Production
and
marketing
of
Florida
tomatoes
is
highly
dependent
upon
influences
from
production
and
marketing
of
tomatoes
grown
in
other
regions
of
the
global
market,
Mexico
in
particular.

Tomato
 
North
Florida
Production
Timeline
The
typical
grower
of
fresh
market
tomatoes
in
north
Florida
produces
about
380
acres
of
field
grown
fresh
market
tomatoes.
Half
of
those
tomatoes
are
produced
in
the
fall
and
the
other
half
are
produced
in
the
spring.
Double
cropping
is
not
a
prevalent
production
practice
in
north
Florida
(
less
than
10
percent
of
the
acres).

Table
6:
Tomato
 
North
Florida
Production
Timeline
Overview
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
Feb.
15
July
1
Feb.
15
 
April
1
July
1
 
Sept.
1
Fumigation/
Bedding
March
1
July
15
March
1
 
April
15
July
15
 
Sept.
15
Transplanting
March
15
Aug.
1
March
15
 
May
1
Aug.
1
 
Sept.
15
Harvesting
June
15
Nov.
1
June
15
 
July
15
Nov.
1
 
Dec.
31
Mulch
Removal/
Post­
Crop
Land
Maintenance
July
1
Dec.
1
July
1
 
Aug.
15
Dec.
1
 
Jan.
31
Cover
Crop
Establishment
July
15
Dec.
15
July
15
 
Sept
1
Dec.
1
 
Jan.
15
Page
10
Tomato
 
Palmetto­
Ruskin
Production
Timeline
The
Ruskin
 
Palmetto
production
region
is
located
in
west
central
Florida
and
is
concentrated
in
Manatee
and
Hillsborough
Counties.
The
15,600
acres
of
production
are
split
into
fall
and
spring
seasons,
with
6,240
acres
in
the
fall
and
9,360
acres
in
the
spring.
The
fall
crop
is
transplanted
in
early
August
with
harvest
beginning
in
late
October
and
continuing
through
late
December.
The
spring
crop
is
transplanted
from
mid­
January
until
early
March
with
harvest
beginning
in
mid­
April
and
continuing
through
late
May.
A
small
portion
of
the
plastic
laid
for
the
fall
tomato
crop
is
double
cropped
with
spring
plantings
of
cucurbits.

The
 
typical 
farm
in
the
Ruskin­
Palmetto
area
produces
about
400
acres
of
field
grown
fresh
market
tomatoes.
A
total
of
240
acres
are
produced
in
the
spring
market
as
a
single
crop
and
144
acres
are
grown
in
the
fall
as
a
single
crop.
Of
the
160
acres
typically
planted
in
the
fall,
16
acres
or
10
percent
of
the
plastic
would
be
double
cropped.

Table
7:
Palmetto­
Ruskin
Production
Timeline
Overview;
Non­
Double
Cropped
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Jan.
15
Fumigation/
Bedding
Aug.
1
Aug.
1
 
Feb.
1
Transplanting
Aug.
15
Aug.
15
 
Sept.
15
Jan.
15
 
Feb.
15
Harvesting
Oct.
15
Oct.
15
 
Dec.
31
May
1
 
June
1
Mulch
Removal/
Post­
Crop
Land
Maintenance
Dec.
15
Dec.
15
 
Dec.
31
May
1
 
July
1
Cover
Crop
Establishment
Jan.
1
Jan.
1
 
July
1
Table
8:
Palmetto­
Ruskin
Production
Timeline
Overview;
Double
Cropped*

Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Jan.
15
Fumigation/
Bedding
Aug.
1
Aug.
1
 
Feb.
1
Transplanting
Aug.
15
Aug.
15
 
Sept.
15
Jan.
15
 
Feb.
15
Harvesting
Oct.
15
Oct.
15
 
Dec.
31
May
1
 
July
1
Tomato
Crop
Destruction
Dec.
1
Dec.
1
 
Feb.
15
Plant
Second
Crop
Dec.
15
Dec.
15
 
March
1
Harvest
Second
Crop
Feb.
15
Feb
15
 
May
1
Mulch
Removal/
Post­
Crop
Land
Maintenance
June
1
June
1
 
July
1
*
For
purposes
of
timeline
and
economic
considerations,
the
second
crop
is
assumed
to
be
a
cucurbit
crop.
Page
11
Tomato
 
South
Florida
Production
Timeline
This
production
region
includes
the
flatwoods
soils
of
the
east
coast
of
Florida
from
St.
Lucie,
Palm
Beach
and
Broward
Counties,
through
central
Florida
south
of
Lake
Okeechobee,
and
over
to
the
lower
west
coast
of
Florida
in
Lee
and
Collier
Counties.
This
large
production
area
overlaps
with
the
fall
production
and
early
spring
production
in
Ruskin
 
Palmetto
but
is
concentrated
in
the
winter
months
of
December
through
late
March.
Limited
production
occurs
through
the
end
of
April.
Production
is
spread
across
the
three
production
periods
with
40
percent
occurring
in
the
fall,
25
percent
in
the
winter,
and
35
percent
occurring
in
the
spring.
The
length
of
the
growing
season
allows
for
a
portion
of
the
acreage,
primarily
the
fall
production
period,
to
be
double
cropped
usually
with
cucurbits
(
squash,
cucumber,
or
melons).
Double
cropping
is
practiced
on
approximately
60
percent
of
the
fall
and
winter
acreage,
with
cucumbers
being
the
typical
second
crop.
The
soils
in
this
production
area
are
the
classic
flatwoods
soils
that
have
a
spodic
layer
of
impermeable
material,
18
to
36
inches
below
the
bed
surface,
that
allows
efficient
seepage
irrigation
of
the
plastic
mulched
bed.

The
typical
grower
of
fresh
market
tomatoes
in
the
east
coast,
Palm
Beach
County
area
produces
about
400
acres
of
field
grown
fresh
market
tomatoes.
In
the
east
coast
production
region,
a
total
of
60
acres
are
produced
as
a
single
crop
and
240
acres
are
grown
as
a
double
crop.
For
the
southwest
production
area,
the
typical
grower
of
fresh
market
tomatoes
likewise
produces
about
400
acres
of
field
grown
fresh
market
tomatoes.
However,
a
total
of
272
acres
are
produced
as
a
single
crop
and
only
128
acres
are
grown
in
the
fall
as
a
double
crop.

Table
9:
South
Florida
Production
Timeline
Overview;
Non­
Double
Cropped
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Jan.
15
Fumigation/
Bedding
Aug.
1
Aug.
1
 
Feb.
1
Transplanting
Aug.
15
Aug.
15
 
Feb.
15
Harvesting
Nov.
15
Nov.
15
 
May
31
Mulch
Removal/
Post­
Crop
Land
Maintenance
Jan.
1
Jan.
1
 
June
15
Cover
Crop
Establishment
Jan.
15
Jan.
15
 
July
1
Table
10:
South
Florida
Production
Timeline
Overview;
Double
Cropped*

Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Jan.
15
Fumigation/
Bedding
Aug.
1
Aug.
1
 
Feb.
1
Transplanting
Aug.
15
Aug.
15
 
Feb.
15
Harvesting
Nov.
15
Nov.
15
 
May
31
Tomato
Crop
Destruction
Jan.
1
Jan.
1
 
Feb.
15
Plant
Second
Crop
Jan.
15
Jan.
15
 
March
1
Harvest
Second
Crop
April
1
April
1
 
July
1
Mulch
Removal/
Post­
Crop
Land
Maintenance
July
1
July
1
 
July
15
*
For
purposes
of
timeline
and
economic
considerations,
the
second
crop
is
assumed
to
be
a
cucurbit
crop.
Page
12
Tomato
 
Dade
County
Production
Timeline
The
Dade
County
production
area
is
unique
due
to
the
soils
and
the
tropical
climate.
The
krome
gravely
loam
soil
(
Rockdale)
is
only
present
in
this
production
area
in
the
continental
United
States.
This
highly
porous
soil
lies
upon
a
surficial
aquifer,
and
care
must
be
exercised
to
prevent
leaching
of
fertilizer
and
pesticides
into
this
source
of
drinking
water.
Therefore,
this
soil,
due
to
its
unique
characteristics,
requires
a
totally
different
set
of
pest
management
options.
The
climatic
conditions
create
a
situation
where
the
only
guaranteed
supply
of
winter
vegetables
is
produced
in
this
area.
Production
of
tomatoes
is
concentrated
in
the
winter
months
with
harvest
typically
occurring
from
December
through
mid­
April.
Limited
production
occurs
in
the
late
fall.
Approximately
10
percent
is
double
cropped.

The
typical
grower
of
fresh
market
tomatoes
in
Dade
County,
Florida
produces
about
350
acres
of
field
grown
fresh
market
tomatoes
during
the
winter
period.
Double
cropping
is
not
a
prevalent
production
practice
in
Dade
County
(
less
than
10
percent
of
the
acres).

