METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
SOD
FARMS
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Sod
Farms
(
Prepared
in
2005)

NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.


Yes

No
Signature
Name
Date
Title:
U.
S.
Turf
ii
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Steve
Knizner
Title:
Acting
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
U.
S.
A.
Telephone:
(
703)
305­
6903
Fax:
(
703)
308­
8090
E­
mail:
knizner.
steve@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
U.
S.
Turf
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
_________________________________________________________
6
1.
Nominating
Party
_________________________________________________________
6
2.
Descriptive
Title
of
Nomination______________________________________________
6
3.
Crop
and
Summary
of
Crop
System___________________________________________
6
4.
Methyl
Bromide
Nominated
_________________________________________________
6
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
6
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
7
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
______________________________
7
7.
(
ii)
If
only
part
of
the
crop
area
is
treated
with
methyl
bromide,
indicate
the
reason
why
methyl
bromide
is
not
used
in
the
other
area,
and
identify
what
alternative
strategies
are
used
to
control
the
target
pathogens
and
weeds
without
methyl
bromide
there.
_______________
7
7.
(
iii)
Would
it
be
feasible
to
expand
the
use
of
these
methods
to
cover
at
least
part
of
the
crop
that
has
requested
use
of
methyl
bromide?
What
changes
would
be
necessary
to
enable
this?______________________________________________________________________
8
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________
8
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
______
8
10.
Sod
 
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________________
9
11.
Sod
 
Characteristics
of
Cropping
System
and
Climate___________________________
9
11.
(
ii)
Sod
 
Indicate
if
any
of
the
above
characteristics
in
11.
(
i)
prevent
the
uptake
of
any
relevant
alternatives?
_______________________________________________________
10
12.
Sod
 
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
10
PART
C:
SOD
 
TECHNICAL
VALIDATION
____________________________________
11
13.
Sod
 
Reason
for
Alternatives
Not
Being
Feasible
_____________________________
11
14.
Sod
 
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
11
15.
Sod
 
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives_______________________________________________________________
12
16.
Sod
 
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested___________
12
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?________________________________________
14
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide
___________________________________________________________
14
Summary
of
Technical
Feasibility
_____________________________________________
14
PART
D:
EMISSION
CONTROL_______________________________________________
15
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
15
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
15
PART
E:
ECONOMIC
ASSESSMENT
__________________________________________
16
U.
S.
Turf
iv
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
16
22.
Gross
and
Net
Revenue___________________________________________________
16
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
17
Summary
of
Economic
Feasibility
_____________________________________________
17
PART
F.
FUTURE
PLANS____________________________________________________
19
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
19
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
19
25.
Additional
Comments
on
the
Nomination
____________________________________
19
26.
Citations
______________________________________________________________
20
U.
S.
Turf
v
LIST
OF
TABLES
PART
A:
SUMMARY___________________________________________________________
6
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
6
Table
A.
1:
Executive
Summary
__________________________________________________
7
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
__________________________
7
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use_______________________
8
Table
10.1:
Sod
 
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_______
9
Table
11.1:
Sod
 
Characteristics
of
Cropping
System
________________________________
9
Table
11.2
Sod
 
Characteristics
of
Climate
and
Crop
Schedule
________________________
10
Table
12.1:
Sod
 
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________
10
PART
C:
SOD
 
TECHNICAL
VALIDATION
______________________________________
11
Table
13.1:
Sod
 
Reason
for
Alternatives
Not
Being
Feasible
_________________________
11
Table
14.1:
Sod
 
Technically
Infeasible
Alternatives
Discussion
______________________
11
Table
15.1:
Sod
 
Present
Registration
Status
of
Alternatives
__________________________
12
Table
16.1:
Sod
 
