METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
PEPPERS
GROWN
IN
OPEN
FIELDS
ON
PLASTIC
TARPAULINS
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
Peppers
Grown
in
Open
Fields
on
Plastic
Tarpaulins
(
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.
Pepper
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.
Pepper
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
_________________________________________________
9
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
9
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
13
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
13
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
14
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
15
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
______________
15
Michigan
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
15
Michigan
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
16
Michigan
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
17
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________
18
Michigan
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
18
Michigan
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
22
Michigan
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
22
Michigan
­
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
___
22
Michigan
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
24
Michigan
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
24
Michigan
­
Summary
of
Technical
Feasibility
____________________________________
25
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_____________________________________
26
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request____
26
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
11.
Characteristics
of
Cropping
System
and
Climate
________________________________________________
27
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____________________________________________________
29
SOUTHEAST
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
________________________________________________________________
30
U.
S.
Pepper
iv
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_______________________________________________
30
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
______________________________________
34
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________
35
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
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
___________________________
36
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?_________________________________________________________________
38
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
39
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
 
Summary
of
Technical
Feasibility
________________________________________________________________
39
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
41
Georgia
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
41
Georgia
­
11.
Characteristics
of
Cropping
System
and
Climate_______________________
41
Georgia
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
44
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
45
Georgia
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________
45
Georgia
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
49
Georgia
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
50
Georgia
­
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
___
50
Georgia
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
51
Georgia
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
52
Georgia
­
Summary
of
Technical
Feasibility
_____________________________________
52
FLORIDA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE________________
54
Florida
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
54
Florida
­
11.
Characteristics
of
Cropping
System
and
Climate
_______________________
54
Florida
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
56
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
57
Florida
­
13.
Reason
for
Alternatives
Not
Being
Feasible
___________________________
57
U.
S.
Pepper
v
Florida
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
61
Florida
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
62
Florida
­
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
___
62
Florida
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
63
Florida
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
64
Georgia
­
Summary
of
Technical
Feasibility
_____________________________________
64
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________
66
California
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
66
California
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
66
California
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
67
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
____________________________________
69
California
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
69
California
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
71
California
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
71
California
­
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
___
72
California
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
73
California
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
73
California
­
Summary
of
Technical
Feasibility
___________________________________
73
PART
D:
EMISSION
CONTROL
___________________________________________________
74
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
74
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
75
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
76
21.
Operating
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
___
76
22.
Gross
and
Net
Revenue___________________________________________________
78
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
79
Summary
of
Economic
Feasibility
_____________________________________________
81
PART
F.
FUTURE
PLANS
_______________________________________________________
84
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
84
U.
S.
Pepper
vi
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
85
25.
Additional
Comments
on
the
Nomination
____________________________________
85
26.
Citations
______________________________________________________________
86
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).________________
91
APPENDIX
B.
2006
Methyl
Bromide
Reconsideration
for
Peppers.___________________
95
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
9
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
9
Table
A.
1:
Executive
Summary
_________________________________________________
12
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
13
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
14
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
15
Michigan
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
15
Michigan
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
16
Michigan
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
16
Michigan
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
18
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION________________________________________
18
Michigan
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
19
Michigan
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
22
Michigan
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
24
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________________________
26
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____________________________
26
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
Table
11.1:
Characteristics
of
Cropping
System
______________________________________________________
27
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
 
January
Fumigation
(
Spring,
Early
Summer
Harvest)
__
27
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
Table
11.3
Characteristics
of
Climate
and
Crop
Schedule
 
Spring
Fumigation
(
Fall
Harvest)__________________
27
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________________________________
29
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________________________________
30
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
_____________________________________________
30
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________________________________
34
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
 
Table
15.1:
Present
Registration
Status
of
Alternatives
for
Peppers
_________________________________
35
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
Table
16.1.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato_________________
36
U.
S.
Pepper
vii
Southeast
U.
S.
Pepper
Consortium
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
____
37
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
41
Georgia
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
___
41
Georgia
­
Table
11.1:
Characteristics
of
Cropping
System
____________________________
41
Georgia
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
 
July
Fumigation
Event,
Pepper
Crop
is
Harvested
in
Fall
____________________________________________
42
Georgia
­
Table
11.3
Characteristics
of
Climate
and
Crop
Schedule
 
Spring
(
Late
February
 
March)
Fumigation
Event,
Pepper
Crop
is
Harvested
in
Early
Summer
______________
42
Georgia
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_______________________
44
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION_________________________________________
45
Georgia
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible______________________
45
Georgia
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________
49
Georgia
 
Table
15.1:
Present
Registration
Status
of
Alternatives
for
Peppers
_____________
50
Georgia
Table
16.1.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
________________________________________________________________
50
Georgia
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary__________________________
51
FLORIDA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
54
Florida
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____
54
Florida
­
Table
11.1:
Characteristics
of
Cropping
System
_____________________________
54
Florida
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_____________________
55
Florida
­
Table
11.3
Characteristics
of
Climate
and
Crop
Schedule
 
Peppers
Double
Cropped
with
another
Vegetable
Crop
(
usually
Cucurbits)
_______________________________
55
Florida
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________
56
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION
_________________________________________
57
Florida
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
______________________
57
Florida
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion____________________
61
Florida
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_______________________
62
Florida
­
Table
16.1.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
________________________________________________________________
62
Florida
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
__________________________
63
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________________
66
California
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request__
66
California
­
Table
11.1:
Characteristics
of
Cropping
System___________________________
66
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
67
California
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____________________
68
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
69
California
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
69
California
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
72
California
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
72
PART
D:
EMISSION
CONTROL
____________________________________________________
74
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
74
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
76
Table
21.1:
Peppers
 
Operating
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_____________________________________________________________
77
Table
22.1:
Peppers
­
Year
1,
2,
and
3
Gross
and
Net
Revenues
________________________
78
California
Pepper
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives_________
79
U.
S.
Pepper
viii
Florida
Pepper
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
___________
79
Georgia
Pepper
 
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
__________
80
Michigan
Pepper
­
Table
E.
4:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
80
Southeastern
USA
(
except
Georgia)
Pepper
­
Table
E.
5:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________________________________________________
81
PART
F.
FUTURE
PLANS
________________________________________________________
84
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
__________________
91
U.
S.
Pepper
Page
9
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Peppers
Grown
in
Open
Fields
on
Plastic
Tarpaulins
(
Prepared
in
2005)

3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Peppers
grown
in
Alabama,
Arkansas,
California,
Florida,
Georgia,
Kentucky,
Louisiana,
Michigan,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia.
These
crops
are
grown
in
open
fields
on
plastic
tarps,
often
followed
by
various
other
crops.
Harvest
is
destined
for
the
fresh
market.

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

2007
1,151,751
7,343
 
This
amount
includes
2,844
kg
for
research.

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
suitable.
In
U.
S.
pepper
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
Pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
pepper
production.
­
Geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
peppers
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
U.
S..
­
Regulatory
constraints:
e.
g.,
1,3
D
use
is
limited
in
Georgia
and
Florida
due
to
the
presence
of
karst
geology.
­
Potential
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
1,3
D
+
Chloropicrin
may
be
up
to
two
weeks
longer
than
methyl
bromide
+
chloropicrin.
In
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
may
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
U.
S.
Pepper
Page
10
Michigan,
California,
Florida,
Southeastern
U.
S.
(
except
Georgia
and
Florida)
are
each
presented
as
separate
regions
in
this
nomination
to
reflect
the
separate
applications
from
growers
in
these
areas.
A
brief
description
of
their
need
for
MB
follows,
also
presented
on
a
regional
basis.

Michigan
The
key
pest
of
peppers
in
Michigan
is
the
soil
fungi
Phytophthora
capsici,
which
can
easily
destroy
the
entire
harvest
from
affected
areas
if
left
uncontrolled.
While
1,3­
D
+
chloropicrin
provided
some
control
in
small
plot
trials
with
peppers
and
other
vegetable
crops
in
Michigan
(
Hausbeck
and
Cortright
2003),
the
level
of
control
was
lower
than
that
afforded
by
MB.
P.
capsici
has
recently
been
shown
to
also
occur
in
irrigation
water
in
Michigan
(
Gevens
and
Hausbeck
2003).
This
will
increase
the
likelihood
of
spread
of
this
pathogen.
It
is
also
not
yet
clear
whether
these
small­
scale
research
results
accurately
reflect
efficacy
of
MB
alternatives
in
pepper
production.
Furthermore,
regulatory
restrictions
due
to
concerns
over
human
exposure
and
ground
water
contamination,
along
with
technical
limitations,
result
in
potential
economic
infeasibility
of
this
formulation
as
a
MB
alternative.
Among
the
more
important
ones
are
a
potential
delay
in
planting
as
long
as
28
days,
(
which
could
lead
to
missing
a
key
market
window)
due
to
label
restrictions
and
low
soil
temperatures,
and
a
mandatory
30
meter
buffer
for
treated
fields
near
inhabited
structures.

Based
on
the
small­
plot
trial
conducted
on
Michigan
peppers
(
cited
above),
the
best­
case
yield
loss
estimate
for
Michigan
using
the
best
available
MB
alternative
(
1,3­
D
+
chloropicrin)
was
estimated
to
be
6
%,
based
on
plant
loss.
In
a
second
trial
undertaken
by
Hausbeck
and
Cortright
(
2004),
yields
from
pepper
plots
treated
with
metam
potassium,
alone
or
in
combination
with
chloropicrin,
and
from
plots
treated
with
1,3­
D
+
chloropicrin
were
comparable
to
yields
from
plots
treated
with
MB
+
chloropicrin
and
yields
from
untreated
(
control
plots).
These
results
Likely
indicate
a
very
low
pest
pressure
in
all
treated
and
control
plots.

Michigan
pepper
farmers
requesting
MB
must
plant
by
the
first
week
of
May
to
capture
an
early
market
window.
Soil
fumigation
must
therefore
be
completed
by
mid
April
to
allow
14­
21
days
for
aeration.
However,
1,3­
D
and
metam
labels
recommend
that
applications
be
made
when
soil
temperatures
(
at
application
depth)
are
above
4.4
°
C.
Furthermore,
optimum
soil
temperatures
for
1,3­
D
are
in
the
10
°
C
­
25
°
C
range
(
University
of
California,
Davis,
undated).
Since
soil
temperatures
in
Michigan
do
not
climb
over
10
°
C
until
after
mid
to
late
May
(
Schaetzl
and
Tomczak,
2001),
neither
1,3­
D
nor
metam
products
can
be
used
effectively
for
early
pepper
planting
in
Michigan.
Metam
products
have
the
additional
disadvantage
that
when
the
soil
is
wet
and
cold
(
below
15
°
C),
the
minimum
recommended
plant
back
period
is
30
days,
which
would
push
the
crop
beyond
the
early
market
window.

California
The
California
peppers
situation
is
similar
to
Michigan's
in
that
the
critical
pest
controlled
by
MB
is
P.
capsici.
The
other
important
pest
targeted
by
MB
use
in
this
region
is
the
root
knot
nematode.
California
is
requesting
MB
for
about
10
%
of
its
pepper
area,
mainly
along
the
coast.
As
in
Michigan,
climatological
conditions
in
these
coastal
areas
­
primarily
long
periods
of
rainy,
cloudy
weather
 
exacerbate
problems
involving
the
use
of
MB
alternatives,
particularly
U.
S.
Pepper
Page
11
formulations
of
1,3
D,
which
cannot
be
used
when
soils
are
very
wet.
Growers
are
also
reporting
lack
of
efficacy
against
both
of
these
pests
at
the
maximum
label
rates
for
this
alternative.
In
addition,
California
has
township
caps
that
limit
the
amount
of
1,3­
D
that
can
be
applied
in
a
given
area,
as
well
as
100
meter
buffer
zones
near
inhabited
structures.
Urban
encroachment
is
increasing
dramatically
in
California
coastal
counties,
making
the
buffer
zone
requirement
more
prevalent.
These
conditions
are
present
in
the
10%
of
California
pepper
production
area
that
need
MB.

Southeastern
United
States
(
Including
Florida
and
Georgia)

In
the
Southeastern
United
States,
including
Florida
and
Georgia,
MB
is
requested
primarily
for
control
of
moderate
to
severe
infestations
of
nutsedge
weeds.
P.
capsici
is
also
an
important
pest
targeted
currently
with
MB
in
these
regions.
Many
growers
also
use
MB
against
root­
knot
nematodes.
Left
uncontrolled,
any
of
these
pests
could
completely
destroy
the
harvests
from
affected
areas.

Of
currently
available
MB
alternatives,
metam­
sodium
offers
inconsistent
control
of
nutsedges
and
nematodes,
while
1,3­
D
+
chloropicrin
provides
adequate
control
of
nematodes
and
disease
(
Locascio
et
al.
1997,
Eger
2000,
Noling
et
al.
2000).
However,
metam­
sodium
has
yield
losses
of
up
to
44
%
compared
to
MB
where
weed
infestations
are
moderate
to
severe
(
Locascio
et
al.
1997).
Metam­
sodium
also
creates
a
planting
delay
as
long
as
30
days
to
avoid
risk
of
phytotoxic
injury
to
crops
compared
to
a
14­
day
delay
for
MB.
Furthermore,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology,
and
anywhere
in
Dade
County,
Florida,
where
the
majority
of
that
region's
peppers
are
grown.
There
is
also
a
28
day
planting
delay
due
to
regulatory
restrictions
for
1,3­
D
+
chloropicrin.
In
Florida
particularly,
growers
are
on
a
tight
production
schedule
and
must
place
pepper
transplants
in
fields
at
a
certain
time
of
the
year
(
see
Table
11.2
in
the
Florida
section
for
details).
Relying
only
on
metam
sodium
for
preplant
treatment
would
force
growers
to
fumigate
earlier
in
their
season,
which
in
turn
would
extend
the
fumigation
schedule
into
rainy
periods.
Growers
would
have
to
fumigate
earlier
to
avoid
rain
and
lose
a
portion
of
the
crop
(
Aerts,
2004).

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

In
a
recent
field
study
conducted
in
Tifton,
Georgia
by
Culpepper
and
Langston
(
2004),
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin,
was
more
effective
than
MB
against
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
Although
this
treatment
performed
as
well
as
MB
in
terms
of
spring
pepper
yield,
its
fall
yield
performance
was
inferior
to
that
of
MB.

In
a
second
treatment,
1,3­
D
by
itself,
followed
by
chloropicrin,
was
significantly
less
effective
U.
S.
Pepper
Page
12
than
methyl
bromide
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
pepper
yield,
however,
this
treatment
performed
as
well
as
MB.

In
a
third
treatment,
1,3­
D
+
chloropicrin,
followed
by
metam
sodium,
was
as
effective
as
MB
against
yellow
nutsedge,
36%
less
effective
than
MB
against
purple
nutsedge,
and
as
effective
as
MB
for
the
control
of
soil
nematodes.
This
treatment
also
performed
as
well
as
MB
in
terms
of
both
spring
and
fall
pepper
yield.

Although
these
combinations
are
showing
promise,
they
will
require
further
testing
and
validation.

In
sum,
although
promising,
these
MB
alternatives
require
further
testing
and
validation
at
the
commercial
level
before
being
available
for
adoption
by
pepper
growers.
Threfore,
MB
remains
a
critical
use
for
peppers
in
the
United
States.

TABLE
A.
1:
EXECUTIVE
SUMMARY.

Region
Michigan
Southeastern
U.
S.
except
Georgia
and
Florida
Georgia
Florida
California
AMOUNT
OF
APPLICANT
REQUEST
2007
Kilograms
15,195
240,086
347,183
1,415,207
136,078
AMOUNT
OF
NOMINATION*

2007
Kilograms
11,396
66,089
178,778
880,121
12,522
*
See
Appendix
A
for
a
complete
description
of
how
the
nominated
amount
was
calculated.
U.
S.
Pepper
Page
13
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

For
Michigan
pests
1,3
D
+
chloropicrin
is
the
only
key
alternative
with
efficacy
comparable
to
MB.
Regulatory
restrictions
due
to
human
exposure
concerns,
combined
with
technical
limitations,
reduce
its
use.
Key
among
these
factors
are
a
potential
delay
in
planting
as
long
as
28
days,
due
both
to
label
restrictions
and
low
soil
temperatures,
and
mandatory
30
to
100
meter
buffers
for
treated
fields
near
inhabited
structures.

For
the
Southeastern
United
States,
including
Florida
and
Georgia,
an
application
of
1,3­
D
+
chloropicrin
(
Telone
C35),
along
with
a
herbicide
mix
(
e.
g.
clomazone
+
metolachlor)
applied
at
bed
formation,
or
Telone
C35
followed
by
a
chloropicrin
or
a
metam
application,
may
be
the
best
available
BM
alternatives
outside
karst
geology
areas.
In
karst
geology
areas,
including
31
counties
in
Florida,
where
Telone
use
is
highly
restricted,
metam
sodium
or
metam
potassium
remain
at
present
the
best
alternatives.
Although
promising,
these
alternatives
will
require
further
testing
and
validation
on
commercial
fields.

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

All
other
available
MB
alternatives
are
currently
technically
infeasible
for
U.
S.
peppers.

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
2003
(
HA)
PROPORTION
OF
REQUEST
FOR
METHYL
BROMIDE
(%)
Michigan
816
16
Southeastern
U.
S.
except
Georgia
and
Florida
5806
16
Georgia
2889
79
Florida
7893
100
California
10659
7
NATIONAL
TOTAL*
24954
50
*
Includes
States
not
requesting
MB.
U.
S.
Pepper
Page
14
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.

In
Michigan,
areas
not
treated
apparently
do
not
have
any
infestation
(
i.
e.,
zero
oospores
per
unit
soil)
of
the
key
fungal
pests.
Applicant
states
that
soil
infestation
is
spreading
in
the
region
annually.
In
California,
areas
where
MB
is
not
used
rely
on
1,3D
+
chloropicrin
and
post­
emergence
fungicides
to
control
the
same
pests.

In
southeastern
U.
S.,
Florida,
and
Georgia,
areas
not
treated
do
not
have
nutsedges
or
nematodes
naturally
present
in
pepper
fields.
Simple
absence
of
all
pests
is
the
only
reason
these
areas
are
not
presently
treated
with
MB.

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?

No.
For
further
discussion
of
limitations
please
see
Part
5
(
above),
and
the
region­
specific
discussions
below.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
Michigan
Southeastern
U.
S.
except
Georgia
and
Florida
Georgia
Florida
California
YEAR
OF
EXEMPTION
REQUEST
2007
2007
2007
2007
2007
KILOGRAMS
OF
METHYL
BROMIDE
15,195
240,086
347,183
1,415,207
136,078
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Strip/
Bed
Strip/
Bed
Strip/
Bed
Strip/
Bed
Flat
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
or
50:
50
67:
33
67:
33
Mostly
67:
33
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
127
1,599
2,312
8,417
759
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
12.0
15.0
15.0
16.8
17.9
.
U.
S.
Pepper
Page
15
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
methyl
bromide
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.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
The
three
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Not
applicable
in
this
sector.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
regulatory
impacts,
karst
geology,
buffer
zones,
unsuitable
terrain,
and
cold
soil
temperatures.

MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
MICHIGAN
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
MICHIGAN
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Michigan
Crown
and
root
rots
caused
by
soilborne
fungus
Phytophthora
capsici.
Fumigation
operations
need
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
for
premium
prices,
as
well
as
ensuring
demand
for
their
crop
during
the
entire
growing
season
(
especially
during
the
mid
and
late
season).
U.
S.
Pepper
Page
16
MICHIGAN
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
MICHIGAN
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pepper
transplants
for
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual;
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Pepper
 
usually
followed
by
an
eggplant
or
pepper
crop
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam;
clay
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
every
2
years
OTHER
RELEVANT
FACTORS:
Key
marketing
opportunities
have
been
established
with
Michigan's
vegetable
crop
diversification
and
aims
toward
stable
demands
in
the
late
spring
and
through
the
summer
for
Midwestern
markets.

MICHIGAN
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
FOR
PEPPERS
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
Plant
Hardiness
zone
5b
SOIL
TEMP.
(
°
C)
<
10
10
­
15
15­
20
20­
25
20­
25
20­
25
20
10­
15
<
10
<
10
<
10
<
10
RAINFALL
(
mm)
40
72
101
48
47
32
17
31
36
20
6
8
OUTSIDE
TEMP.
(
°
C)
0.2
7.4
12.1
17.5
20.6
20.9
18.1
8
2.4
­
2.9
­
8
­
7
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
KEY
MARKET
WINDOW
X
X
X
X
U.
S.
Pepper
Page
17
MICHIGAN 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Michigan
experiences
heavy
rainfall
events
across
the
entire
state
at
any
given
moment
of
the
growing
season.
Heavy
rain
events
(
over
25
mm)
can
trigger
rapid
root
and
crown
rot
development,
and
promote
dissemination
of
P.
capsici
via
irrigation
sources
(
Gevens
and
Hausbeck
2003).
Generally,
there
is
no
difference
in
the
amount
of
infection
depending
on
soil
type.
The
pathogen
is
widespread
and
indigenous
on
almost
all
soil
types
in
Michigan
(
Cortright
2003,
Gevens
and
Hausbeck
2003).

Significant
rainfall
events
(>
25
mm)
or
cold
soil
temperatures
(<
4.4
°
C)
delay
fumigation
and
planting
with
the
MB
alternatives
1,
3
D
+
chloropicrin
and
metam­
sodium.
Also,
all
fumigation
practices
need
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
(
July­
September).

MICHIGAN
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
Growers
are
using
anti­
drip
valves
to
eliminate
loss
of
MB
at
the
end
of
rows
when
the
machinery
is
removed
from
the
ground.
Michigan's
use
of
MB
for
vegetable
production
has
declined
steadily
since
the
mid­
1990s,
when
growers
switched
to
different
application
methods
(
i.
e.
from
Flat
Fumigation
to
tarped
beds)
and
formulations
(
from
98
%
MB
to
67
%
MB).
Currently,
all
MB
is
applied
to
tarped
beds,
with
100%
of
low­
density
polyethylene
sheeting
and
95%
of
the
acreage
was
treated
with
the
67:
33
formulation.
Since
2000,
about
5%
of
the
acreage
has
been
treated
with
the
50:
50
formulation
of
methyl
bromide
and
chloropicrin.

