Reply
to
MBTOC
2005
Page
1
United
States
Supplemental
Request
for
2006
The
dried
bean
sectors
it
the
only
sector
for
which
the
United
States
is
submitting
a
new
request
for
a
2006
methyl
bromide
CUE.

1.
Dried
Beans
Dried
beans
in
California
have
no
alternative
to
control
cowpea
weevil
in
garbanzo
and
blackeye
beans.
The
phosphine
label
does
not
list
cowpea
weevil
on
its
efficacy
list.
The
state
of
California
requires
that
the
pest
be
specifically
listed
on
the
label
for
a
legal
application
of
the
pesticide.
Heat
is
unacceptable
as
the
temperatures
required
to
destroy
the
larvae
of
cowpea
weevils
within
the
beans
would
cook
the
product
and
make
them
unmarketable.

The
U.
S.
supplemental
request
for
dried
beans
in
2006
is
for
7.07
metric
tons
of
methyl
bromide,
which
is
the
same
amount
being
requested
for
2007.
The
basis
for
the
2006
request
is
the
same
as
that
described
in
detail
for
our
2007
request,
so
please
refer
to
those
documents
for
our
analysis
of
the
need
for
methyl
bromide
in
this
sector.
Reply
to
MBTOC
2005
Page
2
United
States
Request
for
Reconsideration
for
2006
The
U.
S.
requests
reconsideration
for
sectors
referred
back
to
MBTOC
at
MOP­
16,
and
has
provided
the
following
clarifications
and
additional
information
to
assist
MBTOC
in
its
further
discussions.
The
additional
information
is
provided
on
a
sector
by
sector
basis.

1.
Dry
commodities/
structures
(
cocoa
beans)

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
61.519
metric
tons
of
methyl
bromide
for
use
on
cocoa
beans
in
the
U.
S.
for
both
2005
and
2006.
This
is
a
request
at
the
national
level
to
treat
cocoa
beans.

The
U.
S.
nomination
is
only
for
those
food
commodities,
such
as
cocoa,
where
the
use
of
alternatives
is
not
suitable.
In
the
U.
S.
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Constraints
of
the
alternatives:
some
types
of
commodities
(
e.
g.,
those
containing
high
levels
of
fats
and
oils)
prevent
the
use
of
heat
as
an
alternative
because
of
its
effect
on
the
final
product
(
e.
g.,
rancidity)
or
because
it
changes
the
nature
of
the
final
product
(
e.
g.
cooking
it).
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
use
on
small
grains
(
flour,
rice,
oats,
etc.)
but
not
for
other
foods.
State
registrations
for
small
grains
have
not
yet
been
issued
in
all
states.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
A
registration
decision
concerning
the
establishment
of
sulfuryl
fluoride
tolerances
on
other
processed
food
ingredients
in
a
treated
facility
is
still
pending.
­
Time
to
complete
fumigation:
e.
g.,
the
use
of
some
methyl
bromide
alternatives
can
add
a
delay
to
production
by
requiring
additional
time
to
complete
the
fumigation
process.
Production
delays
can
result
in
significant
economic
impacts
to
the
processors.
Capacity
of
fumigation
chambers
can
become
an
issue.
If,
for
example,
fumigation
capacity
for
cocoa
beans
is
fully
utilized,
moving
to
an
alternative
that
requires
a
longer
in­
chamber
time
would
require
construction
of
additional
fumigation
capacity
incurring
large
capital
costs.

Overview
of
MBTOC's
prior
Recommendation
MBTOC
recommended
a
25%
cut
to
a
level
of
46.139
metric
tons
for
20061.
The
basis
for
this
suggested
reduction
was
"
for
phasein
of
alternatives".

1
The
original
recommendation
for
2005
was
for
a
cut
of
10%
to
a
level
of
55.367
metric
tons.
The
cut
was
rejected
by
the
Parties
at
the
November
MOP
and
the
full
request
was
granted.
It
is
now
not
clear
if
the
recommended
amount
for
2006
remains
at
46.139,
a
25%
cut
from
the
requested
amount,
or,
whether
the
amount
will
be
adjusted
to
reflect
a
15%
reduction
for
a
recommended
quantity
of
52.291.
Reply
to
MBTOC
2005
Page
3
MBTOC
further
stated
"
Frequent
fumigations
indicate
that
there
are
poor
or
no
measures
to
prevent
re­
infestation,
resulting
in
additional
and
perhaps
unnecessary
use
of
MB."

U.
S.
Response
to
MBTOC's
prior
recommendations
To
clarify
the
U.
S.
request,
shipments
of
cocoa
beans
are
fumigated
once
each
and
then
distributed
throughout
the
U.
S.
for
further
processing
into
finished
products
such
as
cocoa
powder,
chocolates,
etc,
and
we
therefore
disagree
that
cuts
to
our
request
based
on
the
frequency
of
fumigation
are
appropriate.
Although
phosphine
(
aluminium
phosphide)
is
labeled
for
use
on
cocoa
beans
in
the
US,
the
time
required
to
complete
a
fumigation
is
more
than
96
hours
compared
with
24
hours
for
a
methyl
bromide
fumigation.
This
extra
time
imposes
a
cost
on
the
manufacturers
of
finished
cocoa
products.
According
to
the
International
Cocoa
Organization
(
www.
icco.
org)
"
Some
countries
also
use
plastic
strips
containing
Dichlorovos
for
continuous
chemical
control,
though
these
are
banned
in
some
countries
and
the
U.
S.
is
withdrawing
permission
to
use
it."

Methyl
bromide
is
the
cost­
effective
fumigant
to
use
on
cocoa
beans.
The
short
time
required
allows
rapid
turn­
over
of
existing
fumigation
capacity.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
No
technical
assessment
of
the
performance
of
alternatives,
or
economic
assessment
of
the
impact
of
converting
to
alternatives
was
provided
by
MBTOC.
No
economic
data
were
provided
to
support
a
25%
reduction
schedule
as
suggested
by
MBTOC.

To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
longer
treatment
times,
and
the
economic
feasibility
of
a
four
year
transition
time.

U.
S.
2006
nomination
The
U.
S.
has
considered
the
issues
raised
by
MBTOC,
but
continues
to
support
our
request
for
61.519
metric
tons
of
methyl
bromide
for
use
on
cocoa
beans
for
2006,
which
is
an
increase
of
15.380
metric
tons
over
the
MBTOC
recommended
amount
of
46.139
metric
tons.
Reply
to
MBTOC
2005
Page
4
2.
Dry
commodities/
structures
(
processed
foods,
herbs,
spices,
dried
milk,
cheese
processing)

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
83.344
metric
tons
of
methyl
bromide
for
use
on
processed
foods
(
71.889
metric
tons),
herbs
and
spices
(
4.695
metric
tons),
dried
milk
(
0.402
metric
tons),
cheese
processing
facilities
(
2.876
metric
tons),
and
other
commodities
(
3.482
metric
tons)
for
2006.
This
is
a
request
at
the
national
level.

The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
In
U.
S.
food
processing
plants
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Geographic
distribution
of
the
facilities:
some
facilities
are
situated
in
areas
where
key
pests
may
occur
at
low
levels,
such
as
those
located
in
the
northern
part
of
the
U.
S.
In
such
cases,
the
U.
S.
is
only
nominating
a
CUE
for
facilities
where
the
key
pest
pressure
is
moderate
to
high.
­
Age
and
type
of
facility:
older
food
processing
facilities,
especially
those
constructed
of
wood,
experience
more
frequent
and
severe
pest
infestations
that
must
be
controlled
by
fumigation.
­
Constraints
of
the
alternatives:
some
types
of
commodities
(
e.
g.,
those
containing
high
levels
of
fats
and
oils)
prevent
the
use
of
heat
as
an
alternative
because
of
its
effect
on
the
final
product
(
e.
g.,
rancidity).
Further,
the
corrosive
nature
of
phosphine
on
certain
metals
prevents
its
use
in
mechanical
and
electrical
areas
of
the
facilities.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
use
on
small
grains
(
flour,
rice,
oats,
etc.)
but
not
for
other
foods.
State
registrations
for
small
grains
have
not
yet
been
issued
in
all
states.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
A
registration
decision
concerning
the
establishment
of
sulfuryl
fluoride
tolerances
on
other
processed
food
ingredients
in
a
treated
facility
is
still
pending.
­
Delay
in
plant
operations:
e.
g.,
the
use
of
some
methyl
bromide
alternatives
can
add
a
delay
to
production
by
requiring
additional
time
to
complete
the
fumigation
process.
Production
delays
can
result
in
significant
economic
impacts
to
the
processors.

Overview
of
MBTOC's
prior
Recommendation
MBTOC
recommended
47.925
metric
tons
for
processed
dry
foods2,
3.13
metric
tons
for
herbs
and
spices,
nothing
for
dried
milk,
2.876
metric
tons
for
cheese
processing
facilities
(
the
full
2
As
is
the
case
for
cocoa
(
above)
because
the
cut
for
2005
was
rejected
by
the
Parties
at
the
November
MOP,
it
is
not
clear
whether
the
amounts
recommended
by
MBTOC
for
2006
will
remain
as
recommended
(
a
cut
of
approximately
20%
in
addition
to
a
lower
use
rate)
or
will
be
changed
to
a
10%
cut
again,
in
addition
to
the
lower
use
rate)
in
recognition
of
the
higher
2005
amount.
Reply
to
MBTOC
2005
Page
5
amount
requested)
and
2.321
metric
tons
for
other
commodities.
The
total
recommendation
was
for
56.253
metric
tons
of
methyl
bromide
for
these
uses
in
2006.

U.
S.
Response
to
MBTOC's
prior
recommendations
USG
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
in
mills
and
processing
facilities
but
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
this
level
is
not
adequate
to
control
pests
in
the
specific
circumstances
of
the
nomination
when
appropriate
practices
(
eg
careful
sealing
of
the
building/
container
and
other
`
best
practices')
are
followed.

USG
also
agrees
that
there
are
alternatives
for
controlling
pests
in
dried
milk
and
therefore
withdraws
the
requested
amount
of
0.402
metric
tons
for
this
purpose.

USG
does
not
agree
that
it
is
appropriate
to
cut
10%
(
or
20%)
from
the
requested
use
for
transition
to
alternatives
and
for
improved
sealing.

To
take
the
simpler
issue
first,
there
is
no
evidence
that
facilities
for
which
this
request
for
methyl
bromide
is
being
made
are
failing
to
seal
the
facilities
properly.
As
far
as
the
phase­
in
of
alternatives
is
concerned,
the
Montreal
Protocol
calls
for
a
critical
use
nomination
being
granted
when
there
are
no
alternatives
that
are
both
technically
and
economically
feasible.

Over
the
last
decade,
food
processing
facilities
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
to
methyl
bromide
use
identified
by
MBTOC.
The
most
critical
alternative
implemented
is
IPM
strategies,
especially
sanitation,
in
all
areas
of
a
facility.
Plants
are
now
being
monitored
for
pest
populations,
using
visual
inspections,
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
monitoring
and
managing
pests.
However,
when
all
these
methods
fail
to
control
a
pest
problem,
facilities
will
resort
to
phosphine,
heat,
and
if
all
else
fails,
to
methyl
bromide.

Many
facilities
in
the
United
States
also
are
using
both
phosphine
and
heat
treatments
to
disinfest
at
least
portions
of
their
plants.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
is
often
used
to
treat
both
incoming
grains
and
finished
products.
Unfortunately,
phosphine
is
corrosive
to
copper,
silver,
gold
and
their
alloys.
These
metals
are
critical
components
of
both
the
computers
that
run
the
machines
as
well
as
some
of
the
machines
themselves.
Therefore,
phosphine
is
not
feasible
in
all
areas
of
food
processing
facilities.
Additionally,
phosphine
requires
more
time
to
kill
insect
pests
than
does
methyl
bromide,
so
plants
need
to
be
shut
down
longer
to
achieve
mortality,
resulting
in
economic
losses.
There
are
also
reports
of
stored
product
pests
becoming
resist
to
phosphine
(
Taylor,
1989;
Bell,
2000;
Mueller,
2002).

Heat
treatments
have
a
number
of
problems
in
this
industry.
Not
all
areas
of
a
plant
can
be
efficiently
treated
with
heat.
Some
food
substances,
for
instance
oils
and
butters
will
become
rancid
with
heat
treatments.
Not
all
finished
food
products
can
be
heated
for
the
length
of
time
heat
is
required
for
efficient
kill
of
pests.
In
addition,
geography
of
the
United
States
plays
a
crucial
role
in
the
use
of
heat
treatments.
Food
processing
plants
in
the
northern
United
States
Reply
to
MBTOC
2005
Page
6
will
experience
winters
with
several
weeks
of
sustaining
temperatures
of
­
32
°
to
­
35
°
C
(­
30
°
to
­
25
°
F).
In
these
areas
plants
have
heaters
and
the
power
plants
have
the
capacity
to
supply
excess
power
as
needed.
However,
the
southern
and
parts
of
the
western
zones
of
the
United
States
are
geographically
quite
different.
Winter
temperatures
there
seldom
reach
 
1.2
°
C
(
30
°
F)
and
when
temperatures
should
fall
that
low,
it
is
typically
for
only
a
few
hours
one
night.
For
many
winters,
these
areas
of
the
U.
S.
don't
freeze
at
all.
Subsequently,
these
facilities
do
not
have
heaters,
nor
do
the
power
plants
have
enough
power
to
allow
them
to
heat
such
large
areas
and
sustain
the
temperatures
necessary
for
an
effective
kill
of
pest
populations.
Additionally,
escaping
insects
can
survive
these
outdoor
temperatures
and
re­
enter
the
facility
after
treatment,
even
when
low
volatility
pesticides
are
used
to
treat
the
surfaces
exiting
the
plant.
Still,
many
southern
and
western
facilities
use
heat
treatments
as
a
spot
treatment
whereas
the
northern
facilities
can
use
heat
treatments
more
extensively.

In
addition,
there
are
economic
costs
incurred
when
alternatives
are
used
that
are
over
and
above
costs
when
using
methyl
bromide
to
control
pests.
Economic
costs
in
the
post­
harvest
uses
of
the
food­
processing
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
the
direct
pest
control
costs
are
increased
in
most
cases
because
heat
treatment
is
more
expensive,
and
labor
is
increased
because
of
longer
treatment
time
and
increased
number
of
treatments.
For
food­
processing
facilities
that
are
not
already
using
heat,
capital
expenditure
is
also
required
to
retrofit
them
suitable
for
heat
treatment.
Moreover,
additional
production
downtimes
for
the
use
of
alternatives
are
unavoidable.
Many
facilities
operate
at
or
near
full
production
capacity
and
alternatives
that
take
longer
than
methyl
bromide
or
require
more
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
and
shipping
delays.
Slowing
down
production
would
result
in
additional
costs
relative
to
the
costs
incurred
by
methyl
bromide
users.

The
potential
economic
losses
associated
with
the
use
of
heat
treatment
mainly
originate
from
the
cost
of
capital
investment.
Although
economic
costs
were
not
calculated
for
these
specific
types
of
food
processing
facilities,
they
were
calculated
for
milling
facilities.
In
the
milling
facilities
the
estimated
economic
loss
per
1000
m3
ranges
from
$
2,023
to
$
12,439,
depending
on
the
product
being
milled.
The
estimated
economic
losses
as
a
percentage
of
gross
revenue
ranges
from
3%
to
18%
and
the
estimated
economic
loss
as
a
percentage
of
net
revenue
are
over
45%
for
all
the
CUE
applicants
in
the
food­
processing
(
milling)
sector.
We
expect
losses
of
a
similar
scale
in
this
segment
of
the
food
processing
sector
as
well.

The
industries
that
use
methyl
bromide
for
commodity
fumigation
are,
in
general,
subject
to
limited
pricing
power,
changing
market
conditions,
and
government
regulations.
Companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
The
results
suggest
that
heat
treatment
is
not
economically
viable
as
an
alternative
for
methyl
bromide
in
existing
facilities
that
still
use
methyl
bromide.

Sulfuryl
Fluoride
is
not
registered
for
use
on
herbs
and
spices.
Heat
is
not
an
appropriate
treatment,
as
it
will
degrade
the
quality
of
the
spice/
herb.
Although
phosphine
(
aluminium
phosphide)
is
labeled
for
use
on
spices
and
herbs
in
the
U.
S.,
the
time
required
to
complete
a
fumigation
is
more
than
96
hours
compared
with
24
hours
for
a
methyl
bromide
fumigation.
This
extra
time
imposes
a
cost
on
the
manufacturers
of
these
products.
Because
the
market
is
a
Reply
to
MBTOC
2005
Page
7
highly
competitive
and
globalized
one,
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories,
phosphine
may
not
be
an
economically
feasible
alternative
for
methyl
bromide
in
this
use.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
the
technical
assessment
of
the
performance
of
alternatives,
the
economic
assessment
on
the
impact
of
converting
to
alternatives,
and
in
particular
the
economic
data
used
to
support
a
10%
reduction.

To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
longer
treatment
times,
and
the
economic
feasibility
of
a
10%
reduction.

U.
S.
2006
nomination
Therefore
the
U.
S.
is
requesting
that
and
additional
amount
(
over
the
MBTOC
recommended
amount
of
56.253
metric
tons)
of
12.865
metric
tons
by
granted
brining
the
sector
total
to
69.118
metric
tons
of
methyl
bromide.

Citations
Arthur,
F.
H.
2000.
Toxicity
of
diatomaceous
earth
to
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
temperature
and
relative
humidity.
J.
Econ.
Entomol.
93(
2):
526­
532.

Arthur,
F.
H.
1992.
Cyfluthrin
WP
and
EC
formulations
to
control
malathion­
resistant
red
flour
beetles
and
confused
flour
beetles
(
Coleoptera:
Tenebrionidae):
Effects
of
paint
on
residual
activity.
J.
Entomol.
Sci.
27(
4):
436­
444.

Arthur,
F.
and
T.
W.
Phillips.
2003.
Stored­
product
insect
pest
management
an
d
control,
In:
Food
Plant
Sanitation
eds:
Y.
H.
Hui,
B.
L.
Bruinsma,
J.
R.
Gorham,
W.
Nip,
P.
S.
Tong,
and
P.
Ventresca.
Marcel
Dekker,
Inc.,
New
York,
pp.
341­
358.

Bell,
C.
H.
2000.
Fumigation
in
the
21st
century.
Crop
Protection
19:
563­
569.

Cox,
P.
D.
2004.
Potential
for
using
semiochemicals
to
protect
stored
products
from
insect
infestation.
J
Stored
Prod.
Res.
40:
1­
25.

Dowdy,
A
K.&
P.
G.
Fields.
2002.
Heat
combined
with
diatomaceous
earth
to
control
the
confused
flour
beetle
(
Coleoptera:
Tenebrionidae)
in
a
flour
mill.
J
Stored
Prod.
Res.
38:
11­
22.
Reply
to
MBTOC
2005
Page
8
Dunkel,
F.
V.
and
L.
J.
Sears.
1998.
Fumigant
properties
of
physical
preparations
from
Mountain
big
sagebrush,
Artemisia
tridentate
Nutt.
ssp.
vaseyana
(
Rydb.)
Beetle
for
stored
grain
insects.
J.
Stored
Prod.
Res.
34(
4):
307­
321.

Fields,
P.
and
N.
D.
G.
White.
2002.
Alternatives
to
methyl
bromide
treatments
for
storedproduct
and
quarantine
insects.
Annual
Review
of
Entomology
47:
331­
59.

Hou,
X.,
P.
Fields,
and
W.
Taylor.
2004.
The
effect
of
repellents
on
penetration
into
packaging
by
stored­
product
insects.
J
Stored
Prod.
Res.
40:
47­
54.

Mahroof,
R.,
Subramanyam,
B.
and
Eustace,
D.
2003.
Temperature
and
relative
humidity
profiles
during
heat
treatment
of
mills
and
its
efficacy
against
Tribolium
castaneum
(
Herbst)
life
stages.
J.
Stored
Prod.
Res.
39:
555­
569.

Mahroof,
R.,
B.
Subramanyam,
J.
E.
Throne,
and
A.
Menon.
2003.
Time­
mortality
relationships
for
Tribolium
castaneum
(
Coleoptera:
Tenebrionidae)
life
stages
exposed
to
elevated
temperatures.
J.
Econ.
Entomol.
96(
4):
1345­
1351.

Mueller,
D.
K.
1998.
Stored
product
protection 
a
period
of
transition.
Insects
Limited,
Inc.,
Indianapolis,
IN.
337
pp.

Nielsen,
P.
S.
1998.
The
effect
of
a
diatomaceous
earth
formulation
on
the
larvae
of
Ephestia
kuehniella
Zeller.
J
Stored
Prod.
Res
34:
113­
121.

Oberlander,
H.,
D.
L.
Silhacek,
E.
Shaaya,
and
I.
Ishaaya.
1997.
Current
status
and
future
perspectives
of
the
use
of
insect
growth
regulators
for
the
control
of
stored
product
insects.
J
Stored
Prod.
Res.
33:
1­
6.

Skovgard,
H.,
N.
Holst,
and
P.
S.
Nielsen.
1999.
Simulation
model
of
the
Mediterranean
flour
moth
(
Lepidoptera:
Pyralidae)
in
Danish
flour
mills.
Environ.
Entomol.
28(
6):
1060­
1066.

UNEP.
1998.
1998
Assessment
of
alternatives
to
methyl
bromide.
United
Nations
Publication.

UNEP.
2001.
Sourcebook
of
Technologies
for
protecting
the
ozone
layer:
alternatives
to
methyl
bromide.
United
Nations
Publication
Zettler,
J.
L.
1991.
Pesticide
resistance
in
Tribolium
castaneum
and
T.
confusum
(
Coleoptera:
Tenebrionidae)
form
flour
mills
in
the
United
States.
J.
Econ.
Entomol.
84(
3):
763­
767.

Zettler,
J.
L.
and
F.
H.
Arthur.
2000.
Chemical
control
of
stored
product
insects
with
fumigants
and
residual
treatments.
Crop
Protection
19:
577­
582.
Reply
to
MBTOC
2005
Page
9
3.
Mills
and
Processors
Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
505.982
metric
tons
of
methyl
bromide
for
use
in
mills
and
food
processing
facilities
for
2006.
The
request
was
distributed
as
follows:
114.305
metric
tons
for
rice
mills,
14.742
metric
tons
for
bakeries,
48.081
metric
tons
for
pet
food
facilities,
and
328.854
metric
tons
for
flour
mills.
This
is
a
request
at
the
national
level.

The
U.
S.
nomination
is
only
for
those
facilities
where
the
use
of
alternatives
is
not
suitable.
In
U.
S.
food
processing
plants
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide,
making
these
alternatives
technically
and/
or
economically
infeasible.
­
Geographic
distribution
of
the
facilities:
some
facilities
are
situated
in
areas
where
key
pests
may
occur
at
low
levels,
such
as
those
located
in
the
northern
part
of
the
U.
S.
In
such
cases,
the
U.
S.
is
only
nominating
a
CUE
for
facilities
where
the
key
pest
pressure
is
moderate
to
high.
­
Age
and
type
of
facility:
older
food
processing
facilities,
especially
those
constructed
of
wood,
experience
more
frequent
and
severe
pest
infestations
that
must
be
controlled
by
fumigation.
­
Constraints
of
the
alternatives:
some
types
of
commodities
(
e.
g.,
those
containing
high
levels
of
fats
and
oils)
prevent
the
use
of
heat
as
an
alternative
because
of
its
effect
on
the
final
product
(
e.
g.,
rancidity).
Further,
the
corrosive
nature
of
phosphine
on
certain
metals
prevents
its
use
in
mechanical
and
electrical
areas
of
the
facilities.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
small
grains
such
as
flour,
rice,
oats,
etc.
State
registrations
have
not
yet
been
issued
for
all
states.
Further,
it
will
take
some
time
for
applicators
to
be
trained
in
the
use
of
this
chemical
and
for
its
incorporation
into
a
pest
control
program.
A
registration
decision
concerning
the
establishment
of
sulfuryl
fluoride
tolerances
on
other
processed
food
ingredients
in
a
treated
facility
is
still
pending.
­
Delay
in
plant
operations:
e.
g.,
the
use
of
some
methyl
bromide
alternatives
can
add
a
delay
to
production
by
requiring
additional
time
to
complete
the
fumigation
process.
Production
delays
can
result
in
significant
economic
impacts
to
the
processors.