Effectiveness
of
Alternatives
 
Nutsedge
(
Cyperus
spp.)
in
Florida
______
12
Table
16.2:
Sod
 
Effectiveness
of
Alternatives
 
Weedy
Grasses
in
Florida
______________
13
Table
C.
1:
Sod
 
Alternatives
Yield
Loss
Data
Summary
_____________________________
13
PART
D:
EMISSION
CONTROL
________________________________________________
15
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
15
PART
E:
ECONOMIC
ASSESSMENT
____________________________________________
16
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
16
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
16
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________________________
16
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
16
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives_________________________
17
PART
F.
FUTURE
PLANS
_____________________________________________________
19
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
__________________
21
U.
S.
Turf
Page
6
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Sod
Farms
(
Prepared
in
2005)

3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
The
Turfgrass
Producers
International
has
requested
methyl
bromide
(
MB)
as
a
critical
use.
This
nomination
includes
use
of
MB
in
the
production
of
turfgrass
sod,
grown
primarily
in
California,
Florida,
Georgia,
Alabama,
and
Texas.
There
are
at
least
1,143
turfgrass
sod
producers
across
the
U.
S.
who
farm
approximately
132,000
hectares,
with
a
wholesale
product
value
of
U.
S.
$
670
million.
On
average,
fumigation
of
the
affected
soil
occurs
once
every
three
years.
Sod
fields
have
been
flat
fumigated
with
MB
when
first
establishing
new
sod
fields
and
as
a
pre­
plant
fumigation
when
pest
pressures
become
so
severe
that
effective
pest
management
with
alternatives
is
particularly
difficult.
Turfgrass
yields
average
between
6,400
and
8,700
square
meters
per
hectare
per
cutting.
From
planting
to
harvest,
a
sod
crop
takes
between
9­
12
months
to
reach
maturity.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)

2007
78,040
254
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
effective
against
key
pests
when
pressure
is
moderate
to
high.
The
use
of
MB
is
also
considered
critical
only
where
alternatives
are
not
suitable
because
of
regulatory,
economic,
or
technical
constraints.
Although
alternative
treatments
can
be
foreseen
as
long­
term
solutions
to
MB
use,
transition
from
MB
will
depend
on
the
development
of
application
technologies
to
better
deliver
these
alternatives
to
soils
containing
target
pests.
Alternative
treatments
may
require
more
frequent
applications
and
increase
costs
and
environmental
pesticide
burden.
Research
is
ongoing
to
develop
protocols
for
likely
alternatives.

A
small
percentage
of
total
hectares
for
sod
farms
currently
use
MB.
The
use
is
primarily
for
approximately
1%
of
sod
farm
hectares
that
face
pests
that
are
difficult
to
manage.
The
little
U.
S.
Turf
Page
7
research
that
has
been
conducted
to
identify
MB
alternatives
has
found
that
metam­
sodium
and
dazomet
may
be
acceptable
replacements
for
MB
for
many
farms
that
currently
use
MB.
This
sector
is
still
developing
methods
of
applications
that
can
make
these
alternatives
more
effective.

TABLE
A.
1:
EXECUTIVE
SUMMARY
TURF
Turfgrass
Producers
International
AMOUNT
OF
REQUEST*
(
KG)
2007
680,388
AMOUNT
OF
NOMINATION
(
KG)
2007
76,112
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
**
Golfcourse
Superintendents
Association
are
part
of
a
supplemental
request.
They
applied
for
a
CUE
in
2002
and
2004
but
not
2003.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE
Primary
MB
alternatives
for
sod
production
are
metam­
sodium
and
dazomet,
often
in
combination
with
chloropicrin
and
in
some
cases
depending
on
pests,
1,3­
D.
Research
results
(
Unruh
and
Brecke,
2001;
Unruh
et
al.,
2002)
suggest
that
these
alternatives
have
the
potential
to
be
as
effective
as
MB,
although
research
in
application
technologies
will
continue
and
will
permit
development
of
more
effective
pest
control
methodologies.

