Page
1
NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
JUNE
2005
QUESTIONS
ON
CUNS
FOR
2006
AND/
OR
2007
FOR
SOIL
APPLICATIONS
DATE
Version
of
August
18,
2005
Table
of
Contents
I.
General
questions:................................................................................................................................
1
II.
Cucurbits:...........................................................................................................................................
2
III.
Eggplants
..........................................................................................................................................
6
IV.
Forest
Nurseries:.............................................................................................................................
20
V.
Nursery
stock(
fruit
trees,
raspberries,
roses):
....................................................................................
27
VI.
Orchard
Replant:.............................................................................................................................
27
VII.
Peppers:.........................................................................................................................................
28
IX.
Tomatoes:.......................................................................................................................................
47
REFERENCES........................................................................................................................................
59
Appendix
I
Summary
of
Weyerhaeser
Company
Research
.......................................................................
61
Appendix
II
Economic
information
for
Michigan
Herbaceous
Perennials
.................................................
69
Appendix
III
Revised
BUNI
for
Fruit,
Nut
and
Flower
Nurseries.............................................................
77
Appendix
III
Revised
BUNI
for
Strawberry
nurseries
..............................................................................
78
I.
General
questions:

Question
1.
Has
the
registration
status
of
1,3­
D
and,
thus,
its
suitability
for
karst
geology
and/
or
karst
topography
areas
has
changed
recently,
and
if
so,
what
is
the
new
status?

ANSWER:
The
registration
status
of
1,3­
D
has
not
changed
in
regards
to
karst
geology
or
topography.
The
U.
S.
does
not
expect
a
further
change
in
the
registration
status
until
mid
2007
at
the
earliest.
Even
if
the
registration
status
of
1,3­
D
were
to
change
with
respect
to
whether
it
could
be
used
in
situations
of
karst
topography
rather
than
karst
geology
the
estimates
of
the
amount
of
methyl
bromide
needed
would
not
change.
In
making
the
assessment
of
critical
need,
therefore,
the
USG
analyzed
need
as
if
the
label
change
had
already
occurred
Question
2.
Are
there
regulations
which
prevent
the
use
of
low
barrier
permeability
films
in
any
States
other
than
California?

ANSWER:
The
U.
S.
is
not
aware
that
any
States
other
than
California
have
regulations
that
prevent
or
severely
restrict
the
use
of
low
permeability
barrier
films.
Page
2
Question
3.
What
mixtures
of
MB/
Pic
are
registered
in
the
different
States
covered
by
the
CUN
requests?
MBTOC
understands
that
a
full
range
of
mixtures
(
MB/
Pic
98:
2
to
2:
98)
can
be
applied
in
California,
but
in
other
States
may
be
restricted
by
the
premixed
formulations
of
MB/
Pic
available
in
those
States
(
e.
g.
67:
33,
50:
50,
33:
67).
Please
clarify.

ANSWER:
USG
is
not
aware
that
any
States
have
minimum
application
rate
requirements
for
methyl
bromide
or
specific
regulations
covering
the
ratio
of
methyl
bromide
to
chloropicrin
(
i.
e.
premixed
formulations)

II.
Cucurbits:

Question
4.
(
Michigan):
The
Party
states
that
1,3­
D/
chloropicrin
may
be
an
effective
alternative
but
growers
will
miss
the
optimal
market
window
due
to
longer
plant
back
times
with
this
alternative.
There
may
be
scope
for
avoiding
this
problem
through
treatments
in
autumn
preceding
the
crop.
Please
explain
whether
this
is
possible
or
not.

ANSWER:
The
proposal
by
MBTOC
to
obviate
the
use
of
methyl
bromide
in
Michigan
by
applying
some
alternative
(
specifically
a
combination
of
1,3­
D
and
chloropicrin)
in
the
autumn
preceding
crop
planting
will
not
work
on
cucurbits.
In
Michigan,
the
predominant
agricultural
treatment
that
uses
methyl
bromide
is
one
where
methyl
bromide
is
applied
in
strips
of
raised
beds.
Areas
between
the
raised
beds
are
not
treated.
In
addition
to
the
risk
that
the
harsh
winter
conditions
(
prolonged
periods
of
below
freezing
weather
with
snow,
sleet,
and
high
winds)
will
tear
the
plastic
barrier,
there
is
significant
risk
of
flooding
and
concomitant
recontamination
of
the
treated
areas.
The
length
and
severity
of
the
winter
means
4­
5
months
of
precipitation
is
`
stored'
in
frozen
form
and
released
over
the
short
period
of
thaw
in
the
spring.
This
thaw­
based
flooding
can
be
exacerbated
by
heavy
rainfalls
(
in
excess
of
25
mm)
that
occur
throughout
the
spring
and
summer
in
Michigan.
Because
Phytophthora
and
Verticillium
are
endemic
in
the
areas
of
Michigan
for
which
methyl
bromide
is
being
requested,
flooding
will
transfer
spores
from
the
untreated
to
treated
areas,
resulting
in
additional
infected
plants
and
severe
crop
losses.

There
are
two
additional
problems
which
prevent
a
fall
application
of
a
methyl
bromide
alternative
from
being
a
viable
alternative
to
the
current
practice.
Deer
walk
across
the
fields,
making
holes
in
the
plastic.
Mice
also
burrow
under
the
plastic.
Once
underneath
they
chew
the
drip
tapes,
rendering
them
inoperative
and
make
burrows
where
they
are
in
an
ideal
position
to
eat
the
newly
planted
material
in
the
spring.

Question
5.
(
Regions:
other
than
Michigan)
The
CUN
was
based
on
limited
trial
data.
MBTOC
requests
further
information
to
fully
assess
the
other
regions,
in
particular
the
relevance
of
recent
trial
results
in
SE
USA,
especially
those
using
low
permeability
barrier
films
such
as
Gilreath
et
a12005a,
and
those
which
show
new
data
for
alternatives
and
their
methods
of
application
new
application
methods
on
cucurbits
or
similar
crops
from
relevant
production
regions.
(
e.
g.
Gilreath
et
al
2005b,
c)
Page
3
ANSWER:
Several
members
of
MBTOC
and
the
USG
were
recently
able
to
tour
field
research
sites
in
Florida
and
Georgia
including
the
plots
of
Dr.
Gilreath.
During
those
discussions
and
in
his
recent
research
publications
(
Gilreath
et
al
2005;
Gilreath,
Santos,
Motis,
Noling
&
Mirusso
2005;
and
Gilreath
&
Gilreath
2005)
the
improved
pest
control
when
using
Virtually
Impermeable
Film
(
VIF)
or
metalized
films
(
using
an
aluminum
layer
such
as
Canslit)
was
described.
Dr.
Gilreath
and
other
researchers
were
contacted
on
the
topics
of
low
permeability
barrier
films,
and
newer
application
techniques.
Based
on
their
input
it
appears
that
VIF
films
have
still
not
been
widely
adopted
because
of
problems
in:
laying
the
films,
inelasticity
and
the
resultant
difficulty
in
conforming
to
the
bed
shape,
problems
with
linear
shear,
and
the
fact
that
embossed
films
are
not
available.
The
current
versions
of
metalized
films
are
being
widely
tested
by
several
researchers
and
growers
and
they
have
the
potential
to
reduce
fumigant
use
rates
with
better
laying
and
bedshape
conforming
characteristics.
It
is
anticipated
that
the
results
of
many
of
these
research
plots
and
growers
field
tests
will
be
available
next
year.
Use
of
metalized
films
present
several
questions
for
adoption,
such
as
the
fate
of
the
aluminum
coating
if
it
"
flakes
off"
on
the
soil
during
removal
and
the
photostability
of
the
coating
during
multiple
crop
cycles
as
is
common
in
the
southeastern
U.
S.
An
additional
concern
with
all
of
the
low
permeability
films
and
reduced
use
rates
is
poor
uniformity
of
treatment
unless
the
application
equipment
must
be
redesigned
to
accommodate
reduced
flow
rates
and
pressure
(
Gilreath
and
Gilreath
2005).
While
these
results
are
promising
there
are
only
a
few
researchers
that
have
multi­
year
trials
with
these
films
and
new
or
modified
application
equipment.
Many
growers
are
said
to
be
testing
the
new
films,
reduced
rates
of
methyl
bromide,
and
other
alternatives.
Without
multi­
year
trials
under
a
range
of
environmental
conditions
the
consistency,
feasibility,
and
adaptability
cannot
be
assessed.

When
evaluating
research
that
MBTOC
cites
(
Gilreath
et
al
2003)
the
untreated
control
at
the
Bradenton
site
had
53
nutsedge
(
Cyperus
rotundus)
plants
per
square
yard,
while
the
Immokalee
site
had
fewer
than
one
plant
per
square
yard.
The
current
standard
that
the
U.
S.
recommends
for
moderate
nutsedge
pressure
is
5
to
30
plants
per
square
yard.
At
the
Bradenton
site,
the
nutsedge
control
was
not
significantly
different
between
MeBr:
Pic
(
350
lb
per
acre)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb),
but
had
39%
more
nutsedge
plants
and
17%
yield
reduction.
When
comparing
the
same
treatments
at
Immokalee,
which
had
and
no
significant
difference
in
Fusarium,
or
nematodes
(
such
as
Meloidogyne
spp,
Belonolainus
spp.
and
Tylenchorhynchus
spp.),
but
low
nutsedge
pressure
(<
1
plant
per
square
yard),
there
was
still
a
12.5%
reduction
in
yield
compared
to
methyl
bromide.

Question
6.
MBTOC
also
seeks
use
rates
of
MB/
Pic
mixtures
with
lower
MB
than
currently
used
(
especially
30:
70,
50:
50)
for
control
of
the
key
pests
in
the
nomination
and
also
results
of
their
technical
efficacy.

ANSWER:
Communications
with
several
researchers
indicate
that
they
have
started,
or
are
about
to
initiate,
studies
to
look
at
long
term
performance
of
even
lower
rates
of
methyl
bromide
(
at
or
below
200
kg/
ha).
These
studies
will
encompass
a
wide
range
of
environmental
conditions,
pest
pressure,
soil
types,
etc.
and
help
to
demonstrate
consistency
of
control.
Page
4
One
of
the
studies
that
MBTOC
cites
is
from
Florida
(
Gilreath
et
al,
2005a),
which
looked
at
the
impact
of
reduced
rates
of
MB
on
pest
control
and
pepper
yield.
In
that
study,
which
had
high
Cyperus
spp.
pressure,
there
were
no
significant
differences
in
yield
between
any
of
the
rates
of
methyl
bromide
with
the
different
types
of
films.
However,
an
examination
of
the
change
in
yield
with
VIF
treatments,
compared
to
the
standard
MB
treatments,
suggests
significant
variability
within
treatments,
which
led
to
the
lack
of
statistical
significance
in
yield
despite
the
large
numerical
differences
in
yield
between
treatments.
Trials
such
as
those
conducted
by
Gilreath
et
al
(
2005a)
with
peppers,
need
to
be
conducted
over
several
seasons,
and
preferably
with
different
crops.
The
reality
of
the
use
of
VIF
for
the
2007
season
is
its
current
prohibitive
cost
in
the
U.
S.,
and
even
more
significant,
its
lack
of
availability
for
use
on
a
commercial
scale.
The
Party
does
not
anticipate
these
issues
can
be
adequately
resolved
before
the
critical
use
season
of
2007.

Table
1.
Pepper
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large.
Treatment
App
Rate
kg/
ha
Yield
t/
ha
%
Change
1
Untreated
9.5
­
31%
2
MeBr
+
Pic
LDPE
392
13.8
0%
3
MeBr
+
Pic
VIFP
196
10.8
­
22%
4
MeBr
+
Pic
VIFP
98
13.6
1%
5
MeBr
+
Pic
VIFV
196
11.4
­
17%
6
MeBr
+
Pic
VIFV
98
11.9
­
14%
Footnote:
From
Gilreath
et
al.
2005.
Crop
Protection
24:
285­
287.
LDPE
is
low
density
polyethylene,
VIFP
and
VIFV
are
virtually
impermeable
film
by
Plastopil
and
Vikase
respectively.

The
research
plots
that
MBTOC
visited
in
Florida
demonstrated
that
reliance
on
chloropicrin
will
not
be
sufficient
to
control
nutsedge.
Research
by
Gilreath
and
communications
with
him
indicate
that
chloropicrin
enhances
nutsedge
germination
(
this
research
has
yet
to
be
repeated
for
other
pest
species).
Therefore,
increasing
the
amount
of
chloropicrin
applied
can
increase
pest
pressure
and
yield
loss.

Question
7.
The
nomination
indicates
that
MB
is
often
not
applied
directly
before
cucurbits,
but
before
the
preceding
crop
as
part
of
a
double
cropping
process.
MBTOC
requests
further
clarification
on
how
the
proportion
of
the
total
crop
area
where
MB
is
used
immediately
prior
to
cucurbits
is
determined.

ANSWER:
Cucurbits
are
widely
grown
in
several
states
in
the
southeastern
and
midwestern
U.
S.
Florida
produces
the
largest
crop
of
cucurbits.
In
Florida,
cucurbits
are
grown
in
rotation
usually
with
a
solanaceous
crop,
such
as
tomatoes
or
peppers.
However,
none
of
the
U.
S.
nomination
is
for
cucurbits
grown
in
Florida.
In
some
states,
either
one
crop
per
fumigation
is
grown,
or,
cucurbits
Page
5
are
grown
in
rotation
with
another
cucurbit
crop.
In
evaluating
the
critical
need
for
methyl
bromide,
USG
has
removed
from
the
nomination
requests
in
states
where
cucurbits
are
grown
in
rotation
with
solanaceous
crops;
all
of
the
request
is
for
the
solanaceous
crop
with
the
cucurbit
crop
grown
as
a
`
follow
on'.
For
situations
where
the
cucurbit
is
grown
as
a
single
crop,
or
is
grown
in
rotation
with
the
same
or
a
different
cucurbit
crop,
USG
has
compared
the
requested
acreage
with
the
acreage
planted
in
cucurbits.
The
estimate
of
the
area
planted
in
cucurbits
is
derived
from
three
main
sources:
a
proprietary
source
that
tracks
pesticide
use
by
crop,
USDA's
National
Agricultural
Statistical
Service
(
NASS)
database,
and
specialized
state
sources.
These
state
sources
differ
from
state
to
state
 
in
California
the
main
source
is
a
database
maintained
by
the
California
Department
of
Pesticide
Regulation.
In
other
states,
such
as
Georgia,
the
University
of
Georgia
maintains
a
website
that
reports
on
pesticide
use
by
crop
and
county
for
all
of
the
agricultural
counties
in
Georgia.
When
sources
are
in
disagreement,
the
data
from
the
most
detailed
site
was
used.

The
area
reported
in
the
BUNI
as
being
in
cucurbit
cultivation
is
the
area
(
and
its
proportion
of
the
total
area)
that
is
used
only
for
cucurbit
cultivation
(
and
not
the
area
that
is
used
for
cucurbit
cultivation
in
rotation
with
a
non­
cucurbit
crop).
For
the
most
recent
(
2007)
request,
3%
of
the
Michigan
cucurbit
acreage,
34%
of
the
southeastern
cucurbit
acreage,
and
11%
of
the
Georgia
cucurbit
acreage
are
included
in
the
nomination.

Question
8.
In
SE
and
Georgia,
the
key
pest
is
nutsedge.
The
Party
states
that
potential
alternatives,
1,3­
D/
Pic
combinations
and
metham
sodium,
result
in
yield
loss
estimates
of
29%.
Estimates
of
yield
differences
are
a
determining
factor
in
the
relative
economics
of
MB
and
the
next
best
alternative.
The
Party
refers
to
an
old
study
on
tomato
production
for
yield
data
(
Locascio
1997)
and
further
information
is
requested
to
support
the
yield
loss
estimates
relative
to
MB
resulting
from
1,3­
D/
chloropicrin
combinations
and
metham
sodium,
with
or
without
Pic,
and
other
combinations
such
as
1,3­
D
+
trifluralin
4­
chloropicrin
+
napropamide.

ANSWER:
The
article
cited
by
MBTOC
(
Gilreath
et
al,
2003)
examined
methyl
bromide
plus
chloropicrin
(
350
lb
per
acre
of
67:
33)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
for
pepper
yield.
While
the
yields
were
not
statistically
different,
numerically
there
was
a
13
to
14%
yield
loss,
compared
to
methyl
bromide
plus
chloropicrin.
The
large
yield
loss
differences
suggest
a
large
variability
in
the
trials,
which
may
be
caused
by
inconsistent
results
of
treatments.
Therefore,
based
on
MBTOC
references
there
could
be
a
13
to
14%
yield
loss
when
comparing
methyl
bromide
plus
chloropicrin
compared
to
this
alternative.
However,
the
USG
had
suggested
a
yield
loss
of
6.2
%
in
the
BUNI.
Importantly,
the
alternative
treatment,
which
includes
treatments
with
other
chemicals,
will
require
additional
time
for
pesticide
application
and
sufficient
time
to
off­
gas
an
additional
chloropicrin
treatment
to
prevent
damage
to
transplants.
This
additional
time
delay
could
lead
to
impacts
in
terms
of
the
key
market
windows,
resulting
in
an
economic
loss
over
and
above
the
yield
losses.
Techniques
to
remedy
these
problems
are
being
studied,
but
will
not
be
finalized
in
time
for
the
2007
season,
for
which
MB
is
being
requested
by
this
nomination.
This
inconsistency
in
yield
and
additional
soil
treatment
time
argues
for
the
economic
infeasibility
of
this
type
of
alternative
until
new
methodology
can
alleviate
these
problems.
Page
6
Table
2.
Tomato
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large
Bradenton
Immokalee
Treatment
Marketable
Yield
(
pound
per
10
plants)
%
Yield
Change
versus
MeBr
Marketable
Yield
(
pound
per
10
plants)
%
Yield
Change
versus
MeBr
Untreated
51
­
56%
108
­
16%
Methyl
bromide:
chloropicrin
(
350
lb
of
67:
33)
117
0%
128
0%

1,3­
D­
35%
Pic
+
trifluralin
+
napropamide
+
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
101
­
14%
112
­
13%

Footnote:
From
Gilreath
et
al.
2003.
Proc.
Fla.
State
Hort.
Soc.

Question
9.
Recent
references
available
to
MBTOC
demonstrate
effective
alternatives
(
metham
sodium,
with
and
without
Pic)
for
moderate
to
heavy
nutgrass
control
and
further
clarification
is
required
on
their
suitability
to
karst
and
non
karst
areas
(
Johnson
and
Webster,
2001;
Gilreath
et
a1
2005
b,
c).
Yields
were
similar
to
methyl
bromide;
however
there
was
no
data
presented
on
plantback
effects
for
cucurbits.
Please
provide
clarification
of
yield
loss
and
relevance
of
new
studies
to
the
nomination.

ANSWER:
Areas
in
the
southeastern
U.
S
experience
frequent
and
heavy
rainfalls,
which
may
cause
reduce
efficacy
of
some
pest
control
alternatives.
In
western
North
Carolina,
in
2005,
rain
fell
for
41
of
the
61
days
of
June
and
July.
Under
these
conditions
1,3
D/
Pic
combinations
did
not
show
effective
control
in
fields
where
heavy
nutsedge
pressure
was
present.
Combination
treatments,
including
trifluralin,
have
shown
stunting
in
tomato
during
such
years
of
above
average
rainfall.

With
regard
to
cucurbits,
metham
sodium
with
pic
followed
by
use
of
halosulfuron
(
Sandea)
will
need
to
be
evaluated
in
2006,
as
it
appears
to
researchers
in
the
southeastern
U.
S.
(
personal
communication
North
Carolina
State
University),
that
it
holds
probably
the
greatest
potential
for
nutsedge
control
in
tomato
and
cucurbits.
Limited
or
no
data
is
available
on
nutsedge
control
with
this
complete
program.
However,
because
there
are
lengthy
plant
back
restrictions
on
common
rotational
crops
(
up
to
36
months)
the
design
of
a
crop
rotation
program
will
be
very
difficult
and
could
restrict
the
planting
of
profitable
crops.

III.
Eggplants
Question
10.
(
Michigan):
In
Michigan,
the
key
pests
are
Phytophthora
capsici
and
Verticillium.
The
Party
states
that
1,3­
D/
chloropicrin
may
be
an
effective
alternative,
but
growers
will
miss
the
optimal
market
window
due
to
delayed
plantback
times.
There
may
be
scope
for
avoiding
this
problem
through
treatments
in
autumn
preceding
the
crop.
Please
explain
whether
this
is
possible
or
not.

ANSWER:
Page
7
The
proposal
by
MBTOC
to
obviate
the
use
of
methyl
bromide
in
Michigan
by
applying
some
alternative
(
such
as
a
combination
of
1,3­
D
and
chloropicrin)
in
the
autumn
preceding
crop
planting
will
not
work
on
eggplant.
In
Michigan,
the
predominant
agricultural
treatment
that
uses
methyl
bromide
is
one
where
methyl
bromide
is
applied
in
strips
of
raised
beds.
Areas
between
the
raised
beds
are
not
treated.
In
addition
to
the
risk
that
the
harsh
winter
conditions
(
prolonged
periods
of
below
freezing
weather
with
snow,
sleet,
and
high
winds)
will
tear
the
plastic
barrier,
there
is
significant
risk
of
flooding
and
concomitant
recontamination
of
the
treated
areas.
The
length
and
severity
of
the
winter
means
4­
5
months
of
precipitation
is
`
stored'
in
frozen
form
and
released
over
the
short
period
of
thaw
in
the
spring.
This
thaw­
based
flooding
can
be
exacerbated
by
heavy
rainfalls
(
in
excess
of
25
mm)
that
occur
throughout
the
spring
and
summer
in
Michigan.
Because
Phytophthora
and
Verticillium
diseases
are
endemic
in
the
areas
of
Michigan
for
which
methyl
bromide
is
being
requested,
flooding
will
transfer
spores
from
the
untreated
to
treated
areas,
resulting
in
additional
infected
plants
and
severe
crop
losses.

There
are
two
additional
problems
which
prevent
a
fall
application
of
a
methyl
bromide
alternative
from
being
a
viable
alternative
to
the
current
practice.
Deer
walk
across
the
fields,
making
holes
in
the
plastic.
Mice
also
burrow
under
the
plastic.
Once
underneath
they
chew
the
drip
tapes,
rendering
them
inoperative
and
make
burrows
where
they
are
in
an
ideal
position
to
eat
the
newly
planted
material
in
the
spring.

Question
11.
(
Regions
other
than
Michigan):
The
CUN
was
based
on
limited
trial
data,
and
MBTOC
requires
further
information
to
assess
the
other
regions,
in
particular
the
relevance
of
recent
trial
results
in
SE
USA
especially
those
using
low
permeability
barrier
films
(
Gilreath
et
a12005a)
and
new
application
methods
for
alternatives
(
on
cucurbits
or
similar
crops
from
relevant
production
regions).

ANSWER:
Several
members
of
MBTOC
and
the
USG
were
recently
able
to
tour
field
research
sites
in
Florida
and
Georgia,
including
the
research
plots
of
Dr.
Gilreath.
During
discussions
with
Dr.
Gilreath,
and
in
his
recent
research
publications
(
Gilreath
et
al
2005,
Gilreath
et
al
in
press,
and
Gilreath
&
Gilreath
2005)
improved
pest
control
with
virtually
impermeable
film
(
VIF)
or
metalized
films
(
using
an
aluminum
layer
such
as
Canslit)
was
described.
The
Party
contacted
Dr.
Gilreath
and
other
researchers
concerning
low­
permeability
barrier
films,
and
newer
application
techniques.
Based
on
their
assessment
it
appears
that
VIF
have
still
not
been
widely
adopted
because
of
problems
in:
laying
the
films,
inelasticity
and
the
resultant
difficulty
in
conforming
to
the
bed
shape,
problems
with
linear
shear,
and
the
fact
that
embossed
films
are
not
available.
The
current
versions
of
metalized
films
are
being
widely
tested
by
several
researchers
and
growers
and
they
have
the
potential
to
reduce
fumigant
use
rates
with
better
laying
and
bedshape
conforming
characteristics.
It
is
anticipated
that
the
results
of
many
of
these
research
plots
and
growers
field
tests
will
be
available
next
year.
These
metalized
films
pose
several
questions
for
adoption:
the
fate
of
the
aluminum
coating
if
it
"
flakes
off"
on
the
soil
during
removal
and
the
photostability
of
the
coating
during
multiple
crop
cycles
as
is
common
in
the
southeastern
U.
S.
These
older
soils
are
already
high
in
aluminum
and
the
impact
of
additional
amounts
and
potential
phytotoxicity
will
have
to
be
tested.
An
additional
concern
with
low­
permeability
films
and
reduced
use
rates
is
poor
uniformity
of
treatment,
unless
the
application
equipment
must
be
redesigned
to
accommodate
reduced
flow
rates
Page
8
and
pressure
(
Gilreath
and
Gilreath
2005).
While
these
results
are
promising
there
are
only
a
few
researchers
that
have
multi­
year
trials
with
these
films
and
new
or
modified
application
equipment.
Many
growers
are
said
to
be
testing
the
new
films,
reduced
rates
of
methyl
bromide,
and
other
alternatives.
Without
multi­
year
trials
under
a
range
of
environmental
conditions
the
consistency,
feasibility,
and
adaptability
cannot
be
assessed.