Overview
of
MBTOC's
prior
Recommendation
MBTOC
recommended
a
total
of
394.843
metric
tons
of
methyl
bromide
for
this
sector
distributed
as
follows:
73.745
metric
tons
for
rice
mills,
14.742
metric
tons
for
bakery
uses,
43.273
for
dry
pet
food
premises,
and
263.083
for
flour
mills.
The
total
recommendation
was
for
394.843
metric
tons
of
methyl
for
these
uses
in
2006.

U.
S.
Response
to
MBTOC's
prior
recommendations
MBTOC
stated
that
proper
sealing
should
allow
rice
mills
to
reduce
their
use
rate
from
31g/
m
3
to
20
g/
m3.
Although
there
is
no
evidence
that
proper
sealing
procedures
are
not
followed
and
that
is
the
reason
for
the
higher
use
rate
than
is
common
for
the
remainder
of
the
sector,
USG
Reply
to
MBTOC
2005
Page
10
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
but
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
this
level
is
not
adequate
to
control
pests
in
the
specific
circumstances
of
the
nomination
when
appropriate
practices
(
eg
careful
sealing
of
the
building/
container
and
other
`
best
practices')
are
followed.
This
reduction
results
in
an
amended
U.
S.
request
of
73.745
metric
tons
of
methyl
bromide
for
this
portion
of
the
sector
as
recommended
by
MBTOC.

MBTOC
appears
to
believe
that
better
sealing
in
rice
facilities
is
necessary
because
they
believe
that
facilities
are
treated
five
times
per
year.
In
this
industry,
the
majority
of
the
milling
facilities
are
old
and
located
in
the
southern
US3
(
close
to
where
rice
is
produced
in
Florida,
Texas,
Louisiana,
Arkansas
and
California)
where
pest
pressures
are
high
and
where
insects
are
able
to
survive
easily
when
driven
outdoors
by
fumigation.
In
addition,
bringing
new
batches
of
rice
into
the
facilities
can
result
in
a
re­
infestation.
USG
does
not
think
that
there
is
further
scope
for
reduction
in
rice
mills.

MBTOC
recommended
that
the
use
rate
for
pet
food
facilities
be
reduced
from
22
to
20
g/
m3.
USG
agrees
that
in
general,
a
use
rate
of
20g/
m3
should
allow
for
adequate
control
of
pests
but
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
this
level
is
not
adequate
to
control
pests
in
the
specific
circumstances
of
the
nomination
when
appropriate
practices
(
eg
careful
sealing
of
the
building/
container
and
other
`
best
practices')
are
followed.
This
reduction
results
in
an
amended
U.
S.
request
of
44.417
metric
tons
of
methyl
bromide
for
this
portion
of
the
sector,
an
increase
of
1.144
metric
tons
over
the
MBTOC
recommended
amount
of
43.273
metric
tons
MBTOC
further
recommended
that
the
request
for
methyl
bromide
used
in
pet
food
facilities
be
reduced
by
10%
"
to
allow
progressive
adoption
of
fumigant
alternatives
such
as
sulfuryl
fluoride
(
recently
registered
for
flour
mills
(
sic)
4,
continuing
adoption
of
heat
technologies,
improved
sealing
of
buildings,
and
increased
optimization
of
IPM
techniques."

Sulfuryl
fluoride
is
not
registered
for
use
on
dry
pet
food.
There
is
at
present
a
legal
question
as
to
whether
a
registration
is
required
(
authorizing
statute
refers
to
"
foods
for
human
and
other
animals")
or
not
required.
Until
this
issue
is
clarified
sulfuryl
fluoride
cannot
be
used
on
pet
foods.

MBTOC
has
recommended
a
further
reduction
of
10%
in
the
amount
of
methyl
bromide
that
can
be
used
to
fumigate
flour
mills,
citing
increased
adoption
of
sulfuryl
fluoride
in
particular,
and
adoption
of
other
alternatives
more
generally.

Addressing
first
the
issue
of
sulfuryl
fluoride;
as
already
noted,
sulfuryl
fluoride
is
not
registered
in
all
States,
nor
is
it
registered
on
the
additional
components
that
transform
flour
into
bread,

3
Location
of
the
facilities
is
dictated
by
close
proximity
to
the
raw
ingredients
and
to
major
markets.
For
example,
the
22
rice
mills
are
located
primarily
in
Gulf
Coast
states
and
California.
4
There
is
a
Federal
registration
for
sulfuryl
fluoride
use
in
flour
mills,
rice
mills,
and
other
small
grain
mills,
however,
many
states
have
registration
requirements
in
addition
to
the
Federal
requirements
and
until
a
pesticide
has
obtained
a
state
`
label'
it
cannot
be
used.
At
present
Sulfuryl
Fluoride
is
registered
in
neither
California
nor
New
York
and
so
cannot
be
use
in
those
states.
Reply
to
MBTOC
2005
Page
11
cake,
pancake
and
other
mixes.
It
cannot,
therefore,
be
used
at
all
in
some
jurisdictions
nor
can
it
be
used
in
many
areas
of
`
combined'
processing
facilities.

The
Montreal
Protocol
calls
for
a
critical
use
nomination
being
granted
when
there
are
no
alternatives
that
are
both
technically
and
economically
feasible,
There
are
companies
that
have
committed
themselves
to
using
alternatives
to
methyl
bromide
regardless
of
the
cost
differences
as
long
as
they
can
continue
to
meet
necessary
sanitary
standards.
One
such
company
shared
their
experience
with
sulfuryl
fluoride
with
us5
A
nine
story
flour
mill
(
1.2
million
cubic
feet6)
was
fumigated
with
sulfuryl
fluoride.
The
fumigation
took
place
from
October
1st
to
October
3rd.
When
this
facility
has
been
fumigated
with
methyl
bromide
the
typical
amount
used
has
been
between
1200
and
1500
lbs7.
The
fumigation
with
sulfuryl
fluoride
used
5250
lbs.
at
a
temperature
of
828
F
over
a
36
hour
rather
than
a
24
hour
period.
Although
fumigation
with
sulfuryl
fluoride
requires
that
the
material
be
left
in
place
for
a
longer
period
than
is
required
for
methyl
bromide,
this
component
does
not
add
to
the
cost
of
the
alternative
in
this
instance
as
it
is
the
practice
of
this
company
to
conduct
fumigations
over
a
three
day
period
to
allow
adequate
time
for
preparation
and
for
the
gas
to
dissipate
at
the
conclusion
of
the
fumigation.

The
cost
of
a
methyl
bromide
fumigation
is
approximately
$
18,500
of
which
approximately
30­
40%
is
the
cost
of
the
chemical.
The
remaining
costs
are
preparing
and
sealing
the
building,
monitoring,
and
unsealing
at
the
conclusion
of
the
fumigation.
The
cost
of
the
sulfuryl
fluoride
fumigation
was
$
48,000,
nearly
three
times
the
cost
of
the
methyl
bromide
fumigation.
The
ancillary
costs
(
prepping,
sealing,
monitoring,
unsealing,
etc.)
are
the
same
for
both
treatments,
the
cost
difference
is
due
to
the
difference
in
the
price
and
amount
used
of
the
sulfuryl
fluoride.

At
present
the
company
that
produces
sulfuryl
fluoride
is
offering
sulfuryl
fluoride
at
a
price
per
pound
that
is
equal
to
or
below
the
price
of
methyl
bromide.
What
is
not
known
is
whether
this
practice
will
continue
when
methyl
bromide
is
no
longer
available.
There
is
currently
a
sulfuryl
fluoride
product
(
Vikane
®
)
that
is
registered
for
non­
food
uses9.
The
market
price
is
$
10/
lb.
Although
we
expect
that
the
food
use
sulfuryl
fluoride
(
Profume
®
)
to
be
less
expensive,
it
is
currently
impossible
to
determine
the
market
price.
This
compares
to
a
methyl
bromide
cost
of
approximately
$
1.5
to
$
3.0
per
pound.

Over
the
last
decade,
food
processing
facilities
in
the
United
States
have
reduced
the
number
of
methyl
bromide
fumigations
by
incorporating
many
of
the
alternatives
identified
by
MBTOC.
The
most
critical
alternative
implemented
is
IPM
strategies,
especially
sanitation,
in
all
areas
of
a
facility.
Plants
are
now
being
monitored
for
pest
populations,
using
visual
inspections,

5
The
company
has
requested
confidentiality.
There
is
great
concern
within
the
industry
that
the
perception
that
food
facilities
are
infested
with
pests
not
become
widespread.
There
was
great
fear
on
the
part
of
company
officials
that
if
the
company
is
identified
with
a
pest
management
issue
the
public
will
boycott
its
products,
feeling
them
(
wrongly)
to
be
unsanitary.
The
discussion
was
arranged
under
the
auspices
of
the
North
American
Millers
Association
and
took
place
in
Arlington
Virginia
in
November
of
2004.
6
1.2
million
cubic
feet
is
approximately
33,980
cubic
meters.
7
1200
to
1500
lbs
is
545
to
680
kg.
The
use
rates
have
thus
varied
between
16
and
20
g/
m3.
8
5250
lbs
is
2380
kg;
82
F
is
28
C.
The
use
rate
is
thus
70g/
m3.
9
Vikane
®
is
primarily
used
as
a
termiticide
for
wood
structures
and
furniture.
Reply
to
MBTOC
2005
Page
12
pheromone
traps,
light
traps
and
electrocution
traps.
When
insect
pests
are
found,
plants
will
attempt
to
contain
the
infestation
with
treatments
of
low
volatility
pesticides
applied
to
both
surfaces
and
cracks
and
crevices.
These
techniques
do
not
disinfest
a
facility
but
are
critical
in
monitoring
and
managing
pests.
However,
when
all
these
methods
fail
to
control
a
pest
problem,
facilities
will
resort
to
phosphine,
heat,
and
if
all
else
fails,
to
methyl
bromide.

Many
facilities
in
the
United
States
also
are
using
both
phosphine
and
heat
treatments
to
disinfest
at
least
portions
of
their
plants.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
is
often
used
to
treat
both
incoming
grains
and
finished
products.
Unfortunately,
phosphine
is
corrosive
to
copper,
silver,
gold
and
their
alloys.
These
metals
are
critical
components
of
both
the
computers
that
run
the
machines
as
well
as
some
of
the
machines
themselves.
In
the
United
States
it
is
specifically
against
the
label
(
illegal)
to
fumigate
in
areas
with
susceptible
metals
(
at:
http://
oaspub.
epa.
gov/
pestlabl/
ppls).
Therefore,
phosphine
is
not
feasible
in
all
areas
of
food
processing
facilities.
Additionally,
phosphine
requires
more
time
to
kill
insect
pests
than
does
methyl
bromide,
so
plants
need
to
be
shut
down
longer
to
achieve
mortality,
resulting
in
economic
losses.
There
are
also
reports
of
stored
product
pests
becoming
resist
to
phosphine
(
Taylor,
1989;
Bell,
2000;
Mueller,
2002).

Heat
treatments
have
a
number
of
problems
in
this
industry.
Not
all
areas
of
a
plant
can
be
efficiently
treated
with
heat.
Some
food
substances,
for
instance
oils
and
butters
will
become
rancid
with
heat
treatments.
Not
all
finished
food
products
can
be
heated
for
the
length
of
time
heat
is
required
for
efficient
kill
of
pests.
In
addition,
geography
of
the
United
States
plays
a
crucial
role
in
the
use
of
heat
treatments.
Food
processing
plants
in
the
northern
United
States
will
experience
winters
with
several
weeks
of
sustaining
temperatures
of
­
32
°
to
­
35
°
C
(­
30
°
to
­
25
°
F).
In
these
areas
plants
have
heaters
and
the
power
plants
have
the
capacity
to
supply
excess
power
as
needed.
However,
the
southern
and
parts
of
the
western
zones
of
the
United
States
are
geographically
quite
different.
Winter
temperatures
there
seldom
reach
 
1.2
°
C
(
30
°
F)
and
when
temperatures
should
fall
that
low,
it
is
typically
for
only
a
few
hours
one
night.
For
many
winters,
these
areas
of
the
U.
S.
don't
freeze
at
all.
Subsequently,
these
facilities
do
not
have
heaters,
nor
do
the
power
plants
have
enough
power
to
allow
them
to
heat
such
large
areas
and
sustain
the
temperatures
necessary
for
an
effective
kill
of
pest
populations.
Additionally,
escaping
insects
can
survive
these
outdoor
temperatures
and
re­
enter
the
facility
after
treatment,
even
when
low
volatility
pesticides
are
used
to
treat
the
surfaces
exiting
the
plant.
Still,
many
southern
and
western
facilities
use
heat
treatments
as
a
spot
treatment
whereas
the
northern
facilities
can
use
heat
treatments
more
extensively.

Potential
economic
losses
were
estimated
for
the
food­
processing
facilities
that
have
not
been
converted
to
heat
treatment.
This
analysis
only
covers
cases
where
heat
treatment
may
potentially
be
technically
feasible,
and
does
not
cover
situations
where
heat
would
degrade
the
commodity
being
processed
(
those
with
fats
and
edible
oils).
Economic
costs
in
the
post­
harvest
uses
of
the
food­
processing
sector
can
be
characterized
as
arising
from
three
contributing
factors.
First,
the
direct
pest
control
costs
are
increased
in
most
cases
because
heat
treatment
is
more
expensive,
and
labor
is
increased
because
of
longer
treatment
time
and
increased
number
of
treatments.
For
food­
processing
facilities
that
are
not
already
using
heat,
capital
expenditure
is
also
required
to
retrofit
them
suitable
for
heat
treatment.
Moreover,
additional
production
downtimes
for
the
use
of
alternatives
are
unavoidable.
Many
facilities
operate
at
or
near
full
Reply
to
MBTOC
2005
Page
13
production
capacity
and
alternatives
that
take
longer
than
methyl
bromide
or
require
more
frequent
application
can
result
in
manufacturing
slowdowns,
shutdowns,
and
shipping
delays.
Slowing
down
production
would
result
in
additional
costs
to
the
methyl
bromide
users.
Economic
cost
per
1000
m3
was
calculated
as
the
additional
costs
of
methyl
bromide
if
methyl
bromide
users
had
to
replace
methyl
bromide
with
heat
treatment.
Implementations
of
heat
treatment
likely
have
substantial
cost
implications
to
the
facilities
that
have
not
been
converted
to
heat
in
the
food­
processing
sector.

Production
downtime
was
estimated
at
two
more
days
per
fumigation
with
heat
and
total
capital
expenditures
for
heat
treatment
was
assumed
to
be
$
1,076
per
1000
m3
with
10­
years
lifespan
with
10%
interest
rate
from
the
data
provided
by
the
CUE
applicants
for
post­
harvesting
uses.
The
potential
economic
losses
associated
with
the
use
of
heat
treatment
mainly
originate
from
the
cost
of
capital
investment.
The
estimated
economic
loss
per
1000
m3
ranges
from
$
2,023
for
rice
milling
to
$
12,439
for
flour/
grain
milling.
The
estimated
economic
losses
as
a
percentage
of
gross
revenue
ranges
from
3%
to
18%
and
the
estimated
economic
loss
as
a
percentage
of
net
revenue
are
over
45%
for
all
the
CUE
applicants
in
the
food­
processing
sector.
The
industries
that
use
methyl
bromide
for
commodity
fumigation
are,
in
general,
subject
to
limited
pricing
power,
changing
market
conditions,
and
government
regulations.
Companies
within
these
industries
operate
in
a
highly
competitive
global
marketplace
characterized
by
high
sales
volume,
low
profit
margins,
and
rapid
turnover
of
inventories.
The
results
suggest
that
heat
treatment
is
not
economically
viable
as
an
alternative
for
methyl
bromide
in
existing
facilities
that
still
use
methyl
bromide.

For
these
reasons,
both
technical
and
economic,
USG
does
not
believe
it
is
appropriate
to
assume
that
alternatives
that
are
both
technically
and
economically
feasible
will
be
available
to
substitute
for
currently
used
methyl
bromide
in
flour
mills
and
is
requesting
that
the
full
request
of
328.854
metric
tons
of
methyl
bromide,
which
is
an
additional
65.771
metric
tons
of
methyl
bromide
over
the
MBTOC
recommended
amount
of
263.083
metric
tons.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
the
technical
assessment
of
the
performance
of
alternatives,
or
the
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
and
the
economic
feasibility
of
sulfuryl
fluoride
if
it
must
be
used
at
a
higher
rate
than
methyl
bromide.

U.
S.
2006
nomination
The
USG
is
requesting
an
additional
66.915
metric
tons
of
methyl
bromide
for
2006
over
the
MBTOC
recommended
amount
of
394.843
metric
tons
for
use
in
flour
mills.
This
represents
an
amended
request
of
461.758
metric
tons
rather
than
the
505.982
metric
tons
of
methyl
bromide
originally
requested.

Citations
Reply
to
MBTOC
2005
Page
14
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F.
H.
2000.
Toxicity
of
diatomaceous
earth
to
red
flour
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and
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flour
beetles
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Tenebrionidae):
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J.
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93(
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Arthur,
F.
H.
1992.
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Bell,
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2000.
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Hou,
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Mahroof,
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Tenebrionidae)
form
flour
mills
in
the
United
States.
J.
Econ.
Entomol.
84(
3):
763­
767.

Zettler,
J.
L.
and
F.
H.
Arthur.
2000.
Chemical
control
of
stored
product
insects
with
fumigants
and
residual
treatments.
Crop
Protection
19:
577­
582.
Reply
to
MBTOC
2005
Page
16
4.
ORCHARD
REPLANT
Overview
of
MBTOC's
prior
Recommendation
The
U.
S.
requested
827.994
metric
tons
of
methyl
bromide
for
use
in
orchard
replant
for
2006.
The
request
was
distributed
as
follows:
826.336
metric
tons
for
orchard
use
and
1.658
metric
tons
for
research
purposes.

MBTOC
recommended
a
reduced
amount
of
527.6
metric
tons
but
appeared
to
agree
that
for
certain
conditions
there
are
no
feasible
alternatives.
Discussion
with
MBTOC
members
at
the
16th
MOP
(
Prague,
November
2004)
indicated
that
the
basis
for
the
recommended
reduction
was
that
MBTOC
believes
that
alternatives
are
available
for
non­
heavy
(
non­
clay)
soils.
In
addition
during
that
discussion
MBTOC
members
admitted
that
the
amount
of
methyl
bromide
used
in
a
given
year
could
vary
widely
based
on
the
health
of
the
orchards
and
the
economics
of
producing
the
crop.

U.
S.
Response
to
MBTOC's
prior
recommendations
USG
technical
experts
remain
skeptical
that
technically
and
economically
feasible
alternatives
are
available
but
observe
that
less
methyl
bromide
is
used
in
this
sector.
The
U.
S.
does
not
agree
with
the
technical
basis
of
the
MBTOC's
rationale
for
the
reduction,
but
will
not
contest
it
at
this
time.
The
U.
S.
reserves
the
right
to
re­
visit
this
issue
should
we
become
aware
of
data
demonstrating
that
there
are
no
technically
and
economically
feasible
alternatives
in
the
specific
circumstances
of
the
nomination.

U.
S.
2006
nomination
The
U.
S.,
therefore,
accepts
the
MBTOC
recommendation
of
527.6
metric
tons.
Reply
to
MBTOC
2005
Page
17
5.
ORNAMENTALS
Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
162.817
metric
tons
of
methyl
bromide
for
use
on
ornamentals
(
cut
flowers
and
foliage)
for
2006.
The
request
was
distributed
as
follows:
158.797
metric
tons
for
use
on
ornamentals
and
4.060
metric
tons
for
research
purposes.

The
U.
S
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
ornamental
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:

­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
ornamental
production.
­
Key
target
pests:
the
U.
S.
is
only
nominating
a
CUE
where
the
key
pest
pressure
is
moderate
to
high.
­
Regulatory
constraints:
e.
g.,
in
some
areas
of
the
United
States
1,3­
Dichloropropene
use
is
limited
due
to
township
caps
in
California.
­
Delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
Cut
flowers
are
often
marketed
for
a
certain
time
of
year
or
holiday.
Missing
specific
dates
can
result
in
very
large
revenue
losses
to
the
grower.

Overall,
the
ornamentals
industry
has
hundreds
of
crop
species
and
thousands
of
varieties.
This
diversity
makes
finding
methyl
bromide
alternatives
for
each
crop
species
complex,
time
consuming
and
costly
(
Schneider,
2003).

As
part
of
the
overall
ornamentals
industry,
the
cut
flower,
foliage,
and
bulb
industry
is
very
complex.
For
example,
a
single
grower
in
California
may
grow
as
many
as
100
species
and/
or
varieties
in
a
single
year.
Growers
must
find
methyl
bromide
alternatives
that
will
control
previous
crops
grown
on
the
site,
as
well
as
a
diversity
of
key
pests,
which
vary
for
each
crop
variety.
For
example,
in
ranunculus,
residual
tubers,
bulbs,
and
seeds
from
the
previous
crop
must
be
killed
because
they
are
reservoirs
for
nematodes
and
soil
pathogens
and
considered
to
be
weeds
themselves
as
they
are
off­
variety.
Along
with
these
issues,
there
are
concerns
about
phytotoxicity
and
registration
with
alternative
chemicals
(
Schneider,
2003;
Elmore
et
al.,
2003b).
Recent
experiences
with
iodomethane
indicate
that
new
chemistries
can
take
several
years
to
be
registered
by
the
U.
S.
EPA
and
the
state
regulatory
agencies,
such
as
California
Department
of
Pesticide
Regulation.
In
addition,
township
caps
in
California
restrict
the
amount
of
1,3­
Dichloropropene
that
can
be
used
in
a
given
area
(
Trout,
2001).
Buffer
zones
may
also
limit
the
adoption
of
alternatives.
Reply
to
MBTOC
2005
Page
18
Overview
of
the
MBTOC's
prior
recommendation
MBTOC
recommended
for
2005
that
154.00
metric
tons
of
methyl
bromide
be
allowed
for
this
use
but
was
unable
to
assess
this
request
for
2006,
stating
that
more
information
was
needed
specific
to
the
request
and
the
circumstances
of
the
nomination.
Further,
MBTOC
stated
that
without
additional
information
they
would
be
unable
to
recommend
above
84.00
metric
tons
of
methyl
bromide.

U.
S.
Response
to
MBTOC's
prior
recommendations
California
Although
it
is
difficult
to
determine
acreage
information
for
cut
flowers,
production
data
for
the
major
cut
flower
and
bulb
species
grown
is
available
(
See
Table
1)
and
estimates
of
the
acreage
have
been
made
(
See
Table
2).