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TOTAL
CROP
AREA
­
2001­
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)

Turfgrass
Producers
1206
1
%

7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE
Approximately
1%
of
the
total
land
planted
for
turfgrass
is
treated
with
MB
each
year;
the
affected
area
averages
one
treatment
every
three
years.
MB
is
used
only
in
the
portion
of
the
turfgrass
area
where
pest
problems
cannot
be
acceptably
controlled
using
alternative
methods.
For
instance,
some
broadleaf
weeds,
such
as
ragweed,
pigweed,
and
morning
glory,
may
be
controlled
through
continuous
mowing
to
reduce
seed
production.
Spot
treatment
with
a
nonselective
herbicide,
such
as
glyphosate,
may
be
used
to
control
competitive
grasses
that
can
be
easily
distinguished
from
the
turfgrass
crop.
Relatively
low
pest
pressures
in
most
of
the
turfgrass
sod
production
area
make
it
possible
for
producers
to
use
alternative
pesticides
(
herbicides,
fungicides,
nematicides,
and
insecticides)
and
cultural
practices.
U.
S.
Turf
Page
8
7.
(
iii)
WOULD
IT
BE
FEASIBLE
TO
EXPAND
THE
USE
OF
THESE
METHODS
TO
COVER
AT
LEAST
PART
OF
THE
CROP
THAT
HAS
REQUESTED
USE
OF
METHYL
BROMIDE?
WHAT
CHANGES
WOULD
BE
NECESSARY
TO
ENABLE
THIS?

Advances
in
technologies
that
will
improve
efficacy
(
e.
g.,
application
methods,
use
of
VIF)
and
may
increase
the
area
of
production
where
alternatives
can
be
used
effectively.
Research
(
e.
g.,
Unruh
and
Brecke,
2001;
Unruh
et
al,
2002)
in
turfgrass
production
indicates
that
fumigant
efficacy
(
even
MB)
varies
depending
on
location
and
pest
pressure.
It
is
likely
that
farms
where
nutsedge
is
a
major
pest
will
have
the
most
difficult
task
finding
an
alternative.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Turfgrass
Producers
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
METHYL
BROMIDE
680,400
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Flat
fumigation
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CRITICAL
USE
EXEMPTION
(
CUE)
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
1416
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
480
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
48.0
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

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

 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
MB
were
subtracted.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
applicant
included
growth
in
the
request
and
the
growth
amount
was
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
 
Only
the
areas
with
moderate
to
heavy
key
pest
pressure
were
included
in
the
nomination.
U.
S.
Turf
Page
9
10.
SOD
 
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
TABLE
10.1:
SOD
 
KEY
PESTS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
AND
WEED
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Throughout
the
United
States
Weeds:
nutsedge
(
Cyperus
spp.
);
mainly
offtype
perennial
grasses,
crabgrass
(
Digitaria
spp.);
goosegrass
(
Eleusine
indica);
common
bermudagrass
(
Cynodon
dactylon)
and
turfgrass
from
the
previous
crop
cycle.

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

Insects:
white
grubs
(
several
species
of
soilinhabiting
scarabaeid
beetle
larvae)
Producers
of
turfgrass
need
to
produce
sod
that
is
free
of
contamination
with
offtype
perennial
grasses,
other
weeds,
pests,
and
diseases.
For
approximately
1%
of
the
turfgrass
sod
growing
area,
this
degree
of
pest
control
has
been
achieved
through
MB
fumigation.
However,
dazomet
and
metam
sodium
with
chloropicrin
have
looked
as
good
(
statistically)
and
nearly
as
good
(
numerically)
in
control
of
nutsedge
and
weedy
grasses
as
MB
at
the
high
use
rates
for
turf
(
560
kg/
ha)
(
e.
g.,
Unruh
and
Brecke,
2001;
Unruh
et
al.,
2002).

