METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
FOREST
SEEDLINGS
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
Forest
Seedlings
(
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.
Forest
Seedlings
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.
Forest
Seedlings
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY...........................................................................................................................................
9
1.
Nominating
Party
_________________________________________________________
9
2.
Descriptive
Title
of
Nomination______________________________________________
9
3.
Crop
and
Summary
of
Crop
System___________________________________________
9
4.
Methyl
Bromide
Nominated
________________________________________________
10
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
__________________
10
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
11
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
12
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.
______________
12
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?_____________________________________________________________________
13
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
13
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
16
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE..........................................................................................
17
Region
A.
Southern
Forest
Nursery
Management
Cooperative.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________
17
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
11.
(
i)
Characteristics
of
Cropping
System
and
Climate
________________________________________________
17
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
11.
(
ii)
Indicate
if
any
of
the
above
characteristics
in
11.
(
i)
prevent
the
uptake
of
any
relevant
alternatives?
__________
18
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________
19
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
20
Region
B.
International
Paper.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
20
Region
B.
International
Paper.
11.
Characteristics
of
Cropping
System
and
Climate
______
20
Region
B.
International
Paper.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
22
REGION
C.
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.........................................................................................................................
23
Region
C.
Illinois
Department
of
Natural
Resources.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request__________________
23
Region
C.
Illinois
Department
of
Natural
Resources.
11.
Characteristics
of
Cropping
System
and
Climate_______________________________________________________________
23
Region
C.
Illinois
Department
of
Natural
Resources.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________________
24
U.
S.
Forest
Seedlings
iv
REGION
D.
WEYERHAEUSER­
SOUTH.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.....................................................................................................................................................................
25
Region
D.
Weyerhaeuser­
South.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
25
Region
D.
Weyerhaeuser­
South.
11.
Characteristics
of
Cropping
System
and
Climate
____
25
Region
D.
Weyerhaeuser­
South.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
27
REGION
E.
WEYERHAEUSER­
WEST.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE........................
28
Region
E.
Weyerhaeuser­
West.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
28
Region
E.
Weyerhaeuser­
West.
11.
Characteristics
of
Cropping
System
and
Climate
_____
28
Region
E.
Weyerhaeuser­
West.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
29
Region
F.
Weyerhaeuser­
South.
Part
B:
Crop
Characteristics
and
Methyl
Bromide
Use.........................................
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request____
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
11.
Characteristics
of
Cropping
System
and
Climate
________________________________________________
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____________________________________________________
31
REGION
G.
MICHIGAN
SEEDLING
ASSOCIATION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...................................................................................................................................................
33
Region
G.
Michigan
Seedling
Association.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
33
Region
G.
Michigan
Seedling
Association.
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
33
Region
G.
Michigan
Seedling
Association.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
35
REGION
H.
MICHIGAN
HERBACEOUS
PERENNIALS.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE..................................................................................................................................
36
Region
H.
Michigan
Herbaceous
Perennials.
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
36
Region
H.
Michigan
Herbaceous
Perennials.
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
36
Region
H.
Michigan
Herbaceous
Perennials.
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
38
REGIONS
A­
H.
FOREST
SEEDLINGS.
PART
C:
TECHNICAL
VALIDATION
...................................................................
39
Regions
A­
H.
Forest
Seedlings.
13.
Reason
for
Alternatives
Not
Being
Feasible_________
39
Regions
A­
H.
Forest
Seedlings.
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_________________________________________________________________
42
Regions
A­
H.
Forest
Seedlings.
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
43
Regions
A­
H.
Forest
Seedlings.
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________________________________________
44
U.
S.
Forest
Seedlings
v
Regions
A­
H.
Forest
Seedlings.
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
49
Regions
A­
H.
Forest
Seedlings.
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
50
Regions
A­
H.
Forest
Seedlings.
Summary
of
Technical
Feasibility
___________________
51
PART
D:
EMISSION
CONTROL.....................................................................................................................
53
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
53
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
54
PART
E:
ECONOMIC
ASSESSMENT..........................................................................................................................
55
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
55
22.
Gross
and
Net
Revenue___________________________________________________
56
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
57
Summary
of
Economic
Feasibility
_____________________________________________
62
PART
F.
FUTURE
PLANS
........................................................................................................................................
65
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
65
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
66
25.
Additional
Comments
on
the
Nomination
____________________________________
66
26.
Citations
______________________________________________________________
66
APPENDIX
A.
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1.............................................................................................................................
70
U.
S.
Forest
Seedlings
vi
LIST
OF
TABLES
PART
A:
SUMMARY
_________________________________________________________
9
Table
4.1:
Methyl
Bromide
Nominated
___________________________________________
10
Table
A.
1:
Executive
Summary_________________________________________________
11
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
12
Table
8.1.
Region
A
­
Southern
Forest
Nursery
Management
Cooperative:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________
13
Table
8.2.
Region
B
­
International
Paper:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
13
Table
8.3.
Region
C
­
Illinois
Department
of
Natural
Resources:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
_________________________________________________
14
Table
8.4.
Region
D
­
Weyerhaeuser­
South:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
14
Table
8.5.
Region
E
­
Weyerhaeuser­
West:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________________________________________
14
Table
8.6.
Region
F
­
Northeastern
Forest
and
Conservation
Nursery
Association:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________________________________
15
Table
8.7.
Region
G
­
Michigan
Seedling
Association:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________________________
15
Table
8.8.
Region
H
­
Michigan
Herbaceous
Perennials:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________________________________________
15
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________________
17
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________
17
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________
17
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
________________________________________________
18
Region
A
 
Southern
Forest
Nursery
Management
Cooperative
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________________
19
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_________________________________________________________
20
Region
B.
International
Paper.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
20
Region
B.
International
Paper.
Table
11.1:
Characteristics
of
Cropping
System
___________
20
Region
B.
International
Paper.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
____
21
Region
B.
International
Paper.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______
22
Region
C.
Illinois
Department
of
Natural
Resources.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_________________________________________
23
Region
C.
Illinois
Department
of
Natural
Resources.
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________________
23
Region
C.
Illinois
Department
of
Natural
Resources.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule___________________________________________________________
23
U.
S.
Forest
Seedlings
vii
Region
C.
Illinois
Department
of
Natural
Resources.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________________________________________
24
Region
D.
Weyerhaeuser­
South.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
25
Region
D.
Weyerhaeuser­
South.
Table
11.1:
Characteristics
of
Cropping
System__________
25
Region
D.
Weyerhaeuser­
South.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
__
26
Region
D.
Weyerhaeuser­
South.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide_____
27
Region
E.
Weyerhaeuser­
West.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
28
Region
E.
Weyerhaeuser­
West.
Table
11.1:
Characteristics
of
Cropping
System___________
28
Region
E.
Weyerhaeuser­
West.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___
28
Region
E.
Weyerhaeuser­
West.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____
29
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____________________________
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
11.1:
Characteristics
of
Cropping
System
__________________________________________
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
______________________________________________
30
Region
F.
Northeastern
Forest
and
Conservation
Nursery
Association.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________
32
Region
G.
Michigan
Seedling
Association.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__________________________________________________
33
Region
G.
Michigan
Seedling
Association.
Table
11.1:
Characteristics
of
Cropping
System__
33
Region
G.
Michigan
Seedling
Association.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
34
Region
G.
Michigan
Seedling
Association.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
35
Region
H.
Michigan
Herbaceous
Perennials.
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_______________________________________________
36
Region
H.
Michigan
Herbaceous
Perennials.
Table
11.1:
Characteristics
of
Cropping
System
36
Region
H.
Michigan
Herbaceous
Perennials.
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
37
Region
H.
Michigan
Herbaceous
Perennials.
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
38
Regions
A­
H.
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
__________________
39
Regions
A­
H.
Forest
Seedlings.
Table
14.1:
Technically
Infeasible
Alternatives
Discussion__
43
Regions
A­
H.
Forest
Seedlings.
Table
15.1:
Present
Registration
Status
of
Alternatives
_____
43
Regions
A­
H.
Forest
Seedlings.
Table
16.1.
A:
Effectiveness
of
Alternatives 
Weeds
_______
44
Regions
A­
H.
Forest
Seedlings.
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________
49
PART
D:
EMISSION
CONTROL_______________________________________________
53
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
54
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
55
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
55
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
56
Region
A
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
57
U.
S.
Forest
Seedlings
viii
Region
B
­
International
Paper
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
58
Region
C
­
Illinois
Department
of
Natural
Resources
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________
59
Region
d
­
Weyerhaeuser
South
­
Table
E.
4:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
59
Region
E
­
Weyerhaeuser
West
­
Table
E.
5:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________________________________________________________________
60
Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
­
Table
E.
6:
Economic
Impacts
of
Methyl
Bromide
Alternatives
______________________________________
61
Region
G
­
Michigan
Seedling
Association
­
Table
E.
7:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
62
Region
H
­
Michigan
Herbaceous
Perennials
­
Table
E.
8:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
62
PART
F.
FUTURE
PLANS
________________________________________________________
65
APPENDIX
B.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
_________________
72
U.
S.
Forest
Seedlings
Page
9
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
(
MB)
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Forest
Seedlings
(
Prepared
in
2005)

3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
The
Forest
Seedling
sector
in
the
U.
S.
supplies
conifer
and
hardwood
seedlings
that
are
used
for
reforestation,
forest
establishment,
fiber
production,
and
wildlife
and
conservation
uses.
In
a
survey
conducted
in
2001­
2002
(
Southern
Forest
Nursery
Management
Cooperative,
Appendix
1
of
their
request),
there
were
1.7
billion
pine
seedlings
produced
in
the
southern
region
of
the
U.
S.,
which
accounts
for
80%
of
U.
S.
pine
seedling
production.
Nurseries
in
the
U.
S.
are
located
in
eight
climate
zones
(
Zones
3
to
10)
mostly
with
light
or
medium
soils.
The
majority
of
seedlings
are
species
of
conifers,
especially
pine.
In
addition,
30­
60
species
of
hardwoods,
such
as
oaks,
hickory,
poplars,
and
ash,
are
produced.
Nurseries
produce
seedlings
adapted
to
their
respective
regional
conditions,
such
as
climate
and
soil
type.
Overall,
forest
seedling
nurseries
include
those
operated
by
private
forest
industry,
state
and
federal
governments,
and
non­
industry
private
concerns.

Nurseries
produce
conifer
seedlings
that
are
typically
grown
for
one
or
two
years
in
seedling
beds
followed
by
one
or
two
years
fallow
or
cover
crops.
Therefore,
managers
typically
fumigate
a
particular
conifer
seedling
bed
with
MB
only
once
every
3­
4
years,
i.
e.,
only
1/
3­
1/
4
of
the
total
nursery
land
is
fumigated
each
year
to
produce
two
or
three
harvestable
forest
seedling
crops
per
single
bed
fumigation.
Effective
fumigants
such
as
MB
permit
less
frequent
bed
fumigation
per
harvestable
seedling
crop.
For
hardwood
seedlings,
fumigation
is
usually
provided
prior
to
each
seedling
crop,
as
hardwood
species
are
generally
more
prone
than
conifers
to
root
rots
and
damping­
off
diseases.

Upon
maturity,
forest
seedlings
are
harvested
in
the
nursery,
packaged,
and
transported
to
the
planting
site.
Seedlings
may
or
may
not
be
culled
or
sized
during
harvesting
process,
with
cull
trees
discarded
and
typically
recycled
into
nursery
soil.
Those
nurseries
that
grade
their
seedlings
into
number
1
and
number
2
grades
can
sell
them
at
a
price
differential.
The
impact
of
seedling
quality,
particularly
seedling
size,
on
the
success
of
the
plantation
establishment
process
cannot
be
overstated.
The
production
of
large
and
healthy
planting
stock
is
essential
to
the
economic
viability
of
reforestation
processes.
These
typically
include
soil
preparation
at
the
planting
site,
transportation
to
the
planting
site,
planting,
and
weed
control
after
planting.
The
quality
of
seedlings
is
strongly
correlated
with
the
success
of
the
regeneration
process
and
corresponding
long­
term
economic
and
use
benefits
where
a
higher
quality
seedling
implies
better
survival
and
faster
growth.
Nursery
soil
fumigation
is
the
backbone
of
an
integrated
pest
U.
S.
Forest
Seedlings
Page
10
management
approach
to
produce
healthy
seedlings
that
is
the
foundation
for
economically
viable
plantation
establishment
and
management.

Perennial
herbaceous
nurseries
are
also
requesting
MB
and
are
included
in
this
sector.
Growers
require
MB
to
control
nematode
and
weeds.
This
industry
has
adopted
alternative
pest
management
strategies
for
a
portion
of
the
646
ha
of
requested
land,
and
they
are
conducting
trials
to
assess
the
efficacy
of
alternatives.

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

2007
152,629
506
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.
In
addition,
because
of
MB
efficacy,
in
many
nurseries,
up
to
three
seedling
crops
can
be
grown
with
each
MB
application 
generally
applied
only
once
in
four
years.
Alternative
treatments
may
require
more
frequent
applications
and
increase
costs
and
environmental
pesticide
burden.
There
also
have
been
significant
outgassing
incidents
that
resulted
in
destruction
of
millions
of
nursery
seedlings
(
as
described
in
the
request
by
International
Paper).
Because
of
the
importance
placed
on
seedling
quality
(
due
to
the
high
correlation
of
quality
and
subsequent
forest
health
and
value),
failure
to
achieve
consistently
healthy
seedlings
in
even
a
fraction
of
the
production
beds
can
have
a
devastating
effect
on
this
sector's
ability
to
provide
acceptable
seedlings
for
reforestation.
Research
is
ongoing
to
develop
protocols
for
likely
alternatives,
such
as
1,3­
D
and
metam­
sodium.
Completion
of
long
term
field
trials
will
help
to
translate
new
and
effective
methodologies
to
nurseries
in
order
to
meet
their
production
goals
without
MB.
Consortia
are
currently
developing
timelines
to
describe
the
transition
to
alternatives
for
their
nurseries.

Forest
nurseries
throughout
the
U.
S.
must
contend
with
a
variety
of
pests,
but
effective
fumigation
is
primarily
relied
on
to
manage
fungal
pathogens
(
e.
g.,
Fusarium,
Alternaria,
Phytophthora,
Pythium,
Rhizoctonia,
Cylindrocladium
spp.,
and
Macrophomina)
and
especially,
yellow
and
purple
nutsedges
(
species
of
the
Cyperus
weed)
(
Cram
and
Fraedrich,
1997).
Nutsedges
are
generally
considered
the
major
pests
of
all
forest
seedling
nurseries
and
the
pests
most
difficult
to
manage.

Currently,
inconsistency
in
pest
management
performance
by
alternatives
is
the
primary
concern
for
this
sector,
and
the
reason
that
MB
is
currently
critical
for
maintaining
high
quality
seedlings.
U.
S.
Forest
Seedlings
Page
11
While
direct
yield
losses,
in
terms
of
seedlings/
hectare,
were
not
very
large
on
average,
intensive
seedling
production
relies
on
the
ability
of
nursery
managers
to
meet
quality,
as
well
as
yield,
goals.
In
addition,
economic
issues
such
as
increased
application
costs
(
e.
g.,
costs
associated
with
application
of
metam­
sodium
and
a
separate
chloropicrin
application)
may
have
an
impact
on
overall
feasibility
of
these
alternatives
for
the
forest
seedlings
sector.
As
experience
is
gained
with
alternative
treatments,
transition
to
these
alternatives
should
accelerate.
The
requesting
consortia
are
developing
timelines
that
should
help
determine
how
the
transition
from
MB
will
be
achieved.

TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
FOREST
SEEDLINGS*
A.
B.
C.
D.
E.
F.
G.
H.