CALIFORNIA
ORNAMENTALS
­
TABLE
1
PRODUCTION
OF
MAJOR
SPECIES
SPECIES
#
FLOWER
BUNCHES
IN
2003
Alstoemeria
892,789
Carnations
1,694,870
Delphinium
3,617,186
Gladiolus
Data
not
released
Gerbera
62,638,650
Iris
5,823,242
Lilium
6,247,027
Chrysanthemums
1,273,742
Pompons
6,350,127
Roses
7,360,729
Snapdragons
2,976,219
Source:
Prince
&
Prince,
Inc.
Survey,
2003
CALIFORNIA
ORNAMENTALS
­
TABLE
2
PARTIAL
LISTING
AND
ESTIMATE
OF
CUT
FLOWER
AND
FOLIAGE
AREA
PRODUCED
IN
CALIFORNIA
IN
2002
CROP
AREA
(
USUALLY
FIELD)
­
HA
AREA
(
USUALLY
GREENHOUSE)
M
2
Alstroemeria
8
(
0.3%)
47,100
(
3.2
%)
Antirrhinum
(
snapdragon)
126
(
5%)
164,898
(
11.3%)

Aster
57,598
(
4%)
Calla
lily
16
(
0.6%)
Carnation
30
(
1.2%)
21,739
(
1.5%)
Chrysanthemum
88
(
3.3%)
281,023
(
19
%)
Delphinium
22
(
0.8%)
Eucalyptus
54
(
2%)
Gerbera
214,413
(
14.7%)
Gypsophila
55
(
2%)
Iris
(
Dutch)
18
(
0.7%)
Larkspur
6
(
0.2%)
Reply
to
MBTOC
2005
Page
19
Lilium
32
(
1.2%)
205,959
(
14.2%)
Limonium
spp.
13
(
0.5%)
Lisianthus
13
(
0.5%)
Protea
190
(
7.3%)
Rose
41
(
1.6%
­
all
greenhouse)
123,557
(
8.5%)
Stock
(
Matthiola)
26
(
1%)
Wax
flower
317
(
12%)
Other
791
(
30%)
59,177
(
4%)
Greenhouse
misc.
70
(
2.7%)
278,700
(
19%)
Field
misc.
303
(
11.6%)
Cut
greens
misc.
389
(
15%)
Total
2609
1,454,164
m2
(
145
ha)

Florida
According
to
the
2002
Census
of
Agriculture,
cut
flowers
and
florist
greens
were
grown
on
3,402
ha
(
outdoors)
and
foliage
plants
were
grown
on
1,198
ha
(
outdoors).
Approximately
2,511
additional
ha
of
cut
flowers,
florist
greens,
and
foliage
plants
were
grown
indoors
(
under
glass)
(
2002
Census
of
Agriculture).

Caladiums
are
grown
on
642
hectares.
The
remaining
776
hectares
are
for
other
species
of
cut
flowers,
foliage
and
bulb
crops.
Although
it
would
be
useful
to
have
more
accurate
acreage
information
for
each
species
this
has
been
difficult
to
obtain
for
several
reasons.
1)
There
are
hundreds
of
species
of
cut
flowers,
foliage,
and
bulb
crops
grown,
and
often
several
species
are
grown
in
the
same
field
in
the
same
year.
2)
The
species
grown
are
constantly
changing
and
fluctuations
may
occur
at
any
time.
For
example,
several
years
ago
sunflowers
were
not
a
major
commercial
crop
in
Florida
and
currently
it
is
a
major
crop.
3)
There
are
no
records
available
that
show
which
crops
are
grown
at
any
one
time.
Due
to
the
sheer
number
of
species,
and
the
constant
fluctuation
in
the
industry,
the
acreage
of
each
species
is
unable
to
be
determined.
Table
3
shows
a
few
of
the
major
crops
grown
and
the
number
of
spikes
or
stems
produced,
although
acreage
information
was
not
available.
This
information
indicates
that
gladioli
are
another
major
crop
grown
in
Florida,
and
would
be
expected
to
be
grown
on
more
acreage
than
some
of
the
other
crops.

The
only
three
cut
flower
species
identified
by
the
Florida
Agricultural
Statistics
Service
are
gladioli,
lilies
and
snapdragon.
These
are
assumed
to
have
the
highest
acreage.
These
crops
have
also
been
identified
by
the
applicant
as
using
MB.

FLORIDA
ORNAMENTALS
­
TABLE
3
CROP
PRODUCTION
FOR
CERTAIN
CUT
FLOWER
SPECIES
2
2001
2002
2003
Crop
#
of
producers
Quantity
sold
(
1000
spikes)
1
#
of
producers
Quantity
sold
(
1000
spikes)
1
#
of
producers
Quantity
sold
(
1000
spikes)
Gladioli
4
40,331
4
49,581
4
39,444
Snapdragons
5
6,806
4
4,415
4
4,757
Lilies
4
3,031
3
2,257
­
­
Other
cut
­
­
9
­
10
­
Reply
to
MBTOC
2005
Page
20
flowers
1
Quantity
of
lilies
sold
1000
stems.
2
This
table
only
includes
data
for
growers
with
sales
over
$
100,000.
Source:
Foliage,
Floriculture,
and
Cut
Greens,
2003;
Foliage,
Floriculture,
and
Cut
Greens,
2004
Using
several
data
sources,
a
rough
estimate
of
the
number
of
acres
of
gladioli
grown
can
be
obtained.
The
quantity
sold,
shown
in
Table
3,
was
averaged
and
divided
by
an
average
yield,
which
was
calculated
using
data
from
1991
to
1998.
This
method
resulted
in
approximately
638
ha
of
gladioli.
This
number
does
not
take
into
account
the
variability
in
yield
in
an
individual
year
or
if
yields
have
changed
since
1998
(
USDA,
1999).

FLORIDA
ORNAMENTALS
­
TABLE
4
OTHER
CUT
FLOWER
SPECIES
GROWN
IN
FLORIDA
Crop
Crop
Rotation
Limitation
Delphinium
Larkspur
Gerbera
Lisianthus
Sunflower
Aster
Chrysanthemum
These
species
are
often
sensitive
to
the
same
insects
and
pests
as
the
other
cut
flower,
foliage
and
bulb
species.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
or
their
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
longer
plant
back
intervals,
and
the
economic
feasibility
if
key
market
windows
are
missed.

U.
S.
2006
nomination
The
USG
is
reiterating
its
request
for
162.817
metric
tons
of
methyl
bromide
for
use
in
this
sector
(
cut
flowers
and
foliage)
which
represents
a
request
of
158.797
metric
tons
for
direct
use
on
ornamentals
and
4.060
metric
tons
for
research
purposes.

Citations
Elmore,
C.,
J.
MacDonald,
H.
Ferris,
I.
Zasada,
S.
Tsjvold,
K.
Robb,
C.
Wilen,
L.
Bolkin,
L.
Yahaba,
J.
Roncoroni,
2003a,
Alternatives
to
Methyl
Bromide
for
Control
of
Weeds,
Nematodes,
and
Soil­
Borne
Fungi,
Bacteria
in
Coastal
Ornamental
Crops
 
Draft.
Reply
to
MBTOC
2005
Page
21
Elmore,
C.,
J.
Roncoroni,
K.
Robb,
C.
Wilen,
and
H.
Ajwa,
2003b,
Preplant
Pest
Production
in
Ranunculus
Production,
Proceeding
from
the
2003
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions,
Web
address:
www.
mbao.
org
Gerik,
J.,
2003,
Evaluation
of
Alternatives
to
Methyl
Bromide
for
Floriculture
Crop
 
Progress
Report
submitted
by
USDA­
ARS.

Gilreath,
J.
P.,
R.
McSorley,
and
R.
J.
McGovern,
1999,
Soil
Fumigant
and
Herbicide
Combinations
for
Soilborne
Pest
Control
in
Caladium,
Proc
Fla
State
Hort
Soc
112:
285­
290.

Gilreath,
J.,
2004,
University
of
Florida
 
IFAS,
Personal
communication.

Mellano,
M,
Mellano
and
Company,
2003,
Personal
communication.

Overman,
A.
J.
and
B.
K.
Harbaugh,
1983,
Soil
Fumigation
Increases
Caladium
Tuber
Production
on
Sandy
Soil,
Proc
Fla
State
Hort
Soc
96:
248­
250.

Pizano,
M.,
2001,
Floriculture
and
the
Environment:
Growing
Flowers
without
Methyl
Bromide,
United
Nations
Environment
Programme.

Ragsdale,
N.,
USDA­
ARS
National
Program
Staff,
2004,
Personal
communication.

Schneider,
S.,
E.
Rosskopf,
J.
Leesch,
D.
Chellemi,
C.
Bull,
and
M.
Mazzola,
2003,
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
Research
on
Alternatives
to
Methyl
Bromide:
Pre­
plant
and
Post­
harvest,
Pest
Manag
Sci
59:
814­
826.

Semer,
C.
R.
IV,
1987,
Basamid
and
Methyl
Bromide
Compounds
as
Fumigants
in
Carnation
and
Chrysanthemum
Production
in
Selected
Propagation
Media,
Proc
Fla
State
Hort
Soc
100:
330­
334.

Trout,
T.,
2001,
Impact
of
Township
Caps
on
Telone
Use
in
California.

Trout,
T.,
2003,
Impact
of
Township
Caps
on
Telone
Use
in
California,
Proc.
Annual
International
Research
Conference
on
MB
Alternatives
and
Emission
Reductions,
p.
109.
Reply
to
MBTOC
2005
Page
22
6.
PEPPERS
Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
1,498.53
metric
tons
of
methyl
bromide
for
use
on
pepper
crops
in
the
U.
S.
for
2006.
This
amount
was
requested
for
California
(
59.659
metric
tons),
Florida
(
1,006.074
metric
tons),
Georgia
(
242.761
metric
tons),
Michigan
(
9.482
metric
tons),
and
a
group
of
States
in
the
southeastern
part
of
the
U.
S.
(
77.711
metric
tons).
10
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
pepper
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:


pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
pepper
production.


geographic
distribution
of
key
target
pests11:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
peppers
where
the
key
pest
pressure
is
moderate
to
high.
An
example
is
areas
of
moderate
to
high
nutsedge
infestation
in
the
Southeastern
U.
S.


regulatory
constraints:
e.
g.,
1,3
D
use
is
limited
in
Georgia
and
Florida
due
to
the
presence
of
karst
geology
and
in
California
due
to
township
caps.


delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
1,3
D
+
chloropicrin
is
two
weeks
longer
than
methyl
bromide
+
chloropicrin,
and
in
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives
(
this
is
a
regulatory
requirement).
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
In
addition,
delay
in
planting
and
harvesting
may
preclude
the
planting
and
harvesting
of
an
additional
crop
on
the
treated
acreage,
causing
an
additional
economic
loss.


cold
soil
temperatures:
some
alternatives
cannot
be
used
effectively
and
are
precluded
from
such
uses
by
the
label
until
the
soil
temperatures
is
above
40
 
F
(
approximately
5
 
C.)

Overview
of
MBTOC's
prior
Recommendation
MBTOC
recommended
804.033
tons
of
methyl
bromide
for
this
use
distributed
as
follows:
9.482
tons
for
Michigan;
172.629
tons
for
Georgia;
525.121
tons
for
Florida;
55.261
tons
for
the
southeastern
US;
and
41.511
tons
for
California.

U.
S.
Response
to
MBTOC's
prior
recommendations
MBTOC
does
not
appear
to
have
accounted
for
the
new
information
regarding
the
extent
of
nutsedge
infestation
affecting
this
crop.
MBTOC
suggests
that
alternatives
are
available
in
California,
that
growers
are
using
more
than
200kg/
ha,
and
that
alternatives
are
both
technically
10
These
states
are:
Alabama,
Arkansas,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia.
These
States
have
similar
climate
and
terrain
and
face
similar
pests.
11
Key
target
pasts
are
those
pests
that
cannot
be
controlled
by
available
alternatives
to
methyl
bromide.
Reply
to
MBTOC
2005
Page
23
and
economically
feasible
in
non­
karst
areas
of
the
southeastern
U.
S.
(
including
Georgia
and
Florida)
so
that
20%
is
deducted
for
that
phasing
of
alternatives.
We
will
address
each
of
these
issues
separately.

a.
MBTOC
used
their
own
numbers
for
nutgrass
(
nutsedge)
rather
than
the
numbers
provided
by
the
U.
S.

In
2003,
Dr.
Stanley
Culpepper
of
the
University
of
Georgia
conducted
a
survey
of
land
under
cultivation
with
various
crops
to
determine
the
proportion
of
land
(
by
crop)
that
was
infested
with
various
levels
of
nutsedge.
The
values
selected
were
those
used
in
published
literature
and
characterized
as
`
none'
(
no
plants
per
square
yard12),
`
light'
(
fewer
than
five
plants
per
square
yard),
`
moderate'
(
five
to
thirty
plants
per
square
yard),
and
`
severe'
(
more
than
thirty
plants
per
square
yard).
This
information
was
used
to
estimate
nutsedge
information
for
the
entire
southeastern
region
(
including
the
State
of
Florida)
because
the
entire
region
has
similar
climate,
soils
and
rainfall.
In
the
judgment
of
U.
S.
government
experts,
familiar
with
U.
S.
agriculture
and
with
the
southeastern
growing
regions
in
particular,
nutsedge
infestations
are
similar
throughout
the
region13.
For
the
previous
year's
estimates
of
nutsedge
infestation
(
those
used
in
the
2005
nomination),
similar
estimates
were
used
throughout
the
southeastern
growing
region.
These
estimates
were
the
fruit
of
a
half
dozen
phone
calls
to
growers
with
large
tomato
operations
in
one
or
more
of
the
southeastern
states.
The
estimates
derived
were
applied
to
all
crops
in
all
of
the
southeastern
states.
The
new
data
represented
a
significant
improvement
in
accuracy
over
the
previous
estimates,
in
the
judgment
of
U.
S.
experts
familiar
with
the
circumstances
of
the
nomination.
The
USG
is
requesting
restoration
of
the
amount
deducted
for
this
factor.
14
Information
used
for
the
2005
nomination
was
developed
by
asking
some
large
tomato
operations
(
growers
with
large
tomato
acreages
in
several
states)
to
`
guestimate'
the
proportion
of
tomato­
growing
acreage
impacted
by
`
none',
`
light',
`
moderate'
and
`
heavy'
nutsedge
infestations
and
to
compare
these
across
that
various
states
in
which
the
growers
have
operations.
Information
on
the
proportion
of
impacted
tomato
area
was
then
used
for
other
crops
throughout
the
southeastern
growing
region.

The
effort
to
gather
more
refined
and
reliable
estimates
of
the
prevalence
of
this
key
pest
was
one
of
many
improvements
in
estimating
the
amount
of
methyl
bromide
critically
needed
by
U.
S.
agriculture,
which
was
undertaken
to
provide
MBTOC
with
the
best
information
possible.
Replacing
U.
S.­
provided
survey
values
with
MBTOCderived
values
with
no
explanation
of
how
MBTOC
is
better
able
to
make
this
judgment
than
are
the
U.
S.
officials
familiar
with
actual
conditions
casts
doubt
on
the
integrity
of
the
MBTOC
deliberative
process.

12
One
square
yard
is
approximately
9/
10
of
a
square
meter.
13
Conversations
with
officials
in
the
State
of
Florida
regarding
the
extent
of
nutsedge
infestation
indicate
that
these
officials
believe
that
the
infestation
in
Florida
is
more
severe
that
in
Georgia.
They
are
currently
investigating
whether
a
survey
of
cultivated
land
in
Florida
for
nutsedge
infestation
can
be
undertaken.
14
The
U.
S.
is
unable
to
exactly
determine
how
that
various
factors
that
MBTOC
used
were
reflected
in
the
final
amounts.
The
U.
S.
technical
experts
had
been
promised
a
spreadsheet
so
that
the
amounts
could
be
disaggregated
but
were
not
provided
with
one.
Reply
to
MBTOC
2005
Page
24
b.
Alternatives
are
technically
and
economically
feasible
so
a
20%
reduction
for
phase­
in
of
alternatives
such
as
1,3D/
Pic
or
metam
sodium
was
used:
alternatives
can
be
used
in
areas
where
1,3­
D
use
is
not
appropriate
MBTOC
disagrees
with
the
U.
S.
assessments
of
yield
loss,
which
is
the
basis
for
the
MBTOC
recommendation
of
economic
feasibility.

The
U.
S.
assessments
of
yield
loss
were
developed
from
technically
appropriate
studies
relevant
to
the
specific
circumstances
of
the
U.
S.
situation.
Technically
appropriate
studies
are
those
which:

 
Included
an
untreated
control
for
comparison
purposes
 
Included
information
on
the
(
key)
pests
present
in
the
treated
area
 
Give
estimates
of
yield
changes
(
differences)
 
Include
methyl
bromide
as
a
standard
The
U.
S.
nomination
was
restricted
to
those
situations
where
the
presence
and
prevalence
of
pests
(`
key'
pests)
that
could
not
be
controlled
by
alternatives
to
methyl
bromide
was
moderate
to
severe15
and
would
result
in
yield
loss.

The
U.
S.
technical
experts
asked
MBTOC
to
explain
the
basis
for
their
decision16
and
were
told
that
in
some
cases
a
meta
analysis
served
as
the
basis,
and
in
other
cases
the
basis
was
`
experience'.
The
procedure
MBTOC
used,
as
we
understand
it,
was
not
a
meta
analysis.
A
meta
analysis
includes
a
statistical
analysis
of
the
information,
and
compares
only
those
studies
which
are
similar
enough
from
a
statistical
standpoint
that
they
can
be
combined
and
analyzed
as
if
they
comprised
one
study.
Further,
the
studies
need
to
be
identified,
appraised
and
summarized
according
to
an
explicit
and
reproducible
methodology
that
is
designed
to
answer
a
specific
research
question.
In
this
case,
the
appropriate
research
question
would
be
the
performance
of
alternatives
to
methyl
bromide
under
the
conditions
of
the
U.
S.
nomination
(
i.
e.
with
moderate
to
severe
pressure
from
key
pests).
The
studies
used
in
the
meta
analysis
are
not
listed
and
no
indication
is
given
of
the
criteria
used
to
include
or
exclude
a
study
from
the
analysis,
which
presents
a
serious
problem
in
applying
the
results.
Our
understanding
is
that
this
analysis
does
include
some
studies
conducted
under
circumstances
that
are
not
similar
to
the
limited
conditions
included
in
the
U.
S.
nomination,
such
as
the
presence
of
moderate
to
severe
pest
pressure.

The
null
hypothesis
would
be
that
alternatives
work
as
well
as
methyl
bromide
in
the
conditions
of
the
U.
S.
nomination.
The
U.
S.
nomination
is
specifically
for
the
use
of
methyl
bromide
where
key
pests
(
pests
not
adequately
controlled
by
alternatives
to
methyl
bromide)
are
present
at
moderate
to
severe
levels
and/
or
soil,
climate,
terrain,
or
regulatory
conditions
are
such
that
15
In
the
judgment
of
U.
S.
experts
pressure
was
such
that
yield
losses
of
the
magnitude
of
those
used
in
the
economic
assessment
would
be
sustained.
16
MBTOC
asserted
that
alternatives
were
both
technically
and
economically
feasible
for
the
pre­
plant
sectors
of
field
grown
peppers,
strawberries,
and
tomatoes.
Reply
to
MBTOC
2005
Page
25
alternatives
to
methyl
bromide
either
cannot
be
used
or
result
in
significant
economic
losses
when
used.
These
economic
losses
must
be
of
sufficient
magnitude
that
they
render
the
alternative
not
economically
feasible.

When
asked
for
references,
USG
experts
were
directed
to
"
the
Porter
paper
in
press".
USG
experts
have
examined
a
"
Porter
paper
in
press"
17
and
find
a
number
of
concerns
with
respect
to
its
application
to
the
specific
circumstances
of
the
U.
S.
nomination.
Although
it
is
difficult
to
be
certain
how
the
MBTOC
analysis
was
conducted
and
what
it
includes
because
it
has
not
been
reviewed
and
published
and
was
not
provided
to
the
U.
S.
experts
to
evaluate18,
U.
S.
experts
were
able
to
make
some
educated
guesses
about
the
analysis19.

A
version
of
the
paper
was
presented
by
Dr.
Ian
Porter
at
the
Methyl
Bromide
Alternatives
Organization
meeting
in
San
Diego,
November
2003
and
was
the
subject
of
some
controversy
and
concern
among
a
number
of
participants.
Dr.
Porter's
paper
included
a
number
of
papers,
which
U.
S.
experts
believe
are
not
appropriate
for
use
in
determining
the
usefulness
of
alternatives
because
the
research
was
carried
out
under
conditions
of
no
pest
pressure,
and
are
therefore
not
relevant
to
the
specific
circumstances
of
our
nomination20.
If
few
or
no
pests
are
present,
any
alternative,
or
indeed
not
using
any
pesticide
at
all,
will
all
work
equally
well.
By
including
situations
where
there
is
no
pest
pressure
one
in
effect
adds
(
many)
"
100"
to
the
equation21
describing
the
differences
in
yield
between
crops
grown
using
methyl
bromide
and
those
grown
using
an
alternative.
This
has
the
effect
of
lowering
the
average
difference
between
yields
using
methyl
bromide
and
yields
using
an
alternative.
If
a
sufficient
number
of
"
100"
are
added,
the
result
will
be
to
(
falsely)
eliminate
the
yield
differences
between
methyl
bromide
and
the
alternatives.

In
other
papers,
pests
were
present
but
they
were
not
the
pests
present
in
all
of
the
U.
S.
circumstances.
Taking
the
case
of
the
southeastern
US,
for
example,
weeds,
diseases,
fungi,
and
nematodes
all
afflict
the
crops.
Some
of
these
pests
can
be
controlled
with
alternatives,
but
some
of
the
weeds,
in
particular
nutsedges
(
nut
grasses),
nightshades,
and
some
hard
coated
seeds,
cannot.
Situations
without
weeds
will
show
small
or
no
yield
losses
when
alternatives
are
used
17
Porter,
I.,
S.
Mattner,
R.
Mann,
R.
Gounder,
J.
Banks,
and
P.
Fraser.
1994.
Strawberry
Fruit
Production
and
results
from
trials
in
Different
Geographic
Regions.
A
Presentation
to
the
Methyl
Bromide
Alternatives
Conference,
Lisbon,
September
1994.
18
U.
S.
experts
requested
references
from
some
of
the
authors
of
the
studyso
that
the
studies
included
could
be
evaluated
against
the
circumstances
of
the
U.
S.
nomination,
but
they
have
not
been
provided.

19
Some
of
this
material
had
been
previously
presented
at
the
Methyl
Bromide
Alternatives
Organization
2003
meeting
(
San
Diego).
At
that
time
U.
S.
experts
expressed
their
view
that
many
if
not
most
of
the
studies
were
not
an
appropriate
application
of
the
information.

20
For
example,
some
trials
are
used
for
residue
tests.
These
tests
are
likely
to
be
carried
out
in
conditions
of
little
or
no
pest
pressure
in
order
to
have
enough
harvested
fruit
to
to
test
for
residue.
The
Porter
paper
does
not
indicate
which
of
the
studies
used
(
but
not
cited)
where
for
the
purposes
of
examining
pesticide
residues.

21
The
actual
procedure
was
to
add
in
yields
expressed
as
a
percentage
of
(
anticipated)
yield
using
methyl
bromide.
How
this
yield
was
estimated
is
puzzling
as
many
of
the
studies
did
not
include
a
methyl
bromide
control.
Because
there
was
no
indication
of
pest
pressure
in
many
instances,
many
of
the
entries
indicated
yields
of
approximately
100%,
obviating
the
differences
between
methyl
bromide
and
the
alternatives.
Reply
to
MBTOC
2005
Page
26
while
the
true
situation
when
(
key)
weeds
are
present
is
that
there
are
relatively
large
yield
losses.
Including
these
factors
again
has
the
effect
of
adding
"
100"
yield
difference
as
many
times
as
there
are
these
papers.

If
the
issue
in
question
was
to
average
all
papers,
describing
some
"
average"
worldwide
situation,
the
procedure
would
be
correct.
However,
The
U.
S.
submitted
requests
for
continued
methyl
bromide
use
only
in
instances
of
sufficiently
high
pest
pressure
(
not
`
average'
conditions)
for
pests
which
cannot
be
controlled
by
alternatives
to
methyl
bromide.