Please
see
Table
12.1
for
further
information.
U.
S.
Pepper
Page
18
MICHIGAN
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
PEPPERS
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
96
98
117
126
135
128
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
No
pepper
area
in
Michigan
uses
flat
fumigation
application.

AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
11,482
11,747
14,001
15,618
16,230
15,391
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
A
67:
33
67:
33
67:
33
or
50:
50
67:
33
or
50:
50
67:
33
or
50:
50
67:
33
or
50:
50
METHODS
BY
WHICH
METHYL
BROMIDE
APPLIED
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
DOSAGE
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
12.0
12.0
12.0
or
8.9
12.0
or
8.9
12.0
or
8.9
12.0
or
8.9
A
Growers
have
just
started
switching
to
the
50/
50
formulation
of
MB/
Chloropicrin
since
2000
(
about
5%
of
production
acreage)
to
reduce
cost
per
acre.

MICHIGAN
 
PART
C:
TECHNICAL
VALIDATION
­
PEPPERS
MICHIGAN
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
U.
S.
Pepper
Page
19
MICHIGAN
 
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
Metam­
sodium
or
Metam­
potassium
Pepper
farmers
requesting
MB
must
plant
by
the
first
week
of
May
to
capture
an
early
market
window.
Soil
fumigation
must
therefore
be
completed
by
mid
April
to
allow
14­
21
days
for
aeration.
However,
metam
labels
recommend
that
applications
be
made
when
soil
temperatures
(
at
application
depth)
are
above
4.4
°
C.
Since
soil
temperatures
in
Michigan
do
not
climb
over
10
°
C
until
after
mid
to
late
May
(
Schaetzl
and
Tomczak,
2001),
metam
products
cannot
be
used
effectively
for
early
pepper
planting
in
Michigan.
Metam
products
have
the
additional
disadvantage
that
when
the
soil
is
wet
and
cold
(
below
15
°
C),
the
minimum
recommended
plant
back
period
is
30
days,
which
would
further
move
the
crop
beyond
the
early
market
window.

In
addition,
control
of
the
key
pest
is
inconsistent
(
Locascio
et
al.
1997,
Martin
2003).
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season;
P.
capsici
was,
however,
not
present.
In
the
cool
conditions
of
Michigan,
metam­
sodium
is
likely
to
be
slow
to
transform
into
the
active
ingredient
(
methyl
isothiocyanate),
which
also
suggests
that
pest
control
will
not
be
as
effective
as
with
MB
(
Ashley
et
al.
1963).
In
a
recent
study
conducted
in
Oceana
County,
Michigan
by
Hausbeck
and
Cortright
(
2004),
yields
from
pepper
plots
treated
with
metam
potassium
(
K­
Pam)
were
comparable
to
yields
from
control
plots
and
plots
treated
with
MB
+
chloropicrin,
indicating
e
a
very
low
pest
(
P.
capsici)
pressure
at
the
test
site.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
Michigan's
climate
is
typically
cool
(
often
less
than
11
oC
through
May)
and
cloudy,
particularly
early
in
the
growing
season
when
control
of
the
key
pests
is
especially
important.
In
Michigan,
the
growing
season
is
short
(
May
to
September),
and
the
time
needed
to
utilize
solarization
is
likely
to
render
the
subsequent
growing
of
crops
impossible,
even
if
it
did
somehow
eliminate
all
fungal
pathogens.
Since
solarization
has
shown
promise
in
other
crops
and
regions
(
e.
g.,
tomatoes
in
Florida),
the
potential
for
adoption
exists
(
Schneider
et
al.
2003).
However,
because
of
climate,
solarization
is
not
feasible
in
Michigan.
No
Steam
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
field
pepper
crops
in
Michigan.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
U.
S.
Pepper
Page
20
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
MB
because
they
alone
cannot
control
the
soil
pathogens
that
afflict
peppers
in
Michigan.
The
bacterium
Burkholderiaia
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
in
a
test
conducted
by
the
Michigan
applicants,
P.
capsici
was
not
controlled
adequately
in
summer
squash
by
either
of
these
beneficial
microorganisms.
No
Cover
crops
and
mulching
There
is
no
evidence
these
practices
effectively
substitute
for
the
control
MB
provides
against
P.
capsici.
Control
of
P.
capsici
is
imperative
for
pepper
production
in
Michigan.
Plastic
mulch
is
already
in
widespread
use
in
Michigan
vegetables,
and
regional
crop
experts
state
that
it
is
not
an
adequate
protectant
when
used
without
MB.
The
longevity
and
resistance
of
P.
capsici
oospores
renders
cover
crops
ineffective
as
a
management
alternative
to
MB.
No
Crop
rotation
and
fallow
land
The
crop
rotations
available
to
growers
in
Michigan
region
are
also
susceptible
to
these
fungi,
particularly
to
P.
capsici.
Fallow
land
can
still
harbor
P.
capsici
oospores
(
Lamour
and
Hausbeck
2003).
Thus
fungi
would
persist
and
attack
peppers
if
crop
rotation/
fallow
land
was
the
main
management
regime.
No
Endophytes
Though
these
organisms
(
bacteria
and
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
have
been
shown
to
suppress
some
plant
pathogens
in
cucumber,
there
is
no
such
information
for
the
other
pepper
crops
grown
in
Michigan.
Furthermore,
the
pathogens
involved
did
not
include
Phytophthora
species,
which
are
arguably
the
greatest
single
threat
to
Michigan
peppers.
No
Flooding/
Water
management
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
P.
capsici
(
Allen
et
al.
1999),
and
is
likely
to
be
impractical
for
Michigan
pepper
growers.
It
is
unclear
whether
irrigation
methods
in
this
region
could
be
adapted
to
incorporate
flooding
or
alter
water
management
for
pepper
fields.
In
any
case,
there
appears
to
be
no
supporting
evidence
for
its
use
against
the
hardy
oospores
of
P.
capsici.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrate
s/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
MB
replacements
in
peppers,
they
have
been
grouped
together
for
discussion
in
this
document.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
pepper
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
MB
alternatives
for
control
of
Phytophthora
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
MB
for
fungi.
One
of
the
fungal
pests
listed
by
Michigan
can
spread
through
water
(
Gevens
and
Hausbeck
2003),
making
it
difficult
to
keep
any
sort
of
area
(
with
or
without
soil)
disease
free.
Various
aspects
of
organic
production
­
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
U.
S.
Pepper
Page
21
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE
Metam
sodium
or
metam
potassium
+
Chloropicrin
Pepper
farmers
requesting
MB
must
plant
by
the
first
week
of
May
to
capture
an
early
market
window.
Soil
fumigation
must
therefore
be
completed
by
mid
April
to
allow
14­
21
days
for
aeration.
However,
metam
labels
recommend
that
applications
be
made
when
soil
temperatures
(
at
application
depth)
are
above
4.4
°
C.
Since
soil
temperatures
in
Michigan
do
not
climb
over
10
°
C
until
after
mid
to
late
May
(
Schaetzl
and
Tomczak,
2001),
metam
products
cannot
be
used
effectively
for
early
pepper
planting
in
Michigan.
Metam
products
have
the
additional
disadvantage
that
when
the
soil
is
wet
and
cold
(
below
15
°
C),
the
minimum
recommended
plant
back
period
is
30
days,
which
would
further
move
the
crop
beyond
the
early
market
window.

In
addition,
trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Locascio
and
Dickson
1998,
Csinos
et
al.
1999).
These
studies
apparently
did
not
measure
yield
impacts,
and
did
not
involve
peppers.
Hausbeck
and
Cortright
(
2004)
evaluated
several
soil
fumigants
for
control
of
P.
capsici
on
several
vegetable
crops,
including
peppers,
in
Michigan.
Results
show
that
yields
from
pepper
plots
treated
with
metam
potassium
+
chloropicrin
were
comparable
to
yields
from
control
plots
and
from
plots
treated
with
MB
+
chloropicrin.
These
results
point
to
a
very
low
pest
pressure
in
the
study
area.
Further
studies
are
necessary
to
clearly
identify
MB
alternatives.
No
1,3
dichloropropene
+
chloropicrin
Regulatory
restrictions
and
Michigan's
cool
and
wet
soils
may
result
in
a
delay
of
up
to
28
days
in
planting
after
treatment
with
this
combination.
This
delay
could
result
in
growers
missing
key
market
windows,
with
consequent
negative
economic
impacts
(
detailed
in
other
sections
below).
In
a
small
plot
study
conducted
in
Michigan
by
Hausbeck
and
Cortright
(
2004)
pepper
yields
from
plots
treated
with
1,3­
D
+
chloropicrin
were
comparable
to
yields
from
control
plots
and
plots
treated
with
MB
+
chloropicrin.
These
results
seem
to
indicate
a
very
low
pest
(
P.
capsici)
pressure
at
the
test
site.
Further
studies
are
necessary
to
clearly
identify
MB
alternatives.
No
1,3
dichloropropene
+
Metam­
sodium
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
combination
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Csinos
et
al.
1999).
Low
efficacy
in
even
small­
plot
trials
indicates
that
this
is
not
a
technically
feasible
alternative
for
commercially
produced
peppers
in
Michigan
at
this
time.
These
studies
apparently
did
not
measure
yield
impacts,
and
did
not
involve
peppers.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Pepper
Page
22
MICHIGAN
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

Table
14.1
Technically
Infeasible
Alternatives
Discussion.

NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
those
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
belowground
portions
of
pepper
plants.
A
number
of
effective
fungicides
are
available
for
treatment
of
these
fungi
when
they
infect
aerial
portions
of
crops.
However,
these
infections
are
not
the
focus
of
MB
use,
which
is
meant
to
keep
newly
planted
transplants
free
of
these
fungi.

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

MICHIGAN
 
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:

Methyl
iodide
Not
registered
in
the
U.
S.
for
peppers,
although
registration
is
being
pursued
for
tomatoes,
strawberries,
peppers,
and
ornamental
crops.
Yes
Unknown
Furfural
Not
registered
in
the
U.
S.
for
peppers.
Registration
is
currently
being
pursued
only
for
non­
food
greenhouse
uses.
No
(
for
peppers)
Unknown
Sodium
azide
Not
registered.
No
registration
requests
submitted
to
U.
S.
No
(
for
any
crop/
commodity)
Unknown
Propargyl
bromide
Not
registered.
No
registration
requests
submitted
to
U.
S.
No
(
for
any
crop/
commodity)
Unknown
MICHIGAN
­
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:

Michigan
pepper
farmers
requesting
MB
must
plant
by
the
first
week
of
May
to
capture
an
early
market
window.
Soil
fumigation
must
therefore
be
completed
by
mid
April
to
allow
14­
21
days
for
aeration.
However,
1,3­
D
and
metam
labels
recommend
that
applications
be
made
when
soil
temperatures
(
at
application
depth)
are
above
4.4
°
C.
Furthermore,
optimum
soil
temperatures
for
1,3­
D
are
in
the
10
°
C
­
25
°
C
range
(
University
of
California,
Davis,
undated).
Since
soil
temperatures
in
Michigan
do
not
climb
over
10
°
C
until
after
mid
to
late
May
(
Schaetzl
and
Tomczak,
2001),
neither
1,3­
D
nor
metam
products
can
be
used
effectively
for
early
pepper
planting
in
Michigan.
Metam
products
have
the
additional
disadvantage
that
when
the
soil
is
wet
and
cold
(
below
15
°
C),
the
minimum
recommended
plant
back
period
is
30
days,
which
would
push
the
crop
beyond
the
early
market
window.
U.
S.
Pepper
Page
23
Few
studies
have
focused
on
peppers
in
Michigan's
growing
conditions.
A
recent
study,
conducted
in
Oceana
County,
Michigan
by
Hausbeck
and
Cortright
(
2004),
was
undertaken
to
evaluate
soil
fumigants
for
managing
P.
capsici
on
several
solanaceous
and
cruciferous
crops.
Results,
however,
show
that
yields
from
pepper
plots
treated
with
metam
potassium
(
K­
Pam),
alone
or
in
combination
with
chloropicrin,
and
from
plots
treated
with
1,3­
D
+
chloropicrin
(
Telone
C35)
were
comparable
to
yields
from
plots
treated
with
MB
+
chloropicrin
and
to
yields
from
control
plots.
These
results
seem
to
indicate
a
very
low
pest
pressure
in
treated
and
control
plots.
However,
with
the
best
available
MB
alternative,
revenue
losses
would
be
possible
from
planting
delays
and
missing
of
key
market
windows.

In
studies
with
other
vegetable
crops,
1,3
D
+
chloropicrin
has
generally
shown
better
control
of
fungi
than
metam­
sodium
formulations,
although
still
not
as
good
as
control
with
MB.
For
example,
in
a
study
using
a
bell
pepper/
squash
rotation
in
small
plots
­
conducted
in
the
much
warmer
conditions
of
Georgia
and
without
P.
capsici
as
a
component
of
the
pest
complex
­
Webster
et
al.
(
2001)
found
significantly
lower
fungal
populations
with
1,3
D
+
35
%
chloropicrin
(
drip
irrigated
or
chisel
injected,
146
kg/
ha
of
1,3
D),
as
compared
to
the
untreated
control.
However,
MB
(
440
kg/
ha,
shank­
injected)
lowered
fungal
populations
even
more.
Methyl
iodide
had
no
significant
suppressive
effect,
as
compared
to
the
untreated
control.
In
another
study,
conducted
on
tomatoes
in
Florida,
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season.
P.
capsici
was
not
present.
U.
S.
Pepper
Page
24
MICHIGAN
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
dichloropropene
+
Chloropicrin
P.
capsici
0
 
6
%
PLUS
loss
of
revenue
due
to
planting
delays
6
%
loss
of
revenue
due
to
planting
delays
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
6
%
likely
with
the
best
alternative
(
1,3
D
+
chloropicrin)

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

The
critical
use
exemption
applicant
states
that
1,3
D
+
chloropicrin,
metam­
sodium,
methyl
iodide,
chloropicrin,
and
chloropicrin/
metam
sodium
will
continue
to
be
subjects
of
field
studies
of
utilization
and
efficacy
enhancement
where
P.
capsici
fungi
are
the
target
pests.
Most
of
these
alternatives
are
not
currently
registered
for
peppers,
and
there
are
presently
no
commercial
entities
pursuing
registration
in
the
United
States.
The
regulatory
restrictions
on
1,3­
D
discussed
elsewhere
will
adversely
influences
the
economics
of
this
MB
alternative.
The
timeline
for
developing
the
above­
mentioned
MB
alternatives
in
Michigan
is
as
follows:
2003
 
2005:
Test
for
efficacy
of
identified
alternatives.
2005
 
2007:
Establish
on­
farm
demonstration
plots
for
effective
MB
alternatives.
2008
 
2010:
Work
with
growers
to
implement
widespread
commercial
use
of
effective
alternatives.

Research
is
also
under
way
to
optimize
the
use
of
a
50
%
MB:
50
%
chloropicrin
formulation
to
replace
the
currently
used
67:
33
formulation.
In
addition,
field
research
is
being
conducted
to
optimize
a
combination
of
crop
rotation,
raised
crop
beds,
black
plastic,
and
foliar
fungicides.
Use
of
virtually
impermeable
film
(
VIF)
will
also
be
investigated
as
a
replacement
for
the
currently
used
low­
density
polyethylene
(
LDPE).

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

No.
Soilless
systems
and
greenhouse
production
are
not
in
use
for
peppers
in
this
region,
and
quick
adoption
is
probably
economically
infeasible.
Growers
apply
MB
on
fields
with
a
history
of
fungal
contamination,
but
it
appears
that
most
growing
acreage
in
this
region
has
moderate
to
severe
infestations
of
P.
capsici
and
other
soil
borne
fungi,
which
thrive
in
cool
and
moist
climates.
U.
S.
Pepper
Page
25
MICHIGAN
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Based
on
the
new
trials
conducted
in
vegetable
crops
in
Michigan
in
2003
(
described
above
in
Section
16),
EPA
has
determined
that
only
1,3
D
+
chloropicrin
has
some
technical
feasibility
against
the
key
pest
of
peppers
in
this
region.

Available
studies
in
vegetable
crops
in
the
U.
S.
indicate
that
1,3
D
+
chloropicrin
has
some
technical
feasibility
against
the
key
pest
of
peppers
in
this
region.
However,
no
large­
plot
studies
have
yet
been
performed
to
show
commercial
feasibility.
Demonstration
studies
are
planned
(
see
Section
17
above).
Important
regulatory
constraints
on
1,3
D
must
also
be
kept
in
mind:
a
7­
28
day
planting
delay,
mandatory
30
m
buffers
near
inhabited
structures
 
both
of
which
will
cause
negative
economic
impacts
that
make
the
use
of
these
MB
alternatives
infeasible.
There
is
also
potentially
lower
dissipation
(
and
thus
efficacy)
of
these
compounds
in
the
cool,
wet
soils
of
this
region.
These
planting
restrictions
may
thus
be
important
factors
inhibiting
widespread
grower
adoption
of
this
MB
alternative.
Potential
yield
losses
associated
with
plant
restrictions
could
be
exacerbated
because
fumigation
practices
need
to
be
completed
by
the
first
week
of
May
to
allow
growers
to
plant
early
and
capture
the
early
market
(
July
 
September)
and
have
their
product
available
for
premium
prices,
as
well
as
ensuring
demand
for
their
crop
during
the
entire
growing
season
(
especially
during
the
mid
and
late
season).
Key
marketing
opportunities
have
been
established
with
Michigan's
vegetable
crop
diversification
and
aims
toward
stable
demands
in
the
late
spring
and
through
the
summer
for
Midwestern
markets.

Currently
unregistered
alternatives,
such
as
furfural
and
sodium
azide,
have
shown
good
efficacy
against
the
key
pests
involved
(
Cortright,
personal
communication).
However,
even
if
registration
is
pursued
soon,
these
options
would
require
additional
research
focusing
on
their
adaptation
to
commercial
pepper
production
in
Michigan.

There
are
also
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
pepper
growers.
In
sum,
while
the
potential
exists
for
a
combination
of
chemical
and
non­
chemical
alternatives
to
replace
MB
use
in
Michigan
pepper,
this
goal
appears
be
at
least
a
few
years
away.
U.
S.
Pepper
Page
26
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ON
PEPPERS
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
[
U.
S.
States
of
Alabama,
Arkansas,
Kentucky*,
Louisiana*,
North
Carolina,
South
Carolina,
Tennessee
and
Virginia;
*
States
added
for
2005­
2007]
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
FOR
PEPPERS
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TARGET
PESTS
(
WEED
&
PLANT­
PARASITIC
NEMATODES)
PATHOGENS,
AND
[%
DEGREE
OF
INFESTATION,
IF
REPORTED
]
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Southeast
U.
S.
Peppers
Consortium
excluding
Florida
and
Georgia
Yellow
and
purple
nutsedge
(
Cyperus
esculentus,
C.
rotundus),
[
30%];
plant­
parasitic
nematodes
(
Meloidogyne
incognita;
Pratylenchus
sp.);
pythium
root
and
collar
rots
(
P.
irregulare,
P.
myriotylum,
P.
ultimum,
P.
aphanidermatum);
crown
and
root
rot
(
Phytophthora
capsici)
Only
MB
can
effectively
control
the
target
pests
found
in
the
southeastern
United
States
where
pest
pressures
commonly
exist
at
moderate
to
severe
levels.
Most,
if
not
all
of
these
states,
are
limited
in
the
use
of
the
alternative
1,3­
D
because
of
underlying
karst
topography
throughout
the
region.
Halosulfuron,
while
effective
against
nutsedge,
is
only
registered
for
use
on
row
middles
in
peppers.
Metam­
sodium
has
limited
pest
control
capabilities
and
should
never
be
used
as
a
stand­
alone
fumigant
(
Noling,
2003).
U.
S.
Pepper
Page
27
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
FOR
PEPPERS
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pepper
transplants
for
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual;
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Pepper
 
usually
double­
cropped
with
a
highvalue
cucurbit
crop
(
muskmelon,
cucumber,
or
squash).

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam;
clay
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
per
year;
(
either
in
spring
or
fall)

OTHER
RELEVANT
FACTORS:
There
are
two
distinct
pepper­
growing
systems:
1)
a
spring
crop
(
fumigation
cycle
begins
in
January)
and
a
fall
crop
(
fumigation
cycle
begins
in
May).
Methyl
bromide
is
applied
1
time
per
year
on
an
individual
field.
Pepper
does
not
follow
pepper
in
this
rotation;
peppers
are
rotated
with
another
crop,
often
a
high­
value
cucurbit,
which
also
depends
on
MB
fumigation.

SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
JANUARY
FUMIGATION
(
SPRING,
EARLY
SUMMER
HARVEST)
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
CLIMATIC
ZONE
U.
S.
Plant
Hardiness
Zones
6b,
7a,
7b,
8a,
8b
FUMIGATION
SCHEDULE
X
X
X
PLANTING
SCHEDULE
X
X
X
KEY
HARVEST
WINDOW
X
X
X
X
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
11.3
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
SPRING
FUMIGATION
(
FALL
HARVEST)
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
CLIMATIC
ZONE
U.
S.
Plant
Hardiness
Zones
6b,
7a,
7b,
8a,
8b
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
X
KEY
HARVEST
WINDOW
X
X
X
X
U.
S.
Pepper
Page
28
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

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

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require,
respectively,
a
7­
28
day
interval
and
a
14­
30
day
interval
before
planting,
compared
to
14
days
for
MB.
This
interval
may
cause
delays
and
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
for
pepper
growers
(
Kelley,
2003).
U.
S.
Pepper
Page
29
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
PEPPERS,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
PEPPERS
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
A
830
880
809
809
991
1,153
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
Not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
A
(
total
kilograms)
182,253
132,199
121,563
121,563
148,914
173,227
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
No
definitive/
substantiated
information
available
67:
33
67:
33
67:
33
METHODS
BY
WHICH
METHYL
BROMIDE
APPLIED
No
information
available
Injected
15
to
25
cm
deep
Injected
15
to
25
cm
deep
Injected
15
to
25
cm
deep
APPLICATION
RATE
(
KG/
HA)
FOR
THE
FORMULATION
No
information
available
DOSAGE
RATE*
(
G/
HA)
FOR
THE
ACTIVE
INGREDIENT
22.0
15.0
15.0
1.50
15.0
15.0
A
An
increase
in
the
acreage
of
peppers
produced
in
the
Southeastern
U.
S.
is
projected
from
2003
through
2007.
Although
reasons
vary
from
state
to
state;
they
include
shifts
in
acreage
from
tobacco
and
peanut
production
to
the
production
of
peppers
and
other
high­
value
vegetable
crops.
This
nomination
package
also
includes
two
new
states
(
added
since
2001):
Kentucky
and
Louisiana.
B
Based
on
estimated
area:
2,023
to
2,415
m2
(
Lewis,
2003,
personal
communication).
U.
S.
Pepper
Page
30
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
FOR
PEPPERS
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
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
Metam
Sodium
Metam
sodium
provides
limited
and
erratic
performance
at
suppressing
all
major
pepper
pathogens
and
pests.
In
addition,
there
is
a
14­
30
day
waiting
period
at
the
time
of
application
until
planting,
compared
to
14
days
for
MB.
Such
a
delay
could
cause
the
higherend
market
windows
to
be
missed,
particularly
for
the
spring
plantings
(
i.
e.,
fall
harvests).
Beginning
the
application
cycle
earlier
is
not
an
option
since
crops
from
the
previous
fumigation
cycle
must
be
cleaned
up
prior
to
metam
application.
(
Georgia
CUE
#
03­
0049;
Kelley,
2003).
Repeated
applications
of
MITC
(
the
breakdown
product
of
metam
sodium)
are
known
to
enhance
its
biodegradation
and
reduce
efficacy
as
a
result
of
increased
populations
of
adapted
microorganisms
(
Dungan
and
Yates,
2003).
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
United
States,
solarization
is
not
technically
feasible
as
a
methyl
bromide
alternative.
Response
of
Cyperus
species
to
solarization
is
sporadic
and
not
well
understood;
data
show
solarization
to
provide,
at
best,
suppression
of
nutsedge
populations
(
Chase
et
al.
1999).
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50oC
or
higher.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximum
soil
temperatures
of
43
oC
at
5
cm
depth
(
Chase
et
al.
1999).
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
high
enough
to
destroy
nutsedge
tubers.
Also,
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
In
addition,
solarization
would
take
fields
out
of
production
since
it
would
be
needed
during
the
spring
and
into
the
summer
months,
which
are
optimal
for
pepper
production.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
pepper
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
field
pepper
crops.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
U.
S.
Pepper
Page
31
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biological
Control
Biological
control
agents
alone
cannot
control
nutsedge
and/
or
the
soil
pathogens
that
afflict
peppers.
The
bacterium
Burkholderia
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
no
biological
control
agent
has
been
identified
to
effectively
control
nutsedge
or
Phytophthora.
Therefore,
biological
control
is
not
a
stand­
along
replacement
for
methyl
bromide
in
pepper
crops.
Only
a
limited
number
of
biological
organisms
are
effectively
used
to
manage
soil
borne
diseases
and
pests.
Biocontrol
agents
are
usually
very
specific
regarding
the
organisms
they
control
and
their
successful
establishment
is
highly
dependent
on
environmental
conditions.
No
Cover
crops
and
mulching
Cover
crops
and
mulches
have
been
integrated
into
solanaceous
crop
production
systems.
However
there
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
nutsedges
(
Burgos
and
Talbert
1996).
Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
which
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
Crop
rotation
and
fallow
land
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not
provide
adequate
control
of
nutsedges
or
fungal
pathogens.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores
(
Lamour
and
Hausbeck
2003).
Tubers
of
the
perennial
nutsedges
provide
new
plants
with
larger
energy
reserves
than
annual
weeds
that
can
be
more
easily
controlled
by
crop
rotations
and
fallow.
(
Thullen
and
Keeley
1975).
Furthermore,
nutsedge
plants
can
produce
tubers
within
2
weeks
after
emergence
(
Wilen
et
al.
2003).
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Flooding/
Water
management
Flooding
has
been
used
effectively
to
manage
various
soil
borne
pest
and
diseases,
especially
nematodes
and
some
weeds.
However,
nutsedges
have
shown
tolerance
to
this
treatment.
Submerging
nutsedge
tubers
for
8
days
to
4
weeks
showed
no
effect
on
the
sprouting
capabilities
of
the
tubers
(
Horowitz,
1972).
Studies
in
Florida
showed
ineffective
nematode,
disease,
and
nutsedge
control
after
flooding
(
Allen,
1999).
Regulatory
issues
concerning
water
management,
as
well
as
economic
feasibility,
also
preclude
its
viability
as
an
alternative
to
methyl
bromide.
Land
structure,
frequent
and
severe
droughts,
and
the
economics
of
developing
and
managing
flood
capabilities
prevent
flooding
from
being
a
viable,
cost
effective
alternative
in
the
Southeastern
United
States.
No
U.
S.
Pepper
Page
32
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrat
es/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
peppers,
they
have
been
grouped
together
for
discussion
in
this
document.
The
U.
S.
EPA
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
pepper
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
fungi.
Various
aspects
of
organic
production
 
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Although
this
combination
would
likely
be
more
effective
than
metam­
sodium
alone
where
fungal
pests
are
the
only
concern,
it
may
not
prevent
yield
losses
due
to
nutsedges,
particularly
where
weed
pressure
is
high.
In
a
study
with
vegetables
it
provided
control
of
yellow
nutsedge,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
No
1,3
dichloropropene
(
Telone
II)
+
metam­
sodium
This
combination
controls
nematodes
but
not
nutsedges.
In
a
study
with
vegetables,
it
provided
control
of
yellow
nutsedge,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
It
is
inconsistently
effective
against
fungal
pests
(
see
Michigan
sections
for
more
discussion).
1,3­
D
is
also
subject
to
regulatory
prohibition
of
use
on
Karst
geology.
No
1,3
dichloropropene
(
Telone
II)
followed
by
chloropicrin
Culpepper
and
Langston
(
2004)
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
Results
show
that
1,3­
D,
followed
by
chloropicrin,
was
significantly
less
effective
than
MB
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
however,
this
combination
performed
as
well
as
MB.
This
treatment
is
promising
and
will
require
further
testing
and
validation
in
commercial
fields.
No,
but
shows
promise
U.
S.
Pepper
Page
33
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3
dichloropropene
+
chloropicrin
This
combination
does
not
adequately
control
nutsedge.
Because
of
ground
water
contamination
concerns,
1,3­
D
cannot
be
used
in
pepper
growing
areas
of
the
U.
S.
where
karst
topography
exists.
Where
1,3­
D
use
is
allowed,
set
back
restrictions
(~
100
meters
from
occupied
structures;
~
30
meters
for
emulsified
formulations
applied
via
chemigation)
may
limit
the
portion
of
a
field
that
can
be
treated.
In
addition,
because
of
a
28­
day
waiting
period
between
application
and
planting
(
compared
to
14
days
for
MB),
growers
could
lose
half
of
the
harvest
season
and
miss
higher­
end
market
windows,
mainly
for
spring
fumigations
(
i.
e.,
fall
harvests).
No
1,3
dichloropropene
+
chloropicrin
(
Telone
C35)
followed
by
chloropicrin
Culpepper
and
Langston
(
2004)
have
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
In
this
study,
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin,
was
more
effective
than
MB
for
the
control
of
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
This
treatment
performed
as
well
as
MB
in
terms
of
spring
crop
yield,
but
poorly
in
terms
of
fall
yield.
This
combination
does
not
appear
to
show
promise
as
a
MB
alternative.
No
1,3
dichloropropene
+
chloropicrin
(
Telone
C35)
followed
by
metam
sodium
Culpepper
and
Langston
(
2004)
have
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
In
this
study,
1,3­
D
+
chloropicrin,
followed
by
metam
sodium
was
36%
less
effective
than
MB
for
the
control
of
purple
nutsedge,
but
as
effective
as
MB
for
the
control
of
yellow
nutsedge
and
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
This
combination
is
promising
and
will
require
further
testing
and
validation
in
commercial
fields.
No,
but
shows
promise
Fumigant
combination
+
herbicide
partners
Current
research
suggests
that
in
areas
of
low
pest
pressure
this
combination
may
be
suitable
for
some
growers
as
an
alternative
for
methyl
bromide.
In
these
situations
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
Yes
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Pepper
Page
34
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Halosulfuron­
methyl
Is
a
non­
selective
herbicide.
Causes
potential
crop
injury;
has
plant
back
restrictions.
Efficacy
is
lowered
in
rainy
conditions
(
common
during
the
period
of
initial
planting
of
these
crops).
Also,
a
24­
month
plant
back
restriction
may
cause
significant
economic
disruption
if
growers
must
rely
on
this
option.
Since
halosulfuron
can
only
be
applied
to
the
row
middles,
nutsedges
would
survive
on
the
pepper
beds,
close
to
crop
plants.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Glyphosate
Is
a
non­
selective
herbicide.
As
halosulfuron,
it
will
not
control
nutsedge
within
the
plant
rows
and
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
studied.

Paraquat
Is
a
non­
selective
herbicide
that
will
not
control
nutsedge
in
the
plant
rows.
It
does
not
provide
residual
control.
Thus
this
herbicide
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB,
and
its
use
in
conjunction
with
other
pest
management
methods
has
not
yet
been
investigated.

Other
than
those
options
discussed
elsewhere,
no
alternative
exists
for
the
control
of
the
key
weeds,
nematodes,
and
pathogens
affecting
pepper
production.
Non­
chemical
alternatives
and
chemical
alternatives
to
methyl
bromide
have
been
or
are
being
investigated
and
when
suitable,
are
incorporated
into
current
pepper
production
practices.

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

Since
methyl
bromide
has
been
used
effectively
to
manage
minor
crop
production,
there
are
limited
pesticide
alternatives
due
primarily
to
the
small
market
share
and
the
high
cost
associated
with
pesticide
registration.
Labeling
of
these
products
in
minor
crops
could
be
more
expensive
than
returns
from
potential
sales,
and
therefore
pesticide
manufacturers
have
been
reluctant
to
register
pesticides
for
minor
crop
uses.
Methyl
bromide
will
be
needed
until
a
cost­
effective
alternative
regimen
is
in
place.
U.
S.
Pepper
Page
35
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
FOR
PEPPERS
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Methyl
iodide
Not
registered
Yes
Unknown
Furfural
Not
registered.
No
Unknown
Sodium
azide
Not
registered.
No
registration
application
received.
No
Unknown
Propargyl
bromide
Not
registered.
No
registration
application
received.
No
Unknown
U.
S.
Pepper
Page
36
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
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:

SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
TABLE
16.1.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)

Chemicals
Rate
(
kg/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Untreated
(
control)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­

1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
Notes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.

Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
The
data
from
this
tomato
study
are
being
cited
because
comparable
pepper
data
are
not
available.
Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chiselinjected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metam­
sodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists
which
is
approximately
40%
of
the
Florida
pepper
production
area.
U.
S.
Pepper
Page
37
For
root
knot
nematodes,
both
metam­
sodium
and
1,3
D
+
35
%
chloropicrin
have
shown
good
efficacy
in
trials
with
tomato
and
pepper.
For
example,
Locascio
and
Dickson
(
1998)
reported
that
metam­
sodium
+
35
%
chloropicrin
(
295
l/
ha
of
metam­
sodium,
shank­
injected)
reduced
nematode
galls
significantly
over
untreated
control
plots,
though
not
as
much
as
did
MB
+
35
%
chloropicrin
treatments
(
500kg
MB/
ha,
shank­
injected),
in
Florida
tomatoes.
Analysis
of
35
tomato
and
5
pepper
trials
conducted
from
1993
 
1995
indicated
that
1,3
D
(
with
either
17
%
or
35
%
chloropicrin)
provided
control
of
nematodes
that
was
equal
or
superior
to
that
seen
with
MB,
in
95
%
of
the
tomato
and
100
%
of
pepper
trials
(
Eger
2000).
However,
it
is
not
clear
whether
yields
were
also
comparable
to
those
obtained
with
MB.
Noling
et
al
(
2000)
also
studied
the
effects
of
metam­
sodium
(
115
l/
ha,
syringe­
injected),
1,3
D
+
17
%
chloropicrin
(
53.6
l/
ha,
soil­
injected),
and
1,3
D
+
35
%
chloropicrin
(
39.8
l/
ha),
among
other
treatments,
in
tomato
plots.
Galls
inflicted
by
root
knot
nematodes
were
reduced
significantly
by
all
these
MB
alternatives,
as
compared
to
untreated
control
plots.
Yields
were
also
significantly
higher
as
compared
to
the
control
plots;
all
MB
alternatives
resulted
in
similar
high
yields.
However,
the
effects
of
MB
formulations
were
not
reported
in
this
study.
Further,
it
is
the
opinion
of
some
U.
S.
crop
experts
that
metam
sodium,
in
particular,
is
inconsistent
as
a
nematode
control
agent
(
Dr.
S.
Culpeper,
University
of
Georgia,
personal
communication).

SOUTHEAST
U.
S.
PEPPER
CONSORTIUM
­
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
dichloropropene
+
chloropicrin
Nutsedges,
fungal
pathogens
20
­
100
29%

Metam­
sodium
(
with
or
without
chloropicrin)
Nutsedges,
fungal
pathogens
30
­
55
44%

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
29
%
if
1,3
D
+
pic
is
used;
44
%
if
metamsodium
is
used
U.
S.
Pepper
Page
38
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:

Future
plans
to
minimize
MB
use
include:

1)
Optimizing
use
of
plastic
(
VIF)
tarps
and
drip
irrigation
equipment
for
applying
at­
plant
herbicides.
2)
Conducting
studies
on
tomato,
pepper,
and
cucurbit
crops
with
combinations
of
fumigants
and
herbicides
including
halosulfuron,
metolachlor,
rimsulfuron,
and
dimethenamid.
Telone
C­
35
will
be
used
as
a
fumigant
because
of
nematode
and
disease
problems.
3)
Changing
MB:
chloropicrin
formulations
from
98:
2
to
67:
33
Trials
using
the
alternative
fumigants
Telone
C­
35,
iodomethane,
metam
sodium,
chloropicrin,
and
at
least
two
reduced­
risk
products
(
Propozone,
PlantPro45,
DiTera,
Deny)
are
also
planned.
These
trials
will
incorporate
screening
of
pepper
varieties
for
tolerance/
resistance
to
Phytophthora
capsici.
The
applicant
noted
that
a
program
to
evaluate
host
resistance
to
Phytophthora
root
and
crown
rot
has
been
implemented.
Growers
are
starting
to
deploy
lines
identified
with
genetic
resistance
and
acceptable
horticultural
qualities.

In
addition,
the
following
new
long­
term
studies
have
been
initiated
at
the
Coastal
Plain
Experiment
Station
in
Tifton,
Georgia,
with
funding
provided
by
USDA­
CSREES,
Methyl
Bromide
Transitions
Grant:

­
Evaluation
of
the
effects
of
soil
conditions,
particularly
soil
temperature
and
moisture,
on
nutsedge
species
efficacy
from
several
fumigants.

­
Investigation
of
the
impact
of
multiple­
season
adoption
of
methyl
bromide
alternatives
in
terms
of
pest
species
composition,
including
weeds,
diseases,
and
nematodes.

­
Integration
of
multiple
tactics
as
alternatives
to
methyl
bromide
for
management
of
weeds,
diseases,
and
nematodes
in
pepper
and
eggplant.

­
Evaluation
of
vegetable
crop
response
to
herbicides
applied
under
plastic
prior
to
crop
transplants
and
characterize
herbicide
fate
when
applied
in
a
plasticulture
system
between
summer
and
fall
crops.
U.
S.
Pepper
Page
39
SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

No.
Soilless
systems
and
greenhouse
production
are
not
in
use
for
peppers
and
quick
adoption
is
probably
economically
infeasible.
Grafting
has
not
been
evaluated
for
vegetable
production
due
to
the
high
cost
and
the
large
number
of
plants
that
would
be
needed.
In
addition
this
alternative
is
primarily
used
for
nematode
and
disease
management,
but
there
is
no
evidence
that
it
applies
to
competition
from
weeds.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.

SOUTHEAST
U.
S.
PEPPERS
CONSORTIUM
EXCLUDING
FLORIDA
AND
GEORGIA
 
SUMMARY
OF
TECHNICAL
FEASIBILITY
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997)
Nutsedges
resist
traditional
and
modern
methods
of
weed
control
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds,
but
there
are
no
currently
registered
herbicides
to
address
sedge
weed
pests.
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

The
1,3­
dichloropropene
and
chloropicrin
combination
does
not
effectively
control
nutsedges.
Lack
of
an
effective
registered
herbicide
for
control
of
nutsedge
impairs
adoption
of
methyl
bromide
alternatives
in
pepper
(
Banks,
2002).
In
addition,
labeling
of
1,3­
dichloropropene
products
restricts
its
use
in
key
pepper
growing
areas
of
the
United
States
where
karst
topography
exists
due
to
ground­
water
contamination
concerns.
In
areas
where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions
and
7­
28
day
waiting
periods
between
application
and
planting
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
return
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.

Metam
sodium
provides
limited
and
erratic
performance
at
suppressing
all
major
solanaceous
pathogens
and
pests.
Data
indicate
that
metam
sodium
is
not
an
effective
alternative
to
methyl
U.
S.
Pepper
Page
40
bromide
for
nutsedge
control
in
bell
pepper
fields
Webster
et
al.,
(
2002).
A
14­
30
day
planting
delay
is
also
recommended
for
this
chemical.
In
addition
there
is
evidence
that
both
1,3­
dichloropropene
and
methyl
isothiocyanate
(
the
breakdown
product
of
metam
sodium)
levels
decline
more
rapidly,
thus
further
compromising
efficacy,
in
areas
where
these
are
repeatedly
applied
(
Smelt
et
al.
1989,
Ou
et
al.
1995,
Gamliel
et
al.
2003).
This
is
due
to
enhanced
degradation
of
these
chemicals
by
soil
microbes
(
Dungan
and
Yates
2003).

Culpepper
and
Langston
(
2004)
recently
compared
the
effectiveness
of
several
soil
fumigants
in
managing
soil
pests
affecting
peppers
in
Tifton,
Georgia.
Results
show
that
1,3­
D
followed
by
chloropicrin
was
significantly
less
effective
than
methyl
bromide
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin
was
more
effective
than
MB
for
the
control
of
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
This
treatment
performed
as
well
as
MB
in
terms
of
spring
crop
yield,
but
poorly
in
terms
of
fall
yield.
1,3­
D
+
chloropicrin,
followed
by
metam
sodium
was
36%
less
effective
than
methyl
bromide
for
the
control
of
purple
nutsedge,
but
as
effective
as
MB
for
the
control
of
yellow
nutsedge.
This
combination
was
as
effective
as
MB
against
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
These
treatments
are
showing
promise
and
will
require
further
testing
and
validation
in
commercial
fields.

Research
on
the
effectiveness
of
non­
chemical
alternatives
to
methyl
bromide
is
still
in
a
preliminary
stage,
particularly
for
high
value,
minor­
use
crops
such
as
peppers.
U.
S.
Pepper
Page
41
GEORGIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ON
PEPPERS
GEORGIA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
GEORGIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
FOR
PEPPERS
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TARGET
PESTS
(
WEED
&
PLANT­
PARASITIC
NEMATODES)
PATHOGENS,
AND
[%
DEGREE
OF
INFESTATION,
IF
REPORTED
]
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Georgia
Yellow
and
purple
nutsedge
(
Cyperus
esculentus,
C.
rotundus)
[
100%];
crown
and
Root
rot
(
Phytophthora
capsici)
[
40%];
plant­
parasitic
nematodes
(
Meloidogyne
incognita;
Pratylenchus
sp)
[
70%];
southern
blight
(
Sclerotium
rolfsii)
[
70%];
Pythium
root
and
collar
rots
(
P.
irregulare,
P.
myriotylum,
P.
ultimum,
P.
aphanidermatum)
[
100%]
Only
MB
can
effectively
control
the
target
pests
found
in
the
southeast
U.
S.
where
pest
pressures
commonly
exist
at
moderate
to
severe
levels.
Most,
if
not
all
of
these
states
are
limited
in
the
use
of
the
alternative
1,3­
D
because
of
underlying
karst
geology
throughout
the
region.
Halosulfuron,
which
is
registered
only
for
middle­
of­
row
use,
does
not
control
nutsedge
near
pepper
plants
where
most
competition
occurs.
Metam­
sodium
has
limited
pest
control
capabilities
and
should
never
be
used
as
a
stand­
alone
fumigant
(
Noling,
2003).
Refer
to
Item
13
for
additional
detail.

GEORGIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
FOR
PEPPERS
GEORGIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
GEORGIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pepper
transplants
for
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual;
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Pepper
 
usually
followed
by
a
cucurbit
crop
(
cucumbers
or
squash).
Occasionally
eggplants
follow
pepper
crops.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam;
clay
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
per
year;
(
either
in
spring
or
fall)

OTHER
RELEVANT
FACTORS:
Actual
frequency
may
be
between
12
and
15
months
depending
on
the
number
of
crops
grown
per
fumigation
cycle.
U.
S.
Pepper
Page
42
GEORGIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
JULY
FUMIGATION
EVENT,
PEPPER
CROP
IS
HARVESTED
IN
FALL.
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
U.
S.
Plant
Hardiness
Zones
7a,
7b,
8a,
8b
SOIL
TEMP.
(
°
F)
64.1
72.5
80.8
85.9
87.8
86.8
82.2
73.9
34.0
54.0
51.1
55.5
RAINFALL
(
inches)
5.0
3.8
3.5
4.5
5.6
4.8
3.4
2.3
2.3
4.5
4.5
4.2
AVERAGE
AIR
TEMP.
(
°
C
)
69.8
77.7
84.7
89.4
90.7
90.5
87.3
79.3
69.8
63.1
61.5
64.0
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
2C
P
KEY
HARVEST
WINDOWS
2C
2C
2C
P
P
P
Methyl
bromide
applied
in
July
allows
the
grower
to
economically
produce
at
least
two
crops
from
one
annual
fumigation
event.
P
=
planting
or
harvest
of
pepper
crop;
2C
=
planting
and/
or
harvest
of
2nd
crop.