REGION
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
INTERNATIONAL
PAPER
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
WEYERHAEUSER
SOUTH
WEYERHAEUSER
WEST
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOC
MICHIGAN
SEEDLING
ASSOCIATION
MICHIGAN
HERBACEOUS
PERENNIALS
AMOUNT
OF
APPLICANT
REQUEST
Kilograms
(
kg)
246,032
26,3806
4,264
17,962
16,935
31,922
6,908
4,763
AMOUNT
OF
NOMINATION
Kilograms
(
kg)
83,143
22,279
1,911
11,226
9,637
13,279
6,908
4,246
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Alternatives
to
MB
are
currently
problematic
for
optimal
seedling
production
because
of
their
inconsistent
performance
from
season
to
season,
for
nurseries
with
moderate
to
high
pest
(
especially
weed)
pressure
(
e.
g.,
Fraedrich
and
Dwinell,
2003a,
2003b,
2003c;
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96).
While
chemicals
such
as
chloropicrin,
metam­
sodium,
dazomet,
herbicides,
or
1,3­
D
can
be
effective
in
some
situations
in
reducing
pest
infestations,
including
weed
problems,
inconsistency
in
pest
management
by
chemical
alternatives
is
the
primary
concern
for
this
sector,
and
the
reason
that
MB
is
currently
critical
for
maintaining
high
quality
seedlings.
For
example,
Fraedrich
and
Dwinell
(
2003b)
found
that
dazomet
had
some
efficacy
against
nutsedge
in
field
trials
one
year
in
two
southern
nurseries.
But
in
one
of
the
nurseries
in
Georgia,
nutsedge
plant
populations
increased
over
the
course
of
the
summer.
They
cautioned
that
" [
i]
f
dazomet
is
to
be
used
for
nutsedge
control,
additional
efforts
will
be
necessary
to
better
define
the
optimal
use
conditions".
Fraedrich
and
Dwinell
(
2003c)
also
conducted
studies
with
glyphosate
as
a
possible
control
for
nutsedge.
Two
years
of
study
suggested
that
glyphosate
in
broadcast
treatments
might
be
a
feasible
treatment.
However,
again,
an
integrated
system
of
pest
management
must
first
be
developed
for
acceptable
control
to
occur.

Research
studies
with
organic
and
inorganic
soil
amendments
(
Fraedrich
and
Dwinell,
1998;
James
et
al.,
1997;
James
et
al.,
2001;
Lantz,
1997;
Stone
et
al.,
1998)
have
observed
some
reduction
in
reducing
populations
of
certain
pathogens,
but
the
effects
appear
to
be
variable
depending
on
the
nursery
locations
and
species
of
seedlings,
and
it
is
unclear
if
the
pathogen
U.
S.
Forest
Seedlings
Page
12
population
is
correlated
with
disease
incidence.
More
research
is
required
before
there
can
be
commercial
application
of
these
methods
as
independent
treatments.

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
IN
2002
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
IN
2002
(%)
A.
Southern
Forest
Nursery
Management
Cooperative
Not
available
Not
available
B.
International
Paper
Not
available
Not
available
C.
Illinois
Dept
of
Natural
Resources
Not
available
Not
available
D.
Weyerhaeuser­
South
Not
available
Not
available
E.
Weyerhaeuser­
West
Not
available
Not
available
F.
Northeastern
Forest
and
Conservation
Nursery
Association
Not
available
Not
available
G.
Michigan
Seedling
Association
Not
available
Not
available
H.
Michigan
Herbaceous
Perennials
Not
available
Not
available
NATIONAL
TOTAL**:
51,506
2%
*
Typically,
only
a
fraction
of
a
nursery's
beds
are
fumigated
in
a
given
year.
**
National
average
may
include
states
not
requesting
methyl
bromide.

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.

Alternatives
such
as
metam­
sodium,
chloropicrin,
dazomet
are
used
in
possibly
half
of
nursery
hectares,
especially
those
without
severe
nutsedge
problems.
Where
soil
types
and
temperatures
are
conducive,
and
especially
where
pest
pressure
is
not
high,
these
alternatives
can
be
effective.
This
nomination,
however,
only
applies
to
those
nurseries
where
alternatives
are
not
effective.
MB
allows
beds
to
be
fumigated
after
two
or
three
crops
(
as
opposed
to
after
every
crop)
because
of
the
effectiveness
of
MB,
which
usually
makes
a
second
year
treatment
unnecessary.
Moreover,
during
the
subsequent
two
years
an
unfumigated
cover
crop
is
planted
for
the
purposes
of
soil
organic
matter
maintenance.
With
severe
infestation
of
pests,
to
be
effective,
alternative
products
require
fumigation
more
often,
and
consequently,
higher
management
costs
can
be
incurred.
U.
S.
Forest
Seedlings
Page
13
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?

The
use
of
alternative
methods
requires
further
research
to
establish
viable
alternatives
that
provide
the
same
benefits
as
MB.
Currently,
all
members
of
these
consortia
are
conducting
research
to
find
effective
alternatives.
Within
the
next
few
years
there
will
be
considerable
empirical
evidence
as
to
the
effectiveness
of
MB
alternatives
that
will
be
feasible
for
this
sector.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1.
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
246,032
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
656
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
37.5
TABLE
8.2.
REGION
B
­
INTERNATIONAL
PAPER:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
26,436
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
126
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
210
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
21
U.
S.
Forest
Seedlings
Page
14
TABLE
8.3.
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
4,268
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
16
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
267
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
26.7
TABLE
8.4.
REGION
D
­
WEYERHAEUSER­
SOUTH:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
17,962
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
90:
10
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
53
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
336
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
33.6
TABLE
8.5.
REGION
E
­
WEYERHAEUSER­
WEST:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
16,951
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
75
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
226
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
22.6
U.
S.
Forest
Seedlings
Page
15
TABLE
8.6.
REGION
F
­
NORTHEASTERN
FOREST
AND
CONSERVATION
NURSERY
ASSOCIATION:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
31,950
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
92
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
347
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
34.7
TABLE
8.7.
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
6,914
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
26
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
266
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
26.6
TABLE
8.8.
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
MB
4,767
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
flat
fumigation
FORMULATION
(
ratio
of
MB/
Pic
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
MB
OR
MB/
PIC
FORMULATION
(
ha)
12
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
ACTIVE
INGREDIENT
397
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
MB
39.7
U.
S.
Forest
Seedlings
Page
16
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
MB
nominated
by
the
U.
S.
was
calculated
as
follows:

 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop.
No
adjustment
was
made
for
this
sector.
 
Hectares
counted
in
more
than
one
application,
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
MB,
were
subtracted.
The
double
counted
hectares
were
removed.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
five
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
were
removed
from
each
applicant's
request.
 
Only
the
hectares
with
moderate
to
heavy
key
pest
pressure
were
included
in
the
nominated
amount.
U.
S.
Forest
Seedlings
Page
17
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi
[
100%
at
times]:
Fusarium,
Macrophomina,
Rhizoctonia,
Pythium,
Phytophthora;
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Weeds
[
100%
at
times]:
broadleaf,
grasses,
sedges
For
areas
where
pest
pressure
is
high,
MB
allows
three
successive
seedling
crops
with
only
one
fumigation
treatment
(
one
treatment
every
four
years).
Alternative
treatments
will
require
more
frequent
fumigation
due
to
reduced
efficacy
until
protocols
are
developed
to
improve
efficacy.

REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Bareroot
forest
seedlings
(
91­
96%
pine,
4­
9%
hardwood
species)
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
1
year
for
each
of
three
crops
before
fumigation
on
fourth
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
MB
is
used
only
for
seedling
crop
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
(
85%);
medium
(
15%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Typically,
fumigated
once
in
4
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
U.
S.
Forest
Seedlings
Page
18
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
7a,
7b,
8a,
8b
(
nurseries
in:
Alabama,
Arkansas,
Florida,
Georgia,
Louisiana,
Mississippi,
North
Carolina,
Oklahoma,
South
Carolina,
Tennessee,
Texas,
Virginia)

RAINFALL
a
(
mm)
125
128
155
135
91
100
141
118
76
52
87
131
OUTSIDE
TEMP.
(
°
C)
7.7
10.0
13.9
18.3
22.2
26.1
27.2
27.2
25.0
18.9
13.9
10.0
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
b
2nd
3rd
4th
years
aThe
rainfall
and
temperature
data
are
for
Alabama,
which
may
be
considered
typical
of
the
region.
bFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.

REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
typically
occurs
only
once
in
a
four
year
cycle.
Therefore,
typically,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
may
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
U.
S.
Forest
Seedlings
Page
19
REGION
A
 
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000a
2001
a
2002
a
2003
a
AREA
TREATED
(
hectares)
not
available
not
available
656
656
656
656
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
not
available
not
available
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
not
available
not
available
246,032
246,032
246,032
246,032
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
not
available
not
available
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
)
not
available
not
available
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
not
available
not
available
375
375
375
375
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
not
available
not
available
37.5
37.5
37.5
37.5
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
aData
are
based
on
a
survey
of
consortium
members
in
2000.
Consortium
does
not
keep
records
of
seedling
production
data
but
assumes
that
use
rates
and
production
information
do
not
vary
significantly
from
year
to
year.
U.
S.
Forest
Seedlings
Page
20
REGION
B
­
INTERNATIONAL
PAPER
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
B
­
INTERNATIONAL
PAPER
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
B
­
INTERNATIONAL
PAPER
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi:
Rhizoctonia
(
root
rot);

International
Paper
Weeds:
Cyperus
esculentus/
rotundus
(
purple/
yellow
nutsedge)
For
areas
where
pest
pressure
is
high,
MB
allows
two
successive
seedling
crops
with
only
one
fumigation
treatment
(
one
treatment
every
four
years).
Alternative
treatments
will
require
more
frequent
fumigation
due
to
reduced
efficacy
until
protocols
are
developed
to
improve
efficacy.

REGION
B
­
INTERNATIONAL
PAPER
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
B
 
INTERNATIONAL
PAPER
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
INTERNATIONAL
PAPER
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Forest
seedlings
(
all
pine
species)
and
some
hardwoods
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
each
of
two
years
followed
by
two
years
of
unfumigated
cover
crops
before
fumigation
in
the
fourth
year
just
before
sowing
the
first
seedling
crop
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.)
Light,
medium,
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
four
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
U.
S.
Forest
Seedlings
Page
21
REGION
B
 
INTERNATIONAL
PAPER
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
6b,
7a,
7b,
8a,
8b
(
Alabama,
Arkansas,
Georgia,
South
Carolina,
Texas)

RAINFALL
(
mm)
Not
available,
but
varies
with
diverse
climates
OUTSIDE
TEMP.
(
°
C)
Not
available,
but
varies
with
diverse
climates
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
a
2nd
3rd
4th
years
aFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.

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

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
four
year
cycle.
Therefore,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
may
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
In
addition,
it
is
estimated
(
Dr.
George
Lowerts,
International
Paper,
personal
communication)
that
typically,
a
10­
day
delay
would
be
incurred
with
alternative
treatments
such
as
1,3­
D
to
avoid
phytotoxic
effects.
U.
S.
Forest
Seedlings
Page
22
REGION
B
­
INTERNATIONAL
PAPER
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
B
­
INTERNATIONAL
PAPER
­
TABLE
12.1
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)
88
185
121
114
101
128
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
32,580
68,975
43,646
38,666
34,853
49,987
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
371
374
362
338
345
390
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
37.1
37.4
36.2
33.8
34.5
39.0
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
23
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fusarium
spp.

weeds
Illinois
Department
of
Natural
Resources
nematodes
Consistency
in
production
for
the
variety
of
nursery
plants
grown
in
small
public
nursery.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Hardwood
seedlings
(
13
ha);
shrubs
(
2
ha);
prairie
forbs
(
1
ha)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
1
or
2
years
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.)
Light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
every
year
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
5b,
6b
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
U.
S.
Forest
Seedlings
Page
24
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

For
this
small,
public
consortium,
fumigation
in
the
fall
followed
by
planting
is
the
most
effective
means
of
meeting
production
goals.
Alternatives
will
require
delays
due
to
increased
labor
costs
for
hand
weeding,
and
potential
outgassing
damage
to
already
planted
beds.

REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
12.1
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)
15
17
16
13
16
15
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
5,757
4,370
4,211
3,411
4,232
3,873
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
384
263
263
263
263
263
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
38.4
26.3
26.3
26.3
26.3
26.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
25
REGION
D
­
WEYERHAEUSER­
SOUTH
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
D
­
WEYERHAEUSER­
SOUTH
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi:
Fusarium,
Pythium,
Rhizoctonia;

WEYERHAEUSERSOUTH
Weeds:
Cyperus
(
nutsedges)
Only
#
1
grade
seedlings
are
sold;
grade
#
2
and
culls
are
discarded.
To
economically
manage
the
range
of
pests
(
where
infestation
of
fungal
pathogens
and
nutsedges
is
severe),
MB
is
necessary
since
no
alternatives
currently
provide
both
reliable
control
and
economic
sustainability
for
#
1
grade
seedlings.

REGION
D
­
WEYERHAEUSER­
SOUTH
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
WEYERHAEUSER­
SOUTH
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Primarily
loblolly
pine;
some
hardwood
species
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
grown
for
1
year
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.)
Light
(
62%);
Medium
(
22%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
four
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
U.
S.
Forest
Seedlings
Page
26
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
7b,
8a
(
includes
Alabama,
Arkansas,
North
Carolina,
and
South
Carolina)

RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
1st
year
PLANTING
SCHEDULE
a
2nd
3rd
4th
years
aFumigation
occurs
only
once
in
four
years
after
three
successive,
one
year
old
seedlings
are
harvested.

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

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
four
year
cycle.
Therefore,
three
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.
U.
S.
Forest
Seedlings
Page
27
REGION
D
­
WEYERHAEUSER­
SOUTH
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
D
­
WEYERHAEUSER­
SOUTH
­
TABLE
12.1
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)
64
72
66
61
64
65
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
kg)
25,935
29,649
21,516
21,709
24,231
26,102
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
90:
10
90:
10
90:
10
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
405
412
327
355
379
403
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
40.5
41.2
32.7
35.5
37.9
40.3
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
28
REGION
E
­
WEYERHAEUSER­
WEST
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
E
­
WEYERHAEUSER­
WEST
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi
[
100%
at
times]:
Pythium
(
damping­
off,
root
rot),
Fusarium
(
damping­
off,
root
rot),
Phoma,
Fusarium,
Botrytis
(
stem
cankers);
Weyerhaeuser­
West
Weeds:
Cyperus
(
yellow
nutsedge)
[
100%
at
times]
High
pathogen
populations
and
potential
for
contamination
with
Phytophthora
ramorum
(
sudden
oak
death)
leave
little
room
for
production
variability.

REGION
E
­
WEYERHAEUSER­
WEST
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
WEYERHAEUSER­
WEST
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pine,
Christmas
trees,
some
hardwoods
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Typically
one
year
seedling
bed,
one
year
transplant
bed;
transplants
can
be
grown
for
2,
3,
or
4
years
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.)
Light
(
60%),
Medium
(
40%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
once
in
3
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
8a,
8b
(
includes
Washington
and
western
Oregon)

RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
1st
year
PLANTING
SCHEDULE
2nd
3rd
aTypically
fumigation
occurs
only
once
in
three
years
after
two
successive,
one
year
old
seedlings
are
harvested.
U.
S.
Forest
Seedlings
Page
29
REGION
E
­
WEYERHAEUSER­
WEST
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
two
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Alternatives
will
require
fumigation
(
with
1,3­
D
+
chloropicrin,
for
example)
prior
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.