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

CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Turfgrass
sod
grown
from
seeds
or
rhizomes
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Harvested
annually
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
None
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Varies
from
clayish­
loam
to
sandy­
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
The
area
is
treated
with
methyl
bromide
approximately
once
every
3
years.
On
average,
1%
of
the
total
turfgrass
crop
production
area
in
the
U.
S.
is
fumigated
in
any
one
year.

OTHER
RELEVANT
FACTORS:
None
identified.
U.
S.
Turf
Page
10
TABLE
11.2
SOD
 
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
Range
from
temperate
to
subtropical
(
USDA
Plant
Hardiness
Zones
5b
through
11)

SOIL
TEMP.
(
°
C)

RAINFALL
(
mm)

OUTSIDE
TEMP.
(
°
C)
Variable
throughout
the
United
States.

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

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

None
were
identified
as
being
relevant
factors.

12.
SOD
 
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
TABLE
12.1:
SOD
 
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
1,232
1,874
1,563
1,029
1382
648
AMOUNT
OF
MB
ACTIVE
INGREDIENT
USED
(
total
kilograms)
600,619
913,557
762,021
501,568
619,255
312,077
FORMULATIONS
OF
MB
(
MB
/
chloropicrin)
According
to
the
applicant,
the
typical
formulation
used
on
turfgrass
sod
is
98:
2.

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

APPLICATION
RATE
FOR
THE
ACTIVE
INGREDIENT
IN
kg/
ha*
488
488
488
488
448
482
ACTUAL
DOSAGE
RATE
FOR
THE
ACTIVE
INGREDIENT
(
g/
m2)*
48.8
48.8
48.8
48.8
44.8
48.2
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Turf
Page
11
PART
C:
SOD
 
TECHNICAL
VALIDATION
13.
SOD
 
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
TABLE
13.1:
SOD
 
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
CHEMICAL
ALTERNATIVES
Dazomet
Research
results
indicated
that
most
treatments
(
including
MB)
differed
in
efficacy
depending
on
site
location
and
specific
weed
pests
that
were
evaluated
(
e.
g.,
Unruh
et
al.,
2002).
In
research
trials,
dazomet
provided
poor
control
of
nutsedge
in
Jay,
Florida,
44
weeks
after
treatment,
compared
to
MB
(
89%
vs.
57%,
respectively).
At
the
same
site,
dazomet
provided
equal
control
of
weedy
grasses
and
slightly
better
control
of
broadleaf
weeds
compared
to
MB,
44
weeks
after
treatment
and
32
weeks
after
treatment,
respectively
(
Unruh
et
al.,
2002).
MB
fields
may
be
planted
within
48
hours
after
the
plastic
cover
is
removed,
while,
depending
on
soil
temperature,
a
period
of
14
to
21
days
may
be
required
for
effective
fumigation
when
dazomet
is
used
to
treat
the
soil.
In
situations
of
low
pest
pressure
golfcourses
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
Possibly
1,3­
D
and
1,3­
D
+
Chloropicrin
Might
be
used
if
nematodes
are
a
primary
pest,
or
possibly
in
conjunction
with
dazomet
or
metam­
sodium.
Unruh
and
Brecke
(
2001)
did
not
observe
sufficient
efficacy
for
managing
weed
pests.
Possibly
Metam­
Sodium
/
Chloropicrin
Unruh
and
Brecke
(
2001)
found
that
metam­
sodium
with
chloropicrin
provided
comparable
control
(
vs.
MB)
of
weedy
grasses
and
nutsedge
at
some
locations
in
Florida
but
not
in
all.
Efficacy
varied
for
all
treatments,
including
MB,
depending
on
location.
Possibly
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

14.
SOD
 
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
TABLE
14.1:
SOD
 
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Selective
Pre­
or
Post­
Emergent
Herbicides
Please
refer
to
Item
13
above.
U.
S.
Turf
Page
12
15.
SOD
 