When
evaluating
research
cited
by
MBTOC
(
Gilreath
et
al,
2003)
the
untreated
control
at
the
Bradenton
site
had
53
nutsedge
(
Cyperus
rotundus)
plants
per
square
yard,
while
the
Immokalee
site
had
fewer
than
one
plant
per
square
yard.
The
current
standard
that
the
US
recommends
for
moderate
nutsedge
pressure
is
5
to
30
plants
per
square
yard.
At
the
Bradenton
site
the
nutsedge
control
was
not
significantly
different
between
MeBr:
Pic
(
350
lb
per
acre)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
but
had
39%
more
nutsedge
plants
and
a
17%
reduction
in
yield.
When
comparing
the
same
treatments
at
Immokalee,
which
had
and
no
significant
difference
in
Fusarium,
or
nematodes
(
such
as
Meloidogyne
spp,
Belonolainus
spp.
and
Tylenchorhynchus
spp.),
but
low
nutsedge
pressure
(<
1
plant
per
square
yard),
there
was
still
a
12.5%
reduction
in
yield
compared
to
methyl
bromide.

Researchers
in
Georgia
have
also
been
conducting
research
on
methyl
bromide
alternatives
for
eggplant
production
(
Culpepper,
Webster,
Langston
2005)
and
the
interaction
of
VIF
and
LDPE
films.
Their
research
presented
in
the
following
ten
Tables
shows
promising
results
from
VIF
mulch
versus
LDPE
but
some
early
trends
are
apparent.
The
time
of
transplanting
after
fumigation
may
have
to
be
increased
(
18
days
versus
29
days)
with
different
films,
nutsedge
control
with
Telone
C35
followed
by
chloropicrin
(
35
gal
followed
by
150
lbs)
was
not
as
effective
as
methyl
bromide:
chloropicrin
(
67:
33
at
400
lbs,
),
nutsedge
control
was
not
always
enhanced
with
VIF
versus
LDPE
(
unfortunately
nutsedge
can
readily
emerge
through
either
mulch),
delaying
planting
at
this
site
may
have
led
to
a
yield
reduction
(
5
to
9
lbs.
per
22
feet
of
bed)
with
any
of
the
treatments,
eggplant
yield
(
first
three
harvests
pooled
in
pounds
per
plot)
was
somewhat
higher
with
LDPE
versus
VIF
(
but
not
significantly
different).

Table
3.
Eggplant
injury
from
various
fumigant­
mulch
combinations
at
64
days
after
fumigating
in
spring
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
0
0
0
0
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
0
11
0
0
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
0
2
0
0
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
2
16^
0
3
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
0
53^
0
30^
Page
9
Telone
II
fb
Vapam
12
G
fb
75
G
21^
100^
0
13^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
58^
90^
0
32^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
17^
98^
0
2
*
All
means
can
be
compared
using
an
LSD
=
12.
Fumigants
were
applied
on
February
16,
2005.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
4.
Nutsedge
response
to
various
fumigant­
mulch
combinations
at
90
days
after
fumigating
in
spring
2005.*
Percent
visual
control
Number
of
nutsedge
plants
emerging
through
the
mulch
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
0^
0^
154^
183^
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
40^
90
158^
38
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
93
86
17
34
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
88
88
28
48
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
70^
82^
87^
66^

Telone
II
fb
Vapam
12
G
fb
75
G
58^
67^
67^
111^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
82^
68^
65^
89^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
80^
65^
70^
117^
Page
10
*
Means
within
control
estimated
visually
can
be
compared
using
an
LSD
=
11
while
means
within
number
of
nutsedge
plants
penetrating
through
the
plastic
can
be
compared
using
an
LSD
=
29.
Data
for
each
variable
pooled
over
planting
dates.
Fumigants
were
applied
on
February
16,
2005.
Nutsedge
counts
taken
on
the
entire
22
foot
plot.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
within
each
variable.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
5.
Eggplant
heights
affected
by
various
fumigant­
mulch
combinations
60
days
after
fumigating
in
spring
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
14.4
12.8
11.8
10.8
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
12.6
9.3^
12.5
10.7
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
14
13.7
14.2
13.0
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
17.8^
9.8^
12.4
12.0
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
14.1
5.5^
14.1
9.9^

Telone
II
fb
Vapam
12
G
fb
75
G
9.6^
0.0^
12.5
11.3
Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
6.7^
1.0^
13.8
9.0^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
11.2
0.0^
12.4
12.0
*
All
means
can
be
compared
using
an
LSD
=
3.5.
Fumigants
were
applied
on
February
16,
2005.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
6.
Eggplant
heights
affected
by
various
fumigant­
mulch
combinations
90
days
after
fumigating
in
Page
11
spring
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
51.5
50.8
45.7
47.7
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
57.6
53.2
60.1
58.4
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
58.8
62.0
64.7
66.4
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
57.8
55.7
61.1
63.3
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
61.6
38.0^
59.2
46.9
Telone
II
fb
Vapam
12
G
fb
75
G
49.8
0^
62.5
55.2
Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
45.1
3.6^
55.3
50.8
Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
48.6
0.3^
58.1
59
*
All
means
can
be
compared
using
an
LSD
=
14.4.
Fumigants
were
applied
on
February
16,
2005.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
7.
Number
of
eggplant
harvested
during
the
first
harvest
date
comparing
fumigant­
mulch
treatments
in
spring
of
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
31
30
20
22
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
31
34
22
19
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
30
33
15^
12^

Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
34
31
14^
15^
Page
12
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
26
17^
20
17^

Telone
II
fb
Vapam
12
G
fb
75
G
29
0^
15^
14^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
30
2^
17^
15^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
30
1^
15^
16^

*
All
means
can
be
compared
using
an
LSD
=
13.
Fumigants
were
applied
on
February
16,
2005.
Harvest
one
was
made
on
May
17,
2005.
The
entire
plot
of
22
feet
was
harvested.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
8.
Weight
of
eggplant
fruit
(
lbs)
harvested
during
the
first
harvest
date
comparing
fumigant­
mulch
treatments
in
spring
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
40
44
35
35
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
40
48
33
27
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
40
44
20^
17^

Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
43
43
18^
23^

Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
34
25^
30
24^

Telone
II
fb
Vapam
12
G
fb
75
G
39
0^
21^
14^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
41
3^
23^
21^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
41
2^
21^
24^
Page
13
*
All
means
can
be
compared
using
an
LSD
=
11.
Fumigants
were
applied
on
February
16,
2005.
Harvest
one
was
made
on
May
17,
2005.
The
entire
plot
of
22
feet
was
harvested.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
9.
Number
of
eggplant
harvested
pooled
over
the
first
three
harvests
comparing
fumigant­
mulch
treatments
in
spring
of
2005.*
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
68
78
64^
65^
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
78
79
73
62^

Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
89
77
70
63
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
85
83
62^
61^

Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
72
50^
74
73
Telone
II
fb
Vapam
12
G
fb
75
G
73
0^
70
53^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
78
7^
64^
54^

Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
80
3^
58^
69
*
All
means
can
be
compared
using
an
LSD
=
22.
Fumigants
were
applied
on
February
16,
2005.
The
entire
plot
of
22
feet
was
harvested
three
times.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
10.
Weight
of
eggplant
fruit
(
lbs)
harvested
pooled
over
the
first
three
harvests
comparing
fumigantmulch
treatments
in
spring
2005.*
Page
14
Plant
date
1
(
Planted
18
days
after
fumigating)
Plant
date
2
(
Planted
29
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
None
0
90
109
96
98
DMDS
+
Chloropicrin
(
87.5:
12.5)
700
lbs
102
111
105
84
Methyl
Bromide
+
Chloropicrin
(
67:
33)
400
lbs
119
104
95
82
Methyl
Iodide
+
Chloropicrin
(
50:
50)
400
lbs
106
117
83
86
Telone
C35
fb
Chloropicrin
35
G
fb
150
lbs
96
75
114
106
Telone
II
fb
Vapam
12
G
fb
75
G
105
49^
97
69
Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
75
G
fb
150
lbs
108
11^
88
75
Telone
II
fb
Vapam
fb
Chloropicrin
12
G
fb
50
G
fb
100
lbs
109
5^
81
99
*
All
means
can
be
compared
using
an
LSD
=
41.
Fumigants
were
applied
on
February
16,
2005.
The
entire
plot
of
22
feet
was
harvested
three
times.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
bed.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
Vapam
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.
Page
15
Question
12.
MBTOC
also
seeks
the
current
registration
status
and
use
rates
of
MB:
Pic
mixtures
with
lower
MB
than
currently
used
(
especially
30:
70,
50:
50)
for
control
of
the
key
pests
in
the
nomination
and
also
results
of
their
technical
efficacy.

ANSWER:
For
preplant
soil
use
the
U.
S.
EPA
has
not
made
any
recent
label
changes
to
the
methyl
bromide
or
chloropicrin
labels.
The
U.
S.
label
does
not
have
any
minimum
application
rate
requirements
for
methyl
bromide
or
specific
regulations
covering
the
ratio
of
methyl
bromide
to
chloropicrin.
The
U.
S.
is
not
aware
of
any
states
with
minimum
application
rate
requirements
for
methyl
bromide
or
specific
regulations
covering
the
ratio
of
methyl
bromide.

In
past
years
the
majority
of
preplant
fumigant
alternatives
research
on
small
fruits
and
vegetables
has
been
directed
at
strawberry,
tomato,
and
pepper
crops.
Based
on
questions
from
MBTOC
the
vegetable
focus
has
moved
towards
eggplant
and
cucurbits.
Based
on
this
reprioritization
we
hope
that
MBTOC
will
understand
that
the
numbers
and
extent
of
research
studies
on
tomato
and
pepper
problems
will
be
constrained
in
future
years.
While
the
new
research
is
being
conducted
the
actual
data
is
not
yet
available.
Two
studies
on
cucurbits
are
presented
below
to
provide
examples
of
the
types
of
work
that
are
ongoing.

Research
in
Georgia
by
Grey,
Culpepper,
and
Webster
(
2003)
looked
at
the
suitability
of
herbicides
applied
under
plastic
for
weed
control.
In
their
research
they
looked
at
halosulfuron,
metolachlor
and
sulfentrazone
applied
in
the
spring,
under
plastic.
That
work
suggested
that
several
of
the
vegetable
crops
such
as
eggplant,
cucumber,
transplanted
and
seeded
squash
were
initially
injured.
However,
by
the
end
of
the
study
only
squash,
cucumber,
and
potentially
eggplant
and
cabbage
were
potentially
intolerant
of
these
selective
herbicides.
Due
to
differences
in
soil
types
and
water
permeability
this
toxicity
may
be
higher
in
Florida.

Table
11.
Vegetable
injury
from
halosulfuron,
metolachlor
and
sulfentrazone.
Treatments
Rate
(
kg
ai/
ha)
%
Crop
Injury
Halosulfuron
Metolachlor
Metolachlor
+
Halosulfuron
Sulfentrazone
0.027
1.12
1.12
+
0.027
0.28
8
to
16%
for
eggplant,
cucumber,
transplanted
and
seeded
squash
<
4%
for
cabbage
Footnote.
From
Grey,
Culpepper,
and
Webster
2003.
Page
16
Table
12.
Vegetable
tolerance
halosulfuron,
metolachlor
and
sulfentrazone.
Treatments
Rate
(
kg
ai/
ha)
Crop
Tolerance
(
Measured
by
Yield)
Crop
Intolerant
(
Measured
by
Yield)
Halosulfuron
0.027
Cabbage,
eggplant,
squash
and
cucumber
tolerant
Not
described
Metolachlor
1.12
Cabbage
and
eggplant
Squash
and
cucumber
Metolachlor
+
Halosulfuron
1.12
+
0.027
Not
described
Not
described
Sulfentrazone
0.28
Eggplant
and
cabbage
warrant
further
investigation
but
caused
injury
Squash
and
cucumber
Footnote.
From
Grey
et
al
2003.

Research
in
Georgia
by
W.
C.
Johnson
(
2003)
looked
at
metham­
sodium
for
yellow
nutsedge
(
Cyperus
esculentus)
control
in
cantaloupe.
In
2001
and
2002,
in
Georgia,
this
research
examined
full
rate
and
half
rate
applications
of
metham­
sodium
versus
untreated
plots
applied
1,
2,
or
3
weeks
before
transplanting.
In
this
study
metham­
sodium
applied
with
a
power
tiller
at
the
full
rate
(
see
Johnson
and
Webster,
2001)
2
weeks
before
transplanting
provided
the
best
nutsedge
control
(
data
not
presented)
combined
with
least
injury
to
the
transplants.
The
half
rate
application
or
treatments
applied
1
or
3
weeks
before
transplanting
were
not
as
effective.
This
suggests
that
timing
of
application
and
method
of
application
are
as
important
as
use
rate
for
providing
effective
control
of
nutsedge
without
damage
to
the
transplants.

Question
13.
The
nomination
indicates
that
MB
is
often
not
applied
directly
before
eggplant,
but
before
the
preceding
crop.
MBTOC
requests
further
clarification
on
how
the
proportion
of
the
total
crop
area
where
MB
is
used
immediately
prior
to
eggplants
is
determined.

ANSWER:
Eggplant
is
a
very
minor
crop
in
the
U.
S.,
accounting
for
fewer
than
2850
hectares
on
a
national
basis.
It
is
grown
in
about
a
dozen
states,
including
Florida,
Georgia
and
Michigan
(
areas
that
have
a
critical
need
for
methyl
bromide)
and
New
Jersey,
Massachusetts
and
others,
where
alternatives
are
used.
In
evaluating
the
critical
need
for
methyl
bromide
USG
has
removed
from
the
nomination
all
requests
in
states
where
eggplants
are
grown
in
rotation
with
another
crop
within
one
year.
For
situations
where
eggplant
is
grown
as
a
single
crop,
or
is
grown
in
rotation
with
eggplant
(
doublecropped
USG
has
compared
the
requested
area
with
the
area
planted
in
eggplant.
The
estimate
of
the
area
planted
in
eggplant
is
derived
from
three
main
sources:
a
proprietary
source
that
tracks
pesticide
use
by
crop,
USDA's
National
Agricultural
Statistical
Service
database
(
NASS),
and
specialized
state
sources.
These
state
sources
differ
from
state
to
state
 
in
California
the
main
source
is
a
database
maintained
by
the
California
Department
of
Pesticide
Regulation.
In
other
states,
such
as
Georgia,
the
University
of
Georgia
maintains
a
website
that
reports
on
crop
acres
by
county
for
all
of
the
agricultural
counties
in
Georgia.
When
sources
are
in
disagreement,
the
data
from
the
most
detailed
site
was
used.

The
area
reported
in
the
BUNI
as
being
cultivated
with
eggplant
is
the
area
(
and
its
proportion
of
the
total
area)
that
is
only
used
for
eggplant
cultivation,
and
not
the
area
that
is
used
for
eggplant
cultivation
in
rotation
with
a
non­
eggplant
crop
within
one
year.
For
the
most
recent
(
2007)
Page
17
request,
60%
of
the
Georgia
eggplant
cultivation,
and
100%
of
the
Florida
eggplant
cultivation
are
included
in
the
nomination.
USG
was
not
able
to
determine
the
proportion
of
the
Michigan
eggplant
that
is
contained
in
the
nomination,
but
as
33
hectares
were
requested
for
Michigan
eggplant,
USG
is
confident
that
at
least
this
number
of
hectares
is
in
eggplant
production
and
not
rotated
with
non­
eggplant
crops.

Question
14.
In
Georgia
and
Florida,
nematodes,
soil
borne
fungi
and
nutsedge
are
the
key
pests.
The
Party
states
that
1,3­
D
+
chloropicrin
+
trifluralin
+
napropamide
is
an
effective
alternative
in
Florida
except
in
areas
of
karst
topography
which
comprise
40%
of
the
growing
acreage.
1,3­
D/
chloropicrin
is
effective
against
nematodes,
but
not
nutsedge.
Although
not
controlling
nutsedge
as
well
as
MB,
this
combination
provided
equivalent
yields
in
spring
and
fall
crops
in
Tifton
GA
(
Culpepper
and
Langston,
2004).
Party
is
requested
to
clarify
why
this
information
is
not
relevant
to
the
nomination.

ANSWER:
MBTOC
has
cited
the
U.
S.
nomination
package
that
states
that
1,3­
D
is
not
suitable
under
conditions
of
karst
topography
then
cites
the
1,3­
D
research
of
Culpepper
Langston
(
2004)
and
asks
about
its
relevance
to
the
nomination.
That
research
is
described
below.
In
cases
where
an
alternative
cannot
be
used
due
to
a
regulatory
restriction,
the
U.
S.
has
not
described
that
research
because
MBTOC
has
clearly
stated
that
they
do
not
want
information
on
chemicals
that
are
not
registered
for
those
sites.
If
the
description
below
does
not
adequately
answer
the
question
please
contact
the
U.
S.
for
additional
information.

The
research
of
Culpepper
and
Langston
(
2004)
looked
at
yellow
and
purple
nutsedge
control
and
pepper
yield
for
methyl
bromide
versus
combinations
of
Telone
(
1,3­
dichloropropene)
alone,
with
chloropicrin
or
K­
Pam
(
metam
potassium)
versus
Midas
(
iodomethane).
The
research
results
are
shown
in
Table
5
and
6
below.
In
this
study
there
was
no
statistically
significant
yield
loss
when
comparing
methyl
bromide
(
400
lb
of
67:
33)
to
Telone
II
(
12
gal/
acre)
followed
by
chloropicrin
(
150
lb
per
acre),
but
numerically,
a
7%
yield
loss
was
demonstrated.
However,
in
the
alternative
treatment,
nutsedge
control
was
significantly
reduced
compared
to
methyl
bromide.
Therefore,
in
subsequent
crop
cycles
the
weed
pressure
would
likely
be
even
greater.

Fumigant
treatment
options,
rates,
and
application
methods
were
as
follows
(
Culpepper
and
Langston,
2004):
1.
Methyl
Bromide
67:
33
(
400
lb/
A
broadcast)
injected
6­
8"
in
the
bed
with
a
Super­
Bedder
plastic
layer.
2.
Telone
II
(
12
gal/
A
broadcast)
injected
10­
12
inches
deep
with
a
Yetter
rig
followed
with
Chloropicrin
(
150
lb/
A
broadcast)
injected
6­
8
inches
in
the
bed
with
a
Super­
Bedder
plastic
layer.
3.
Telone
C35
(
35
gal/
A
broadcast)
injected
10­
12
inches
deep
with
a
Yetter
rig
followed
with
Chloropicrin
(
150
lb/
A
broadcast)
injected
6­
8
inches
in
the
bed
with
a
Super­
Bedder
plastic
layer.

4.
Telone
II
(
12
gal/
A
broadcast)
injected
10­
12
inches
deep
with
a
Yetter
rig
followed
with
K­
Pam
(
46
gal/
A
broadcast)
incorporated
3­
4
inches
deep
with
a
tilrovator
and
followed
with
a
Super­
Bedder
plastic
layer.
5.
MIDAS
98:
2
(
175
lb/
A
broadcast)
injected
6­
8"
in
the
bed
with
a
Super­
Bedder
plastic
layer.
6.
Inline
(
35
gal/
treated
acre)
injected
through
two
lines
of
drip
tape
the
day
following
laying
plastic.
7.
No
fumigant
under
plastic.
Page
18
Table
13.
Methyl
Bromide
Alternatives
Impact
on
Yellow
and
Purple
Nutsedge
Control.
TyTy,
Georgia.
Fall,
2003.
Percent
Late
Season
Control
Fumigant
Option
Yellow
Nutsedge
Purple
Nutsedge
Methyl
Bromide
92
a
80
a
Telone
II
plus
K­
Pam
79
a
50
c
Telone
II
plus
Chloropicrin
52
b
31
d
Telone
C35
plus
Chloropicrin
92
a
65
b
Midas
87
a
49
c
Inline
50
b
16
e
No
Fumigant
36
c
12
e
Fumigant
main
effects
were
significant.
Values
within
a
column
followed
by
the
same
letter
are
not
significantly
different
at
P
=
0.05.

Table
14.
Methyl
Bromide
Alternatives
Impact
on
the
Number
of
28
lb.
boxes
of
peppers
harvested
per
acre.
TyTy,
Georgia.
Fall,
2003.

Fumigant
Option
Percent
Loss
in
boxes
per
acre
compared
to
Methyl
Bromide
Methyl
Bromide
0
Telone
II
plus
K­
Pam
7
Telone
II
plus
Chloropicrin
17*
Telone
C35
plus
Chloropicrin
22*
Midas
16*
Inline
36*
No
Fumigant
48*
Values
are
pooled
over
two
herbicide
options
as
fumigant
main
effects
were
significant.
*
Denotes
a
statistical
loss
in
yield
compared
to
Methyl
Bromide
at
P
=
0.05.

Question
15.
An
effective
strategy
for
controlling
nematodes,
pathogens
and
nutsedge
has
been
demonstrated
in
Florida
as
described
above.
Also,
recent
references
available
to
MBTOC
demonstrate
effective
alternatives
(
metham
sodium,
with
and
without
Pic)
for
moderate
to
heavy
nutgrass
control
in
similar
regions
for
non­
karst
and
karst
areas
(
Johnson
and
Webster,
2001;
Gilreath
et
al,
2005
b,
c).
Yields
were
similar
to
methyl
bromide,
however
there
was
no
data
presented
on
plantback
effects
for
eggplants.
It
is
not
clear
why
this
combination
cannot
be
used
in
92%
of
Georgia
nomination
where
karst
topography
is
not
a
concern.
Please
clarify
ANSWER:

Communications
with
several
researchers
indicate
that
they
have
started,
or
are
about
to
initiate,
studies
to
look
at
long­
term
performance
of
alternatives
for
eggplant.
These
studies
will
encompass
a
wide
range
of
environmental
conditions,
pest
pressure,
soil
types,
etc.
and
help
to
demonstrate
consistency
of
control.
However,
to
date
the
U.
S.
has
still
not
seen
consistent
control
for
multiple
years
for
these
alternatives
(
see
summaries
below).
Page
19
One
of
the
studies
that
MBTOC
cites
is
from
Florida
(
Gilreath
et
al,
2005a),
which
looked
at
the
impact
of
reduced
rates
of
MB
on
pest
control
and
pepper
yield.
In
that
study,
which
had
high
Cyperus
spp.
pressure,
there
were
no
significant
differences
in
yield
between
any
of
the
rates
of
methyl
bromide
with
the
different
types
of
films.
However,
an
examination
of
the
change
in
yield
with
VIF
treatments,
compared
to
the
standard
MB
treatments,
suggests
significant
variability
within
treatments,
which
led
to
the
lack
of
statistical
significance
in
yield
despite
the
large
numerical
differences
in
yield
between
treatments.
Trials
such
as
those
conducted
by
Gilreath
et
al
(
2005a)
with
peppers,
need
to
be
conducted
over
several
seasons,
and
preferably
with
different
crops.
The
reality
of
the
use
of
VIF
for
the
2007
season
is
its
current
prohibitive
cost
in
the
U.
S.,
and
even
more
significant,
its
lack
of
availability
for
use
on
a
commercial
scale.
The
Party
does
not
anticipate
these
issues
can
be
adequately
resolved
before
the
critical
use
season
of
2007.