GEORGIA
­
TABLE
11.3.
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
SPRING
(
LATE
FEBRUARY
­
MARCH)
FUMIGATION
EVENT,
PEPPER
CROP
IS
HARVESTED
IN
EARLY
SUMMER
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
CLIMATIC
ZONE
U.
S.
Plant
Hardiness
Zones
7a,
7b,
8a,
8b
SOIL
TEMP.
(
°
C)
Same
as
above­
Table
11.2
RAINFALL
(
mm)
Same
as
above­
Table
11.2
AIR
TEMP.
(
°
C)
Same
as
above­
Table
11.2
FUMIGATION
SCHEDULE
A
X
PLANTING
SCHEDULE
A,
P
2C
KEY
HARVEST
WINDOW
A,
P
P
P
2C
2C
2C
AFumigation
is
an
early
spring
event.
Two
crops
are
shown
as
being
produced
from
one
fumigation
event.
P
=
planting
and/
or
harvest
of
pepper
crop;
2C
=
planting
and/
or
harvest
of
second
crop.
U.
S.
Pepper
Page
43
GEORGIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Peppers
are
generally
produced
using
mechanized
practices
that
involve
deep
injection
of
methyl
bromide.
Methyl
bromide
is
being
requested
only
for
moderate
to
severe
pest
infestations.
Approximately
81%
of
the
Georgia
pepper
area
is
considered
to
have
moderate
to
severe
infestations
of
nutsedge
(
Culpepper,
2004).

Weeds,
especially
nutsedge,
are
the
most
serious
concern
precipitating
methyl
bromide
use
in
both
transplant
beds
and
in
the
field.
Nutsedge
species
grow
even
under
adverse
conditions,
resist
traditional
and
modern
methods
of
weed
control,
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds
­
but
there
are
no
currently
registered
herbicides
that
control
nutsedges
near
pepper
plants.
Weeds,
when
present
in
crops
such
as
pepper,
tomato,
and
cucurbits
for
40
to
60
days
may
reduce
yields
by
10
to
50%.
In
addition
to
weeds,
soil­
borne
fungal
pathogens
and
plant­
parasitic
nematodes
are
endemic
to
the
region
and
nearly
all
production
areas
have
severe
infestations,
thus
necessitating
annual
treatment
with
a
broad­
spectrum
soil
fumigant.

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require,
respectively,
a
14­
28
day
interval
and
a
14­
30
day
interval
before
planting,
compared
to
14
days
for
MB.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops
(
Kelley,
2003).
U.
S.
Pepper
Page
44
GEORGIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
PEPPERS,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
GEORGIA
­
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
ON
PEPPERS
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1998
1999
2000
2001
2002
2003
AREA
TREATED
(
hectares)
1,267
1,767
2,263
2,252
2,312
2,117
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
production
acreage
is
strip/
bed
fumigation
and
tarped
with
LDPE
films.
Approximately
58%
of
the
field
is
treated
with
MB
and
covered
with
plastic
mulch.

AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
313,053
337,163
347,944
338,248
347,183
317,886
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
(
15%
acreage)
67:
33
(
85%
Of
acreage)
67:
33
67:
33
67:
33
67:
33
METHODS
BY
WHICH
METHYL
BROMIDE
APPLIED
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
Injected,
20.3
to
30.5
cm,
under
tarp
DOSAGE
RATE*(
G/
M
2)
OF
ACTIVE
INGREDIENT
24.7
18.1
15.0
15.0
15.0
15.0
U.
S.
Pepper
Page
45
GEORGIA
­
PART
C:
TECHNICAL
VALIDATION
FOR
PEPPERS
GEORGIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
GEORGIA
 
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
Metam
Sodium
Metam
sodium
provides
limited
and
erratic
performance
at
suppressing
all
nutsedge
weed
species
and
pepper
pathogens.
Also,
there
is
a
14­
30
day
waiting
period
at
the
time
of
application
until
planting
compared
to
14
days
for
MB.
Such
a
delay
may
cause
the
higher­
end
market
windows
to
be
missed 
particularly
for
the
spring
plantings
(
i.
e.,
fall
harvests).
Beginning
the
application
cycle
earlier
is
not
an
option
since
crops
from
the
previous
fumigation
cycle
must
be
cleaned
up
prior
to
metam
application.
(
Georgia
CUE
#
03­
0049;
Kelley,
2003).
Repeated
applications
of
MITC
(
the
breakdown
product
of
metam
sodium)
are
known
to
enhance
its
biodegradation
(
and
reduce
efficacy)
as
a
result
of
increased
populations
of
adapted
microorganisms
(
Dungan
and
Yates,
2003).
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
United
States,
solarization
is
not
technically
feasible
as
a
methyl
bromide
alternative.
Response
of
Cyperus
species
to
solarization
is
sporadic
and
not
well
understood;
data
show
solarization
to
provide,
at
best,
suppression
of
nutsedge
populations
(
Chase
et
al.
1999).
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50
oC
or
higher
(
Chase
et
al.
1999).
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximum
soil
temperatures
of
43
oC
at
5
cm
depth.
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
high
enough
to
destroy
nutsedge
tubers.
Also,
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
In
addition,
solarization
would
take
fields
out
of
production
since
it
would
be
needed
during
the
spring
and
into
the
summer
months,
which
are
optimal
for
pepper
production.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
pepper
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
field
pepper
crops.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
U.
S.
Pepper
Page
46
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Biological
Control
Biological
control
agents
alone
cannot
control
nutsedge
and/
or
the
soil
pathogens
that
afflict
peppers.
The
bacterium
Burkholderia
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
no
biological
control
agent
has
been
identified
to
effectively
control
nutsedge
or
Phytophthora.
Therefore,
biological
control
is
not
a
stand­
along
replacement
for
methyl
bromide
in
pepper
crops.
Only
a
limited
number
of
biological
organisms
are
effectively
used
to
manage
soil
borne
plant
pathogens
and
pests.
Biocontrol
agents
are
usually
very
specific
regarding
the
organisms
they
control
and
their
successful
establishment
is
highly
dependent
on
environmental
conditions.
No
Cover
crops
and
mulching
Cover
crops
and
mulches
have
been
integrated
into
solanaceous
crop
production
systems.
However
there
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
nutsedges
(
Burgos
and
Talbert
1996).
Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
which
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
Crop
rotation
and
fallow
land
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not
provide
adequate
control
of
nutsedges
or
fungal
pathogens.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores
(
Lamour
and
Hausbeck
2003).
Tubers
of
the
perennial
nutsedges
provide
new
plants
with
larger
energy
reserves
than
annual
weeds
that
can
be
more
easily
controlled
by
crop
rotations
and
fallow.
(
Thullen
and
Keeley
1975).
Furthermore,
nutsedge
plants
can
produce
tubers
within
2
weeks
after
emergence
(
Wilen
et
al.
2003).
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Flooding/
Water
management
Flooding
has
been
used
effectively
to
manage
various
soil
borne
pest
and
plant
pathogens,
especially
nematodes
and
some
weeds.
However,
nutsedges
have
shown
tolerance
to
this
treatment.
Submerging
nutsedge
tubers
for
8
days
to
4
weeks
showed
no
effect
on
the
sprouting
capabilities
of
the
tubers
(
Horowitz,
1972).
Studies
in
Florida
showed
ineffective
nematode,
plant
pathogen,
and
nutsedge
control
after
flooding
(
Allen,
1999).
Regulatory
issues
concerning
water
management,
as
well
as
economic
feasibility,
also
preclude
its
viability
as
an
alternative
to
methyl
bromide.
Land
structure,
frequent
and
severe
droughts,
and
the
economics
of
developing
and
managing
flood
capabilities
prevent
flooding
from
being
a
viable,
cost
effective
alternative
in
the
Southeastern
United
States.
No
U.
S.
Pepper
Page
47
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates
/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
peppers,
they
have
been
grouped
together
for
discussion
in
this
document.
The
United
States
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
pepper
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
fungi.
Various
aspects
of
organic
production
 
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Would
possibly
be
more
effective
than
metam­
sodium
alone
where
fungal
pests
are
the
only
concern
(
see
Michigan
sections
for
more
discussion),
but
this
combination
may
not
prevent
yield
losses
due
to
nutsedges,
particularly
where
the
weed
pressure
is
high.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
No
1,3
dichloropropene
+
Metam­
sodium
Controls
nematodes
but
not
nutsedges.
U.
S.
EPA
is
aware
of
one
vegetable
study
that
showed
control
of
yellow
nutsedge
with
this
chemical
combination,
but
weed
pressure
in
that
small
plot
test
was
low,
according
to
the
authors
(
Csinos
et
al.
1999).
Inconsistently
effective
against
fungal
pests
(
see
Michigan
sections
for
more
discussion).
1,3­
D
also
subject
to
regulatory
prohibition
of
use
on
Karst
geology.
No
1,3
dichloropropene
(
Telone
II)
followed
by
chloropicrin
Culpepper
and
Langston
(
2004)
have
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
Results
show
that
1,3­
D
followed
by
chloropicrin
was
significantly
less
effective
than
MB
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
however,
this
combination
performed
as
well
as
MB.
This
treatment
is
promising
and
will
require
further
testing
and
validation
in
commercial
fields.
No,
but
shows
some
promise
U.
S.
Pepper
Page
48
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3
dichloropropene
+
chloropicrin
This
combination
does
not
adequately
control
nutsedge.
Due
to
ground­
water
contamination
concerns,
1,3­
D
cannot
be
used
in
pepper
growing
areas
of
the
U.
S.
where
karst
topography
exists.
Where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions
(~
100
meters
from
occupied
structures;
~
30
meters
for
emulsified
formulations
applied
via
chemigation)
may
limit
the
proportion
of
the
field
that
can
be
treated.
In
addition,
because
of
a
28­
day
waiting
period
between
application
and
planting
(
compared
to
14
days
for
MB),
growers
could
lose
half
of
the
harvest
season
and
miss
higher­
end
market
windows,
mainly
for
spring
fumigations
(
i.
e.,
fall
harvests).
(
SE
Pepper
Consortium,
CUE
#
03­
0041).
No
1,3
dichloropropene
+
chloropicrin
(
Telone
C35)
followed
by
chloropicrin
Culpepper
and
Langston
(
2004)
have
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
In
this
study,
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin
was
more
effective
than
MB
for
the
control
of
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
This
treatment
performed
as
well
as
MB
in
terms
of
spring
crop
yield,
but
poorly
in
terms
of
fall
yield.
This
combination
does
not
appear
to
show
promise
as
a
MB
alternative.
No
1,3
dichloropropene
+
chloropicrin
(
Telone
C35)
followed
by
metam
sodium
Culpepper
and
Langston
(
2004)
have
tested
the
effectiveness
of
several
soil
fumigant
combinations
for
the
management
of
nutsedges
and
nematodes
affecting
peppers
in
Tifton,
Georgia.
In
this
study,
1,3­
D
+
chloropicrin,
followed
by
metam
sodium
was
36%
less
effective
than
MB
for
the
control
of
purple
nutsedge,
but
as
effective
as
MB
for
the
control
of
yellow
nutsedge
and
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
This
combination
is
promising
and
will
require
further
testing
and
validation
in
commercial
fields.
No,
but
shows
promise
Fumigant
combination
+
herbicide
partners
Current
research
suggests
that
in
areas
of
low
pest
pressure
this
combination
may
be
suitable
for
some
growers
as
an
alternative
for
methyl
bromide.
In
these
situations
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
Yes
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Pepper
Page
49
GEORGIA­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

GEORGIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Halosulfuron­
methyl
For
nutsedges:
potential
crop
injury;
plant
back
restrictions.
Efficacy
is
lowered
in
rainy
conditions
(
which
are
common
in
this
region).
Also,
a
24
month
plant
back
restriction
may
cause
significant
economic
disruption
if
growers
must
rely
on
this
control
option.

Glyphosate
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Repeated
applications
are
required
for
control
even
in
row
middles.

Paraquat
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Other
than
those
options
discussed
in
Table
13.1
and
elsewhere
in
this
document,
no
alternative
exists
for
the
control
of
the
key
pests
and
fungi
affecting
pepper
production.
Non­
chemical
alternatives
and
chemical
alternatives
to
methyl
bromide
have
been
or
are
being
investigated
and
when
suitable,
are
incorporated
into
current
pepper
production
practices.

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

Since
methyl
bromide
has
been
used
effectively
to
manage
minor
crop
production,
there
are
limited
pesticide
alternatives
due
primarily
to
the
small
market
share
and
the
high
cost
associated
with
pesticide
registration.
Labeling
of
these
products
in
minor
crops
could
be
more
expensive
than
returns
from
potential
sales,
and
therefore
pesticide
manufacturers
have
been
reluctant
to
register
pesticides
for
minor
crop
uses.
Methyl
bromide
will
be
needed
until
a
cost­
effective
alternative
regimen
is
in
place.

The
applicant
supplied
information
indicating
pepper
yield
in
fields
treated
with
1,3­
D
was
43%
below
MB­
treated
fields,
though
these
results
are
as
yet
unpublished.
U.
S.
Pepper
Page
50
GEORGIA
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

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

Iodomethane
Not
registered
Yes
Unknown
Furfural
(
Multigard
 
)
Not
registered
No
Unknown
Sodium
azide
Not
registered.
No
registration
application
received.
No
Unknown
Propargyl
bromide
Not
registered.
No
registration
application
received.
No
Unknown
GEORGIA
­
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:

GEORGIA
­
TABLE
16.1.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)

Chemicals
Rate
(
kg/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

UNTREATED
(
CONTROL)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­

1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
Notes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.

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

Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
U.
S.
Pepper
Page
51
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville,
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
{
In
considering
1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists.}

GEORGIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
D
+
chloropicrin
Nutsedges,
fungal
pathogens
20
 
100
29
Metam­
sodium
(
with
or
without
chloropicrin)
Nutsedges,
fungal
pathogens
30
 
55
44
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
29
%
if
1,3
D
+
pic
is
used;
44
%
if
metamsodium
is
used
GEORGIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

There
are
plans
to
conduct
studies
on
tomato,
pepper,
and
cucurbit
crops
with
combinations
of
fumigants
and
herbicides
including
halosulfuron,
metolachlor,
rimsulfuron,
and
dimethenamid.
Telone
C­
35
will
be
used
as
a
fumigant
because
of
nematode
and
plant
pathogen
problems.

Trials
using
the
alternative
fumigants
Telone
C­
35,
iodomethane,
metam
sodium,
chloropicrin,
and
at
least
two
low
risk
products
(
Propozone,
PlantPro45,
DiTera,
Deny)
are
also
planned.
These
trials
will
incorporate
screening
of
pepper
varieties
for
tolerance/
resistance
to
P.
capsici.
The
applicant
noted
that
a
program
to
evaluate
host
resistance
to
Phytophthora
root
and
crown
rot
has
been
implemented.
Growers
are
starting
to
deploy
lines
identified
with
genetic
resistance
and
acceptable
horticultural
qualities.

In
addition,
the
following
new
long­
term
studies
have
been
initiated
at
the
Coastal
Plain
Experiment
Station
in
Tifton,
Georgia,
with
funding
provided
by
USDA­
CSREES,
Methyl
Bromide
Transitions
Grant:

­
Evaluation
of
the
effects
of
soil
conditions,
particularly
soil
temperature
and
moisture,
on
nutsedge
species
efficacy
from
several
fumigants.

­
Investigation
of
the
impact
of
multiple­
season
adoption
of
methyl
bromide
alternatives
in
terms
of
pest
species
composition,
including
weeds,
diseases,
and
nematodes.
U.
S.
Pepper
Page
52
­
Integration
of
multiple
tactics
as
alternatives
to
methyl
bromide
for
management
of
weeds,
diseases,
and
nematodes
in
pepper
and
eggplant.

Evaluation
of
vegetable
crop
response
to
herbicides
applied
under
plastic
prior
to
crop
transplants
and
characterize
herbicide
fate
when
applied
in
a
plasticulture
system
between
summer
and
fall
crops.

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

No.
Soilless
systems
and
greenhouse
production
are
not
in
use
for
peppers
and
quick
adoption
is
probably
economically
infeasible.
Grafting
has
not
been
evaluated
for
vegetable
production
due
to
the
high
cost
and
the
large
number
of
plants
that
would
be
needed.
In
addition
this
alternative
is
primarily
used
for
nematode
and
plant
pathogen
management,
but
there
is
no
evidence
that
it
applies
to
competition
from
weeds.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.

GEORGIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
plant
pathogen
complex
affecting
pepper
production.
Nutsedges
resist
traditional
and
modern
methods
of
weed
control
and
are
endemic
to
large
tracts
of
pepper
producing
area
in
the
Southeastern
United
States.
Herbicides
are
applied
to
the
row
middles
between
raised
production
beds
to
manage
grass
and
broadleaf
weeds,
but
there
are
no
currently
registered
herbicides
to
address
nutsedges
in
the
row.
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern.
These
pests
are
expected
to
become
serious
problems
for
pepper
production
if
methyl
bromide
were
not
available
for
pre­
plant
fumigation.

The
1,3­
dichloropropene
and
chloropicrin
combination
does
not
effectively
control
nutsedges.
Lack
of
an
effective
registered
herbicide
for
control
of
nutsedge
impairs
adoption
of
methyl
bromide
alternatives
in
pepper
(
Banks,
2002).
In
addition,
labeling
of
1,3­
dichloropropene
products
restricts
its
use
in
key
pepper
growing
areas
of
the
U.
S.
where
karst
topography
exists,
due
to
ground­
water
contamination
concerns.
In
areas
where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions,
and
7­
28
day
waiting
periods
between
application
and
planting
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
fetch
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.
U.
S.
Pepper
Page
53
Metam
sodium
provides
limited
and
erratic
performance
at
suppressing
all
major
solanaceous
pathogens
and
pests.
Data
indicate
that
metam
sodium
is
not
an
effective
alternative
to
methyl
bromide
for
nutsedge
control
in
bell
pepper
fields
Webster
et
al.,
(
2002
a).
A
14­
30
day
planting
delay
is
also
recommended
for
this
chemical.
In
addition
there
is
evidence
that
both
1,3­
dichloropropene
and
methyl
isothiocyanate
(
the
breakdown
product
of
metam
sodium)
levels
decline
more
rapidly,
thus
further
compromising
efficacy,
in
areas
where
these
are
repeatedly
applied
(
Smelt
et
al.
1989,
Ou
et
al.
1995,
Gamliel
et
al.
2003).
This
is
due
to
enhanced
degradation
of
these
chemicals
by
soil
microbes
(
Dungan
and
Yates
2003).

Culpepper
and
Langston
(
2004)
recently
compared
the
effectiveness
of
several
soil
fumigants
in
managing
soil
pests
affecting
peppers
in
Tifton,
Georgia.
Results
show
that
1,3­
D
followed
by
chloropicrin
was
significantly
less
effective
than
methyl
bromide
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin
was
more
effective
than
MB
for
the
control
of
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
This
treatment
performed
as
well
as
MB
in
terms
of
spring
crop
yield,
but
poorly
in
terms
of
fall
yield.
1,3­
D
+
chloropicrin,
followed
by
metam
sodium
was
36%
less
effective
than
methyl
bromide
for
the
control
of
purple
nutsedge,
but
as
effective
as
MB
for
the
control
of
yellow
nutsedge.
This
combination
was
as
effective
as
MB
against
soil
nematodes.
In
terms
of
spring
and
fall
crop
yield,
this
treatment
performed
as
well
as
MB.
These
treatments
are
showing
promise
and
will
require
further
testing
and
validation
in
commercial
fields.

Research
on
the
effectiveness
of
non­
chemical
alternatives
to
methyl
bromide
is
still
in
a
preliminary
stage,
particularly
for
high
value,
minor­
use
crops.
U.
S.
Pepper
Page
54
PART
B:
FLORIDA
­
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ON
PEPPERS
FLORIDA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
FLORIDA­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
TARGET
PATHOGENS,
NEMATODES
AND/
OR
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Florida
Weeds:
yellow
&
purple
nutsedges
(
Cyperus
rotundus
&
C.
esculentus),
nightshade
(
Solanum
spp.),
white
clover
(
Trifollium
repens),
ragweed
(
Ambrosia
artemisifolia)

Plant
diseases:
phytophthora
blight
(
Phytophthora
spp.),
damping­
off
(
Rhizoctonia
solani,
Pythium
spp.),
white
mold
(
Sclerotinia
sclerotiorum)

Nematodes:
root­
knot
nematodes
(
Meloidogyne
spp.),
Only
MB
can
effectively
control
the
target
pests
found
in
Florida,
where
pest
pressures
commonly
exist
at
moderate
to
severe
levels.
Use
of
1,3­
D
is
restricted
in
key
pepper
growing
areas
of
Florida
underlain
by
karst
geology
and
sandy
(
porous)
subsoils
geological
features
that
could
lead
to
groundwater
contamination.
Approximately
40%
of
Florida's
pepper
production
land
has
these
soil
constraints.
For
instance,
1,3­
D
is
prohibited
in
Dade
County,
where
100%
of
the
pepper
growing
area
is
affected
(
U.
S.
EPA,
2002,
Noling,
2003).
Metam­
sodium
has
limited
pest
control
capabilities
and
is
not
useful
as
a
stand­
alone
fumigant
(
Noling,
2003).
Halosulfuron,
which
is
effective
against
nutsedge,
is
only
registered
for
use
in
row
middles
in
peppers.

FLORIDA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
FLORIDA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
FLORIDA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pepper
transplants
for
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
(
usually
1
yr)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Eggplants
or
cucurbits
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
and
sandy­
loam
soils
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1time
per
year
OTHER
RELEVANT
FACTORS:
Double­
cropped
with
cucurbits
U.
S.
Pepper
Page
55
FLORIDA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
Sept
Oct
NOV
DEC
JAN
FEB
CLIMATIC
ZONES
Plant
Hardiness
Zones
9a;
9b;
10a,
10.