REGION
E
­
WEYERHAEUSER­
WEST
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
E
­
WEYERHAEUSER­
WEST
­
TABLE
12.1
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)
47
43
70
65
69
75
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
12,296
11,360
17,864
17,125
14,647
16,951
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
263
263
255
263
211
226
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
26.3
26.3
25.5
26.3
21.1
22.6
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
30
Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
­
Part
B:
Crop
Characteristics
and
Methyl
Bromide
Use
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Fungi:
Phytophthora
(
damping­
off,
root
rot)
[
80%],
Fusarium
(
damping­
off,
root
rot)
[
80%],
Cylindrocladium
[
50%];
Northeastern
Forest
&
Conservation
Nursery
Association
Weeds:
Cyperus
(
yellow
nutsedge)
[
40%],
Cirsium
(
Canada
thistle)
[
70%]
In
humid,
warm
conditions
damping­
off
is
a
significant
problem;
as
with
much
of
industry,
weed
problems,
especially
nutsedge
and
Canada
thistle,
are
difficult
to
manage
without
MB.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
NORTHEASTERN
FOREST
AND
CONSERVATION
NURSERY
ASSOCIATION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Conifers
(
10­
15
spp.)=
1­
yr,
8%;
2­
yr,
4%;
3­
yr,
14%;
hardwoods
(
30­
50
spp.)=
1­
yr,
55%;
2­
yr,
9%;
shrubs
and
forbs
(>
75
spp.)=
10%

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Bareroot
cuttings,
and
transplants,
typically
grown
1­
3
years
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.)
Light,
Medium
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
typically
once
in
2­
3
year
rotation,
depending
on
species
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
3a,
4b,
5a,
5b,
6a,
6b,
7a
(
includes
state­
owned
nurseries
in
Illinois,
Indiana,
Kentucky,
Maryland,
Missouri,
New
Jersey,
Ohio,
Pennsylvania,
West
Virginia,
and
Wisconsin)

RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
X
PLANTING
SCHEDULE
a
X
X
X
X
X
X
aDue
to
the
large
number
of
species
and
wide
geographical
area
represented
in
this
consortium,
seedlings
can
be
U.
S.
Forest
Seedlings
Page
31
planted
at
various
times
in
the
fall
or
spring.
Generally,
fumigation
occurs
once
in
two
or
three
years,
but
beds
for
certain
hardwood
species
may
be
treated
every
year.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Because
of
MB
efficacy,
fumigation
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
two
successive
annual
seedling
crops
are
produced
for
each
fumigation
event.
Until
effective
combination
treatments
can
be
devised,
alternatives
(
e.
g.,
dazomet)
will
require
application
to
each
crop,
increasing
significantly
the
costs
and
environmental
burden.

REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
Variation
in
MB
use
is
due
to
changes
in
products,
and
may
be
determined
by
market
demand
and/
or
availability
of
seed.
Changes
in
product
will
affect
area
planted
(
and
therefore
treated).
For
example,
hardwoods
are
grown
at
densities
of
only
65­
130
seedlings/
m2,
while
conifer
seedlings
are
grown
at
densities
of
215­
320
seedlings/
m2.
Changes
in
the
proportion
of
hardwood
and
pine
seedlings,
therefore,
will
affect
the
area
requiring
fumigation.
U.
S.
Forest
Seedlings
Page
32
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
12.1
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)
98
91
87
80
72
86
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
34,997
31,961
28,308
26,844
26,273
30,863
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
357
352
326
337
363
359
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
35.7
35.2
32.6
33.7
36.3
363
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
33
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Michigan
Seedling
Association
Primarily
annual
and
perennial
weeds
(
e.
g.,
nutsedge,
Canada
thistle);
also,
fungal
pathogens;
nematodes
Nutsedge
(
50%
of
area),
common
groundsel
(
95%
of
area),
hairy
bittercress
(
60%
of
area),
Canada
thistle
(
25%
of
area),
and
mugwort
(
20%
of
area);
Soil­
borne
diseases
are
also
of
concern;
dazomet
and
metam­
sodium
are
not
reliable
in
this
region
because
of
cooler
soil
temperatures.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
SEEDLING
ASSOCIATION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Conifers,
hardwoods
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Conifers:
bareroot
and
transplants,
typically
1,
2,
or
3
years
growth;
Hardwood:
1­
year
(
80%)
and
2­
year
(
20%)
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.)
Light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Fumigation
every
3­
4
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified.
U.
S.
Forest
Seedlings
Page
34
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
4b,
5a,
5b
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
(
sometimes)
Spring
(
usually)
Fall
(
usually)
Fall
PLANTING
SCHEDULE
for
conifers,
after
Fall
fumigation
for
hardwoods,
after
Fall
fumigation
aFumigation
schedules
depend
on
growth
as
annual
seedlings
or
additional
bed
requirements
as
transplants.
Generally,
fumigation
occurs
once
in
two
or
three
years,
but
beds
for
certain
hardwood
species
may
be
treated
every
year.

REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Michigan
Seedling
Association
working
with
Michigan
State
University
is
in
the
midst
of
conducting
research
(
with
grants
from
USDA
MB
Alternatives
program)
to
assess
the
efficacy
of
alternatives
with
an
economic
survey
conducted
to
define
costs
associated
with
alternatives.
Results
of
this
research
that
will
be
available
in
2006­
2007,
should
help
identify
true
alternatives
to
MB.
Until
this
time,
MB
is
critical
for
the
continuation
of
this
industry.
Because
of
MB
efficacy,
fumigation
generally
occurs
only
once
in
a
three
year
cycle.
Therefore,
typically,
successive
crops
are
produced
for
each
fumigation
event.
U.
S.
Forest
Seedlings
Page
35
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
12.1
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)
55
46
51
34
34
35
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
14,914
12,301
13,825
8,954
8,954
9,501
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
shank
injected
w/
tarp
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
269
269
269
263
263
271
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
26.9
26.9
26.9
26.3
26.3
27.1
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
36
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
MICHIGAN
Herbaceous
Perennials
Nematodes:
Meloidogyne
hapla,
Pratylenchus
spp.,
Ditylenchus
spp.;
Fungi:
Pythium
(
damping­
off,
root
rot),
Fusarium
(
damping­
off,
root
rot),
Phytophthora,
Rhizoctonia;
Weeds:
Cyperus
esculentus
(
yellow
nutsedge),
Inula
brittanica,
Oxalis
stricta,
Cirsium
arvense,
Rorippa
sylvestris
Research
for
effective
alternative
to
MB
is
ongoing
with
USDA
supported
research
due
to
be
analyzed
and
reported
after
2006
studies
end.
Until
field­
tested
alternatives
can
be
identified
and
protocols
developed
for
them,
MB
will
be
critical
to
pest
management
for
this
industry.

REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
HERBACEOUS
PERENNIALS
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Ornamental
herbaceous
perennials
(
e.
g.,
Delphinium,
Hosta,
Phlox)

ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Perennial:
2­
year
seeded
(
6%
of
treated
area)
and
2­
year
transplants
(
29%
of
treated
area)
are
on
a
2
year
replant/
fumigation
cycle;
3­
year
transplants
(
65%
of
treated
area)
are
on
a
3
year
replant/
fumigation
cycle
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.)
Various,
light
to
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Once
in
2
to
3
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
identified.
U.
S.
Forest
Seedlings
Page
37
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
Year
1
of
two­
year
cycle.

Year
1
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
5a,
5b,
6a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
2­
year
transplants
2­
year
seedlings;
3­
year
transplants
PLANTING
SCHEDULE
2­
year
transplants
3­
year
transplants
3­
year
transplants
Year
2
of
two­
year
cycle.

Year
1
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
zones
5a,
5b,
6a
RAINFALL
(
mm)
Not
available
OUTSIDE
TEMP.
(
°
C)
Not
available
FUMIGATION
SCHEDULE
a
PLANTING
SCHEDULE
2­
year
seedlings
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Long
term
research
results
are
to
be
compiled
and
analyzed
in
2006­
2007,
to
assess
the
efficacy
of
alternatives.
In
addition,
the
consortium
is
developing
timelines
to
determine
a
strategy
to
transition
from
MB.
Fumigation
schedule
with
MB
is
based
on
the
effectiveness
in
managing
the
numerous
pests.
With
alternatives,
fumigation
will
likely
have
to
be
increased
and
timing
of
seedling
and
transplant
production
will
be
affected.
Consequently,
the
ongoing
research
program
must
be
completed
to
address
implementation
of
production
processes
with
newly
identified
alternatives.
U.
S.
Forest
Seedlings
Page
38
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
12.1
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)
258
248
228
129
128
108
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
kg)
101,.
287
97,477
89,539
50,485
51,068
41,190
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide:
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
injected
injected
injected
injected
injected
injected
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
392
392
392
392
392
381
ACTUAL
DOSAGE
RATE
[
ACTIVE
INGREDIENT]
(
g/
m2)*
39.2
39.2
39.2
39.2
39.2
38.1
*
For
flat
fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
U.
S.
Forest
Seedlings
Page
39
PART
C:
TECHNICAL
VALIDATION
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
CHEMICAL
ALTERNATIVES:
ALSO,
SEE
SECTION
14
FOR
ADDITIONAL
CHEMICALS
NOT
LISTED
BY
MBTOC.

Dazomet
(
400
kg/
ha)
Inconsistent
results
with
weeds,
especially
w/
moderate
to
high
weed
pressure.
Does
not
consistently
provide
acceptable
levels
of
nutsedge
control,
nor
does
it
manage
some
diseases
associated
with
fungal
pathogens
(
root
rot
and
damping­
off
pathogens).
Most
effective
use
will
probably
be
incorporated
with
other
methods,
but
protocols
must
be
developed
(
Fraedrich
and
Dwinell,
2003b).
Field
trials
show
that
seedling
size
(
diameter
and
height)
and
root
volume
were
inconsistent,
non­
uniform,
and
reduced
with
dazomet,
leading
to
higher
counts
of
Grade
#
2
seedlings
and
culls
compared
to
greater
numbers
of
Grade
#
1
seedlings
with
MB.
Reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
dazomet
has
resulted
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Soil
temperature
requirements
(
above
6
°
C/
optimal
12­
18
°
C)
of
dazomet,
due
to
vapor
pressure
properties,
constrains
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989);
(
Fraedrich
and
Dwinell,
2003b;
Campbell
and
Kelpsas,
1988;
Carey,
1996;
Carey,
1994;
Enebak
et
al.,
1990;
Weyerhaeuser,
#
3,
1984­
87;
Weyerhaeuser,
#
4,
1985­
87;
Weyerhaeuser,
#
6,
1992;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
9,
1994­
95;
Weyerhaeuser,
#
10,
1994­
96)
No
U.
S.
Forest
Seedlings
Page
40
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam­
sodium
(
485
kg/
ha)
Inconsistent
results
with
weeds,
especially
w/
high
weed
pressure.
Average
yield
losses
are
estimated
to
be
approximately
5%
with
metam­
sodium,
although
the
addition
of
other
pesticides
to
provide
broader
control
could
reduce
losses.
As
with
dazomet,
reduced
efficacy
requires
production
cycle
compensation
by
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period
in
order
to
obtain
better
control
of
weeds
and
other
pests.
These
strategies
result
in
reduced
seedling
production.
As
with
dazomet,
seedling
quality
is
inconsistent
resulting
in
less
predictable
seedling
production
factors.
Damage
to
seedlings
growing
adjacent
to
beds
being
fumigated
with
metam­
sodium
has
resulted
in
significant
loss
of
seedlings
due
to
fumigant
drift.
Fumigant
drift
may
result
in
issues
related
to
human
safety
and
legal
liability.
Soil
temperature
requirements
(
above
4
°
C)
of
metam­
sodium,
due
to
vapor
pressure
properties,
can
constrain
use
in
some
areas
(
north
and
west)
(
Landis
and
Campbell,
1989);
(
Campbell
and
Kelpsas,
1988;
Carey,
1996;
Carey,
1994,
Darrow,
2002;
Weyerhaeuser,
#
4,
1985­
87;
Weyerhaeuser,
#
6,
1992)
No
NON
CHEMICAL
ALTERNATIVES
Containerized
production
Containerization
of
nursery
production
would
(
1)
require
a
large
capital
investment
by
all
participants
in
the
sector,
(
2)
increase
seedling
production
costs
by
300
to
600%,
(
3)
reduce
reforestation
rates
as
public
nurseries
opt
out
of
reforestation
as
expenditures
go
up.
(
see
Section
18
and
Appendix
A.).
Some
nurseries
with
specialized
markets
have
a
portion
of
their
production
in
containers
(
Barnett
and
McGilvrary,
1997;
Darrow,
2002;
Lowerts,
2003).
For
seedling
production
goals,
is
not
cost
effective
for
the
complex
production
system.
[
see
Section
18
and
Appendix
A.]

Virtually
Impermeable
Film
(
VIF)
Current
technology
does
not
allow
the
gluing
together
of
overlapping
sheets
and
therefore
makes
this
product
nonfunctional
for
flat
fumigation
treatments,
and
currently
available
products
are
relatively
weak
and
torn
by
wind
or
pressure.
However,
manufacturers
believe
problems
can
be
resolved
(
Rimini
and
Wigley,
2004).
Both
factors
combine
to
make
VIF
film
impractical
using
current
technology.
In
the
future,
VIF
might
have
a
role
in
reducing
MB
use
rates
while
maintaining
efficacy,
due
to
reduced
emissions.
Ongoing
studies
may
help
assess
value
of
VIF
with
MB
and
chemical
alternatives.
(
Carey
and
Godbehere,
2004;
Guillino
et
al.,
2002;
Martin,
2003).
Not
currently
cost
effective;
not
allowed
in
California
U.
S.
Forest
Seedlings
Page
41
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Solarization
Not
able
to
generate
acceptable
heat
to
allow
spring
planting;
most
effective
time
for
solarization
is
not
compatible
with
timing
for
production;
uses
solar
radiation
to
heat
soil
under
clear
plastic,
and
under
certain
conditions
in
some
locations
in
the
summer,
soil
can
be
heated
to
as
high
as
60
C
to
a
depth
of
7.5
cm.
Effective
solarization
would
likely
require
several
months
of
covered
bed
treatments,
to
heat
soil
to
a
sufficient
depth
(
25­
30
cm)
in
order
to
affect
soil­
borne
pathogens.
Seeds
of
some
weed
species
are
resistant
even
to
higher
temperatures
obtained
with
solarization.
Nutsedges,
Fusarium
spp.,
Macrophomina
spp.
are
not
controlled,
or
unpredictably
controlled,
by
solarization
(
Elmore
et
al.,
1997).
Therefore,
this
alternative
is
not
considered
technically
feasible.
Conceivably,
solarization
could
be
optimized
for
efficacy
and
incorporated
into
an
integrated
pest
management
(
IPM)
program
that
would
help
reduce
chemical
use
for
bed
preparation,
but
because
of
intensive
scheduling
of
seedling
production,
solarization
is
inadequate
as
a
sole
replacement
for
MB
in
the
forest
seedling
industry
even
in
the
southern
U.
S.
(
Weyerhaeuser,
#
8,
1992­
95)
Not
cost
effective
as
drop­
in
replacement
Biofumigation
This
is
a
process
where
mustard
species
(
Brassica
spp.)
are
grown
and
ultimately
disked
into
soils.
A
bioactive
breakdown
product
of
some
of
these
species
is
MITC.
However,
this
alternative
is
not
considered
feasible
due
to
the
difficulty
in
obtaining
sufficient
biomass
to
produce
effective
amounts
of
MITC
to
manage
diseases
and
weeds
under
nursery
conditions.
11,500
kg
per
ha
of
Brassica
plants 
an
amount
that
is
considered
very
high
production 
is
only
equivalent
to
approximately
25
kg
dazomet,
an
amount
significantly
less
than
effective
fumigation
rates.
In
addition,
increased
Fusarium
populations
due
to
favorable
conditions
provided
by
Brassica
plants
have
been
reported
to
increase
seedling
diseases
after
biofumigation
treatments.
While
some
Petri
dish
studies
(
e.
g.,
Charron
and
Sams)
have
indicated
a
reduction
in
growth
of
some
fungal
pathogens
limited
field
studies
have
been
conducted
to
verify
effects.
Not
able
to
provide
sufficient
biomass
Flooding/
Water
management
Nursery
beds
generally
are
designed
and
graded
for
good
drainage
to
prevent
standing
water.
Flooding
could
increase
incidence
of
Phytophthora
and
Pythium,
which
cause
important
damping­
off
and
root
rot
diseases.
Therefore,
this
alternative
is
not
considered
technically
feasible.
No
General
Integrated
Pest
Management
(
IPM)
Nurseries
currently
use
IPM
techniques,
but
these
measures
do
not
provide
adequate
weed
and
disease
control.
Therefore,
this
alternative
is
not
considered
technically
feasible.
Not
as
drop­
in
replacement
U.
S.
Forest
Seedlings
Page
42
Name
of
Alternative
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Plowing/
Tillage
Nursery
beds,
especially
medium
type
soils
with
higher
clay
or
organic
matter
than
light
soil
beds,
are
susceptible
to
damage
to
soil
structure
and
development
of
an
impermeable
"
plow
pan"
layer.
Increased
plowing
can
result
in
less
productive
seedling
beds,
therefore,
this
alternative
is
not
considered
feasible.
No
Physical
Removal/
Sanitation
Appropriate
sanitation
practices
are
already
followed
by
nurseries,
as
this
improves
productivity.
Weed
control
by
mechanical
means
would
not
be
technically
feasible
for
largescale
nursery
seedling
production.
No
Organic
Amendments/
Compost
Not
acceptably
effective
alone
in
weed
management;
often
cover
crops
are
already
used
for
beds
not
in
current
production,
as
part
of
general
IPM
program;
can
be
issue
with
weed
introduction
by
plant­
based
mulches
(
James
et
al.,
1997;
James
et
al.,
2001;
Stone
et
al.,
1998).
Most
nurseries
employ
various
soil
amendments
to
enhance
seedling
growth
and
quality,
but
these
measures
do
not
provide
adequate
weed
and
disease
control,
therefore,
this
alternative
is
not
considered
feasible.
No
COMBINATIONS
OF
ALTERNATIVES
See
Section
14
for
non­
MBTOC
alternatives
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