In
the
case
of
crops
other
than
strawberries,
the
basis
for
MBTOC's
suggestion
of
no
differences
in
yields
between
methyl
bromide
treatments
and
treatments
with
the
alternatives
is
more
difficult
to
assess.
MBTOC
indicated
to
us
in
recent
meetings
at
MOP­
16
that
their
expert
judgment
was
the
basis
for
the
finding
that
alternatives
were
technically
and
economically
feasible.
It
is
impossible
to
determine
from
this
statement
whether
the
conditions
used
by
the
experts
to
make
their
findings
are
similar
to
the
particular
conditions
of
the
U.
S.
nomination.
Given
what
we
already
know
about
the
applicability
of
the
meta
analysis
for
strawberries
to
the
U.
S.
circumstances,
we
are
concerned
that
MBTOC
may
not
be
limiting
their
evaluation
to
experience
accrued
in
situations
similar
to
those
prevailing
in
the
portions
of
the
U.
S.
for
which
methyl
bromide
is
requested,
but
rather
relying
on
more
generalized
experience
to
make
these
judgments
for
which
references
have
been
provided.
The
U.
S.
disagrees
with
the
MBTOC
assessment
of
yield
loss
in
the
circumstances
of
the
U.
S.
nomination.

Turning
now
to
the
component
of
economic
loss
that
is
a
consequence
of
market
timing
we
find
that
MBTOC
has
not
accounted
for
losses
arising
from
missing
market
windows,
and
other
losses
due
to
timing,
such
as
shorter
harvesting
periods
and
loss
of
the
opportunity
to
plant
a
`
follow­
on'
or
second
crop.

Experts
are
familiar
with
high
prices
for
fresh
produce
early
in
the
season,
prices
which
decline
as
the
produce
becomes
abundant
(
and
more
familiar)
later
in
the
season.
The
U.
S.
has
provided
marketing
data
documenting
the
existence
of
these
market
windows
and
their
effects
on
the
revenue
and
profits
earned
by
farmers.
Anecdotally,
farmers
tell
us
that
virtually
al
of
their
net
revenue
(
approximately
90%)
above
cost
is
earned
during
the
short
period
of
high
prices.
For
some
crops,
75%
of
the
economic
loss
is
due
to
missing
a
market
window
rather
than
through
smaller
crops,
lower
fruit
quality,
or
higher
costs
of
using
alternatives
Many
of
the
alternatives
will
cause
farmers
to
miss
the
market
window.
In
conditions
of
cold
soil
temperatures,
such
as
in
Michigan
and
coastal
California,
where
the
growing
season
is
short,
alternatives
cannot
be
used
until
the
soil
temperatures
reach
at
least
40
F.
This
temperature
is
reached
3­
4
weeks
into
the
growing
season,
delaying
planting
and
consequently
harvesting
for
that
time.
Because
the
Michigan
growing
season
is
already
short
due
to
the
cold
temperatures,
even
apart
from
missing
the
market
window,
delaying
planting
will
result
in
a
smaller
harvestable
amount.
In
other
situations
the
"
plant­
back"
interval
is
longer,
by
two
weeks,
relative
to
the
methyl
bromide
plant
back
times.
Requiring
a
longer
interval
before
a
crop
can
be
planted
will
delay
the
harvesting,
again
causing
a
farmer
to
miss
a
market
window.
Some
alternatives
also
require
a
different
bed
preparation,
which
will
also
delay
the
planting
time.
The
strawberry
crop
in
California
is
one
example
of
this
situation.
Reply
to
MBTOC
2005
Page
27
It
is
not
clear
that
MBTOC
considered
the
specific
circumstances
of
the
U.
S.
nomination,
which
are
that
methyl
bromide
is
requested
only
for
situations
where
regulatory
concerns
preclude
use
of
an
alternative
or
where
there
are
`
key'
pests
present
at
moderate
to
severe
levels,
or
where
terrain
conditions
(
temperature,
topography)
result
in
no
alternative
being
technically
and
economically
feasible.
MBTOC
has
not
referenced
research
findings
to
support
their
view
that
alternatives
are
both
technically
and
economically
feasible,
while
the
U.
S.
has
presented
extensive
results
in
the
circumstances
of
the
nomination
to
support
our
request.

Georgia
Peppers
are
generally
produced
using
mechanized
practices
that
involve
injection
of
methyl
bromide
to
a
depth
of
20
 
25
cm.
Weeds,
especially
nutsedge,
are
the
most
serious
concern
precipitating
MB
use
in
both
transplant
beds
and
the
field
although
nightshade
and
hard
coated
seeds
are
also
problems.
Nutsedge
species
grow
even
under
adverse
conditions,
resist
traditional
and
modern
methods
of
weed
control,
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds.
Most
preemergence
herbicides
do
not
provide
effective
control
of
nutsedge
for
one
crop
cycle
let
alone
multiple
crop
cycles.
Many
of
the
newer
sulfonyl
urea
herbicides
are
not
as
effective
preemergence
as
is
necessary
to
be
effective
under
the
plastic
tarps
as
postemergence
(
60
to
70
percent
for
one
crop
cycle
versus
90%
postemergence).
In
addition
to
weeds,
soil­
borne
fungal
pathogens
(
such
as
Phytophthora
blight)
and
plant­
parasitic
nematodes
(
e.
g.
Meloidogyne
spp.)
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thereby
necessitating
annual
treatment
with
a
broad­
spectrum
soil
fumigant.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997).

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require
a
21
to
28­
day
interval
before
planting,
compared
to
14
days
for
MB
or
methyl
bromide
with
Pic.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops
(
Kelley,
2003
Nutsedge
management
has
proven
to
be
difficult
due
to
the
perennial
growth
habit
of
nutsedge
and
tubers
as
primary
means
of
propagation.
There
are
no
herbicides
which
control
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041.)
Smetolachlor
can
suppress
yellow
nutsedge
for
a
single
crop
cycle
but
would
need
to
be
reapplied
for
multiple
crops
along
with
removing
and
replacing
the
existing
plastic
tarps.
Approximately
81%
of
the
Georgia
pepper
area
is
considered
to
have
moderate
to
severe
infestations
of
nutsedge
(
Culpepper,
2004).
Research
suggests
that
metam
sodium
can,
in
some
situations,
provide
effective
pest
management
for
certain
diseases
and
weeds.
However,
even
though
there
have
been
nearly
50
years
experience
with
metam
sodium,
(
which
breaks
down
to
methyl
isothiocyanate)
nutsedge
control
results
have
been
unpredictable.
Reply
to
MBTOC
2005
Page
28
Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
(
The
data
from
this
tomato
study
are
being
cited
because
comparable
pepper
data
are
not
available.)

Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering
1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists
Further,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology.

Furthermore,
trials
of
metam­
sodium
and
1,3
D
+
chloropicrin
(
and
various
combinations
thereof)
are
based
on
small
plot
research
trials
conducted
in
the
Southeastern
United
States
on
crops
other
than
peppers.
For
fungi
and
nutsedge,
no
on­
farm,
large­
scale
trials
have
yet
been
done.
Some
researchers
have
also
reported
that
these
MB
alternatives
degrade
more
rapidly
in
areas
where
they
are
applied
repeatedly
due
to
enhanced
metabolism
by
soil
microbes
(
Dungan
and
Yates
2003,
Gamliel
et
al.
2003).
This
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.

For
the
Southeastern
United
States,
including
Florida
and
Georgia,
metam­
sodium
and
1,3
D
+
chloropicrin
are
alternatives
for
nutsedges
and
nematodes,
respectively,
the
key
target
pests
in
these
regions.
However,
peppers
treated
with
metam­
sodium,
the
best
available
alternative,
have
an
estimated
44
percent
yield
decrease
compared
to
MB.
1,3
D
+
chloropicrin
is
infeasible
because
it
cannot
used
on
karst
geology
or
in
Dade
county,
Florida,
and
because
there
is
a
28­
day
planting
delay.

There
is
also
evidence
that
the
efficacy
of
1,3­
D
and
metam­
sodium
declines
in
areas
where
it
is
repeatedly
applied
due
to
enhanced
degradation
of
methyl
isothiocyanate,
the
active
ingredient,
by
soil
microbes
(
Ashley
et
al.
1963,
Ou
et
al.
1995,
Verhagen
et
al.
1996,
Gamliel
et
al.
2003).

In
sum,
neither
of
these
MB
alternatives
is
presently
technically
and
economically
feasible
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
peppers
in
the
Southeastern
United
States.
Reply
to
MBTOC
2005
Page
29
The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses22:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield.

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
Georgia
for
control
of
nutsedge
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.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

Florida
Peppers
are
generally
produced
using
mechanized
practices
that
involve
injection
of
methyl
bromide
to
a
depth
of
20
 
25
cm.
Weeds,
especially
nutsedge,
are
the
most
serious
concern
precipitating
MB
use
in
both
transplant
beds
and
the
field,
although
nightshade
and
hard
coated
seeds
are
also
problems.
Nutsedge
species
grow
even
under
adverse
conditions,
resist
traditional
and
modern
methods
of
weed
control,
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds
­
but
there
are
no
currently
registered
herbicides
that
control
nutsedges
near
pepper
plants.
In
addition
to
weeds,
soil­
borne
fungal
pathogens
and
plant­
parasitic
nematodes
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thereby
necessitating
annual
treatment
with
a
broad­
spectrum
soil
fumigant.

22
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
Reply
to
MBTOC
2005
Page
30
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997)
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

The
sandy
soils
of
Florida
are
a
contributing
factor
to
the
erratic
performance
suppressing
nematodes
and
plant
pathogens
of
the
metam
sodium
+
chloropicrin
combination,
the
most
promising
alternative
to
methyl
bromide
currently
available
for
use
in
Dade
County
(
because
of
label
restrictions
for
1,3­
D)
23.
Methyl
bromide
has
higher
vapor
pressure
than
metam
sodium,
therefore
can
penetrate
and
diffuse
throughout
the
soil
more
effectively
than
metam
sodium.

Several
climatic
factors
appeared
to
contribute
to
increases
in
plant
pathogens,
e.
g.,
Southern
stem
blight,
caused
by
the
soil­
borne
fungus
(
Sclerotium
rolfsii)
across
the
production
area,
even
with
methyl
bromide.
Variations
in
rainfall
and
soil
and
air
temperatures
may
predispose
developing
plants
to
diseases
caused
by
plant­
pathogenic
fungi.
Furthermore,
in
the
fall,
temperature
and
rainfall
patterns
favor
high
levels
of
nematode
infestation.

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require
a
21
to
28­
day
interval
before
planting,
compared
to
14
days
for
MB.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops
(
Kelley,
2003).

Weeds,
particularly
nutsedge,
are
the
major
pests
of
Florida
peppers
that
drive
the
need
for
methyl
bromide.
There
are
no
registered
herbicides
compatible
with
pepper
production.
Although
s­
metolachlor
(
Dual
Magnum)
and
napropamide
(
Devrinol)
were
cited
as
herbicides
with
some
potential
to
control
nutsedges,
the
efficacy
of
these
herbicides
in
sub­
tropical
Florida
is
inconsistent
(
Noling,
2003).
When
nutsedge
pressure
is
moderate
to
severe,
1,3­
D
+
chloropicrin
is
not
technically
feasible
because
it
needs
to
be
coupled
with
an
effective
herbicide
to
provide
control
for
the
entire
growing
season
(
U.
S.
EPA,
2002).
Frank
et
al
(
1992)
reported
that
weeds
in
pepper
for
40
to
60
days
could
reduce
yields
by
10
to
50
percent.
Stall
and
Morales­
Payan
reported
that
tomato
must
be
nutsedge­
free
for
2
to10
weeks
to
keep
yield
reductions
below
5
percent.
There
are
no
herbicides
which
control
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041).

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Phytophthora
spp.,
Verticillium
spp.,
Pythium
spp.
and
Rhizoctonia
solani
)
commonly
reside
in
many
production
areas,
since
many
23
By
law
1,3­
D
cannot
be
used
anywhere
in
Dade
county,
Florida,
where
the
majority
of
that
region's
peppers
are
grown
Reply
to
MBTOC
2005
Page
31
pepper
production
areas
are
old
tomato
production
fields.
Fungicides
such
as
chlorothalonil,
and
azoxystrobin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck
2003).

Nematodes,
such
as
the
root
knot
nematode
species
of
Meloidogyne
were
third,
following
weeds
and
fungal
pathogens,
in
order
of
causing
yield
and
economic
losses
in
Florida
peppers.
Preplant
control
of
nematodes
is
very
important
because
root
feeding
and
damage
may
predispose
the
plant
tissues
to
fungal
pathogens
or
bacterial
wilt
which
can
lead
to
significant
yield
loss.
Fumigant
alternatives
such
as
metam­
sodium
(
Vapam,
K­
pam)
have
proven
inconsistent.
(
Noling,
2003;
CUE
#
03­
0017).

In
addition,
labeling
of
1,3­
dichloropropene
products
restricts
its
use
in
key
pepper
growing
areas
of
the
U.
S.
where
karst
topography
exists
due
to
ground­
water
contamination
concerns.
In
areas
where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions
and
28­
day
waiting
periods
between
application
and
planting
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
fetch
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.

Nutsedge
management
has
proven
to
be
difficult
due
to
the
perennial
growth
habit
of
nutsedge
and
tubers
as
primary
means
of
propagation.
Research
suggests
that
metam
sodium
can,
in
some
situations,
provide
effective
pest
management
for
certain
diseases
and
weeds.
However,
even
though
there
have
been
nearly
50
years
experience
with
metam
sodium,
(
which
breaks
down
to
methyl
isothiocyanate)
nutsedge
control
results
have
been
unpredictable.

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
The
data
from
this
tomato
study
are
being
cited
because
comparable
pepper
data
are
not
available.

Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists
which
is
Reply
to
MBTOC
2005
Page
32
approximately
40%
of
the
Florida
pepper
production
area,
including
all
of
Dade
country,
a
major
pepper
growing
area.

Further,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology.
By
law
1,3­
D
cannot
be
used
anywhere
in
Dade
county,
Florida,
where
the
majority
of
that
region's
peppers
are
grown.
There
is
also
a
28
day
planting
delay
(
vs.
14
days
for
MB)
due
to
regulatory
restrictions
for
1,3­
D
+
chloropicrin.
In
Florida
particularly,
growers
are
on
a
tight
production
schedule
where
buyers
must
place
pepper
transplants
in
fields
at
a
certain
time
of
the.
Thus,
if
growers
have
only
metam
sodium
for
preplant
pest
control,
they
will
be
forced
to
fumigate
earlier
in
their
season,
which
in
turn
will
force
the
fumigation
schedule
into
rainy
periods,
an
untenable
situation
since
rain
causes
this
and
all
other
available
fumigants
to
lose
efficacy
dramatically
(
Aerts,
2004).

Furthermore,
trials
of
metam­
sodium
and
1,3
D
+
chloropicrin
(
and
various
combinations
thereof)
are
based
on
small
plot
research
trials
conducted
in
the
Southeastern
United
States
on
crops
other
than
peppers.
For
fungi
and
nutsedge,
no
on­
farm,
large­
scale
trials
have
yet
been
done.
Some
researchers
have
also
reported
that
these
MB
alternatives
degrade
more
rapidly
in
areas
where
they
are
applied
repeatedly
due
to
enhanced
metabolism
by
soil
microbes
(
Dungan
and
Yates
2003,
Gamliel
et
al.
2003).
This
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.

For
the
Southeastern
United
States,
including
Florida
and
Georgia,
metam­
sodium
and
1,3
D
+
chloropicrin
are
alternatives
for
nutsedges
and
nematodes,
respectively,
the
key
target
pests
in
these
regions.
However,
peppers
treated
with
metam­
sodium,
the
best
available
alternative,
have
an
estimated
44
percent
yield
decrease
compared
to
MB.
1,3
D
+
chloropicrin
is
infeasible
because
it
cannot
used
on
karst
geology
or
in
Dade
county,
Florida,
and
because
there
is
a
28­
day
planting
delay.

There
is
also
evidence
that
the
efficacy
of
1,3­
D
and
metam­
sodium
declines
in
areas
where
it
is
repeatedly
applied
due
to
enhanced
degradation
of
methyl
isothiocyanate,
the
active
ingredient,
by
soil
microbes
(
Ashley
et
al.
1963,
Ou
et
al.
1995,
Verhagen
et
al.
1996,
Gamliel
et
al.
2003).

In
sum,
neither
of
these
MB
alternatives
is
presently
technically
and
economically
feasible
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
peppers
in
the
Southeastern
United
States.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
AND
economically
feasible
rests
on
two
kinds
of
losses24:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
24
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.
Reply
to
MBTOC
2005
Page
33
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
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
for
control
of
nutsedge
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.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

Southeastern
US
Peppers
are
generally
produced
using
mechanized
practices
that
involve
injection
of
methyl
bromide
to
a
depth
of
20
 
25
cm.
Weeds,
especially
nutsedge,
are
the
most
serious
concern
precipitating
MB
use
in
both
transplant
beds
and
the
field,
although
nightshade
and
hard
coated
seeds
are
also
problems.
Nutsedge
species
grow
even
under
adverse
conditions,
resist
traditional
and
modern
methods
of
weed
control,
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds
­
but
there
are
no
currently
registered
herbicides
that
control
nutsedges
near
pepper
plants.
In
addition
to
weeds,
soil­
borne
fungal
pathogens
and
plant­
parasitic
nematodes
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thereby
necessitating
annual
treatment
with
a
broad­
spectrum
soil
fumigant.

There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997)
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
Reply
to
MBTOC
2005
Page
34
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require
a
21
to
28­
day
interval
before
planting,
compared
to
14
days
for
MB.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops
(
Kelley,
2003).

Nutsedge
management
has
proven
to
be
difficult
due
to
the
perennial
growth
habit
of
nutsedge
and
tubers
as
primary
means
of
propagation.
There
are
no
herbicides
which
control
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041.)
Research
suggests
that
metam
sodium
can,
in
some
situations,
provide
effective
pest
management
for
certain
diseases
and
weeds.
However,
even
though
there
have
been
nearly
50
years
experience
with
metam
sodium,
(
which
breaks
down
to
methyl
isothiocyanate)
nutsedge
control
results
have
been
unpredictable.

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
The
data
from
this
tomato
study
are
being
cited
because
comparable
pepper
data
are
not
available.

Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists
which
is
approximately
40%
of
the
Florida
pepper
production
area.

Further,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology.
There
is
also
a
28
day
planting
delay
(
vs.
14
days
for
MB)
due
to
regulatory
restrictions
for
1,3­
D
+
chloropicrin.
In
many
areas
of
the
southeast
growers
are
on
a
tight
production
schedule
where
buyers
must
place
pepper
transplants
in
fields
at
a
certain
time
of
the.
Thus,
if
growers
have
only
metam
sodium
for
preplant
pest
control,
they
will
be
forced
to
fumigate
earlier
in
their
season,
which
in
turn
will
force
the
fumigation
schedule
into
rainy
periods,
an
untenable
situation
since
rain
causes
this
and
all
other
available
fumigants
to
lose
efficacy
dramatically
(
Aerts,
2004).
Reply
to
MBTOC
2005
Page
35
Furthermore,
trials
of
metam­
sodium
and
1,3
D
+
chloropicrin
(
and
various
combinations
thereof)
are
based
on
small
plot
research
trials
conducted
in
the
Southeastern
United
States
on
crops
other
than
peppers.
For
fungi
and
nutsedge,
no
on­
farm,
large­
scale
trials
have
yet
been
done.
Some
researchers
have
also
reported
that
these
MB
alternatives
degrade
more
rapidly
in
areas
where
they
are
applied
repeatedly
due
to
enhanced
metabolism
by
soil
microbes
(
Dungan
and
Yates
2003,
Gamliel
et
al.
2003).
This
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.

For
the
Southeastern
United
States,
including
Florida
and
Georgia,
metam­
sodium
and
1,3
D
+
chloropicrin
are
alternatives
for
nutsedges
and
nematodes,
respectively,
the
key
target
pests
in
these
regions.
However,
peppers
treated
with
metam­
sodium,
the
best
available
alternative,
have
an
estimated
44
percent
yield
decrease
compared
to
MB.
1,3
D
+
chloropicrin
is
infeasible
because
it
cannot
used
on
karst
geology,
and
because
there
is
a
28­
day
planting
delay.

There
is
also
evidence
that
the
efficacy
of
1,3­
D
and
metam­
sodium
declines
in
areas
where
it
is
repeatedly
applied
due
to
enhanced
degradation
of
methyl
isothiocyanate,
the
active
ingredient,
by
soil
microbes
(
Ashley
et
al.
1963,
Ou
et
al.
1995,
Verhagen
et
al.
1996,
Gamliel
et
al.
2003).

In
sum,
neither
of
these
MB
alternatives
is
presently
technically
and
economically
feasible
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
peppers
in
the
Southeastern
United
States.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
AND
economically
feasible
rests
on
two
kinds
of
losses25:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
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
the
Southeastern
U.
S.
for
control
of
nutsedge
in
25
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
Reply
to
MBTOC
2005
Page
36
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.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

California
Urban
encroachment
and
concomitant
buffer
zones,
and
local
(
township)
caps
restrict
the
use
of
the
MB
alternative
1,3
D
(
with
or
without
chloropicrin).
Essentially
this
prevents
the
use
of
this
alternative
on
approximately
10
%
of
the
pepper
growing
area
in
California,
according
to
the
applicant.
The
applicant
is
requesting
MB
only
for
this
proportion
of
their
total
pepper
acreage
Peppers
are
generally
produced
using
mechanized
practices
that
involve
injection
of
methyl
bromide
to
a
depth
of
20
 
25
cm.
Weeds,
especially
nutsedge,
are
the
most
serious
concern
precipitating
MB
use
in
both
transplant
beds
and
the
field,
although
nightshade
and
hard
coated
seeds
are
also
problems
Nutsedge
species
grow
even
under
adverse
conditions,
resist
traditional
and
modern
methods
of
weed
control,
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States
and
coastal
California.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds
­
but
there
are
no
currently
registered
herbicides
that
control
nutsedges
near
pepper
plants.
In
addition
to
weeds,
soil­
borne
fungal
pathogens
and
plant­
parasitic
nematodes
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thereby
necessitating
annual
treatment
with
a
broadspectrum
soil
fumigant.

There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

As
far
as
EPA
can
ascertain,
virtually
none
of
the
studies
on
key
MB
alternatives
has
focused
on
peppers
in
coastal
California's
growing
conditions.
One
exception
to
this
situation
can
be
summarized
first,
although
this
study
was
ongoing
at
the
time
it
was
submitted
to
EPA.
This
study
is
a
field
trial,
conducted
in
small
plots
in
2003
in
Michigan
by
M.
K.
Hausbeck
and
B.
D.
Cortright
of
Michigan
State
University.
The
study
focused
on
a
number
of
vegetable
crops,
including
bell
peppers.
As
of
July
31,
2003,
results
indicated
that
1,3
D
+
35
%
chloropicrin
treatments
(
shank­
injected
at
56.7
liters/
ha)
showed
approximately
6
%
plant
loss
(
due
to
P.
capsici)
 
less
than
the
7
%
loss
seen
in
the
untreated
control
plots.
Metam­
sodium
(
drip­
applied
Reply
to
MBTOC
2005
Page
37
at
58.7
kg/
ha)
showed
a
13
%
loss.
Methyl
iodide
with
either
50
%
or
33
%
chloropicrin
(
shankinjected
at
either
46.1
or
36.8
kg/
ha,
respectively)
showed
only
2
%
plant
loss.
However,
methyl
iodide
is
not
registered
for
this
crop
in
the
U.
S.
at
present.
It
should
also
be
noted
that
(
1)
since
the
trial
had
not
yet
ended,
statistical
analysis
on
these
figures
was
not
conducted,
(
2)
plant
loss
figures
are
for
all
vegetable
crops
combined,
and
(
3)
these
plots
were
being
carefully
monitored
and
managed
with
post­
plant
prophylactic
foliar
fungicides
(
e.
g.,
chlorothalonil
and
myclobutanil)
 
an
optimal
management
scheme
that
will
require
time
to
enable
growers
to
adopt.