Table
11:
Dade
County
Production
Timeline
Overview
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
Aug.
15
Aug.
15
 
Dec.
15
Fumigation/
Bedding
Sept.
1
Sept.
1
 
Dec.
15
Transplanting
Sept.
15
Sept.
15
 
Dec.
31
Harvesting
Dec.
15
Dec.
15
 
April
15
Mulch
Removal/
Post­
Crop
Land
Maintenance
Feb.
1
Feb.
1
 
April
30
Cover
Crop
Establishment
May
15
May
15
 
July
1
Strawberry
Production
Timeline
This
description
of
the
production
timeline
for
Florida
strawberries
is
presented
from
a
perspective
that
should
be
considered
 
typical .
Variations
to
suggested
intervals
do
and
will
occur
on
either
side
of
proposed
timeline
boundaries,
which
is
distinctive
of
an
activity
that
is
highly
dependent
upon
uncontrollable
characteristics
such
as
weather
and
marketing
opportunities.
These
timelines
are
designed
to
provide
specific
information
on
normally
expected
crop
production
activities
associated
with
Florida s
fresh
market
strawberry
crop.

It
needs
to
be
made
clear
that
the
vast,
inclusive
fresh
market
strawberry
industry
is
extremely
competitive
towards
Florida
from
both
the
domestic
and
worldwide
standpoints.
Production
and
marketing
of
Florida
strawberries
is
highly
dependent
upon
influences
from
production
and
marketing
of
strawberries
grown
in
other
regions
of
the
country
in
particular.
Page
13
Table
12:
Strawberry
Production
Timeline
Overview;
Non­
Double
Cropped
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Aug.
15
Fumigation/
Bedding
Aug.
15
Aug.
15
 
Sept.
15
Transplanting
Sept.
25
Sept.
25
 
Oct.
31
Harvesting
Dec.
1
Dec.
1
 
April
15
Mulch
Removal/
Post­
Crop
Land
Maintenance
May
1
May
1
 
May
15
Cover
Crop
Establishment
May
15
May
15
 
May
30
Table
13:
Strawberry
Production
Timeline
Overview;
Double
Cropped*

Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Aug.
15
Fumigation/
Bedding
Aug.
15
Aug.
15
 
Sept.
15
Transplanting
Sept.
25
Sept.
25
 
Oct.
31
Harvesting
Dec.
1
Dec.
1
 
April
15
Strawberry
Crop
Removal
March
21
March
21
 
April
15
Plant
Second
Crop
March
25
March
25
 
April
30
Harvest
Second
Crop
June
1
June
1
 
July
7
Mulch
Removal/
Post­
Crop
Land
Maintenance
July
7
July
7
 
July
15
*
For
purposes
of
timeline
and
economic
considerations,
the
second
crop
is
assumed
to
be
a
cucurbit
crop.

Pepper
Production
Timeline
This
description
of
the
production
timeline
for
Florida
peppers
is
presented
from
a
perspective
that
should
be
considered
 
typical .
Variations
to
suggested
intervals
do
and
will
occur
on
either
side
of
proposed
timeline
boundaries,
which
is
distinctive
of
an
activity
that
is
highly
dependent
upon
uncontrollable
characteristics
such
as
weather
and
marketing
opportunities.
These
timelines
are
designed
to
provide
specific
information
on
normally
expected
crop
production
activities
associated
with
Florida s
fresh
market
pepper
crop.

Table
14:
Pepper
Production
Timeline
Overview;
Non­
Double
Cropped
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Jan.
15
Fumigation/
Bedding
Aug.
15
Aug.
15
 
Jan.
31
Transplanting
Sept.
1
Sept.
1
 
March
15
Harvesting
Nov.
15
Nov.
15
 
June
1
Mulch
Removal/
Post­
Crop
Land
Maintenance
May
1
May
1
 
June
15
Cover
Crop
Establishment
May
15
May
15
 
July
1
Page
14
Table
15:
Pepper
Production
Timeline
Overview;
Double
Cropped*

Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
July
15
July
15
 
Aug.
15
Fumigation/
Bedding
Aug.
15
Aug.
15
 
Sept.
15
Transplanting
Sept.
1
Sept.
1
 
Oct.
31
Harvesting
Nov.
15
Nov.
15
 
April
15
Pepper
Crop
Destruction
Feb.
1
Feb.
1
 
March
15
Plant
Second
Crop
Feb.
15
Feb.
15
 
April
30
Harvest
Second
Crop
May
1
May
1
 
July
1
Mulch
Removal/
Post­
Crop
Land
Maintenance
July
1
July
1
 
July
15
*
For
purposes
of
timeline
and
economic
considerations,
the
second
crop
is
assumed
to
be
a
cucurbit
crop.

Eggplant
Production
Timeline
This
description
of
the
production
timeline
for
Florida
eggplants
is
presented
from
a
perspective
that
should
be
considered
 
typical .
Variations
to
suggested
intervals
do
and
will
occur
on
either
side
of
proposed
timeline
boundaries,
which
is
distinctive
of
an
activity
that
is
highly
dependent
upon
uncontrollable
characteristics
such
as
weather
and
marketing
opportunities.
These
timelines
are
designed
to
provide
specific
information
on
normally
expected
crop
production
activities
associated
with
Florida s
fresh
market
eggplant
crop.

Table
16:
Eggplant
Production
Timeline
Overview;
Non­
Double
Cropped
Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
June
1
June
1
 
Jan.
15
Fumigation/
Bedding
June
15
June
15
 
Feb.
1
Transplanting
July
1
July
1
 
Feb.
15
Harvesting
Nov.
1
Nov.
1
 
July
31
Mulch
Removal/
Post­
Crop
Land
Maintenance
April
15
April
15
 
June
15
Cover
Crop
Establishment
May
1
May
1
 
July
1
Table
17:
Eggplant
Production
Timeline
Overview;
Double
Cropped*

Operation
Earliest
Start
Date
Activity
Variance
Land
Preparation
June
1
June
1
 
Jan.
15
Fumigation/
Bedding
June
15
June
15
 
Sept.
15
Transplanting
July
1
July
1
 
Oct.
1
Harvesting
Nov.
1
Nov.
1
 
Jan.
15
Eggplant
Crop
Destruction
Jan.
15
Jan.
15
 
Feb.
1
Plant
Second
Crop
Feb.
1
Feb.
1
 
Feb.
30
Harvest
Second
Crop
April
15
April
15
 
May
15
Mulch
Removal/
Post­
Crop
Land
Maintenance
May
15
May
15
 
June
1
*
For
purposes
of
timeline
and
economic
considerations,
the
second
crop
is
assumed
to
be
a
cucurbit
crop.
Page
15
3)
Regulatory
Issues
Several
critical
actions
have
taken
place
since
the
submission
of
the
initial
CUE
petitions
that
have
influenced
the
potential
choices
among
alternative
strategies.
The
unsettled
regulatory
status
creates
difficulty
in
the
decision
matrix
for
both
research
planning
purposes,
as
well
as
budgetary
comparisons
with
methyl
bromide
based
production
practices.

Some
of
the
major
regulatory
decisions
that
have
influenced
the
alternative
strategies
for
methyl
bromide
include:

 
The
loss
of
pebulate
 
Changes
to
PPE
and
buffer
requirements
on
1,3­
dichloropropene
 
Changes
to
registration
status
for
herbicides
Also
of
significant
influence
over
the
process
of
determining
the
best
available
alternative
strategies
is
the
moving
time
frame
associated
with
potential
registration
status
of
new
crop
protection
tools
such
as
iodomethane
and
fosthiozate.

While
each
of
these
have
been
considered
in
the
development
of
the
strategies
discussed
below,

the
long­
term
impacts
on
the
technical
and
economic
viability
of
the
proposed
strategies
have
not
been
determined.

Pebulate
The
loss
of
pebulate
(
Tillam
6E
®
)
resulting
from
bankruptcy
of
the
technical
registrant,
Cedar
Chemical,
and
the
subsequent
nonpayment
of
the
annual
registration
maintenance
fee,
has
created
tremendous
uncertainty
with
the
alternative
strategies
for
methyl
bromide.
Pebulate,
where
registered,
provided
efficacy
against
the
primary
weed
species
that
impact
plastic
mulched
vegetable
production
system
(
yellow
and
purple
nutsedge).
This
weed,
while
providing
direct
competition
for
the
crop,
also
increases
potential
losses
by
growing
through
the
plastic
mulch,
disrupting
the
fertilization
margin
program
and
creating
potential
physical
damage
to
the
crops
because
of
abrasion
caused
as
the
mulch
is
lifted
by
the
wind.

Beginning
with
initial
small­
scale
research
plots
to
determine
the
best
alternatives
for
methyl
bromide,
the
need
to
establish
nutgrass
control
was
clearly
established.
Pebulate
was
identified
as
the
material
of
choice,
especially
for
tomatoes,
as
it
could
be
applied
prior
to
laying
the
plastic
to
control
the
nutgrass
before
it
emerged
through
the
mulch.

Telone
In
June
2003,
EPA
OPP/
Registration
Division
approved
label
changes
for
products
containing
1,3­

dichloropropene.
These
label
changes
reduced
the
buffer
restrictions
from
300
to
100
feet
from
occupied
structures
and
reduced
the
Personal
Protective
Equipment
for
some
field
workers,
applicators
and
handlers.
The
impacts
of
these
changes,
while
anticipated
to
be
favorable,

cannot
be
determined
at
this
time.
Page
16
Much
of
the
research
effort
involving
1,3­
dichloropropene
in
Florida
has
focused
on
broadcast
applications
in
advance
of
bed
formation
as
a
result
of
the
restrictive
PPE
requirements
imposed
upon
early
reentry
field
workers
involved
in
the
plastic
laying
operation.
There
is
a
strong
possibility
that
the
preferred
application
process
for
this
alternative
may
shift
back
to
the
in­
bed
fumigation
process.
Existing
research
projects
have
been
modified
to
begin
to
test
this
alternative.