RAINFALL
(
mm),
TAMPA,
FL
65.5
50.0
72.5
134.1
175.8
193.3
152.7
65.0
42.7
158.8
62.0
66.8,

OUTSIDE
TEMP.
(
°
C);
TAMPA,
FL
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16.0
16.9
FUMIGATION
SCHEDULE
A
X
X
X
X
X
X
TRANSPLANTING
SCHEDULE;
,
NON
DOUBLECROPPED
B
X
X
X
X
X
X
X
KEY
HARVEST
WINDOW;

NON
DOUBLE­
CROPPED
C
X
X
X
X
X
X
X
X
A
Non­
double
cropped:
earliest
start
date:
August
15;
cells
marked
with
an
"
x"
represent
variation
in
fumigation
initiation
amongst
pepper
growers.
B
For
Non­
Double
cropped
pepper
production,
transplanting
peppers
is
usually
initiated
around
September
1;
cells
marked
with
an
"
x"
represent
variation
in
transplanting
dates
amongst
pepper
growers.
.
C
For
Non­
Double
Cropped
Peppers:
Harvest
Period
usually
begins
as
early
as
Nov.
15,
and
may
continue
until
June
15,
depending
on
when
planted
and
weather
conditions.

FLORIDA
­
TABLE
11.3
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
 
PEPPERS
DOUBLE
CROPPED
WITH
ANOTHER
VEGETABLE
(
USUALLY
CUCURBITS)

MAR
APR
MAY
JUN
JUL
AUG
SEPT
Oct
NOV
DEC
JAN
FEB
CLIMATIC
ZONES
Plant
Hardiness
Zones
9a;
9b;
10a,
10.

RAINFALL
(
mm),
TAMPA,
FL
65.5
50.0
72.5
134.1
175.8
193.3
152.7
65.0
42.7
158.8
62.0
66.8,

OUTSIDE
TEMP.
(
°
C);
TAMPA,
FL
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16.0
16.9
FUMIGATION
SCHEDULE
,;
DOUBLE­
CROPPED
A
X
X
TRANSPLANTING
SCHEDULE;
DOUBLE­
CROPPED
B
2C
2C
P
P
2C
KEY
HARVEST
WINDOW;
DOUBLE­
CROPPED
C
P
P
2C
2C
2C
P
P
P
P
ADouble­
cropped;
assumed
to
be
with
cucurbits;
earliest
start
date
is
August
15;
shaded
cells
represent
variation
in
fumigation
initiation
among
pepper
growers
who
double­
crop.
BFor
Double­
Cropped
pepper
production,
transplanting
(
P)
is
typically
initiated
on
September
1;
variance
can
be
until
October
31.
The
second
crop
of
cucurbits
(
usually)
transplants
(
indicated
by
"
2C")
would
typically
be
initiated
around
Feb
15,
and
may
vary
until
April
30
C
For
Double
Cropped
peppers,
Harvest
Period
usually
begins
as
early
as
Nov.
15,
(
P),
may
continue
until
April
15,
depending
on
when
planted
and
weather
conditions;
Harvesting
of
second
crop
(
2C)
may
start
around
May
and
continue
until
mid­
July.

Climate
Zone
designation
(
http://
www.
usna.
usda.
gov/
Hardzone)
U.
S.
Pepper
Page
56
FLORIDA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

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

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

FLORIDA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
FLORIDA
­
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)
8,903
8,903
8,741
8,741
ha
8,195
ha
8,417
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
100%
strip
treatments
are
used
in
this
region
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
1,630,376
1,644,501
1,431,639
1,406,135
1,285,199
1,320,860
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
A
98:
2
&
67:
33
98:
2
&
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
A
Sweptback
chiselshank
25­
30.5
cm.
deep
Sweptback
chiselshank
25­
30.5
cm.
deep
Sweptback
chiselshank
25­
30.5
cm.
deep
Sweptback
chiselshank
25­
30.5
cm.
deep
Sweptback
chiselshank
25­
30.5
cm.
deep
Sweptback
chiselshank
25­
30.5
cm.
deep
DOSAGE
RATE
OF
STRIP/
BED,
G
MB/
M
2
18.3
18.5
16.4
16.1
15.7
15.7
A
Sources:
personal
communication,
Professor
J.
W.
Noling,
November
25,
2003;
M.
Aerts,
December
2,
2003.
U.
S.
Pepper
Page
57
Florida
­
PART
C:
TECHNICAL
VALIDATION
FLORIDA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
FLORIDA
 
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
1,3
dichloropropene
1,3­
D
provides
control
of
nematode
populations,
but
poor
control
of
plant
pathogens
and
weeds.
Control
of
nematodes
is
erratic,
due
to
poor
distribution
of
the
fumigant
in
the
sandy
soils
of
Florida.
1,3­
D's
use
is
prohibited
due
to
groundwater
contamination
in
key
pepper
growing
areas
with
karst
geology,
which
is
estimated
to
be
about
40%
in
of
FL
pepper
area
in
2002.
In
Dade
County,
a
major
pepper
production
area,
100%
of
pepper
acreage
is
affected
by
a
label
prohibition
that
addresses
groundwater
contamination
concerns.
In
areas
where
1,3­
D
use
is
allowed,
set
back
restrictions
(~
100
meters
from
occupied
structures;
~
30
meters
for
emulsified
formulations
applied
via
chemigation)
may
limit
the
portion
of
a
field
that
can
be
treated.
In
addition,
the
28­
day
waiting
period
between
application
and
planting
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
higher­
end
market
windows.
No
Metamsodium
potassium
Provides
limited
and
erratic
performance
for
suppressing
major
pepper
pathogens
and
pests.
Does
not
work
under
high
pest
pressure.
This
soil
fumigant
is
considered
the
best
available
alternative
for
Dade
County
only,
where
1,3
D
use
is
prohibited
(
Aerts,
2003).
This
is
at
best
a
treatment
that
complements
other
fumigants
and
herbicides,
and
is
not
a
stand­
alone
option
(
Noling,
2003).
Metam
sodium
has
a
lower
vapor
pressure
than
methyl
bromide,
and
therefore
cannot
penetrate
and
diffuse
throughout
the
soil
as
effectively
as
MB.
In
addition,
the
effectiveness
of
metam
sodium
is
dependent
on
the
organic
matter
and
moisture
content
of
the
soil.
Metam
sodium
tends
to
degrade
rapidly
in
warm
soils
where
it
has
been
previously
used.
No
U.
S.
Pepper
Page
58
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
Solarization
Solarization
is
not
technically
feasible
as
a
methyl
bromide
alternative
for
control
of
nutsedges.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50
oC
or
higher
(
Chase
et
al.
1999.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43
oC
at
5
cm
depth.
Thus,
solarization,
even
in
the
warmer
months
in
southern
states,
did
not
result
in
temperatures
reliably
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
Response
of
Cyperus
species
to
solarization
is
sporadic
and
not
well
understood
and
data
show
solarization
to
provide,
at
best,
suppression
of
nutsedge
populations
(
Chase
et
al.
1999).
In
addition,
solarization
will
take
fields
out
of
production
since
it
would
be
needed
during
the
spring
and
into
the
summer
months,
which
are
optimal
for
pepper
production.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
pepper
production
because
it
requires
sustained
heat
over
a
required
period
of
time
(
UNEP
1998).
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
field
pepper
crops.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
alone
cannot
control
nutsedge
and/
or
the
soil
pathogens
that
afflict
peppers.
The
bacterium
Burkholderia
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
no
biological
control
agent
has
been
identified
to
effectively
control
nutsedge
or
Phytophthora.
Therefore,
biological
control
is
not
a
stand­
along
replacement
for
methyl
bromide
in
pepper
crops.
Only
a
limited
number
of
biological
organisms
are
effectively
used
to
manage
soil
borne
plant
pathogens
and
pests.
No
Cover
crops
and
mulching
Cover
crops
and
mulches
have
been
integrated
to
solanaceous
crop
production
management.
However
there
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
nutsedges
(
Burgos
and
Talbert
1996).
Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
and
Talbert
1996,
Galloway
and
Weston
1996).
Mulching
has
also
been
shown
to
be
ineffective
in
controlling
nutsedges,
since
these
plants
are
able
to
penetrate
through
both
organic
and
plastic
mulches
(
Munn
1992,
Patterson
1998).
No
U.
S.
Pepper
Page
59
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Crop
rotation
and
fallow
land
Crop
rotation/
fallow
is
not
a
technically
feasible
alternative
to
methyl
bromide
because
it
does
not
provide
adequate
control
of
nutsedges
or
fungal
pathogens.
The
crop
rotations
available
to
growers
are
also
susceptible
to
fungi;
fallow
land
can
still
harbor
fungal
oospores
(
Lamour
and
Hausbeck
2003).
As
regards
to
nutsedges,
tubers
of
these
perennial
species
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land
(
Thullen
and
Keeley
1975).
Furthermore,
nutsedge
plants
can
produce
tubers
within
2
weeks
after
emergence
(
Wilen
et
al.
2003).
This
enhances
their
survival
across
different
cropping
regimes
that
can
disrupt
other
plants
that
rely
on
a
longer
undisturbed
growing
period
to
produce
seeds
to
propagate
the
next
generation.
No
Flooding/
Water
management
South
Florida
is
generally
subject
to
natural
flooding
during
summer
months,
but
other
areas
cannot
be
flooded
because
of
lack
of
a
shallow,
impermeable
layer.
Although
flooding
is
a
pest
management
tool
that
has
been
used
effectively
to
manage
various
soil
borne
pest
and
plant
pathogens,
nutsedges
have
shown
tolerance
to
this
treatment.
Submergence
of
nutsedge
tubers
for
periods
of
8
days
to
4
weeks
showed
no
effect
on
the
sprouting
capabilities
of
the
tubers
(
Horowitz,
1972).
Studies
in
Florida
(
Allen,
1999)
showed
ineffective
nematode,
plant
pathogen,
and
nutsedge
control.
Regulatory
issues
concerning
water
management,
as
well
as
economic
feasibility,
also
preclude
its
viability
as
an
alternative
to
methyl
bromide.
Land
structure,
frequent
and
severe
droughts,
and
the
economics
of
developing
and
managing
flood
capabilities
will
prevent
flooding
from
being
a
viable,
cost
effective
alternative
in
the
Southeastern
states.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
peppers,
they
have
been
grouped
together
for
discussion
in
this
document.
The
U.
S.
was
unable
to
locate
any
studies
showing
any
potential
for
grafting,
resistant
rootstock
or
plant
breeding
as
technically
feasible
alternatives
to
methyl
bromide
control
of
nutsedges.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
pepper
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
fungi.
Various
aspects
of
organic
production
 
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
U.
S.
Pepper
Page
60
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam
sodium
+
Chloropicrin
This
combination
has
been
used
in
Florida
since
the
1970s.
It
is
being
tested
as
a
leading
alternative
to
MB
in
Dade
County
because
of
label
restrictions
for
1,3­
D,
which
do
not
allow
its
use
in
that
county.
However,
it
has
shown
erratic
performance
suppressing
weeds,
nematodes,
and
plant
pathogens
in
the
sandy
soils
of
Florida.
MB
has
higher
vapor
pressure
than
metam
sodium
and
can
penetrate
and
diffuse
throughout
the
soil
more
effectively.
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
combination
against
soil
pathogens,
though
it
is
generally
better
than
metam­
sodium
alone
(
Locascio
and
Dickson
1998,
Csinos
et
al.
1999).
This
alternative
will
require
further
testing
and
validation
on
commercial
fields.
No,
but
shows
promise
1,3
dichloropropene
+
chloropicrin
(
Telone
C35)
Although
this
combination,
by
itself,
is
not
effective
in
areas
with
moderate
to
high
nutsedge
pressure,
it
can
provide
season
long
control
when
coupled
with
herbicides
(
Chellemi
et
al.
2001;
Gilreath
and
Santos,
2003).
Trials
comparing
Flat
Fumigation
applications
with
standard
in­
row
applications
indicated
the
need
to
increase
the
amount
of
chloropicrin
to
compensate
for
the
potential
decrease
in
efficacy
of
1,3­
D
applied
via
Flat
Fumigation.
Applications
via
micro­
irrigation
systems
have
yielded
mixed
results,
probably
due
to
poor
lateral
distribution
of
the
chemical
in
the
soil
(
Martin
2003;
Dungan
and
Yates,
2003).
In
addition,
1,3­
D's
use
is
prohibited
due
to
groundwater
contamination
in
areas
with
karst
geology,
estimated
to
be
about
40%
in
of
FL
pepper
area
in
2002.
In
Dade
County
this
combination
is
not
allowed
at
all.
A
Telone
C35
application,
along
with
a
herbicide
mix
(
e.
g.
clomazone
+
metolachlor)
applied
at
bed
formation,
has
been
identified
by
the
Florida
Fruit
and
Vegetable
Association
as
the
recommended
best
MB
alternative
outside
karst
geology
areas.
Although
promising,
this
alternative
will
require
further
testing
and
validation
on
commercial
fields.
No,
but
shows
promise
for
nonkarst
geology
areas.

1,3
dichloropropene
+
Metam­
sodium
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Csinos
et
al.
1999).
Low
efficacy
in
even
small­
plot
trials
indicates
that
this
is
not
a
technically
feasible
alternative
for
commercially
produced
peppers
at
this
time.
In
addition,
1,3­
D's
use
is
prohibited
due
to
groundwater
contamination
in
all
pepper
growing
areas
with
karst
geology,
estimated
to
be
about
40%
in
of
FL
pepper
area
in
2002.
In
Dade
County
100%
of
pepper
acreage
is
affected
by
this
limitation.
No
Fumigant
combination
+
herbicide
partners
Current
research
suggests
that
in
areas
of
low
pest
pressure
this
combination
may
be
suitable
for
some
growers
as
an
alternative
for
methyl
bromide.
In
these
situations
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition
Yes
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
U.
S.
Pepper
Page
61
FLORIDA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

FLORIDA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Halosulfuron­
methyl
For
nutsedges:
potential
crop
injury;
plant
back
restrictions.
Efficacy
is
lowered
in
rainy
conditions
(
which
are
common
in
this
region).
Also,
a
24­
month
plant
back
restriction
may
cause
significant
economic
disruption
if
growers
must
rely
on
this
control
option.
Halosulfuron
is
registered
for
use
in
row
middles
only.

Glyphosate
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Paraquat
For
nutsedges:
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control.
Another
weed,
nightshade,
has
shown
resistance
to
paraquat,
a
dangerous
development
since
this
plant
serves
as
a
reservoir
for
many
insects
(
e.
g.,
whiteflies),
that
are
vectors
of
pepper
diseases
(
Aerts,
2004)

Other
than
those
options
discussed
in
Table
13.1
and
elsewhere
in
this
document,
no
alternative
exists
for
the
control
of
the
key
pests
and
fungi
affecting
pepper
production.
Non­
chemical
alternatives
and
chemical
alternatives
to
methyl
bromide
have
been
or
are
being
investigated
and
when
suitable,
incorporated
into
current
pepper
production
practices.

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

Since
methyl
bromide
has
been
used
effectively
to
manage
minor
crop
production,
there
are
limited
pesticide
alternatives
due
primarily
to
the
small
market
share
and
the
high
cost
associated
with
pesticide
registration.
Labeling
of
these
products
in
minor
crops
could
be
more
expensive
than
returns
from
potential
sales,
and
therefore
pesticide
manufactures
have
been
reluctant
to
register
pesticides
for
minor
crop
uses.
Methyl
bromide
will
be
needed
until
a
cost­
effective
alternative
regimen
is
in
place.
U.
S.
Pepper
Page
62
FLORIDA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

FLORIDA
 
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:

Iodomethane
Pre­
plant
soil
fumigant.
Not
registered
yet
Yes
Unknown
Trifloxysulfuron
sodium
Herbicide
­
recently
registered
for
tomato
in
FL
only.
Crop
injury
potential
exist
No
Unknown
Fosthiazate
Not
registered
on
peppers
No
Unknown
Furfural
(
Multigard
 
)
Not
registered
No
Unknown
Sodium
azide
Not
registered.
No
registration
application
received.
No
Unknown
Propargyl
bromide
Not
registered.
No
registration
application
received.
No
Unknown
Paecilomyces
lilacinus
Biological
nematicide;
not
registered
Yes
Unknown
FLORIDA
­
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:

FLORIDA
­
TABLE
16.1.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.
1997)­
)

Chemicals
Rate
(
kg/
ha)
Average
Nutsedge
Density
(#/
m2)
Average
Marketable
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Untreated
(
control)
­
300
ab
20.1
a
59.1
MB
+
Pic
(
67­
33),
chisel­
injected
390
kg
90
c
49.1
b
­­­

1,3
D
+
Pic
(
83­
17),
chisel­
injected
327
l
340
a
34.6
c
29.5
Metam
Na,
Flat
Fumigation
300
l
320
a
22.6
a
54.0
Metam
Na,
drip
irrigated
300
l
220
b
32.3
c
34.2
Notes:
(
1)
Numbers
followed
by
the
same
letter
(
within
a
column)
are
not
significantly
different
at
the
0.05
level
of
probability,
using
Duncan's
multiple
range
test.
(
2)
Data
shown
are
from
the
Gainesville/
Horticultural
Unit
site,
1994
season
(
this
was
one
of
three
sites
included
in
this
study).
This
site
had
relatively
high
nutsedge
pressure,
and
data
for
both
pest
pressure
and
marketable
yields
for
all
treatments
shown.
All
fumigants
were
injected
15­
20
cm
deep,
with
three
chisels
per
bed,
30
cm
apart
U.
S.
Pepper
Page
63
Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
The
data
from
the
tomato
study
are
being
cited
because
pepper
data
are
not
available.

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

FLORIDA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
dichloropropene
+
chloropicrin
Nutsedges,
fungal
pathogens
20
­
100
29
Metam­
sodium
(
with
or
without
chloropicrin)
Nutsedges,
fungal
pathogens
30
­
55
44
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
29
%
if
1,3
D
+
pic
is
used;
44
%
if
metamsodium
is
used
FLORIDA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Iodomethane
is
being
considered
for
registration
as
a
methyl
bromide
replacement.
Its
registration
date
is
not
known.
Please
refer
to
Table
15.1
for
details.
U.
S.
Pepper
Page
64
FLORIDA­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

The
U.
S.
EPA
is
unaware
of
large­
scale,
commercial
greenhouse
operations
for
peppers
or
other
technologies
that
could
reduce
methyl
bromide
use.
There
may
be
local
or
small
community
organic
or
hothouse
pepper
production
that
targets
fresh
market
and/
or
temporal
(
seasonal)
sectors.

Grafting
has
not
been
evaluated
for
vegetable
production
due
to
the
high
cost
and
the
large
number
of
plants
that
would
be
needed.
In
addition
this
alternative
is
primarily
used
for
nematode
and
plant
pathogen
management,
but
there
is
no
evidence
that
it
applies
to
competition
from
weeds.
Plug
plants
are
extensively
used
on
high
value
vegetable
crops
like
pepper
but
they
do
not
control
competition
from
nutsedges.

FLORIDA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
Weeds,
particularly
nutsedge,
are
the
major
pests
of
Florida
peppers
that
drive
the
need
for
methyl
bromide.
There
are
no
registered
herbicides
compatible
with
pepper
production.
Although
s­
metolachlor
(
Dual
Magnum)
and
napropamide
(
Devrinol)
were
cited
as
herbicides
with
some
potential
to
control
nutsedges,
their
efficacy
in
sub­
tropical
Florida
is
inconsistent
(
Noling,
2003).
Furthermore,
s­
metolachlor's
effectiveness
is
restricted
to
yellow
nutsedge.
When
nutsedge
pressure
is
moderate
to
severe,
1,3­
D
+
chloropicrin
is
not
technically
feasible
because
it
needs
to
be
coupled
with
an
effective
herbicide
to
provide
control
for
the
entire
growing
season
(
U.
S.
EPA,
2002).
Frank
et
al
(
1992)
reported
that
weeds
in
pepper
for
40
to
60
days
could
reduce
yields
by
10
to
50
percent.
Stall
and
Morales­
Payan
reported
that
tomato
must
be
nutsedge­
free
for
2
to10
weeks
to
keep
yield
reductions
below
5
percent.
There
are
no
herbicides
which
control
purple
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041).

In
addition,
labeling
of
1,3­
dichloropropene
products
restricts
its
use
in
key
pepper
growing
areas
of
the
U.
S.
where
karst
geology
exists
due
to
ground­
water
contamination
concerns.
In
areas
where
1,3­
dichloropropene
use
is
allowed,
set
back
restrictions
and
a
28
day
waiting
periods,
at
the
maximum
label
rate,
between
application
and
planting
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops.
For
example,
peppers
produced
during
the
winter
fetch
a
higher
price
than
peppers
produced
during
warmer
months,
and
many
growers
rely
on
this
price
premium
to
maintain
profitability.
U.
S.
Pepper
Page
65
Metam
sodium
provides
limited
and
erratic
performance
at
suppressing
all
major
solanaceous
pathogens
and
pests.
Data
indicate
that
metam
sodium
is
not
an
effective
alternative
to
methyl
bromide
for
nutsedge
control
in
bell
pepper
fields
(
Webster
et
al.
(
2002).
A
14­
30
day
planting
delay
is
also
recommended
for
this
chemical.
In
addition
there
is
evidence
that
both
1,3­
dichloropropene
and
methyl
isothiocynate
(
the
breakdown
product
of
metam
sodium)
levels
decline
more
rapidly,
thus
further
compromising
efficacy,
in
areas
where
these
are
repeatedly
applied
(
Smelt
et
al.
1989,
Ou
et
al.
1995,
Gamliel
et
al.
2003).
This
is
due
to
enhanced
degradation
of
these
chemicals
by
soil
microbes
(
Dungan
and
Yates
2003).

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Sclerotinia,
Phytophthora
spp.,
Verticillium
spp.,
Pythium
spp.
and
Rhizoctonia
solani
)
commonly
reside
in
many
production
areas,
since
many
pepper
production
areas
are
old
tomato
production
fields.
Fungicides
such
as
chlorothalonil,
and
azoxystrobin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck
2003).