Chloropicrin
and
1,3­
D
were
not
listed
as
one
of
the
MB
alternatives
by
MBTOC.
These
have
been
investigated
by
the
industry
as
potential
alternatives,
and
in
certain
circumstances
(
e.
g.,
low
weed
pressure),
can
be
effective
in
reducing
weed,
fungi
and
nematode
populations.
U.
S.
Forest
Seedlings
Page
43
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Chloropicrin
(
340
kg/
ha)
A
good
fungicide,
but
not
acceptably
effective
with
moderate
or
high
weed
pressure,
some
reports
of
enhanced
weed
seed
germination
(
Carey,
2000;
Carey,
1996;
Enebak
et
al.,
1990;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
10,
1994­
96).
Weed
pressure
will
likely
increase
overtime.

Metam­
sodium
(
485
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
Can
be
effective
against
weeds
and
fungi,
especially
with
low
to
moderate
pressure
and
light
soils
(
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
10,
1994­
96).
There
is
a
history
of
outgassing
problems
and
significant
seedling
damage.

1,3­
D
(
260
kg/
ha)
+
chloropicrin
(
140
kg/
ha)
A
good
nematicide,
requires
light
soils
with
optimal
moisture
content.
Not
sufficiently
effective
against
weeds,
especially
with
even
moderate
weed
pressure;
may
have
legal
restrictions
on
use
(
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
7,
1994­
96;
Weyerhaeuser,
#
10,
1994­
96)

Herbicides
Research
will
help
to
identify
herbicides
(
e.
g.,
glyphosate)
that
can
effectively
reduce
high
populations
of
nutsedge
with
consistent
and
reliable
activity,
most
likely
as
part
of
an
integrated
program
of
alternatives
(
e.
g.,
Fraedrich
and
Dwinell,
2003c).

15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Sodium
Azide
Not
registered
in
U.
S.
No
registration
package
has
been
received.
No
Unknown
Propargyl
bromide
Not
registered
in
U.
S.
No
registration
package
has
been
received.
No
Unknown
Iodomethane
Not
registered
in
U.
S.
Yes
Unknown
U.
S.
Forest
Seedlings
Page
44
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED.

16.1.
A:
EFFECTIVENESS
OF
ALTERNATIVES
 
WEEDS
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
193b
[
2]
236a
[
3]
236a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
6b
[
2]
19ab
[
3]
45a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
3%

[
2]
8%

[
3]
19%
(#
Nutsedge
rhizomes
per
m2)

[
1]
91a
[
2]
43b
[
3]
5b
No
MB
trt
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
285
kg/
ha)

[
3]
Chloropicrin
(
285
kg/
ha)
+

metam
sodium
(
240
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
150b
[
2]
214ab
[
3]
246a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
8b
[
2]
15ab
[
3]
53a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
5%

[
2]
7%

[
3]
22%
(
Nutsedge
dry
wt,

kg/
ha)

[
1]
551a
[
2]
40b
[
3]
11b
No
MB
trt
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)

[
4]
MB
(
385
kg/
ha)
+
Pic
(
8
kg/
ha)
1
(
W/
Loblolly
pine)
Average
Total
Yield
(
per
m2)

[
1]
150b
[
2]
193a
[
3]
204a
[
4]
204a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
27b
[
2]
114ab
[
3]
150a
[
4]
131a
Quality
(%
Grade
#
1
compared
to
total)

[
1]
18%

[
2]
59%

[
3]
74%

[
4]
64%
Not
reported
Not
reported
Carey,

2000
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
340
kg/
ha)

[
3]
Chloropicrin
(
340
kg/
ha)
+

metam
sodium
(
320
kg/
ha)

[
4]
MB
(
385
kg/
ha)
+
Pic
(
8
kg/
ha)
1
(
W/

Slash
pine)
Average
Total
Yield
(
per
m2)

[
1]
107a
[
2]
150a
[
3]
150a
[
4]
129a
Average
Grade
#
1
Yield
(
per
m2)

[
1]
63b
[
2]
109ab
[
3]
136a
[
4]
109ab
Quality
(%
Grade
#
1
compared
to
total)

[
1]
59%

[
2]
73%

[
3]
91%

[
4]
84%
Not
reported
Not
reported
Carey,

2000
"
Heavy"
soil
(
57%
silt,
14%
clay,

29%
sand)
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
285
kg/
ha)

[
3]
Metam
sodium
(
455
kg/
ha)

[
4]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
455
kg/
ha)

[
5]
1,3­
D
(
240
kg/
ha)
+
Pic
(
100
kg/
ha)

[
6]
Dazomet
(
285
kg/
ha)

[
7]
MB
(
265
kg/
ha)+
Pic(
130kg/
ha)
1
(
w/
Loblolly
pine
Average
Total
Yield
(
per
m2)

[
1]
194
[
2]
181
[
3]
204
[
4]
192
[
5]
238
[
6]
214
[
7]
188
[
LSD,
0.05=
20]
Average
Grade
#
1
Yield
(
per
m2)

[
1]
41
[
2]
31
[
3]
35
[
4]
31
[
5]
28
[
6]
25
[
7]
23
[
LSD,
0.05=
40]
Quality
(%
Grade
#
1
compared
to
total)

[
1]
21%

[
2]
17%

[
3]
17%

[
4]
16%

[
5]
12%

[
6]
12%

[
7]
12%
(#
Total
weeds/
m2;

53
days
after
treatment)

[
1]
37
[
2]
16
[
3]
25
[
4]
7
[
5]
12
[
6]
12
[
7]
6
[
LSD,
0.05=
14]
(%
Coverage
of
weeds
per
plot
(
30
m2);
53
days
after
treatment)

[
1]
39%
a
[
2]
14%
bc
[
3]
25%
ab
[
4]
11%
bc
[
5]
21%
bc
[
6]
22%
bc
[
7]
6%
c
Carey,

1996
U.
S.
Forest
Seedlings
Page
45
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
Chem.
trts
w/
tarp]

[
1]
Control
(
no
fumigation)

[
2]
1,3­
D
(
240
kg/
ha)
+

chloropicrin
(
100
kg/
ha)

[
3]
Metam
sodium
(
455
kg/
ha)

[
4]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
455
kg/
ha)

[
5]
Dazomet
(
340
kg/
ha)

[
6]
Dazomet
(
170
kg/
ha)
+
Pic
(
130kg/
ha)

[
7]
MB
(
265
kg/
ha)+
Pic(
130kg/
ha)
Not
reported
Not
reported
Not
reported
Not
reported
(#
Nutsedge
/
m2;
7
months
after
treatment)

[
1]
85abc
[
2]
5c
[
3]
27bc
[
4]
15bc
[
5]
98abc
[
6]
127abc
[
7]
1c
[
LSD,
0.05=
38]
(%
Coverage
of
weeds
per
plot
(
175
m2)
7
months
after
treatment)

[
1]
100%
a
[
2]
35%
c
[
3]
36%
c
[
4]
38%
c
[
5]
95%
a
[
6]
46%
c
[
7]
29%
c
[
LSD,
0.05=
16]
Carey,

1994
[
1]
Metam­
sodium
(
485
kg/
ha)

[
2]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
[
spring
trt]

[
3]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)
[
fall
trt]
1
(
1st
year
Ponderosa
pine)
Average
Total
Yield
(
per
m2)

[
1]
245/
m2
[
2]
221/
m2
[
3]
208/
m2
Not
reported
Not
reported
Not
reported
Not
reported
Weyerhaeuser
#
2,
1980
[
1]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)

[
2]
Metam­
sodium
(
485
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)
1
(
2nd
year
crop
Douglas
fir)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
54/
m2
[
3]
 
5/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
11%

[
3]
1%
Consortium
(
CUE
03­
0021)
Comment:

"
Height,
caliper,

shoot
weight
were
greater
w/
MBC
treated
soil"
Not
reported
Not
reported
Weyerhaeuser
#
4,
1985­

1987
[
1]
MB
(
235
kg/
ha)
+
chloropicrin
(
115
kg/
ha)

[
2]
Dazomet
(
285
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)

[
4]
Control
1
(
2nd
year
crop
w/

Douglas
fir)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
88/
m2
[
3]
 
13/
m2
[
4]
 
75/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
18%

[
3]
3%

[
4]
16%
Consortium
(
CUE
03­
0021)
Comment:

"
Seedling
size
not
significantly
different
between
MBC
and
dazomet
at
285
kg/
ha;
size
reduced
w/
dazomet
at
400
kg/
ha
(
toxicity?")
Not
reported
Not
reported
Weyerhaeuser
#
5,
1985­

1987
U.
S.
Forest
Seedlings
Page
46
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
10
kg/
ha)

[
2]
Metam
sodium
(
485
kg/
ha)

[
3]
Dazomet
(
400
kg/
ha)

[
4]
Control
1
(
1st
year
crop
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
27/
m2
[
3]
 
13/
m2
[
4]
 
27/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
6%

[
3]
3%

[
4]
6%
Consortium
(
CUE
03­
0021)
Comment:

"
Seedling
height
averaged
5
cm
shorter
for
dazomet
and
10
cm
shorter
for
metam
sodium
and
control."
"
Caliper
(
diameter)
was
reduced
by
1
mm
in
metam
sodium
and
control
seedlings."
Not
reported
Not
reported
Weyerhaeuser
#
6,
1992
[
1]
MB
(
390
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
MB
(
300
kg/
ha)
+
chloropicrin
(
100
kg/
ha)
)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[
tarped]

[
4]
Dazomet
(
400
kg/
ha)
[

untarped

[
5]
Pic­
chlor
(
400
kg/
ha)
[
tarped]

[
6]
Chloropicrin
(
340
kg/
ha)

[
tarped]

[
7]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

1st
year
crop:

[
1]
=[
2]

[
3]
 
64/
m2
[
4]
 
99/
m2
[
5]
+
11/
m2
[
6]
+
19/
m2
[
7]
 
88/
m2
2nd
year
crop:

[
1]
=[
2]

[
3]
 
83/
m2
[
4]
 
59/
m2
[
5]
 
59/
m2
[
6]
 
19/
m2
[
7]
Not
reported
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
1]
=[
2]

[
3]
13%

[
4]
21%

[
5]
2%
gain
[
6]
4%
gain
[
7]
18%

2nd
year
crop:

[
1]
=[
2]

[
3]
17%

[
4]
12%

[
5]
12%

[
6]
4%

[
7]
Not
reported
Consortium
(
CUE
03­
0021)
Comment:

[
1st
year
crop
reduction
with
dazomet
due
to
stunting,
and
reduced
root
volume]

[
2nd
year
crop
yield
reduction
due
to
stunting,
and
reduced
root
volume]
Not
reported
Not
reported
Weyerhaeuser
#
7,
1994­

1996
[
1]
MB
(
390
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
Dazomet
(
400
kg/
ha)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[
tarped
&

solarized
3
mo.]

[
4]
Solarization
[
tarped,
solar.
3
mo]

[
5]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(
bare
fallow
from
harvest
Feb.,

1992
through
fumigation
and
tarp
(
3
mo.)
summer
1992
(#
Of
packable
seedlings
relative
to
MB
trt)

1st
year
crop:

[
2]
 
8/
m2
[
3]
 
5/
m2
[
4]
 
11/
m2
[
5]
=
[
1]

2nd
year
crop:

[
2]
 
8/
m2
[
3]
 
5/
m2
[
4]
 
11/
m2
[
5]
+
19/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
2]
2%

[
3]
1%

[
4]
2%

[
5]
no
loss
2nd
year
crop:

[
2]
2%

[
3]
1%

[
4]
2%

[
5]
4%
gain
[#
weeds/
m2
May,

1993;
dominant
species:
Amaranthaceae
spp.,

Mollugo
verticillata,

Euphorbia
supine]

[
1]
31b
[
2]
25b
[
3]
35b
[
4]
54ab
[
5]
104a
[#
weeds/
m2
June,

1993;
dominant
species:

Euphorbia
supine,

Digitaria
ciliaris,

Digitaria
ischaemun]

[
1]
13b
[
2]
10b
[
3]
17b
[
4]
28a
[
5]
36a
Not
reported
Weyerhaeuser
#
8,
1992­

1995
U.
S.
Forest
Seedlings
Page
47
Research
Results
for
Weed
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Treatment
#
Trials
Yield
Quality
Relative
Quality
Weed
Severity
Weed
Incidence
Citation
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
8
kg/
ha)
[
tarped]

[
2]
Dazomet
(
400
kg/
ha)
[
tarped]

[
3]
Dazomet
(
400
kg/
ha)
[

untarped

[
4]
Control
1
(
1st
year
crop
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt)

[
2]
 
19/
m2
[
3]
 
35/
m2
[
4]
 
5/
m2
Loss
(
based
on
480
seedlings/
m2
w/
MB):

[
2]
4%

[
3]
7%

[
4]
1%
Consortium
(
CUE
03­
0021)
Comment:

Short
trees
and
poor
root
structure
were
main
cull
factors
Not
reported
Not
reported
Weyerhaeuser
#
9,
1994­

1995
[
1]
MB
(
400
kg/
ha)
+
chloropicrin
(
8
kg/
ha)

[
2]
1,3­
D
(
260
kg/
ha)
+

chloropicrin
(
140
kg/
ha)

[
3]
Chloropicrin
(
130
kg/
ha)
+

metam
sodium
(
240
kg/
ha)

[
tarped]

[
4]
Dazomet
(
400
kg/
ha)[
tarped]

[
5]
Dazomet
(
400
kg/
ha)[
untarped]

[
6]
Chloropicrin
(
340
kg/
ha)

[
tarped]

[
7]
Control
1
(
1st
and
2nd
year
crops
w/
loblolly
pine)
(#
Of
packable
seedlings
relative
to
MB
trt
[
1])

1st
year
crop:

[
2]
 
40/
m2
[
3]
 
8/
m2
[
4]
+
3/
m2
[
5]
 
29/
m2
[
6]
 
13/
m2
[
7]
 
46/
m2
2nd
year
crop:

[
2]
 
3/
m2
[
3]
 
3/
m2
[
4]
+
3/
m2
[
5]
Not
reported
[
6]
+
3/
m2
[
7]
Not
reported
Loss
(
based
on
480
seedlings/
m2
w/
MB):

1st
year
crop:

[
2]
8%

[
3]
2%

[
4]
no
loss
[
5]
6%

[
6]
3%

[
7]
10%

2nd
year
crop:

[
2]
No
loss
[
3]
No
loss
[
4]
No
loss
[
5]
Not
reported
[
6]
No
loss
[
7]
Not
reported
1st
year
crop:

Culls
were
short
with
small
diameters
2nd
year
crop:

Study
was
suspended
due
to
high
nutsedge
populations
Not
reported
Not
reported
Weyerhaeuser
#
10,
1994­

1996
U.
S.
Forest
Seedlings
Page
48
TABLE
16.1.
B:
EFFECTIVENESS
OF
ALTERNATIVES
 
DISEASE
Research
Results
for
Disease
(
Fusarium,
Pythium,
Rhizoctonia)
Management
with
Methyl
Bromide
(
MB)
and/
or
Alternatives
Stand
density,

seedlings/
m2
(
fumigation
Sept.
1986,
seeding
Oct.,

1986)

Treatment
#
Trials
Yield
Percent
Survival
Average
Yield
Post
Emergence
(
per
m2)
Percent
Healthy
Root
Tips
(
1
year
old
seedlings)
May
1987
Sept
1987
Citation
Number
[
1]
Control
(
no
fumigation)

[
2]
Chloropicrin
(
196
kg/
ha)

[
3]
MB
(
392
kg/
ha]

[
4]
MB
(
263
kg/
ha)
+

chloropicrin
(
65
kg/
ha)

[
5]
MB
(
130
kg/
ha)
+

chloropicrin
(
131
kg/
ha)

[
6]
Dazomet
(
280
kg/
ha)

[
7]
Captan
(
6
kg/
ha)
[
soil
drench]

[
8]
Thiram
(
38
g/
kg
seed)

[
seed
trt.]