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
TABLE
15.1:
SOD
 
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Iodomethane
(
Methyl
Iodide)
Iodomethane
is
undergoing
registration
reviews
in
the
U.
S.,
but
not
for
use
on
turfgrass
No
Unknown
Potassium
Azide
The
manufacturer
has
not
requested
registration
in
the
U.
S.
No
Unknown
16.
SOD
 
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
TABLE
16.1:
SOD
 
EFFECTIVENESS
OF
ALTERNATIVES
 
NUTSEDGE
(
CYPERUS
SPP.)
IN
FLORIDA
1
%
NusedgeControl2
Site
1
Site
2
Treatment
Rates
Application
Methods
6
WAT3
44
WAT3
3
WAT3
15
WAT3
Methyl
Bromide
+
Chloropicrin
549
kg/
ha
+
11
kg/
ha
Shank
injected
100a
89a
100a
83a
1,3­
D
+
oxadiazon
140
L/
ha
+
168
kg/
ha
Shank
injected
+
surface
broadcast
0f
86ab
0c
74ab
Dazomet
392
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
80abc
57de
78b
58bcd
Dazomet
+
Chloropicrin
392
+
168
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
81ab
63bcd
81b
48cd
Dazomet
+
1,3­
D
392
kg/
ha
+
140
L/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
51de
31f
76b
41d
Metam­
sodium
748
L/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
43e
26f
71b
73ab
Metam­
sodium
+
Chloropicrin
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
+
shank
injected
55cde
38ef
72b
76ab
Metam­
sodium
+
Chloropicrin
tarped
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
+
shank
injected
64b­
e
56de
100a
79ab
Metam­
sodium
+
1,3­
D
748
+
140
L/
ha
Surface
spray
followed
by
rototill
+
shank
injected
69bcd
50def
87ab
70abc
Untreated
Control
0f
0g
0c
0e
LSD
(
0.05)
25
24
17
23
1
Modified
from
Unruh
and
Brecke
(
2001)
and
Unruh
et
al.
(
2002)
2
Numbers
followed
by
the
same
letter(
s)
are
not
significantly
different.
3
Number
of
weeks
after
treatment
U.
S.
Turf
Page
13
TABLE
16.2:
SOD
 
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDY
GRASSES
1
IN
FLORIDA
2
%
Weed
Control3
Site
1
Site
2
Treatment
Rates
Application
Methods
6
WAT3
44
WAT3
3
WAT3
15
WAT3
Methyl
Bromide
+
Chloropicrin
549
kg/
ha
+
11
kg/
ha
Shank
injected
100a
98a
100a
74ab
1,3­
D
+
oxadiazon
140
L/
ha
+
168
kg/
ha
Shank
injected
+
surface
broadcast
0b
53b
13c
71ab
Dazomet
392
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
98a
93a
83b
44cd
Dazomet
+
Chloropicrin
392
+
168
kg/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
96a
93a
91ab
38d
Dazomet
+
1,3­
D
392
kg/
ha
+
140
L/
ha
Surface
broadcast
followed
by
rototill
followed
by
soil
seal
+
shank
injected
100a
95a
90ab
54bcd
Metam­
sodium
748
L/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
98a
88a
87b
65abc
Metam­
sodium
+
Chloropicrin
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
followed
by
soil
seal
+
shank
injected
100a
89a
92a
69abc
Metam­
sodium
+
Chloropicrin
tarped
748
L/
ha
+
168
kg/
ha
Surface
spray
followed
by
rototill
+
shank
injected
100a
94a
100a
70abc
Metam­
sodium
+
1,3­
D
748
+
140
L/
ha
Surface
spray
followed
by
rototill
+
shank
injected
96a
94a
95ab
59a­
d
Untreated
Control
0b
0c
0c
0d
LSD
(
0.05)
35
13
13
27
1
Grass
species
include
coastal
bermudagrass
at
Site
1
and
alexandergrass,
broadleaf
signalgrass,
and
common
bermudagrass
at
Site
2.
2Modified
from
Unruh
and
Brecke
(
2001)
and
Unruh
et
al.
(
2002)
3
Numbers
followed
by
the
same
letter(
s)
are
not
significantly
different.
4
Number
of
weeks
after
treatment
TABLE
C.
1:
SOD
 