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

Research
on
the
effectiveness
of
non­
chemical
alternatives
to
methyl
bromide
is
still
in
a
preliminary
stage,
particularly
for
high
value,
minor­
use
crops.
U.
S.
Pepper
Page
66
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL)
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Crown
and
root
rots
caused
by
soilborne
fungi
 
particularly
Phytophthora
capsici;
plant­
parasitic
nematodes,
primarily
root
knot
(
Meloidogyne
spp.)
Registered
alternative
fumigants,
fungicides,
and
nematicides
are
not
as
cost­
effective
and
do
not
provide
the
same
level
of
pest
control
as
methyl
bromide.
One
application
of
methyl
bromide
can
last
more
than
a
year
(
within
a
particular
field),
whereas
alternative
chemicals
must
be
applied
annually.

CALIFORNIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Pepper
transplants
for
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual;
generally
1
year
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Pepper
may
be
followed
by
pepper,
celery,
broccoli
or
leafy
vegetables
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
loam;
clay
loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
1
time
every
2
years
OTHER
RELEVANT
FACTORS:
High
land
costs
and
urban
encroachment
increasing
near
production
areas.
Very
few
crops
can
be
rotated
with
peppers
that
will
provide
an
economic
return.
U.
S.
Pepper
Page
67
CALIFORNIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
Plant
Hardiness
Zone
9b
RAINFALL
(
mm)
A,
B
16.0
29.7
72.1
112.3
17.3
16.0
0
0
T
17.2
1.0
T
T
0
0
T
44.7
74.9
56.9
273.1
9.9
36.3
30.5
62.2
OUTSIDE
TEMP.
(
°
C)
A
14.4
13.2
14.8
12.4
20.8
14.9
25.7
17.1
30.3
17.2
27.4
19.1
25.1
18.2
18.4
16.3
13.4
14.2
9.6
11.4
10.3
2.1
10.6
11.2
FUMIGATION
SCHEDULE
C
X*
X*
X*

PLANTING
SCHEDULE
C
X
X
KEY
MARKET
WINDOW
X
X
X
X
X
Notes:
*
Fumigation
occurs
in
these
months,
but
only
every
other
year,
typically.
A
Air
temperatures
and
rainfall
data
were
collected
from
weather
stations
in
Fresno
(
top
number)
and
at
the
San
Francisco
Airport
(
bottom
number)
from
September
to
December
2002
and
January
to
August,
2003.
BA
"
T"
in
the
column
denotes
trace
amount
of
rainfall
recorded
C
The
above
cycle
is
if
another
pepper
crop
followed
the
first
planting
of
peppers.
If
other
crops
follow
pepper,
then
planting
of
the
other
crops
(
e.
g.,
a
leafy
vegetable)
would
begin
in
October
and
harvest
would
be
in
December,
January
and
February.

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

Urban
encroachment
and
concomitant
buffer
zones
and
local
(
township)
caps
restrict
the
use
of
the
MB
alternative
1,3
D
(
with
or
without
chloropicrin).
This
prevents
the
use
of
this
alternative
on
approximately
10
%
of
the
pepper
growing
area
in
California,
according
to
the
applicant.
The
applicant
is
requesting
MB
only
for
this
proportion
of
their
total
pepper
acreage.

CALIFORNIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
In
California,
the
soil
injection
of
MB
under
tarps
has
increased
from
approximately
68%
of
the
area
using
this
fumigant
in
1997
to
93%
in
2003.
The
depth
of
methyl
bromide
application
varies
from
15
to
36
cm
centimeters
below
tarps.
The
low
MB
dosage
rate
is
due
in
large
part
to
a
shift
by
all
growers
to
formulations
lower
than
the
98:
2
ratio
that
was
used
in
the
mid­
1990s.
The
formulations
most
commonly
in
use
currently
are
75:
25
or
67:
33
mixture
of
methyl
bromide:
chloropicrin.
(
Melban
2003).
Please
see
Table
12.1
for
further
information.
U.
S.
Pepper
Page
68
CALIFORNIA­
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)
864
1,226
995
447
121
Not
available
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Ratio
of
Flat
Fumigation
treatments
versus
bed
applications
is
not
known.
Two
methods
of
application
are
used:
Flat­
fumed
type,
and
methyl
bromide
is
injected,
and
sealed
with
plastic
ground
cover.
If
buffer
zones
are
strict
(
e.
g.,
in
southern
Santa
Clara
County),
then
almost
all
applications
are
flat­
fumed,
Flat
Fumigation.
The
second
type
of
application
involves
bed­
fumed
(~
0.67
A,
or
29,000
sq.
ft)
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
182,834
247,191
170,830
63,558
25,929
Not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
75:
25
or
67:
33
75:
25
or
67:
33
75:
25
or
67:
33
75:
25
or
67:
33
75:
25
or
67:
33
75:
25
or
67:
33
METHODS
BY
WHICH
METHYL
BROMIDE
APPLIED
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
Flat­
fumed
or
bed
fumed,
injected
16­
36
cm
deep
APPLICATION
RATE
OF
FLAT
FUMIGATION
;
FLATFUMED
KG
A.
I./
ha*
212
202
172
142
214
Not
available
DOSAGE
RATE*(
G/
M
2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
27.4
27.4
27.4
27.4
27.4
Not
available
U.
S.
Pepper
Page
69
California
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA 
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
Metam
Sodium
Control
of
key
fungal
pest
is
inconsistent
at
best
(
Martin
2003).
The
use
of
metam­
sodium
also
creates
a
14­
30
day
planting
delay
(
waiting
period
from
application
to
planting)
to
avoid
risk
of
phytotoxic
injury
to
crops
compared
to
a
14­
day
delay
for
MB.
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season;
Fusarium
was
one
of
several
pests
present
No
1,3
dichloropropene
I,
3­
D
controls
nematodes,
but
performs
poorly
with
soil
pathogens
and
weeds.
Furthermore,
California
has
township
caps
limiting
the
amount
of
1,
3
D
that
can
be
used
near
urban
areas
and
a
mandatory
buffer
(
approx.
100
m)
around
treated
areas.
The
use
of
1,3­
D
also
requires
a
28­
day
waiting
period
between
application
and
planting.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
California's
coastal
climate
is
typically
cool
(
less
than
16
oC
frequently
through
December),
rainy,
and
cloudy,
particularly
early
in
the
pepper­
growing
season
when
control
of
the
key
pests
is
particularly
important.
Since
solarization
has
shown
some
potential
in
other
crops
and
regions
(
e.
g.,
tomatoes
in
Florida),
the
potential
for
adoption
exists
(
Schneider
et
al.
2003).
However,
at
this
time
it
is
technically
infeasible
for
California
coastal
peppers.
No
Steam
While
steam
has
been
used
effectively
against
fungal
pests
in
protected
production
systems,
such
as
greenhouses,
there
is
no
evidence
that
it
would
be
effective
in
open
field
pepper
crops
in
California.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
sterilize
soil
down
to
the
rooting
depth
of
field
crops
(
at
least
20­
50
cm).
No
Biological
Control
Biological
control
agents
are
not
technically
feasible
alternatives
to
methyl
bromide
because
they
alone
cannot
control
the
soil
pathogens
that
afflict
peppers
in
California.
The
bacterium
Burkholderia
cepacia
and
the
fungus
Gliocladium
virens
have
shown
some
potential
in
controlling
some
fungal
plant
pathogens
(
Larkin
and
Fravel
1998).
However,
in
a
test
conducted
in
Michigan,
P.
capsici
was
not
controlled
adequately
in
summer
squash
by
either
of
these
beneficial
microorganisms.
Tests
in
California
peppers
have
apparently
not
been
conducted.
No
U.
S.
Pepper
Page
70
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Cover
crops
and
mulching
There
is
no
evidence
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
P.
capsici.
Plastic
mulch
is
already
in
widespread
use
in
California
vegetables,
and
regional
crop
experts
state
that
it
is
not
an
adequate
protectant
when
used
without
methyl
bromide.
The
longevity
and
resistance
of
P.
capsici
oospores
renders
cover
crops
ineffective
as
a
stand­
alone
management
alternative
to
methyl
bromide.
No
Crop
rotation
and
fallow
land
The
crop
rotations
available
to
growers
in
the
coastal
California
region
are
also
susceptible
to
these
fungi,
particularly
to
P.
capsici.
Fallow
land
can
still
harbor
P.
capsici
oospores
(
Lamour
and
Hausbeck
2003).
Thus
fungi
would
persist
and
attack
peppers
if
crop
rotation/
fallow
land
was
the
main
management
regime.
The
same
phenomenon
applies
to
nematodes,
another
important
soil
pest
in
this
region.
No
Endophytes
Though
these
organisms
(
fungi
that
grow
symbiotically
or
as
parasites
within
plants)
have
been
shown
to
suppress
some
plant
pathogens
in
cucumber,
there
is
no
such
information
for
the
pepper
crops
grown
in
California.
Furthermore,
the
pathogens
involved
did
not
include
Phytophthora
species,
which
are
arguably
the
greatest
single
threat
to
California
peppers.
No
Flooding/
Water
management
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
P.
capsici
(
Allen
et
al.
1999),
and
is
likely
to
be
impractical
for
California
pepper
growers.
It
is
unclear
whether
irrigation
methods
in
this
region
could
be
adapted
to
incorporate
flooding
or
alter
water
management
for
pepper
fields.
In
any
case,
there
appears
to
be
no
supporting
evidence
for
its
use
against
the
hardy
oospores
of
P.
capsici.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrat
es/
plug
plants.
Due
to
the
paucity
of
scientific
information
on
the
utility
of
these
alternatives
as
methyl
bromide
replacements
in
peppers,
they
have
been
grouped
together
for
discussion
in
this
document.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
major
pepper
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
Phytophthora
and
Fusarium
fungi.
Soilless
culture,
organic
production,
and
substrates/
plug
plants
are
also
not
technically
viable
alternatives
to
methyl
bromide
for
fungi.
P.
capsici
can
spread
through
water
(
Gevens
and
Hausbeck
2003),
making
it
difficult
to
keep
any
sort
of
area
(
with
or
without
soil)
plant
pathogen
free.
Various
aspects
of
organic
production
 
e.
g.,
cover
crops,
fallow
land,
and
steam
sterilization
­
have
already
been
addressed
in
this
document
and
assessed
to
be
technically
infeasible
methyl
bromide
alternatives.
No
COMBINATIONS
OF
ALTERNATIVES
U.
S.
Pepper
Page
71
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam
sodium
+
Chloropicrin
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Locascio
and
Dickson
1998,
Csinos
et
al.
1999).
Low
efficacy
in
even
small­
plot
trials
indicates
that
this
is
not
a
technically
feasible
alternative
for
commercially
produced
cucurbits
at
this
time.
These
studies
apparently
did
not
measure
yield
impacts,
and
did
not
involve
cucurbits.
The
use
of
metam­
sodium
requires
a
21­
day
waiting
period
from
application
to
planting
to
avoid
risk
of
phytotoxic
injury
to
crops.
No
1,3
dichloropropene
+
metam­
sodium
Trials
in
tomato
have
shown
inconsistent
efficacy
of
this
formulation
against
fungal
pests,
though
it
is
generally
better
than
metam­
sodium
alone
(
Csinos
et
al.
1999).
Furthermore,
the
use
of
metam­
sodium
requires
a
21­
day
waiting
period
from
application
to
planting,
while
1,2­
D
has
a
28­
day
waiting
period.
No
1,3
dichloropropene
+
chloropicrin
This
combination
has
shown
effectiveness
equivalent
to
that
of
MB
against
nematodes
(
Eger
2000).
However,
California
has
township
caps
on
the
amount
of
1,3­
D
and
chloropicrin
that
can
be
used
near
urban
areas
and
a
mandatory
buffer
(
approx.
100
m)
around
treated
areas,
factors
that
may
result
in
significant
areas
remaining
untreated.
The
use
of
1,3­
D
requires
a
28
day
waiting
period
between
application
and
planting.
No
Fumigant
combination
+
herbicide
partners
Current
research
suggests
that
in
areas
of
low
pest
pressure
this
combination
may
be
suitable
for
some
growers
as
an
alternative
for
methyl
bromide.
In
these
situations
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
Yes
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

NAME
OF
ALTERNATIVE
DISCUSSION
Other
than
those
options
discussed
elsewhere,
no
alternatives
exist
for
the
control
of
the
key
pests
when
they
are
present
in
the
soil
and/
or
afflict
the
belowground
portions
of
pepper
plants.
A
number
of
effective
fungicides
are
available
for
treatment
of
these
fungi
when
they
infect
aerial
portions
of
crops.
However,
these
infections
are
not
the
focus
of
MB
use,
which
is
meant
to
keep
newly
planted
transplants
free
of
these
fungi.

California
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
U.
S.
Pepper
Page
72
CALIFORNIA
 
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
State
if
registered
for
this
crop,
registered
for
crop
but
use
restricted,
registered
for
other
crops
but
not
target
crop,
or
not
registered
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

Methyl
iodide
Not
registered
Yes
Unknown
Furfural
Not
registered
No
Unknown
Sodium
azide
Not
registered.
No
registration
application
received.
No
Unknown
Propargyl
bromide
Not
registered.
No
registration
application
received.
No
Unknown
CALIFORNIA­
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:

1,3­
D
+
chloropicrin
has
shown
effectiveness
equivalent
to
that
of
MB
against
nematodes
(
Eger
2000).
In
studies
with
other
vegetable
crops,
this
combination
has
generally
shown
better
control
of
soil­
borne
fungi
than
metam­
sodium
formulations
(
though
still
not
as
good
as
control
with
MB).
For
example,
in
a
study
using
a
bell
pepper/
squash
rotation
in
small
plots
­
conducted
in
the
much
warmer
conditions
of
Georgia
and
without
P.
capsici
as
a
component
of
the
pest
complex
­
Webster
et
al.
(
2001)
found
significantly
lower
fungal
populations
with
1,3
D
+
35
%
chloropicrin
(
drip
irrigated
or
chisel
injected,
146
kg/
ha
of
1,3
D),
as
compared
to
the
untreated
control.
However,
MB
(
440
kg/
ha,
shank­
injected)
lowered
fungal
populations
even
more.
Methyl
iodide
had
no
significant
suppressive
effect,
as
compared
to
the
untreated
control.
In
another
study,
conducted
on
tomatoes
in
Florida,
Gilreath
et
al.
(
1994)
found
that
metam­
sodium
treatments
did
not
match
MB
in
terms
of
plant
vigor
at
the
end
of
the
season;
Fusarium
was
one
of
several
pests
present.
However,
California
has
township
caps
on
the
amount
of
1,3­
D
and
chloropicrin
that
can
be
used
near
urban
areas
and
a
mandatory
buffer
(
approx.
100
m)
around
treated
areas,
factors
that
may
result
in
significant
areas
remaining
untreated.
The
use
of
1,3­
D
also
requires
a
28
day
waiting
period
between
application
and
planting.

CALIFORNIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3
dichloropropene
+
Chloropicrin
Soil
borne
plant
pathogens
and
nematodes
0
 
6
%
PLUS
loss
of
revenue
due
to
planting
delays
6
%
loss
of
revenue
due
to
planting
delays
Metam
sodium
(
with
or
without
chloropicrin)
Soil
borne
plant
pathogens
and
nematodes
0
 
6
%
PLUS
loss
of
revenue
due
to
planting
delays
6
%
loss
of
revenue
due
to
planting
delays
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
6
%
likely
with
the
best
alternative
(
1,3
D
+
chloropicrin)
U.
S.
Pepper
Page
73
CALIFORNIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

The
critical
use
exemption
applicant
states
that
chloropicrin,
1,3
D,
metam­
sodium,
water
management,
and
plant
varieties
will
continue
to
be
tested
for
efficacy
against
P.
capsici
and
other
key
soil­
borne
pathogens.

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

No.
Soilless
systems
and
greenhouse
production
are
not
in
use
for
peppers
in
this
region,
and
quick
adoption
is
probably
economically
infeasible.
Growers
apply
MB
on
fields
with
a
history
of
pest
contamination,
but
it
appears
that
most
growing
acreage
in
this
region
has
moderate
to
severe
infestations,
particularly
of
P.
capsici
and
other
soil
borne
fungi,
which
thrive
in
cool
and
moist
climates.

CALIFORNIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Without
MB,
pepper
producers
in
cool
weather
climates
of
Ventura
and
Santa
Clara
Counties
would
most
likely
use
a
mixture
of
1,3­
D
and
chloropicrin
(
Telone
C­
35)
to
manage
nematode
and
fungal
pathogen
populations
prior
to
transplanting
pepper.
There
is
evidence
from
numerous
small
plot
and
large­
scale
trials
to
indicate
that
these
MB
alternatives,
in
combination,
will
control
nematodes
to
the
extent
that
MB
does
nematodes
(
e.
g.
Eger
2000).
However
fungal
pests,
particularly
P.
capsici,
may
not
be
controlled
to
a
similar
extent.
No
large­
plot
studies
have
yet
been
performed
to
show
commercial
feasibility
against
fungal
pests
in
coastal
California
peppers.
Regulatory
constraints
on
1,3
D
and
chloropicrin
must
also
be
kept
in
mind:
township
caps
on
the
amounts
used
(
which
may
affect
the
use
rate,
and
hence
efficacy),
and
mandatory
100
m
buffers
near
inhabited
structures,
both
of
which
could
cause
negative
economic
impacts
on
the
pepper
industry.
These
planting
restrictions
may
inhibit
widespread
grower
adoption
of
this
MB
alternative.

Currently
unregistered
alternatives,
such
as
furfural
and
sodium
azide,
have
shown
good
efficacy
against
the
key
pests
involved.
However,
even
if
registration
is
pursued
soon
(
and
there
is
no
indication
of
plans
to
do
so)
these
options
will
need
more
validation
and
adaptation
research
specific
to
commercial
pepper
production
in
California.
There
are
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
pepper
growers.
In
sum,
while
the
potential
exists
for
a
combination
of
chemical
and
non­
chemical
alternatives
to
replace
MB
use
in
California
pepper,
this
goal
still
is
a
few
years
away.
U.
S.
Pepper
Page
74
PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE:

TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
Currently
some
growers
use
HDPE
tarps.
Growers
have
switched
from
a
98%
MB
formulation
to
a
67
%
formulation.
Between
1997
and
2001,
the
U.
S.
has
achieved
a
36
%
reduction
in
use
rates.
From
2
%
to
33
%
No
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Research
is
underway
to
develop
use
in
commercial
production
systems
A
50
%
MB
formulation
is
being
tested
in
Michigan
pepper
fields.
A
similar
formulation
was
tested
in
Florida
and
found
to
be
ineffective.
A
50
%
MB
formulation
is
being
tested
in
Michigan
pepper
fields.
A
similar
formulation
was
tested
in
Florida
and
found
to
be
ineffective.
The
U.
S.
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

OTHER
MEASURES
(
please
describe)
Examination
of
promising
but
presently
unregistered
alternative
fumigants
and
herbicides,
alone
or
in
combination
with
non­
chemical
methods,
is
planned
in
all
regions
(
Please
see
Section
17
for
each
region
for
details)
Measures
adopted
in
Michigan
will
likely
be
used
in
the
other
regions
when
fungi
are
the
only
key
pests
involved
Measures
adopted
in
Michigan
will
likely
be
used
in
the
other
regions
when
fungi
are
the
only
key
pests
involved
Unknown
U.
S.
Pepper
Page
75
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
In
accordance
with
the
criteria
of
the
critical
use
exemption,
each
party
is
required
to
describe
ways
in
which
it
strives
to
minimize
use
and
emissions
of
MB.
The
use
of
MB
in
the
growing
of
peppers
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
MB
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
MB
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
MB
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
MB
and
keep
related
emissions
to
the
lowest
level
possible,
MB
application
for
cucurbits
is
most
often
machine
injected
into
soil
to
specific
depths.

As
MB
has
become
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
MB
and
chloropicrin.
Specifically,
in
the
early
1990s,
MB
was
typically
sold
and
used
in
MB
mixtures
made
up
of
92%
MB
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
MB,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
MB.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
at
low
to
moderate
levels
of
infestation,
it
must
be
stressed
that
the
long­
term
efficacy
of
these
mixtures
is
unknown.

Tarpaulin
(
high
density
polyethylene)
is
also
used
to
minimize
use
and
emissions
of
MB.
In
addition,
pepper
growers
utilize
cultural
practices.

Reduced
MB
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
MB
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world
for
the
uses
described
in
this
nomination.
U.
S.
Pepper
Page
76
PART
E:
ECONOMIC
ASSESSMENT
Economic
data
from
the
2004
submission
for
all
applicants
were
not
substantially
different
from
those
in
2003
(
greater
or
less
than
a
10%
change
in
costs
and
revenue).
Given
these
insignificant
differences,
the
economic
analyses
were
not
updated
for
any
applicants
other
than
Michigan,
which
was
updated
to
reflect
a
change
in
the
requested
pounds
of
MeBr.