In
studies
with
other
vegetable
crops,
1,3
D
+
chloropicrin
has
generally
shown
better
control
of
fungi
than
metam­
sodium
formulations
(
though
still
not
as
good
as
control
with
MB).
For
example,
in
a
study
using
a
bell
pepper/
squash
rotation
in
small
plots
­
conducted
in
the
much
warmer
conditions
of
Georgia
and
without
P.
capsici
as
a
component
of
the
pest
complex
­
Webster
et
al.
(
2001)
found
significantly
lower
fungal
populations
with
1,3
D
+
35
%
chloropicrin
(
drip
irrigated
or
chisel
injected,
146
kg/
ha
of
1,3
D),
as
compared
to
the
untreated
control.
However,
MB
(
440
kg/
ha,
shank­
injected)
lowered
fungal
populations
even
more.
Methyl
iodide
had
no
significant
suppressive
effect,
as
compared
to
the
untreated
control.
In
another
study,
conducted
on
tomatoes
in
Florida,
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season;
Fusarium
was
one
of
several
pests
present.

Without
methyl
bromide,
pepper
producers
in
cool
weather
climates
of
Ventura
and
Santa
Clara
Counties
would
most
likely
use
a
mixture
of
1,3­
D
and
chloropicrin
(
Telone
C­
35)
to
manage
the
nematode
and
fungal
pathogen
populations
prior
to
transplanting
pepper.
There
is
evidence
from
numerous
small
plot
and
large­
scale
trials
to
indicate
that
these
MB
alternatives,
in
combination,
will
control
nematodes
to
the
extent
that
MB
does
nematodes.(
e.
g.
Eger
2000).
However,
EPA
believes
that
there
is
no
comparable
set
of
research
results
to
indicate
that
fungal
pests,
particularly
P.
capsici,
will
be
controlled
to
a
similar
extent.

To
wit,
no
large­
plot
studies
have
yet
been
performed
to
show
commercial
feasibility
against
fungal
pests
in
coastal
California
peppers.
Important
regulatory
constraints
on
1,3
D
and
chloropicrin
must
also
be
kept
in
mind:
township
caps
on
the
amounts
used
(
which
may
affect
the
use
rate
and
hence
efficacy),
mandatory
100
m
buffers
near
inhabited
structures
 
both
of
which
will
cause
negative
economic
impacts
that
are
likely
to
make
the
use
of
these
MB
alternatives
infeasible
for
the
near
future.
These
planting
restrictions
may
thus
be
important
factors
inhibiting
widespread
grower
adoption
of
this
MB
alternative.

Currently
unregistered
alternatives,
such
as
furfural
and
sodium
azide,
have
shown
good
efficacy
against
the
key
pests
involved.
However,
even
if
registration
is
pursued
soon
(
and
the
EPA
has
no
indications
of
any
commercial
venture
planning
to
do
so)
these
options
will
need
more
research
on
how
to
adapt
them
to
commercial
pepper
production
in
California.

There
are
also
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
pepper
growers.
In
sum,
while
the
potential
exists
for
a
combination
of
chemical
and
non­
chemical
alternatives
to
replace
MB
use
in
California
pepper,
this
goal
appears
be
at
least
a
few
years
away.
Reply
to
MBTOC
2005
Page
38
USG
does
not
agree
that
alternatives
are
available
in
California
except
where
regulatory
constraints
(
township
caps
dictating
maximum
use
of
1.3­
D)
are
binding.
California
peppers
are
similar
to
Michigan,
in
that
the
critical
pest
controlled
by
MB
currently
is
P.
capsici.
The
other
important
pest
targeted
by
MB
use
in
this
region
is
the
root
knot
nematode.
California
is
requesting
MB
for
less
than
10
%
of
its
pepper
area,
mainly
along
the
coast.
As
in
Michigan,
climatological
conditions
in
these
coastal
areas
­
primarily
long
periods
of
rainy,
cloudy
weather
 
exacerbate
problems
involving
possible
methyl
bromide
alternatives,
particularly
formulations
of
1,3
D,
which
cannot
be
used
when
soils
are
very
wet.
Growers
are
also
reporting
lack
of
efficacy
against
both
of
these
pests
at
the
maximum
label
rates
for
this
alternative.
In
addition,
California
has
township
caps
that
limit
the
amount
of
1,3­
D
that
can
be
used
in
a
given
area,
as
well
as
100
meter
buffer
zones
near
inhabited
structures.
Urban
encroachment
is
increasing
dramatically
in
California
coastal
counties,
making
the
buffer
zone
requirement
more
constraining.
These
factors
are
present
in
the
10%
of
California
pepper
area
that
need
MB
Of
the
currently
available
MB
alternatives,
metam­
sodium
offers
inconsistent
control
of
nutsedges
and
nematodes,
while
1,3­
D
+
chloropicrin
provides
adequate
control
of
nematodes
(
Locascio
et
al.
1997,
Eger
2000,
Noling
et
al.
2000).
However,
metam­
sodium
has
yield
losses
of
up
to
44
%
compared
to
MB
where
weed
infestations
are
moderate
to
severe
(
Locascio
et
al.
1997).
Metam­
sodium
also
creates
a
planting
delay
as
long
as
21
days
to
avoid
risk
of
phytotoxic
injury
to
crops
compared
to
a
14­
day
delay
for
MB.

Further,
it
is
the
opinion
of
some
U.
S.
crop
experts
that
metam
sodium,
in
particular,
is
very
inconsistent
in
its
beneficial
effects
as
a
nematode
control
agent
(
Dr.
S.
Culpeper,
University
of
Georgia,
personal
communication).

For
California
pests
1,3
D
+
chloropicrin
is
the
only
key
alternative
with
efficacy
comparable
to
MB.
Regulatory
restrictions
due
to
human
exposure
concerns,
combined
with
technical
limitations,
reduce
its
use.
Key
among
these
factors
are
a
delay
in
planting
as
long
as
30
days,
due
both
to
label
restrictions
and
low
soil
temperatures,
and
mandatory
30
to
100
meter
buffers
for
treated
fields
near
inhabited
structures.

MBTOC
has
suggested
that
shank­
injected
1,3­
D/
Pic
can
be
used
in
all
areas
that
are
not
currently
impacted
by
the
township
caps.
In
making
this
suggestion
they
are
not
accounting
for
both
the
technical
and
regulatory
factors
described
above
and
the
actual
working
of
the
township
caps
in
California.
The
township
cap
is
a
maximum
that
can
be
applied
assuming
that
the
method
of
application
is
deep
shank
injection.
For
all
other
forms
of
injection
an
`
application
factor'
is
applied.
The
purpose
of
this
application
factor
is
to
reduce
the
amount
of
1,3­
D
that
can
be
applied
to
a
given
area,
reducing
exposure
to
the
population
to
a
level
comparable
to
that
experienced
when
deep
shank
injection
is
used.

Deep
shank
injection
cannot
be
used
to
control
pests
in
California
pepper
production.
Unlike
Florida,
where
the
soils
are
sandy
to
a
considerable
depth,
in
California
the
soils
are
prepared
for
planting
to
a
depth
of
12­
18
inches26.
The
deep
shank
method
injects
1,3­
D
below
this
level
where
the
soil
is
not
prepared
and
breaks
into
clumps.
The
soil
must
be
re­
tilled
before
planting
26
This
corresponds
to
30­
45
cm.
Reply
to
MBTOC
2005
Page
39
which
risks
introducing
pathogens
back
into
the
planting
zone.
When
shallow­
shank
injection
is
used,
the
higher
application
factors
mean
that
a
much
smaller
area
can
be
injected.

Dr.
Legard27
of
the
California
Strawberry
Commission
has
estimated
the
impact
on
maximum
acreage
treated
if
1,3­
D
is
(
shallow)
shank­
injected
into
the
soil
rather
than
drip­
applied
a
s
a
liquid.
Using
Telone
C35
®
at
39­
50
gallons
per
treated
acre,
138.8
to
178.0
acres
per
township
could
be
treated.
When
Inline
®
is
used
at
25
gallons
per
acre28
473.7
acres
per
township
can
be
treated.
In
other
words,
the
use
of
drip­
applied
1,3­
D
results
in
2.5
to
3
times
as
many
treated
acres.
Shank
injection
of
1,3­
D
will
greatly
reduce
the
acreage
treated29.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses30:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
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.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

27
Daniel
Legard,
PhD,
personal
communication.
January
9,
2005.
28
The
common
use
rate
on
strawberries
in
California
29
The
main
concern
associated
with
broadcast
fumigation
with
telone
C35
is
related
to
the
telone
township
cap.
There
are
different
emission
ratios
used
for
the
different
application
methods
that
adjusts
the
amount
of
telone
applied
to
the
township
cap.
The
lbs
used
are
"
adjusted"
by
the
following
factors
(
1x
for
deep
shank,
1.1x
for
drip
applied,
1.8x
for
shallow
shank).
Hopefully,
most
growers
would
use
deep
shank
where
possible
for
broadcast
telone
applications.
However,
broadcast
applications
still
involve
treating
approximately
40%
more
acreage
than
drip
(
2
row
bed
and
slightly
lower
for
3
and
4
row
beds,
which
are
becoming
more
popular
in
the
North).
The
net
result
of
both
changes
is
to
reduce
the
maximum
treatable
area
to
between
30­
40%
of
the
area
that
can
be
treated
using
drip
applied
1,3­
D.

30
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
Reply
to
MBTOC
2005
Page
40
c.
rate
reduction
to
200kg/
ha
under
treated
strips
MBTOC
has
also
reduced
the
amount
recommended
for
peppers
stating:
"
A
further
adjustment
was
applied
to
reduce
the
dosage
to
the
guideline
level
of
200kg/
ha
under
the
strips."
When
this
issue
was
discussed
with
MBTOC
members
during
the
16th
MOP,
U.
S.
experts
agreed
to
clarify
whether
the
reported
rates
were
in
fact
the
rates
used
under
the
strips
(
as
the
U.
S.
believed)
or
whether
they
were
the
average
for
an
acre
as
MBTOC
believed31.
The
U.
S.
has
verified
that
the
application
rates
provided
in
the
quantitative
assessment
(
the
Methyl
Bromide
Usage
Numerical
Index,
or
BUNI)
are
in
fact
the
rates
under
the
strips.
The
number
of
acres
reported
is
the
"
treated
acres".
A
strip
application
that
results
in
two
thirds
of
an
acre
being
fumigated
while
one­
third
is
untreated
is
reported
as
two
thirds
of
an
acre,
not
as
an
acre.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
ortheir
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
complete
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

U.
S.
2006
nomination
The
USG
is
reiterating
its
request
for
an
additional
691.683
metric
tons
of
methyl
bromide
for
use
in
field
grown
peppers
for
a
total
amount
in
this
sector
of
1,498.530
which
includes
a
research
amount
of
2.844
metric
tons.

Citations
Aerts,
M.
2003.
Asst.
Director,
Environmental
and
Pest
Management
Division,
FFVA
(
Florida
Fruit
and
Vegetable
Association).
Personal
Communication
with
G.
Tomimatsu,
U.
S.
EPA,
December
2,
2003.

31
If
the
rates
were
an
average
per
acre,
as
MBTOC
believed,
given
that
in
strip
treatments
approximately
one­
third
of
the
acre
is
left
untreated,
the
rates
applied
would,
in
some
cases,
exceed
the
MBTOC
recommended
dosage
of
200kg/
ha.
Reply
to
MBTOC
2005
Page
41
Aerts,
M.
2004.
Asst.
Director,
Environmental
and
Pest
Management
Division,
FFVA
(
Florida
Fruit
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Vegetable
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February
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MBTOC
(
1994):
1994
Report
of
the
Methyl
Bromide
Technical
Options
Committee
for
the
1995
Assessment
of
the
UNEP
Montreal
Protocol
on
Substances
that
Deplete
the
Ozone
Layer.
Nairobi.

Melban,
K.
2003.
California
Pepper
Commission.
Personal
Communication
with
G.
Tomimatsu.
Kenny@
tabcomp.
com.
11/
26/
2003.

Munn.
D.
A.
1992.
"
Comparison
of
shredded
newspaper
and
wheat
straw
as
crop
mulches."
Hort
technol.
2:
361
­
366.

Noling,
J.
W.
2003.
University
of
Florida­
Lake
Alfred.
Personal
Communication
with
G.
Tomimatsu.
Jwn@
lal.
ufl.
edu.
11/
25/
2003.

Noling,
J.
W.,
E.
Rosskopf,
and
D.
L.
Chellemi.
2000.
Impacts
of
alternative
fumigants
on
soil
pest
control
and
tomato
yield.
Proc.
Annual
Int.
Res.
Conf.
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.
Available
on
the
web
at
http://
www.
mbao.
org/
mbrpro00.
html.

Ou,
L.­
T.,
K.
Y.
Chung,
J.
E.
Thomas,
T.
A.
Obreza,
and
D.
W.
Dickson.
1995.
Degradation
of
1,3­
dichloropropene
(
1,3­
D)
in
soils
with
different
histories
of
field
applications
of
1,3­
D.
J.
Nematol.
25:
249
 
257.

Phatak,
S.
C.,
D.
R.
Sumner,
H.
D.
Wells,
D.
K.
Bell,
and
N.
C.
Glaze.
1983.
Biological
control
of
yellow
nutsedge,
Cyperus
esculentus,
with
the
indigenous
rust
fungus
Puccinia
canaliculata.
Science.
219:
1446
 
1448.

Patterson,
D.
T.
1998.
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch.
Weed
Technology,
12:
275­
280.
Reply
to
MBTOC
2005
Page
44
Porter,
I.,
S.
Mattner,
R.
Mann,
R.
Gounder,
J.
Banks,
and
P.
Fraser.
1994.
Strawberry
Fruit
Production
and
results
from
trials
in
Different
Geographic
Regions.
A
Presentation
to
the
Methyl
Bromide
Alternatives
Conference,
Lisbon,
September
1994
Schneider
S.
M.,
E.
N.
Rosskopf,
J.
G.
Leesch,
D.
O.
Chellemi,
C.
T.
Bull,
and
M.
Mazzola.
2003.
United
States
Department
of
Agriculture
 
Agricultural
Research
Service
research
on
alternatives
to
methyl
bromide:
pre­
plant
and
post­
harvest.
Pest
Manag
Sci.
59:
814­
826.

Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.

Smelt,
J.
H.,
S.
J.
H.
Crum,
and
W.
Teinissen.
1989.
Accelerated
transformation
of
the
fumigant
methyl
isocyanate
in
soil
after
repeated
application
of
metam
sodium.
J.
Environ.
Sci.
Health
B24:
437­
455.

Stall,
W.
M.
and
J.
Morales­
Payan.
2000.
The
critical
period
of
nutsedge
interference
in
tomato.
S.
W.
Florida
Research
&
Education
Center.
Available
on
the
web
at
www.
imok.
ufl.
edu/
liv/
groups/
IPM/
weed_
con/
nutsedge.
htm
UNEP
(
United
Nations
Environment
Programme).
1998.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
1998
assessment
of
alternatives
to
methyl
bromide.
p.
49.

U.
S.
EPA.
2002.
Peppers­
Field.
Peppers
Grown
Outdoors
on
Plastic
Mulch.
CUN2003/
058
Verhagen,
C.,
G.
Lebbink,
and
J.
Bloem.
1996.
Enhanced
biodegradation
of
the
nematicides
1,3­
dichloropropene
and
methyl
isothiocyanate
in
a
variety
of
soils.
Soil
Biol.
Biochem.
28:
1753
 
1756.

Webster,
T.
M.
2002.
Nutsedge
eradication:
impossible
dream?
National
Nursery
Proc.
RMRS­
P­
000.
U.
S.
DA
Forest
Service,
Rocky
Mtn
Res.
Station,
Ogden,
Utah.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
R.
L.
Fery.
2001.
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Protection
20:
605­
614.

Wilen,
C.
A.,
M.
E.
McGiffen,
and
C.
L.
Elmore.
2003.
Nutsedge:
Integrated
Pest
Management
for
Home
Gardeners
and
Landscape
Professionals.
University
of
California
IPM
Publication
#
4732.
Available
on
the
Web
at
www.
ipm.
ucdavis.
edu.
Reply
to
MBTOC
2005
Page
45
7.
SMOKEHOUSE
HAMS
Overview
of
the
U.
S.
Nomination
The
U.
S.
has
requested
135.742
metric
tons
of
methyl
bromide
for
use
on
uncooked
(
dry
cured
or
`
country')
hams
for
2006.
MBTOC
was
unable
to
make
a
recommendation
for
this
sector.

Currently
there
are
no
viable
alternatives
to
methyl
bromide
for
the
dried
meat
industry:
phosphine
does
not
control
mites
(
a
major
pest
affecting
this
sector)
and
heat
would
alter
the
product.
In
U.
S.
pork
processing
plants
that
produce
dry­
cured
pork
products
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
MB,
making
these
alternatives
technically
and/
or
economically
infeasible.
Phosphine,
alone
or
in
combination
with
carbon
dioxide
does
not
control
mites,
a
major
pest
on
cured
hams.
­
Geographic
distribution
of
the
facilities:
Facilities
included
in
this
nomination
are
located
in
the
southern
U.
S.
where
mild
temperatures
and
high
relative
humidity
result
in
key
pest
pressures
that
are
moderate
to
severe.
These
ambient
conditions
require
that
pests
be
killed
because
they
will
only
reinfest
the
facility
after
fumigation.
­
Age
and
type
of
facility:
older
food
processing
facilities,
especially
those
constructed
of
wood,
experience
more
frequent
and
severe
pest
infestations
that
must
be
controlled
by
fumigation.
In
the
U.
S.
it
is
usual
for
dry­
cured
processed
pork
to
be
produced
in
traditional
facilities.
These
facilities
are
usually
constructed
of
wood
and
many
are
decades
old,
if
not
older.
Many
newer
facilities
are
constructed
using
the
older
facilities
as
models.
­
Constraints
of
the
alternatives:
some
types
of
commodities
(
e.
g.,
those
containing
high
levels
of
fats
and
oils)
prevent
the
use
of
heat
as
an
alternative
because
of
its
effect
on
the
final
product
(
e.
g.,
rancidity).
All
of
the
pork
products
are
relatively
high
fat
products
so
rancidity
would
be
a
problem.
In
addition,
using
heat
will
alter
the
character
of
the
final
product,
producing,
for
example,
a
cooked
pork
product
rather
than
a
dry­
cured
pork
product
with
the
attendant
flavor
differences.
­
Transition
to
newly
available
alternatives:
Sulfuryl
fluoride
recently
received
a
Federal
registration
for
certain
commodities
and
structures,
such
as
cereal
mills.
At
present,
pork
and
pork
products
are
not
included
among
the
legal
uses
of
sulfuryl
fluoride,
so
this
chemical
is
not
an
option
for
these
facilities.
­
Delay
in
plant
operations:
e.
g.,
the
use
of
some
alternatives
can
add
a
delay
to
production
by
requiring
additional
time
to
complete
the
fumigation
process.
Production
delays
can
result
in
significant
economic
impacts
to
the
processors.

It
is
common
for
producers
of
cured
pork
products
to
experience
pest
pressure
from
insects
such
as
the
ham
skipper,
the
red
legged
ham
beetle,
dermestid
beetles,
and
mites.
These
insects
infest
and
feed
on
meat
as
it
cures
and
ages.
Environmental
conditions
(
temperature
and
humidity)
in
and
around
the
facility
strongly
influence
the
level
of
pest
pressure.
Under
favorable
ambient
conditions,
such
as
those
seen
in
silo
curing,
pest
pressure
increases
and
a
regular
fumigation
schedule
is
recommended.
In
the
U.
S.,
the
Food
and
Drug
Administration
(
FDA)
regulates
the
Reply
to
MBTOC
2005
Page
46
maximum
levels
of
live
or
dead
insects
or
insect
parts
that
may
be
present
in
stored
food
products.
Food
commodities
that
exceed
maximum
limits
allowed
are
considered
adulterated
by
FDA
and
thus
unfit
for
human
consumption.
There
are
currently
no
alternatives
registered
for
use
on
hams
in
the
U.
S.
that
would
provide
the
same
level
of
pest
control.

The
specific
name
and
physical
address
of
each
facility
was
not
requested
in
the
forms
filled
out
by
the
applicants
in
the
United
States.
However,
general
location
information
for
the
following
facilities
is
known:

 
Kentucky
(
Cadiz,
Greenville)
 
Missouri
(
California)
 
North
Carolina
(
Boone,
Goldsboro,
Smithfield,
Wayne
County)
 
Virginia
(
Surry)
 
Tennessee
(
Various
locations)
 
South
Carolina
(
Various
locations).

In
order
to
address
this
concern,
USG
has
requested
location
information
from
the
post­
harvest
sector
participants.
The
forms
have
begun
to
come
in
from
the
applicants
and
are
currently
under
review.
When
the
analysis
is
complete
it
will
be
forwarded
to
MBTOC.

It
has
been
difficult
to
determine
the
amount
of
methyl
bromide
used
historically
in
this
sector.
Some
data
have
been
supplied
by
applicants32:

METHYL
BROMIDE
CONSUMPTION
FOR
THE
PAST
5
YEARS
AND
THE
AMOUNT
REQUIRED
IN
THE
YEAR(
S)
NOMINATED
Historical
Use
Requested
Use
For
each
year
specify:
1997
1998
1999
2000
2001
2002
2005
2006
Amount
of
MB
(
kg)
1,159
1,309
1,291
972
1,659
1,528
170,350
170,350
Volume
Treated
1000
m
³
50
53
52
41
48
43
7,087
7,087
Formulation
of
MB
Information
not
provided
Information
not
provided
Dosage
Rate
(
kg/
1000
m
³
)
31
30
32
29
38
35
25
25
Actual
(
A)
or
Estimate
(
E)
Information
not
provided
Information
not
provided
There
are
currently
no
alternatives
to
methyl
Bromide
in
Ham
fumigation.
Phosphine,
alone
and
in
combination
with
carbon
dioxide,
does
not
control
mites,
a
major
pest
in
cured
pork
products.
Additionally,
according
to
the
phosphine
label,
the
state
of
North
Carolina
has
further
restricted
the
use
of
this
alternative.
According
to
state
regulations,
phosphine
may
only
be
used
to
control
rats
and
mice,
but
not
insects.