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
QUALITY
LOSS
BEST
ESTIMATE
OF
QUALITY
LOSS
1
Dazomet,
alone
or
in
combination
with
chloropicrin
Metam
sodium,
alone
or
in
combination
with
chloropicrin
Weeds,
primarily
off­
type
perennial
grasses;
secondarily,
nutsedge,
nematodes
and
insects
Unable
to
determine
since
research
shows
variability
even
among
MB
treatments,
depending
on
location
of
trials
and
pest
type
Unable
to
determine
since
research
shows
variability
even
among
MB
treatments,
depending
on
location
of
trials
and
pest
type
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
Unable
to
determine
since
research
shows
variability
even
among
MB
treatments,
depending
on
location
of
trials
and
pest
type
However,
in
areas
of
low
to
moderate
pest
pressure,
information
suggests
that
some
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
The
assessment
of
need
was
adjusted
to
account
for
this.
U.
S.
Turf
Page
14
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Metam­
sodium
and
dazomet,
possibly
in
conjunction
with
chloropicrin,
are
likely
effective
alternatives
to
MB
for
turfgrass
sod
production.
Covering
plots
treated
with
metam
sodium
+
chloropicrin
with
plastic
tarpaulin
increased
the
nutsedge
control
effectiveness
of
this
combination
in
southern
Florida,
although
not
in
a
western
Florida
site
(
Unruh
et
al.,
2002).
However,
MB
was
also
variable
in
its
efficacy
depending
on
the
location
and
specific
pests.

18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE
The
turfgrass
producers
claim
that
the
reduction
in
MB,
for
2003,
was
a
result
of
increased
use
of
metam­
sodium.
However,
they
claim
a
loss
of
quality
as
a
result.
Research
indicates
that
metam­
sodium
and
dazomet,
and
chloropicrin
combinations
have
the
potential
to
reduce
the
use
of
MB
in
many
situations.

SUMMARY
OF
TECHNICAL
FEASIBILITY
Research
indicates
that
metam
sodium
and
dazomet
are
the
best
available
alternatives
for
MB
in
turfgrass
sod
production.
Metam
sodium
and
dazomet
applied
alone,
or
in
conjunction
with
chloropicrin,
can
provide
good
control
of
wild
and
off­
type
perennial
grasses
and
broad
leaf
weeds,
but
typically,
fair
to
poor
control
of
nutsedge
(
Unruh
and
Brecke,
2001).
In
research
trials
(
e.
g.,
Unruh
and
Brecke,
2001;
Unruh
et
al.,
2002)
all
of
the
fumigants
that
were
tested,
including
MB,
had
variable
efficacy
depending
on
the
location
of
the
field
trials.
These
studies
indicated
that
in
some
locations
metam­
sodium
+
chloropicrin,
under
polyvinyl
tarp,
can
be
as
effective
as
MB
for
controlling
some
target
weeds.
For
areas
with
nutsedge
infestations,
efficacy
of
MB
varied
depending
on
location,
and
was
superior
in
one
trial
in
Florida
and
comparable
to
metam­
sodium
in
another
(
Unruh
et
al.,
2002).
Farms
with
severe
nutsedge
infestations
are
most
at
risk
for
pest
management
problems
when
using
dazomet
or
metam­
sodium.
U.
S.
Turf
Page
15
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Research
to
examine
tarps
is
ongoing
and
appears
to
improve
efficacy
(
e.
g.,
Landschoot
and
Park,
2004;
Park
and
Landschoot,
2003)
None
identified;
industry
traditionally
has
had
a
high
use
rate
of
MB
None
identified;
industry
traditionally
has
had
a
high
use
rate
of
MB
For
sod
farms,
used
once
in
3
years.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
to
examine
tarps
is
ongoing
and
appears
to
improve
efficacy
(
e.
g.,
Landschoot
and
Park,
2004;
Park
and
Landschoot,
2003)
None
identified;
industry
traditionally
has
had
a
high
use
rate
of
MB
None
identified;
industry
traditionally
has
had
a
high
use
rate
of
MB
For
sod
farms,
used
once
in
3
years.