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

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

21.
OPERATING
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:
U.
S.
Pepper
Page
77
TABLE
21.1:
PEPPERS
 
OPERATING
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
California
Methyl
Bromide
100%
$
17,246
$
17,246
$
17,246
1,3­
D
+
Chloropicrin
94%
$
17,160
$
17,160
$
17,160
Florida
Methyl
Bromide
100%
$
20,341
$
20,341
$
20,341
1,3­
D
+
Chloropicrin
71%
$
18,510
$
18,510
$
18,510
Metam­
Sodium
56%
$
16,999
$
16,999
$
16,999
Georgia
Methyl
Bromide
100%
$
28,623
$
28,623
$
28,623
1,3­
D
+
Chloropicrin
71%
$
25,790
$
25,790
$
25,790
Metam­
Sodium
56%
$
23,598
$
23,598
$
23,598
Michigan
Methyl
Bromide
100%
$
23,938
$
23,938
$
23,938
1,3­
D
+
Chloropicrin
94%
$
25,607
$
25,607
$
25,607
Southeast
USA
Methyl
Bromide
100%
$
18,758
$
18,758
$
18,758
1,3­
D
+
Chloropicrin
71%
$
18,844
$
18,844
$
18,844
Metam­
Sodium
56%
$
16,731
$
16,731
$
16,731
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide
e.
g.
10%
more
yield,
write
110.
U.
S.
Pepper
Page
78
22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
PEPPERS
 
YEAR
1,
2,
AND
3
GROSS
AND
NET
REVENUES
YEAR
1,
2,
AND
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
California
Methyl
Bromide
$
21,344
$
4,098
1,3­
D
+
Chloropicrin
$
20,063
$
2,903
Florida
Methyl
Bromide
$
29,498
$
9,158
1,3­
D
+
Chloropicrin
$
20,944
$
2,433
Metam­
Sodium
$
16,519
$(
479)
Georgia
Methyl
Bromide
$
35,176
$
6,553
1,3­
D
+
Chloropicrin
$
24,975
$(
816)
Metam­
Sodium
$
19,698
$(
3,900)
Michigan
Methyl
Bromide
$
24,056
$
118
1,3­
D
+
Chloropicrin
$
20,916
$(
2,994)
Southeastern
USA
Methyl
Bromide
$
30,579
$
11,822
1,3­
D
+
Chloropicrin
$
21,711
$
2,867
Metam­
Sodium
$
17,124
$
393
NOTE:
Year
1
equals
year
2
and
3.
U.
S.
Pepper
Page
79
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
PEPPER
­
TABLE
E1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

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

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

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

5.
PROFIT
MARGIN
(%)
19%
14%

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

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

FIVE
LOSS
MEASURES
*

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

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
73%
105%

5.
PROFIT
MARGIN
(%)
31%
12%
­
3%
U.
S.
Pepper
Page
80
GEORGIA
PEPPER
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
GEORGIA
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

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

FIVE
LOSS
MEASURES
*

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

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

5.
PROFIT
MARGIN
(%)
19%
­
3%
­
20%

MICHIGAN
PEPPER­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
YIELD
LOSS
(%)
0%
6%

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

FIVE
LOSS
MEASURES
*

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

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

5.
PROFIT
MARGIN
(%)
0%
­
22%
U.
S.
Pepper
Page
81
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
PEPPER
­
TABLE
E.
5:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
USA
(
EXCEPT
GEORGIA)
PEPPER
METHYL
BROMIDE
1,
3­
D
+
CHLOROPICRIN
METAMSODIUM
YIELD
LOSS
(%)
0%
29%
44%

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

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

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

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

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

California
Yield
loss
in
California
pepper
production
is
expected
to
be
6%
when
using
MeBr
alternatives.
Growers
will
experience
loss
on
a
per
hectare
basis
of
approximately
$
1,200
and
6%
and
29%
losses
in
gross
and
net
revenues,
respectively.
However,
these
measures
do
not
clearly
indicate
that
1,3­
D
+
chloropicrin
is
an
economically
infeasible
alternative
to
MeBr.

The
economic
conditions
facing
pepper
growers
were
quantified
as
best
as
possible
but,
primarily
due
to
limited
data
availability,
every
aspect
of
the
economic
picture
was
not
included
in
the
numeric
assessment.
Factors
not
accounted
for
are
distribution
of
yield
loss
across
individual
growers
and
the
yield
risk
associated
with
using
MeBr
alternatives.
U.
S.
Pepper
Page
82
Michigan
The
US
concludes
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Michigan
pepper
production.
Two
factors
have
proven
most
important
in
this
conclusion.
These
are
yield
loss
and
missed
market
windows,
which
are
discussed
individually
below.

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

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

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

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

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

Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MeBr
are
presently
available
to
U.
S.
Pepper
Page
83
the
effected
pepper
growers.
As
such,
the
US
concludes
that
use
of
MeBr
is
critical
in
Georgia
pepper
production.

Southeastern
USA
Except
Georgia
No
technically
(
and
thus
economically)
feasible
alternatives
to
MeBr
are
presently
available
to
the
effected
pepper
growers.
As
such,
the
US
concludes
that
use
of
MeBr
is
critical
in
Southeastern
USA
pepper
production.
U.
S.
Pepper
Page
84
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Since
1997,
the
United
States
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
registration
priority.
Because
the
EPA
currently
has
more
applications
pending
in
its
registration
review
queue
than
the
resources
to
evaluate
them,
EPA
prioritizes
the
applications.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
Agency
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
Agency's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
Agency
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
Agency
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
U.
S.
DA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
drinking
water
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
U.
S.$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
U.
S.
$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.

The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
peppers
research
will
require
2844
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
One
example
of
the
research
is
a
field
study
testing
the
comparative
performance
of
methyl
bromide,
host
resistance,
cultural
practices,
pest
management
approaches
for
control
of
rootknot
nematodes.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
D
combined
with
biologically
based
materials
including
transplant
treatments
for
control
of
weeds,
root­
knot
nematodes
and
soil
borne
fungal
pathogens.
U.
S.
Pepper
Page
85
24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

See
Section
23
above.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

New
data
used
in
this
CUN
1.
Southeastern
states,
including
Georgia
New
data
on
potential
MB
alternatives
for
use
on
peppers
were
submitted
by
the
Georgia
and
Southeast
U.
S.
Peppers
Consortium.
Results
of
a
small
plot
field
study
conducted
in
Tifton,
Georgia
by
Culpepper
and
Langston
(
2004)
show
that
1,3­
D
+
chloropicrin,
followed
by
more
chloropicrin,
was
more
effective
than
MB
against
yellow
nutsedge,
but
less
effective
against
purple
nutsedge.
Although
this
treatment
performed
as
well
as
MB
in
terms
of
spring
crop
yield,
its
fall
yield
performance
was
inferior
to
that
of
MB.
In
a
second
treatment,
1,3­
D
by
itself,
followed
by
chloropicrin,
was
significantly
less
effective
than
methyl
bromide
for
the
control
of
both
purple
and
yellow
nutsedge,
but
as
effective
as
MB
for
the
control
soil
nematodes.
In
terms
of
spring
and
fall
pepper
yield,
however,
this
treatment
performed
as
well
as
MB.
In
a
third
treatment,
1,3­
D
+
chloropicrin,
followed
by
metam
sodium,
was
as
effective
as
MB
against
yellow
nutsedge,
36%
less
effective
than
MB
against
purple
nutsedge,
and
as
effective
as
MB
for
the
control
of
soil
nematodes.
This
treatment
also
performed
as
well
as
MB
in
terms
of
both
spring
and
fall
pepper
yield.
Although
these
combinations
are
showing
promise,
they
will
require
further
testing
and
validation.

Ongoing
research
at
University
of
Florida
includes
various
techniques
with
existing
chemical
alternatives
as
well
as
the
development
of
new
chemistries,
such
as
propargyl
bromide,
a
compound
with
reduced
risk.
The
efficacy
of
pre
plant
herbicides
and
soil­
applied
fumigants
depends
on
the
physical,
chemical
and
biological
properties
of
the
soil.
The
depth
of
the
incorporation
could
play
a
critical
role
in
the
efficacy
of
a
given
chemical
alternative,
because
of
the
changes
in
soil
humidity,
microbial
activity,
and
temperature.
These
changes
could
alter
the
chemistry
of
the
applied
chemicals.

In
addition,
the
Florida
Fruit
and
Vegetable
Association
has
been
screening,
as
stand­
alone
MB
replacements,
1,3­
D,
chloropicrin,
metam
sodium,
and
dazomet
evaluated
against
98:
2
and
67:
33
MB
+
chloropicrin
formulations
at
the
maximum
allowable
label
rate
at
multiple
locations.
Results
indicate
that
the
best
alternatives
will
likely
include
a
pre­
plant
application
of
1,3­
D
+
chloropicrin,
followed
by
an
application
of
chloropicrin
injected
into
the
raised
bed
and
a
herbicide
mix
applied
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APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
37,557
35%

2003
Hectares
%
of
2001
&
2002
Avg
Requested
%

10,659
3%
7%

5,806
16%
28%

2,899
79%
80%

7,893
107%
107%

816
16%
16%

28,074
43%
47%

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

28,524
7,606
12,522
80
157
96,560
56,729
66,089
440
150
251,519
156,432
178,778
1,190
150
1,085,364
817,072
880,121
5,538
159
11,396
11,396
11,396
95
120
1,473,364
1,049,237
1,148,907
7,343
156
32%
51%
47%
44%
4%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
%
adopt
%
per
year
157
157
0
0
0
0
100
100
26
17
0
0
0
0
75%
20%
75%
15%

150
150
0
0
0
0
80
47
0
0
0
0
0
0
80%
47%
86%
11%

150
150
8
8
0
0
80
47
0
0
0
0
0
0
82%
51%
84%
11%

159
159
40
40
1
1
80
47
0
0
0
0
0
0
89%
67%
75%
9%

120
120
0
0
0
0
75
75
0
0
0
0
75
75
75%
75%
0%
0%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
Tarp
No
Yes
0
Yes
1/
year
8
$
6%
29%

Yes
Yes
Yes
Tarp
No
Yes
+
Yes
1/
year
60
$
29%
76%

Yes
Yes
Yes
Tarp
No
Yes
+
Yes
1/
year
76
$
37%
97%

Yes
Yes
Yes
Tarp
No
Yes
+
Yes
1/
year
49
$
21%
112%

Yes
Yes
Yes
Tarp
No
Yes
+
Yes
1/
year
70
$
30%
160%

Yes
Yes
Yes
Tarp
No
Yes
­
Yes
1/
year
45
$
23%
73%

Yes
Yes
Yes
Tarp
No
Yes
­
Yes
1/
year
64
$
33%
105%

Yes
Yes
Yes
Tarp
No
No
N/
A
Yes
1/
year
40
$
20%
100%

Pest
Distribution
GA
used
Stanley
Culpepper,
UGA
survey.
GA
figures
were
used
for
FL
and
SE
US
High
estimate
adds
moderate
and
severe,
Low
estimate
add
1/
2
of
moderate
and
all
severe
1
Pound
=
0.453592
Kilograms
1
Acre
=
0.404686
Hectares
High
24%
Low
77%

29%
44%
29%

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

6%
29%
44%
1,3­
D
+
Pic
22%
­
6
yield
+
16
planting
delay
Metam­
Sodium
1,3­
D
+
Pic
2007
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
44%
1,3­
D
+
Pic
1,3­
D
+
Pic
Metam­
Sodium
1,3­
D
+
Pic
Metam­
Sodium
**
Georgia
Acreage
estimates
verified
at
http://
www.
caed.
uga.
edu/
2003gafgveg.
pdf
*
Georgia
rotates
crops
with
solanaceous
crops
therefore
we
had
to
balance
the
distribution
with
the
other
sectors
in
Georgia's
application.

GEORGIA
SOUTHEASTERN
US
10,453
$
6,724
$

FLORIDA
Combined
Impacts
Adjustment
(
kgs)

REGION
REGION
REGION
GEORGIA
FLORIDA
MICHIGAN
GEORGIA
Other
Issues
Regulatory
Issues
(%)
0%
Conversion
Units:

***
Michigan
rates
are
higher
for
2007
based
on
more
current
information.

MICHIGAN
CALIFORNIA
SOUTHEASTERN
US
MICHIGAN
MICHIGAN
***

CALIFORNIA
CALIFORNIA*
SOUTHEASTERN
US
GEORGIA
FLORIDA
FLORIDA
Other
Considerations
Nomination
Amount
%
Reduction
from
Initial
Request
CALIFORNIA
Dichotomous
Variables
(
Y/
N)
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)

SOUTHEASTERN
US
Adjustments
to
Requested
Amounts
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
(%)
100
ft
Buffer
Zones
13%

(%)
Key
Pest
Distribution
0%
0%
13%
1,631,815
1,160,289
13%
24%
46%

2,153,749
2,153,749
1,883,560
­

­
69,540
­
1,883,560
1,883,560
1,197,643
901,597
15,195
­
­
­
­
11,396
11,396
1,415,207
­
108,191
63,562
347,183
­
4,467
­
­
281,027
174,785
240,086
­
104,848
­
(­)
QPS
HIGH
LOW
136,078
­
91,334
­
­
33,558
8,949
2007
Request
(­)
Double
Counting
(­)
Growth
(­)
Use
Rate
Adjustment
133
120
0%

TOTAL
OR
AVERAGE
2,153,749
13,213
163
1,884,288
12,067
156
15,195
127
120
15,924
2,282
150
0%

1,415,207
8,417
168
1,345,667
8,468
159
0%

347,183
2,312
150
342,716
284
157
0%

240,086
1,599
150
135,238
900
150
0%

136,078
759
179
44,743
2007
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

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

Methyl
Bromide
Critical
Use
Exemption
Process
Date:
1/
28/
2005
Average
Hectares
in
the
US:
Regional
Hectares
Combined
Impacts
(%)
MOST
LIKELY
IMPACT
VALUE
Adoption
/
Transition
Research
Amount
(
kgs)

2844
Adoption
Transition
Adjustment
(
kgs)

Most
Likely
Impact
Value:

9,637
$
4,808
$
Economic
Analysis
Loss
per
Hectare
(

US$/

ha)
1,194
$
8,954
$
11,429
$
7,368
$
U.
S.
Pepper
Page
92
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
3.
2007
Amount
of
Request
 
The
2007
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
8.
2007
Nomination
Options
 
2007
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2007
Request
 
Subtractions
from
Requested
Amounts,
2007
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2007
request
from
an
applicant's
2002
CUE
application
compared
with
the
2007
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
U.
S.
Pepper
Page
93
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.
Adaptation
/
Transition
­
Estimate
of
the
percentage
of
the
weighted
usage
that
can
be
transitioned
to
a
marginal
strategy.
This
estimate
is
for
areas
of
low
to
moderate
pest
pressure,
where
some
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
24.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
25.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2007
or
the
historic
average
use
rate.
26.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
27.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
28.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
29.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
U.
S.
Pepper
Page
94
30.
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.
31.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
32.
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.
33.
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.
34.
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.
35.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
36.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
37.
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.
38.
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.
39.
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.
40.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
41.
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.
42.
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.
43.
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.
44.
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.
45.
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.
46.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
U.
S.
Pepper
Page
95
APPENDIX
B.
2006
Methyl
Bromide
Reconsideration
for
Peppers.

Overview
of
the
U.
S.
Nomination
The
U.
S.
requested
1,498.53
metric
tons
of
methyl
bromide
for
use
on
pepper
crops
in
the
U.
S.
for
2006.
This
amount
was
requested
for
California
(
59.659
metric
tons),
Florida
(
1,006.074
metric
tons),
Georgia
(
242.761
metric
tons),
Michigan
(
9.482
metric
tons),
and
a
group
of
States
in
the
southeastern
part
of
the
U.
S.
(
77.711
metric
tons).
1
The
U.
S.
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
pepper
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:


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


geographic
distribution
of
key
target
pests2:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
U.
S.
is
only
nominating
a
CUE
for
peppers
where
the
key
pest
pressure
is
moderate
to
high.
An
example
is
areas
of
moderate
to
high
nutsedge
infestation
in
the
Southeastern
U.
S.


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


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


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

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

MBTOC
does
not
appear
to
have
accounted
for
the
new
information
regarding
the
extent
of
nutsedge
infestation
affecting
this
crop.
MBTOC
suggests
that
alternatives
are
available
in
California,
that
growers
are
using
more
than
200kg/
ha,
and
that
alternatives
are
both
technically
and
economically
feasible
in
non­
karst
areas
of
the
southeastern
U.
S.
(
including
Georgia
and
Florida)
so
that
20%
is
deducted
for
that
phasing
of
alternatives.
We
will
address
each
of
these
issues
separately.

1
These
states
are:
Alabama,
Arkansas,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee,
and
Virginia.
These
States
have
similar
climate
and
terrain
and
face
similar
pests.
2
Key
target
pasts
are
those
pests
that
cannot
be
controlled
by
available
alternatives
to
methyl
bromide.
U.
S.
Pepper
Page
96
a.
MBTOC
used
their
own
numbers
for
nutgrass
(
nutsedge)
rather
than
the
numbers
provided
by
the
U.
S.

In
2003,
Dr.
Stanley
Culpepper
of
the
University
of
Georgia
conducted
a
survey
of
land
under
cultivation
with
various
crops
to
determine
the
proportion
of
land
(
by
crop)
that
was
infested
with
various
levels
of
nutsedge.
The
values
selected
were
those
used
in
published
literature
and
characterized
as
`
none'
(
no
plants
per
square
yard3),
`
light'
(
fewer
than
five
plants
per
square
yard),
`
moderate'
(
five
to
thirty
plants
per
square
yard),
and
`
severe'
(
more
than
thirty
plants
per
square
yard).
This
information
was
used
to
estimate
nutsedge
information
for
the
entire
southeastern
region
(
including
the
State
of
Florida)
because
the
entire
region
has
similar
climate,
soils
and
rainfall.
In
the
judgment
of
U.
S.
government
experts,
familiar
with
U.
S.
agriculture
and
with
the
southeastern
growing
regions
in
particular,
nutsedge
infestations
are
similar
throughout
the
region4.
For
the
previous
year's
estimates
of
nutsedge
infestation
(
those
used
in
the
2005
nomination),
similar
estimates
were
used
throughout
the
southeastern
growing
region.
These
estimates
were
the
fruit
of
a
half
dozen
phone
calls
to
growers
with
large
tomato
operations
in
one
or
more
of
the
southeastern
states.
The
estimates
derived
were
applied
to
all
crops
in
all
of
the
southeastern
states.
The
new
data
represented
a
significant
improvement
in
accuracy
over
the
previous
estimates,
in
the
judgment
of
U.
S.
experts
familiar
with
the
circumstances
of
the
nomination.
The
USG
is
requesting
restoration
of
the
amount
deducted
for
this
factor.
5
Information
used
for
the
2005
nomination
was
developed
by
asking
some
large
tomato
operations
(
growers
with
large
tomato
acreages
in
several
states)
to
`
guestimate'
the
proportion
of
tomato­
growing
acreage
impacted
by
`
none',
`
light',
`
moderate'
and
`
heavy'
nutsedge
infestations
and
to
compare
these
across
that
various
states
in
which
the
growers
have
operations.
Information
on
the
proportion
of
impacted
tomato
area
was
then
used
for
other
crops
throughout
the
southeastern
growing
region.

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

3
One
square
yard
is
approximately
9/
10
of
a
square
meter.
4
Conversations
with
officials
in
the
State
of
Florida
regarding
the
extent
of
nutsedge
infestation
indicate
that
these
officials
believe
that
the
infestation
in
Florida
is
more
severe
that
in
Georgia.
They
are
currently
investigating
whether
a
survey
of
cultivated
land
in
Florida
for
nutsedge
infestation
can
be
undertaken.
5
The
U.
S.
is
unable
to
exactly
determine
how
that
various
factors
that
MBTOC
used
were
reflected
in
the
final
amounts.
The
U.
S.
technical
experts
had
been
promised
a
spreadsheet
so
that
the
amounts
could
be
disaggregated
but
were
not
provided
with
one.
U.
S.
Pepper
Page
97
b.
Alternatives
are
technically
and
economically
feasible
so
a
20%
reduction
for
phase­
in
of
alternatives
such
as
1,3D/
Pic
or
metam
sodium
was
used:
alternatives
can
be
used
in
areas
where
1,3­
D
use
is
not
appropriate
MBTOC
disagrees
with
the
U.
S.
assessments
of
yield
loss,
which
is
the
basis
for
the
MBTOC
recommendation
of
economic
feasibility.

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

 
Included
an
untreated
control
for
comparison
purposes
 
Included
information
on
the
(
key)
pests
present
in
the
treated
area
 
Give
estimates
of
yield
changes
(
differences)
 
Include
methyl
bromide
as
a
standard
The
U.
S.
nomination
was
restricted
to
those
situations
where
the
presence
and
prevalence
of
pests
(`
key'
pests)
that
could
not
be
controlled
by
alternatives
to
methyl
bromide
was
moderate
to
severe6
and
would
result
in
yield
loss.

The
U.
S.
technical
experts
asked
MBTOC
to
explain
the
basis
for
their
decision7
and
were
told
that
in
some
cases
a
meta
analysis
served
as
the
basis,
and
in
other
cases
the
basis
was
`
experience'.
The
procedure
MBTOC
used,
as
we
understand
it,
was
not
a
meta
analysis.
A
meta
analysis
includes
a
statistical
analysis
of
the
information,
and
compares
only
those
studies
which
are
similar
enough
from
a
statistical
standpoint
that
they
can
be
combined
and
analyzed
as
if
they
comprised
one
study.
Further,
the
studies
need
to
be
identified,
appraised
and
summarized
according
to
an
explicit
and
reproducible
methodology
that
is
designed
to
answer
a
specific
research
question.
In
this
case,
the
appropriate
research
question
would
be
the
performance
of
alternatives
to
methyl
bromide
under
the
conditions
of
the
U.
S.
nomination
(
i.
e.
with
moderate
to
severe
pressure
from
key
pests).
The
studies
used
in
the
meta
analysis
are
not
listed
and
no
indication
is
given
of
the
criteria
used
to
include
or
exclude
a
study
from
the
analysis,
which
presents
a
serious
problem
in
applying
the
results.
Our
understanding
is
that
this
analysis
does
include
some
studies
conducted
under
circumstances
that
are
not
similar
to
the
limited
conditions
included
in
the
U.
S.
nomination,
such
as
the
presence
of
moderate
to
severe
pest
pressure.

The
null
hypothesis
would
be
that
alternatives
work
as
well
as
methyl
bromide
in
the
conditions
of
the
U.
S.
nomination.
The
U.
S.
nomination
is
specifically
for
the
use
of
methyl
bromide
where
key
pests
(
pests
not
adequately
controlled
by
alternatives
to
methyl
bromide)
are
present
at
moderate
to
severe
levels
and/
or
soil,
climate,
terrain,
or
regulatory
conditions
are
such
that
alternatives
to
methyl
bromide
either
cannot
be
used
or
result
in
significant
economic
losses
6
In
the
judgment
of
U.
S.
experts
pressure
was
such
that
yield
losses
of
the
magnitude
of
those
used
in
the
economic
assessment
would
be
sustained.
7
MBTOC
asserted
that
alternatives
were
both
technically
and
economically
feasible
for
the
pre­
plant
sectors
of
field
grown
peppers,
strawberries,
and
tomatoes.
U.
S.
Pepper
Page
98
when
used.
These
economic
losses
must
be
of
sufficient
magnitude
that
they
render
the
alternative
not
economically
feasible.