An
important
issue
not
resolved
in
this
action
by
the
Office
of
Pesticide
Programs
is
the
label
language
regarding
Karst
geology.
Current
label
language
states,
 
Do
not
apply
in
areas
overlying
Karst
geology .
This
language
taken
literally
would
appear
to
prohibit
the
use
of
Telone
products
in
Florida.
The
historical
approach
has
been
to
restrict
uses
where
surficial
topography
exhibits
Karst
features,
i.
e.,
sink
holes,
and
there
is
a
proposed
label
change
that
would
formalize
this
approach.
The
Florida
Department
of
Agriculture
and
Consumer
Services
has
reviewed
the
proposed
language
 
Do
not
make
application
within
25
feet
of
Karst
topogeographical
features .
We
remain
concerned
that
with
current
language
many
of
the
areas
where
Telone
is
considered
an
alternative
may
not
actually
be
able
to
use
this
product.

Several
publications
from
the
USGS
are
provided
in
Appendix
II,
B,
3,
which
detail
the
ubiquitous
nature
of
limestone
solution
channels
as
a
subsurface
feature
of
Florida s
geology.
Until
this
issue
is
resolved,
Telone
products
should
not
be
considered
as
available
alternatives
from
a
regulatory
perspective.
The
Florida
industry
in
cooperation
and
full
knowledge
of
the
Florida
Department
of
Agriculture
and
Consumer
Services
is
looking
to
this
product
as
a
primary
component
of
methyl
bromide
alternatives
strategies.

Herbicide
Registration
Status
In
addition
to
the
above­
referred
loss
of
pebulate,
other
herbicidal
active
ingredients
have
received
changes
in
their
regulatory
status
associated
with
the
crops
addressed
in
this
petition.
Prominently
among
these
are
halosulfuron
(
Sandea
®
)
,
rimsulfulron
(
Matrix
®
)
,
and
S­
metolachlor
(
Dual
Magnum
®
)
.
Also
included
with
the
discussion
of
these
newly
available
alternative
products,
it
is
important
to
note
the
issues
surrounding
use
of
other
labeled
herbicides
and
their
role
in
the
replacement
strategies
for
methyl
bromide.

Halosulfuron
Halosulfuron,
a
sulfonylurea
herbicide,
received
labeling
during
2003
allowing
use
on
crops
such
as
tomatoes,
cucumber,
winter
squash,
pumpkins,
cantaloupe
and
snap
beans.
In
addition,
row
middle
applications
are
labeled
for
the
fruiting
vegetables
and
cucurbit
crop
groupings.
Halosulfuron
is
a
selective
herbicide
that
is
intended
to
provide
both
pre­
and
post­
emergence
control
of
purple
and
yellow
nutsedge.
Halosulfuron
inhibits
an
essential
plant
enzyme,
acetolactate
synthase,
thus
blocking
the
production
of
the
three
amino
acids:
isoleucine,
leucine
and
valine.
In
tomatoes,
this
product
may
be
used
as
a
pre­
transplant
spray
applied
directly
to
the
bed
immediately
before
the
plastic
laying
operation,
or
as
a
post­
emergent
spray
targeting
nutsedge
weeds
that
have
emerged
through
the
plastic
within
the
bed.
The
level
of
weed
control
is
dependent
upon
application
rates
and
methods
of
application,
specific
weed
species,

size
and
infestation
intensity
at
the
time
of
application,
and
growing
conditions.
While
this
product
appears
to
have
favorable
activity
when
applied
in
a
post­
emergent
fashion,
its
level
of
activity
when
applied
pre­
emergent
is
not
of
an
acceptable
level
for
commercial
tomato
Page
17
production.
Post­
emergent
applications
to
pepper
and
eggplant
crops
are
not
recommended,
as
foliage/
plants
of
these
crops
are
very
sensitive
to
halosulfuron.
In
addition,
where
crops
such
as
a
cucurbit
might
be
grown
on
the
same
land
subsequent
to
the
labeled
crop,
producers
are
prohibited
from
planting
fruiting
vegetable
or
cucurbit
crops
to
that
land
for
an
additional
four
months
following
the
last
halosulfuron
application
under
the
crop
rotational
restrictions
referenced
on
the
label.
For
certain
other
crops,
the
plant­
back
restriction
is
as
long
as
36
months.
This
issue
potentially
affects
succeeding
cropping
strategies.
The
plant­
back
interval
needs
to
be
extended
if
dry
conditions
prevail.
Rotation
to
other
crops,
such
as
snap
beans,

cannot
take
place
for
a
full
nine
months
after
the
last
halosulfuron
application.
These
plant­
back
restrictions
clearly
limit
the
use
of
this
product.
Since
application
in
pepper
and
eggplant
fields
is
for
row
middle
only,
this
product
does
not
provide
nutsedge
control
in
the
raised
bed,
the
area
where
competition
from
nutsedge
is
the
most
critical.
Also,
halosulfuron
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.
Compounding
other
pest
management
strategies
within
the
overall
production
system
is
the
fact
that
this
herbicide
cannot
be
applied
to
crops
treated
with
soil
applied
organophosphate
insecticides,
and
foliar
applications
of
organophosphate
insecticides
may
not
be
made
within
21
days
before
or
7
days
after
a
halosulfuron
application.

Rimsulfuron
The
rimsulfuron
registrant
claims
only
suppression
of
yellow
nutsedge.
Research
supports
registrants 
claim.
This
product
does
not
suppress
development
of
purple
nutsedge.
Tank
mixing
with
organophosphate
insecticides
may
cause
crop
injury.
Plant­
back
restrictions
are
12
months
or
greater
for
many
vegetable
crops.

S­
metolachlor
S­
metolachlor
is
a
chloroacetanilide­
classed
herbicide,
which
received
a
federal
label
allowing
its
use
on
tomato
crops
during
2003.
Use
of
this
selective
herbicide
on
pepper
has
been
allowed
in
Florida
under
a
Special
Local
Need
registration
since
approximately
1995.
S­
metolachlor
may
be
used
as
a
pre­
transplant
spray
applied
directly
to
the
bed
immediately
before
the
plastic
laying
operation
for
control
of
nightshade
and
pigweed.
Application
may
also
be
made
post­
directed
to
transplants
after
the
first
setting
rain,
and
also
to
treat
row
middles,
although
this
product
may
damage
transplants
that
have
been
weakened
by
environmental
stress.
This
herbicide
will
not
control
emerged
weeds.
S­
metolachlor
may
not
be
applied
within
90
days
of
tomato
harvest,
making
harvest
of
early
season
varieties
a
challenge
in
certain
years.
S­
metolachlor
is
not
registered
for
use
on
eggplant.
S­
Metolachlor
applied
under
plastic
mulch
offers
only
suppression
of
yellow
nutsedge
development.
It
does
not
impact
purple
nutsedge
development.
Both
nutsedge
species
are
present
in
most
vegetable
fields.
Further
work
is
required
to
address
potential
crop
tolerance
issues
with
this
new
tomato
label.

Glyphosate
Glyphosate
is
a
non­
selective
herbicide
that
usually
only
suppresses
nutsedge
development.
Additionally,
glyphosate
provides
no
residual
weed
control
and
repetitive
applications
would
be
required
to
manage
nutsedge.
Glyphosate
may
be
applied
prior
to
planting
or
only
between
vegetable
rows.
Contact
of
glyphosate
with
the
crop
will
cause
severe
injury.
Row
middle
Page
18
application
use
is
limited
because
of
the
potential
of
glyphosate
drift
to
the
crop
causing
severe
injury.

Napropamide
Napropamide
is
a
pre­
emergent
herbicide
applied
at
a
rate
of
2
 
4
lbs.
a.
i.
per
acre,
depending
on
specific
crop
usage.
It
may
be
applied
at
transplanting
or
during
the
early
stage
of
crop
development.
Napropamide
application
to
the
soil
must
be
incorporated
within
a
few
days
of
application
with
sufficient
rainfall
or
sprinkler
irrigation.
It
can
be
used
to
manage
certain
annual
grass
and
annual
broadleaf
weeds
if
applied
before
the
weeds
have
emerged.
It
is
important
that
this
product
be
applied
to
weed­
free
ground.
The
use
of
napropamide
can
delay
maturity
and
result
in
10
 
20
percent
yield
reductions,
although
this
is
not
typically
seen
in
banded
bed
fumigation.
Application
once
crop
plants
begin
blooming
is
prohibited.
Napropamide
is
only
fair
in
its
nutsedge
management
capabilities.
This
is
an
old
compound
that
has
not
held
a
lot
of
favor
in
the
past.
It
breaks
down
quickly
in
sunlight
and
without
overhead
irrigation
there
is
no
easy
way
to
move
it
into
the
soil
surface
to
protect
it.
While
it
is
effective
against
certain
grass
and
broadleaf
weeds,
it
is
weak
on
nutsedge,
especially
at
the
current
tomato/
pepper
rate.