32
Data
for
only
one
company.
Given
the
small
share
of
the
market
for
dry­
cured
pork
products
represented
by
the
reporting
company,
these
data
cannot
be
taken
as
representative.
Reply
to
MBTOC
2005
Page
47
In
the
U.
S.,
the
Food
and
Drug
Administration
(
FDA)
regulates
the
maximum
levels
of
live
or
dead
insects
or
insect
parts
that
may
be
present
in
stored
food
products.
Food
commodities
that
exceed
maximum
limits
allowed
are
considered
adulterated
by
FDA
and
thus
unfit
for
human
consumption
and
cannot
be
sold.
The
law
is
part
of
the
Federal
Food,
Drug,
and
Cosmetic
Act
and
available
on
the
World
Wide
Web
at:
http://
www.
cfsan.
fda.
gov/~
dms/
dalbook.
html).
Another
source
for
the
Food,
Drug,
and
Cosmetics
Act
can
be
found
at:
http://
www.
fda.
gov/
opacom/
laws/
fdcact/
fdcact4.
htm
Meat
Inspections
are
through
the
Food
Safety
and
Inspection
Service
(
FSIS)
of
the
United
States
Department
of
Agriculture
(
USDA).
Under
authority
of
the
Federal
Meat,
Poultry
and
Egg
Products
Inspection
Acts,
FSIS
inspects
and
monitors
all
meat,
poultry
and
egg
products
sold
in
interstate
and
foreign
commerce
to
ensure
compliance
with
mandatory
U.
S.
food
safety
standards
and
inspection
legislation.
http://
www.
fsis.
usda.
gov/
regulations_&_
policies/
federal_
inspection_
programs/
index.
asp
Establishments
have
the
option
to
apply
for
Federal
or
State
inspection.
Under
the
agreement,
a
State's
program
must
enforce
requirements
"
at
least
equal
to"
those
imposed
under
the
Federal
Meat
and
Poultry
Products
Inspection
Acts.
However,
product
produced
under
State
inspection
is
limited
to
intrastate
commerce.
FSIS
provides
up
to
50%
of
the
State's
operating
funds,
as
well
as
training
and
other
assistance.
http://
www.
fsis.
usda.
gov/
regulations_&_
policies/
state_
inspection_
programs/
index.
asp
Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
or
their
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

U.
S.
2006
nomination
In
responding
to
MBTOC
concerns
USG
has
developed
some
information
suggesting
that
less
methyl
bromide
is
needed
in
this
sector
than
previously
thought.
Accordingly,
USG
is
submitting
an
amended
request
for
this
sector
of
40.854
metric
tons
of
methyl
bromide,
a
reduction
to
less
than
1/
3
of
the
previously
requested
amount.

Citations
Bell,
C.
H.
2000.
Fumigation
in
the
21st
Century.
Crop
Protection,
19:
563­
69.
Reply
to
MBTOC
2005
Page
48
8.
FIELD
GROWN
STRAWBERRIES
Overview
of
the
U.
S.
Nomination
The
U.
S.
is
requesting
1,918.4
metric
tons
of
methyl
bromide
for
use
on
field
grown
strawberries
in
California
(
1,452.732
metric
tons),
Florida
(
310.997
metric
tons),
and
the
southeastern
U.
S.
(
152.294
metric
tons).

The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
strawberry
fruit
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:


pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
strawberry
fruit
production.


geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
strawberry
fruit
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.


regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
townships
caps
and
in
Florida
due
to
the
presence
of
karst
geology.


delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.


unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

Overview
of
MBTOC's
prior
recommendations
MBTOC
recommended
that
1,520.803
metric
tons
of
methyl
bromide
be
allocated
to
this
use
as
follows:
Florida,
224.142
metric
tons,
the
southeastern
U.
S.
134.476
metric
tons,
and
California
1162.186
metric
tons.

MBTOC
reasons
that
the
amount
calculated
by
the
USG
was
predicated
on
a
1X
township
cap
but
that
the
`
Ornamental'
portion
of
the
U.
S.
nomination
indicates
that
a
greater
availability
of
1,3­
D
is
expected
for
2006.
MBTOC
further
argues
that
there
are
available
substitutes
for
methyl
bromide
and
cites
"
Porter,
in
press",
to
justify
a
20%
reduction
in
the
nominated
amount.
MBTOC
states
that
Pic
EC
®
or
metam
and
pic
are
`
technically
suitable'
for
Florida
and
the
southeastern
US.
MBTOC
also
states
that
reduced
dosage
is
appropriate
because
the
treated
portion
of
the
beds
can
be
held
to
200kg/
ha
and
because
dosages
can
be
reduced
when
higher
density
films
(
including
VIF)
are
used,
citing
Fennimore
et
al
2005
and
Gilreath
et
al
2003.
Reply
to
MBTOC
2005
Page
49
U.
S.
Response
to
MBTOC's
prior
recommendations
The
U.
S.
nomination
for
strawberry
field
grown
strawberry
fruit
is
a
critical
need
for
an
amount
of
methyl
bromide
in
areas
with
moderate
to
severe
pest
pressure,
because
currently
there
are
no
feasible
alternatives
and
farmers
would
face
severe
economic
hardships
in
the
absence
of
methyl
bromide.
Where
there
is
moderate
to
severe
pest
pressure,
the
suggested
alternatives
for
strawberry
fruit
production
fail
to
provide
the
necessary
degree
of
pest
control
or
their
use
is
not
easily
adoptable
due
to
state­
imposed
restrictions.
The
nomination
also
notes
that
applying
alternatives
is
further
complicated
when
plant­
back
restrictions
prevent
farmers
from
meeting
marketing
windows
(
e.
g.,
winter
or
early
spring)
when
strawberry
sale
prices
are
as
much
as
100%
higher
than
during
the
rest
of
the
year
(
see
Market
Window
Information).
The
nomination
notes
significant
progress
in
adopting
emission
reduction
technologies
and
changing
formulations
and
application
rates
to
reduce
methyl
bromide
dosage
rates
to
some
of
the
lowest
in
the
world,
and
that
further
trials
are
being
conducted
to
evaluate
new
alternatives,
and
to
test
ways
of
overcoming
constraints
in
further
lowering
methyl
bromide
formulations
and
adopting
even
more
impermeable
barriers.

Despite
use
of
many
alternatives,
many
of
which
have
already
been
incorporated
into
standard
strawberry
production
systems,
methyl
bromide
is
believed
to
be
the
only
currently
available
treatment
that
consistently
provides
reliable
control
of
nutsedge
species,
nematodes
and
the
disease
complex
affecting
strawberry
production.
Only
acreage
with
moderate
to
high
pest
pressure
is
included
in
this
nomination.

a.
Township
caps
MBTOC
indicates
their
understanding
that
the
nomination
was
based
on
1X
township
caps.
In
fact,
a
weighted
average
of
expected
probability
of
1X
and
2X
cap
was
used
in
developing
the
U.
S.
request,
so
the
MBTOC
assumption
on
this
issue
is
incorrect33.
MBTOC
reasons
that
the
availability
of
1,3,­
D
for
strawberry
production
will
be
greater
than
the
1X
township
cap
but
this
is
by
no
means
certain
(
see
footnote
below).
MBTOC
cites
the
`
Ornamentals'
section
of
the
nomination
to
bolster
their
assertion.
The
`
Ornamentals'
section
was
in
error,
and
the
USG
thanks
MBTOC
for
noting
this
discrepancy
(
which
has
now
been
corrected).

b.
Alternatives
are
technically
and
economically
feasible
so
a
20%
reduction
for
phasein
of
alternatives
such
as
1,3­
D/
Pic
or
metam
sodium
was
used:
alternatives
can
be
used
in
areas
where
1,3­
D
is
not
appropriate
MBTOC
appears
to
disagree
with
the
U.
S.
assessments
of
yield
loss.

33
In
practice,
the
weights
applied
were
1/
3
of
the
2X
cap
and
2/
3
of
the
1X
cap.
In
the
current
judgment
of
USG
experts
this
places
too
much
likelihood
on
an
increased
township
cap.
In
repeated
conversations
with
State
of
California
pesticide
regulators,
USG
has
been
given
no
indication
that
the
township
caps
would
be
raised
beyond
the
temporary
increase
in
the
cap
except
as
negotiated
in
individual
agreements.
In
order
to
be
eligible
for
an
increased
cap
amount
under
these
agreements,
a
township
must
have
an
unused
(
banked)
amount
available
to
increase
the
cap.
As
the
program
currently
stands,
only
townships
with
banked
amounts
can
increase
their
use
of
1,3­
D
above
the
1X
cap.
As
townships
exceed
the
1X
cap
they
lose
their
ability
to
increase
the
caps
by
depleting
their
`
banked'
amount.
Reply
to
MBTOC
2005
Page
50
The
U.
S.
assessments
of
yield
loss
were
developed
from
technically
appropriate
studies
relevant
to
the
specific
circumstances
of
the
U.
S.
situation.
Technically
appropriate
studies
are
those
which:


Included
an
untreated
control
for
comparison
purposes

Included
information
on
the
(
key)
pests
present
in
the
treated
area

Give
estimates
of
yield
changes
(
differences)


Include
methyl
bromide
as
a
standard
The
U.
S.
nomination
was
restricted
to
those
situations
where
`
key'
pest
pressure
was
moderate
to
severe34
and
where
these
pests
could
not
be
controlled
by
alternatives
and,
therefore,
would
result
in
yield
loss.

MBTOC
used
what
they
describe,
interchangeably
as
a
"
meta
analysis"
or
an
`
average'.
The
procedure
MBTOC
used
was
not
a
meta
analysis
in
the
sense
thata
meta
analysis
includes
only
studies
which
are
similar
enough
from
a
statistical
standpoint
that
they
can
be
combined
and
analyzed
as
if
they
comprised
one
study,
and
the
studies
need
to
be
identified,
appraised
and
summarized
according
to
an
explicit
and
reproducible
methodology
that
is
designed
to
answer
a
specific
research
question.
In
this
case,
the
appropriate
research
question
would
be
the
performance
of
alternatives
to
methyl
bromide
under
the
conditions
of
the
U.
S.
nomination
(
i.
e.
with
moderate
to
severe
pressure
from
key
pests).
The
null
hypothesis
would
be
that
alternatives
work
as
well
as
methyl
bromide
in
the
circumstances
of
the
U.
S.
nomination.
The
U.
S.
nomination
is
specifically
for
the
use
of
methyl
bromide
where
key
pests
(
pests
not
adequately
controlled
by
alternatives
to
methyl
bromide)
are
present
at
moderate
to
severe
levels
and/
or
soil,
climate,
terrain,
or
regulatory
conditions
are
such
that
alternatives
to
methyl
bromide
either
cannot
be
used
or
result
in
significant
economic
losses
when
used.
These
economic
losses
must
be
of
sufficient
magnitude
that
they
render
the
alternative
"
not
economically
feasible".

Although
it
is
difficult
to
be
certain
how
the
MBTOC
analysis
was
conducted
and
what
it
includes
because
it
has
not
been
reviewed
and
published
and
was
not
provided
to
the
U.
S.
experts
to
evaluate35,
U.
S.
experts
were
able
to
make
some
educated
guesses
about
the
analysis36.
The
analysis
for
strawberry
fruit
is
described
in
a
paper
is
listed
as
being
"
in
press"
as
conference
proceedings
with
a
date
after
the
MBTOC
recommendations
on
the
U.
S.
nomination
were
tendered.

A
version
of
the
paper
was
presented
by
Dr.
Ian
Porter
at
the
Methyl
Bromide
Alternatives
Organization
meeting
in
San
Diego,
November
2003
and
the
subject
of
considerable
controversy
34
In
the
judgment
of
U.
S.
experts
pressure
was
such
that
yield
losses
of
the
magnitude
of
those
used
in
the
economic
assessment
would
be
sustained.

35
The
U.
S.
requested
two
of
the
authors
of
the
paper
for
references
so
that
the
studies
included
could
be
evaluated
against
the
circumstances
of
the
U.
S.
nomination,
but
to
date
the
references
have
not
been
provided.

36
Some
of
this
material
with
references
had
been
previously
presented
at
the
Methyl
Bromide
Alternatives
Organization
2003
meeting
(
San
Diego).
At
that
time
U.
S.
experts
expressed
their
view
that
many
if
not
most
of
the
studies
were
not
an
appropriate
application
of
the
information.
Reply
to
MBTOC
2005
Page
51
and
questioning
among
participants.
Dr.
Porter's
paper
included
a
number
of
papers
which
U.
S.
experts
believe
are
not
representative
of
the
specific
conditions
included
in
the
U.
S.
nomination
in
determining
the
usefulness
of
alternatives
because
the
research
was
carried
out
under
conditions
of
no
pest
pressure37.
If
no
pests
are
present
any
alternative,
or
indeed
not
using
any
pesticide
at
all,
will
all
work
equally
well.
By
including
situations
where
there
is
no
pest
pressure
one
in
effect
adds
(
many)
"
0"
to
the
equation38
describing
the
differences
in
yield
between
crops
grown
using
methyl
bromide
and
those
grown
using
an
alternative.
This
has
the
effect
of
lowering
the
average
difference
between
yields
using
methyl
bromide
and
yields
using
an
alternative.
If
a
sufficient
number
of
"
0"
are
added,
the
result
will
be
to
(
falsely)
eliminate
the
yield
differences
between
methyl
bromide
and
the
alternative
treatments.

In
other
studies,
pests
were
present
but
they
were
not
the
same
pests
that
were
present
in
all
of
the
U.
S.
circumstances.
Taking
the
case
of
the
southeastern
U.
S.,
for
example,
weeds,
diseases,
fungi,
and
nematodes
all
infest
the
crops.
Some
of
these
pests
can
be
controlled
with
alternatives,
but
some
of
the
weeds,
in
particular
nutsedges
(
nut
grasses),
nightshades,
and
some
hard
seed
coated
weeds,
cannot.
Situations
without
weeds
will
show
small
or
no
yield
losses
when
alternatives
are
used
while
the
true
situation
when
(
key)
weeds
are
present
is
that
there
are
large
yield
losses39.
Including
these
factors
has
the
effect
of
adding
"
0"
yield
difference
as
many
times
as
there
are
papers.

If
the
issue
had
been
to
average
all
results,
describing
an
"
average"
worldwide
situation,
the
procedure
would
be
correct.
However,
The
U.
S.
submitted
requests
for
continued
methyl
bromide
use
only
for
situations
with
sufficiently
high
pest
pressure
(
not
average),
which
cannot
be
controlled
by
alternatives
to
methyl
bromide.

The
U.
S.
disagrees
with
the
MBTOC
assessment
of
yield
loss
in
the
specific
circumstances
of
the
U.
S.
nomination.

Market
Windows
As
to
the
component
of
economic
loss
that
is
a
consequence
of
market
timing,
we
believe
that
MBTOC
has
not
accounted
for
losses
arising
from
market
windows.

Experts
are
familiar
with
the
occurrence
of
high
prices
for
fresh
produce
early
in
the
season,
prices
which
decline
as
the
produce
becomes
abundant
(
and
more
familiar)
later
in
the
season.

37
For
example,
some
trials
are
used
for
residue
tests.
These
tests
are
likely
to
be
carried
out
in
conditions
of
little
or
no
pest
pressure
in
order
to
have
enough
harvested
fruit
to
to
test
for
residue.
The
Porter
paper
does
not
indicate
which
of
the
studies
that
were
used
(
but
not
cited)
were
for
the
purposes
of
examining
pesticide
residues.

38
The
actual
procedure
was
to
add
in
yields
expressed
as
a
percentage
of
(
anticipated)
yield
using
methyl
bromide.
How
this
yield
was
estimated
is
puzzling
as
many
of
the
studies
did
not
include
a
methyl
bromide
control.
Because
there
was
no
indication
of
pest
pressure
in
many
instances,
many
of
the
entries
indicated
yields
of
approximately
100%,
obviating
the
differences
between
methyl
bromide
and
the
alternatives.

39
So,
for
example,
studies
conducted
in
California,
where
there
is
less
pressure
for
weeds
will
not
give
an
accurate
picture
of
the
situation
in
the
southeastern
U.
S.
where
nutsedge,
nightshades,
and
hard
seed­
coated
weeds
are
a
major
problem.
Reply
to
MBTOC
2005
Page
52
The
U.
S.
has
provided
marketing
data
documenting
the
existence
of
these
market
windows
and
their
effects
on
the
revenue
and
profits
earned
by
farmers.
Farmers
tell
us
that
nearly
all
of
their
net
revenue
(
approximately
90%)
above
cost
is
earned
during
the
short
period
of
high
prices.
For
some
crops,
75%
of
the
economic
loss
is
due
to
missing
a
market
window
rather
than
through
smaller
crops,
lower
fruit
quality,
or
higher
costs.

Many
of
the
alternatives
will
cause
farmers
to
miss
the
market
window.
For
some
alternatives,
for
example,
the
"
plant­
back"
interval
is
2­
4
weeks
longer,
relative
to
methyl
bromide
plant
back
times.
Requiring
a
longer
interval
before
a
crop
can
be
planted
will
delay
the
harvesting,
causing
a
farmer
to
miss
a
market
window.
Some
alternatives
also
require
a
different
bed
preparation,
which
will
also
delay
the
planting
time.
The
strawberry
crop
in
California
is
one
example
of
this
situation.

The
main
issue
for
drip
applied
fumigants
is
that
the
entire
field
and
irrigation
equipment
must
be
set
up
before
you
can
apply
the
fumigants.
Growers
here
have
told
me
that
this
requires
at
least
an
additional
2­
3
weeks
longer
than
with
broadcast
fumigation.
The
extension
of
this
time
is
not
a
serious
problem
on
fields
with
short
day
cultivars
like
Camarosa,
however,
it
is
an
important
problem
on
fields
with
day­
neutral
cultivars
like
Diamonte
(
a
majority
of
the
acreage
in
the
Watsonville
/
Salinas
area).

On
ranches
crowing
predominantly
day­
neutral
(
long
day)
cultivars
the
production
season
overlaps
with
the
next
crops
planting
season,
so
fields
of
day­
neutral
cultivars
are
typically
rotated
with
vegetable
crops
(
i.
e.
half
the
ranch
is
planted
in
strawberry
and
the
other
half
is
rotated
out
each
year).
The
normal
cycle
is
strawberry
(
September
04
 
November
05)
followed
by
two
vegetable
crops
(
November
05
 
September
06
)
then
back
to
strawberry
(
September
06
 
November
07).
The
value
of
the
October
/
November
fruit
harvests
from
the
day­
neutral
cultivars
is
so
high
that
growers
cannot
shorten
the
length
of
their
season
(
not
economically
possible
since
this
is
when
most
ranches
break
even
and
make
their
profit).
The
need
for
an
additional
2­
3
weeks
to
prepare
a
field
for
drip
fumigation
forces
strawberry
growers
to
take
back
the
land
from
the
rotation
vegetable
growers
2­
3
weeks
earlier.
Normally,
vegetable
growers
can
produce
two
crops
between
the
strawberry
rotations.
However,
the
shortening
of
the
season
by
2­
3
weeks
would
cause
result
in
only
one
vegetable
crop
on
80%
of
the
land
instead
of
two.
Land
sublease
rates
to
vegetable
growers
are
approximately
$
1000
for
one
crop
and
$
1800
for
two
(
the
land
leases
for
$
2200
for
full
year).
Therefore,
strawberry
growers
would
need
to
absorb
the
$
800
increase
in
rent
on
80%
of
their
crop
acreage
due
to
the
loss
of
one
of
the
two
vegetable
crops.

A
second
issue
with
the
transition
to
drip
applied
fumigants
is
the
need
to
setup
the
entire
irrigation
system
before
they
fumigate.
In
the
traditional
production
system
(
i.
e.
broadcast
fumigation),
growers
migrate
most
of
their
irrigation
headers
and
other
main
line
pipes
over
from
the
previous
season's
crop
to
the
new
after
the
end
of
that
season
(
in
November/
December/
January).
However,
with
drip
applied
fumigants
growers
will
need
two
sets
of
this
equipment,
an
increased
cost
that
is
difficult
for
many
growers
to
absorb.
It
is
difficult
to
get
firm
prices
on
this
but
I
have
an
estimate
of
$
500
/
acre
for
the
additional
equipment.
Another
related
issue
is
that
growers
cannot
use
drip
applied
fumigants
on
land
that
has
not
had
strawberries
on
it
before
due
to
a
similar
issue.
The
main
valves
and
pipes
for
the
irrigation
system
need
to
be
setup
for
strawberry,
and
this
can't
be
done
while
another
crop
is
in
the
ground,
and
there
is
insufficient
time
put
this
equipment
in
and
setup
for
drip
applied
Reply
to
MBTOC
2005
Page
53
fumigation.
Growers
in
this
situation
will
have
to
use
broadcast
fumigation
for
the
first
year
on
new
non­
strawberry
ground.
40
Losses
result
not
only
from
missing
market
windows
but
also
from
the
inability
to
plant
other
crops
in
rotation
with
strawberries,
losing
the
revenue
from
these
crops
USG
experts
have
examined
a
"
Porter
paper
in
press"
41
and
have
a
number
of
concerns
with
the
applying
the
results
of
this
paper
in
the
context
of
the
specific
circumstances
of
the
U.
S.
nomination.
Although
it
has
a
`
publication
date"
of
one
year
later
than
the
San
Diego
presentation,
we
find
that
our
concerns
on
this
issue
remain
the
same.
The
studies
used
in
the
meta
analysis
are
not
listed
and
no
indication
is
given
of
the
criteria
used
to
include
or
exclude
a
study
from
the
analysis.

A
specific
requirement
of
the
Montreal
Protocol
findings
is
that
they
be
made
"
in
the
circumstances
of
the
nomination".
There
is
no
indication
that
MBTOC
considered
the
specific
circumstances
of
the
U.
S.
nomination
(
which
are
that
methyl
bromide
is
requested
only
for
situations
where
regulatory
concerns
preclude
use
of
an
alternative
or
where
there
are
`
key'
pests
present
at
moderate
to
severe
levels,
or
where
terrain
conditions
(
temperature,
topography)
result
in
no
alternative
being
technically
and
economically
feasible).
MBTOC
has
not
cited
research
findings
to
support
their
contention
that
alternatives
are
both
technically
and
economically
feasible.
The
U.
S.
has
relied
upon
and
presented
specific
results
in
the
circumstances
of
the
nomination
to
support
our
request.

California
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
California.
Uses
of
alternatives
are
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
amount
of
1,3­
D
that
can
be
used.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
57:
43
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

Florida
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
Florida.
In
addition,
the
use
of
alternatives
are
limited
in
some
areas
because
the
soil
overlays
a
vulnerable
water
table
(
karst
geography).
Finally,
there
are
other
areas
where
regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures
make
alternatives
infeasible.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
40
Daniel
Legard,
PhD,
personal
communication,
January
3,
2005.
41
Porter,
I.,
S.
Mattner,
R.
Mann,
R.
Gounder,
J.
Banks,
and
P.
Fraser.
1994.
Strawberry
Fruit
Production
and
results
from
trials
in
Different
Geographic
Regions.
A
Presentation
to
the
Methyl
Bromide
Alternatives
Conference,
Lisbon,
September
1994.
Reply
to
MBTOC
2005
Page
54
compromising
pest
management.

Southeastern
U.
S.

At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
southeastern
U.
S.
In
addition,
the
use
of
alternatives
are
limited
in
some
areas
because
the
soil
overlays
a
vulnerable
water
table
(
karst
geography).
Finally,
there
are
other
areas
where
regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures
make
alternatives
infeasible.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

A
requirement
for
obtaining
a
critical
use
exemption
for
methyl
bromide
under
the
Montreal
Protocol
is
that
there
are
no
alternatives
that
are
both
technically
and
economically
feasible.
In
making
its
assessment,
MBTOC
has
ignored
the
issue
of
economic
feasibility.
Presented
below
are
economic
considerations
for
each
of
the
regions
applying
for
a
critical
use
exemption.

TABLE
1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Methyl
Bromide
100
1,248
1,248
1,248
Chloropicrin+
metam
sodium
73
964
964
964
1,3­
d
chloropicrin
86
1,416
1,416
1,416
Metam
Sodium
70
849
849
849
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.