[
9]
Captan
(
6
kg/
ha)
[
soil
drench]
+
thiram
(
38
g/
kg
seed)
[
seed
trt.]

[
10]
Silica
sand
(
overlay
seeds)
6
reps
(
w/
white
pine
in
WI)
[
Yield
per
m2
at
seedling
emergence,
based
on
survival
from
damping­
off
diseases,

calculated
rate
of
720
seedlings/
m2
at
seeding
rate
of
14
g
seed/
m2]

[
1]
496b
[
2]
550a
[
3]
570a
[
4]
566a
[
5]
564a
[
6]
522ab
[
7]
474b
[
8]
404c
[
9]
408c
[
10]
366c
Percent
survival
from
dampingoff
at
seedling
emergence
[
1]
69%
ab
[
2]
76%
a
[
3]
79%
a
[
4]
79%
a
[
5]
78%
a
[
6]
73%
a
[
7]
66%
ab
[
8]
57%
c
[
9]
57%
c
[
10]
51%
c
[
Yield
per
m2
after
seedling
emergence
based
on
survival
from
damping­
off
diseases
at
cotyledon
or
primary
needle
stage]

[
1]
592d
[
2]
702a
[
3]
694ab
[
4]
710a
[
5]
682abc
[
6]
686ab
[
7]
580d
[
8]
646c
[
9]
670abc
[
10]
662bc
[
1]
20%
c
[
2]
55%
ab
[
3]
68%
a
[
4]
72%
a
[
5]
76%
a
[
6]
31%
bc
[
7]
8%
c
[
8]
18%
c
[
9]
16%
c
[
10]
38%
bc
[
1]
464
[
2]
464
[
3]
464
[
4]
464
[
5]
464
[
6]
464
[
7]
320
[
8]
360
[
9]
360
[
10]
320
[
1]
110
[
2]
464
[
3]
464
[
4]
464
[
5]
464
[
6]
250
[
7]
106
[
8]
106
[
9]
106
[
10]
80
Enebak
et
al.,
1990
[
1]
Control
(
no
fumigation)

[
2]
MB
(
266
kg/
ha)
+

chloropicrin
(
130
kg/
ha)

[
3]
Metam
sodium
(
485
kg/
ha)

[
4]
Dazomet
(
400
kg/
ha)
4
reps
(
w/

ponderosa
pine
in
Pacific
NW)
[%
Mortality
due
to
Pythium,

and
Fusarium,
during
1st
growing
season]

[
1]
25%
a
[
2]
12%
b
[
3]
8%
b
[
4]
10%
b
[#
Of
seedlings
after
1st
growing
season]
(
per
m2)

[
1]
150a
[
2]
300b
[
3]
343b
[
4]
300b
Campbell
and
Kelpsas,

1988
[
1]
Control
(
no
fumigation)

[
2]
MB
(
266
kg/
ha)
+

chloropicrin
(
130
kg/
ha)

[
3]
MB
(
580
kg/
ha)
+

chloropicrin
(
285
kg/
ha)

[
4]
Dazomet
(
400
kg/
ha)
1
(
with
Douglas
fir)
1st
crop
year:

Seedlings/
m2
[
1]
429
[
2]
482
[
3]
455
[
4]
469
Weyerhaeuser
#
3,
1984­

1987
Page
49
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
(
COMPARED
TO
MB)
BEST
ESTIMATE
OF
YIELD
LOSS
Chloropicrin
Fungi
+
3%
to
 
13%
5%
loss
Metam­
sodium
Weeds
+
3%
to
 
13%
5%
loss
Dazomet
Weeds
+
3%
to
 
13%
5%
loss
1,3­
D
Nematodes,
Weeds
+
3%
to
 
13%
5%
loss
Metam­
sodium
+
chloropicrin
Weeds,
Fungi
+
5%
to
 
8%
0­
3%
loss
1,3­
D
+
chloropicrin
Weeds,
Fungi
+
5%
to
 
8%
0­
3%
loss
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
3­
5%

Yield
loss
estimates
for
the
forest
nursery
sector
do
not
adequately
address
the
even
greater
effect
that
less
than
optimally
healthy
seedlings
have
on
subsequent
forest
plantings.
Forests
planted
with
undersized
seedlings
will
have
reduced
survival
and
slowed
growth
if
initial
seedling
health
is
compromised.
No
alternatives
have
been
sufficiently
tested
to
currently
substitute
for
MB.

17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Combinations
of
chemicals,
such
as
chloropicrin,
metam­
sodium,
or
1,3­
D
appear
to
be
effective
for
some
nurseries
in
reducing
pest
infestations,
including
some
weed
problems
(
e.
g.,
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96).
Combinations
of
these
compounds
and
application
techniques
(
such
as
deep
injection)
to
achieve
the
same
pest
control
efficiencies
as
MB
are
being
studied.
So
far,
none
have
proven
cost
effective
and
have
generally
resulted
in
an
increased
input
of
other
pest
control
products.
Because
of
their
physical
limitations
(
e.
g.,
low
vapor
pressure
of
metam­
sodium),
these
products
are
frequently
criticized
by
nursery
managers
for
their
lack
of
consistency.
Conclusions
from
individual
research
trials
may
be
skewed
since
large­
scale
production
will
result
in
greater
differences
between
MB
and
certain
alternatives.
In
addition,
economic
issues
may
have
an
impact
on
overall
acceptability
of
these
alternatives
for
the
forest
seedling
nursery
sector.
Tests
are
being
conducted
with
methyl
iodide,
which
has
potential
as
a
MB
replacement,
although
it
is
unknown
when
registration
might
occur.

The
use
of
virtually
impermeable
film
(
VIF)
may
offer
a
means
of
reducing
MB
use
rates
while
maintaining
efficacy
and
production
goals
(
Carey
and
Godbehere,
2004).
Work
is
being
conducted
to
determine
if
this
type
of
film
is
feasible
in
the
U.
S.
from
a
technical
standpoint
(
e.
g.,
does
it
hold
up
physically
in
field
conditions?
can
it
be
glued
to
acceptable
specifications?,
etc.)
and
economically
feasible
(
e.
g.,
cost
of
material,
cost
of
application).
VIF
manufacturers
believe
that
technical
problems
will
be
solved
(
Rimini
and
Wigley,
2004).
However,
the
efficacy
of
VIF
for
U.
S.
agriculture
may
be
different
than
that
for
Europe
(
Federal
Register,
1998);
California
does
not
permit
the
use
of
VIF.
There
is
also
interest
in
examining
the
effects
of
certain
fertilizer
salts
(
e.
g.,
ammonium
thiosulfate,
see
Gan
and
Yates,
1998),
which
may
act
as
barriers
to
volatile
compounds
(
e.
g.,
1,3­
D,
MB)
when
applied
to
the
soil
surface,
thus
reducing
emissions
and
improving
efficacy.
Page
50
A
major
limitation
with
respect
to
ongoing
research
is
the
general
lack
of
information
to
accurately
assess
pest
control
in
large
scale,
compared
to
small
research
trials,
including
issues
such
as
outgassing
damage
as
a
result
of
metam­
sodium
applications
(
e.
g.,
see
Application
Request
Packages).
Technical
difficulties
in
extrapolating
research
scale
plots
to
"
real
world"
applications
make
it
difficult
to
transition
away
from
MB
and
calculate
implementation
timelines,
since
production
consistency
is
frequently
compromised.
As
discussed
in
Section
23
below,
considerable
research
dollars
have
been
spent
on
research
of
MB
alternatives.
However,
phasing
out
MB
for
many
current
uses
may
be
foreseeable.
A
combination
of
methods
can
conceivably
be
used
to
reduce
MB,
but
this
will
require
several
seasons
of
testing
and
analyses.

The
reduction
of
MB
from
98:
2
to
65:
35
or
even
50:
50,
the
reduction
in
use
rate,
increased
periods
of
cover
crop
growth,
use
of
glyphosate
(
Fraedrich
and
Dwinell,
2003c),
and
an
increased
use
of
mechanical
cultivation
should
all
reduce
weed
populations,
and
the
overall
use
of
MB.
Experiments
have
indicated
that
some
soil
amendments
can
reduce
possible
adverse
growth
effects
of
some
alternatives
(
e.
g.,
dazomet).
Work
in
Wisconsin
(
Enebak
et
al.,
1990;
Iver,
undated)
suggested
that
white
pine
seedlings
subjected
to
dazomet,
but
supplied
with
various
nutrients,
could
reduce
chlorosis
sometimes
observed
in
dazomet
treated
beds.
Large
scale
trials
will
be
necessary
to
confirm
this
effect.
For
disease
control,
studies
(
James
et
al.,
1997)
comparing
cultivation
practices,
such
as
till
vs.
no­
till
and
organic
amendments
indicate
that
effects
vary
according
to
the
species
grown,
thus
each
nursery
may
have
to
consider
alternatives
with
species
and
local
environment
in
mind,
unlike
the
more
consistent
effects
of
MB
fumigation.
Promising
results
in
disease
management
have
been
observed
(
Lantz,
1997;
Stone
et
al.,
1998)
with
organic
amendments,
but
successful
weed
management
has
not
been
adequately
achieved.

18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

Containerization
is
used
for
seedling
production
in
a
limited
capacity
throughout
the
forest
nursery
sector.
One
Michigan
grower
(
see
request
from
the
Michigan
Seedling
Association)
produces
greenhouse­
grown
plug
plants,
which
are
grown
for
1­
2
years,
then
planted
in
beds
for
an
additional
1­
3
years.
Containers
can
also
be
for
special
circumstances
where
species
survival
or
an
genetic
value
of
the
planting
stock
make
them
economically
feasible.
Recent
surveys
indicate
that
of
the
1.2
billion
seedlings
grown
in
the
southeastern
U.
S.
in
the
2002­
2003
season,
fewer
than
5%
were
produced
in
containers
(
McNabb
and
VandersSchaaf,
2003).
An
estimate
can
be
made
that
less
than
10%
of
the
national
forest
seedling
production
is
containerized.
Containerization
is
mandated
by
species
or
site
requirements.
An
example
is
the
use
of
containerized
seedlings
to
reforest
mine­
spoil
sites
which
are
extremely
harsh
edaphic
environments
requiring
a
soil
plug
system
to
obtain
adequate
seedling
survival
(
Lowerts,
2003).

A
large
investment
would
be
necessary
to
shift
the
national
production
to
containerization,
as
well
as
a
shift
for
many
nurseries
in
the
well
established
protocols
of
growing
seedlings.
According
to
Darrow
(
2002)
(
also
see
Appendix
A)
the
transition
from
bed
to
container
production
would
require
additional
capital
and
operating
costs.
Investment
would
be
necessary
for
the
purchases
of
greenhouses,
container
filling
and
sowing
machines,
containers,
outdoor
holding
areas,
fertigation
systems,
and
new
seedling
transport
systems
both
in
the
nursery
and
in
the
field.
Not
all
sectors
of
seedling
production
would
have
this
capital
available
to
them.
It
is
Page
51
likely
that
smaller
bareroot
operations
would
close
and
many
state­
run
nurseries
would
opt
to
close
rather
than
budget
state
funds
for
such
a
significant
capital
outlay.
There
is
little
doubt
that
seedling
prices
could
increase
by
up
to
six
times
current
prices.
A
typical
one
year
old
bareroot
seedling
currently
sells
for
$
0.04
each,
while
the
typical
container
seedling
of
the
same
species
begins
at
$
0.12
each.
In
addition
to
an
increase
in
seedling
costs,
there
are
significant
cost
increases
associated
with
transportation
and
planting
container
stock.
Fewer
container
plants
can
be
transported
per
truck
and
fewer
seedlings
can
be
carried
by
individual
tree
planters.
More
trucks
and
more
fuel
are
needed
to
get
seedlings
to
the
planting
site
and
more
labor
and
time
are
needed
to
plant
a
given
area.
One
study
found
that
daily
production
decreased
from
9.7
ha
per
day
with
bareroot
seedlings
to
7.3
ha
per
day
with
containerized
seedlings,
a
decrease
of
25%,
without
increasing
planting
crew
size
(
Lowerts,
2003).

The
inevitable
result
of
containerization
would
be
a
significant
increase
in
reforestation
costs
and
a
decrease
in
the
rate
of
reforestation.
According
to
the
U.
S.
Forest
Service,
48%
of
all
reforestation
in
the
U.
S.
is
done
on
non­
industrial
private
lands,
an
additional
42%
is
done
on
industrial
lands,
and
only
10%
on
government
lands
(
Moulton
and
Hernandez,
2000).
It
is
well
established
that
non­
industrial
forest
owners
are
very
sensitive
to
reforestation
costs,
decreasing
their
investment
in
direct
proportion
to
increasing
costs
(
Hardie
and
Parks,
1991;
Royer,
1987).
Given
the
importance
of
non­
industrial
owners
on
the
general
timber
supply,
a
reduction
in
reforestation
efforts
by
this
group
may
have
serious
long­
term
negative
impacts
on
the
sustainability
of
the
forest
economy.
Industrial
owners
will
also
be
negatively
impacted
by
increased
reforestation
costs
as
raw
material
costs
will
increase
(
typically
about
40­
60%
of
the
cost
of
final
fiber
products),
impacting
the
competitiveness
of
their
industry.

Conclusion:
The
infrastructure
investment
necessary
for
containerization
is
enormous
and
would
probably
force
many
nurseries
out
of
business.
Seedling
production
costs
would
increase,
resulting
in
seedling
price
increases
of
over
250%.
New
transportation
and
planting
systems
would
have
to
be
adopted.
Reforestation
costs
would
go
up
significantly
and
probably
result
in
fewer
non­
industrial
forest
owners
reforesting
after
harvest.
The
potential
long­
term
effect
of
these
changes
on
the
forestry
economy
is
enormous.
Overall,
containerization
would
result
in
a
significant
increase
in
seedling
production,
transportation,
and
planting
costs
and
would
most
likely
decrease
reforestation
rates.