Strawberry
allows
a
2X
increase
in
use
rate.
Napropamide
also
has
a
plant­
back
restriction,
which
is
12
months
for
non­
labeled
crops.
Another
significant
drawback
of
this
material
is
that
napropamide,
according
to
its
label,
does
not
control
established
weeds,
and
weeds
such
as
nutsedge
are
a
postemergent
weed
problem
in
Florida
vegetable
fields
annually.
Napropamide
is
not
even
marginally
efficacious
in
managing
nightshade
or
morningglory.
Consequently,
neither
of
these
weeds
is
listed
under
the
Weeds
Controlled
portion
of
the
napropramide
label.

Oxyfluorfen
Oxyfluorfen
is
a
diphenyl­
ether
herbicide
used
for
broad­
spectrum
pre­
and
post­
emergent
control
of
annual
broadleaf
weeds.
The
use
of
oxyfluorfen
is
not
practical
for
use
on
fruiting
vegetable
and
strawberry
crops
because
of
the
long
replant
period
required
following
application.
Oxyfluorfen s
use
would
be
limited
to
long
fallow
periods,
a
rare
condition
for
fields
that
are
typically
in
production
most
of
the
year.
This
product
could
provide
effective
control
of
difficult
weed
species
that
other
herbicides
cannot
control
if
used
during
renovation
or
a
fallow
period,
but
must
be
a
long
enough
timeframe
prior
to
initiation
of
the
next
cropping
cycle.
A
minimum
of
30
days
must
pass
between
oxyfluorfen
treatment
and
transplanting.
Not
incorporating
this
product
at
the
time
of
application
increases
the
potential
for
crop
injury
later,
especially
under
wet
conditions.

Paraquat
Paraquat
is
a
non­
selective
herbicide
that
provides
poor
control
of
nutsedge.
Additionally,
paraquat
does
not
provide
residual
weed
control.
Paraquat
may
be
applied
prior
to
planting
or
only
between
vegetable
rows.
Contact
of
paraquat
with
the
crop
causes
severe
injury.

Paraquat,
which
in
the
past
was
the
industry
standard
for
nightshade
management
in
Florida
vegetable
fields,
no
longer
manages
weeds
such
as
nightshade.
Resistance
to
paraquat
(
as
high
as
nearly
20
fold)
has
been
documented
in
the
state.
With
the
occurrence
and
expansion
of
resistance
among
the
nightshades
to
the
bipyridilium
class
of
chemistry,
producers
are
not
able
to
effectively
manage
this
weed.
Nightshade
is
also
an
alternate
host
capable
of
sustaining
large
populations
of
insect
pests
including
whiteflies,
aphids,
thrips
and
leafminers.
Additional
Page
19
treatments
of
alternative
herbicides
are
necessary
to
help
eliminate
bipyridilium
class
resistant
nightshade,
thus
eliminating
this
alternate
host
for
these
insect
pests.
In
addition
to
their
inherent
feeding
damage,
whiteflies,
aphids,
thrips
and
leafminers
are
the
vectors
for
numerous
virus
diseases
that
attack
vegetable
crops
and
severely
inhibit
yield.

Trifluralin
Trifluralin
is
used
to
aid
in
the
control
of
annual
grasses,
but
this
product
does
little
towards
management
of
broadleaf
weeds.
Tolerance
exhibited
by
crops
such
as
eggplants
is
only
marginal,
so
much
so
that
the
users
are
cautioned
about
the
tolerance
parameters
on
the
trifluralin
supplemental
labeling
for
eggplant
use.
Additionally,
use
of
this
product,
when
combined
with
effects
of
certain
cultural
practices
and
unfavorable
soils
or
environmental
conditions,
may
cause
excessive
crop
stress
resulting
in
retarded
crop
growth,
stand
reductions
and
reduced
yield.

Emerging
Alternatives
Among
the
other
active
ingredients
being
looked
at
as
potential
alternatives,
several
have
been
moving
toward
regulatory
decisions
that
would
influence
the
consideration
of
combination
treatments
to
replace
methyl
bromide.
Both
iodomethane
and
fosthiozate
represent
potential
chemical
replacements.
Iodomethane
exhibits
a
broader
spectrum
of
efficacy
where
fosthiozate
is
targeted
specifically
as
a
nematicide.
There
has
been
research
on
both
compounds
in
Florida,
but
many
issues
remain
in
determining
their
appropriate
place
in
current
production
schemes
and
the
application
methodology
required
to
maximizing
their
efficacy.

In
addition,
trifloxysulfuron­
Na
is
also
of
interest
to
Florida
tomato
producers.
The
spectrum
of
efficacy
of
this
research
compound
appears
to
make
this
a
product
of
choice
as
we
search
for
a
selective
herbicide
with
efficacy
toward
pre­
emergent
control
of
nutgrass.
Page
20
4)
Pest
Complex
and
Economic
Thresholds
In
the
2002
CUE
process,
one
of
the
more
difficult
aspects
was
capturing
the
complex
relationship
between
a
crop
production
system
and
pest
control
program
that
one
begins
with
the
application
of
extremely
efficacious
broad­
spectrum
material
such
as
methyl
bromide.
Also
complicating
the
decision
process
of
prioritizing
pests
to
be
used
in
the
targeted
search
for
the
best
alternative
is
the
long
history
of
access
to
methyl
bromide
across
the
current
production
areas.
The
emergence
of
new
pests
or
resurgence
of
pests
no
longer
has
to
be
considered
as
a
result
of
the
efficacy
of
methyl
bromide.

As
a
starting
point,
the
list
of
currently
identified
pests
across
the
four
crops
included
in
the
2002
submission
that
are
at
least
partially
controlled
with
methyl
bromide
were
utilized.
As
a
further
step
with
the
2003
submission,
the
research
and
grower
communities
were
asked
to
address
the
priority
of
control
associated
with
each
major
segment
of
pest
management,
weed
control,
pest
diseases
and
nematodes.
This
request
was
further
refined
to
look
at
regional
aspects
of
specific
pest
control
needs
for
the
separate
areas
of
tomato
production.
The
results
of
that
effort
are
provided
in
Tables
(),
(),
and
()
for
tomatoes,
strawberries
and
peppers/
eggplants,
respectively.

The
relative
ranking
down
major
pest
segments
does
not
indicate
a
ranking
that
would
include
all
of
the
weeds
prior
to
a
decision
for
nematode
or
plant
disease
control.
The
inherent
complexity
of
this
management
discussion
rationale
makes
a
simplistic
 
sample
pest
analysis 
of
critical
need
a
basic
screening
effort
at
best.
The
research
data
collected
to
date
illustrates
this
problem
in
that
we
have
very
few
trials
where
all
major
categories
of
pests
potentially
controlled
by
methyl
bromide
were
present.
Where
multiple
pests
did
occur,
the
relative
efficacy
differences
across
alternative
treatment
strategies
were
magnified.
The
reverse
of
this
is
also
true
in
that
many
of
the
alternative
strategies
were
commercially
screened
in
production
areas
that
had
been
in
continuous
production
utilizing
the
preplant
fumigant
methyl
bromide
and
may
have
appeared
to
be
more
efficacious
than
actually
warranted.

Pest
Complexes
Tomato
For
tomato,
the
relative
priority
of
the
major
categories
did
not
change
across
regions,
with
weed
control
followed
by
plant
disease
then
nematodes
as
the
decending
order
of
concern
from
a
direct
crop/
yield
perspective.
The
internal
priorities
for
specific
weed
species
and
plant
diseases
did
shift
based
on
production
region.
The
consistent
nematode
that
represented
the
highest
priority
was
the
root­
knot
nematode,
Meloidogyne
spp.

The
Dade
County
production
area
represents
a
unique
situation
because
of
the
soils
encountered
in
this
production
area.
There
is
significant
concern
over
the
possible
resurgence
of
a
soilborne
disease,
corky
brown
root
rot,
Pyrenochaeta
lycopersici,
that
has
not
been
a
problem
since
the
introduction
of
methyl
bromide
as
a
soil
fumigant
of
choice.
Page
21
Table
18:
Pest
Complex
and
Control
Priorities
 
Tomato
North
Florida
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&

C.
esculentus)
Nightshade
(
Solanum
spp.)

2
Plant
Diseases
Bacterial
Wilt
(
Ralstonia
solanacerum)
Damping
Off
(
Rhizoctonia
solani,

Pythium
spp.,
Phytophthora
spp.)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)

Ruskin
 
Palmetto
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Nightshade
(
Solanum
spp.)
Eclipta
(
Eclipta
prostrata)
Morningglory
(
Ipomoea
spp.)

2
Plant
Diseases
Fusarium
Wilt
(
Fusarium
oxysporum)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)

Palm
Beach
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&

C.
esculentus)
Nightshade
(
Solanum
spp.)
Eclipta
(
Eclipta
prostrata)

2
Plant
Diseases
Fusarium
(
Fusarium
oxysporum
f
sp.
radiscislycopersici
Southern
Blight
(
Schlerosium
rolfsii)
Damping
Off
(
Rhizoctonia
solani,

Pythium
spp.,
Phytophthora
spp.)
White
Mold
(
Schlerotinia
sclerotiorum)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)

Southwest
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Nightshade
(
Solanum
spp.)
Eclipta
(
Eclipta
prostrata)
Morningglory
(
Ipomoea
spp.)