Table
15.
Pepper
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large.
Treatment
App
Rate
kg/
ha
Yield
t/
ha
%
Change
1
Untreated
9.5
­
31%
2
MeBr
+
Pic
LDPE
392
13.8
0%
3
MeBr
+
Pic
VIFP
196
10.8
­
22%
4
MeBr
+
Pic
VIFP
98
13.6
1%
5
MeBr
+
Pic
VIFV
196
11.4
­
17%
6
MeBr
+
Pic
VIFV
98
11.9
­
14%
Footnote:
From
Gilreath
et
al.
2005.
Crop
Protection
24:
285­
287.
LDPE
is
low
density
polyethylene,
VIFP
and
VIFV
are
virtually
impermeable
film
by
Plastopil
and
Vikase
respectively.

The
research
plots
that
MBTOC
visited
in
Florida
clearly
demonstrated
that
chloropicrin
will
not
control
weeds
such
as
Cyperus
esculentus
or
C.
rotundus
.
Research
by
Gilreath
and
communications
with
him
indicate
that
chloropicrin
enhances
nutsedge
germination
(
this
research
has
yet
to
be
repeated
for
other
pest
species).
Therefore,
increasing
the
amount
of
chloropicrin
applied
can
increase
pest
pressure
and
yield
loss.

Another
study
by
Gilreath,
Santos,
Motis,
Noling
and
Mirusso
(
2005)
looked
at
nematode
and
Cyperus
control
in
bell
pepper
(
Capsicum
annum).
In
that
study
the
authors
stated
"
For
bell
pepper
yield,
the
application
of
metam
sodium
and
metam
sodium
+
chloropicrin
provided
similar
fruit
weight
as
for
methyl
bromide
+
chloropicrin
in
two
of
the
three
seasons."
However,
in
that
year
(
Fall,
2002)
the
yields
went
from
18.8
t/
ha
for
methyl
bromide
+
chloropicrin
to
13.7
t/
ha
for
metam
sodium
+
chloropicrin,
or
a
27%
drop
in
yield.
This
level
of
yield
loss
could
have
severe
economic
impacts
for
a
grower.
Because
of
the
inconsistency
of
some
of
the
alternative
treatments
the
U.
S.
does
not
consider
them
to
be
a
replacement
for
methyl
bromide.
The
work
of
Johnson
and
Webster
(
2001)
as
described
in
Question
12
above
indicated
that
for
metam
sodium
the
time
of
application
before
transplanting,
rate,
and
type
of
incorporation
equipment
all
can
have
significant
impacts
on
performance
of
the
chemicals.
Page
20
Question
16.
Yield
differences
are
the
principal
factor
in
economic
analyses
on
economic
feasibility
of
technically
suitable
alternatives
for
these
regions.
These
yield
differences
are
estimated
for
eggplant
on
the
basis
of
some
tomato
data
including
Locascio
(
1997).
Party
is
asked
to
validate
the
yield
losses
for
alternatives
on
direct
observations
on
eggplants
ANSWER:
Communications
with
several
researchers
indicated
that
they
have
initiated
studies
to
look
at
long
term
performance
of
alternatives
for
eggplant.
These
studies
will
encompass
a
wide
range
of
environmental
conditions,
pest
pressure,
soil
types,
etc.
and
help
to
demonstrate
consistency
of
control.
Until
these
studies
are
complete
the
U.
S.
has
relied
on
surrogate
crops
to
help
demonstrate
yield
and
pest
control
differences.
Perhaps
MBTOC
could
share
some
of
the
yield
loss
estimates
from
other
countries
to
help
illustrate
their
concerns.

IV.
Forest
Nurseries:

Question
17.
MBTOC
is
unclear
why
regions
A,
B,
D
and
F,
which
presently
use
MB/
Pic
98:
2
cannot
use
similar
mixtures
of
MB/
Pic
67:
33
(
as
used
by
the
other
regions)
which
are
considered
to
be
technically
effective
in
control
of
weeds
and
pathogens.
Further
clarification
is
requested.

ANSWER:
A
key
pest
problem
for
these
four
nominees
is
nutsedge,
given
their
geographical
locations,
with
hot,
humid
summers.
The
U.
S.
nomination
is
only
for
those
areas
with
moderate
to
severe
pest
problems
(
not
the
entire
area
where
these
forest
nurseries
are
in
operation).
Nurseries
with
little
nutsedge
pressure
have
found
that
a
MeBr:
chloropicrin
formulation
of
67:
33
provides
acceptable
weed
control,
as
well
as
good
disease
control.
Nurseries
with
high
nutsedge
pressure
routinely
use
a
MeBr:
chloropicrin
formulation
of
98:
2,
as
this
gives
them
better
nutsedge
control,
even
in
the
subsequent
crop,
in
addition
to
good
disease
control.
Nurseries
that
have
lowered
the
formulation
ratio
from
98:
2
to
67:
33
frequently
have
found
that
they
need
higher
rates
of
the
formulated
compound
to
get
adequate
control
(
e.
g.,
440
kg/
ha
of
67:
33
vs.
390
kg/
ha
of
98:
2),
even
with
reduced
weed
pressure.
Thus,
the
amount
of
MB
commonly
used
is
only
somewhat
less
than
with
the
98:
2
formulation.
Nurseries
that
have
been
able
to
lower
the
formulation
ratio
are
almost
always
in
locations
without
severe
infestations
of
nutsedge.
Research
is
being
conducted
on­
site
in
many
of
these
nurseries
(
personal
communication,
International
Paper
[
Region
B];
Southern
Forest
Nursery
Management
Cooperative
[
Region
A])
to
try
to
reduce
the
rate
of
MB
while
maintaining
adequate
weed
and
disease
control.
However,
the
Party
submits
that
MB
will
still
be
critical
for
the
2007
use
season.
USG
will
provide
these
results
when
they
become
available.

The
Northeastern
Forest
and
Conservation
Nursery
Association
[
Region
F]
provided
the
following
clarification
(
information
was
provided
by
the
four
largest
users
of
MB/
Pic
98:
2
in
the
Association
and
by
the
contract
applicator
of
methyl
bromide
for
these
nurseries.
Observations
reported
from
these
users
were
made
under
operational
conditions,
not
from
research
plots):
Page
21
The
current
largest
users
of
98:
2
in
the
consortium
reported
they
had
tried
the
67:
33
mixtures
in
their
nurseries
at
one
time
or
another.
These
users
report
that
the
67:
33
formulation
at
the
standard
application
rate
of
350
lbs./
A
was
less
effective
in
controlling
weeds,
including
nutsedge,
than
the
98:
2
mixture
at
350­
400
lbs/
A.
They
felt
that
67:
33
would
need
to
be
applied
at
a
higher
rate
if
it
was
to
be
as
effective
as
98:
2,
which
would
offset
any
reduction
in
methyl
bromide
by
using
the
67:
33formulation.

One
nursery
also
observed
that
mycorrhizal
recolonization
of
seed
beds
fumigated
with
67:
33
appeared
to
be
less
than
that
in
beds
fumigated
with
98:
2,
leading
to
stunting
of
seedlings
of
several
tree
species.

All
users
of
67:
33
also
reported
that
this
mixture
caused
severe
nasal
irritation
and
nausea
to
workers
removing
plastic
tarps
as
much
as
7
days
after
fumigation.
Protective
gear
needed
to
prevent
these
symptoms
would
be
extremely
uncomfortable,
and
perhaps
even
cause
heat­
related
injuries,
in
the
weather
conditions
usually
found
in
August
and
early
September
in
the
nurseries
in
this
consortium.

Weyerhaeuser
Company
[
Region
D]
provided
the
following
clarification
(
also,
see
Appendix
A
for
a
summary
of
Weyerhaeuser
research
studies
pertinent
to
the
MB
nomination):

The
fumigation
selection
process
is
complex
and
a
result
of
soil
testing
and
analysis,
including
the
following
factors:
(
1)
timing­
spring
versus
fall
fumigation;
(
2)
target
pathogens;
(
3)
contractor
application;
and
(
4)
historical
efficacy
data.

Historically,
within
Weyerhaeuser
Company,
numerous
earlier
studies
tested
MEBR:
PIC
efficacy
as
98:
2
or
67:
33,
but
not
in
the
context
of
direct
"
head­
to­
head"
comparison.
Our
southern
nursery
seedling
production
has
maintained
a
long
track
record
of
effectively
using
the
MEBR:
PIC
98:
2
formulation
with
tarp
for
pathogen
and
weed
control.
These
facilities
are
situated
on
similar
sandy
soils,
typically
low
in
organic
matter
(<
2%).
Pre­
and
post­
fumigation
efficacy
testing
over
a
number
of
years
demonstrates
that
this
treatment
combination
can
yield
an
expectation
of
>
90%
reduction
in
key
pathogen
complexes
such
as
Fusarium
and
Pythium.
This
treatment
effect
is
managed
so
that
soil
fumigation
is
used
once,
every
three
to
four
years,
or
longer
on
a
particular
crop
production
area.
Thus,
MEBR:
PIC
98:
2
soil
treatment
has
been
the
standard
soil
treatment
within
southern
Weyerhaeuser
facilities
for
the
last
25
years,
and
is
directly
responsible
for
successful
seedling
production
(~
2
billion
seedlings)
and
regeneration
of
millions
of
acres.

Our
alternatives
fumigate
testing
(
Weyerhaeuser
Co.)
during
the
late
1990'
s
focused
on
chloropicrin
(
PIC)
as
the
"
next
best
case"
tool
for
effective
soil
pathogen
management.
This
was
largely
driven
off
the
historic
use
of
MeBr:
Pic
67:
33
in
our
western
Weyerhaeuser
nursery
production
facilities
(
likewise,
a
25+
year
track
record
of
similar
production).
These
facilities
are
situated
on
heavier
loam
to
sandy­
loam
soils
with
high
organic
matter
(
5­
10%).
We
observed
that
with
increased
levels
of
PIC,
fumigation
was
more
effective,
especially
on
root
residual
pathogens.
Similarly,
later
trials
conducted
by
us
in
the
South
showed
that
Pic
(
200
lbs­
300
lbs/
ac)
[~
220­
330
kg/
ha]
or
in
combination
with
Telone­
PIC
could
be
as
effective
as
MeBr:
Pic
98:
2,
both
in
the
longevity
of
the
Page
22
fumigation
effect
and
in
aspects
of
seedling
production
(
except
noxious
weed
control).
However,
as
described
below
longer
off­
gassing
has
been
a
problem
with
chloropicrin.

Fall
is
the
preferred
timing
of
fumigant
application,
since
it
allows
for
the
most
effective
soil
management,
preparation,
and
temperature
conditions
conducive
to
treatment.
MB
has
the
unique
property
of
being
the
chemical
least
affected
by
soil
temperature.
Soil
moisture
also
plays
a
large
role
in
fumigant
efficacy,
but
it
affects
a
broad
class
of
chemical
agents,
including
MB.
The
higher
concentration
of
MB
in
the
98:
2
formulation
versus
67:
33
might
have
some
advantages
to
penetration
of
compacted
soil,
tills
and
to
some
degree
soil
depth.
This
advantage
may
be
greater
under
spring
fumigation
conditions
when
soil
properties
may
not
be
ideal
for
fumigation.
We
have
had
several
instances
of
late­
spring
soil
fumigation
with
MeBr:
Pic
67:
33,
where
incomplete
offgassing
has
occurred,
which
could
not
be
detected
with
a
MeBr
meter,
and
which
caused
considerable
post­
transplant
seedling
mortality.
This
damage
was
most
likely
caused
by
the
slower
off­
gassing
by
the
PIC
component,
facilitated
by
a
cool
wet
spring.

Our
soil
pathogen
monitoring
program
is
designed
to
target
critical
pathogen
groups
which
historically
have
caused
the
greatest
damage
to
seedling
production.
Against
these
pathogens
(
mostly
Fusarium
and
Pythium
species),
we
have
arrayed
tests
using
many
of
the
front­
line
fumigant
agents
(
MEBR:
PIC,
PIC,
Telone­
PIC,
Metam
Sodium,
Basamid,
and
others).
To
date,
we
feel
confident
that
MEBR:
PIC
98:
2
and
MEBR:
PIC
67:
33
would
show
similar
efficacy
against
these
pest
complexes
under
the
range
of
treatment
and
soil
conditions
represented
in
our
different
facilities.
However,
we
have
yet
to
conclude
that
CT
values
(
critical
exposure
time
for
MB)
can
be
achieved
for
weed
pests
in
the
South
with
the
short
tarping
interval
that
is
being
used
(
7
days
versus
20+
days
South
versus
West
respectively).
I
suspect
the
short
tarping
period
is
more
a
function
of
climatic
factors
such
as
wind
force,
than
simply
contractor
recommendations.

We
now
have
some
preliminary
data
from
one
facility
in
Washington
State
that
suggests
that
MeBr:
Pic
67:
33
may
not
completely
control
a
new
root
pathogen,
Cylindrocarpon.
The
appearance
and
dominance
by
this
pathogen
may
coincide
with
decade
long
change
from
cover
crop
to
barefallow
practiced
between
fumigation
events.
We
are
currently
investigating
the
possible
link
between
the
lack
of
beneficial
soil
microbes
under
bare
fallow
and
increased
pathology
by
Cylindrocarpon.
However,
Pic
applied
at
300+
lbs/
ac
[
330
kg/
ha]
does
seem
to
control
this
pathogen.
In
the
future,
we
suggest
that
facilities
may
need
to
rotate
fumigant
chemicals
during
upcoming
fumigation
cycles
to
head
off
this
phenomenon.

I
do
not
know
the
current
contractor
preference
for
which
fumigant
is
used
by
facility.
In
several
attempts
we
have
been
unable
to
secure
some
materials
for
testing,
or
equipment
to
apply
those
chemicals
have
not
been
available.
Since
MeBr:
Pic
98:
2
and
MEBR:
PIC
67:
33
do
not
fit
this
criteria,
I
don't
see
any
reason
why
either
formulation
could
not
be
available
for
use
in
any
given
facility
or
year.

In
conclusion,
I
don't
see
a
pathological
reason
to
exclude
the
MEBR:
PIC
67:
33
formulation
from
use
in
Southern
and
Western
facilities.
Other
formulations
with
lower
MB
concentrations
(
50:
50)
would
need
to
be
tested
over
several
crop
cycles.
My
only
reservations
would
be
on
the
substitution
of
MeBr:
Pic
67:
33
for
MeBr:
Pic
98:
2
for
spring
fumigation.
The
time
interval
between
Page
23
to
fumigate
and
to
off­
gas
is
very
short,
and
a
delay
of
1­
month
to
plant
or
longer
can
have
serious
economic
consequences
to
normal
seed
germination
and
seedling
production.

Question
18.
Research
is
ongoing
to
determine
if
Pic
with
metham,
1,3­
D
and/
or
herbicides
can
provide
acceptable
control
of
high
levels
of
nutsedge.
To
date,
metham
sodium
and
chloropicrin
in
combination
showed
promising
results,
but
when
used
without
plastic
sheeting
caused
severe
crop
injury:
MBTOC
considers
that
this
treatment
(
and
others)
covered
with
plastic
films,
particularly
low
permeability
barrier
films,
may
provide
an
effective
technical
alternative
and
avoid
crop
injury
Further
clarification
is
required
on
the
technical
efficacy
of
this
treatment.
MBTOC
accepts
that
some
barrier
films
may
be
difficult
to
apply
in
broadacre
continuous
applications,
and
requests
clarification
on
what
films
have
been
evaluated
and
the
suitability
of
these
films
for
application
and
use;

ANSWER:
As
MBTOC
has
stated,
the
use
of
metham
without
tarping
is
not
feasible
due
to
crop
injury
and
worker
exposure
issues.
It
might
appear
appropriate,
then,
to
tarp
the
material
to
prevent
outgassing
problems.
However,
the
application
of
metham
followed
by
chloropicrin
under
flat­
tarping,
considering
the
large
number
of
hectares
treated
each
year,
is
not
practical
or
cost
effective,
and
currently,
not
technically
feasible
(
personal
communication,
International
Paper
[
Region
B];
Southern
Forest
Nursery
Management
Cooperative
[
Region
A]).
A
three­
step
process
would
be
required,
first
application
of
metham,
then
chloropicrin,
and
finally,
application
of
the
tarp.
Incorporation
of
metham
using
a
rotovator
is
an
extremely
slow
process,
and
the
area
to
be
treated
within
a
given
treatment
window
(
determined
by
weather:
temperature,
moisture,
wind)
is
limited.
This
window
of
application
is
generally
4­
6
weeks,
and
even
under
the
best
application
methods,
this
treatment
takes
four
times
as
long
to
apply
as
the
typical
MB
treatment.
Therefore,
to
treat
the
necessary
hectares
each
year
would
require
a
four­
fold
increase
in
labor
and
additional
available
equipment
in
order
to
apply
metham,
chloropicrin
and
cover
with
tarp.
According
to
the
label,
and
depending
on
soil
and
weather
conditions,
there
would
be
a
two
to
six
week
delay
before
planting
after
application
of
metham,
chloropicrin
and
tarp­
covering.
This
would
affect
market
production
costs.

The
equipment
needed
to
treat
the
area
in
spring
and
fall
would
not
be
available
without
the
purchase
of
four
additional
applicator
units
and
would
greatly
increase
the
cost
to
growers,
as
would
the
"
set­
up"
time
for
the
treatment
with
additional
machinery.
In
order
for
tarps
to
be
placed
on
the
treated
metham
areas,
workers
must
return
into
the
treated
area
to
lay
down
tarps
after
chloropicrin
has
been
injected
into
the
soil.
In
this
case,
out­
gassing
occurs,
and
workers
must
wear
personal
protection
equipment
that
is
not
practical
given
the
temperatures
that
normally
occur
at
the
time
of
application.
Nursery
growers
of
these
regions
are
currently
using
high
density
films
to
decrease
emissions
of
MB,
but
have
found
that
for
current
production
VIF
is
not
an
option
due
to
excessive
costs
and
technical
difficulties
of
gluing
during
application.
Nursery
members
of
the
Southern
Forest
Nursery
Cooperative,
among
others,
are
experimenting
with
VIF,
but
are
not
able
to
adopt
this
technology
for
their
2007
production.

The
Northeastern
Forest
and
Conservation
Nursery
Association
[
Region
F]
provided
the
following
clarification:
Page
24
The
consortium
has
no
additional
information
on
the
technical
efficacy
of
the
treatments
in
question.
There
are
no
commercial
applicators
in
the
region
that
have
the
capability
to
apply
VIF
in
broadacre
applications,
so
these
treatment
combinations
have
not
been
evaluated.
All
methyl
bromide
applied
by
the
consortium
is
done
under
by
1
mil
polyethylene
film
that
is
glued
together
to
cover
the
entire
field.

Weyerhaeuser
Company
[
Region
D]
provided
the
following
clarification
(
also,
see
Appendix
A
for
a
summary
of
Weyerhaeuser
research
studies
pertinent
to
the
MB
nomination):

Our
research
experience
has
been
that
PIC
and
Telone­
PIC
have
tested
with
nearly
the
same
efficacy
as
MB
across
various
facilities,
crop
types
(
seedbed
or
transplants)
and
years.
Essentially,
all
this
test
data
has
been
done
in
association
with
standard
fumigation
tarping
(
1­
2
mil
plastic).
This
is
also
true
for
MIT
agents,
such
as
Basamid,
Metam,
Busan,
Soil
Prep,
or
Vapam.
In
this
later
chemical
group,
we
have
also
shown
that
efficacy
is
tied
to
the
use
of
plastic
tarp.
Furthermore,
MIT
agents
require
conversion
before
they
become
effective
fumigants.
Conversion
is
both
temperature
and
moisture
dependent.

The
use
of
mixtures
of
PIC+
Metam
or
Telone­
PIC+
Metam
in
agriculture
settings
does
not
mirror
larger
nursery
scale
site
fumigation
with
MeBr:
Pic,
PIC
or
Telone­
PIC.
In
fall
nursery
fumigation,
it
is
difficult
to
manage
for
uniform
soil
moisture
over
a
large
acreage.
Irrigation
pipelines
are
removed
to
facilitate
land
preparation
for
fumigation.
Soil
temperature
must
also
be
maintained
in
a
range
above
50F
for
effective
conversion.
This
severely
restricts
the
timing
in
the
fall,
but
in
most
years,
effectively
removes
the
likelihood
of
using
MIT
agents
in
combination
with
other
fumigants
for
spring
fumigation.

A
more
effective
barrier
would
potentially
provide
two
aspects
to
mitigate
the
issue
of
conversion.
First,
the
barrier
composition
should
facilitate
solarization
of
the
soil
to
maintain
the
optimal
temperature
regime
for
conversion
and
to
retain
soil
moisture.
Conventional
fumigation
tarp
(
1­
mil
thickness)
in
solarization
tests
conducted
at
our
Magnolia
(
AR)
and
Mima
(
WA)
did
not
function
as
a
heat
sink
as
well
as
thicker
mil
plastic
(
6
mil),
nor
did
it
physically
last
sufficiently
long
to
solarize
the
soil.

We
have
observed
several
severe
deficiencies
in
MIT
agents
that
have
not
been
observed
in
tests
using
other
agents.
In
these
examples,
we
have
not
been
able
to
deduce
whether
the
negative
crop
effects
are
based
on
residual
MIT
caused
soil
phytotoxicity
or
lack
of
control
of
non­
target
pathogen
groups
(
one's
we
do
not
currently
monitor).

Tarp
cost
is
also
a
limiting
next
step.
Costs
increase
dramatically
with
thickness
and
area
being
covered.
Currently,
standard
1­
mil
tarp
is
adequate
to
achieve
the
treatment
efficacy
(>
90+%
reduction
in
soil
pathogen
population
in
numbers
and
area).

We
suggest
that
MITC
agents
can
be
a
viable
component
of
a
comprehensive
fumigation
plan
for
any
nursery
facility.
We
have
prepared
to
test
a
formulation
of
Telone­
PIC­
Metam,
but
the
Page
25
equipment
was
not
available
for
injection
of
the
later.
Our
understanding
of
the
limitations
of
MIT
agents
and
the
cultural
aspects
to
facilitate
optimal
conversion
offers
further
interest
in
testing
these
mixtures.

Question
19.
MBTOC
also
requests
further
information
on
whether
1,3­
D/
Pic
+
metham
sodium
(
or
glyphosate)
can
be
used
in
place
of
MB/
Pic
formulations
to
control
nutsedge
(
Culpepper
and
Langston,
2004).
MBTOC
also
requests
clarification
from
the
Party
of
the
availability
and
effects
of
VIF
films
used
with
MB:
Pic
mixtures
or
alternatives
to
control
persistent
targets
(
e.
g.
nutgrass)
as
this
can
further
reduce
rates
(
Gilreath
et
al
2005a).

ANSWER:
Forest
tree
seedlings
cannot
be
exposed
to
glyphosate
as
the
herbicide
kills
both
hardwood
and
conifer
species
(
personal
communication,
International
Paper
[
Region
B];
Southern
Forest
Nursery
Management
Cooperative
[
Region
A]).
While
`
shielded
sprayers'
with
glyphosate
have
been
tested
in
small
trials,
seedling
mortality
from
over­
spray
does
occur.
An
International
Paper
nursery,
for
example,
will
typically
produce
300
million
seedlings
per
year,
and
so,
even
1%
mortality
due
to
herbicide
sprays
could
result
in
significant
seedling
loss.
Consequently,
glyphosate
would
not
be
an
option
to
control
nutsedge
in
nursery
beds.

MBTOC
cited
studies
by
Gilreath
et
al.
and
Culpepper
and
Langston.
The
crops
used
for
these
studies
were
eggplant
and
pepper,
which
require
strip­
tarping.
Results
of
these
studies
are
not
applicable
to
the
flat­
tarping
system
used
by
forest
tree
nurseries.
Field
trials
evaluating
VIF
have
been
conducted
by
members
of
the
Southern
Forest
Nursery
Cooperative.
Because
of
its
virtually
impermeable
character,
however,
glues
have
not
been
adequately
developed
that
are
amenable
to
VIF
material,
which
must
withstand
harsh
field
conditions.
Thus,
while
this
method
has
great
potential,
it
will
not
be
technically
feasible
for
the
2007
production
season.
In
addition,
there
is
a
limited
supply
of
VIF,
even
for
research
purposes.
Nursery
managers
have
stated
that
they
cannot
get
the
VIF
material
in
the
quantities
needed,
especially
at
an
acceptable
price.
Therefore,
the
technology
is
currently
not
economically
feasible,
and
MB
will
be
critical
for
the
2007
growing
season.