OTHER
MEASURES
(
please
describe)

20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
The
requesting
consortia
identified
future
plans
for
examining
high
density
polyethylene
as
a
means
to
minimize
MB
emissions.
U.
S.
Turf
Page
16
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD/
QUALITY*
COST
IN
YEAR
1
(
U.
S.$/
ha)
COST
IN
YEAR
2
(
U.
S.$/
ha)
COST
IN
YEAR
3
(
U.
S.$/
ha)

Methyl
Bromide
100%
$
1,235
$
1,235
$
1,235
Dazomet
75%
$
2,964
$
2,964
$
2,964
*
As
percentage
of
typical
or
3­
year
average
yield
and
quality,
compared
to
methyl
bromide.

22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.$/
ha)
Methyl
Bromide
$
19,619
$
10,327
Dazomet
$
14,714
$
3,693
U.
S.
Turf
Page
17
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
METHYL
BROMIDE
DAZOMET
YIELD/
QUALITY
LOSS
(%)
0
25%

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

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

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

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

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

Net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
U.
S.
Turf
Page
18
income
should
be
smaller
than
the
net
revenue
measured
in
this
study.
We
did
not
include
fixed
costs
because
it
is
often
difficult
to
measure
and
verify.

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

To
reflect
a
lower
bound
on
impacts,
under
the
assumption
that
some
areas
covered
by
the
nomination
would
delay
their
shift
in
grass
type,
or
delay
their
control
of
other
key
pests,
the
economic
analysis
used
25%
as
the
yield/
price
effect.
It
is
important
to
recognize
that
in
some
areas,
the
loss
could
be
as
high
as
75%.
Using
the
lower
bound,
we
estimate
that
a
representative
grower
would
suffer
$
6,634
loss
per
hectare
per
year
due
to
inferior
product
and
a
lower
proportion
of
harvestable
acreage,
and
an
increase
of
fumigation
costs
with
dazomet
(
TPI,
2003).
The
loss
as
a
percentage
of
gross
revenue
was
estimated
at
33.81%
and
the
loss
as
a
percentage
of
net
revenue
at
64.24%.
These
changes
are
estimated
to
have
a
significant
economic
impact
to
the
sod
industry.
The
results
suggest
that
dazomet
is
not
economically
viable
as
an
alternative
for
methyl
bromide.
U.
S.
Turf
Page
19
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Metam­
sodium
and
dazomet
already
are
used
in
the
sod
turfgrass
production
industry.
It
has
not
been
determined
how
the
1%
of
total
sod
farm
hectares
that
use
MB
can
further
reduce
its
use.

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

According
to
the
Critical
Use
Exemption
request,
studies
of
high
density
polyethylene
will
be
evaluated.
The
consortium
will
create
a
timeline
for
a
transition
from
MB
to
alternatives.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?
U.
S.
Turf
Page
20
26.
CITATIONS
Dunn,
R.
A.
and
Crow,
W.
T.
2001.
Soil
fumigation
before
planting
turf.
University
of
Florida
IFAS
Extension
Publication
ENY­
26.
http://
edis.
ifas.
ufl.
edu/
IN095.