2
Plant
Diseases
Fusarium
(
Fusarium
oxysporum
f
sp.
radiscislycopersici
Damping
Off
(
Rhizoctonia
solani,

Pythium
spp.,
Phytophthora
spp.)
White
Mold
(
Schlerotinia
sclerotiorum)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)
Page
22
Table
18:
Pest
Complex
and
Control
Priorities
 
Tomato
(
cont.)

Dade
County
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Pigweed
(
Amareanthus
spp.)
Crabgrass
(
Digetaria
spp.)
Barnyardgrass
(
Echinochloa
crusgalli

2
Plant
Diseases
Verticillium
Wilt
(
Verticillium
albaatrum
Fusarium
(
Fusarium
oxysporum
f
sp.
raadiscislycopersici
Corky
Brown
Root
Rot
(
Pyrenochaeta
lycopersici)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)
Reniform
(
Rotylenchulus
spp.)

Strawberry
The
pest
complex
targeted
for
strawberry
contains
the
same
component
as
tomatoes,
but
in
a
different
order.
The
nematode
complex
is
top
priority,
followed
by
weeds
and
the
plant
diseases,
with
a
different
spectrum
of
pest
to
be
considered.
The
primary
nematode
to
be
controlled
is
the
sting
nematode,
Belonolaimus
longicaudatus,
and
additional
weed
species
have
been
added
to
nutsedge
in
the
weed
matrix.
Plant
diseases,
while
a
consideration,
do
not
appear
to
be
on
the
same
order
of
magnitude
as
the
other
two
major
categories.

Table
19:
Pest
Complex
and
Control
Priorities
Strawberry
Priority
1
2
3
4
1
Nematodes
Sting
Nematode
(
Belonolaimus
longicaudatus)
Root­
Knot
(
Meloidogyne
spp.)

2
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Carolina
Geranium
(
Geranium
carolinianum)
Cut­
Leaf
Evening
Primrose
(
Onoethera
laciniata)

3
Plant
Diseases
Phytophthora
Crown
Rot
(
Phytophthora
citricola
&
P.
cactorum)

Pepper/
Eggplant
The
relative
priority
among
major
pest
categories
for
these
two
solanaceous
crops
are
the
same
as
tomato,
with
weeds
representing
the
top
priority
followed
by
plant
diseases
and
then
nematodes.
The
spectrum
of
weeds
is
similar
regionally
to
those
for
the
regional
considerations
for
tomato
where
production
areas
overlap.
There
was
no
attempt
to
further
refine
the
statewide
distributions
for
these
two
crops.
The
nematode
pests
are
the
same
with
root­
knot
being
far
and
away
the
primary
pest
to
be
controlled.
The
plant
disease
spectrum
was
different
as
would
be
expected.
We
are
currently
seeing
an
increase
in
incidence
of
white
mold
across
the
Page
23
growing
region
even
with
methyl
bromide.
The
factors
influencing
this
increase
appear
to
be
climactic
in
nature.

Table
20:
Pest
Complex
and
Control
Priorities
Pepper
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Nightshade
(
Solanum
spp.)
Morningglory
(
Ipomoea
spp.)

2
Plant
Diseases
Phytophthora
Blight
(
Phytophthora
spp.)
Damping
Off
(
Rhizoctonia
solani,
Pythium
spp.,)
White
Mold
(
Schlerotinia
sclerotiorum)

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)

Eggplant
Priority
1
2
3
4
1
Weeds
Nutsedge
(
Cyperus
rotundus
&
C.
esculentus)
Nightshade
(
Solanum
spp.)
Morningglory
(
Ipomoea
spp.)

2
Plant
Diseases
Southern
Blight
(
Schlerosium
rolfsii)
Damping
Off
(
Rhizoctonia
solani,
Pythium
spp.,
Fusarium
spp.)
Verticillium
Wilt
(
Verticillium
albaatrum

3
Nematodes
Root­
Knot
(
Meloidogyne
spp.)

Economic
Thresholds
Justification
for
the
continued
use
and
availability
of
broad
spectrum
soil
fumigants
like
methyl
bromide
are
fundamentally
based
on
the
common
occurrence,
diversity
and
distribution
of
pests
problems
which
occur
in
the
field,
and
to
the
avoidance
of
crop
loss
that
these
pests
cause.

Most
vegetable
crops
produced
in
Florida
and
dependent
upon
methyl
bromide
soil
fumigation
are
susceptible
to
nematode
and
disease
injury.
The
ability
to
predict
crop
losses
attributable
to
nematodes
and
other
pests
first
requires
accurate
assessment
and
description
of
pest
density,

distribution,
and
areas
of
pest
species
overlap
within
the
field.
The
areas
of
overlap
are
important
since
they
form
the
critical
areas
for
pest
interactions.
With
methyl
bromide
soil
fumigation,
specific
grower
decisions
regarding
soilborne
pest
and
disease
monitoring
were
never
truly
essential
because
of
the
broad­
spectrum
efficacy
of
the
fumigant.
Although
progress
is
being
made
to
develop
new
soil
sampling/
plant
bioassay/
pest
monitoring
protocols,
cost
effective,
reliable
sampling
procedures
to
accurately
quantify
soilborne
pest
and
disease
population
levels
are
currently
not
available
for
grower
use.

Even
if
reliable
soil
sampling
methodologies
were
available
in
Florida,
it
is
also
currently
not
possible
to
confidently
predict
crop
losses
due
to
nematodes
and
other
soilborne
diseases
based
solely
on
soil
and
root
sample
information
of
pest
population
density.
Based
on
previous
university
research
efforts,
much
is
known
about
the
impact
of
specific
pests,
agronomic
inputs,
Page
24
and
environmental
factors
on
plant
growth
when
they
are
manipulated
and
studied
separately.
Significantly
less
is
known
about
multiple
pest
interaction
effects
on
plant
growth
and
epidemiological
processes.
As
such,
damage
functions
and
economic
thresholds
quantitatively
relating
pest
population
levels
to
pest
management
decisions
have
not
been
accurately
determined
and
field
validated
for
grower
use
for
either
individual
or
concomitant
pest
species.

Most
research
does
show
that
plant
symptoms
and
yield
reductions
are
not
only
related
to
preplant
pest
infestation
levels
of
nematodes,
diseases,
and
weeds
in
soil
but
to
interactive
effects
and
other
environmental
stresses
imposed
upon
the
plant
during
crop
growth.
As
a
result
of
these
interactions,
most
attempts
to
characterize
crop
losses
based
on
even
a
single
pest
species
model
typically
underestimate
observed
production
losses
in
the
field.

Based
on
additional
risk
assessments,
university
recommendations
for
pest
management
for
the
high
value
vegetable
crops
of
Florida
caution
growers
that
even
the
mere
presence
of
root­
knot
nematode
in
preplant
soil
samples
indicates
a
potentially
serious
problem,
particularly
on
sandy
ground
during
the
fall
when
temperature
and
rainfall
patterns
favor
high
levels
of
pest
activity
and
growth,
and
or
in
fields
where
various
wilt
diseases
occur
concomitantly.
The
bestdocumented
example
of
this
type
of
multiple
pest
interaction
is
the
root­
knot
nematode,
Meloidogyne
spp.,
and
Fusarium
wilt
disease
on
old
tomato
production
land
in
Florida.
The
rootknot
nematode,
by
causing
the
development
of
root
galls,
provides
a
nutrient­
rich
food
source
that
the
fungus
colonizes
rapidly.
Root­
knot
nematode
can
thus
significantly
enhance
disease
development
and
yield
loss,
elevating
primary
or
secondary
pathogens
to
major
pest
status
even
though
population
levels
or
pathogenic
potential
of
the
fungi
were
initially
very
low
and
yield
losses
would
have
been
minimal
in
the
absence
of
the
nematode.

To
be
practical
and
meaningful
to
growers,
prediction
of
crop
loss
and
development
of
economic
thresholds
for
advisory
purposes
must
be
able
to
partition
and
account
for
the
interaction
of
multiple
pests
under
varying
agronomic
practices
and
economic
and
environmental
conditions.

Crop
loss
and
economic
threshold
information
from
the
total
pest
complex
forms
the
basis
for
rational
or
optimal
farm,
crop,
and
pest
management
decisions.
Development
of
 
pest
complex 
based
crop
loss
predictions
that
consider
environmental
and
economic
flux
have
not
been
developed
for
use
in
Florida
and
therefore
must
await
further
refinements
in
many
different
areas
of
nematology,
plant
pathology,
weed
science,
and
agricultural
economics.
Page
25
5)
Best
Available
Alternatives
In
keeping
with
the
process
utilized
in
the
2002
application,
the
2003
budgets
and
analysis
of
impacts
are
based
on
conversations
among
the
research
community
on
the
best
currently
available
treatment
strategies.
While
there
are
differences
of
opinions
about
the
absolute
value
of
these
alternatives
at
the
research
level,
these
represent
the
 
best
currently
available
alternatives 
to
methyl
bromide.
Some
of
these
treatment
alternatives
have
not
received
a
tremendous
amount
of
research­
based
scrutiny,
as
most
work
prior
to
the
2003
spring
use
season
was
done
with
the
assumption
that
pebulate
would
be
the
herbicide
product
of
choice
where
available
 
the
largest
use
sector
being
tomato.
Also,
with
some
of
the
more
recently
registered
herbicides,
further
refinement
in
use
patterns
and
application
rates
may
affect
the
utility
of
these
products.
The
most
recent
change
in
personal
protective
equipment
(
PPE)
and
buffer
zone
reductions
for
1,3­
dichloropropene
containing
compounds
may
shift
some
of
the
crops
back
to
an
in­
bed
fumigation
as
the
application
method
of
choice.
With
the
above
caveats,

we
have
attempted
to
capture
the
alternative
treatment
regimes
and
the
impacts
of
those
alternatives
to
crop
production
practices.
The
direct
costs
associated
with
the
changes
are
reflected
in
the
alternative
crop
budgets
found
in
Appendix
II.
Brief
descriptions
of
those
impacts
are
included
in
the
individual
regional
or
crop­
based
alternative
presented
below.