The
Northeastern
Forest
and
Conservation
Nursery
Association
[
Region
F]
provided
the
following
clarification
(
information
was
provided
by
the
four
largest
users
of
MB/
Pic
98:
2
in
the
Association
and
by
the
contract
applicator
of
methyl
bromide
for
these
nurseries.
Observations
reported
from
these
users
were
made
under
operational
conditions,
not
from
research
plots):

Consortium
members
report
that
glyphosate
is
not
a
particularly
effective
herbicide
for
nutsedge
control.
Also,
it
can
only
be
used
during
the
fallow
part
of
the
nursery
production
cycle;
and
unless
it
is
used
with
glyphosate­
resistant
cover
crops,
which
are
limited
in
number,
it
must
be
used
on
bare
ground.
Since
the
cover
crop
used
during
the
fallow
cycle
serves
to
add
organic
matter
to
the
soil,
bare
ground
fallow
will
prevent
the
addition
of
organic
matter
to
the
nursery
soil
during
this
period.
Page
26
The
consortium
currently
has
no
additional
information
on
the
effectiveness
of
other
Pic+
formulations
mentioned
by
the
MBTOC.
However,
one
nursery
is
planning
to
apply
a
2­
acre
trial
of
Pic
Plus
starting
this
fall.

The
consortium
does
not
know
of
any
commercial
applicators
in
their
region
that
have
the
capability
of
applying
fumigation
treatments
with
VIF
in
broadacre
applications,
so
this
option
is
currently
unavailable
for
their
use.

The
commercial
applicator
of
methyl
bromide
used
by
the
consortium
nurseries
reports
that
there
is
no
manufacturer
of
VIF
in
the
U.
S.,
so
this
product
must
be
imported
from
Europe.
This
applicator
reports
that
the
cost
of
VIF
is
currently
about
double
the
cost
of
the
1.0
mil
polyethylene
sheeting
used
for
broadacre
MB
applications
by
consortium
nurseries.

Weyerhaeuser
Company
[
Region
D]
provided
the
following
clarification
(
also,
see
Appendix
A
for
a
summary
of
Weyerhaeuser
research
studies
pertinent
to
the
MB
nomination):

Weed
control
is
secondary
benefit
of
soil
fumigation,
with
the
primary
effect
being
to
maintain
and
manage
soil
pathogens
over
crop
rotation
cycles.
Periodically,
infestations
of
noxious
weeds
such
as
nutsedge
need
attention.
Some
facilities
are
required
by
specific
State
law
to
maintain
a
"
nutsedge­
free"
growing
environment,
and
crops
can
be
put
in
quarantine
if
the
weed
nuts
can
be
found
in
association
with
seedlings
going
to
the
forest.

Herbicide
use
in
conifer
nursery
facilities
is
curtailed
by
EPA
registration.
Few
currently
registered
herbicides
can
be
used
effectively
on
existing
populations
of
nutsedge.
This
becomes
more
difficult
when
nutsedge
infests
currently
growing
seedlings,
because
few
herbicides
are
safe
to
use
on
pine
or
fir
seedlings.

Herbicides
like
TELAM,
which
have
been
used
effectively
in
agriculture
settings
with
fumigants
(
Metam)
to
control
nutsedge
are
not
currently
registered
for
use
on
conifers.
We
have
undertaken
the
first
step
in
this
evaluation
process
by
securing
a
experimental
use
permit
to
test
the
phytotoxicity
of
this
herbicide
on
loblolly
pine.
This
test
was
completed
in
2004,
and
its
further
testing
does
not
appear
to
be
restricted
by
phytotoxicity.
Tests
like
this
are
dependent
on
state
pesticide
restrictions
and
regulations.

Other
herbicides,
such
as
Goal
and
Roundup
(
Glyphosate)
are
used
routinely
to
control
nursery
weeds,
either
pre
or
post
fumigation,
but
not
simultaneously.
We
have
one
documented
situation
where
Glyphosate
applied
30
days
prior
to
transplant
in
a
bare­
fallow
field
(
non­
fumigated
field)
might
have
contributed
to
excessive
levels
of
mortality
by
the
pathogen,
Cylindrocarpon.
There
is
some
disagreement
in
the
literature
on
the
rate
of
breakdown
and
movement
of
Glyphosate
after
application,
but
less
so
on
the
ability
of
this
herbicide
to
reduce
plant
defensive
mechanisms.

We
maintain
an
active
cooperative
research
role
with
both
the
Western
and
Southern
Nursery
Cooperatives
to
study,
test,
and
register
new
herbicides
for
nursery
use.
There
is
a
high
likelihood
Page
27
that
this
research
in
combination
with
our
effective
soil
pathogen
monitoring
and
management
program
will
result
in
effect
alternative
soil
treatment
combinations.

Question
20.
The
Party
states
that
substrates
cannot
be
used
for
Region
H
because
roots
will
freeze,
but
clarification
is
required
on
whether
this
could
be
avoided
by
use
of
polyethylene
tunnels
or
in
greenhouses
where
plug
plants
are
raised
successfully
for
many
crops
in
many
regions
(
Styter
and
Koranski,
1997).

Note:
As
the
herbaceous
seedlings
portion
of
the
nomination
(
region
H)
has
more
similarities
to
the
Ornamentals
sector
than
to
Forest
Seedlings,
it
is
suggested
that
this
nomination
could
be
included
in
the
Ornamentals
CUN.
Is
this
possible
in
future
nominations?

ANSWER:
The
Party
agrees
that
plug
plants
can
be
raised
under
plastic
or
glass
for
"
many
crops,
in
many
regions".
However,
in
this
case,
the
applicant
has
considered
this
option
and
determined
that
this
technology
would
not
be
economically
feasible
for
herbaceous
perennials
in
Michigan.
Therefore,
the
nomination
for
the
2007
is
critical.
The
economic
analysis
(
see
attached
economic
worksheets,
Appendix
B)
concludes
that
transitioning
to
covered
production
would
require
such
a
large
preproduction
investment
there
would
be
an
unacceptable
burden
to
growers.
This
analysis
did
not
include
additional
building
costs
that
would
be
associated
with
greenhouse
construction.
The
Party
contends
that
the
applicant
already
uses
alternatives
for
most
of
its
production
and
has
requested
only
an
amount
of
MB
(
for
12
ha)
that
is
critically
necessary
for
use
in
2007.
These
12
hectares
are
a
significant
reduction
from
the
35
hectares
treated
in
2003,
and
from
an
average
128
ha
treated
in
2001/
2002.
Furthermore,
multi­
season
field
studies
conducted
by
Michigan
State
University
researchers
will
be
completed
and
analyzed
in
2007.
Results
of
these
studies
should
help
identify
options
for
further
reductions
in
MB
use,
while
maintaining
production
requirements.

Note:
Future
applications
by
this
nominee
will
be
included
in
the
Ornamentals
CUN.

V.
Nursery
stock(
fruit
trees,
raspberries,
roses):

Question
21.
MBTOC
is
awaiting
a
revised
nomination
and
BUNI
to
be
submitted.

ANSWER:
A
revised
BUNI
has
been
attached.
Please
see
Appendix
III
VI.
Orchard
Replant:

Question
22.
In
bilateral
discussions
with
the
Party
on
April
13,
2005,
the
Party
indicated
it
needed
to
further
check
calculations
in
all
nominations
in
which
strip
treatments
are
used:
This
nomination
indicates
strip
treatments
are
used
for
stone
fruit
and
for
almond.
MBTOC
awaits
the
confirmation
of
the
calculations
in
order
to
complete
this
evaluation.
Page
28
ANSWER:
USG
has
confirmed
that
the
treated
area
estimates
have
been
adjusted
to
account
for
the
strip
bed
treatments
that
are
used
for
stone
fruits.
Specifically,
the
requested
hectares
were
multiplied
by
0.65
to
account
for
the
fact
that
only
the
strips
are
treated.

VII.
Peppers:

Question
23.
In
SE
US,
Georgia
and
Florida,
nematodes,
soilborne
fungi
and
nutsedge
are
key
pests.
The
Party
states
that
1,3­
D
+
chloropicrin
+
trifluralin
+
napropamide
is
the
best
alternative
strategy,
but
further
testing
required.
This
is
restricted
to
areas
without
karst
topography
and
the
Party
states
that
several
large
scale
trials
are
in
progress.
The
Party
is
requested
to
provide
details
and
results
of
these
trials.

ANSWER
The
researchers
in
these
states
are
actively
conducting
research
on
alternatives.
However,
these
are
multiyear
studies
and
the
results
are
not
yet
available.
For
example,
as
described
in
Question
15
above,
in
the
multiyear
study
by
Gilreath,
Santos,
Motis,
Noling
and
Mirusso
(
2005)
looking
at
nematode
and
Cyperus
control
in
bell
pepper
(
Capsicum
annum).
In
that
study
the
author's
state
"
For
Cyperus,
the
herbicides
failed
to
improve
control,
although
in
one
season
napropamide
and
trifluralin
showed
some
activity."
"
For
bell
pepper
yield,
the
application
of
metam
sodium
and
metam
sodium
+
chloropicrin
provided
similar
fruit
weight
as
for
methyl
bromide
+
chloropicrin
in
two
of
the
three
seasons."
In
that
one
year
(
Fall
2002)
the
yields
went
from
18.8
t/
ha
for
methyl
bromide
+
chloropicrin
to
13.7
t/
ha
for
metam
sodium
+
chloropicrin
or
a
27%
drop
in
yield.
This
level
of
yield
loss
could
have
severe
economic
impacts
for
a
grower.
Because
of
the
inconsistency
of
some
of
the
alternative
treatments
the
U.
S.
does
not
consider
them
to
be
a
replacement
for
methyl
bromide.
When
highly
trained,
careful
researchers
see
this
level
of
variability
it
clearly
demonstrates
the
need
for
multi­
year
studies
to
validate
alternatives.
Until
those
multi­
year
results
are
available
accurate
interpretation
of
the
results
is
impossible.

Question
24.
The
CUN
was
based
on
limited
research
results,
and
MBTOC
seeks
further
discussion
on
recent
trial
results
in
SE
USA,
especially
those
using
low
permeability
barrier
films
(
Gilreath
et
al
2005a)
and
new
application
methods
for
alternatives
on
peppers.
Recent
references
available
to
MBTOC,
demonstrate
effective
alternatives
(
metham
sodium,
with
and
without
Pic)
for
moderate
to
heavy
nutgrass
control
in
similar
regions
to
the
nomination
and
for
non
karst
and
karst
areas
(
Johnson
and
Webster,
2001
;
Gilreath
et
al
2005b,
c):
Yields
were
similar
to
methyl
bromide,
however
there
was
no
data
presented
on
plantback
effects
for
peppers.
Party
is
requested
to
clarify
the
relevance
of
these
results
to
the
nomination.

ANSWER
Several
members
of
MBTOC
and
the
USG
were
recently
able
to
tour
field
research
sites
in
Florida
and
Georgia
including
the
plots
of
Dr.
Gilreath.
During
those
discussions
and
in
his
recent
research
publications
(
Gilreath
et
al
2005,
Gilreath
et
al
in
press,
and
Gilreath
&
Gilreath
2005)
improved
pest
control
when
using
virtually
impermeable
film
(
VIF)
or
metalized
films
(
using
an
aluminum
layer
such
as
Canslit)
was
described.
Dr.
Gilreath
and
other
researchers
were
contacted
on
the
Page
29
topics
of
low
permeability
barrier
films,
and
newer
application
techniques.
Based
on
their
input
it
appears
that
VIF
films
have
still
not
been
widely
adopted
because
of
problems
in:
laying
the
films,
inelasticity
and
the
resultant
difficulty
in
conforming
to
the
bed
shape,
problems
with
linear
shear,
and
the
fact
that
embossed
films
are
not
available.
The
current
versions
of
metalized
films
are
being
widely
tested
by
several
researchers
and
growers
and
they
have
the
potential
to
reduce
fumigant
use
rates
with
better
laying
and
bedshape
conforming
characteristics.
It
is
anticipated
that
the
results
of
many
of
these
research
plots
and
growers
field
tests
will
be
available
next
year.
These
metalized
films
pose
several
questions
for
adoption:
the
fate
of
the
aluminum
coating
if
it
"
flakes
off"
on
the
soil
during
removal
and
the
photostability
of
the
coating
during
multiple
crop
cycles
as
is
common
in
the
southeastern
U.
S.
An
additional
concern
with
all
of
the
low
permeability
films
and
reduced
use
rates
is
poor
uniformity
of
treatment,
unless
the
application
equipment
is
redesigned
to
accommodate
reduced
flow
rates
and
pressure
(
Gilreath
and
Gilreath
2005).
While
all
of
these
results
are
promising
there
are
only
a
few
researchers
that
have
multi­
year
trials
with
these
films
and
new
or
modified
application
equipment.
Many
growers
are
said
to
be
testing
the
new
films,
reduced
rates
of
methyl
bromide,
and
other
alternatives.
Without
multi­
year
trials
under
a
range
of
environmental
conditions
the
consistency,
feasibility,
and
adaptability
cannot
be
assessed.

When
evaluating
research
cited
by
MBTOC
(
Gilreath
et
al
2003)
the
untreated
control
at
the
Bradenton
site
had
53
nutsedge
(
Cyperus
rotundus)
plants
per
square
yard,
while
the
Immokalee
site
had
fewer
than
one
plant
per
square
yard.
The
current
standard
that
the
U.
S.
recommends
for
moderate
nutsedge
pressure
is
5
to
30
plants
per
square
yard.
At
the
Bradenton
site
the
nutsedge
control
was
not
significantly
different
between
MeBr:
Pic
(
350
lb
per
acre)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
but
had
39%
more
nutsedge
plants
and
a
17%
reduction
in
yield.
When
comparing
the
same
treatments
at
Immokalee,
which
had
and
no
significant
difference
in
Fusarium,
or
nematodes
(
such
as
Meloidogyne
spp,
Belonolainus
spp.
and
Tylenchorhynchus
spp.),
but
low
nutsedge
pressure
(<
1
plant
per
square
yard),
there
was
still
a
12.5%
reduction
in
yield
compared
to
methyl
bromide.

Researchers
in
Georgia
have
also
been
conducting
research
on
methyl
bromide
alternatives
for
pepper
production
(
Culpepper,
Webster,
Langston
2005)
and
the
interaction
of
VIF
and
LDPE
films.
Their
research
presented
in
the
following
four
Tables
shows
promising
results
from
VIF
mulch
versus
LDPE
but
some
early
trends
are
apparent.
Telone
II
or
C35
followed
by
chloropicrin
may
lead
to
more
injury
when
using
VIF
rather
than
LDPE,
nutsedge
visual
estimate
of
control
and
the
number
of
plants
penetrating
the
mulch
was
generally
better
with
VIF
than
LDPE,
pepper
yield
(
number
of
fancy
fruit
and
weight
or
fancy
or
total
fruit)
did
not
appear
to
be
effected
by
the
type
of
mulch.
When
this
type
of
study
is
repeated
we
hope
to
have
a
better
understanding
of
the
seasonal
variability
in
pest
control
and
harvest
yield
when
using
different
types
of
mulches.
Page
30
Table
16.
Pepper
response
to
various
fumigant­
mulch
treatments
in
fall
2004.*

Visual
injury
(
45
day
after
planting)
Pepper
height
(
30
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
Telone
II
fb
chloropicrin
12
G
fb
150
lbs
3
12
18
17
Telone
C35
fb
chloropicrin
35
G
fb
150
lbs
2
15
17
15^

Telone
II
fb
KPAM
12
G
fb
60
G
6
6
18
17
None
0
0
17
15^
Methyl
bromide
+
chloropicrin
(
67:
33)
400
lbs
2
3
17
18
Methyl
iodide
+
chloropicrin
(
50:
50)
400
lbs
2
73^
17
11^

Dimethyldisulfide
800
lbs
0
2
19
17
Dimethyldisulfide
+
chloropicrin
(
50:
50)
700
lbs
0
18^
18
14^

*
Means
within
crop
injury
(
plant
stunting)
can
be
compared
with
an
LSD
=
8
while
plant
heights
can
be
compared
with
an
LSD
=
2.
Fumigants
were
applied
on
July
20
and
the
crop
was
planted
on
August
2.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
32
inch
bedtop.
Kapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
KPAM
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
within
each
variable.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
17.
Nutsedge
response
to
various
fumigant­
mulch
treatments
in
pepper
during
the
fall
of
2004.*

Visual
control
(
95
days
after
fumigating)
Number
plants
penetrating
mulch
(
95
days
after
fumigating)
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
Telone
II
fb
chloropicrin
12
G
fb
150
lbs
17^
53^
140^
76^

Telone
C35
fb
chloropicrin
35
G
fb
150
lbs
44^
90^
85^
21
Telone
II
fb
KPAM
12
G
fb
60
G
35^
43^
95^
118^

None
0^
0^
126^
116^
Page
31
Methyl
bromide
+
chloropicrin
(
67:
33)
400
lbs
75
87^
47
22
Methyl
iodide
+
chloropicrin
(
50:
50)
400
lbs
32^
70
96^
36
Dimethyldisulfide
800
lbs
5^
13^
156^
140^
Dimethyldisulfide
+
chloropicrin
(
50:
50)
700
lbs
12^
87^
154^
38
*
Means
within
visual
nutsedge
control
can
be
compared
with
an
LSD
=
6
while
the
number
of
nutsedge
plants
penetrating
the
mulch
over
the
entire
20
foot
plot
can
be
compared
with
an
LSD
=
28.
Fumigants
were
applied
on
July
20
and
the
crop
was
planted
on
August
2.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
32
inch
bedtop.
Kpam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
KPAM
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
at
plant
date
1.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
18.
Number
of
pepper
in
various
fumigant­
mulch
treatments
harvested
in
fall
2004.*

Number
of
fancy
fruit
(
harvest
1
only)
Number
of
fancy
fruit
from
harvest
1,
2,
and
3
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
Telone
II
fb
chloropicrin
12
G
fb
150
lbs
10^
14
70
86
Telone
C35
fb
chloropicrin
35
G
fb
150
lbs
11^
14
83
74
Telone
II
fb
KPAM
12
G
fb
60
G
13
18
72
81
None
4^
8^
32
53^
Methyl
bromide
+
chloropicrin
(
67:
33)
400
lbs
18
22
84
88
Methyl
iodide
+
chloropicrin
(
50:
50)
400
lbs
14
1^
72
46^

Dimethyldisulfide
800
lbs
2^
18
43^
82
Dimethyldisulfide
+
chloropicrin
(
50:
50)
700
lbs
11^
12
63^
75
Page
32
*
Means
within
the
first
harvest
only
can
be
compared
using
an
LSD
=
7
while
the
number
of
fancy
fruit
harvested
over
the
first
three
harvest
dates
can
be
compared
using
an
LSD
=
17.
Harvest
sample
size
was
20
row
feet
of
pepper.
Fumigants
were
applied
on
July
20
and
crop
was
planted
on
August
2.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
32
inch
bedtop.
Vapam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
KPAM
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
within
each
variable.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Table
19.
Weight
of
pepper
(
lbs)
in
various
fumigant­
mulch
treatments
harvested
in
fall
2004.*

Weight
(
lbs)
of
fancy
fruit
(
harvest
1
only)
Total
weight
(
lbs)
of
fruit
from
harvest
1,
2,
and
3
Fumigants**
Rates
(
broadcast
rate)
LDPE
mulch
VIF
mulch
LDPE
mulch
VIF
mulch
Telone
II
fb
chloropicrin
12
G
fb
150
lbs
4^
6
31^
37
Telone
C35
fb
chloropicrin
35
G
fb
150
lbs
5^
5^
37
33
Telone
II
fb
KPAM
12
G
fb
60
G
5^
7
32
35
None
2
3^
14^
23^
Methyl
bromide
+
chloropicrin
(
67:
33)
400
lbs
8
9
38
39
Methyl
iodide
+
chloropicrin
(
50:
50)
400
lbs
6
0^
32
22^

Dimethyldisulfide
800
lbs
1^
8
19^
37
Dimethyldisulfide
+
chloropicrin
(
50:
50)
700
lbs
5^
5^
28^
32
*
Means
within
harvest
date
1can
be
compared
with
an
LSD
=
3
while
the
weight
of
fancy
fruit
harvested
over
the
first
three
harvest
dates
can
be
compared
with
an
LSD
=
7.
Harvest
sample
size
was
20
row
feet
of
pepper.
Fumigants
were
applied
on
July
20
and
crop
was
planted
on
August
2.

**
DMDS,
methyl
bromide,
chloropicrin,
Telone
C35,
and
methyl
iodide
were
applied
with
a
normal
methyl
bromide
application
apparatus
applying
fumigants
6
to
8
inches
deep
using
3
injecting
knives
per
32
inch
bedtop.
Kpam
was
injected
into
the
soil
with
blades
4.5
inches
apart.
KPAM
was
applied
as
a
broadcast
treatment
and
then
pulled
into
the
bed
where
all
other
treatments
were
applied
only
in
the
bed.

^
Values
differ
from
methyl
bromide
under
LDPE
mulch
within
each
variable.
From:
A.
S.
Culpepper,
T.
M.
Webster,
D.
Langston,
Univ.
of
Georgia,
August
15,
2005
E­
mail
from
W.
T.
Kelley.

Question
25.
MBTOC
also
requests
the
Party
provide
the
registration
status
and
use
rates
available
for
use
with
MB/
Pic
mixtures
and
verify
that
mixtures
with
less
MB
(
especially
30:
70,
50:
50)
are
unsuitable
for
control
of
the
key
pests
in
the
nomination.
Also
it
is
requested
that
Page
33
economic
data
be
provided
for
the
two
most
appropriate
alternatives
for
all
circumstances
of
the
nomination.

ANSWER
Communications
with
several
researchers
indicated
that
they
have
started,
or
are
about
to
initiate,
studies
to
look
at
long
term
performance
of
even
lower
rates
of
methyl
bromide
(
at
or
below
200
kg/
ha).
These
studies
will
encompass
a
wide
range
of
environmental
conditions,
pest
pressure,
soil
types,
etc.
and
help
to
demonstrate
consistency
of
control.
IF
MBTOC
has
references
indicating
the
use
of
50:
50
or
30:
70
is
effective
in
the
circumstances
of
the
US
nomination
we
would
like
to
have
those
citations.

One
of
the
studies
that
MBTOC
cites
is
from
Florida
(
Gilreath
et
al,
2005a),
which
looked
at
the
impact
of
reduced
rates
of
MB
on
pest
control
and
pepper
yield.
In
that
study,
which
had
high
Cyperus
spp.
pressure,
there
were
no
significant
differences
in
yield
between
any
of
the
rates
of
methyl
bromide
with
the
different
types
of
films.
However,
an
examination
of
the
change
in
yield
with
VIF
treatments,
compared
to
the
standard
MB
treatments,
suggests
significant
variability
within
treatments,
which
led
to
the
lack
of
statistical
significance
in
yield
despite
the
large
numerical
differences
in
yield
between
treatments.
Trials
such
as
those
conducted
by
Gilreath
et
al
(
2005a)
with
peppers,
need
to
be
conducted
over
several
seasons,
and
preferably
with
different
crops.
The
reality
of
the
use
of
VIF
for
the
2007
season
is
its
current
prohibitive
cost
in
the
U.
S.,
and
even
more
significant,
its
lack
of
availability
for
use
on
a
commercial
scale.
The
Party
does
not
anticipate
these
issues
can
be
adequately
resolved
before
the
critical
use
season
of
2007.

Table
20.
Pepper
yield
are
not
significantly
different
but
percent
yield
loss
can
be
large.
Treatment
Application
Rate
kg/
ha
Yield
t/
ha
%
Change
1
Untreated
9.5
­
31%
2
MeBr
+
Pic
LDPE
392
13.8
0%
3
MeBr
+
Pic
VIFP
196
10.8
­
22%
4
MeBr
+
Pic
VIFP
98
13.6
1%
5
MeBr
+
Pic
VIFV
196
11.4
­
17%
6
MeBr
+
Pic
VIFV
98
11.9
­
14%
Footnote:
From
Gilreath
et
al.
2005.
Crop
Protection
24:
285­
287.
LDPE
is
low
density
polyethylene,
VIFP
and
VIFV
are
virtually
impermeable
film
by
Plastopil
and
Vikase
respectively.