SUMMARY
OF
TECHNICAL
FEASIBILITY
This
nomination
includes
requests
for
MB
only
for
those
nurseries
where
sufficient
pest
control
can
not
be
achieved
otherwise.
While
combinations
of
chemicals,
such
as
chloropicrin,
metamsodium
and
1,3­
D
appear
to
be
effective
for
some
nurseries
in
reducing
pest
infestations,
including
some
weed
problems
(
e.
g.,
Carey,
2000;
Carey,
1996;
Carey,
1994;
Weyerhaeuser,
#
8,
1992­
95;
Weyerhaeuser,
#
10,
1994­
96),
currently
all
nurseries
can
not
rely
solely
on
alternatives.
For
example,
1,3­
D
is
an
effective
nematicide
that
may
have
some
efficacy
against
plant
pathogens,
but
for
efficacy
for
weed
management
additional
inputs
will
be
required
(
such
as
use
of
a
formulation
with
chloropicrin
and
use
of
VIF).
Its
overall
use
may
be
limited
by
local
legal
restrictions
and
pest­
free
permit
requirements,
and
VIF
has
technical
problems
and
is
restricted
in
California
(
e.
g.,
Carey,
1996;
Carey,
1994;
Weyerhaeuser
#
10,
1994­
96).
In
addition,
economic
issues
such
as
application
costs
may
have
an
impact
on
overall
acceptability
of
these
alternatives
for
the
forest
seedling
nursery
sector.
Page
52
Recent
studies
with
dazomet
in
Georgia
and
North
Carolina
nurseries
(
Fraedrich
and
Dwinell,
2003b)
and
glyphosate
(
Fraedrich
and
Dwinell,
2003c)
suggest
that
both
have
potential
as
nutsedge
treatments,
but
will
be
used
in
seedling
production
only
after
research
can
" 
better
define
the
optimal
use
conditions".
It
is
expected
that
the
various
consortia
will
present
timelines
for
transition
from
MB
in
the
near
future.

Statistically
analyzed
trials
measuring
quantity
and
quality
losses
due
to
specific
pests
(
e.
g.,
weeds
or
pathogens)
are
not
readily
available.
More
commonly
found
are
trials
indicating
overall
yield
(
and
sometimes
quality
assessments),
allowing
a
comparison
of
treatments
based
on
yield,
but
making
it
difficult
to
ascribe
losses
to
particular
pests.
This
is
particularly
a
problem
since
the
numerous
forest
seedling
nurseries
can
experience
various
problems
unique
to
the
combination
of
climate,
soil,
seedling
species,
market
forces,
and
customer
base
(
e.
g.,
public
vs.
private
nursery,
or
commercial
vs.
recreational
end
uses).
Overall
yield
losses
with
the
best
alternatives,
compared
to
MB,
were
estimated
at
0­
3%
based
on
research
data.
In
estimating
the
yield
of
alternatives
in
comparison
to
MB,
it
should
be
remembered
that
these
figures
are
for
the
general
case,
and
individual
nurseries
will
likely
experience
greater
or
lesser
efficacy
with
a
given
treatment,
depending
on
soil,
climate,
production
practices,
market
requirements,
species
of
seedling,
etc.
The
yield
estimates
listed
in
Table
C.
1
are
based
on
research
results
described
in
Section
16.
Quality
factors
are
as
important
in
this
industry
as
yield,
and
may
affect
the
efficacy
of
a
given
alternative
beyond
considerations
of
yield
alone
(
e.
g.,
"
Percent
`
Healthy
Root
Tips'"
in
Table
16.1B,
Enebak
et
al.,
1990).

Larger
seedling
size
and
improved
seedling
vigor
translate
to
improved
reforestation
success
and
increased
growth
rate
of
young
plantations.
This
positive
contribution
to
reforestation
is
well
documented
for
seedlings
produced
in
MB
fumigated
soil.
Increases
in
seedling
size
and
quality
resulting
from
fumigation
with
MB
alternatives
have
been
variable.
The
long­
term
impact
on
reforestation
success
with
alternatives
is
not
known.
An
important
factor
is
the
long­
term
implication
associated
with
forest
growth
and
health
over
a
20­
40
year
period
of
forest
life.
Seedling
quality
has
been
highly
correlated
with
productive
and
healthy
forests
impacting
both
commercial
and
public
interests.

The
industry
is
continuing
to
sponsor
research
alternatives
and
test
improved
chemical
application
technologies
to
increase
the
efficacy
of
some
of
the
most
viable
alternatives.
MB
is
considered
to
be
critical
in
the
short­
term,
with
chemical
alternatives
the
likely
long­
term
solution.
Non­
chemical
and
biological
control
methodologies
are
not
advanced
enough
to
rely
on
in
the
foreseeable
future.
Research
with
organic
and
inorganic
soil
amendments
(
Fraedrich
and
Dwinell,
1998;
James
et
al.,
1997;
James
et
al.,
2001;
Lantz,
1997;
Stone
et
al.,
1998)
have
had
some
successes
under
certain
conditions,
but
the
effects
appear
to
be
variable
depending
on
the
nursery
locations
and
species
of
seedlings.
Integration
of
several
alternative
treatments
is
the
most
likely
alternative
to
MB.
Page
53
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
The
Forest
Seedlings
sector
has
reduced
its
MB
consumption
through
several
techniques
developed
over
the
past
several
years.
First,
the
sector
has
incorporated
the
use
of
high­
density
polyethylene
(
HDPE)
tarp
material
that
has
helped
increase
fumigation
efficiencies
and
reduced
application
rates.
HDPE
increases
MB
soil
residence
time,
increasing
efficiency
and
reducing
application
rates.
VIF
is
likely
to
be
an
important
means
of
further
reducing
emissions
if
a
method
can
be
developed
to
efficiently
glue
overlapping
sheets
of
VIF
film
(
e.
g.,
Carey
and
Godbehere,
2004).
VIF
film
becomes
impractical
if
adjacent
overlapping
sheets
cannot
be
glued.
In
addition,
there
is
a
problem
with
film
breakage
during
application.
Suppliers
believe
technical
problems
can
be
fixed
(
Rimini
and
Wigley,
2004),
however,
currently
regulations
prevent
the
use
of
VIF
in
California.

Second,
MB
fumigation
in
the
forest
seedlings
sector
increasingly
has
been
made
using
deep
injection
that
places
the
material
deeper
into
the
soil
than
previously.
Deeper
placement
contributes
to
longer
residence
time
in
the
soil
and
greater
application
efficiency.
This
has
been
accomplished
at
considerable
capital
investment
on
the
part
of
applicators.

Third,
forest
seedlings
nurseries
have
increased
the
percentage
of
chloropicrin
in
fumigation
mixtures.
While
98%
MB
and
2%
chloropicrin
was
the
most
widely
used
compound
a
few
years
ago,
a
66:
33
formulation
is
now
more
common.
Growers
still
applying
98:
2
formulations,
such
as
International
Paper,
are
currently
examining
the
effects
of
66:
33
in
their
nursery
trials.
Some
efficiency
in
weed
control
has
been
sacrificed
by
this
change
in
procedure,
however,
and
higher
concentrations
of
chloropicrin
become
increasingly
less
satisfactory
as
weed
pressure,
particularly
nutsedge,
increases.
Some
nurseries
are
investigating
use
of
herbicides,
such
as
glyphosate,
as
an
economic
means
of
weed
control
(
e.
g.,
Fraedrich
and
Dwinell,
2003c;
Northeastern
Consortium
request,
Worksheet
4).

Fourth,
forest
seedlings
nurseries
routinely
use
integrated
pest
management
(
IPM)
techniques
to
develop
their
fumigation
strategies.
Nurseries
fumigate
only
once
every
four
years,
growing
two
seedling
crops
and
two
cover
crops
following
fumigation.
Soil
organic
matter
content,
weed
populations,
and
disease
incidence
are
carefully
monitored
during
the
crop
rotation
to
ensure
the
correct
timing
and
rate
of
MB
application.
Monitoring
pest
populations
is
an
integral
part
of
an
IPM
approach
and
helps
ensure
MB
efficiency.

Finally,
the
forest
seedlings
sector
has
devoted
considerable
resources
to
investigating
MB
alternatives
and
continues
to
search
for
methodologies
to
reduce
MB
use
rates.
The
industry
is
committed
to
continuing
research
to
address
the
issue
of
improved
consistency
(
especially
for
nutsedge
control)
with
available
chemical
alternatives
and
to
test
new
products
in
order
to
determine
efficacy
and
obtain
the
information
necessary
for
U.
S.
registrations.
Page
54
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?
Currently
some
growers
use
HDPE
tarps.
No
trend
was
identified.
Research
is
ongoing
examining
lower
proportion
of
MB
No
trend
was
identified.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
The
U.
S.
anticipates
that
the
decreasing
supply
of
MB
will
motivate
growers
to
try
high
barrier
film.
The
U.
S.
anticipates
that
the
decreasing
supply
of
MB
will
motivate
growers
to
try
dosage
reduction.
The
U.
S.
anticipates
that
the
decreasing
supply
of
MB
will
motivate
growers
to
try
increasing
the
chloropicrin
percentage
in
formulations.
The
U.
S.
anticipates
that
the
decreasing
supply
of
MB
will
motivate
growers
to
try
less
frequent
applications.
OTHER
MEASURES
(
please
describe)
Unknown
Unknown
Unknown
Unknown
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS:

As
stated
previously,
emission
reduction
technologies
are
being
addressed
by
the
sector
(
e.
g.,
VIF,
reduced
MB
component
of
formulation,
use
of
advanced
delivery
techniques
to
make
alternative
chemicals
more
effective
at
deeper
soil
levels).
Page
55
PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
OPERATING
COSTS
WITH
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
REGION
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
U.
S.
$/
ha)
COST
IN
YEAR
2
(
U.
S.
$/
ha)
COST
IN
YEAR
3
(
U.
S.
$/
ha)

Methyl
Bromide
100
$
17,820
$
17,820
$
17,820
Dazomet
95
$
20,750
$
20,750
$
20,750
1,3­
D
+
Chloropicrin
97
$
19,865
$
19,865
$
19,865
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Metam
Sodium
+
Chloropicrin
97
$
20,258
$
20,258
$
20,258
Methyl
Bromide
100
$
15,740
$
15,740
$
15,740
Dazomet
95
$
18,284
$
18,284
$
18,284
1,3­
D
+
Chloropicrin
97
$
18,343
$
18,343
$
18,343
REGION
B
­
INTERNATIONAL
PAPER
Metam
Sodium
+
Chloropicrin
97
$
18,621
$
18,621
$
18,621
Methyl
Bromide
100
$
46,031
$
46,031
$
46,031
Dazomet
95
$
48,442
$
48,442
$
48,442
1,3­
D
+
Chloropicrin
97
$
48,442
$
48,442
$
48,442
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Metam
Sodium
+
Chloropicrin
97
$
48,442
$
48,442
$
48,442
Methyl
Bromide
100
$
16,960
$
16,960
$
16,960
Dazomet
95
$
17,758
$
17,758
$
17,758
1,3­
D
+
Chloropicrin
97
$
17,736
$
17,736
$
17,736
REGION
D
­
WEYERHAEUSER
SOUTH
Metam
Sodium
+
Chloropicrin
97
$
17,656
$
17,656
$
17,656
Methyl
Bromide
100
$
10,187
$
10,187
$
10,187
Dazomet
95
$
11,748
$
11,748
$
11,748
1,3­
D
+
Chloropicrin
97
$
11,748
$
11,748
$
11,748
REGION
E
­
WEYERHAEUSER
WEST
Metam
Sodium
+
Chloropicrin
97
$
10,342
$
10,342
$
10,342
Methyl
Bromide
100
$
32,718
$
32,718
$
32,718
Dazomet
95
$
38,747
$
38,747
$
38,747
1,3­
D
+
Chloropicrin
97
$
37,994
$
37,994
$
37,994
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
Metam
Sodium
+
Chloropicrin
97
$
37,994
$
37,994
$
37,994
Methyl
Bromide
100
$
94,908
$
94,908
$
94,908
Dazomet
95
$
96,186
$
96,186
$
96,186
1,3­
D
+
Chloropicrin
97
$
96,394
$
96,394
$
96,394
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
Metam
Sodium
+
Chloropicrin
97
$
95,959
$
95,959
$
95,959
Methyl
Bromide
100
$
37,311
$
37,311
$
37,311
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
Various
Alternatives*
95
$
58,414
$
58,414
$
58,414
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.
**
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.
Page
56
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.
$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
U.
S.
$/
ha)
Methyl
Bromide
$
33,682
$
15,862
Dazomet
$
31,998
$
11,247
1,3­
D
+
Chloropicrin
$
32,671
$
12,806
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Metam
Sodium
+
Chloropicrin
$
32,671
$
12,413
Methyl
Bromide
$
31,096
$
15,356
Dazomet
$
29,541
$
11,257
1,3­
D
+
Chloropicrin
$
30,163
$
11,820
REGION
B
­
INTERNATIONAL
PAPER
Metam
Sodium
+
Chloropicrin
$
30,163
$
11,542
Methyl
Bromide
$
178,824
$
132,794
Dazomet
$
169,883
$
121,441
1,3­
D
+
Chloropicrin
$
173,460
$
125,018
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Metam
Sodium
+
Chloropicrin
$
173,460
$
125,018
Methyl
Bromide
$
26,719
$
9,759
Dazomet
$
25,383
$
7,626
1,3­
D
+
Chloropicrin
$
25,918
$
8,182
REGION
D
­
WEYERHAEUSER
SOUTH
Metam
Sodium
+
Chloropicrin
$
25,918
$
8,262
Methyl
Bromide
$
18,759
$
8,571
Dazomet
$
17,821
$
6,073
1,3­
D
+
Chloropicrin
$
18,196
$
6,448
REGION
E
­
WEYERHAEUSER
WEST
Metam
Sodium
+
Chloropicrin
$
18,196
$
7,854
Methyl
Bromide
$
48,759
$
16,041
Dazomet
$
46,321
$
7,574
1,3­
D
+
Chloropicrin
$
47,296
$
9,302
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
Metam
Sodium
+
Chloropicrin
$
47,296
$
9,302
Methyl
Bromide
$
143,815
$
48,907
Dazomet
$
136,624
$
40,438
1,3­
D
+
Chloropicrin
$
139,501
$
43,107
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
Metam
Sodium
+
Chloropicrin
$
139,501
$
43,542
Methyl
Bromide
$
140,956
$
103,645
REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
Various
Alternatives*
$
133,908
$
75,494
*
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.
Page
57
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
A
­
SOUTHERN
FOREST
NURSERY
MANAGEMENT
COOPERATIVE
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
YIELD
LOSS
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
Pine
779,617
740,636
756,228
756,228
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.04
$
0.04
$
0.04
$
0.04
Gross
Revenue
per
Proportion
(
88%)
$
27,443
$
26,070
$
26,619
$
26,619
Yield
(
seedling)
per
Hectare
Longleaf
Pine
423,785
402,596
411,072
411,072
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.06
$
0.06
$
0.06
$
0.06
Gross
Revenue
per
Proportion
(
3%)
$
763
$
725
$
740
$
740
Yield
(
seedling)
per
Hectare
Hardwood
243,399
231,229
236,097
236,097
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.25
$
0.25
$
0.25
$
0.25
Gross
Revenue
per
Proportion
(
9%)
$
5,476
$
5,203
$
5,312
$
5,312
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
33,682
$
31,998
$
32,671
$
32,671
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
17,820
$
20,750
$
19,865
$
20,258
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
15,862
$
11,247
$
12,806
$
12,413
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
4,614
$
3,055
$
3,449
2.
Loss
per
Kilogram
of
MB
(
U.
S.
$)
$
0
$
49.21
$
32.59
$
36.78
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
14%
9%
10%