Tomato
The
alternatives
for
tomato
are
split
on
a
geographical
basis
between
Dade
County
and
the
rest
of
the
Florida
production
regions.
For
clarity,
the
two
alternative
treatment
strategies
will
be
discussed
separately.

Tomato
(
Florida
and
adjacent
counties
in
Georgia)

To
replace
the
industry
standard
methyl
bromide:
Chloropicrin
C­
35
formulation,
plus,
the
following
products
were
added
to
the
crop
production
scenarios.

Telone
C­
35,
26
gallons
per
acre,
broadcast
applied,
3
 
5
weeks
prior
to
bed
formation.
A
subsequent
chloropicrin
application
four
weeks
later
at
150
pounds
per
treated
acre
is
shanked
directly
into
the
bed,
with
a
combination
herbicide
application
of
napropamide
at
2
pounds
of
active
ingredient
per
treated
acre
and
S­
metolachlor
at
1.27
pounds
of
active
ingredient
per
treated
acre,
applied
as
a
tank
mix
to
the
bed
immediately
prior
to
laying
plastic
on
the
pressed
bed.
For
areas
with
heavy
nutsedge
pressure,
there
is
the
need
to
include
an
additional
application
of
halosulfuron
at
0.05
pounds
of
active
ingredient
per
treated
acre
applied
as
a
postemergent
directed
spray.

This
treatment
regime
adds
an
additional
fumigation
application,
and
an
additional
herbicide
application
when
compared
to
the
industry
standard
bed
fumigation
with
methyl
bromide.
In
addition
to
the
direct
materials
and
application
costs,
the
longer
time
interval
to
transplanting
also
creates
a
management
cost
associated
with
field
and
soil
moisture
maintenance.
Page
26
Tomato
(
Dade
County)

Rockdale
and
marl
soils,
coupled
with
use
prohibitions
of
Telone
in
Dade
County,
make
the
alternative
fumigants
Vapam
or
K­
pam
at
75
gallons
or
60
gallons
per
acre,
respectively,
depending
on
grower
choice,
as
the
best
currently
available
alternatives.
This
application
is
applied
with
150
pounds
of
chloropicrin
per
treated
acre
and
shanked
into
the
bed
at
time
of
plastic
laying.
The
same
additional
herbicides
as
for
the
rest
of
Florida
tomatoes
are
also
part
of
this
treatment
regime.

The
major
changes
in
the
crop
budgets
under
this
alternative
treatment
strategy
are
the
differential
cost
of
the
fumigant,
and
the
added
cost
of
the
herbicides
and
application
costs
associated
with
those
products.

Strawberry
The
best
currently
available
treatment
alternative
for
strawberry
includes
the
broadcast
application
of
26
gallons
of
Telone
C­
35
per
acre,
followed
four
weeks
later
by
the
in­
bed
application
of
150
gallons
of
chloropicrin
per
treated
acre
shanked
into
the
bed
at
plastic
laying.
The
herbicide
combination
includes
oxyfluorfen
at
0.5
pounds
of
active
ingredient
per
treated
acre
plus
napropamide
at
4
pounds
of
active
ingredient
per
treated
acre,
broadcast
to
the
bed
surface
at
plastic
laying.
No
post­
emergent
nutsedge
material
is
available
at
this
time
for
strawberry.

Cost
considerations
under
this
alternative
treatment
scenario
include
the
differential
fumigation
costs
and
the
additional
application
costs
associated
with
the
herbicide
applications
at
plastic
laying.
The
additional
field
maintenance
period
required
by
the
broadcast
application
of
Telone
was
also
factored
into
the
crop
budgets.

Pepper/
Eggplant
The
non­
tomato
solanaceous
crops
pepper
and
eggplant
share
the
same
fumigation
regime
as
the
best
currently
available
alternative
to
methyl
bromide.
This
includes
the
Telone
C­
35
26
gallons
per
acre
broadcast
fumigation.
Also
required
is
the
additional
application
of
chloropicrin
at
150
pounds
per
treated
acre
four
weeks
later
shanked
into
the
bed
at
plastic
laying.
For
peppers,
an
additional
herbicide
application
is
required
at
plastic
laying
with
the
treatment
of
choice
currently
being
napropamide
at
2
pounds
of
active
ingredient
per
treated
acre
combined
with
S­
metolachlor
at
0.95
pounds
of
active
ingredient
per
acre
per
treated
acre,
applied
at
plastic
laying.
For
eggplants,
the
additional
napropamide
application
is
instead
combined
with
trifluralin
at
0.5
pounds
of
active
ingredient
per
treated
acre.

The
impact
on
the
enterprise
budgets
in
adopting
these
alternatives
includes
the
alternative
fumigant
costs,
the
additional
application
costs
associated
with
the
broadcast
fumigation,
and
the
additional
herbicide
application
costs.
Increased
field
maintenance
costs,
as
a
result
of
the
increased
time
required
for
the
crop
cycle,
was
also
included.
Page
27
6)
Emission
Reduction
 
Virtually
Impermeable
Film
Mulch
Virtually
Impermeable
Films
(
VIF)
have
been
developed
to
reduce
overall
field
application
rates
and
soil
emissions
of
methyl
bromide.
VIF
has
been
used
for
agricultural
mulch
film
in
Europe
for
some
time
now,
but
its
use
in
the
United
States
has
been
very
limited.
There
are
many
reasons
for
this
differential
adoption
rate
between
Europe
and
the
USA.
The
following
narrative
outlines
major
constraints
to
implementation
that
must
be
overcome
prior
to
expansion
of
agricultural
use
of
VIF
in
Florida.

Linear
Shearing
Most
soil
fumigant
applications
in
Europe
are
broadcast,
solid
tarp
(
i.
e.
the
entire
field
is
fumigated)
fumigation
employing
slower
ground
speeds
than
typically
used
in
Florida.
Most
Florida
growers,
and
many
of
those
throughout
the
southeastern
U.
S.,
inject
soil
fumigants
like
methyl
bromide
into
the
soil
in
an
8
inch
tall,
raised
bed
about
32
inches
in
width
and
cover
just
the
treated
bed
with
mulch
film.
Application
of
mulch
film
to
raised
beds
requires
burial
of
the
film
in
the
soil
on
both
sides
of
the
bed.
Film
is
typically
applied
at
ground
speeds
of
4.5
mph
or
faster.
The
speed
of
application,
the
equipment
used,
and
the
process
of
stretching
the
film
across
a
raised
bed
and
down
into
soil
on
either
side,
then
covering
it
with
a
coarse,
abrasive,

sandy
soil,
subjects
the
film
to
shear
forces
much
greater
than
would
be
encountered
with
a
broadcast
application.
These
shear
forces
have
resulted
in
linear
shearing
of
most
of
the
VIF
products
tested
in
Florida,
which
has
subsequently
caused
growers
to
reject
these
products
as
viable
options
to
standard
low
density
polyethylene
film
mulch.

Photodegradation
Broadcast,
solid
tarp
fumigation
generally
requires
a
film
which
will
hold
up
for
at
most
2
weeks,
while
Florida
vegetable
growers
require
a
film
that
maintains
its
integrity
for
at
least
6
months
or
longer,
depending
upon
the
crop
and
subsequent
cropping
practices,
such
as
production
of
a
second
crop
on
the
same
beds
with
the
existing
mulch
film.
To
date,
all
of
the
commercially
available
VIF
has
been
produced
in
Europe,
and
designed
to
satisfy
the
needs
of
the
European
market.
As
a
result,
producers
include
very
little
uv
inhibitor
in
the
film
as
the
film
will
be
covering
the
soil
for
such
a
short
time
interval.
The
lack
of
sufficient
uv
inhibitor
means
the
film
deteriorates
rapidly
in
the
climate
of
the
southeastern
U.
S.
and
does
not
remain
intact
for
the
length
of
the
season.

Wind
Lift
None
of
the
VIF
products
currently
available
are
embossed.
Embossing
allows
the
film
to
have
some
natural
elasticity
and
 
memory 
that
allows
it
to
tighten
as
the
temperature
drops
and
stretch
as
the
temperature
increases,
thereby
maintaining
a
tight
fit
on
the
raised
bed.
Without
embossing,
it
is
difficult
to
lay
the
film
tight
across
the
bed
and
maintain
that
tension,
resulting
in
increased
problems
with
wind
lift.
Wind
is
a
problem
during
much
of
the
production
season
in
Florida.
In
the
spring
we
experience
high
winds
as
the
weather
changes
with
the
season
and
weather
fronts
come
through
the
state.
In
the
period
of
July
through
November,
a
time
encompassing
most
of
our
fall
production
season,
Florida
is
vulnerable
to
hurricanes
and
other
Page
28
tropical
storms
which
deliver
torrential
rains
and
high
winds;
conditions
ideal
for
massive
loss
of
mulch
film
from
the
raised
beds.
Tight
fitting
film
is
important
because
any
looseness
provides
an
opportunity
for
wind
to
lift
the
film
and
blow
it
off
the
bed.