The
research
plots
that
MBTOC
visited
in
Florida
clearly
demonstrated
that
chloropicrin
will
not
control
sedges
such
as
Cyperus
esculentus
or
C.
rotundus
.
Research
by
Gilreath
and
communications
with
him
indicate
that
chloropicrin
enhances
nutsedge
germination
(
this
research
has
yet
to
be
repeated
for
other
pest
species).
Therefore,
increasing
the
amount
of
chloropicrin
applied
can
increase
pest
pressure
and
yield
loss.

The
economic
information
was
presented
in
the
sector
chapter
for
peppers
and
is
reproduced
below:

Part
E:
Economic
Assessment
Page
34
Economic
data
from
the
2004
submission
for
all
applicants
were
not
substantially
different
from
those
in
2003
(
greater
or
less
than
a
10%
change
in
costs
and
revenue).
Given
these
insignificant
differences,
the
economic
analyses
were
not
updated
for
any
applicants
other
than
Michigan,
which
was
updated
to
reflect
a
change
in
the
requested
pounds
of
MeBr.

The
following
economic
assessment
is
organized
by
MeBr
critical
use
application.
Cost
of
MeBr
and
alternatives
are
given
first
in
table
21.1.
This
is
followed
in
table
22.1
by
a
listing
of
net
and
gross
revenues
by
applicant.
Expected
losses
when
using
MeBr
alternatives
are
then
further
decomposed
in
tables
E1
through
E5.

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

21.
OPERATING
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:
Page
35
TABLE
21.1:
PEPPERS
 
OPERATING
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
California
Methyl
Bromide
100%
$
17,246
$
17,246
$
17,246
1,3­
D
+
Chloropicrin
94%
$
17,160
$
17,160
$
17,160
Florida
Methyl
Bromide
100%
$
20,341
$
20,341
$
20,341
1,3­
D
+
Chloropicrin
71%
$
18,510
$
18,510
$
18,510
Metam­
Sodium
56%
$
16,999
$
16,999
$
16,999
Georgia
Methyl
Bromide
100%
$
28,623
$
28,623
$
28,623
1,3­
D
+
Chloropicrin
71%
$
25,790
$
25,790
$
25,790
Metam­
Sodium
56%
$
23,598
$
23,598
$
23,598
Michigan
Methyl
Bromide
100%
$
23,938
$
23,938
$
23,938
1,3­
D
+
Chloropicrin
94%
$
25,607
$
25,607
$
25,607
Southeast
USA
Methyl
Bromide
100%
$
18,758
$
18,758
$
18,758
1,3­
D
+
Chloropicrin
71%
$
18,844
$
18,844
$
18,844
Metam­
Sodium
56%
$
16,731
$
16,731
$
16,731
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
e.
g.
10%
more
yield,
write
110.

22.
GROSS
AND
NET
REVENUE:
Page
36
TABLE
22.1:
PEPPERS
 
YEAR
1,
2,
AND
3
GROSS
AND
NET
REVENUES
YEAR
1,
2,
AND
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
California
Methyl
Bromide
$
21,344
$
4,098
1,3­
D
+
Chloropicrin
$
20,063
$
2,903
Florida
Methyl
Bromide
$
29,498
$
9,158
1,3­
D
+
Chloropicrin
$
20,944
$
2,433
Metam­
Sodium
$
16,519
$(
479)
Georgia
Methyl
Bromide
$
35,176
$
6,553
1,3­
D
+
Chloropicrin
$
24,975
$(
816)
Metam­
Sodium
$
19,698
$(
3,900)
Michigan
Methyl
Bromide
$
24,056
$
118
1,3­
D
+
Chloropicrin
$
20,916
$(
2,994)
Southeastern
USA
Methyl
Bromide
$
30,579
$
11,822
1,3­
D
+
Chloropicrin
$
21,711
$
2,867
Metam­
Sodium
$
17,124
$
393
NOTE:
Year
1
equals
year
2
and
3.
Page
37
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
PEPPER
­
TABLE
E1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
787
739
*
PRICE
PER
UNIT
(
US$)
$
27
$
27
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
21,344
$
20,063
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
17,246
$
17,160
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4,098
$
2,903
FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
0
$
1,194
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
8
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
6%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
29%

5.
PROFIT
MARGIN
(%)
19%
14%

FLORIDA
PEPPER
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
2,922
2,074
1,636
*
PRICE
PER
UNIT
(
US$)
$
10
$
10
$
10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
29,498
$
20,944
$
16,519
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
20,341
$
18,510
$
16,999
=
NET
REVENUE
PER
HECTARE
(
US$)
$
9,158
$
2,433
$(
479)

FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
0
$
6,724
$
9,637
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
45
$
64
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
23%
33%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
73%
105%
Page
38
5.
PROFIT
MARGIN
(%)
31%
12%
­
3%

GEORGIA
PEPPER
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
4,440
3,152
2,486
*
PRICE
PER
UNIT
(
US$)
$
8
$
8
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
35,176
$
24,975
$
19,698
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
28,623
$
25,790
$
23,598
=
NET
REVENUE
PER
HECTARE
(
US$)
$
6,553
$(
816)
$(
3,900)

FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
0
$
7,368
$
10,453
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
49
$
70
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
21%
30%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
112%
160%

5.
PROFIT
MARGIN
(%)
19%
­
3%
­
20%
Page
39
MICHIGAN
PEPPER­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

YIELD
PER
HECTARE
4,530
4,258
*
PRICE
PER
UNIT
(
US$)
$
5
$
5
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
24,056
$
20,916
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
23,938
$
25,607
=
NET
REVENUE
PER
HECTARE
(
US$)
$
118
$(
4,690)

FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
0
$
4,808
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
40
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
20%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
100%

5.
PROFIT
MARGIN
(%)
0%
­
22%
Page
40
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
PEPPER
­
TABLE
E.
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

YIELD
PER
HECTARE
3,707
2,632
2,076
*
PRICE
PER
UNIT
(
US$)
$
8
$
8
$
8
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
30,579
$
21,711
$
17,124
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
18,758
$
18,844
$
16,731
=
NET
REVENUE
PER
HECTARE
(
US$)
$
11,822
$
2,867
$
393
FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
0
$
8,954
$
11,429
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
$
60
$
76
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
29%
37%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
76%
97%

5.
PROFIT
MARGIN
(%)
39%
13%
2%

Summary
of
Economic
Feasibility
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
peppers.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
As
described
above,
the
two
most
promising
alternatives
to
methyl
bromide
in
Florida,
Georgia,
and
the
Southeastern
USA
for
control
of
nut­
sedge
in
peppers
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
expected
yield
losses
when
they
are
used.
Economic
data
representing
the
Florida,
Georgia,
and
Southeastern
USA
pepper
growing
conditions
are
included
in
this
section
as
a
supplement
to
the
biological
review
to
illustrate
the
impacts
of
using
MeBr
alternatives,
not
to
gauge
them
with
respect
to
economic
feasibility.
However,
in
California
and
Michigan
1,3­
D
+
chloropicrin
is
considered
technically
feasible.

California
Yield
loss
in
California
pepper
production
is
expected
to
be
6%
when
using
MeBr
alternatives.
Growers
will
experience
loss
on
a
per
hectare
basis
of
approximately
$
1,200
and
6%
and
29%
losses
in
gross
and
net
revenues,
respectively.
However,
these
measures
do
not
clearly
indicate
that
1,3­
D
+
chloropicrin
is
an
economically
infeasible
alternative
to
MeBr.
Page
41
The
economic
conditions
facing
pepper
growers
were
quantified
as
best
as
possible
but,
primarily
due
to
limited
data
availability,
every
aspect
of
the
economic
picture
was
not
included
in
the
numeric
assessment.
Factors
not
accounted
for
are
distribution
of
yield
loss
across
individual
growers
and
the
yield
risk
associated
with
using
MeBr
alternatives.

Michigan
The
US
concludes
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Michigan
pepper
production.
Two
factors
have
proven
most
important
in
this
conclusion.
These
are
yield
loss
and
missed
market
windows,
which
are
discussed
individually
below.

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

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

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

To
describe
these
conditions
in
Michigan
pepper
production,
weekly
pepper
sales
data
from
the
US
Department
of
Agriculture
for
the
previous
three
years
was
used
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
it
is
assumed
that
if
pepper
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
receive
gross
revenues
reduced
by
approximately
7.5%.
The
season
average
price
was
reduced
by
7.5%
in
the
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
the
US
believes
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Michigan
pepper
production.

Florida
No
technically
(
and
thus
economically)
feasible
alternatives
to
MeBr
are
presently
available
to
the
effected
pepper
growers.
As
such,
the
US
concludes
that
use
of
MeBr
is
critical
in
Florida
pepper
production.
Page
42
Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MeBr
are
presently
available
to
the
effected
pepper
growers.
As
such,
the
US
concludes
that
use
of
MeBr
is
critical
in
Georgia
pepper
production.

Southeastern
USA
Except
Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MeBr
are
presently
available
to
the
effected
pepper
growers.
As
such,
the
US
concludes
that
use
of
MeBr
is
critical
in
Southeastern
USA
pepper
production.

Question
26.
There
appears
to
be
scope
for
substantial
reduction
in
MB
use
in
this
area
through
adoption
of
barrier
film
technology
together
with
reduced
MB
dosages.
Party
is
requested
to
clarify
why
low
permeability
barrier
films
cannot
be
used
in
SE
USA
based
on
results
from
recent
studies
and
publications
from
trials
conducted
from
1998
to
2005.

ANSWER:
Several
members
of
MBTOC
and
the
USG
were
recently
able
to
tour
field
research
sites
in
Florida
and
Georgia,
including
the
plots
of
Dr.
Gilreath.
In
those
discussions,
and
in
his
recent
research
publications
(
Gilreath
et
al
2005,
Gilreath
et
al
in
press,
and
Gilreath
&
Gilreath
2005),
the
improved
pest
control
using
virtually
impermeable
film
(
VIF)
or
metalized
films
(
using
an
aluminum
layer
such
as
Canslit)
was
described.
Dr.
Gilreath
and
other
researchers
were
contacted
on
the
topics
of
low
permeability
barrier
films,
and
newer
application
techniques.
Based
on
their
input
it
appears
that
VIF
films
have
still
not
been
widely
adopted
because
of
problems
in:
laying
the
films,
inelasticity
and
the
resultant
difficulty
in
conforming
to
the
bed
shape,
problems
with
linear
shear,
and
the
fact
that
embossed
films
are
not
available.
The
current
versions
of
metalized
films
are
being
widely
tested
by
several
researchers
and
growers
and
they
have
the
potential
to
reduce
fumigant
use
rates
with
better
laying
and
bedshape
conforming
characteristics.
It
is
anticipated
that
the
results
of
many
of
these
research
plots
and
growers
field
tests
will
be
available
next
year.
These
metalized
films
pose
several
questions
for
adoption
of
these
films:
the
fate
of
the
aluminum
coating
if
it
"
flakes
off"
on
the
soil
during
removal
and
the
photostability
of
the
coating
during
multiple
crop
cycles
as
is
common
in
the
southeastern
U.
S.
An
additional
concern
with
all
of
the
low
permeability
films
and
reduced
use
rates
is
poor
uniformity
of
treatment
unless
the
application
equipment
must
be
redesigned
to
accommodate
reduced
flow
rates
and
pressure
(
Gilreath
and
Gilreath
2005).
While
all
of
these
results
are
promising
there
are
only
a
few
researchers
that
have
multi­
year
trials
with
these
films
and
new
or
modified
application
equipment.
Many
growers
are
said
to
be
testing
the
new
films,
reduced
rates
of
methyl
bromide,
and
other
alternatives.
Without
multi­
year
trials
under
a
range
of
environmental
conditions
the
consistency,
feasibility,
and
adaptability
cannot
be
assessed.

When
evaluating
research
cited
by
MBTOC
(
Gilreath
et
al,
2003)
the
untreated
control
at
the
Bradenton
site
had
53
nutsedge
(
Cyperus
rotundus)
plants
per
square
yard,
while
the
Immokalee
site
had
fewer
than
one
plant
per
square
yard.
The
current
standard
that
the
US
recommends
for
moderate
nutsedge
pressure
is
5
to
30
plants
per
square
yard.
At
the
Bradenton
site
the
nutsedge
control
was
not
significantly
different
between
MeBr:
Pic
(
350
lb
per
acre)
versus
1,3­
D­
Page
43
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
but
had
39%
more
nutsedge
plants
and
a
17%
reduction
in
yield.
When
comparing
the
same
treatments
at
Immokalee,
which
had
and
no
significant
difference
in
Fusarium,
or
nematodes
(
such
as
Meloidogyne
spp,
Belonolainus
spp.
and
Tylenchorhynchus
spp.),
but
low
nutsedge
pressure
(<
1
plant
per
square
yard),
there
was
still
a
12.5%
reduction
in
yield
compared
to
methyl
bromide.

VIII.
STRAWBERRY
FRUIT
Question
27.
In
California,
the
nomination
is
based
on
the
grounds
that
township
caps
limit
further
adoption
of
1,3­
D,
and
hilly
terrain
prevents
the
use
of
drip­
applied
alternatives.
In
the
case
of
township
caps,
alternatives
that
do
not
contain
1,3­
D
(
such
as
Pic
and
Pic
+
metham
applied
sequentially)
are
technically
feasible
in
at
least
part
of
this
area
(
Ajwa
et
a12002,
2004),
Party
to
describe
why
these
alternatives
proven
in
recent
studies
are
not
feasible
for
a
proportion
of
the
nomination.

ANSWER:
The
Party
agrees
that
some
research
has
shown
that
alternatives
such
as
chloropicrin
and
metham
sodium
might
offer
effective
pest
management
possibilities
to
strawberry
farmers.
However,
the
reality
in
the
field
is
that
for
such
a
high
value
crop,
potential
alternatives
to
MB
must
be
proven
on
a
larger
scale
than
has
been
done
thus
far.
Efforts
to
identify
risks
of
alternatives,
such
as
offgassing
accidents
that
can
devastate
crops,
are
actively
being
pursued
by
farmers,
researchers
and
extension
workers.
For
the
2007
growing
season,
however,
the
Party
maintains
that
the
nomination
for
MB
for
this
sector
is
critical.
The
California
Strawberry
Commission
provided
the
following
to
address
MBTOC's
concerns:

Straight
Pic
and
Pic
+
metam
sodium
sequential
treatments
are
used
in
a
small
proportion
of
the
strawberry
acreage
due
to
a
combination
of
efficacy,
regulatory
and
production
system
limitations.
A
review
of
the
2003
PUR
[
California
Pesticide
Use
Report]
data
from
Cal
DPR
[
California
Department
of
Pesticide
Regulation]
reveals
that
only
902.5
acres
[
366
ha]
were
treated
with
metam
sodium
compared
to
26,480
acres
[
10,722
ha]
treated
with
Pic
combinations.
This
represents
only
3%
of
the
acreage
with
several
counties
showing
0
acres
treated.
Many
County
Ag
Commissions
discourage
or
prohibit
metam
sodium
applications
through
strict
permit
conditions,
the
result
of
several
fumigation
accidents
in
the
past.
Currently
in
many
counties
500
foot
buffers
are
required
around
metam
sodium
treated
fields
which
causes
many
fields
to
be
unsuitable
candidates
for
this
fumigant.
The
use
of
Pic
+
metam
applications
was
primarily
restricted
to
Orange
County
with
some
use
other
Counties
(
see
Table
1).
The
main
production
issue
with
using
metam
is
the
need
for
an
extended
plant
back
time
that
lengthens
the
time
needed
to
prepare
the
field
for
planting
by
up
to
2
weeks.
Pic
alone
applications
have
been
shown
to
be
less
efficacious
than
methyl
bromide
+
Pic,
Telone
+
Pic
or
Pic
+
metam
sodium.
In
the
northern
districts,
where
50%
(
Santa
Maria)
to
90%
(
Monterey/
Watsonville)
of
the
acreage
is
planted
to
day­
neutral
cultivars,
drip
fumigation
presents
significant
transitional
issues
due
to
the
need
to
switch
from
broadcast
to
bed
fumigation.
This
requires
a
significant
increase
in
setup
time
for
growers
prior
to
fumigation
and
results
in
a
loss
of
revenue
from
a
vegetable
crop
not
being
able
to
be
grown
in
rotation
with
the
strawberry
crop.
Recent
research
suggests
that
Pic
+
high
barrier
films
may
prove
to
be
a
viable
alternative.
The
Page
44
California
Strawberry
Commission
is
conducting
research
to
verify
these
results
and
working
with
the
regulators
to
allow
increased
use
of
straight
Pic
applications.

Table
21.
Pesticide
use
data
for
major
strawberry
production
regions
in
California,
2003
(
California
Department
of
Pesticide
Regulation
database).
County
Methyl
Bromide
Chloropicrin
1,3­
D
Metam
Sodium
Pic
only
(=
Pic
­
MB
­
1,3­
D)*
Hectares
treated
with
fumigant
San
Diego
188
230
7
0
34
Orange
365
676
25
38
286
Ventura
3003
3467
348
301
116
Santa
Barbara
923
1665
672
24
70
San
Luis
Obispo
17
256
238
0
1
Monterey
2662
3317
596
0
59
Santa
Cruz
1006
1111
115
3
­
10
total
8164
10722
2001
366
556
%
of
total
(
Pic)
76%
100%
19%
3%

*
negative
values
are
due
to
recording
errors
in
California
Department
of
Pesticide
Regulation
database
Question
28.
The
CUN
noted
that
producers
of
day­
neutral
cultivars
like
Diamonte
could
miss
early
market
windows
due
to
longer
equipment
set­
up
time
for
drip
application
and/
or
reduced
harvest
period,
However,
the
Party
noted
that
this
is
not
a
serious
problem
for
short
day
cultivars,
such
as
Camaresa.
MBTOC
notes
that
chloropicrin
alone
and
chloropicrin
mixtures
are
being
adopted
for
strawberry
fruit,
particularly
in
the
south,
where
short
day
cultivars
are
grown
(
PUR
data
cited
in
Trout
and
Damodaran
2004;
California
Strawberry
Commission
2005).
The
Party
is
requested
to
clarify
the
scope
for
additional
adoption
of
chloropicrin
and/
or
chloropicrin
÷
metham
for
short
day.
cultivars.

ANSWER:
While
Northern
California
growers
of
short
day
strawberry
varieties
have
some
latitude
in
planting
dates,
yield
of
short
day
cultivars
planted
in
the
southeastern
U.
S.
are
dependent
on
proper
time
of
planting.
Therefore,
the
MB
nomination
for
this
sector
is
critical
for
the
2007
growing
season.
Without
MB,
high
rates
of
chloropicrin
would
extend
the
plant­
back
time,
which
is
critical
in
key
strawberry­
growing
regions
(
Hamill
et
al
2004).
The
Southeastern
Strawberry
Consortium
addressed
the
issue
of
the
importance
of
timing
of
plantback
for
their
industry
(
http://
www.
smallfruits.
org/
Strawberries/
production/
2003SEstrawberryNarrativeFinal.
pdf):

Upper
Coastal
Plain
and
Lower
Central
Piedmont
strawberry
acreage
in
North
Carolina
must
be
planted
from
25­
Sept
to
1­
Oct
for
growers
in
this
area
to
achieve
the
kinds
of
yields
that
we
are
Page
45
representing (
20,600
lb/
A)
[
23,100
kg/
ha].
Outsiders
to
our
industry
are
often
surprised
to
learn
that
even
an
extra
week
of
delay
in
planting
for
the
popular
`
short
day'
type
strawberry
cultivars
Chandler,
Camarosa
and
Sweet
Charlie,
can
result
in
reductions
in
yield
potential
of
15­
20%,
or
more.
A
two
week
delay
could
potentially
reduce
yields
by
50%,
especially
in
a
colder
than
normal
fall
and
winter
conditions,
such
as
the
in
2000­
2001
season.
In
fact,
at
the
Clayton
Central
Crops
Research
Station
(
Upper
Coastal
Plain)
in
a
2002­
2003
strawberry
plasticulture
fumigation
study
involving
Telone
C­
35
at
30
gal/
A
[
278
L/
ha],
iodomethane
98:
2
at
150
lb/
A
[
168
kg/
ha]
and
iodomethane
98:
2
at
120
lb/
A
[
135
kg/
ha],
it
was
learned
that
by
planting
on
27­
Sep­
02
we
achieved
an
overall
marketable
yield
of
21,791
lb/
A
[
24,436
kg/
ha]
vs.
17,492
[
19,615
kg/
ha]
for
4­
Oct­
02
and
10,287
lb/
A
[
11,536
kg/
ha]
for
planting
on
11­
Oct­
02
(
averaged
over
all
3
fumigants).
This
represents
an
actual
reduction
in
yield
of
nearly
20%
for
a
1­
week
delay
and
52%
for
a
2­
week
delay
for
Chandler
fruit
harvested
in
April­
May
2003
(
unpublished
report
 
Poling
and
Schiavone).
In
addition,
iodomethane
at
150
lb/
A
[
168
kg/
ha]
(
75
lb/
A
in
the
bed)
[
84
kg/
ha]
produced
a
statistically
significant
higher
yield
than
Telone
C­
35,
and
was
statistically
no
different
than
the
120
lb/
A
[
135
kg/
ha]
rate
(
Iodomethane
98:
2)
 
suggesting
some
important
cost
savings
are
possible
with
shank
injection
of
this
fumigant.
The
anticipated
label
for
Iodomethane
98:
2
will
permit
a
1
week
plant­
back 
At
this
stage,
only
MBC­
33
(
2
week
plant­
back),
or
iodomethane
98:
2
(
1
week
plant­
back
 
assuming
that
this
product
receives
EPA
registration
in
Sep­
03)
[
it
did
not]
will
permit
growers
to
achieve
a
timely
planting,
assuming
that
the
fumigation
is
completed
in
mid­
September.

The
California
Strawberry
Commission
provided
the
following
clarification:

The
California
Strawberry
Commission
is
working
aggressively
to
verify
the
suitability
of
Pic
+
high
barrier
films
and
overcome
regulatory
barriers
to
the
use
of
straight
Pic
applications.
The
key
to
improving
local
permit
conditions
for
the
use
of
Pic
may
be
through
reduced
emissions.
If
Pic
can
be
retained
within
the
treated
bed
for
sufficiently
long
it
will
degrade
(
2
day
half
life),
dramatically
reducing
emissions.
Research
on
the
use
of
high
barrier
films,
salt/
water
furrow
seals
and
other
technology
is
under
consideration
by
the
Commission
and
should
prove
helpful
in
obtaining
more
permissive
local
permit
conditions
for
using
Pic
and
other
alternatives.
The
same
methods
should
be
useful
in
reducing
emissions
of
Telone,
leading
to
a
significant
increase
in
the
amount
of
acres
that
can
be
treated
with
Telone
within
the
township
cap
restrictions.

Question
29.
Regarding
hilly
terrain,
MBTOC
acknowledges
that
current
methods
of
drip
application
may
not
be
appropriate.
MBTOC
is
aware
that
pressure,
compensated
drip
application
systems
are
used
in
parts
of
the
world,
and
requests
if
there
are
any
issues
affecting
their
adoption
on
some
parts
of
the
hilly
terrain,

ANSWER
Because
the
technology
for
this
problem
has
not
been
fully
field­
tested,
MB
will
be
critical
for
the
2007
season.
The
California
Strawberry
Commission
provided
the
following
clarification
to
MBTOC:

This
represents
an
increase
in
cost
and
the
adaptation
of
new
technology
that
requires
transitional
time.
There
are
questions
about
the
effectiveness
of
such
systems.
We
will
further
investigate
this
Page
46
option
with
Dr.
Tom
Trout
who
has
an
extensive
understanding
of
the
drip
irrigation
systems
used
on
strawberry
in
California."

Question
30.
MBTOC
considers
that
alternatives
appear
to
be
available
for
some
part
of
the
buffer
zones,
which
are
not
subject
to
heavy
nutsedge
pressure
(
e.
g.
Pic
formulations
metham
+
Pie),
so
is
seeking
further
information
about
the
potential
area
that
could
adopt
such
alternatives.