TABLE
2:
YEAR
1
GROSS
AND
NET
REVENUE
Year
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
TABLE
3:
YEAR
2
GROSS
AND
NET
REVENUE
Year
2
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
Reply
to
MBTOC
2005
Page
55
TABLE
4:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
Reply
to
MBTOC
2005
Page
56
CALIFORNIA
­
TABLE
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
ALTERNATIVE
PIC+
MS
ALTERNATIVE
1,3­
D+
PIC
ALTERNATIVE
MS
YIELD
LOSS
(%)
0
27%
14%
30%

YIELD
PER
HECTARE
(
FRESH)
48,438
35,359
41,639
33,906
*
PRICE
PER
UNIT
(
US$)
$
1.71
$
1.62
$
1.62
$
1.62
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
73,683
51,099
60,173
48,999
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
60,131
55,339
58,438
54,921
=
NET
REVENUE
PER
HECTARE
(
US$)
$
13,552
(
4,240)
(
1,735)
(
5,922)

LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
17,792
11,817
19,474
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
88.19
58.57
96.52
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
24%
16%
26%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
131%
87%
144%

FLORIDA
­
TABLE
6:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
METHYL
BROMIDE
ALTERNATIVE
1,3­
D+
PIC
YIELD
LOSS
(%)
0
25
YIELD
PER
HECTARE
3,138
2,353
*
PRICE
PER
UNIT
(
US$)
23.10
23.10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
72,511
54,360
­
OPERATING
COSTS
PER
HECTARE
(
US$)
44,459
40,795
=
NET
REVENUE
PER
HECTARE
(
US$)
28,012
13,565
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
14,447
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
77.72
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
20%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
52%
Reply
to
MBTOC
2005
Page
57
EASTERN
UNITED
STATES
­
TABLE
7:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
EASTERN
UNITED
STATES
METHYL
BROMIDE
ALTERNATIVE
PIC+
MS
ALTERNATIVE
1,3­
D+
PIC
ALTERNATIVE
MS
YIELD
LOSS
(%)
0%
27%
14%
30%

YIELD
PER
HECTARE
22,417
16,364
19,270
15,692
*
PRICE
PER
UNIT
(
US$)
2.59
2.59
2.59
2.59
=
GROSS
REVENUE
PER
HECTARE
(
US$)
51,892
37,881
44,608
36,324
­
OPERATING
COSTS
PER
HECTARE
(
US$)
29,623
30,555
31,658
30,270
=
NET
REVENUE
PER
HECTARE
(
US$)
22,269
7,327
12,950
6,054
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
14,942
9,319
16,215
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
99.49
62.05
107.96
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
29%
18%
31%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
67%
42%
73%

Summary
of
Economic
Feasibility
The
economic
analysis
evaluated
methyl
bromide
alternative
control
scenarios
for
strawberry
production
of
fruit
in
Southeastern
states,
Florida,
and
California
by
comparing
the
economic
outcomes
of
methyl
bromide
oriented
production
systems
to
those
using
alternatives.

The
economic
factors
that
most
influence
the
feasibility
of
methyl
bromide
alternatives
for
fresh
market
strawberry
production
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,
and
(
3)
missed
market
windows
due
to
plant
back
time
restrictions,
which
also
affect
the
quantity
and
price
received
for
the
goods.

The
economic
reviewers
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.

(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
nominal
marginal
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
Reply
to
MBTOC
2005
Page
58
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
as
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,
strawberry
farmers
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.

Several
methodological
approaches
will
help
interpret
the
findings.
Economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
Costs
for
alternatives
are
based
on
market
prices
for
the
control
products
multiplied
by
the
number
of
pounds
of
active
ingredient
that
would
be
applied.
Baseline
costs
were
based
on
the
average
number
of
annual
applications
necessary
to
treat
strawberry
fields
with
methyl
bromide.

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.
Fixed
costs
were
not
included
because
they
are
difficult
to
measure
and
verify.

Loss
per
hectare
measures
the
value
of
methyl
bromide
based
on
changes
in
operating
costs
and/
or
changes
in
yield.
Loss
expressed
as
a
percentage
of
the
gross
revenue
is
based
on
the
ratio
of
the
revenue
loss
to
the
gross
revenue.
Likewise,
for
the
loss
as
a
percentage
of
net
revenue.
The
profit
margin
percentage
is
the
ratio
of
net
revenue
to
gross
revenue
per
hectare.
The
values
to
estimate
gross
revenue
and
the
operating
costs
for
each
alternative
were
derived
for
three
alternative
fumigation
scenarios
for
the
Eastern
States
and
California,
relative
to
methyl
bromide:
1)
metam
sodium
+
chloropicrin;
2)
1,3­
d
+
chloropicrin;
and
3)
metam
sodium.
Yield
loss
estimates
were
based
on
data
from
the
CUE's
and
EPA
data,
as
well
as
expert
opinion.

For
Florida,
three
scenarios
were
compared
to
the
methyl
bromide
baseline:
1)
1,3­
D
plus
chloropicrin;
2)
Iodomethane;
and
3)
Iodomethane
+
chloropicrin.
Because
Iodomethane
is
not
registered,
it
is
not
considered
a
feasible
alternative
but
the
analysis
is
provided
for
comparative
purposes.
Reply
to
MBTOC
2005
Page
59
Florida
In
2002,
Florida
had
2,792
hectares
(
6,900
acres)
or
100%
of
harvested
area
treated
with
an
average
of
75
kilograms
(
166
pounds)
of
methyl
bromide
per
hectare
(
acre).
The
closest
chemical
alternative
to
methyl
bromide
is
1,3­
D
plus
chloropicrin
(
as
Telone
C­
35).
However,
US­
EPA
estimates
that
approximately
40%
of
Florida's
strawberry
growing
areas
overlay
Karst
geology,
which
prohibits
the
use
of
1,3­
D
because
of
the
potential
for
groundwater
contamination.
The
use
of
1,3­
D
also
requires
a
30
m
buffer
around
inhabited
structures.
This
would
reduce
the
strawberry
producing
acreage
by
about
10%.
Nematodes
and
nutsedge
are
key
pests
in
Florida
strawberry
controlled
with
methyl
bromide.
Chloropicrin
is
not
as
effective
in
controlling
weeds
as
methyl
bromide.
Using
chloropicrin
adds
to
production
costs
through
increased
labor
costs
for
weeding
and
harvesting.

The
least­
loss
scenario
for
Florida
in
the
absence
of
methyl
bromide
is
for
growers
to
use
1,3­
d
plus
chloropicrin.
Under
that
scenario,
yield
loss
would
be
approximately
27%,
not
including
increases
in
labor
costs
for
hand
weeding,
drip
irrigation
costs,
or
changes
in
market
prices
due
to
later
harvests
missing
early
market
price­
premiums.
A
delay
in
planting
occurs
due
to
the
longer
plant­
back
interval
for
1,3­
d,
which
means
delayed
harvesting.
According
to
U.
S.
Department
of
Agriculture
data,
market
prices
for
Florida
strawberries
decline
approximately
18%
between
December
and
January.
Yield
and
price
impacts
together
make
up
impacts
on
gross
revenues.

Under
Alternative
1
(
1,3­
d
plus
chloropicrin),
the
yield
loss
was
estimated
to
be
25%
with
operating
costs
in
U.
S.
dollars
per
hectare
of
$
40,795.
The
estimated
net
revenue
was
$
13,565
per
hectare.
The
estimated
loss
per
hectare
is
estimated
to
be
$
14.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
77.72
per
kilogram.
If
growers
miss
the
December
market
window,
a
loss
of
approximately
one
month's
revenue
would
reduce
grower
gross
revenues
by
about
22%
in
addition
to
the
yield
loss
of
25%.

The
following
alternatives
are
presented
for
comparative
purposes
only
as
the
products
are
not
registered.
Under
alternative
2
(
Iodomethane),
the
yield
loss
was
estimated
to
be
14%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
40,795.
The
estimated
net
revenue
was
$
21,538
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
6,474.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
34.83
per
kilogram.

Under
alternative
3
(
Iodomethane
+
chloropicrin),
the
yield
loss
was
estimated
to
be
30%.
Operating
costs
in
U.
S.
dollars
per
hectare
are
$
40,795.
The
estimated
net
revenue
was
$
9,963
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
18,049.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
97.11
per
kilogram.

California
In
California,
1,3­
D
plus
chloropicrin
would
also
be
the
primary
replacement
for
methyl
bromide.
California
restricts
total
use
of
1,3­
D,
at
the
local
level
(
township
cap).
Approximately
63%
of
California's
strawberry
areas
are
fumigated
with
methyl
bromide,
and
31%
are
fumigated
with
alternatives.
Approximately
15%
of
the
strawberry
areas
are
on
hillsides
with
slopes
severe
Reply
to
MBTOC
2005
Page
60
enough
to
make
drip
irrigation
impractical.

Increased
production
preparation
time
would
delay
planting
in
the
southern
region
of
California
and
reduce
the
harvest
period
in
the
northern
region,
leading
to
decreases
in
the
prices
farmers
receive.
Ground
preparation
between
crops
takes
30
days
longer
using
1,3­
D
and
chloropicrin
because
of
the
time
required
to
prepare
drip
irrigation.
According
to
U.
S.
Department
of
Agriculture
data,
market
prices
for
strawberries
California
decline
5%
between
January
and
February.
If
using
the
alternatives
delay
the
harvest
period,
US­
EPA
estimates
there
will
be
a
market
price
decline
in
addition
to
a
yield
loss.
The
following
paragraphs
illustrate
the
estimated
losses
with
three
alternatives
for
California.

Alternative
1
(
chloropicrin+
metam
sodium),
yield
loss
was
estimated
to
be
27%,
and
gross
revenues
are
expected
to
decline
24%.
The
estimated
net
revenue
is
estimated
to
decline
more
than
131%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
88.19
per
kilogram.

Under
alternative
2
(
1,3­
D
plus
chloropicrin),
the
yield
loss
was
estimated
to
be
14%
and
prices
by
05%,
if
growers
miss
key
market
windows.
Gross
revenue
is
expected
to
decline
16%.
The
net
revenue
is
expected
to
decline
by
more
than
87%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
58.57
per
kilogram.

Under
alternative
3
(
metam
sodium),
the
yield
loss
was
estimated
to
be
30%,
and
the
gross
revenue
loss
was
estimated
to
by
26%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
96.52
per
kilogram.

Southeastern
United
States:
Under
Alternative
1
(
chloropicrin+
metam
sodium),
yield
loss
was
estimated
to
be
27%,
with
gross
revenues
decline
29%,
and
a
loss
in
estimated
net
revenue
of
67%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
99.49
per
kilogram.

Under
alternative
2
(
1,3­
D
+
chloropicrin),
the
yield
loss
was
estimated
to
be
14%,
with
gross
revenues
declining
18%,
and
net
revenues
expected
to
decline
by
42%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
62.05
per
kilogram.

Under
alternative
3
(
Metam
Sodium),
the
yield
loss
was
estimated
to
be
30%,
with
gross
revenues
declining
31%,
and
net
revenues
expected
to
decline
by
73%.
The
loss
per
kilogram
of
methyl
bromide
in
U.
S.
dollars
is
estimated
to
be
$
107.96
per
kilogram.

Note:
Market
price
data
was
not
available
for
the
Eastern
United
States
but
it
is
assumed
that
the
net
effect
of
shifting
from
methyl
bromide
to
any
of
the
alternatives
would
result
in
additional
revenue
reductions
due
fluctuations
in
market
price
due
to
changes
in
production
and
harvesting
times.

It
should
be
noted
that
the
applicants
do
not
consider
any
alternative
to
be
feasible
and
that
these
estimates
are
an
attempt
to
measure
potential
impacts.
Reply
to
MBTOC
2005
Page
61
c.
use
of
methyl
bromide
can
be
reduced
because
soil
pests
can
be
controlled
with
a
use
rate
of
200kg/
ha
and
because
use
of
higher
density
films
(
including
VIF)
will
allow
pest
control
at
lower
dosages.

In
making
this
assertion
MBTOC
has
relied
on
the
work
cited
in
two
papers,
Fennimore
et
al,
2003
and
Gilreath
et
al,
2003.
Fennimore
was
contacted
to
determine
whether,
in
his
opinion,
his
work
could
be
appropriately
used
to
support
lower
application
rates.
His
reply,
reproduced
below,
indicates
that
he
is
very
uncomfortable
with
this
interpretation
of
his
results42.

42
From:
Steven
Fennimore
[
mailto:
safennimore@
ucdavis.
edu]
Sent:
Fri
Jan
07
16:
24:
43
2005
To:
Dan
Legard
Cc:
jmduniway@
ucdavis.
edu;
haajwa@
ucdavis.
edu
Subject:
MBTOC
VIF
stance
Hi
Dan
I
am
a
bit
disturbed
to
learn
from
you
that
the
some
in
MBTOC
may
have
come
to
the
conclusion
that
VIF
will
allow
reduced
rates
of
methyl
bromide.
While
I
stand
behind
my
research
that
indicates
clearly
that
the
weed
control
efficacy
of
drip­
applied
chloropicrin
and
Inline
are
improved
under
VIF
compared
to
standard
film,
these
fumigants
are
used
to
control
many
other
pests
besides
weeds.
For
example,
results
do
not
necessarily
suggest
that
VIF
improves
phytopthora
cactorum
control.
Our
research
results
presented
at
MBAO
are
preliminary
and
we
are
currently
preparing
peer
reviewed
publications.
When
those
are
written
we
will
have
a
more
clear
understanding
of
the
potential
benefits
and
limitations
of
VIF
than
we
have
now.
I
do
believe
that
VIF
offers
real
potential
benefits,
however
I
caution
anyone
to
make
policy
decisions
about
VIF
based
on
my
preliminary
results
presented
at
MBAO
Steve
Fennimore
Extension
Specialist
University
of
California,
Davis
1636
East
Alisal
St
Salinas,
CA
93905
831­
755­
2896
Reply
to
MBTOC
2005
Page
62
Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.

We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
ortheir
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
complete
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

U.
S.
2006
nomination
In
summary,
the
USG
disagrees
with
MBTOC's
recommendation
that
the
U.
S.
request
can
be
reduced
and
reiterates
its
request
for
an
additional
397.597
metric
tons
of
methyl
bromide
for
a
total
of
1,918.4
metric
tons
of
methyl
bromide.

Citations
California
Department
of
Food
and
Agriculture.
California
Agricultural
Statistics
Service.

Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3­
DC
will
Impact
Adjustment
to
Methyl
bromide
Phase­
out.
California
Agriculture,
Volume
55,
Number
3.

Carpenter,
Janet
and
Lori
Lynch.
1999.
Impact
of
1,3­
D
Restrictions
in
California
after
a
Ban
on
Methyl
Bromide.
Presentation
at
the
1999
Annual
International
Conference
of
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Crop
Profile
for
Strawberries
in
California.
1999.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Crop
Profile
for
Strawberries
in
Florida.
2002.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Crop
Profile
for
Strawberries
in
Virginia.
2000.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Florida
Department
of
Agriculture
and
Consumer
Services.
Florida
Agricultural
Statistics
Service.
Reply
to
MBTOC
2005
Page
63
Florida
Summary
of
Plant
Protection
Regulations.
Oct.
2002.
Florida
Department
of
Agriculture
and
Consumer
Services.

Furguson
L.
M.,
Ducharme
D.
T.,
Driver
J.
G.,
Louws
F.
J.,
Snelson
J.
D.
Alternatives
to
methyl
bromide
to
control
black
root
rot
of
strawberry
in
North
Carolina,
2001­
2002.
Undated.
Publication
not
stated
or
unpublished
data.
No
untreated
control
reported.

Gamini,
S.
and
R.
K.
Nishimoto.
1987.
Propagules
of
purple
nutsedge
(
Cyperus
rotundus)
in
soil.
Weed
Technol.
1:
217­
220.

Georgia
Summary
of
Plant
Protection
Regulations.
Jan.
2000.
Georgia
Department
of
Agriculture.

Gilreath,
J.
P.,
J.
W.
Noling,
and
P.
R.
Gilreath.
1999.
Nutsedge
management
with
cover
crop
for
tomato
in
the
absence
of
methyl
bromide.
Research
summary.,
USDA
Specific
Cooperative
Agreement
58­
6617­
6­
013.

Holm,
L.
G.,
D.
L.
Plucknett,
J.
V.
Pancho,
and
J.
P.
Herberger.
1977.
The
world's
worst
weeds:
distribution
and
biology.
Honolulu,
HI:
University
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Hawaii
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pp.
8­
24.

Legard,
D.,
Personal
communication,
January
3,
2005.

Legard,
D.,
personal
communication,
January
7,
2005.

Locascio
S.
J.,
Olson
S.
M.,
Chase
C.
A.,
Sinclair
T.
R.,
Dickson
D.
W.,
Mitchell
D.
J.
and
Chellemi
D.
O.
1999.
Annual
International
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on
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and
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North
Carolina
Department
of
Agriculture
and
Consumer
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North
Carolina
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North
Carolina
Summary
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2003.
North
Carolina
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of
Agriculture
and
Consumer
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Patterson,
D.
T.
1998.
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nutsedge
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Shaw
V.
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Larson
K.
D.,
1999.
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plant
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Production.
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the
United
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of
Agriculture,
National
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97.

Tennessee
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Tennessee
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Tennessee
Summary
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Apr.
2000.
Tennessee
Department
of
Agriculture.

Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
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and
resprouting
potential.
Weed
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23:
333­
337.

Virginia
Department
of
Agriculture
and
Consumer
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Virginia
Agricultural
Statistics
Service.

Webster,
T.
M.,
A.
S.
Casinos,
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W.
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C.
C.
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D.
R.
Sumner,
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L.
Fery.
2001(
a).
Methyl
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in
a
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614
Webster,
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CITATIONS
REVIEWED
BUT
NOT
APPLICABLE
Southeastern
Literature
Citations
Benlioglu
S.,
Boz,
O.,
Yildiz
A.,
Kaskavalci
G.,
Benlioglu,
K.,
2002.
Soil
Solarization
Options
in
Aydin
Strawberry
Without
Methyl
Bromide.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Eger
J.
E.
Efficacy
of
Telone
Products
in
Florida
Crops:
A
Seven
Year
Summary.
2000.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Motis
T.
N.,
and
Gilreath,
J.
P.,
2002.
Stimulation
of
Nutsedge
Emergence
With
Chloropicrin.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Nelsen
K.
A.,
Renner,
K.
A.,
and
Penner,
D.,
2002.
Yellow
Nutsedge
(
Cyperus
esculentus)
Control
and
Tuber
Yield
with
Glyphosate
and
Glufosinate.
Weed
Technology
16:
360­
365.

Shaw
V.
S.,
and
Larson
K.
D.,
1999.
A
meta­
analysis
of
Strawberry
Yield
Response
to
Pre­
plant
Soil
Fumigation
with
Combinations
of
Methyl
Bromide­
chloropicrin
and
Four
Alternative
Systems.
HortScience
34:
839­
845.

California
Studies:
Reply
to
MBTOC
2005
Page
65
Ajwa,
H.
Study
conducted
from
2001
through
2003.
Iodomethane
and
Iodine
­
based
Materials
for
Strawberry
Production
in
California.
Publication
not
specified,
UC­
Davis.

Ajwa
H.,
Kabir
Z.
and
Fennimore
S.
Year
of
experiment
or
publication
not
specified.
Drip
Fumigation.
UC­
Davis.

Ajwa
H.,
Trout,
T.
Mueller
S.,
Wilhelm
S.,
Nelson
S.
D.,
Scoppe
R.
and
Shately
D.,
Application
of
Alternative
Fumigants
Through
Drip
Irrigation
Systems.
Phytopathology
92:
1349­
1355.

Browne
G.
T.,
Becherer
S.
T.,
Bhat
R.
G.
and
Lee
R.
C.
M..
2003.
Strategies
for
Management
of
Pytophthora
on
California
Strawberries.
USDA­
ARS,
Department
of
Plant
Pathology
UC
Davis,
Monterey
Bay
Academy
Field
Day.

Duniway
J.
M.,
Status
of
Chemical
Alternatives
to
Methyl
Bromide
for
Pre­
plant
Fumigation
of
Soil.
2002.
Phytopathology
92:
1337­
1343.

Duniway
J.,
Dopkins
D.
and
Hao
J.
2003.
Current
Experiments
on
Alternatives
to
Methyl
Bromide
for
Strawberry.
Published
for
the
Annual
Monterey
Bay
Academy
Field
Day.

Fennimore
S.
A.,
and
Valdez
J.,
Study
conducted
in
2002
and
2003.
Strawberry
Herbicide
Evaluation,
Monterey
Bay
Academy.
UC­
Davis,
Publication
not
specified.

Kabir
Z.,
Fennimore
S.,
Ajwa
H.,
and
Roth
K.
Study
conducted
in
2001
and
2002.
Chloropicrin
and
InlineTM
Field
Dose­
Response
Study
Under
VIF
and
Standard
Tarp:
Weed
Biomass
and
Weeding
Time
at
Las
Cuevas,
CA.
Publication
not
stated.

Kabir
Z.,
Fennimore
S.,
Ajwa,
and
Roth
K.
Study
conducted
in
2002
and
2003.
The
Efficacy
of
Agrizide
and
Plant
Pro
Alone
or
in
Combination
with
Chloropicrin
on
Weeds
Seeds
and
Native
Weeds
at
La
Cuevas,
CA.
Publication
not
stated.

Kabir
Z.,
Fennimore
S.,
Ajwa,
and
Roth
K.
Weed
Control
Efficacy
of
Drip
and
Shank
Applied
Iodomethane:
Chloropicrin
at
MBA,
CA
2002­
3.
Publication
not
specified.

Martin
F.
N.,
Management
of
Root
Diseases
of
Strawberry.
USDA­
ARS
Publication
not
specified.

Martin
F.
N.,
Study
conducted
in
2002.
The
Use
of
Remote
Sensing
in
Strawberry
Production.
Publication
unspecified.

Martin
F.
N.,
and
Bull
D.
T.,
Biological
Approaches
for
Control
of
Root
Pathogens
of
Strawberry.
Phytopathology
92:
1356­
1362.

Noling
J.
W.
The
Practical
Realities
of
Alternatives
to
Methyl
Bromide:
Concluding
Remarks.
Presented
at
the
Methyl
Bromide
Alternatives
­
Meeting
the
Deadlines
Symposium.
2002.
Published
in
Phytopathology
92:
1373­
1375.
Reply
to
MBTOC
2005
Page
66
Subbarao
K.
V.
Methyl
Bromide
Alternatives
­
Meeting
the
Deadlines.
Presented
at
the
92nd
Annual
Meeting
of
the
American
Phytopathological
Society,
Augus
14,
2000.
Accepted
for
publication
by
the
American
Phytopathological
Society
on
23
July
2002.

Trout,
T.
and
Gartung
J.,
2003.
Irrigation
Water
Requirements
for
California
Strawberries.
Not
used,
neither
methyl
bromide
nor
alternatives
were
evaluated,
just
water
requirements.
Publication
unspecified.

Yates
S.
R.,
Gan
J.
Papiernik
S.
K.
Dungan
R.
and
Wang
D.
Reducing
Fumigant
Emissions
After
Soil
Application.
2002.
Phytopathology
92:
1344­
1348.
Reply
to
MBTOC
2005
Page
67
9.
FIELD
GROWN
TOMATOES
Overview
of
the
U.
S.
nomination
The
U.
S.
is
requesting
2,844.985
metric
tons
of
methyl
bromide
for
use
on
field­
grown
tomatoes
in
the
following
areas:
Michigan
(
10.746
metric
tons),
California
(
102.058
metric
tons),
and
the
southeastern
U.
S.
Florida
and
Georgia
as
well
as
other
states
in
the
southeast
(
2,
726.68
metric
tons)
with
a
small
additional
amount
(
5.501
metric
tons)
for
research
purposes.

Currently
registered
alternatives
to
methyl
bromide
do
not
consistently
provide
effective
control
of
nutsedge
weed
species
and
more
time
is
needed
to
evaluate
relationship
between
fumigant
alternatives,
various
mulches,
and
herbicide
systems
under
different
growing
conditions.

The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
tomato
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:


pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
tomato
production.


geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
tomato
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.


regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
townships
caps
and
in
Florida
due
to
the
presence
of
karst
geology.


delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin,
and
in
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.


unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

Overview
of
MBTOC's
prior
Recommendation
MBTOC
has
recommended
a
total
of
2,217.433
metric
tons
of
methyl
bromide
distributed
as
follows:
Michigan
(
10.746metric
tons),
the
southeastern
U.
S.
(
2,197.5
metric
tons)
and
California
(
9.185
metric
tons).
The
research
amount
was
approved.