4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
29%
19%
22%
Page
58
REGION
B
­
INTERNATIONAL
PAPER
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
B
­
INTERNATIONAL
PAPER
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
(
seedling)
per
Hectare
741,315
704,250
719,076
719,076
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.04
$
0.04
$
0.04
$
0.04
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
31,096
$
29,541
$
30,163
$
30,163
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
15,740
$
18,284
$
18,343
$
18,621
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
15,356
$
11,257
$
11,820
$
11,542
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
4,099
$
3,536
$
3,814
2.
Loss
per
Kilogram
of
MB
(
U.
S.
$)
$
0
$
78.97
$
68.13
$
73.49
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
13%
11%
12%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
27%
23%
25%
Page
59
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
C
­
ILLINOIS
DEPARTMENT
OF
NATURAL
RESOURCES
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%

Yield
(
seedling)
per
Hectare
­
Tree
295,564
280,786
286,697
286,697
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.55
$
0.55
$
0.55
$
0.55
Gross
Revenue
per
Proportion
(
81.6%)
$
132,615
$
125,984
$
128,636
$
128,636
Yield
(
shrub)
per
Hectare
­
Shrub
Seedling
249,107
236,651
241,634
241,634
*
Price
per
Unit
(
U.
S.
$/
shrub)
$
0.31
$
0.31
$
0.31
$
0.31
Gross
Revenue
per
Proportion
(
13.2%)
$
10,161
$
9,653
$
9,856
$
9,856
Yield
per
Hectare
­
Forb
Root
Stock
123,298
117,134
119,600
119,600
*
Price
per
Unit
(
U.
S.
$/
root
stock)
$
0.04
$
0.04
$
0.04
$
0.04
Gross
Revenue
per
Proportion
(
5.3%)
$
260
$
247
$
252
$
252
Yield
(
kilograms)
per
Hectare
­
Forb
Seed
411
390
399
399
*
Price
per
Unit
(
U.
S.
$/
kilogram)
$
87.08
$
87.08
$
87.08
$
87.08
Gross
Revenue
per
Proportion
$
35,789
$
34,000
$
34,715
$
34,715
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
178,824
$
169,883
$
173,460
$
173,460
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
46,031
$
48,442
$
48,442
$
48,442
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
132,794
$
121,441
$
125,018
$
125,018
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S
$)
$
0
$
11,352
$
7,776
$
7,776
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
43.10
$
29.52
$
29.52
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
6%
4%
4%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
9%
6%
6%

REGION
D
­
WEYERHAEUSER
SOUTH
­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
D
­
WEYERHAEUSER
SOUTH
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
(
seedling)
per
Hectare
574,612
545,882
557,374
557,374
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.05
$
0.05
$
0.05
$
0.05
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
26,719
$
25,383
$
25,918
$
25,918
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
16,960
$
17,758
$
17,736
$
17,656
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
9,759
$
7,626
$
8,182
$
8,262
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
2,134
$
1,578
$
1,497
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
25.38
$
18.77
$
17.81
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
8%
6%
6%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
22%
16%
15%
Page
60
REGION
E
­
WEYERHAEUSER
WEST
­
TABLE
E.
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
REGION
E
­
WEYERHAEUSER
WEST
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
(
seedling)
per
Hectare
60,610
57,579
58,792
58,792
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.31
$
0.31
$
0.31
$
0.31
=
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
18,759
$
17,821
$
18,196
$
18,196
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
10,187
$
11,748
$
11,748
$
10,342
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
8,571
$
6,073
$
6,448
$
7,854
LOSS
MEASURES
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
2,499
$
2,124
$
718
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
28.52
$
24.24
$
8.19
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
13%
11%
4%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
29%
25%
8%
Page
61
REGION
F
­
NORTHEASTERN
FOREST
&
CONSERVATION
NURSERY
ASSOCIATION
­
TABLE
E.
6:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
F
­
Northeastern
Forest
&
Conservation
Nursery
Association
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
per
Hectare
Conifer
Seedling
1­
0
247,105
234,750
239,692
239,692
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.22
$
0.22
$
0.22
$
0.22
Gross
Revenue
per
Proportion
(
8%)
$
4,349
$
4,132
$
4,219
$
4,219
Yield
per
Hectare
Conifer
Seedling
2­
0
247,105
234,750
239,692
239,692
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.22
$
0.22
$
0.22
$
0.22
Gross
Revenue
per
Proportion
(
4%)
$
2,175
$
2,066
$
2,109
$
2,109
Yield
per
Hectare
Conifer
Seedling
3­
0
135,908
129,112
131,831
131,831
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.31
$
0.31
$
0.31
$
0.31
Gross
Revenue
per
Proportion
(
14%)
$
5,898
$
5,603
$
5,721
$
5,721
Yield
per
Hectare
Deciduous
Tree
Seedling
1­
0
185,329
176,062
179,769
179,769
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.28
$
0.28
$
0.28
$
0.28
Gross
Revenue
per
Proportion
(
55%)
$
28,541
$
27,114
$
27,684
$
27,684
Yield
per
Hectare
Deciduous
Tree
Seedling
2­
0
123,553
117,375
119,846
119,846
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.34
$
0.34
$
0.34
$
0.34
Gross
Revenue
per
Proportion
(
9%)
$
3,781
$
3,592
$
3,667
$
3,667
Yield
per
Hectare
Deciduous.
Shrub
Seedling
1­
0
154,441
146,719
149,808
149,808
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.26
$
0.26
$
0.26
$
0.26
Gross
Revenue
per
Proportion
(
10%)
$
4,015
$
3,815
$
3,895
$
3,895
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
48,759
$
46,321
$
47,296
$
47,296
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
32,718
$
38,747
$
37,994
$
37,994
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
16,041
$
7,574
$
9,302
$
9,302
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
8,467
$
6,738
$
6,738
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
49.38
$
39.30
$
39.30
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
17%
14%
14%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
53%
42%
42%
Page
62
REGION
G
­
MICHIGAN
SEEDLING
ASSOCIATION
­
TABLE
E.
7:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
G
­
Michigan
Seedling
Association
Methyl
Bromide
Dazomet
1,3­
D
+
Chloropicrin
Metam­
Sodium
+
Chloropicrin
Yield
Loss
(%)
0%
5%
3%
3%
Yield
per
Hectare
Conifer
Seedlings
1,070,789
1,017,250
1,038,665
1,038,665
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.14
$
0.14
$
0.14
$
0.14
Gross
Revenue
per
Proportion
(
60%)
$
89,946
$
85,449
$
87,248
$
87,248
Yield
per
Hectare
Conifer
Transplants
74,132
70,425
71,908
71,908
*
Price
per
Unit
(
U.
S.
$/
transplants)
$
0.60
$
0.60
$
0.60
$
0.60
Gross
Revenue
per
Proportion
(
10%)
$
4,448
$
4,225
$
4,314
$
4,314
Yield
per
Hectare
Deciduous
Transplants
329,474
313,000
319,589
319,589
*
Price
per
Unit
(
U.
S.
$/
transplants)
$
0.50
$
0.50
$
0.50
$
0.50
Gross
Revenue
per
Proportion
(
30%)
$
49,421
$
46,950
$
47,938
$
47,938
=
Aggregate
Gross
Revenue
per
Hectare
(
U.
S.
$)
$
143,815
$
136,624
$
139,501
$
139,501
­
Operating
Costs
per
Hectare
(
U.
S.
$)
$
94,908
$
96,186
$
96,394
$
95,959
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
48,907
$
40,438
$
43,107
$
43,542
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
8,469
$
5,800
$
5,365
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
95.26
$
65.24
$
60.35
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
6%
4%
4%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
17%
12%
11%

REGION
H
­
MICHIGAN
HERBACEOUS
PERENNIALS
­
TABLE
E.
8:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
Region
H
­
Michigan
Herbaceous
Perennials
Methyl
Bromide
Various
Alternatives**
Yield
Loss
(%)
0%
5%
Yield
per
Hectare
Conifer
Seedlings
144,920
137,674
*
Price
per
Unit
(
U.
S.
$/
seedling)
$
0.97
$
0.97
=
Gross
Revenue
per
Proportion
(
60%)
$
140,956
$
133,908
­
Operating
Cost
per
Hectare
(
U.
S.
$)
$
37,311
$
58,414
=
Net
Revenue
per
Hectare
(
U.
S.
$)
$
103,645
$
75,494
Loss
Measures
1.
Loss
per
Hectare
(
U.
S.
$)
$
0
$
28,151
2.
Loss
per
Kilogram
of
Methyl
Bromide
(
U.
S.
$)
$
0
$
143.52
3.
Loss
as
a
Percentage
of
Gross
Revenue
(%)
0%
21%
4.
Loss
as
a
Percentage
of
Net
Revenue
(%)
0%
37%
**
The
category
Various
Alternatives
includes
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.

SUMMARY
OF
ECONOMIC
FEASIBILITY
An
economic
assessment
was
made
for
three
technically
feasible
in­
kind
(
chemical)
alternatives
for
the
forest
seedlings
sector:
dazomet,
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin.
The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
MB
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
Page
63
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
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.

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

(
1)
Losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
Absolute
losses
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.

(
3)
Losses
per
kilogram
of
MB
requested.
This
measure
indicates
the
value
of
MB
to
crop
production
but
is
also
useful
for
structural
and
post­
harvest
uses.

(
4)
Losses
as
a
percent
of
net
revenues.
We
define
net
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.

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

Economic
reviewers
analyzed
potential
economic
losses
from
using
dazomet,
1­
3
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin
because
they
are
currently
considered
technically
feasible
alternatives
for
nursery
seedlings
production.

Total
losses
are
similar
for
both
1­
3­
D
+
chloropicrin
and
metam­
sodium
+
chloropicrin.
Quantifiable
losses
originate
from
yield
losses
and
cost
increases.
Dazomet
has
slightly
higher
yield
losses
than
1­
3­
D
+
chloropicrin,
and
metam­
sodium
+
chloropicrin,
but
similar
treatment
costs.
Indirect
yield
losses
occurred
due
to
lengthening
of
the
production
cycle,
which
resulted
in
less
land
in
production
and
more
in
fallow
or
longer
time
for
seedlings
to
reach
appropriate
size.
Additional
losses
may
also
arise
due
to
a
shift
from
high
quality
Grade
#
1
seedlings
to
lower
quality
Grade
#
2,
which
causes
a
loss
of
about
30%
of
value,
and
more
seedlings
that
must
be
culled.
Unfortunately,
data
were
lacking
to
measure
this
shift.
Thus,
total
losses
are
underestimated.

Tables
E.
1
­
E.
8
provides
a
summary
of
the
estimated
economic
losses.
A
measure
of
net
revenue
loss
may
not
be
completely
accurate
partly
because
many
nurseries
are
publicly
owned
and
seedling
prices
or
production
costs
are
subsidized.
Although
attempts
were
made
to
Page
64
appropriately
value
the
seedlings
at
a
true
market
price,
losses
as
a
percentage
of
gross
revenues
and
of
net
revenue
should
be
viewed
with
caution.
Direct
yield
losses
are
similar
across
the
regions,
mainly
because
the
same
studies
were
used
to
predict
impacts.
The
range
of
losses
in
the
studies
is
rather
large
because
both
dazomet
and
metam­
sodium
provide
inconsistent
pest
control.
Indirect
losses
arising
from
shifts
in
the
production
cycle
were
not
quantified.
In
the
Northern
region
this
impact
is
expected
to
be
more
pronounced
due
to
cooler
temperatures
and
longer
time
required
for
production
of
a
seedling
crop.
Changes
in
production
costs
arise
due
to
differences
between
the
costs
of
methyl
bromide
and
the
alternatives,
shifts
in
the
production
cycle
(
increasing
the
frequency
of
fumigation
or
lengthening
the
fallow
period)
and
additional
expenses
such
as
supplementary
irrigation.
These
costs
vary
across
regions
and
within
the
Western
region,
which
is
highly
diverse,
because
of
differences
in
pests,
production
systems
and
regional
differences
in
costs
of
water
and
labor.
Costs
are
higher
in
the
South,
in
part
because
warmer
temperatures
increase
pest
pressure.

Michigan
Herbaceous
Perennials
Michigan
herbaceous
perennials,
labeled
Region
H
above,
comprise
three
categories
of
production
systems
with
numerous
plant
varieties
grown
within
each
category.
These
categories
are
2­
year
seeded
(
6%
of
plants),
2­
year
transplanted
(
29%
of
plants),
and
3­
year
transplanted
(
65%
of
plants).
To
represent
growing
conditions
on
a
typical
hectare
of
production,
and
to
account
for
the
fact
that
each
category
has
different
revenues
and
costs
of
production,
the
above
measures
were
calculated
using
representative
revenues
and
costs
for
each
category;
these
were
weighted
by
the
proportion
of
total
production.
In
addition,
various
combinations
of
alternative
pest
control
measures
would
need
to
be
employed
to
accomplish
the
most
effective
and
lowest
cost
pest
control
without
MB.
These
various
alternative
pest
control
measures
include
physical
removal
and
sanitation,
the
use
of
artificial
media,
and
soil
treatment
with
1,3­
D
+
chloropicrin.

If
growers
switch
to
MB
alternatives,
their
losses,
in
terms
of
MB
per
kilogram
no
longer
used,
would
be
the
largest
of
the
forest
seedlings.
Based
on
the
economic
impact
of
switching
to
MB
alternatives,
the
U.
S.
believes
that
current
alternatives
to
MB
are
not
economically
feasible
and
growers
of
herbaceous
perennials
have
a
critical
need
for
MB.
Page
65
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Because
of
high
costs
associated
with
forest
seedlings
considerable
resources
have
been
spent
examining
methods
to
reduce
costs
and
improve
efficiency
in
seedling
production.
The
Southern
Forest
Nursery
Management
Cooperative
has
spent
$
1.2
million
on
MB
alternatives
since
1992.
This
is
significant,
since
several
of
the
nurseries
are
publicly
owned
and
have
limited
resources
for
independent
research.
Research
has
included
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
(
two
year
cover
crops 
see
International
Paper
request
CUE
03­
0007)
to
MB,
including
some
potential
alternatives
that
are
not
currently
listed
by
MBTOC,
including
combinations
of
chemicals
such
as
1,3­
D,
chloropicrin,
metamsodium
and
methyl
iodide
(
not
currently
registered
in
the
U.
S.).
Development
of
technologies
to
improve
efficacy
of
alternatives
are
underway
and
include
work
with
deep
injection
application
methods,
soil
moisture
management
by
improving
drip
technologies,
and
trials
with
VIF
to
increase
efficacy
and
decrease
emissions
while
allowing
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
The
Michigan
Field
Grown
Herbaceous
Perennial
Growers
Association
is
currently
assisting
in
field
trials
with
Michigan
State
University
in
research
supported
in
part
by
the
USDA
MB
Alternatives
Grant
Program.
For
2002­
2004,
$
68,979
has
been
allocated
for
weed
and
nematode
studies
and
$
370,701
has
been
granted
for
a
study
that
runs
from
2003­
2006.
This
work
is
a
large
investment
in
identifying
alternatives
for
Michigan
growers.

One
difficulty
in
identifying
alternatives
to
MB
is
that
information
obtained
from
research
plots
must
be
transferred
to
large­
scale
commercial
production
requirements.
Fumigants
applied
to
small
plots
may
not
exhibit
similar
effects
when
applied
to
commercial
seedling
beds.
Overall,
especially
for
nurseries
with
high
pest
pressure,
protocols
for
alternative
chemicals
have
not
been
sufficiently
developed
to
provide
consistent
and
effective
production
results.
Continued
research
on
alternatives
that
will
be
adaptable
to
large­
scale
applications
will
shift
the
industry
to
MB
alternatives.