Installation
Costs
Vegetable
growers
are
always
pressed
for
time
and
because
of
the
many
different
operations
involved
in
forming
beds
(
applying
fertilizer
and
fumigant,
laying
plastic
and
drip
irrigation
tubing),
minimum
requirements
for
a
successful
fumigation
operation
make
it
necessary
to
lay
a
mulch
film
at
ground
speeds
of
at
least
4.5
mph,
in
order
to
be
able
to
prepare
the
necessary
20
to
25
acres
per
day.
Anything
that
slows
that
process
costs
more
in
terms
of
manpower.
Since
most
VIF
products
tested
to
date
have
had
problems
with
linear
shear,
and
shear
problems
increase
with
increased
ground
speed,
the
physical
limitations
of
VIF
film
application
can
reduce
that
figure
to
10
to
12
acres
per
day;
a
number
which
is
not
acceptable
or
cost
effective.

Manufacture/
Distribution/
Logistics
Since
all
of
the
currently
available
VIF
products
are
produced
in
Europe,
there
is
considerable
cost
associated
with
importation,
including
shipping
fees,
the
fee
charged
by
a
customs
broker,

import
duties
and
trucking
fees
from
the
port
to
the
local
distributor.
As
a
result,
growers
can
expect
to
pay
more
than
twice
as
much
for
VIF
as
they
pay
for
standard
polyethylene
mulch
film.
There
is
little
to
no
warehoused
supply
of
VIF
in
Florida
or
the
U.
S.,
thus
it
is
imported
as
it
is
ordered
and
that
can
mean
delivery
delays
in
excess
of
2
months.
Growers,
like
most
of
us,
are
not
keen
on
ordering
something
sight
unseen
and
having
to
wait
months
to
receive
it.
Unexpected
transoceanic
delivery
delays
are
common
as
a
result
of
increased
scrutiny
of
imported
products
into
the
U.
S.,
and
this
lack
of
stability
in
the
market
can
leave
a
grower
without
the
film
he
needs
when
he
has
to
have
it.

Since
reduction
in
methyl
bromide
rate
is
an
integral
part
of
the
use
of
VIF,
the
resultant
lack
of
VIF
mulch
can
force
a
grower
to
reduce
his
acreage
in
order
to
increase
the
rate
of
methyl
bromide
on
the
remainder
of
his
acreage.
While
this
may
seem
like
a
minor
issue,
it
must
be
remembered
that
all
other
production
inputs
have
been
ordered
by
this
time
and
a
grower s
production
finances
are
based
on
projected
returns
from
planned
acreage.
When
the
planned
acreage
changes,
a
grower
may
find
themselves
in
financial
problems.

Grower
Adoption
Growers
have
not
had
enough
experience
with
VIF
mulch
and
the
experience
they
have
had
generally
has
been
bad
due
to
poor
handling
and
laying
characteristics.
Problems
such
as
reduction
of
ground
speed
done
in
an
effort
to
eliminate
linear
shear
during
installation,
and
wind
damage
(
lifting,
complete
release)
of
film
due
to
it
not
being
held
tightly
enough
against
the
soil,
have
kept
grower
interest
in
VIF
to
a
minimum.
While
research
and
grower
education
efforts
have
been
conducted
with
VIF
for
the
past
5
years,
poor
handling
characteristics
under
commercial
conditions,
confusion
about
what
constitutes
a
VIF
and
a
lack
of
understanding
of
their
potential
market
on
the
part
of
some
VIF
manufacturers
have
resulted
in
low
interest
and
adoption
of
VIF
technology.
Page
29
Another
problem
growers
confront
with
VIF
is
the
lack
of
an
accepted
standard.
The
only
published
standard
for
VIF
is
the
French
standard
for
permeability,
and
there
is
a
great
deal
of
variability
among
products
that
comply
with
the
French
standard.
Indeed,
there
can
be
variability
among
films
produced
by
the
same
manufacturer.
Growers
require
a
consistent
product
with
good
handling
characteristics.
Most
of
the
VIF
tested
to
date
in
Florida
and
the
U.
S.
has
not
provided
that.
There
is
much
confusion
as
to
what
VIF
mulch
really
is,
as
some
suppliers
have
been
marketing
 
high
barrier 
polyethylene
mulch
as
being
the
same
as
VIF,
which
it
most
definitely
is
not.
Hopefully,
future
exposure
of
growers
to
true
VIF
products
will
eliminate
that
confusion.

Continuing
Research
Research
on
the
use
of
VIF
to
reduce
soil
application
rates
and
emissions
of
methyl
bromide
and
other
soil
fumigants
has
been
broadly
conducted
in
the
state.
It
is
clear
from
this
research
with
VIF
that
fumigant
use
rates
can
be
potentially
reduced
by
as
much
as
20
 
25
percent
without
serious
loss
of
crop
yield
or
pest
control
efficacy.
The
conduct
of
the
research
was
also
instrumental
in
identifying
all
of
the
potential
problems
of
actual
grower
use
and
adoption.

Research
and
demonstration
projects
continue
in
the
west
central,
south
and
southwest
production
regions
of
Florida
to
evaluate
the
most
promising
VIF
mulch
under
commercial
conditions
and
to
collect
efficacy
and
handling
characteristics
data
in
cooperation
with
growers.

It
is
hoped
that
this
project
will
aid
in
the
adoption
of
VIF
as
a
practical
means
of
reducing
methyl
bromide
rate
and
emissions.
Page
30
7)
FLORIDA
METHYL
BROMIDE
ALTERNATIVES
RESEARCH
Historical
Perspective
Since
1993,
alternatives
to
methyl
bromide
research
efforts
in
Florida
have
been
formulated
and
collectively
defined
by
a
core
group
of
individuals
from
agricultural
commodity
groups,
fruit
and
vegetable
associations,
as
well
as
University
of
Florida
and
USDA
scientists.
The
alternatives
to
methyl
bromide
research
task
force
was
initially
assembled
in
1994
to
discuss,
organize
and
optimize
future
alternatives
to
methyl
bromide
research
efforts
within
the
state,
as
well
as
to
draft
a
long­
term
plan
to
characterize
potential
phase­
out
impacts,
possible
avenues
of
research
funding,
and
to
develop
long
term
plans
of
work
for
defining
and
moving
economically
viable
alternatives
for
methyl
bromide
into
commercial
use.

Florida
research
efforts
were
also
formulated
and
regionally
defined
to
account
for
the
broad,
yet
distinct,
geographic,
environmental
and
cultural
variation
in
agricultural
production
that
occurs
throughout
the
state.
Separate,
yet
interconnected,
research
programs
of
the
University
of
Florida
have
been
developed
in
primary
fruit
and
vegetable
producing
areas
of
northwest,
north
central,
west
central,
southwest
and
south
Florida.
Within
each
production
region,
research
protocols
for
the
evaluation
of
chemical
and
nonchemical
methyl
bromide
alternatives
were
standardized
among
research
locations
to
minimize
possible
response
variability
associated
with
differences
in
site
preparation,
chemical
use
rates,
application
and
incorporation
methodology,
as
well
as
timings
and
measurement
units
of
pest
and
crop
response.
Initially,
selection
and
funding
priorities
were
given
to
projects
which
emphasized
1)
treatment
comparisons
that
had
the
widest
applicability
across
crops
and
soils;
2)
projects
that
examined
multiple
pests
and
control
strategies
(
IPM);
or
3)
projects
that
addressed
multicropping.
In
addition,
research
priorities
were
also
assigned
to
chemical
alternatives
with
defined
potential
to
replace
methyl
bromide
and
where
they
could
be
repeatedly
evaluated
as
independent
treatments
in
replicated
field
trials,
often
in
the
same
location,
with
the
same
crops
for
repeated
production
cycles
to
insure
response
consistency
and
or
to
characterize
any
response
degradation.

In
total,
Florida
based
research
projects
have
involved
more
than
21
University
of
Florida
and
United
States
Department
of
Agriculture
­
Agricultural
Research
Service
scientists
with
primary
emphasis
on
this
issue.
Small
plot
research
trials
have
been
annually
conducted
at
six
University
of
Florida
Research
&
Education
Centers
located
in
Quincy,
Gainesville,
Lake
Alfred,
Bradenton,
Immokalee,
and
Homestead,
FL,
and
at
the
USDA
Horticultural
Research
Laboratory
in
Ft.
Pierce,
FL.
The
Florida
research
program
has
been
diverse,
involving
evaluations
of
various
chemical,

nonchemical,
and
integrated
pest
management
(
IPM)
tactics.
Overall,
the
principal
objective
of
this
research
has
been
to
evaluate
and
validate
the
effectiveness
and
economic
viability
of
alternatives
to
methyl
bromide
soil
fumigation
for
nematode,
soilborne
disease,
and
weed
control
in
plastic
mulch
vegetable
production
systems
in
Florida.