Answer:
Only
a
small
portion
of
the
buffer
zone
would
be
available
for
alternatives,
and
the
MB
use
for
this
sector
would
not
be
effectively
different
than
the
2007
nomination.
According
to
experts
at
the
Department
of
Horticulture,
North
Carolina
State
University:
"
There
is
a
potential
for
use
of
both
metham
+
Pic
in
approximately
10%
of
the
buffer
zones
which
are
not
subject
to
heavy
nutsedge,
and
this
option
will
be
pursued
by
1­
2%
of
the
growers
in
the
Consortium
in
2006
under
the
guidance
of
North
Carolina
State
University
researchers
and
Extension
workers
(
under
a
grant
from
USDA).
There
is
no
opportunity
to
utilize
Chloropicrin
alone
due
to
its
poor
control
of
any
weeds."

Question
31.
For
Florida,
the
Party
states
that
at
moderate
to
severe
pest
pressure
(
primarily
nutsedge
on
30­
40%
of
area),
protocols
for
commercial
application
of
alternatives
have
not
been
sufficiently
developed
to
be
implemented
for
the
2007
season.
However
no
recent
trial
data
was
provided
to
MBTOC
to
substantiate
the
information.
Please
provide.

ANSWER:
The
Party
maintains
that
regulatory
restrictions
and
technical
feasibility
prevent
the
implementation
of
alternatives
in
critical
areas
by
strawberry
farmers
for
the
2007
season.
The
use
of
1,3­
D
is
restricted
as
an
alternative
to
MB
in
areas
with
karst
geology.
Maps
showing
areas
of
karst
geology
in
Florida
are
available
online
http://
www.
caves.
com/
fss/
pages/
misc/
images/
karst_
map.
gif,
http://
www.
dep.
state.
fl.
us/
geology/
geologictopics/
sinkhole.
htm,
and
(
http://
www2.
nature.
nps.
gov/
nckri/
map/
maps/
engineering_
aspects/
davies_
map_
PDF.
pdf).
The
proportion
of
the
current
Florida
strawberry
crop
that
should
not
use
1,3­
D
because
of
karst
geology
is
not
known
exactly
but
appears
to
be
high
in
the
major
strawberry­
growing
areas
of
Florida
(
see
map).
These
areas
are
concentrated
within
a
40
km
radius
of
Plant
City,
Florida
on
approximately
2,760
ha
(
2002
estimate;
see
Rosskopf
et
al.,
2005)
in
an
increasingly
populated
region
between
Tampa
and
Orlando.
Much
of
this
area
sits
on
limestone
at,
or
near,
the
surface
(
Rosskopf
et
al
2005)
(
http://
www.
caves.
com/
fss/
pages/
misc/
images/
karst_
map.
gif).

Another
alternative,
VIF
tarp
technology,
is
being
actively
researched.
Recently,
Noling
and
Gilreath
(
2004)
reported
on
demonstration
trials
comprising
17
commercial
strawberry
fields
that
were
conducted
by
growers
from
2000­
2004.
Results
of
these
trials
allowed
the
evaluation
of
the
use
of
VIF
and
its
efficacy
when
used
in
combination
with
reduced
rates
of
MB.
Results
were
promising
from
a
pest
management
perspective,
but
conclusions
reached
concerning
the
technical
aspects
of
VIF
are
consistent
with
the
Party's
contention
that
for
the
2007
season,
MB
is
critical
for
strawberry
farmers
in
Florida.
According
to
Noling
and
Gilreath:
Page
47
At
many
of
the
demonstration
sites,
problems
were
incurred
during
the
plastic
laying
operation,
in
that
tractor
speeds
needed
to
be
reduced
as
low
as
2
to
3
mph
[
3­
5
kph],
rather
than
4
to
5
mph
[
6.4­
8
kph],
to
properly
install
the
plastic.
Since
the
VIF
plastics
are
not
embossed,
they
have
a
tendency
to
slip
from
under
the
rear
press
wheels
during
installation
causing
stoppages
in
the
plastic
laying
operation.
Since
the
VIF
mulch
lack
`
stretch'
characteristics,
utilizing
marginally
wider
spool
widths
of
plastic
than
typically
used
have
improved
laying
characteristics
in
the
field.
There
is
also
no
question
that
these
new
VIF
mulches
will
be
more
expensive
(
2x)
in
terms
of
material
and
labor
costs
to
install
It
should
also
be
recognized
that
these
slower
tractor
speeds
can
also
create
a
flow
metering
problem
for
accurate,
uniform
dispensing
of
methyl
bromide;
thereby
requiring
some
possible
changes
in
application
equipment
(
Noling
and
Gilreath
2004).

IX.
Tomatoes:

Question
32.
The
Party
provided
limited
information
on
recent
trials
conducted
in
the
US
especially
those
using
VIF
films
and
new
application
methods
for
alternatives.
MBTOC
also
requests
the
Party
to
review
the
use
rates
used
with
MB/
Pic
mixtures
and
verify
that
mixtures
with
less
MB
(
especially
30:
70
and
50:
50)
are
unsuitable
for
control
of
the
key
pests
in
the
nomination.

ANSWER:
Several
members
of
MBTOC
and
the
USG
were
recently
able
to
tour
field
research
sites
in
Florida
and
Georgia
including
the
plots
of
Dr.
Gilreath.
During
those
discussions
and
in
his
recent
research
publications
(
Gilreath
et
al
2005,
Gilreath
et
al
in
press,
and
Gilreath
&
Gilreath
2005)
the
improved
pest
control
when
using
virtually
impermeable
film
(
VIF)
or
metalized
films
(
using
an
aluminum
layer
such
as
Canslit)
was
described.
Dr.
Gilreath
and
other
researchers
were
contacted
on
the
topics
of
low
permeability
barrier
films,
and
newer
application
techniques.
Based
on
their
input
it
appears
that
VIF
films
have
still
not
been
widely
adopted
because
of
problems
in:
laying
the
films,
inelasticity
and
the
resultant
difficulty
in
conforming
to
the
bed
shape,
problems
with
linear
shear,
and
the
fact
that
embossed
films
are
not
available.
The
current
versions
of
metalized
films
are
being
widely
tested
by
several
researchers
and
growers
and
they
have
the
potential
to
reduce
fumigant
use
rates
with
better
laying
and
bedshape
conforming
characteristics.
It
is
anticipated
that
the
results
of
many
of
these
research
plots
and
growers
field
tests
will
be
available
next
year.
These
metalized
films
pose
several
questions
for
adoption:
the
fate
of
the
aluminum
coating
if
it
"
flakes
off"
on
the
soil
during
removal
and
the
photostability
of
the
coating
during
multiple
crop
cycles
as
is
common
in
the
southeastern
U.
S.
An
additional
concern
with
all
of
the
low
permeability
films
and
reduced
use
rates
is
poor
uniformity
of
treatment
unless
the
application
equipment
must
be
redesigned
to
accommodate
reduced
flow
rates
and
pressure
(
Gilreath
and
Gilreath
2005).
While
all
of
these
results
are
promising
there
are
only
a
few
researchers
that
have
multi­
year
trials
with
these
films
and
new
or
modified
application
equipment.
Many
growers
are
said
to
be
testing
the
new
films,
reduced
rates
of
methyl
bromide,
and
other
alternatives.
Without
multi­
year
trials
under
a
range
of
environmental
conditions
the
consistency,
feasibility,
and
adaptability
cannot
be
assessed.

When
evaluating
research
cited
by
MBTOC
(
Gilreath
et
al,
2003)
the
untreated
control
at
the
Bradenton
site
had
53
nutsedge
(
Cyperus
rotundus)
plants
per
square
yard,
while
the
Immokalee
site
had
fewer
than
one
plant
per
square
yard.
The
current
standard
that
the
US
recommends
for
moderate
nutsedge
pressure
is
5
to
30
plants
per
square
yard.
At
the
Bradenton
site
the
nutsedge
Page
48
control
was
not
significantly
different
between
MeBr:
Pic
(
350
lb
per
acre)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
but
had
39%
more
nutsedge
plants
and
a
17%
reduction
in
yield.
When
comparing
the
same
treatments
at
Immokalee,
which
had
and
no
significant
difference
in
Fusarium,
or
nematodes
(
such
as
Meloidogyne
spp,
Belonolainus
spp.
and
Tylenchorhynchus
spp.),
but
low
nutsedge
pressure
(<
1
plant
per
square
yard),
there
was
still
a
12.5%
reduction
in
yield
compared
to
methyl
bromide.

Question
33.
Also
it
is
requested
that
economic
data
be
provided
for
the
two
most
appropriate
alternatives
for
all
circumstances
of
the
nomination.

ANSWER:

Those
data
were
provided
in
the
tomato
sector
report
and
are
reproduced
below:

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

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

21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
REGION
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
CALIFORNIA
Methyl
Bromide
100
$
50,240
$
50,240
$
50,240
Metam
Sodium
85
$
46,353
$
46,353
$
46,353
Metam
Sodium
80
$
44,626
$
44,626
$
44,626
MICHIGAN
Methyl
Bromide
100
$
30,559
$
30,559
$
30,559
1,3
 
D
+
Chloropicrin
78
$
29,555
$
29,555
$
29,555
Metam
Sodium
78
$
29,739
$
29,739
$
29,739
Chloropicrin
78
$
29,555
$
29,555
$
29,555
SOUTHEASTERN
US
Methyl
Bromide
100
$
26,380
$
26,380
$
26,380
Page
49
1,3
 
D
+
Chloropicrin
83
$
24,946
$
24,946
$
24,946
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
e.
g.
10%
more
yield,
write
110.

22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)

CALIFORNIA
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%)
$
70,862
$
24,509
Metam
Sodium
(
20%)
$
66,694
$
22,068
MICHIGAN
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
Chloropicrin
$
32,880
$
3,325
SOUTHEASTER
N
US
Methyl
Bromide
$
40,914
$
14,533
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)

CALIFORNIA
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%)
$
70,862
$
24,509
Metam
Sodium
(
20%)
$
66,694
$
22,068
MICHIGAN
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
Chloropicrin
$
32,880
$
3,325
SOUTHEASTERN
US
Methyl
Bromide
$
40,914
$
14,533
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)

CALIFORNIA
Methyl
Bromide
$
83,367
$
33,127
Page
50
Metam
Sodium
(
15%)
$
70,862
$
24,509
Metam
Sodium
(
20%)
$
66,694
$
22,068
MICHIGAN
Methyl
Bromide
$
39,996
$
9,438
1,3
 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
Chloropicrin
$
32,880
$
3,325
SOUTHEASTERN
US
Methyl
Bromide
$
40,914
$
14,533
1,3
 
D
+
Chloropicrin
$
33,772
$
8,825
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
METAM
SODIUM
PRODUCTION
LOSS
(%)
0%
15%
20%

PRODUCTION
PER
HECTARE
11,532
9,802
9,225
*
PRICE
PER
UNIT
(
US$)
$
7.17
$
7.17
$
7.17
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
82,719
$
70,311
$
66,175
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
57,004
$
49,990
$
48,197
=
NET
REVENUE
PER
HECTARE
(
US$)
$
25,712
$
20,321
$
17,978
FIVE
LOSS
MEASURES
*
1.
LOSS
PER
HECTARE
(
US$)
$
­
$
5,391
$
7,733
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
22
$
32
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
7%
9%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
OPERATING
REVENUE
(%)
0%
21%
30%

5.
OPERATING
PROFIT
MARGIN
(%)
40%
29%
27%

**
Note
that
the
measures
in
the
tables
below
must
be
interpreted
carefully.
Operating
costs
do
not
include
fixed
costs
and
net
revenue
equals
gross
revenue
minus
operating
costs.
Page
51
MICHIGAN
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
METHYL
BROMIDE
1,3­
D
+
PIC
METAM
SODIUM
CHLOROPICRIN
PRODUCTION
LOSS
(%)
0%
6%
13%
6%

PRODUCTION
PER
HECTARE
4,414
4,132
3,845
4,132
*
PRICE
PER
UNIT
(
US$)
$
9.44
$
9.44
$
9.44
$
9.448
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
41,652
$
38986
$
36,279
$
38986
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
37,055
$
32453
$
31,170
$
32,453
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4596
$
6,533
$
5,109
$
6,533
FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
­
$
1,937
$
512
$
1,937
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
16
$
4
$
16
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
5%
1%
5%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
OPERATING
REVENUE
(%)
0%
42%
11%
42%

5.
OPERATING
PROFIT
MARGIN
(%)
11%
17%
14%
17%

**
Note
that
the
measures
in
the
tables
below
must
be
interpreted
carefully.
Operating
costs
do
not
include
fixed
costs
and
net
revenue
equals
gross
revenue
minus
operating
costs.
Page
52
SOUTHEASTERN
US
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
US
METHYL
BROMIDE
1,3­
D
+
PIC
PRODUCTION
LOSS
(%)
0%
6%

PRODUCTION
PER
HECTARE
4,551
4,269
*
PRICE
PER
UNIT
(
US$)
$
10
$
10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
46,986
$
44,073
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
26,660
$
29,860
=
NET
REVENUE
PER
HECTARE
(
US$)
$
20,326
14,212
FIVE
LOSS
MEASURES
*

1.
LOSS
PER
HECTARE
(
US$)
$
­
$
6,113
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
­
$
36
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
13%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
OPERATING
REVENUE
(%)
0%
30%

5.
OPERATING
PROFIT
MARGIN
(%)
43%
32%

**
Note
that
the
measures
in
the
tables
below
must
be
interpreted
carefully.
Operating
costs
do
not
include
fixed
costs
and
net
revenue
equals
gross
revenue
minus
operating
costs.

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

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

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

(
1)
Loss
per
Hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.
Page
53
(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production.

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

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

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

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
tomato
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

California
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
California
tomato
production.
We
have
quantified
the
economic
conditions
of
tomato
growers
as
best
as
possible
but,
primarily
due
to
limited
data
availability,
are
unable
to
capture
every
aspect
of
the
economic
picture
in
our
numeric
analysis.
Factors
not
accounted
for
in
this
analysis
are
distribution
of
yield
loss
across
individual
growers
and
the
yield
risk
associated
with
using
MeBr
alternatives.

Michigan
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Michigan
tomato
production.
Three
factors
have
proven
most
important
in
our
conclusion.
These
are
yield
loss,
quality
loss,
and
missed
market
windows.

Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
tomato
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
Page
54
possible
quantity
of
tomatoes
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
tomato
operations.

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

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

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

To
describe
these
conditions
in
Southeastern
US
tomato
production,
we
used
weekly
tomato
sales
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
three
years
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
we
assume
that
if
tomato
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
accumulate
gross
revenues
reduced
by
approximately
12%.
We
reduced
the
season
average
price
by
12%
in
our
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
we
believe
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Southeastern
US.

Question
34.
In
Michigan,
the
key
pests
are
Phytophthora
capsici
and
Verticillium.
The
Party
states
that
1,3­
Dichloropicrin
may
be
an
effective
alternative
but
growers
will
miss
the
optimal
market
window.
The
Party
is
requested
to
clarify
why
this
problem
cannot
be
overcome
by
scheduling
fumigations
in
autumn
prior
to
the
crop.

ANSWER:
The
proposal
by
MBTOC
to
obviate
the
use
of
methyl
bromide
in
Michigan
by
applying
some
alternative
(
specifically
a
combination
of
1,3­
D
and
chloropicrin)
in
the
autumn
preceding
crop
planting
will
not
work
on
tomatoes.
In
Michigan,
the
predominant
agricultural
treatment
that
uses
methyl
bromide
is
one
where
methyl
bromide
is
applied
in
strips
of
raised
beds.
Areas
between
the
Page
55
raised
beds
are
not
treated.
In
addition
to
the
risk
that
the
harsh
winter
conditions
(
prolonged
periods
of
below
freezing
weather
with
snow,
sleet,
and
high
winds)
will
tear
the
plastic
barrier,
there
is
significant
risk
of
flooding
and
concomitant
recontamination
of
the
treated
areas.
The
length
and
severity
of
the
winter
means
4­
5
months
of
precipitation
is
`
stored'
in
frozen
form
and
released
over
the
short
period
of
thaw
in
the
spring.
This
thaw­
based
flooding
can
be
exacerbated
by
heavy
rainfalls
(
in
excess
of
25
mm/
event)
that
occur
throughout
the
spring
and
summer
in
Michigan.
Because
Phytophthora
and
Verticillium
diseases
are
endemic
in
the
areas
of
Michigan
for
which
methyl
bromide
is
being
requested,
flooding
will
transfer
spores
from
the
untreated
to
treated
areas,
resulting
in
additional
infected
plants
and
severe
crop
losses.

There
are
two
additional
problems
which
prevent
a
fall
application
of
a
methyl
bromide
alternative
from
being
a
viable
alternative
to
the
current
practice.
Deer
walk
across
the
fields,
making
holes
in
the
plastic.
Mice
also
burrow
under
the
plastic.
Once
underneath
they
chew
the
drip
tapes,
rendering
them
inoperative
and
make
burrows
where
they
are
in
an
ideal
position
to
eat
the
newly
planted
material
in
the
spring.

Question
35.
In
the
Southeast,
including
Florida,
nematodes,
soil
borne
fungi
and
nutsedge
are
the
key
pests.
The
Party
states
that
a
combination
of
1,3D
+
chloropicrin
+
herbicides
(
trifluralin,
napropamide,
halosulfuron,
S­
metolachlor)
is
the
best
alternative
strategy,
but
further
testing
is
required.
However,
the
Party
estimates
yield
losses
of
6.2%
and
market
window
losses
of
14%
due
to
delays
in
plant
back
after
treatment.
This
combination
is
not
available
to
areas
with
karst
topography
(
32
%
of
the
production).
The
Party
is
requested
to
provide
yield
and
market
window
data
for
other
alternatives.

ANSWER:
Please
see
the
answer
to
question
33
above
Question
36.
Owing
to
the
lack
of
data
from
recent
trials
in
the
south
east
region
provided
with
the
nomination,
MBTOC
cannot
fully
evaluate
the
effectiveness
of
alternatives
for
moderate
to
heavy
nutgrass
infestations.
New
technical
review
and
economic
data
based
on
the
yields
from
recent
studies
is
requested.

ANSWER:
In
Florida
Gilreath
et
al
2003
looked
at
methyl
bromide
plus
chloropicrin
(
350
lb
per
acre
of
67:
33)
versus
1,3­
D­
35%
Pic/
trifluralin/
napropamide/
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
for
pepper
yield.
While
the
yields
were
not
significantly
different
there
was
a
14
to
13
percent
yield
loss
compared
to
methyl
bromide
plus
chloropicrin.
In
addition
this
alternative
treatment
with
additional
chemicals
will
require
extra
time
to
apply
the
other
pesticides
and
allow
the
second
application
of
chloropicrin
to
off
gas
so
that
the
transplants
are
not
killed.
This
additional
time
delay
would
lead
to
impacts
in
terms
of
the
key
market
windows.

Table
22.
Tomato
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large
Bradenton
Immokalee
Treatment
Marketable
%
Yield
Marketable
%
Yield
Page
56
Yield
(
pound
per
10
plants)
Change
versus
MeBr
Yield
(
pound
per
10
plants)
Change
versus
MeBr
Untreated
51
­
56%
108
­
16%
Methyl
bromide:
chloropicrin
(
350
lb
of
67:
33)
117
0%
128
0%

1,3­
D­
35%
Pic
+
trifluralin
+
napropamide
+
chloropicrin
(
28
gal/
0.5
lb/
2
lb/
125
lb)
101
­
14%
112
­
13%

Footnote:
From
Gilreath
et
al.
2003.
Proc.
Fla.
State
Hort.
Soc.

One
of
the
studies
that
MBTOC
cites
is
from
Florida
(
Gilreath
et
al,
2005a),
which
looked
at
the
impact
of
reduced
rates
of
MB
on
pest
control
and
pepper
yield.
In
that
study,
which
had
high
Cyperus
spp.
pressure,
there
were
no
significant
differences
in
yield
between
any
of
the
rates
of
methyl
bromide
with
the
different
types
of
films.
However,
an
examination
of
the
change
in
yield
with
VIF
treatments,
compared
to
the
standard
MB
treatments,
suggests
significant
variability
within
treatments,
which
led
to
the
lack
of
statistical
significance
in
yield
despite
the
large
numerical
differences
in
yield
between
treatments.
Trials
such
as
those
conducted
by
Gilreath
et
al
(
2005
a)
with
peppers,
need
to
be
conducted
over
several
seasons,
and
preferably
with
different
crops.
The
reality
of
the
use
of
VIF
for
the
2007
season
is
its
current
prohibitive
cost
in
the
U.
S.,
and
even
more
significant,
its
lack
of
availability
for
use
on
a
commercial
scale.
The
Party
does
not
anticipate
these
issues
can
be
adequately
resolved
before
the
critical
use
season
of
2007.

Table
23.
Pepper
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large.
Treatment
App
Rate
kg/
ha
Yield
t/
ha
%
Change
1
Untreated
9.5
­
31%
2
MeBr
+
Pic
LDPE
392
13.8
0%
3
MeBr
+
Pic
VIFP
196
10.8
­
22%
4
MeBr
+
Pic
VIFP
98
13.6
1%
5
MeBr
+
Pic
VIFV
196
11.4
­
17%
6
MeBr
+
Pic
VIFV
98
11.9
­
14%
Footnote:
From
Gilreath
et
al.
2005.
Crop
Protection
24:
285­
287.
LDPE
is
low
density
polyethylene,
VIFP
and
VIFV
are
virtually
impermeable
film
by
Plastopil
and
Vikase
respectively.

The
research
plots
that
several
MBTOC
members
visited
in
Florida
in
2005
clearly
demonstrated
that
chloropicrin
will
not
control
sedges
such
as
Cyperus
esculentus
or
C.
rotundus
.
Research
by
Gilreath
and
communications
with
him
indicate
that
chloropicrin
enhances
nutsedge
germination
(
this
research
has
yet
to
be
repeated
for
other
pest
species).
Therefore,
increasing
the
amount
of
chloropicrin
applied
can
increase
pest
pressure
and
yield
loss.

Another
study
by
Gilreath,
Santos,
Motis,
Noling
and
Mirusso
(
2005)
looks
at
nematode
and
Cyperus
control
in
bell
pepper
(
Capsicum
annum).
In
that
study
the
authors
state
"
For
bell
pepper
Page
57
yield,
the
application
of
metam
sodium
and
metam
sodium
+
chloropicrin
provided
similar
fruit
weight
as
for
methyl
bromide
+
chloropicrin
in
two
of
the
three
seasons."
However,
in
that
one
year
(
Fall
2002)
the
yields
went
from
18.8
t/
ha
for
methyl
bromide
+
chloropicrin
to
13.7
t/
ha
for
metam
sodium
+
chloropicrin
or
a
27%
drop
in
yield.
This
level
of
yield
loss
could
have
severe
economic
impacts
for
a
grower.
Because
of
the
inconsistency
of
some
of
the
alternative
treatments
the
U.
S.
does
not
consider
them
to
be
a
replacement
for
methyl
bromide.
The
work
of
Johnson
and
Webster
(
2001)
as
described
in
Question
12
above
indicated
that
for
metam
sodium
the
time
of
application
before
transplanting,
rate,
and
type
of
incorporation
equipment
can
all
have
a
significant
impact
on
the
chemicals
performance.

Question
37.
Recent
references
available
to
MBTOC
demonstrate
effective
alternatives
(
metham
sodium,
with
and
without
Pic)
for
moderate
to
heavy
nutgrass
control
in
similar
regions
to
the
nomination
and
for
non­
karst
and
karst
areas
(
Johnson
and
Webster,
2001
;
Gilreath
et
a12005
b,
c).
As
yields
were
similar
to
methyl
bromide,
further
clarification
is
required
on
their
suitability
for
commercial
use,

ANSWER:
The
work
of
Johnson
and
Webster
(
2001)
published
in
Weed
Technology
describes
a
modification
to
a
power
tiller
for
improved
metham
application.
In
this
study
across
the
control
of
yellow
nutsedge
was
evaluated
with
the
untreated
control
areas
averaging
88
plants/
m2
and
across
all
tillage
treatments
and
cultivars,
there
was
an
average
of
2.7
nutsedge
plants/
m2
.
See
also
the
description
of
the
Gilreath
et
al
2005
research
in
question
36
above.