Unruh,
J.
B.
and
B.
J.
Brecke.
2001.
Seeking
Alternatives
for
Methyl
Bromide.
Golf
Course
Management.
69(
3):
65­
72.
http://
www.
gcsaa.
org/
gcm/
2001/
mar01/
pdfs/
03seeking.
pdf
Unruh,
J.
B.,
B.
J.
Brecke,
J.
A.
Dusky
and
J.
S.
Godbehere.
2002.
Fumigant
Alternatives
for
Replacement
of
Methyl
Bromide
in
Turfgrass.
Weed
Technology,
16:
379­
387,
pp
379­
387.
http://
www.
pw.
ucr.
edu/
textfiles/
methyl%
20bromide­
1.
pdf
U.
S.
Turf
Page
21
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
131,971
1%

2001
&
2002
Average
%
of
2001
&

2002
Average
Requested
%

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

112,143
65,043
76,112
254
300
112,143
65,043
76,112
254
300
84%
90%
89%
82%
38%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
%
adopt
473
300
0
0
0
0
50
29
0
0
0
0
0
0
50%
29%
75%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
No
Yes
Yes
Tarp
Yes
0
No
1
/
3
years
6,634
$
14
$
34%
64%

Conversion
Units:

1
Pound
=
Kilograms
0.404686
Hectare
High
24%
Low
77%

Pest
distribution
estimated
using
tomato
pest
distribution
(
similar
geographic
distribution)
due
to
lack
of
information
provided
by
applicant.

Turfgrass
Producers
International
­
In
2003
the
2002
year
was
reported
as
605,200
lb.,
1513
acres
&
400
lb/
acre.
In
2004
the
2002
year
was
reported
as
1,365,200
lb.,
3413
acres,
400
lb/
acre.
No
explanation
for
increase
so
old
numbers
were
used.

Turfgrass
Producers
International
25%
Dazomet
0.453592
1
Acre
=
Most
Likely
Impact
Value:

Turfgrass
Producers
International
9%

REGION
Quality/
Time/

Market
Window/

Yield
Loss
(%)
Marginal
Strategy
Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
Combined
Impacts
(%)
%
Adopt
New
Fumigants
REGION
%
per
year
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)

Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
(%)
100
ft
Buffer
Zones
64%
64%
82%
89%

%
Reduction
from
Initial
Request
0%
0%
43%
246,468
246,468
123,234
71,476
Nomination
Amount
680,388
680,388
388,041
141,573
­
123,234
71,476
Turfgrass
Producers
International
680,388
­
292,347
Adoption
/
Transition
Adjustment
(
kgs)
MOST
LIKELY
IMPACT
VALUE
REGION
2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
2007
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)
Not
Available
1,928
TOTAL
OR
AVERAGE
680,388
1,416
480
388,041
821
473
0%

388,041
821
473
0%

Turfgrass
Producers
International
680,388
1,416
480
Research
Amount
(
kgs)

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

2007
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Regional
Hectares**

2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Sector:
TURF
%
of
Average
Hectares
Requested:

Methyl
Bromide
Critical
Use
Exemption
Process
Date:
1/
28/
2005
Average
Hectares
in
the
US:
U.
S.
Turf
Page
22
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2007
Amount
of
Request
 
The
2007
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2007
Nomination
Options
 
2007
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2007
Request
 
Subtractions
from
Requested
Amounts,
2007
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2007
request
from
an
applicant's
2002
CUE
application
compared
with
the
2007
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
U.
S.
Turf
Page
23
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2007
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2007
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
U.
S.
Turf
Page
24
32.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
33.
Tarps/
Deep
Injection
Used
 
Because
all
pre­
plant
methyl
bromide
use
in
the
US
is
either
with
tarps
or
by
deep
injection,
this
variable
takes
on
the
value
`
tarp'
when
tarps
are
used
and
`
deep'
when
deep
injection
is
used.
34.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
35.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
36.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
37.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
38.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
39.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
40.
Loss
per
Hectare
 
This
measures
the
total
loss
per
hectare
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
41.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
42.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
43.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
This
item
is
also
called
net
cash
returns.
44.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
45.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