In
addition
to
USDA
ARS
and
CSREES
sponsored
research,
the
USDA s
IR­
4
research
program
in
Florida
has
also
been
actively
involved
in
identifying
and
evaluating
alternative
chemicals
either
alone
or
in
combination
as
potential
replacements
of
methyl
bromide.
The
Florida
IR­
4
program
has
involved
the
University
of
Florida,
USDA
and
contract
researchers
in
soil
fumigation
studies
with
methyl
bromide
alternatives
in
fresh
market
strawberries
and
tomatoes.
Funding
for
these
studies
have
been
exclusively
supported
by
contributions
from
various
chemical
companies
Page
31
desiring
field­
testing
of
potential
alternative
replacements,
either
alone
or
in
combination,
to
that
of
methyl
bromide.

Research
Priorities
An
effort
was
made
to
coordinate
the
research
effort
and
funding
as
much
as
possible.
Funding
for
projects
undertaken
during
this
initiative
has
come
from
federal
government
sources,
USDA
and
EPA,
state
level
institutional
support,
University
of
Florida
IFAS
Dean
for
Research,

commodity
organizations,
and
individual
grower
and
industry
support.

Since
1993,
significant
advances
have
been
attempted
in
Florida
towards
the
evaluation
and
integration
of
various
chemical
and
nonchemical
tactics
to
replace
the
broad­
spectrum
efficacy
of
soil
fumigation
uses
of
methyl
bromide.
Overall,
the
results
of
this
collective
work
also
have
shown
that
pest
control
efficacy
for
all
of
the
chemical
alternatives
are
generally
more
highly
dependent
upon
parameters
such
as
uniform
delivery
and
distribution
in
soil
compared
to
that
of
methyl
bromide.
This
research
has
also
clearly
demonstrated
that
prevailing
soil,
soil
moisture
and
climatic
conditions
can
be
much
more
important
determinants
of
efficacy
and
crop
response
with
the
alternative
tactics.
Previous
research
evaluating
various
chemical
alternatives
to
methyl
bromide
suggests
that
the
mixture
of
1,3­
dichloropropene
(
Telone)
with
chloropicrin,
coupled
with
separate,
but
complementary
chloropicrin
and
herbicide
treatments
for
weed
control,
has
a
potential
as
an
IPM
alternative
to
methyl
bromide
to
manage
soilborne
pests
and
sustain
crop
yields.
Field
research
continues
to
focus
on
fumigant
combinations
and
new
herbicide
partners,
as
well
refinements
in
application
and
incorporation
technologies
to
define
and
reduce
causes
of
pest
and
crop
response
inconsistencies.

The
breadth
and
focus
of
the
methyl
bromide
alternatives
research
program
in
Florida
has
not
been
limited
exclusively
to
evaluations
of
chemical
combinations
treatment
regimes.
Rather,
the
program
has
encompassed
an
evaluation
of
a
diversity
of
nonchemical
tactics
as
well.
The
nonchemical
alternatives
which
continue
to
be
evaluated
in
field
experimentation
include
1)
Cover
Crops;
2)
Host
Plant
Resistance;
3)
Organic
Amendments;
4)
Solarization/
Biofumigation;

5)
Biological
Control;
6)
Paper
and
Plastic
Mulch
Technologies
and
Emission
Reduction;
7)
Natural
Product
Pesticides;
and
8)
Crop
Rotation.
A
considerable
amount
of
Florida
research
is
also
currently
evaluating
microbial
approaches
to
the
enhancement
of
crop
growth
and
yield
potential.
Unfortunately,
most
of
these
approaches
are
only
marginally
effective
and
remain
largely
undeveloped
and
essentially
unranked
as
potential
replacements
to
methyl
bromide.
Continued
research
and
development
of
these
tactics
will
require
significant
commitments
of
additional
research
funds
and
human
resources.

Future
Research
Plans
Historically,
the
principal
objective
of
Florida
research
has
been
to
evaluate
and
validate
the
effectiveness
and
economic
viability
of
alternatives
to
methyl
bromide
soil
fumigation
for
nematode,
soilborne
disease,
and
weed
control
in
plastic
mulch
vegetable
production
systems
in
Florida.
During
the
period
1995
to
the
present,
significant
advances
have
been
made
in
the
evaluation
and
integration
of
various
chemical
and
nonchemical
tactics.
Ongoing
Florida
research
is
still
broadly
defined
to
include
a
diverse
mix
of
chemical
and
nonchemical
alternatives.
The
magnitude
of
these
research
efforts
has
diminished
however
with
the
overall
decline
in
federal
and
state
research
funding.
Page
32
Underlying
the
current
research
projects,
and
serving
as
a
foundation
of
future
research
directives,
is
a
need
to
focus
on
long­
term
practical
solutions
for
a
very
complex
cropping
system.
Current
research
priorities
include
the
following:

 
Continue
to
identify
and
further
define
optimum
conditions
and
procedures
required
to
maximize
performance
of
Telone,
chloropicrin,
and
other
fumigant
and
herbicide
products.

 
Develop
a
more
comprehensive
understanding
of
the
possible
biologic
and
economic
impacts
of
implementing
the
proposed
alternatives
to
methyl
bromide
in
commercial
Florida
agriculture.

 
Continue
to
identify
and
resolve
implementational
constraints
to
methyl
bromide
alternatives
(
i.
e.,
high
costs,
lower
efficacy,
increased
production
or
environmental
risks,

regulatory
constraints,
and/
or
reduced
farm
profitability)
that
negatively
impact
future
widespread
adoption
of
such
alternatives.

 
Identify
and
evaluate
new
herbicide
partners
to
Tillam
(
Pebulate),
which
has
identified
as
an
integral
component
of
the
methyl
bromide
potential
alternative
for
tomatoes.

 
Expand
alternative
to
methyl
bromide
research
efforts
in
Florida
to
include
pepper,
eggplant,
cucurbits,
cut
flowers,
caladiums,
turf,
and
ornamentals.

 
Continue
to
develop
effective
multi­
crop,
IPM
based
systems,
including
characterization
of
impacts
and
residual
effects
within
current
double
cropping
systems.

 
Maintain
technology
transfer
projects
to
educate
growers
to
learn
how
to
effectively
choose,
apply,
and
incorporate
alternative
chemical
so
as
to
maximize
pest
control,
crop
response
and
to
avoid
problems
of
plant
phytotoxicity
and
crop
loss.

 
Continue
to
identify
and
evaluate
new
pest
monitoring
systems
to
provide
rationale
and
justification
for
Florida
pest
management/
crop
production
systems.

 
Continue
to
evaluate
mulch
technologies
and
procedures
to
minimize
emissions
of
methyl
bromide
and
other
soil
fumigant
compounds
from
soil.

 
Continue
to
identify
and
evaluate
emerging
nonchemical
alternatives.

As
research
data
becomes
available
and
is
reviewed,
the
focus
of
individual
research
areas
will
change.
The
Florida
Alternatives
Research
Task
Force
will
continue
to
serve
as
an
information
review
committee
for
this
research.
Additional
funding
is
required
to
insure
a
timely
and
effective
research
effort.

A
sampling
of
the
types
of
research
efforts
and
individual
research
programs
are
attached
in
Appendix
II,
A
and
B,
Research
Program
Information.
This
is
not
an
all­
inclusive
survey
of
ongoing
research
efforts
in
Florida.
Page
33
8)
2003
Application
Forms
Individual
application
forms
have
been
completed
for
the
crops
and
sub
regions
as
identified
in
the
CUE
petitions
filed
last
year,
Tomato
02­
0046,
Strawberry
02­
0053,
and
Solanaceous
crops
other
than
Tomato
02­
0054.
A
summary
of
the
total
amounts
request
for
each
crop
group
is
provided
in
Table
21.

Table
21:
Summary
of
amounts
of
methyl
bromide
quantities
requested
by
Florida
Tomato,
Strawberry,
Eggplant
and
Pepper.

2005
2006
2007
Crop
Acres
Amount
Acres
Amount
Acres
Amount
Tomato
52,460
7,344,400
52,460
7,029,640
52,460
7,029,640
Strawberry
7,100
1,278,000
7,100
1,278,000
7,100
1,278,000
Eggplant
1,600
214,400
1,600
214,400
1,600
214,400
Pepper
20,250
2,713,500
20,250
2,713,500
20,250
2,713,500
Attached
in
the
order
referenced
are
the
individual
completed
forms.
Completed
Application
Form
OMB
Control
Number
2060­
0482
Tomato
(
North
Florida)
Completed
Application
Form
OMB
Control
Number
2060­
0482
Tomato
(
Ruskin
Palmetto)
Completed
Application
Form
OMB
Control
Number
2060­
0482
Tomato
(
Southern
Florida
 
Palm
Beach)
Completed
Application
Form
OMB
Control
Number
2060­
0482
Tomato
(
Southern
Florida
 
Southwest)
Completed
Application
Form
OMB
Control
Number
2060­
0482
Tomato
(
Dade
County)
Completed
Application
Form
OMB
Control
Number
2060­
0482
Strawberry
Completed
Application
Form
OMB
Control
Number
2060­
0482
Pepper
Completed
Application
Form
OMB
Control
Number
2060­
0482
Eggplant