Question
38.
For
all
areas
the
dosage
range
is
close
to
or
below
MBTOC
guideline
rates:
Growers
may
be
able
to
reduce
dosages
to
about
100
kg/
ha
under
strips
by
adoption
of
low
permeability
barrier
films
(
VIF
or
equivalent)
and
by
adopting
formulations
of
MB/
Pic
with
less
MB
(
e.
g.
50:
50).
Recent
trials
are
evaluating
use
of
these
products
and
an
update
of
these
is
requested
to
further
assist
assessment
of
this
nomination.

ANSWER:
One
of
the
studies
that
MBTOC
cites
is
from
Florida
(
Gilreath
et
al,
2005a),
which
looked
at
the
impact
of
reduced
rates
of
MB
on
pest
control
and
pepper
yield.
In
that
study,
which
had
high
Cyperus
spp.
pressure,
there
were
no
significant
differences
in
yield
between
any
of
the
rates
of
methyl
bromide
with
the
different
types
of
films.
However,
an
examination
of
the
change
in
yield
with
VIF
treatments,
compared
to
the
standard
MB
treatments,
suggests
significant
variability
within
treatments,
which
led
to
the
lack
of
statistical
significance
in
yield
despite
the
large
numerical
differences
in
yield
between
treatments.
Trials
such
as
those
conducted
by
Gilreath
et
al
(
2005a)
with
peppers,
need
to
be
conducted
over
several
seasons,
and
preferably
with
different
crops.
The
reality
of
the
use
of
VIF
for
the
2007
season
is
its
current
prohibitive
cost
in
the
U.
S.,
and
even
more
significant,
its
lack
of
availability
for
use
on
a
commercial
scale.
The
Party
does
not
anticipate
these
issues
can
be
adequately
resolved
before
the
critical
use
season
of
2007.
Page
58
Table
24.
Pepper
yields
are
not
significantly
different
but
percent
yield
loss
can
be
large.
Treatment
App
Rate
kg/
ha
Yield
t/
ha
%
Change
1
Untreated
9.5
­
31%
2
MeBr
+
Pic
LDPE
392
13.8
0%
3
MeBr
+
Pic
VIFP
196
10.8
­
22%
4
MeBr
+
Pic
VIFP
98
13.6
1%
5
MeBr
+
Pic
VIFV
196
11.4
­
17%
6
MeBr
+
Pic
VIFV
98
11.9
­
14%
Footnote:
From
Gilreath
et
al.
2005.
Crop
Protection
24:
285­
287.
LDPE
is
low
density
polyethylene,
VIFP
and
VIFV
are
virtually
impermeable
film
by
Plastopil
and
Vikase
respectively.

The
research
plots
that
several
MBTOC
members
visited
in
Florida
in
2005
clearly
demonstrated
that
chloropicrin
will
not
control
sedges
such
as
Cyperus
esculentus
or
C.
rotundus
.
Research
by
Gilreath
and
communications
with
him
indicate
that
chloropicrin
enhances
nutsedge
germination
(
this
research
has
yet
to
be
repeated
for
other
pest
species).
Therefore,
increasing
the
amount
of
chloropicrin
applied
can
increase
pest
pressure
and
yield
loss.
Page
59
REFERENCES
Culpepper,
A.
S.
and
D.
B.
Langston.
2004.
Potential
impact
of
methyl
bromide
alternatives
on
Georgia's
pepper
industry.
Department
of
Crop
and
Soil
Sciences
and
Department
of
Plant
Pathology,
University
of
Georgia,
Tifton,
GA
31793.
E­
mail
message.

Culpepper,
A.
S.,
T.
M.
Webster,
D.
Langston.
2004
&
2005.
E­
mail
from
W.
T.
Kelley.
August
15,
2005.
Univ.
of
Georgia
Gilreath,
J.
P.
and
P.
R.
Gilreath.
2005.
Successful
use
of
reduced
rates
of
methyl
bromide
in
vegetable
crops.
Citrus
and
Vegetable
Magazine.
August
2005.

Gilreath,
J.
P.,
J.
P.
Jones,
T.
N.
Motis,
B.
M.
Santos,
J.
W.
Noling,
and
E.
R.
Rosskopp.
2003.
Evaluation
of
various
chemical
treatment
for
potential
as
methyl
bromide
replacements
for
disinfestations
of
soilborne
pests
in
polyethylene­
mulched
tomato.
Proc.
Fla.
State
Hort.
Soc.
116:
151­
158.

Gilreath,
J.
P.,
T.
N.
Motis,
and
B.
M.
Santos.
2005.
Cyperus
spp.
Control
with
reduced
methyl
bromide
plus
chloropicrin
doses
under
virtually
impermeable
films
in
pepper.
Crop
Prot.
24:
285­
287.

Gilreath,
J.
P.
B.
M.
Santos,
T.
M.
Motis,
J.
W.
Noling,
and
J.
M.
Mirusso.
(
2005)
Methyl
bromide
alternatives
for
nematode
and
Cyperus
control
in
bell
pepper
(
Capsicum
annul).
Crop
Prot.
24:
in
press.

Grey,
T.
L.,
A.
S.
Culpepper,
and
T.
M.
Webster.
2003.
Fall
vegetable
response
to
halosulfuron,
metolachlor,
and
sulfentrazone
spring
applied
under
plastic.
Proc.
Southern
Weed
Science
Society.
Volt
56:
116­
117.

Hamill,
J.
E.,
Dickson,
D.
W.,
T­
Our,
L.,
Allen,
L.
H.,
Burrell,
N.
K.,
and
Mendes,
M.
L.
2004.
Reduced
rates
of
MBR
and
C35
under
LDPE
and
VIF
for
control
of
soil
pests
and
pathogens.
2004
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
online
at
http://
www.
mbao.
org/
2004/
Proceedings04/
002%
20HamillJ%
20MBr%
20alternatives%
20abstr_
04.
pdf].

Johnson
III,
W.
C.
and
T.
M.
Webster.
2001.
A
Modified
Power
Tiller
for
Metham
Application
on
Cucurbit
Crops
Transplanted
to
Polyethylene­
Covered
Seedbeds.
Weed
Technology:
Vol.
15,
No.
2,
pp.
387
 
395
Johnson
III,
W.
C.
2003.
Yellow
nutsedge
control
with
metham­
sodium
in
transplanted
cantaloupe.
Proc.
Southern
Weed
Science
Society.
Volt
56:
109.
Page
60
Noling,
J.
W.
and
Gilreath,
J.
P.
2004.
Use
of
virtually
impermeable
plastic
mulches
(
VIF)
in
Florida
strawberries.
2004
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
online
at
http://
www.
mbao.
org/
2004/
Proceedings04/
001%
20Noling%
20paper.
pdf
Rosskopf,
E.
N.,
Chillum,
D.
O.,
Kokalis­
Burelle,
N.,
and
Church,
G.
T.
2005.
Alternatives
to
methyl
bromide:
A
Florida
perspective.
American
Phytopathological
Society.
APSnet
Feature,
June,
2005.
Available
online
at:
http://
www.
apsnet.
org/
online/
feature/
methylbromide/
Page
61
Appendix
I
Summary
of
Weyerhaeser
Company
Research
Summary
of
recent
(
2002­
2005)
Weyerhaeuser
Company
research
studies
concerning
MB,
fumigation
efficacy,
herbicides
and
alternatives
to
methyl
bromide
studies
that
pertain
to
the
submitted
questions.

2002
Weyerhaeuser
R&
D
Activities
on
Fumigation,
Disease
and
Trials
2003­
25
Fumigation
Alternative
Trial
(
Mima,
WA).
MBC
67:
33
(
350lbs/
ac)
was
tested
against
Triform
35(
400lbs/
ac
Telone
61.1%
PIC
35%
:
no
Metam
Sodium
applied
due
to
lack
of
application
equipment)
in
the
fall
2000.
Post
fumigation
testing
(
Study
2001­
25)
spring
2001
showed
no
significant
difference
in
soil
Fusarium
populations.
Soil
testing
in
the
fall
of
2002,
again
showed
very
low
levels
of
soil
Fusarium.
Root
infection
was
analyzed
several
months
into
1+
1
transplant
growing
season
(
August
2002).
Root
infection
by
Fusarium
was
low
and
not
significantly
different
between
treatments
(
1.9%
versus
2.5%
MBC
and
Triform
respectively).
Root
infection
by
Cylindrocarpon
was
significantly
lower
in
Triform
(
1.5%)
than
in
MBC
(
25.1%)
treated
plots.

Interpretations:
Soil
pathogen
assays
are
used
to
estimate
the
need
for
and
assess
the
efficacy
of
soil
fumigation
chemicals.
Based
on
this
and
previous
tests,
these
two
fumigants
appear
to
be
equal
in
efficacy.
Clearly,
this
study
indicates
that
reliance
on
a
single
bioassay
organism
(
Fusarium)
can
lead
to
this
conclusion,
while
tests
for
another
root­
pathogen
yield
somewhat
different
results.
Reliance
on
a
single
fumigant
agent
could
potentially
result
in
development
of
resistant
strains
or
selection
for
another
pathogen
agent.

2003­
25
Fumigation
Alternative
Trial
(
GHW,
NC).
MBC
98:
2,
Telone­
PIC,
and
PIC
fall
2001
fumigation
efficacy
was
tested
on
previous
soils
left
bare
fallow
for
6­
months.
Soils
and
seedlings
were
analyzed
for
pathogen
levels
in
the
fall
of
2002.
There
was
no
significant
difference
in
soil
Fusarium
levels
detected
at
lift
(
128,
156,
and
98
CFU/
g
respectively).
Seedling
root
infection
severity
was
also
low
(
6%,
6.8%,
8.6%
respectively)
and
not
significantly
different
between
treatments.
No
Pythium
was
detected
in
soil
or
seedling
assays.

Interpretations:
Under
these
ideal
fall
fumigation
conditions,
low
pre­
fumigation
pathogen
populations,
low
weed
pressure,
and
methods
of
application,
MBC,
Telone­
PIC
and
PIC
are
acceptable
alternatives
as
soil
fumigants.
Page
62
2002­
5,6,7,8
Pre­
Sow
Pathogen
Testing
(
N.
C.,
AR.,
S.
C.,
AL).
Soil
pathogen
testing
shows
variable
spring
2002
Fusarium
populations
prior
to
sowing
at
four
facilities.
Samples
were
compared
against
the
fumigation
management
threshold
of
<
1000
CFU/
g
soil).
Pine
Hill
nursery
shows
5/
18
samples
within
the
threshold
(
top
range
508­
1142
CFU/
g
soil).
GHW
samples
(
n=
6)
all
tested
below
the
threshold
(
all
samples
<
417
CFU/
g
soil).
Aiken
had
3/
13
areas
test
within
the
threshold
(
range
700­
1500
CFU/
g
soil).
Magnolia
reported
with
8/
10
within
the
threshold
(
range
595­
3825
CFU/
g
soil).

Interpretations:
Sow
ground
should
be
managed
below
1000
CFU/
g
Fusarium
in
the
spring
to
achieve
a
healthy
pine
crop.
Soil
testing
of
potential
crop
areas
can
help
to
identify
areas
that
should
be
further
tested
for
pathogen
uniformity
or
left
fallow.
Disease
avoidance
is
another
mechanism
of
preventative
action
when
sow
acreage
is
not
limited,
too
little
time
remains
for
safe
and
effective
fumigation,
or
areas
of
unexpected
disease
develop
2002­
15
Post­
Fumigation
Testing
(
S.
C).
Soil
pathogen
testing
in
the
spring
following
fall
application
of
MBC
98:
2
shows
detectable
Fusarium
levels
in
8/
12
sample
locations
(
range
CFU/
g
27­
365
).

Interpretations:
Re­
invasion
of
fumigated
soil
can
occur
from
above
and
below
the
fumigation
treatment
profile.
Good
soil
sanitation
processes
are
needed
to
limit
cross­
contamination
of
treated
and
non­
treated
fields
by
equipment,
overland
water
and
soil
movement,
and
incorporation
of
nontreated
edge
soils
into
treated
areas.

2002­
20
Alternative
Fumigant
Testing
(
AR).
Continuation
of
Studies
(
2000­
47,
54,
Study
2002­
31)
Soil
pathogen
testing
following
fall
2000
application
of
MBC
(
98:
2),
PIC
(
100%)
and
Telone­
PIC
(
70:
30)
showed
no
significant
difference
in
post
treatment
efficacy
in
areas
that
contained
low­
threshold
levels
of
soil
Fusarium
(
pre­
treatment
levels;
MBC
272­
1170
CFU/
g;
PIC
0­
798
CFU/
g;
and
Telone­
PIC
0­
506
CFU/
g
soil
respectively).
At
pre­
sow
2001,
Fusarium
was
detected
in
3/
10,
1/
10,
and
1/
10
sample
locations
for
MBC,
PIC,
and
Telone­
PIC
respectively
(
levels
44­
431
CFU/
g
soil).
Sampling
resumed
spring
2002
following
the
2001
pine
crop
cycle.
Soil
Fusarium
levels
were
similar
in
all
three
treatment
areas
(
MBC
243
CFU/
g,
PIC
140
CFU/
g,
and
Telone­
PIC
261
CFU/
g
soil).
Seedling
root
infection
by
Fusarium
was
not
significantly
different
between
treatments,
but
a
trend
towards
higher
root
infection
occurred
between
MBC
(
19%
root
infection),
PIC
(
17%)
and
Telone­
PIC
(
10%).

Interpretations:
MBC,
PIC
and
Telone­
PIC
produce
equivalent
fumigation
results
across
management
blocks
with
low­
threshold
levels
of
Fusarium
as
the
target
organism.
The
longer­
term
crop
to
crop
rotation
length
based
on
soil
Fusarium
population
dynamics
appears
similar
when
these
agents
are
used
in
the
prescribed
manner.
Page
63
2002­
49
Fumigation
Efficacy
(
GHW,
NC).
Routine
sampling
post­
fumigation
soil
pathogen
analysis
was
done
to
test
the
efficacy
of
contractor
applied
MBC
98:
2.
Some
40%
of
the
samples
returned
detectable
levels
of
Fusarium
(
43­
362
CFU/
g)
one
month
post
fumigation.
These
soils
were
retested
again
in
March
2003
as
part
of
Study
2003­
1.
These
results
also
confirmed
some
residual
Fusarium
populations
post­
fumigation.

Interpretations:
Complete
control
of
soil
pathogen
populations
is
essential
to
initiation
of
the
next
3­
4
seedling
crop
cycles.
The
detected
pathogen
pattern
might
reflect
under
treated
areas,
overlaps
zones
of
tarping,
fumigation
strips,
edge
effects,
and
or
soil
and
water
movement
post
fumigation
(
wind,
water,
mechanical).
These
issues
will
be
more
critical
with
less
effective
fumigants
and
potentially
result
in
larger
"
under
treated"
areas.

2002­
50
Fumigation
Efficacy
(
S.
C.).
Routine
sampling
post­
fumigation
soil
pathogen
analysis
was
done
to
test
the
efficacy
of
contractor
applied
MBC
98:
2
in
two
management
units.
Pivot
1­
5
showed
½
of
the
area
with
a
post­
treatment
efficacy
of
65­
80%
and
100%
in
the
remaining
areas.
Pivot
1­
6
showed
53­
84%
efficacy
on
½
of
the
area
with
the
remaining
sample
at
100%.

Interpretations:
Incomplete
efficacy
of
MBC
is
often
linked
to
failure
to
achieve
label
rates
due
to
penetration
or
retention
issues.
The
cause
was
not
investigated
at
the
time
of
the
fumigation,
but
appears
to
be
a
common
practice
with
the
fumigation
being
done
in
any
given
year.

2002­
51
Pathogen
Testing
(
Pine
Hill
AL).
Routine
pre­
fumigation
soil
pathogen
analysis
was
done
to
test
crop
areas
in
three
production
blocks.
Block
1
(
909
CFU/
g
soil)
and
Block
2
(
668
CFU/
g)
showed
much
elevated
Fusarium
levels
than
Block
4
at
173
CFU/
g.

Interpretations:
Variation
in
soil
Fusarium
populations
increase
following
the
period
since
last
fumigation.
Historical
data
along
with
new
specific
sampling
information
from
specific
nursery
blocks
are
the
best
management
tool
to
decide
on
when
and
where
to
fumigate.

2003­
25
Fumigation
Versus
Bare­
Fallow
(
Mima,
WA).
Block
8
was
spring
fumigated
with
350lb/
ac
MBC
(
67:
33)
following
1­
year
in
bare­
fallow
(
Roundup
Treated
Spring
2002).
The
field
had
been
previously
cropped
for
1­
year
following
MBC
fumigation,
then
allowed
to
remain
fallow
through
the
next
crop
year
and
brought
back
into
crop
rotation
in
the
spring
of
2002.
Roundup
(
Glyphosate)
was
applied
30
days
prior
to
fumigation
to
kill
surface
weeds.
Soil
and
root
residual
pathogen
analysis
(
Fusarium,
Pythium,
Cylindrocarpon)
was
conducted
prior
to
fumigation
planning.
These
results
showed
no
detectable
pathogen
population
on
2/
3rd
of
the
field,
but
some
elevated
levels
on
a
normally
wet
end,
some
150
feet
in
length.
MBC
67:
33
was
applied
to
the
wet
area
and
tarped.
Douglas­
fir
1­
year
old
seedlings
were
transplanted
in
spring
2002
to
grow
1+
1
regeneration
stock.
Page
64
Severe
stem
and
needle
stunt
symptoms
began
to
develop
in
late­
June
and
into
July
in
the
nonfumigated
portions
of
the
field.
Soil
and
foliar
analysis
did
not
detect
any
nutrient
based
causal
factors.
Root
necrosis
associated
with
elevated
levels
of
Cylindrocarpon
didymum
and
Fusarium
oxysporum
on
transplants
were
determined
to
be
the
most
likely
pathogen
agents.
All
attempts
to
correct
seedling
growth
and
development
with
fertilizers,
fungicides,
and
irrigation
failed.
Substantial
portions
of
the
field
seedlings
did
not
meet
regeneration
standards,
and
had
to
be
destroyed.
The
fumigation
portion
was
nearly
90+%
packable.

Interpretations:
1­
year
bare
fallow
was
insufficient
to
reduce
disease
levels
below
thresholds
for
disease
development.
Glyphosate,
although
an
effective
herbicide
on
surface
weeds
may
also
play
a
synergistic
role
in
plant
disease
development,
by
interfering
with
normal
plant
phenolic
metabolism.
Soil
and
root
residual
pathogen
testing
is
not
always
a
reliable
measure
of
soil
disease
potential.
Page
65
2003
Weyerhaeuser
R&
D
Activities
on
Fumigation,
Disease
and
Trials
2003­
2
Fumigation
Threshold
Testing
(
AR).
Areas
of
Blocks
7,
8,
and
10
were
sampled
for
Fusarium
levels
to
indicate
the
need
for
fumigation.
Two
units
within
Block
10
contained
sufficient
Fusarium
(
800­
1400
CFU/
g
soil)
to
justify
soil
fumigation.

Interpretations:
Soil
pathogen
assays
are
used
to
estimate
the
need
for
and
assess
the
efficacy
of
soil
fumigation
chemicals.
Based
on
this
sample,
much
of
the
crop
area
would
not
benefit
from
soil
fumigation
at
this
time.

2003­
12
Fumigation
Threshold
Testing
(
S.
C.).
Soil
sampling
across
portions
of
Pivot
3
show
variable
levels
of
soil
Fusarium.
Three
of
18
areas
tested
greater
than
400
CFU/
g
soil,
where
the
decision
to
fumigation
can
sometimes
begin.

Interpretations:
The
soil
sampling
method
and
testing
allows
for
the
planning
for
most
effective
use
of
MBC
in
the
nursery.
This
pivot
area
needs
to
be
resampled
to
determine
the
validity
of
high
soil
Fusarium
levels
detected
in
portions
of
a
production
field,
while
other
areas
appear
to
be
safe
for
cropping.

2003­
18
Fumigation
Threshold
Testing
(
AL).
Soil
sampling
across
portions
of
Blocks
10
and
19
show
low
levels
of
soil
Fusarium
(
0­
220
CFU/
g
soil).
These
soils
are
well
within
the
safe
zone
for
pine
seedbed
production.

Interpretations:
The
soil
sampling
method
and
testing
allows
for
the
effective
soil
management
decision
making.

2003­
25
Pathogen
Contributions
Packing
Room
(
Turner,
OR).
Soil
sampling
across
fumigated
and
non­
fumigated
portions
of
Block1,
2
and
3
show
low
levels
of
soil
Fusarium
(
0­
223
CFU/
g
soil).
Variation
was
minimal
within
blocks
and
even
in
immediately
adjacent
non­
fumigated
areas.
These
soils
are
well
within
the
safe
zone
for
Douglas­
fir
transplant
production.
Soil
and
the
roots
from
the
packing
room
was
collected
and
tested
for
Fusarium,
Pythium,
and
Cylindrocarpon.
Direct
isolation
from
sample
root
fragments
was
compared
with
levels
of
each
fungus
"
baited"
using
sterile
autoclaved
Douglas­
fir
roots.

Roughly
10%
of
the
root
residues
from
fumigated
and
non­
fumigated
areas
yielded
Pythium,
although
fewer
roots
could
be
recovered
from
the
non­
fumigated
areas
(
previous
crop
residuals).
Pack
room
root
residuals
yielded
Pythium
from
17%
of
the
isolation
attempts.
Attempts
to
bait
it
from
soil
was
only
successful
in
one
fumigated
sample,
but
several
non­
fumigated
samples
and
more
so
from
the
soil
in
the
packing
room.

Fusarium
was
isolated
from
about
3%
of
the
root
residuals
and
did
not
show
any
pattern
to
fumigation
or
packing
room
samples.
Baiting
reduced
the
isolation
frequency
to
about
1.5%.
Page
66
Cylindrocarpon
represented
some
4%
of
the
root
fragment
isolates
and
there
was
no
pattern
to
root
residual
source.
Attempts
to
bait
this
fungus
yielded
low
results.

Interpretations:
Seedling
harvest
activities
yields
many
pounds
of
soil
and
root
fragments
as
a
consequence
of
lifting
and
storing
regeneration
stock.
It
is
common
practice
to
return
these
residues
to
fields
that
will
be
fallow
or
fumigated
during
the
next
crop
cycle,
but
some
facilities
will
compost
the
residues
prior
to
land
application.
These
residue
potentially
harbor
considerable
reservoirs
of
pathogens,
especially
if
the
field
is
further
into
the
fumigation
rotation.
In
this
example,
even
though
the
fields
show
low
levels
of
all
three
pathogens
they
might
still
be
expected
to
increase
once
applied
to
soils.
Proper
sanitation
procedures
dictate
not
returning
these
soils
or
roots
to
production
fields.

2003­
34
Alternative
Fumigation
Testing
(
AR).
Soil
sampling
in
June
following
fall
fumigation
at
Magnolia
with
MBC
(
98:
2),
Telone­
PIC
and
PIC
show
no
significant
differences
in
soil
Fusarium
levels
(
158
CFU/
g,
91
CFU/
g,
and
82
CFU/
g
respectively).

Interpretations:
The
replication
of
tests
between
facilities
is
needed
to
fully
understand
the
potential
for
alternative
agents
to
serve
as
replacements
for
MB.
This
test
confirms
previous
data
on
the
efficacy
of
Telone­
PIC
and
PIC
as
soil
fumigants
under
normative
prescriptions
for
soil
fumigation.
Page
67
2004
Weyerhaeuser
R&
D
Activities
on
Fumigation,
Disease
and
Trials
2004­
15
Fumigation
Skip
Investigation
(
Mima,
WA).
Soil
sampling
in
spring
in
Blk­
14
was
initiated
after
a
circular
weedy
patch
(
roughly
100
sq
ft)
developed
in
a
field
treated
with
MBC
67:
33
the
previous
fall.
Sampling
and
around
the
weedy
area
turned
up
no
significant
pathogen
(
Fusarium,
Cylindrocarpon)
population.

Interpretations:
The
sampling
satisfies
concerns
over
a
fumigation
skip.
Weed
invasion
is
more
likely
associated
with
equipment
or
soil
movement.