Weyerhaeuser
Corporation,
one
of
the
largest
growers
of
forest
seedlings,
suggested
their
preference
for
MB
alternatives
(
in
descending
order):
1)
chloropicrin,
340
kg/
ha;
2)
1,3­
D
at
260
kg/
ha
+
chloropicrin
at
140
kg/
ha;
3)
metam­
sodium,
(
485
kg/
ha)
and
chloropicrin
(
115
kg/
ha);
4)
dazomet,
400
kg/
ha;
5)
non­
chemical
treatments
such
as
steam;
6)
biological
control
agents.
Page
66
24.
ARE
THERE
PLANS
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

Plans
to
reduce
MB
in
formulations
to
50%
mixed
with
chloropicrin
are
already
underway,
even
though
nurseries
currently
use
MB
only
once
in
three
to
four
years
on
a
particular
bed.
Reduction
in
MB
may
be
achieved
with
use
of
VIF
if
technological
and
cost
issues
can
be
resolved
(
Carey
and
Godbehere,
2004).
Weed
management
is
the
issue
of
most
concern
by
most
nurseries
and
work
is
ongoing
to
study
the
strategic
use
of
herbicides
(
e.
g.,
$
370,701
USDA
grant
for
MB
alternatives
research
by
Michigan
State
University
that
will
test
numerous
herbicides
and
other
weed
control
methods).
Also
cultural
practices
are
being
examined
to
increase
mechanical
cultivation
and/
or
soil
amendments
and
fertilizers
to
maximize
productivity
and
reduce
reliance
on
MB.
Development
of
predictive
models
to
strategically
determine
when
fumigation
is
appropriate
can
reduce
overall
use
of
fumigants
(
e.
g.,
Fraedrich
and
Dwinell,
1998).
As
stated
in
Section
23,
minimizing
use
of
MB
can
be
achieved
through
the
development
of
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
experience
with
virtually
impermeable
films
to
increase
efficacy
and
decrease
emissions,
and
still
have
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

The
MB
critical
use
exemption
nomination
for
Forest
Seedlings
has
been
reviewed
by
the
U.
S.
Environmental
Protection
Agency
and
the
U.
S.
Department
of
Agriculture
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
nomination
includes
requests
for
MB
only
for
those
nurseries
where
sufficient
pest
control
can
not
be
achieved
otherwise.
This
use
is
considered
critical
because
there
are
conditions
in
some
nurseries
within
this
sector
with
high
pest
pressure
where
no
feasible
alternatives
are
currently
effective.
High
production
nurseries
require
a
consistent
and
reliable
pre­
plant
fumigation
treatment
that
will
allow
production
goals
to
be
met.
Currently
MB
is
the
only
consistent
provider
of
this
requirement
for
nurseries
with
severe
pest
infestations
and
where
other
treatments
are
not
effective.
The
loss
of
MB,
therefore,
would
result
in
a
significant
market
disruption.
The
effort
to
avoid
market
disruption
provides
the
basis
for
nomination
of
this
sector
for
critical
use
exemption
of
MB.

26.
CITATIONS
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J.
P.
and
McGilvrary,
J.
M.
1997.
Practical
guidelines
for
producing
longleaf
pine
seedlings
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Gen.
Tech.
Rep.
SRS­
14.
Asheville,
NC.
U.
S.
Department
of
Agriculture,
Forest
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Southern
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28
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http://
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org/
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html
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S.
J.
and
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B.
R.
1988.
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Carey,
W.
A.
2000.
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as
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67
Carey,
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A.
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Carey,
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Cram,
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2003
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02.

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Tree
planting
in
the
United
States,
1998.
Tree
Planters
Notes
V49(
2).
USDA
Forest
Service.
pp
1­
36.

Rimini,
R.
and
Wigley,
S.
2004.
VIF:
A
supplier's
view.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2004).
http://
mbao.
org/

Royer,
J.
P.
1987.
Determinants
of
reforestation
behavior
among
southern
landowners.
Forest
Science
33(
3)
654­
667.
Page
69
Stone,
J.
K.,
Hildebrand,
D.
M.,
James,
R.
L.,
Frankel,
S.
M.
1998.
Alternatives
to
methyl
bromide
fumigation
for
control
of
soil
borne
diseases
in
bareroot
forest
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
1998).
http://
mbao.
org/

USDA­
APHIS
(
Animal
and
Plant
Health
Inspection
Service),
Plant
Protection
and
Quarantine.
2002.
Sudden
Oak
Death.
http://
www.
aphis.
usda.
gov/
ppq/
ispm/
sod/

Weyerhaeuser
In­
house
Research
Study
2
(
Bonanza
Nursery,
Molin,
Oregon).
1980.
MBchloropicrin
(
spring
and
fall),
Vorlex
(
MITC+)
and
Vapam
(
metam
sodium)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
3
(
Mima
Nursery,
Olympia,
Washington).
1984­
1987.
MB­
chloropicrin,
Basamid
(
dazomet)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
4
(
Mima
Nursery,
Olympia,
Washington).
1985­
1987.
MB­
chloropicrin,
Basamid
(
dazomet),
soil
preparation
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
5
(
Mima
Nursery,
Olympia,
Washington).
1985­
1987.
MB­
chloropicrin,
Basamid
(
dazomet)
rate
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
6
(
Aiken
Nursery,
Aiken,
South
Carolina).
1992.
MBchloropicrin
Basamid
(
dazomet),
Busan
(
metam­
sodium)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
7
(
Fort
Towson
Nursery,
Ft.
Towson,
Oklahoma).
1994­
1996.
MB­
chloropicrin
alternatives
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
8
(
Magnolia
Nursery,
Magnolia,
Arkansas).
1992­
1995.
MB­
chloropicrin
alternatives
trial.
2002
CUE
request
package
and
Appendices
A
and
C,
2003
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
9
(
G.
H.
W.
Nursery,
Washington,
North
Carolina).
1994­
1995.
Basamid
(
dazomet)
trial.
2002
CUE
request
package.

Weyerhaeuser
In­
house
Research
Study
10
(
G.
H.
W.
Nursery,
Washington,
North
Carolina).
1994­
1996.
Alternative
fumigant
trial.
2002
CUE
request
package.
Page
70
APPENDIX
A.
Estimated
Costs
Of
Converting
A
Loblolly
Forest
Tree
Seedling
Nursery
From
Soil­
Based
To
Containerized
Soilless
Culture1
The
costs
below
are
based
on
the
conversion
of
a
10
million
bareroot
seedling,
soil­
based,
nursery
[
typical
nurseries
in
the
southern
U.
S.
can
produce
20­
60
million
bareroot
seedlings]
to
a
container,
soilless,
nursery
for
the
raising
of
Loblolly
pine
seedlings
in
the
southern
USA.
The
cost
estimates
include
estimates
of
additional
expenditures
(
over
and
above
$.
04
per
seedling
cost
for
soil­
based
system)
for:

A.
Capital
Infrastructure
B.
Operating
Costs
Limitations
of
analysis:
There
are
also
expected
to
be
additional
shipping
costs,
due
to
the
larger
size
and
weight
of
containerized
plants,
but
estimating
these
costs
were
beyond
the
scope
of
this
analysis.
Economy
of
scale
can
be
significant
and
regional
costs
vary,
making
it
difficult
to
provide
a
precise
cost.

Additional
note:
The
capital
costs
associated
with
conversion
from
a
soil­
based
to
a
soilless
nursery
are
much
less
than
the
capital
costs
of
establishing
a
new
soilless
nursery.
All
of
the
basic
infrastructure
and
much
of
the
equipment
would
already
be
in
place
with
a
soil­
based
nursery.

A.
Capital
Infrastructure:
Many
of
the
facilities
required
for
the
operation
of
a
soil­
based
seedling
nursery
are
required
for
a
soilless
nursery,
so
conversion
costs
and
the
conversion
costs
are
Conversion
cost:
Water
supply
$
0
Power
$
0
Buildings
$
0
Landscaping/
leveling/
roads
$
0
Equipment
­
assuming
no
trade­
ins
$
100,000
Nursery
structures
+
irrigation
$
130,000
B.
Operating
costs:
Working
capital
requirements
are
greater
in
a
soilless
nursery
than
a
soil­
based
nursery
as
more
labor
is
used.
The
cost
of
conversion
from
a
soil­
based
nursery
to
a
soilless
nursery
should
include
the
need
for
additional
working
capital.

Working
capital:
Additional
container
system
cost
$
150,000
(
Over
and
above
~$
50,000
cost
for
soil­
based
system)
Containers
$
410,000
Page
71
C.
Land
The
soil­
based
nursery
requires
13.3
hectares
exclusive
of
buildings,
storage
and
administrative
area.
The
soilless
nursery
requires
4
hectares
for
the
same
production.

Assuming
the
soil­
based
nursery
owner
is
able
to
sell
or
exchange
the
surplus
land,
the
change
from
soil­
based
to
soilless
will
be
a
source
of
revenue.
A
review
of
land
prices
in
the
southern
USA,
in
localities
where
forest
tree
nurseries
are
situated
reveals
an
average
of
$
12,350
per
hectare.

Land
Savings:
Land
(
9.3
hectares
at
$
12,350
per
hectare)
($
114,855)

D.
Analysis
of
Net
Costs:
Converting
10
million
Seedling
Nursery
from
Bareroot
to
Containerized,
Soilless
Culture
Capital
Cost
Years
of
Use*
Annual
Cost
Cost
per
Seedling
EQUIPMENT
$
100,000
10
$
11,723
$
0.0012
Nursery
Structures
$
130,000
10
$
15,240
$
0.0015
Running
Container
System
$
150,000
$
0.015
Containers
$
410,000
$
0.041
Total
Additional
Cost**
$
586,963
$
0.059
Land
rent
savings***
($
3,450)
($
0.0003)

Net
additional
cost
$
0.0583
Base
production
cost
(
for
bareroot
and
soilless
system)
$
0.04
Total
Cost
per
Seedling
$
0.0983
*
Incorporates
real
interest
cost
at
3%
per
year.
**
Does
not
include
additional
cost
of
shipping
due
to
larger
and
heavier
containers.
***
Using
land
capitalization
rate
of
3%.

Conclusion:
Converting
to
a
soilless
containerized
system
would
increase
the
cost
of
production
by
approximately
250%,
and
could
be
higher
when
the
increased
cost
of
shipping
containerized
seedlings
is
included.

1
Based
on
communication
with
Kevin
Darrow,
Sept.
2002
Page
72
APPENDIX
B.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
51,506
2%

2001
&
2002
Average
%
of
Request
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

83,143
238
350
22,279
107
208
1,911
7
263
11,226
33
336
9,637
43
224
13,279
39
343
6,908
26
267
4,246
12
350
152,629
506
302
57%
52%
10%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
375
350
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

208
208
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

263
263
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

336
336
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

224
224
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

343
343
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

267
267
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

392
350
0
0
0
0
100
100
0
0
0
0
0
0
100%
100%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
(#
of
Times
per
Year)
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MB
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
No
Yes
Yes
Tarp
Yes
0
No
1x/
4years
3,449
$
37
$
10%
22%

No
Yes
Yes
Tarp
Yes
­
No
1x/
4years
3,536
$
68
$
11%
25%

No
Yes
Yes
Tarp
Yes
0
No
1x/
1year
7,776
$
30
$
4%
6%

No
Yes
Yes
Tarp
Yes
0
No
1x/
4years
1,578
$
19
$
6%
16%

No
Yes
Yes
Tarp
Yes
­
No
1x/
3years
2,124
$
24
$
11%
25%

No
Yes
Yes
Tarp
Yes
­
No
1x/
1­
3years
6,738
$
39
$
14%
42%

No
Yes
Yes
Tarp
Yes
­
No
1x/
3­
4years
5,365
$
60
$
4%
11%

No
Yes
Yes
Tarp
0
0
No
1x/
2­
3years
28,151
$
144
$
21%
37%

Notes:

1
Conversion
Units:
1
Pound
=
Kilograms
1
Acre
=
0.404686
Hectare
High
24%
Low
77%

metam/
Pic
or
1,3­
D/
Pic
metam/
Pic
or
1,3­
D/
Pic
metam/
Pic
1,3­
D/
Pic
metam/
Pic
or
1,3­
D/
Pic
1,3­
D/
Pic
metam/
Pic
or
1,3­
D/
Pic
metam/
Pic
or
1,3­
D/
Pic
3%
Yield
Loss
3%
Yield
Loss
3%
Yield
Loss
5%
Yield
Loss
0
3%
Yield
Loss
3%
Yield
Loss
3%
Yield
Loss
*
International
Paper
and
Weyerhaeuser
(
SE)
were
included
in
the
Southern
Forest
Nursery
Management
Cooperative,
therefore
they
were
removed
from
the
Southern
Forest
Cooperative
application
as
double
counting.

0.453592
EPA
believes
that
Michigan
Seedling
Association
and
Michigan
Herbaceous
Perennials
have
already
subtracted
their
QPS
amounts
from
their
application
and
their
application
reflects
methyl
bromide
critical
use
for
crops
that
do
not
fall
under
QPS
requirements.
All
other
applications
are
adjusted
for
EPA
QPS
estimates.
Most
Likely
Impact
Value:

Southern
Forest
Nursery
Mgmt
Coop.

International
Paper
Illinois
Department
of
Natural
Resources
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)

NE
Forest
&
Conservation
Nursery
Assoc.

Michigan
Seedling
Association
Michigan
Herbaceous
Perennials
REGION
Quality/
Time/
Market
Window/

Yield
Loss
(%)
Marginal
Strategy
Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
NE
Forest
&
Conservation
Nursery
Assoc.

Michigan
Seedling
Association
Michigan
Herbaceous
Perennials
International
Paper
Illinois
Department
of
Natural
Resources
Weyerhaeuser
(
SE)

Weyerhaeuser
(
NW)
Cold
Soil
Temp
(%)

Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
ha)

Southern
Forest
Nursery
Mgmt
Coop.

REGION
(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)

(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
25%
57%
57%
57%

%
Reduction
from
Initial
Request
0%
19%
21%
268,049
152,629
152,629
152,629
Nomination
Amount
355,166
287,473
280,618
517
­
4,246
4,246
Michigan
Herbaceous
Perennials
4,763
­
­
­
­
6,908
6,908
Michigan
Seedling
Association
6,908
­
­
­
13,279
13,279
13,279
NE
Forest
&
Conservation
Nursery
Assoc.
31,922
­
5,363
­
6,250
9,637
9,637
Weyerhaeuser
(
NW)
16,935
­
1,049
­
6,736
11,226
11,226
Weyerhaeuser
(
SE)
17,962
­
­
­
1,911
1,911
1,911
Illinois
Department
of
Natural
Resources
4,264
­
442
­
4,101
22,279
22,279
International
Paper
26,380
­
­
12,052
83,143
83,143
83,143
Southern
Forest
Nursery
Mgmt
Coop.
246,032
67,693
­
(­)
Use
Rate
Adjustment
(­)
QPS
HIGH
LOW
REGION
2007
Request
(­)
Double
Counting
(­)
Growth
2007
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)
MOST
LIKELY
IMPACT
VALUE
50,723
129
392
0%

412,167
1,148
359
30%

TOTAL
OR
AVERAGE
355,166
1,059
335
Michigan
Herbaceous
Perennials
4,763
12
392
35
269
0%

Michigan
Seedling
Association
6,908
26
267
9,417
NE
Forest
&
Conservation
Nursery
Assoc.
31,922
93
343
26,558
76
349
50%

15,886
67
236
39%

Weyerhaeuser
(
NW)
16,935
76
224
Weyerhaeuser
(
SE)
17,962
53
336
22,970
63
367
38%

3,822
15
263
50%

Illinois
Department
of
Natural
Resources
4,264
16
263
International
Paper
26,380
127
208
36,759
108
341
16%

246,032
656
375
50%

Southern
Forest
Nursery
Mgmt
Coop.
246,032
656
375
2007
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment1
REGION
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

Methyl
Bromide
Critical
Use
Exemption
Process
Date:
1/
28/
2005
Average
Hectares
in
the
US:

2007
Methyl
Bromine
Usage
Numerical
Index
(
BUNI)
Sector:
FOREST
SEEDLINGS
%
of
Average
Hectares
Requested:

Combined
Impacts
(%)

Regional
Hectares**

Not
Available
Research
Amount
(
kgs)

0
Page
73
Footnotes
for
Appendix
B:
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
Page
74
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
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.
Page
75
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.
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.