MBTOC
suggests
that
California
can
use
shank
injected
1,3­
D/
pic
and
avoid
the
problems
that
drip
applied
poses
on
the
hilly
terrain
that
forms
the
basis
for
the
California
request.
MBTOC
asserts
that
only
9%
of
the
California
terrain
is
precluded
from
this
option
due
to
binding
township
caps.
In
the
case
of
the
southeastern
states,
MBTOC
has
indicated
their
view
that
alternatives
are
technically
and
economically
feasible
and
applies
a
20%
phasein
factor.
MBTOC
further
states
that
the
dosage
can
be
reduced
for
a
maximum
applied
rate
of
200kg/
ha
for
the
treated
areas
and
may
be
further
reduced
if
high
density
films,
including
VIF
are
used.
Reply
to
MBTOC
2005
Page
68
California
MBTOC
has
suggested
that
shank­
injected
1,3­
D/
Pic
can
be
used
in
all
areas
that
are
not
currently
impacted
by
the
township
caps.
In
making
this
suggestion
they
are
ignoring
both
the
technical
and
regulatory
factors
described
above
and
the
actual
working
of
the
township
caps
in
California.
The
township
cap
is
a
maximum
that
can
be
applied
assuming
that
the
method
of
application
is
deep
shank
injection.
For
all
other
forms
of
injection
an
`
application
factor'
is
applied.
The
purpose
of
this
application
factor
is
to
reduce
the
amount
of
1,3­
D
that
can
be
applied
to
a
given
area,
reducing
exposure
to
the
population
to
a
level
comparable
to
that
experienced
when
deep
shank
injection
is
used.

Deep
shank
injection
cannot
be
used
to
control
pests
in
California
tomato
production.
Unlike
Florida,
where
the
soils
are
sandy
to
a
considerable
depth,
in
California
the
soils
are
prepared
for
planting
to
a
depth
of
12­
18
inches43.
The
deep
shank
method
injects
1,3­
D
below
this
level
where
the
soil
is
not
prepared
and
breaks
into
clumps.
The
soil
must
be
re­
tilled
before
planting
which
risks
introducing
pathogens
back
into
the
planting
zone.
When
shallow­
shank
injection
is
used,
the
higher
application
factors
mean
that
a
much
smaller
area
can
be
injected.

Dr.
Legard44
of
the
California
Strawberry
Commission
has
estimated
the
impact
on
maximum
acreage
treated
if
1,3­
D
is
(
shallow)
shank­
injected
into
the
soil
rather
than
drip­
applied
a
s
a
liquid.
Using
Telone
C35
®
at
39­
50
gallons
per
treated
acre,
138.8
to
178.0
acres
per
township
could
be
treated.
When
Inline
®
is
used
at
25
gallons
per
acre45
473.7
acres
per
township
can
be
treated.
In
other
words,
the
use
of
drip­
applied
1,3­
D
results
in
2.5
to
3
times
as
many
treated
acres.
Shank
injection
of
1,3­
D
will
greatly
reduce
the
acreage
treated46.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses47:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
43
This
corresponds
to
30­
45
cm.
44
Daniel
Legard,
PhD,
personal
communication.
January
9,
2005.
45
The
common
use
rate
on
strawberries
in
California
46
The
main
concern
associated
with
broadcast
fumigation
with
telone
C35
is
related
to
the
telone
township
cap.
There
are
different
emission
ratios
used
for
the
different
application
methods
that
adjusts
the
amount
of
telone
applied
to
the
township
cap.
The
lbs
used
are
"
adjusted"
by
the
following
factors
(
1x
for
deep
shank,
1.1x
for
drip
applied,
1.8x
for
shallow
shank).
Hopefully,
most
growers
would
use
deep
shank
where
possible
for
broadcast
telone
applications.
However,
broadcast
applications
still
involve
treating
approximately
40%
more
acreage
than
drip
(
2
row
bed
and
slightly
lower
for
3
and
4
row
beds,
which
are
becoming
more
popular
in
the
North).

47
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
Reply
to
MBTOC
2005
Page
69
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
Southeastern
United
States
MBTOC
has
asserted
that
for
the
southeastern
United
States
alternatives
are
technically
and
economically
feasible.
Using
this
assertion
as
a
basis
they
recommend
a
20%
reduction
for
phase­
in
of
alternatives
such
as
1,3D/
Pic
or
metam
sodium
with
or
without
Pic.

MBTOC
disagrees
with
the
U.
S.
assessments
of
yield
loss.

The
U.
S.
assessments
of
yield
loss
were
developed
from
technically
appropriate
studies
for
the
specific
circumstances
of
the
U.
S.
situation.
Technically
appropriate
studies
are
those
which:


Included
an
untreated
control
for
comparison
purposes
on
pest
levels

Included
methyl
bromide
as
a
treatment
standard

Included
information
on
the
(
key)
pests
present
in
the
treated
area

Give
estimates
of
yield
changes
(
differences)

The
U.
S.
nomination
was
restricted
to
those
situations
where
the
presence
and
prevalence
of
pests
(`
key'
pests)
that
could
not
be
controlled
by
alternatives
to
methyl
bromide
was
moderate
to
severe48
and
would
result
in
yield
loss.

As
we
understand
it
from
discussions
at
MOP­
16,
MBTOC
used
what
they
describe,
interchangeably
as
a
"
meta
analysis"
or
an
`
average'.
The
procedure
MBTOC
used
was
not
a
meta
analysis
in
that
a
meta
analysis
includes
only
studies
which
are
similar
enough
from
a
statistical
standpoint
that
they
can
be
combined
and
analyzed
as
if
they
comprised
one
study,
and
the
studies
need
to
be
identified,
appraised
and
summarized
according
to
an
explicit
and
reproducible
methodology
that
is
designed
to
answer
a
specific
research
question.
In
this
case,
the
appropriate
research
question
would
be
the
performance
of
alternatives
to
methyl
bromide
under
the
conditions
of
the
U.
S.
nomination
(
i.
e.
with
moderate
to
severe
pressure
from
key
pests).
The
null
hypothesis
would
be
that
alternatives
work
as
well
as
methyl
bromide
in
the
conditions
of
the
U.
S.
nomination.
The
U.
S.
nomination
is
specifically
for
the
use
of
methyl
bromide
where
key
pests
(
pests
not
adequately
controlled
by
alternatives
to
methyl
bromide)
are
present
at
moderate
to
severe
levels
and/
or
soil,
climate,
terrain,
or
regulatory
conditions
are
such
that
alternatives
to
methyl
bromide
either
cannot
be
used
or
result
in
significant
economic
losses
when
used.
These
economic
losses
must
be
of
sufficient
magnitude
that
they
render
the
alternative
"
not
economically
feasible"
which
presents
a
serious
problem
in
applying
the
meta
analysis.
Our
understanding
is
that
this
analysis
includes
some
studies
conducted
under
48
In
the
judgment
of
U.
S.
experts
pressure
was
such
that
yield
losses
of
the
magnitude
of
those
used
in
the
economic
assessment
would
be
sustained.
Reply
to
MBTOC
2005
Page
70
circumstances
that
are
not
similar
to
the
limited
conditions
included
in
the
U.
S.
nomination,
such
as
the
presence
of
moderate
to
severe
pest
pressure.

Although
it
is
difficult
to
be
certain
how
the
MBTOC
analysis
was
conducted
and
what
it
includes
because
it
has
not
been
reviewed
and
published
and
was
not
provided
to
the
U.
S.
experts
to
evaluate49,
we
are
able
to
make
some
educated
guesses
about
the
analysis50.
The
analysis
for
strawberry
fruit
is
described
in
a
paper
is
listed
as
being
"
in
press"
as
conference
proceedings
with
a
date
after
the
MBTOC
recommendations
on
the
U.
S.
nomination
were
tendered.

A
version
of
the
paper
was
presented
by
Dr.
Ian
Porter
at
the
Methyl
Bromide
Alternatives
Organization
meeting
in
San
Diego,
November
2003
and
was
the
subject
of
some
controversy
and
concern
among
a
number
of
participants.
Dr.
Porter's
paper
included
a
number
of
papers
which
U.
S.
experts
believe
are
not
appropriate
for
use
in
determining
the
usefulness
of
alternatives
because
the
research
was
carried
out
under
conditions
of
no
pest
pressure,
and
are
therefore
not
relevant
to
the
specific
circumstances
of
our
nomination51.
If
no
pests
are
present
any
alternative,
or
indeed
not
using
any
pesticide
at
all,
will
all
work
equally
well.
By
including
situations
where
there
is
no
pest
pressure
one
in
effect
adds
(
many)
"
100"
to
the
equation52
describing
the
differences
in
yield
between
crops
grown
using
methyl
bromide
and
those
grown
using
an
alternative.
This
has
the
effect
of
lowering
the
average
difference
between
yields
using
methyl
bromide
and
yields
using
an
alternative.
If
a
sufficient
number
of
"
100"
are
added,
the
result
will
be
to
(
falsely)
eliminate
the
yield
differences
between
methyl
bromide
and
the
alternatives.

In
other
papers,
pests
were
present
but
they
were
not
the
pests
present
in
the
all
of
the
U.
S.
circumstances.
Taking
the
case
of
the
southeastern
US,
for
example,
weeds,
diseases,
fungi,
and
nematodes
all
afflict
the
crops.
Some
of
these
pests
can
be
controlled
with
alternatives,
but
some
of
the
weeds,
in
particular
nutsedges
(
nut
grasses),
nightshades,
and
some
hard
seed
coated
weeds,
cannot.
Situations
without
weeds
will
show
small
or
no
yield
losses
when
alternatives
are
used
while
the
true
situation
when
(
key)
weeds
are
present
is
that
there
are
relatively
large
yield
losses.
Including
these
factors
again
has
the
effect
of
adding
"
100"
yield
difference
as
many
times
as
there
are
papers.

49
The
US
Government
requested
references
from
two
of
the
authors
of
the
paper
to
allow
us
to
better
understand
the
analysis,
but
this
information
has
not
yet
been
provided
50
Some
of
this
material
with
references
had
been
previously
presented
at
the
Methyl
Bromide
Alternatives
Organization
2003
meeting
(
San
Diego).
At
that
time
U.
S.
experts
expressed
their
view
that
many
if
not
most
of
the
studies
were
not
an
appropriate
application
of
the
information.

51
For
example,
some
trials
are
used
for
residue
tests.
These
tests
are
likely
to
be
carried
out
in
conditions
of
little
or
no
pest
pressure
in
order
to
have
enough
harvested
fruit
to
test
for
residue.
The
Porter
paper
does
not
indicate
which
of
the
studies
used
(
but
not
cited)
where
for
the
purposes
of
examining
pesticide
residues.

52
The
actual
procedure
was
to
add
in
yields
expressed
as
a
percentage
of
(
anticipated)
yield
using
methyl
bromide.
How
this
yield
was
estimated
is
puzzling
as
many
of
the
studies
did
not
include
a
methyl
bromide
control.
Because
there
was
no
indication
of
pest
pressure
in
many
instances,
many
of
the
entries
indicated
yields
of
approximately
100%,
obviating
the
differences
between
methyl
bromide
and
the
alternatives.
Reply
to
MBTOC
2005
Page
71
If
the
issue
had
been
to
average
all
papers,
describing
some
"
average"
worldwide
situation,
the
procedure
followed
in
this
approach
would
be
appropriate.
However,
The
U.
S.
submitted
requests
for
continued
methyl
bromide
use
only
instances
of
sufficiently
high
pest
pressure
(
not
average)
for
pests
which
cannot
be
controlled
by
alternatives
to
methyl
bromide.

In
the
case
of
crops
other
than
strawberries,
the
basis
for
MBTOC's
suggestion
of
no
differences
in
yields
between
methyl
bromide
treatments
and
treatments
with
the
alternatives
is
more
difficult
to
assess.
MBTOC
representatives
at
MOP­
16
indicated
that
their
"
expert
judgment"
was
the
basis
for
the
finding
that
alternatives
were
technically
and
economically
feasible.
It
is
impossible
to
determine
from
this
statement
whether
the
conditions
used
by
the
experts
to
make
their
findings
are
similar
to
the
particular
conditions
of
the
U.
S.
nomination.
Given
what
we
already
know
about
the
applicability
of
the
meta
analysis
for
strawberries
to
the
U.
S.
circumstances,
it
seems
likely
that
MBTOC
is
not
using
experience
accrued
in
situations
similar
to
those
prevailing
in
the
portions
of
the
U.
S.
for
which
methyl
bromide
is
requested,
but
rather
relying
on
more
generalized
experience
to
make
these
judgments
for
which
no
data
or
references
have
been
provided.

The
U.
S.
disagrees
with
the
MBTOC
assessment
of
yield
loss
in
the
specific
circumstances
of
the
U.
S.
nomination.

Turning
now
to
the
component
of
economic
loss
that
is
a
consequence
of
market
timing
we
find
that
MBTOC
has
completely
ignored
losses
arising
from
market
windows.

Experts
are
familiar
with
high
prices
for
fresh
produce
early
in
the
season,
prices
which
decline
as
the
produce
becomes
abundant
(
and
more
familiar)
later
in
the
season.
The
U.
S.
has
provided
marketing
data
documenting
the
existence
of
these
market
windows
and
their
effects
on
the
revenue
and
profits
earned
by
farmers.
Anecdotally,
farmers
tell
us
that
virtually
al
of
their
net
revenue
(
approximately
90%)
above
cost
is
earned
during
the
short
period
of
high
prices.
For
some
crops,
75%
of
the
economic
loss
is
due
to
missing
a
market
window
rather
than
through
smaller
crops,
lower
fruit
quality,
or
higher
costs.

Many
of
the
alternatives
will
cause
farmers
to
miss
the
market
window.
In
conditions
of
cold
soil
temperatures,
such
as
in
Michigan
and
coastal
California,
where
the
growing
season
is
short,
alternatives
cannot
be
used
until
the
soil
temperatures
reach
at
least
40
F.
This
temperature
is
reached
3­
4
weeks
into
the
growing
season,
delaying
planting
and
consequently
harvesting
for
that
time.
Because
the
Michigan
growing
season
is
already
short
due
to
the
cold
temperatures,
even
apart
from
missing
the
market
window,
delaying
planting
will
result
in
a
smaller
harvestable
amount.
In
other
situations
the
"
plant­
back"
interval
is
longer,
by
2­
4
weeks,
relative
to
the
methyl
bromide
plant
back
times.
Requiring
a
longer
interval
before
a
crop
can
be
planted
will
delay
the
harvesting,
again
causing
a
farmer
to
miss
a
market
window.
Some
alternatives
also
require
a
different
bed
preparation,
which
will
also
delay
the
planting
time.
The
strawberry
crop
in
California
is
one
example
of
this
situation.

It
is
difficult
to
determine
the
basis
MBTOC
used
in
determining
that
alternatives
for
methyl
bromide
are
both
technically
and
economically
feasible
in
tomato
production.
USG
technical
Reply
to
MBTOC
2005
Page
72
experts
asked
MBTOC
to
explain
the
basis
for
their
decision53
and
were
told
that
in
some
cases
a
meta
analysis
served
as
the
basis,
and
in
other
cases
the
basis
was
experience.
When
asked
for
references,
USG
experts
were
directed
to
"
the
Porter
paper
in
press".
USG
experts
have
examined
a
"
Porter
paper
in
press"
54
and
have
a
number
of
concerns
over
its
applicability
to
the
specific
circumstances
of
the
U.
S.
CUE.
Although
it
has
a
publication
date
of
one
year
later
than
the
San
Diego
presentation,
we
find
that
our
concerns
over
its
applicability
have
not
been
resolved.
The
studies
used
in
the
meta
analysis
are
not
listed
and
no
indication
is
given
of
the
criteria
used
to
include
or
exclude
a
study
from
the
analysis.

There
is
no
indication
that
MBTOC
considered
the
specific
circumstances
of
the
U.
S.
nomination
(
which
are
that
methyl
bromide
is
requested
only
for
situations
where
regulatory
concerns
preclude
use
of
an
alternative
or
where
there
are
`
key'
pests
present
at
moderate
to
severe
levels,
or
where
terrain
conditions
(
temperature,
topography)
result
in
no
alternative
being
technically
and
economically
feasible).
MBTOC
has
not
cited
research
findings
supporting
their
contention
that
alternatives
are
both
technically
and
economically
feasible;
the
U.
S.
has
presented
extensive
results
in
the
circumstances
of
the
nomination
to
support
our
position.

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

1.
Yield
Loss
­
Expected
yield
losses
of
somewhat
over
6%
55
are
anticipated
throughout
southeastern
U.
S.
tomato
production.

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

Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
53
MBTOC
suggests
that
alternatives
were
both
technically
and
economically
feasible
for
the
pre­
plant
sectors
of
field
grown
peppers,
strawberries,
and
tomatoes.
The
same
assertions
were
made
for
portions
of
other
countries'
nominations
as
well.
54
Porter,
I.,
S.
Mattner,
R.
Mann,
R.
Gounder,
J.
Banks,
and
P.
Fraser.
1994.
Strawberry
Fruit
Production
and
results
from
trials
in
Different
Geographic
Regions.
A
Presentation
to
the
Methyl
Bromide
Alternatives
Conference,
Lisbon,
September
1994.
55
The
submitted
data
showed
that
using
the
above
best
alternative
the
growers
are
expected
to
suffer
6.2%
yield
losses
(
Chellemi,
Botts
and
Noling.
2001).
A
combination
of
1,3­
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
is
no
longer
available
then
the
growers
will
need
to
substitute
another
herbicides
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
to
control
nutsedge
weeds.
These
herbicides,
however,
have
significant
limitations.
In
addition,
losses
will
be
higher
in
areas
of
Karst
geology,
where
1,3­
D
may
not
be
used.
Reply
to
MBTOC
2005
Page
73
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
U.
S.
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
15%.
We
reduced
the
season
average
price
by
15%
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.

MBTOC
has
suggested
that
rates
can
be
reduced
to
a
maximum
level
of
200kg/
ha
MBTOC
has
also
reduced
the
amount
recommended
for
tomatoes
stating:
"
A
further
adjustment
was
applied
to
reduce
the
dosage
to
the
guideline
level
of
200kg/
ha
under
the
strips."
When
this
issue
was
discussed
with
MBTOC
members
during
the
16th
MOP,
U.
S.
experts
agreed
to
clarify
whether
the
reported
rates
were
in
fact
the
rates
used
under
the
strips
(
as
the
U.
S.
believed)
or
whether
they
were
the
average
for
an
acre
as
MBTOC
believed56.
The
U.
S.
has
verified
that
the
application
rates
provided
in
the
quantitative
assessment
(
the
Methyl
Bromide
Usage
Numerical
Index,
or
BUNI)
are
in
fact
the
rates
under
the
strips.
The
number
of
acres
reported
is
the
"
treated
acres",
so
that
a
strip
application
results
in
two
thirds
of
an
acre
being
fumigated
while
one­
third
is
the
untreated
is
reported
as
two
thirds
of
an
acre.

They
have
further
suggested
that
rates
can
be
reduced
still
further
if
higher
density
tarps,
including
VIF,
are
used.
One
of
the
papers
cited
in
support
of
this
proposal
is
Fennimore
et
el,
2003.
Fennimore
was
contacted
to
determine
whether,
in
his
opinion,
his
work
could
be
appropriately
used
to
support
lower
application
rates.
His
reply,
reproduced
below,
indicates
that
he
is
very
uncomfortable
with
this
interpretation
of
his
results57.

56
If
the
rates
were
an
average
per
acre,
as
MBTOC
believed,
given
that
in
strip
treatments
approximately
one­
third
of
the
acre
is
left
untreated,
the
rates
applied
would,
in
some
cases,
exceed
the
MBTOC
recommended
dosage
of
200kg/
ha.
57
From:
Steven
Fennimore
[
mailto:
safennimore@
ucdavis.
edu]
Sent:
Fri
Jan
07
16:
24:
43
2005
To:
Dan
Legard
Cc:
jmduniway@
ucdavis.
edu;
haajwa@
ucdavis.
edu
Subject:
MBTOC
VIF
stance
Hi
Dan
I
am
a
bit
disturbed
to
learn
from
you
that
the
some
in
MBTOC
may
have
come
to
the
conclusion
that
VIF
will
allow
reduced
rates
of
methyl
bromide.
While
I
stand
behind
my
research
that
indicates
clearly
that
the
weed
control
efficacy
of
drip­
applied
chloropicrin
and
Inline
are
improved
under
VIF
compared
to
standard
film,
these
fumigants
are
used
to
Reply
to
MBTOC
2005
Page
74
Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
ortheir
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
complete
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

U.
S.
2006
nomination
In
summary,
the
USG
does
not
agree
with
MBTOC's
contention
that
the
U.
S.
request
can
be
reduced
and
reiterates
it
request
for
an
additional
622.053
metric
tons
of
methyl
bromide
for
a
total
of
2,844.985
metric
tons
of
methyl
bromide.

Citations
Chellemi,
D.,
Botts,
D.
A.
and
Noling,
J.
W.
2001.
Field
scale
demonstration/
validation
studies
of
methyl
bromide
in
plastic
mulch
culture
in
Florida,
USDA
ARS
specific
co­
operative
agreement
SCA
#
58­
6617­
6­
013,
Executive
Summary
(
1996­
2001)
submitted
to
the
USEPA

control
many
other
pests
besides
weeds.
For
example,
results
do
not
necessarily
suggest
that
VIF
improves
phytopthora
cactorum
control.
Our
research
results
presented
at
MBAO
are
preliminary
and
we
are
currently
preparing
peer
reviewed
publications.
When
those
are
written
we
will
have
a
more
clear
understanding
of
the
potential
benefits
and
limitations
of
VIF
than
we
have
now.
I
do
believe
that
VIF
offers
real
potential
benefits,
however
I
caution
anyone
to
make
policy
decisions
about
VIF
based
on
my
preliminary
results
presented
at
MBAO
Steve
Fennimore
Extension
Specialist
University
of
California,
Davis
1636
East
Alisal
St
Salinas,
CA
93905
831­
755­
2896
Reply
to
MBTOC
2005
Page
75
Burnette,
G.
2003.
Personal
communication,
November
25,
2003.

Culpepper,
Stanley.
2004.
Faculty,
University
of
Georgia,
Athens,
GA.
Comments
on
methyl
bromide
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use
nomination
for
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in
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2000.
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soil
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Web
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imok.
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Hausbeck,
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and
Cortright,
B.
2003.
Soil
temperature
data
submitted
to
BEAD
(
OPP,
US­
EPA)
in
support
of
methyl
bromide
critical
use
exemption
application.

Jacob,
W.
C.
1977.
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outside
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rainfall
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by
the
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Lamour,
H.
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2003.
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crop
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survival
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Locasio,
S.
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.,
Kucharek,
T.
A.,
Jones,
J.
P.
and
Noling,
J.
W.
1997.
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alternatives
to
methyl
bromide
for
polyethylene­
mulched
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32(
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Morales,
J.
P.,
Santos,
B.
M.,
Stall,
W.
M.
and
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1997.
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(
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Nelson,
K.
A.
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K.
A.
2002.
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tuber
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16(
3):
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Norton,
J.,
Nelson,
R.
D.,
Nelson,
M.
D.,
Olson,
B.
O.,
Mey,
B.
V.
and
Lepez,
G.
2000.
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of
alternatives
to
methyl
bromide
for
pre­
plant
soil
fumigant
in
California
tomatoes.
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IR­
4
methyl
bromide
alternatives
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for
minor
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to
the
US­
EPA
during
2003
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support
of
methyl
bromide
critical
use
exemption.

Stall,
W.
M.
and
Morales­
Payan,
J.
P.
2003.
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critical
period
of
nutsedge
interference
in
tomato,
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Web
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http://
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imok.
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S.
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of
using
gas
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tarps
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methyl
bromide
emissions
associated
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in
the
United
States.