2004­
16
Nursery
Pathogen
Management
(
AL).
Soil
sampling
in
spring
across
18
Pine
Hill
nursery
growing
blocks
shows
the
within
facility
variation
in
pathogen
occurrence
by
field
management
and
past
fumigation
history.
In
eight
fields
(
44%)
pathogen
levels
were
categorized
as
low
to
not­
detectable
(<
100
CFU/
g
soil).
Seven
fields
(
39%)
tested
within
the
low
to
moderate
range
(
100­
400
CFU/
g
soil).
Three
fields
were
within
the
target
threshold
for
cropping
(
600­
1205
CFU/
g
soil),
and
would
most
likely
be
in
need
of
fumigation
after
the
next
crop
cycle.

Interpretations:
Block
management
is
an
important
factor
in
achieving
consistent
crop
production.
Fall
fumigation
has
been
proven
to
be
more
effective
than
spring
fumigation
owing
to
optimal
chemical,
climatic
and
cultural
aspects.
It
is
prudent
for
a
facility
to
maintain
a
large
percentage
of
its
production
ground
in
a
state
of
"
disease­
free"
growing,
represented
here
by
pathogen
population
estimates.
This
allows
for
better
identification,
timing
and
optimal
fumigation
on
the
nursery
areas
outside
the
normative
prescription
for
pathogens.

2004­
38;
2004­
62,
2004­
64
Alternative
Fumigation
Testing
(
Aurora,
OR).
Soil
sampling
in
June
following
fall
fumigation
at
MBC
(
67:
33),
Telone­
PIC
and
PIC
show
no
significant
differences
in
soil
Fusarium
levels
in
Douglas­
fir
seedbeds
(
0
CFU/
g,
93
CFU/
g,
and
34
CFU/
g
respectively).
Samples
were
taken
in
December
of
2004
(
Study
2004­
62)
to
determine
Fusarium
levels
at
the
end
the
growing
season.
These
results
show
that
after
1­
year
in
crop
the
soil
levels
had
raised
to
315
CFU/
g
soil
(
MBC),
167
CRU/
g
(
Telone­
PIC);
and
176
CFU/
g
(
PIC).
Seedling
infection
levels
(
Study
2004­
64)
pathogen
and
non­
pathogen
fungal
groups
were
determined.
Differences
between
fumigation
treatments
were
not
significant.
Isolation
of
Fusarium
oxysporum
from
roots
declined
from
4.6%
(
PIC),
5.1%
(
Telone­
PIC)
to
9.7%
with
MBC
67:
33.
Isolation
frequency
of
Fusarium
roseum
(
1.6­
2.3%),
Phoma
sp.
(
19­
22.6%),
and
Cylindrocarpon
(
0­
0.3%)
varied
little
by
treatment.

Interpretations:
Fumigation
with
MBC,
Telone­
PIC
or
PIC
demonstrates
similar
pathogen
control
in
soils
of
widely
varying
texture
and
composition.
Under
these
culture
conditions
the
build­
up
post
treatment
and
infections
levels
that
result
appear
similar
for
all
three
fumigants.
Page
68
2004­
63
Alternative
Fumigation
Testing
(
Mima,
WA).
Soil
sampling
in
December
from
soils
treated
with
MBC
(
67:
33),
PIC
(
350lbs/
ac)
or
Metam
Sodium
(
100
gal/
ac)
showed
varied
results
to
pathogen
abundance.
Fusarium
was
not
detected
in
plots
taken
in
MBC
fumigated
ground,
while
C350
contained
background
levels
(
55
CFU/
g
soil)
and
slightly
higher
for
Metam
(
181
CFU/
g
soil).
Phoma
was
far
more
common
as
a
soil
isolate
in
Metam
treated
soil
(
2173
CFU/
g)
than
C350
(
1403
CFU/
g)
or
MBC
(
667
CFU/
g).
Cylindrocarpon
was
only
detected
in
3
plots
all
treated
with
MBC
(
18
CFU/
g
soil).

Interpretations:
Most
testing
for
fumigation
efficacy
has
been
done
with
a
specific
"
target"
pathogen,
in
most
examples,
Fusarium
oxysporum.
This
study
provides
some
evidence
that
this
technique
may
be
a
technology
shortcoming,
and
that
not
all
pathogenic
fungi
are
controlled
in
the
same
manner.
This
also
provides
some
clues
as
to
the
appearance
and
dominance
of
Cylindrocarpon
in
some
nursery
production
blocks,
where
it
seemingly
had
not
existed
before.
These
results
might
further
support
the
need
for
rotation
of
fumigants,
rates,
or
fumigant
mixtures,
not
merely
selection
of
the
"
next"
best
fumigant.
Further
testing
is
needed
to
understand
the
shortcomings
of
a
particular
fumigant
and
the
conditions
which
facilitate
pathogen
escape.

2004­
71
Alternative
Fumigation
Test
(
Mima,
WA).
Soil
sampling
was
conducted
in
Blk
12
during
the
late
fall
after
being
treated
with
MBC
(
67:
33)
or
with
increasing
levels
of
PIC
(
150lbs/
ac,
250
lbs/
ac,
and
350
labs/
ac).
Post­
treatment
soil
Fusarium
was
very
low
(
11­
43
CFU/
g)
and
not
significantly
different
between
treatment
plots.
In
contrast,
Phoma
was
very
high
(
1790­
4675
CFU/
g)
and
not
consistent
with
increasing
fumigation
rates.
Cylindrocarpon
was
low
(
0­
27
CFU/
g
soil)
in
all
treatments.

Interpretations:
The
information
provided
in
this
analysis
shows
that
pathogen
response
to
various
fumigants,
and
rates
of
application
may
be
more
variable
than
previously
thought.
Control
for
one
target
organism
may
fit
the
expectation
of
the
sanitation
process,
while
another
organism
is
not
controlled
to
any
degree.
The
long­
term
interactions
of
differential
pathogen
control
remains
to
be
examined
and
understood.
Page
69
Appendix
II
Economic
information
for
Michigan
Herbaceous
Perennials
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
E.
8:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
H
­
Michigan
Herbaceous
Perennials
Methyl
Bromide
Various
Alternatives**
Yield
Loss
(%)
0%
5%
Yield
per
Hectare
Conifer
Seedlings
144,920
137,674
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.97
$
0.97
=
Gross
Revenue
per
Proportion
(
60%)
$
140,956
$
133,908
­
Operating
Cost
per
Hectare
(
U.
S.
$)
$
37,311
$
58,414
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
103,645
$
75,494
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
28,151
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
143.52
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
21%

4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
37%
**
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.
Page
70
Alternative:

A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
768.00
Fumigation
product
application
Irrigation
Bulb
crates
and
media
11,293
crates
$
2.50
28,233.00
Seedlings
67,760
plants
$
0.80
67,760.00
Cultural
Operations
Fertilizer/
soil
amendments
450
lbs
$
1.00
498.00
450
lbs
$
1.00
498.00
Pesticides
Insecticide
Herbicide
Fungicide
Nematicide
Irrigation
32
man
hours
$
15.00
480.00
32
man
hours
$
15.00
480.00
Interest
on
Land
Prep
Charges
11,525
7.00%
807.00
11,525
7.00%
807.00
Interest
on
Operating
Capital
98,950
6.00%
1,989.00
16,278
6.00%
488.00
Hand
Weeding
96
man
hours
$
12.00
1,152.00
96
man
hours
$
12.00
1,152.00
Dept
of
Ag
Inspection
20.00
20
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Labor
and
Hauling
1,440.00
Storage
Cost
3,750.00
Processing
0.03
271040
8,131.00
EPA
Form
#
7620­
18a
16,766.00
$
118,474.00
$
Year
1
&
2
Total
Cost
Per
Acre
101,707.00
$
OMB
Control
#
2060­
0482
Worksheet
3­
B2
(
3).
Alternatives
­
Changes
in
Operating
Costs
for
Perennial
Crops
PRE
PRODUCTION
YEAR
1
Harvest
Year
2
Grown
In
Artificial
Media
on
Acreage
Prepared
as
Container
Field
(
Soiless
culture/
plugs
substrates)
Page
71
Economists
Comments
for
worksheet
3­
B2(
3)
 
Artificial
media
on
Acreage
Prepared
as
Container
Field
Soiless
culture/
plugs
substrates)

Year
1
 
Land
preparation:
Container
field
preparation
­
$
10,000
for
leveling,
draining,
gravel
roads,
etc.
and
$
0.05
per
square
foot
(
70%
of
acreage)
for
ground
mat
depreciated
over
15
years.

 
Bulb
crates
and
media:
$
1
per
crate
and
$
1.50
for
soil
in
crate
 
a
crate
is
2.7
sq
ft
and
they
cover
70%
of
the
sq
ft
in
an
acre.

 
Field
clean
up:
Labor
to
pick
up
plastic,
plastic
disposal
fee
and
tractor
&
trailer
use
(
custom
rate).

 
Seedlings:
Plants
and
planting
costs.
Takes
5
seconds
per
plant
to
put
into
bulb
crates.

 
Fertilizer/
soil
amendments:
Includes
material
and
application
cost
(
1
hr/
ac
@
$
12
4x).

 
Irrigation:
Labor
to
water
about
2
"
per
week
June
1­
Sept
30.

 
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
8
months
in
Year
1
and
12
months
in
Year
2.

Year
2
 
Labor
and
Handling:
Includes
loading
crates,
hauling
on
trailer
to
polyhouse
and
unloading
(
120
person
hrs/
ac).
Page
72
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
170.00
Fumigation
product
$
312.50
lbs
MB/
ch
$
3.35
1,047.00
application
809.00
Irrigation
Seed
and
Seeding
287.00
Other
costs
63.00
63.00
Cultural
Operations
Fertilizer/
soil
amendments
73.00
60.00
Pesticides
Insecticide
Herbicide
12.00
Fungicide
356.00
Custom
application
of
fungicide
$
12.00
application
$
15.00
180.00
Irrigation
70.00
Hand
hoeing
&
Trimming
$
120
hrs
$
12.00
1440.00
Fuel/
machine
labor
115.00
Interst
on
Operting
Capital
$
2,194
6.00%
33.00
$
7,409
6.00%
167.00
Dept
of
Ag
Inspection
20.00
20.00
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Digging
&
Transporting
1007
Grading/
packing
1495
Cold
Storage
997
Shipping
1329
2,227.00
7,586.00
9,813.00
Year
1
&
2
Total
Cost/
Ac
EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
2­
D(
2a).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
­
2
Year
Seeded
INITIAL
PRODUCTION
YEARS
_____

PRE
PRODUCTION
YEARS
_______
Page
73
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
112.00
Fumigation
product
$
350.00
lbs
MB/
ch
$
3.35
1,173.00
application
632.00
Cover
Crops
100.00
Seedlings
38,000
divisions
$
0.03
1,241.00
Other
costs
1,624.00
7.00
Cultural
Operations
Fertilizer/
soil
amendments
42.00
150.00
Pesticides
Insecticide
&
Fungicide
150.00
600.00
Custom
application
of
fungicide
3
applic
$
15.00
45.00
$
15.00
application
$
15.00
225.00
Hand
weeding
10
hrs
$
12.00
120.00
$
40.00
hrs
$
12.00
480.00
Irrigation
Labor
&
Operations
1.5
hrs
$
15.00
23.00
3.5
hrs
$
15.00
53.00
Labor
(
manual)

Mechanical
Cultivation
10
hrs
$
15.00
173.00
Interest
on
Operting
Capital
$
5,288
6.00%
159.00
$
7,409
6.00%
405.00
Dept
of
Ag
Inspection
20.00
20.00
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Cutting
(
Mechanical
Operations)
2.7
hr/
ac
$
15.00
41
Cutting
&
Packing
(
Labor)
522
hrs
12
6,261.00
Equipment
Rental
Hi­
Los
435
Truck
495
Trailers
275
Packing
Materials
20,000.00
flats
0.21
4305
5,447.00
13,917.00
19,364.00
Year
1
&
2
Total
Cost/
Ac
EPA
Form
#
7620­
18a
Pre
Plant
Worksheet
2­
D(
2b).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
­
3
Year
Transplanted
INITIAL
PRODUCTION
YEARS
_____

PRE
PRODUCTION
YEARS
_______
Page
74
A
B
(
1)
C
(
1)
D
(
1)
E
(
1)
B
(
2)
C
(
2)
D
(
2)
E
(
2)

Operation
or
Input
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Quantity
used
per
acre
Units
(
lbs,

hours,
etc)
Unit
Cost
Total
Cost
per
Acre
Establishment
Operations
Land
preparation
167.00
Fumigation
product
400
lbs
MB/
ch
$
3.35
1,340.00
application
409.00
Field
clean
up
135.00
Irrigation
Seedlings
50000
plants
$
0.08
40,833.00
Cultural
Operations
Fertilizer/
soil
amendments
450
lbs
$
0.50
243.00
450
lbs
$
0.50
243.00
Pesticides
Insecticide
Herbicide
Fungicide
Custom
application
of
fungicide
Irrigation
16
man
hrs
$
15.00
240.00
Hand
hoeing
&
Trimming
192
man
hrs
$
12.00
2,304.00
$
192
man
hrs
$
12.00
2304.00
Fuel/
machine
labor
Interest
on
Operating
Capital
$
45,691
6.00%
918.00
$
11,740
6.00%
352.00
Dept
of
Ag
Inspection
20.00
20.00
Harvest
Operations
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Constant
Cost
per
Acre
Cost
per
Unit
of
Yield
Yield
Total
Cost
Digging
Labor
600
Digging
Equipment
633
Storage
Cost
1700
Processing
6000
46,609.00
12,092.00
58,701.00
Year
1
&
2
Total
Cost/
Ac
Worksheet
2­
D(
2c).
Methyl
Bromide
­
Baseline
­
Operating
Costs
for
Perennial
Crops
­
2
Year
Transplanted
Harvest
Year
2
PRE
PRODUCTION
YEAR
1
Page
75
Economist's
comments
for
worksheet
2­
D
(
2a)
­
2
Year
Seeded
Year
1
 
Land
preparation:
Includes
soil
test,
disk,
plow,
drag,
float,
apply
fert.,
drag,
apply
herbicide,
disk,
drag,
float
 
priced
as
custom
rates
so
includes
some
fixed
costs.

 
Application:
Includes
custom
application,
tarp
removal,
and
tarp
disposal.

 
Other
costs:
Post
planting
field
prep.
And
cover
crop
 
cover
crop
is
certified
seed
to
minimize
weed
contamination
 
Fertilizer/
soil
amendments:
Lime
and
potassium.

 
Irrigation:
Labor
Solid
set
and
hand
hose
 
includes
some
fixed
expense.

 
Hand
hoeing
&
Trimming:
Includes
hoeing
(
1x
per
month
@
½
ac
per
hour
with
15
people)
and
trimming.

 
Fuel/
machine
labor:
Field
maintenance
 
cultivation
and
driveway
and
ditch
maintenance
 
includes
some
fixed
cost.

 
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
6
months
in
Year
1
and
9
months
in
Year
2.

 
Cold
Storage:
$
0.90
per
sq
ft
 
90
d
on
#
1
and
50
d
on
Liners
Year
2
 
Fertilizer/
soil
amendments:
28%
Nitrogen.

Economist's
comments
for
worksheet
2­
D
(
2b)
3
Year
Transplant
Year
1
 
Land
preparation:
Includes
soil
test,
disk,
subsoil,
plant
&
disc
cover
crop,
disc,
plow,
drag.

 
Application:
Includes
custom
application
cost
(
less
materials)
and
plastic
disposal
and
clean
up.

 
Cover
crop:
Cover
crop
seed
is
certified
to
minimize
weed
contamination.

 
Planting
labor:
Includes
splitting
plants
into
divisions,
transplanting
into
field
and
transport
to
field.

 
Equipment
Operation
(
Planting):
Fuel
and
Maintenance
on
transplanter.

 
Irrigation
Labor
and
Operation:
Includes
labor
(
calculated)
plus
$
0.10
per
application
in
electricity
&
maintenance
cost.

 
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
12
months
in
Year
1
and
12
months
in
Year
2.

Year
2
 
Cutting
&
Packaging
Labor:
150
people
per
crew
for
an
8
hour
day
doing
2.3
ac
per
day
 
Equipment
rental:
10
hi­
los,
truck
rental
(
4
trucks)
plus
truck
mileage
to
and
from
field,
Trailer
rental
(
3
trailers)
plus
mileage
to
and
from
field
Economist's
comments
for
worksheet
2­
D
(
2c)
­
2
Year
Transplanted
Year
1
 
Land
preparation:
Includes
chisel
plow
3X
and
rotofill
once
before
and
once
after
fertilization.

 
Application:
Includes
2
people
on
hand
at
application
to
bury
ends
of
plastic
and
assist
custom
operators.

 
Field
Clean
Up:
Labor
to
pick
up
plastic,
plastic
disposal
fee
and
tractor
&
trailer
use
(
custom
rate)

 
Seedling:
Plants
and
planting
costs.

 
Fertilizer/
soil
amendments:
Includes
material
and
application
cost.

 
Irrigation:
Labor
to
water
about
1"
per
week
June1
 
Sept
30.

 
Interest
on
Operating
Capital:
Assume
grower
borrows
half
of
variable
expenses
for
8
months
in
Year
1
and
12
months
in
Year
2.

Year
2
 
Digging
Equipment:
Includes
custom
rates
for
2
tractors
 
1
for
digger
and
1
for
trailer
 
potato
digger
and
trailer.

 
Storage
Cost:
Includes
mulch
to
cover
in
polyhouse
and
polyhouse
rental
($
0.50
per
sq
ft
*
3,000
sq
ft
necessary
for
1
acre
hosta
yield
Page
76
 
Processing:
Splitting
divisions.
Page
77
Methyl
Bromide
Critical
Use
Exemption
Process
2001
&
2002
Average
Requested
%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

10,952
47
235
2,100
7
280
17,962
57
314
31,014
111
279
94%
74%
76%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
235
235
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

280
280
0
0
0
0
100
100
44
31
0
0
0
0
100%
100%

314
314
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

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
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
No
Yes
Tarp
Yes
+
Yes
No
Yes
Yes
Tarp
Yes
­
Yes
No
No
Yes
Tarp
Yes
0
Yes
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Most
Likely
Impact
Value:
High
24%
Low
77%

*
CA
Deciduous
Fruit
&
Nut
Tree
Growers
have
a
new
QPS
%
of
92%
instead
of
their
previous
100%.

*
Raspberry
was
recalculated
using
original
QPS%
of
60%
instead
of
90%
based
on
communications
with
Dave
Riggs.

***
Recalculation
of
QPS
based
on
conversation
with
Jim
Wells
on
8/
5/
2005.
QPS
should
be
calculated
as
99and
92%
of
their
total
methyl
bromide
usage.

*
USEPA
has
recently
been
informed
that
a
larger
proportion
of
methyl
bromide
use
falls
under
QPS
therefore
EPA
has
reduced
the
request
to
adjust
for
this
new
information.

Date:
8/
10/
2005
Average
Hectares
in
the
US:

2007
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Hectares
(
ha)

2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Sector:
FRUIT,
NUT,
&
FLOWER
NURSERY
Hectares
(
ha)
Use
Rate
(
kg/
ha)

REGION
117
235
Kilograms
(
kgs)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
27,379
Western
Raspberry
Nursery
Consortium
53,416
212
252
209,975
81
2,594
208,217
616
338
99%

642
314
92%

224,528
134
1,681
201,678
TOTAL
OR
AVERAGE
487,919
426
1,145
437,274
1,374
318
2007
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

(­)
QPS
HIGH
LOW
2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
53,416
­
26,037
­
16,427
10,952
10,952
209,975
­
­
­
207,875
2,100
2,100
206,566
17,962
17,962
224,528
­
­
­

Nomination
Amount
487,919
487,919
461,882
94%

461,882
31,014
31,014
%
Reduction
from
Initial
Request
0%
0%
5%

Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
(%)
100
ft
Buffer
Zones
(%)
Key
Pest
Distribution
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
Dichotomous
Variables
(
Y/
N)

CA
Rose
Growers
***

CA
Assoc.
­
Fruit
&
Nut
Tree
Growers***

REGION
REGION
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
Other
Considerations
Adjustments
to
Requested
Amounts
REGION
Western
Raspberry
Nursery
Consortium
CA
Rose
Growers
CA
Assoc.
­
Fruit
&
Nut
Tree
Growers
3­
5x/
1yr
0.453592
1
Acre
=
0.404686
Frequency
of
Treatment
2­
3x/
1yr
3­
5x/
1yr
Not
included
as
there
is
no
technically
feasible
alternative.

Marginal
Strategy
Quality/
Time/
Market
Window/
Yield
Loss
(%)

Other
Issues
MOST
LIKELY
IMPACT
VALUE
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)

Economic
Analysis
94%

5%
Combined
Impacts
(%)

Cold
Soil
Temp
(%)

94%
not
available
%
of
Average
Hectares
Requested:

31,014
60%
Not
Available
Regional
Hectares**
Research
Amount
(
kgs)

1,506
Page
78
Appendix
III
Revised
BUNI
for
Strawberry
nurseries
2001
&
2002
Average
Requested
%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

4,434
17
263
2,654
8
350
7,089
24
290
99%
96%
63%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
263
263
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

413
350
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

Strip
B
ed
T
reatm
ent
C
urrently
U
se
A
lternatives?
R
esearch
/

T
ransition
P
lans
Tarps
/

D
eep
Injection
U
s
ed
P
est­

free
C
ert.

R
equirem
ent
C
hange
from
Prior
C
U
E
R
equest
(+/­)
V
erified
H
istoric
M
eBr
U
s
e
/

S
tate
F
requency
of
T
reatm
ent
Loss
per
H
ec
tare
(

U
S$/

ha)
Los
s
per
Kilogram
of
M
eB
r
(

U
S
$/

kg)
Los
s
as
a
%

of
G
ross
R
evenue
Los
s
as
a
%

of
N
et
R
evenue
No
Yes
Yes
Tarp
Yes
+
Yes
2~
5
years
4,606
$
17
$
10%
46%

No
Yes
Yes
Tarp
Yes
+
Yes
2~
5
years
5,469
$
13
$
13%
46%

*
Growth
calculated
after
subtracting
QPS
Conversion
Units:
1
Pound
=
Kilograms
Hectare
High
24%
Low
77%

***
Recalculation
of
QPS
based
on
conversation
with
Jim
Wells
on
8/
5/
2005.
QPS
should
be
calculated
as
99and
92%
of
their
total
methyl
bromide
usage.
Not
Available
Regional
Hectares**

Not
Available
Research
Amount
(
kgs)

454
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
Unsuitable
Terrain
(%)

(%)
Key
Pest
Distribution
Regulatory
Issues
(%)

(%)
100
ft
Buffer
Zones
CALIFORNIA
SOUTHEASTERN
US
Economic
Analysis
Dichotomous
Variables
(
Y/
N)
Other
Issues
REGION
SOUTHEASTERN
US
CALIFORNIA
SOUTHEASTERN
US
Other
Considerations
Nomination
Amount
Adjustments
to
Requested
Amounts
%
Reduction
from
Initial
Request
0%
0%

REGION
CALIFORNIA***
SOUTHEASTERN
US
CALIFORNIA
2007
Nomination
Options
REGION
486,723
486,723
3%
7,089
7,089
Cold
Soil
Temp
(%)

99%
99%

4%
99%

471,930
467,561
4,434
43,292
­
14,793
4,370
21,475
2,654
2,654
438,997
­
(­)
Growth*
7,089
4,434
­
­

Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

393,544
1,455
270
94%

TOTAL
OR
AVERAGE
486,723
627
776
1,386
263
99%

43,292
105
413
28,499
69
413
89%

443,432
522
263
365,045
2007
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
Sector:
STRAWBERRY
NURSERY
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
%
of
Average
Hectares
Requested:

Date:
8/
10/
2005
Methyl
Bromide
Critical
Use
Exemption
Process
Average
Hectares
in
the
US:

Most
Likely
Impact
Value:
Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
10%
10%
1,3­
D
+
Pic
1,3­
D
+
Pic
1
Acre
=
0.404686
443,432
2007
Request
0.453592
MOST
LIKELY
IMPACT
VALUE
Combined
Impacts
(%)

(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
(­)
Double
Counting
Page
79