When
asked
for
references,
USG
experts
were
directed
to
"
the
Porter
paper
in
press".
USG
experts
have
examined
a
"
Porter
paper
in
press"
8
and
find
a
number
of
concerns
with
respect
to
its
application
to
the
specific
circumstances
of
the
U.
S.
nomination.
Although
it
is
difficult
to
be
certain
how
the
MBTOC
analysis
was
conducted
and
what
it
includes
because
it
has
not
been
reviewed
and
published
and
was
not
provided
to
the
U.
S.
experts
to
evaluate9,
U.
S.
experts
were
able
to
make
some
educated
guesses
about
the
analysis10.

A
version
of
the
paper
was
presented
by
Dr.
Ian
Porter
at
the
Methyl
Bromide
Alternatives
Organization
meeting
in
San
Diego,
November
2003
and
was
the
subject
of
some
controversy
and
concern
among
a
number
of
participants.
Dr.
Porter's
paper
included
a
number
of
papers,
which
U.
S.
experts
believe
are
not
appropriate
for
use
in
determining
the
usefulness
of
alternatives
because
the
research
was
carried
out
under
conditions
of
no
pest
pressure,
and
are
therefore
not
relevant
to
the
specific
circumstances
of
our
nomination11.
If
few
or
no
pests
are
present,
any
alternative,
or
indeed
not
using
any
pesticide
at
all,
will
all
work
equally
well.
By
including
situations
where
there
is
no
pest
pressure
one
in
effect
adds
(
many)
"
100"
to
the
equation12
describing
the
differences
in
yield
between
crops
grown
using
methyl
bromide
and
those
grown
using
an
alternative.
This
has
the
effect
of
lowering
the
average
difference
between
yields
using
methyl
bromide
and
yields
using
an
alternative.
If
a
sufficient
number
of
"
100"
are
added,
the
result
will
be
to
(
falsely)
eliminate
the
yield
differences
between
methyl
bromide
and
the
alternatives.

In
other
papers,
pests
were
present
but
they
were
not
the
pests
present
in
all
of
the
U.
S.
circumstances.
Taking
the
case
of
the
southeastern
US,
for
example,
weeds,
diseases,
fungi,
and
nematodes
all
afflict
the
crops.
Some
of
these
pests
can
be
controlled
with
alternatives,
but
some
of
the
weeds,
in
particular
nutsedges
(
nut
grasses),
nightshades,
and
some
hard
coated
seeds,
cannot.
Situations
without
weeds
will
show
small
or
no
yield
losses
when
alternatives
are
used
while
the
true
situation
when
(
key)
weeds
are
present
is
that
there
are
relatively
large
yield
8
Porter,
I.,
S.
Mattner,
R.
Mann,
R.
Gounder,
J.
Banks,
and
P.
Fraser.
1994.
Strawberry
Fruit
Production
and
results
from
trials
in
Different
Geographic
Regions.
A
Presentation
to
the
Methyl
Bromide
Alternatives
Conference,
Lisbon,
September
1994.
9
U.
S.
experts
requested
references
from
some
of
the
authors
of
the
studyso
that
the
studies
included
could
be
evaluated
against
the
circumstances
of
the
U.
S.
nomination,
but
they
have
not
been
provided.

10
Some
of
this
material
had
been
previously
presented
at
the
Methyl
Bromide
Alternatives
Organization
2003
meeting
(
San
Diego).
At
that
time
U.
S.
experts
expressed
their
view
that
many
if
not
most
of
the
studies
were
not
an
appropriate
application
of
the
information.

11
For
example,
some
trials
are
used
for
residue
tests.
These
tests
are
likely
to
be
carried
out
in
conditions
of
little
or
no
pest
pressure
in
order
to
have
enough
harvested
fruit
to
to
test
for
residue.
The
Porter
paper
does
not
indicate
which
of
the
studies
used
(
but
not
cited)
where
for
the
purposes
of
examining
pesticide
residues.

12
The
actual
procedure
was
to
add
in
yields
expressed
as
a
percentage
of
(
anticipated)
yield
using
methyl
bromide.
How
this
yield
was
estimated
is
puzzling
as
many
of
the
studies
did
not
include
a
methyl
bromide
control.
Because
there
was
no
indication
of
pest
pressure
in
many
instances,
many
of
the
entries
indicated
yields
of
approximately
100%,
obviating
the
differences
between
methyl
bromide
and
the
alternatives.
U.
S.
Pepper
Page
99
losses.
Including
these
factors
again
has
the
effect
of
adding
"
100"
yield
difference
as
many
times
as
there
are
these
papers.

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

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

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

Experts
are
familiar
with
high
prices
for
fresh
produce
early
in
the
season,
prices
which
decline
as
the
produce
becomes
abundant
(
and
more
familiar)
later
in
the
season.
The
U.
S.
has
provided
marketing
data
documenting
the
existence
of
these
market
windows
and
their
effects
on
the
revenue
and
profits
earned
by
farmers.
Anecdotally,
farmers
tell
us
that
virtually
al
of
their
net
revenue
(
approximately
90%)
above
cost
is
earned
during
the
short
period
of
high
prices.
For
some
crops,
75%
of
the
economic
loss
is
due
to
missing
a
market
window
rather
than
through
smaller
crops,
lower
fruit
quality,
or
higher
costs
of
using
alternatives
Many
of
the
alternatives
will
cause
farmers
to
miss
the
market
window.
In
conditions
of
cold
soil
temperatures,
such
as
in
Michigan
and
coastal
California,
where
the
growing
season
is
short,
alternatives
cannot
be
used
until
the
soil
temperatures
reach
at
least
40
F.
This
temperature
is
reached
3­
4
weeks
into
the
growing
season,
delaying
planting
and
consequently
harvesting
for
that
time.
Because
the
Michigan
growing
season
is
already
short
due
to
the
cold
temperatures,
even
apart
from
missing
the
market
window,
delaying
planting
will
result
in
a
smaller
harvestable
amount.
In
other
situations
the
"
plant­
back"
interval
is
longer,
by
two
weeks,
relative
to
the
methyl
bromide
plant
back
times.
Requiring
a
longer
interval
before
a
crop
can
be
planted
will
delay
the
harvesting,
again
causing
a
farmer
to
miss
a
market
window.
Some
alternatives
also
require
a
different
bed
preparation,
which
will
also
delay
the
planting
time.
The
strawberry
crop
in
California
is
one
example
of
this
situation.
U.
S.
Pepper
Page
100
It
is
not
clear
that
MBTOC
considered
the
specific
circumstances
of
the
U.
S.
nomination,
which
are
that
methyl
bromide
is
requested
only
for
situations
where
regulatory
concerns
preclude
use
of
an
alternative
or
where
there
are
`
key'
pests
present
at
moderate
to
severe
levels,
or
where
terrain
conditions
(
temperature,
topography)
result
in
no
alternative
being
technically
and
economically
feasible.
MBTOC
has
not
referenced
research
findings
to
support
their
view
that
alternatives
are
both
technically
and
economically
feasible,
while
the
U.
S.
has
presented
extensive
results
in
the
circumstances
of
the
nomination
to
support
our
request.

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

Alternatives
like
1,3­
dichloropropene
and
metam
sodium
require
a
21
to
28­
day
interval
before
planting,
compared
to
14
days
for
MB
or
methyl
bromide
with
Pic.
This
interval
can
cause
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profits
on
pepper
crops
(
Kelley,
2003
Nutsedge
management
has
proven
to
be
difficult
due
to
the
perennial
growth
habit
of
nutsedge
and
tubers
as
primary
means
of
propagation.
There
are
no
herbicides
which
control
nutsedge
in
the
crop
row.
Paraquat
and
glyphosate
will
suppress
emerged
nutsedge,
but
cannot
be
used
in
the
crop
row
because
of
potential
crop
injury
(
SE
Pepper
Consortium
CUE
02­
0041.)
Smetolachlor
can
suppress
yellow
nutsedge
for
a
single
crop
cycle
but
would
need
to
be
reapplied
for
multiple
crops
along
with
removing
and
replacing
the
existing
plastic
tarps.
Approximately
81%
of
the
Georgia
pepper
area
is
considered
to
have
moderate
to
severe
infestations
of
nutsedge
(
Culpepper,
2004).
Research
suggests
that
metam
sodium
can,
in
some
situations,
provide
effective
pest
management
for
certain
diseases
and
weeds.
However,
even
though
there
have
been
nearly
50
years
experience
with
metam
sodium,
(
which
breaks
down
to
methyl
isothiocyanate)
nutsedge
control
results
have
been
unpredictable.
U.
S.
Pepper
Page
101
Locascio
et
al.
(
1997)
studied
MB
alternatives
on
tomatoes
grown
in
small
plots
at
two
Florida
locations
with
high
nutsedge
infestation.
(
The
data
from
this
tomato
study
are
being
cited
because
comparable
pepper
data
are
not
available.)

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

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

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

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

In
sum,
neither
of
these
MB
alternatives
is
presently
technically
and
economically
feasible
for
control
of
key
pests,
and
MB
remains
a
critical
use
for
peppers
in
the
Southeastern
United
States.
U.
S.
Pepper
Page
102
The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses13:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield.

There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
peppers.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
As
described
above,
the
two
most
promising
alternatives
to
methyl
bromide
in
Georgia
for
control
of
nutsedge
in
peppers
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
expected
yield
losses
when
they
are
used.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

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

13
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
U.
S.
Pepper
Page
103
There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997)
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

The
sandy
soils
of
Florida
are
a
contributing
factor
to
the
erratic
performance
suppressing
nematodes
and
plant
pathogens
of
the
metam
sodium
+
chloropicrin
combination,
the
most
promising
alternative
to
methyl
bromide
currently
available
for
use
in
Dade
County
(
because
of
label
restrictions
for
1,3­
D)
14.
Methyl
bromide
has
higher
vapor
pressure
than
metam
sodium,
therefore
can
penetrate
and
diffuse
throughout
the
soil
more
effectively
than
metam
sodium.

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

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

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

Diseases
caused
by
soil­
borne
plant
pathogenic
fungi,
(
e.
g.,
Phytophthora
spp.,
Verticillium
spp.,
Pythium
spp.
and
Rhizoctonia
solani
)
commonly
reside
in
many
production
areas,
since
many
14
By
law
1,3­
D
cannot
be
used
anywhere
in
Dade
county,
Florida,
where
the
majority
of
that
region's
peppers
are
grown
U.
S.
Pepper
Page
104
pepper
production
areas
are
old
tomato
production
fields.
Fungicides
such
as
chlorothalonil,
and
azoxystrobin
are
considered
to
be
only
prophylactic,
and
may
not
offer
sufficient
pest
management.
Resistance
of
Phytophthora
spp
to
metalaxyl
and
mefanoxem
(
Ridomil
and
Ridomil
Gold,
respectively)
has
been
reported
in
tomato
crop
areas,
and
most
recently
pepper
(
Lamour
and
Hausbeck
2003).

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

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

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

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

Various
treatments
were
tested
on
plots
that
had
multiple
pests.
At
the
Bradenton
site
there
was
moderate
to
heavy
Fusarium
infestation;
heavy
purple
nutsedge
infestation
and
light
root­
knot
nematode
pressure.
At
Gainesville
there
was
heavy
infestation
of
yellow
and
purple
nutsedge
and
moderate
infestation
of
root­
knot
nematode.
The
treatments
at
both
locations
included
MB
(
67%)
+
chloropicrin
(
33%)
chisel­
injected
at
390
kg/
ha;
metam­
sodium
(
chisel­
injected)
at
300L/
ha;
metam­
sodium
drip­
irrigated
at
300L/
ha;
and
1,3­
D
+
17%
chloropicrin
chisel­
injected
at
327L/
ha.
In
pairwise
statistical
comparisons,
the
yield
was
significantly
lower
in
metamsodium
treatments
compared
to
MB
at
both
sites.
At
Bradenton,
the
average
yield
from
both
metam­
sodium
treatments
was
33%
of
the
MB
yields,
suggesting
a
67%
yield
loss
from
not
using
MB.
At
Gainesville
the
average
yield
of
the
two
metam­
sodium
treatments
was
56%
of
the
MB
yield,
suggesting
a
44%
yield
loss
from
not
using
MB.
The
yield
of
the
1,3­
D
treatment
at
Gainesville
was
71%
of
the
MB
standard
suggesting
a
29%
loss
by
not
using
MB
(
yield
data
for
1,3­
D
were
not
reported
for
Bradenton).
In
considering1,3
D
results,
one
must
keep
in
mind
that
this
MB
alternative
cannot
be
used
in
areas
where
karst
geology
exists
which
is
U.
S.
Pepper
Page
105
approximately
40%
of
the
Florida
pepper
production
area,
including
all
of
Dade
country,
a
major
pepper
growing
area.

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

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

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

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

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

The
U.
S.
assessment
that
the
alternatives
are
not
technically
AND
economically
feasible
rests
on
two
kinds
of
losses15:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
15
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.
U.
S.
Pepper
Page
106
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
peppers.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
As
described
above,
the
two
most
promising
alternatives
to
methyl
bromide
in
Florida
for
control
of
nutsedge
in
peppers
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
expected
yield
losses
when
they
are
used.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

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

There
has
been
extensive
research
on
alternatives
for
solanaceous
crops,
and
methyl
bromide
minimizing
practices
have
been
incorporated
into
pepper
production
systems
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
pepper
production.
(
Locascio
et
al.,
1997)
Nematodes,
especially
root
knot
nematodes
(
Meloidogyne
spp.),
and
fungal
diseases
(
such
as
Phytophthora
blight)
are
Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
U.
S.
Pepper
Page
107
also
of
concern.
Fungal
pests
are
expected
to
become
serious
problems
for
pepper
production
if
MB
were
not
available
for
pre­
plant
fumigation.

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

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

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

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

Further,
due
to
regulatory
restrictions
resulting
from
groundwater
contamination
concerns,
1,3­
D
+
chloropicrin
cannot
be
used
in
large
portions
of
the
southeastern
United
States
due
to
the
presence
of
karst
geology.
There
is
also
a
28
day
planting
delay
(
vs.
14
days
for
MB)
due
to
regulatory
restrictions
for
1,3­
D
+
chloropicrin.
In
many
areas
of
the
southeast
growers
are
on
a
tight
production
schedule
where
buyers
must
place
pepper
transplants
in
fields
at
a
certain
time
of
the.
Thus,
if
growers
have
only
metam
sodium
for
preplant
pest
control,
they
will
be
forced
to
fumigate
earlier
in
their
season,
which
in
turn
will
force
the
fumigation
schedule
into
rainy
periods,
an
untenable
situation
since
rain
causes
this
and
all
other
available
fumigants
to
lose
efficacy
dramatically
(
Aerts,
2004).
U.
S.
Pepper
Page
108
Furthermore,
trials
of
metam­
sodium
and
1,3
D
+
chloropicrin
(
and
various
combinations
thereof)
are
based
on
small
plot
research
trials
conducted
in
the
Southeastern
United
States
on
crops
other
than
peppers.
For
fungi
and
nutsedge,
no
on­
farm,
large­
scale
trials
have
yet
been
done.
Some
researchers
have
also
reported
that
these
MB
alternatives
degrade
more
rapidly
in
areas
where
they
are
applied
repeatedly
due
to
enhanced
metabolism
by
soil
microbes
(
Dungan
and
Yates
2003,
Gamliel
et
al.
2003).
This
may
compromise
long­
term
efficacy
of
these
compounds
and
appears
to
need
further
scientific
scrutiny.

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

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

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

The
U.
S.
assessment
that
the
alternatives
are
not
technically
AND
economically
feasible
rests
on
two
kinds
of
losses16:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
peppers.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
As
described
above,
the
two
most
promising
alternatives
to
methyl
bromide
in
the
Southeastern
U.
S.
for
control
of
nutsedge
in
16
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
U.
S.
Pepper
Page
109
peppers
(
1,3­
D
+
chloropicrin
and
metam­
sodium)
are
considered
not
technically
feasible.
This
derives
from
regulatory
restrictions
and
the
magnitude
of
expected
yield
losses
when
they
are
used.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

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

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

As
far
as
EPA
can
ascertain,
virtually
none
of
the
studies
on
key
MB
alternatives
has
focused
on
peppers
in
coastal
California's
growing
conditions.
One
exception
to
this
situation
can
be
summarized
first,
although
this
study
was
ongoing
at
the
time
it
was
submitted
to
EPA.
This
study
is
a
field
trial,
conducted
in
small
plots
in
2003
in
Michigan
by
M.
K.
Hausbeck
and
B.
D.
Cortright
of
Michigan
State
University.
The
study
focused
on
a
number
of
vegetable
crops,
including
bell
peppers.
As
of
July
31,
2003,
results
indicated
that
1,3
D
+
35
%
chloropicrin
treatments
(
shank­
injected
at
56.7
liters/
ha)
showed
approximately
6
%
plant
loss
(
due
to
P.
capsici)
 
less
than
the
7
%
loss
seen
in
the
untreated
control
plots.
Metam­
sodium
(
drip­
applied
U.
S.
Pepper
Page
110
at
58.7
kg/
ha)
showed
a
13
%
loss.
Methyl
iodide
with
either
50
%
or
33
%
chloropicrin
(
shankinjected
at
either
46.1
or
36.8
kg/
ha,
respectively)
showed
only
2
%
plant
loss.
However,
methyl
iodide
is
not
registered
for
this
crop
in
the
U.
S.
at
present.
It
should
also
be
noted
that
(
1)
since
the
trial
had
not
yet
ended,
statistical
analysis
on
these
figures
was
not
conducted,
(
2)
plant
loss
figures
are
for
all
vegetable
crops
combined,
and
(
3)
these
plots
were
being
carefully
monitored
and
managed
with
post­
plant
prophylactic
foliar
fungicides
(
e.
g.,
chlorothalonil
and
myclobutanil)
 
an
optimal
management
scheme
that
will
require
time
to
enable
growers
to
adopt.

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

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

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

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

There
are
also
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
pepper
growers.
In
sum,
while
the
potential
exists
for
a
combination
of
chemical
and
non­
chemical
alternatives
to
replace
MB
use
in
California
pepper,
this
goal
appears
be
at
least
a
few
years
away.
U.
S.
Pepper
Page
111
USG
does
not
agree
that
alternatives
are
available
in
California
except
where
regulatory
constraints
(
township
caps
dictating
maximum
use
of
1.3­
D)
are
binding.
California
peppers
are
similar
to
Michigan,
in
that
the
critical
pest
controlled
by
MB
currently
is
P.
capsici.
The
other
important
pest
targeted
by
MB
use
in
this
region
is
the
root
knot
nematode.
California
is
requesting
MB
for
less
than
10
%
of
its
pepper
area,
mainly
along
the
coast.
As
in
Michigan,
climatological
conditions
in
these
coastal
areas
­
primarily
long
periods
of
rainy,
cloudy
weather
 
exacerbate
problems
involving
possible
methyl
bromide
alternatives,
particularly
formulations
of
1,3
D,
which
cannot
be
used
when
soils
are
very
wet.
Growers
are
also
reporting
lack
of
efficacy
against
both
of
these
pests
at
the
maximum
label
rates
for
this
alternative.
In
addition,
California
has
township
caps
that
limit
the
amount
of
1,3­
D
that
can
be
used
in
a
given
area,
as
well
as
100
meter
buffer
zones
near
inhabited
structures.
Urban
encroachment
is
increasing
dramatically
in
California
coastal
counties,
making
the
buffer
zone
requirement
more
constraining.
These
factors
are
present
in
the
10%
of
California
pepper
area
that
need
MB
Of
the
currently
available
MB
alternatives,
metam­
sodium
offers
inconsistent
control
of
nutsedges
and
nematodes,
while
1,3­
D
+
chloropicrin
provides
adequate
control
of
nematodes
(
Locascio
et
al.
1997,
Eger
2000,
Noling
et
al.
2000).
However,
metam­
sodium
has
yield
losses
of
up
to
44
%
compared
to
MB
where
weed
infestations
are
moderate
to
severe
(
Locascio
et
al.
1997).
Metam­
sodium
also
creates
a
planting
delay
as
long
as
21
days
to
avoid
risk
of
phytotoxic
injury
to
crops
compared
to
a
14­
day
delay
for
MB.

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

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

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

Deep
shank
injection
cannot
be
used
to
control
pests
in
California
pepper
production.
Unlike
Florida,
where
the
soils
are
sandy
to
a
considerable
depth,
in
California
the
soils
are
prepared
for
planting
to
a
depth
of
12­
18
inches17.
The
deep
shank
method
injects
1,3­
D
below
this
level
where
the
soil
is
not
prepared
and
breaks
into
clumps.
The
soil
must
be
re­
tilled
before
planting
17
This
corresponds
to
30­
45
cm.
U.
S.
Pepper
Page
112
which
risks
introducing
pathogens
back
into
the
planting
zone.
When
shallow­
shank
injection
is
used,
the
higher
application
factors
mean
that
a
much
smaller
area
can
be
injected.

Dr.
Legard18
of
the
California
Strawberry
Commission
has
estimated
the
impact
on
maximum
acreage
treated
if
1,3­
D
is
(
shallow)
shank­
injected
into
the
soil
rather
than
drip­
applied
a
s
a
liquid.
Using
Telone
C35
®
at
39­
50
gallons
per
treated
acre,
138.8
to
178.0
acres
per
township
could
be
treated.
When
Inline
®
is
used
at
25
gallons
per
acre19
473.7
acres
per
township
can
be
treated.
In
other
words,
the
use
of
drip­
applied
1,3­
D
results
in
2.5
to
3
times
as
many
treated
acres.
Shank
injection
of
1,3­
D
will
greatly
reduce
the
acreage
treated20.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses21:
changes
in
yields
which
result
in
a
lesser
amount
harvested
and
therefore
lower
revenues
to
farmers,
and
later
yields
which
resulted
in
further
reduced
revenues
to
farmers
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
There
are
currently
few
alternatives
to
methyl
bromide
for
use
in
peppers.
Furthermore,
there
are
factors
that
limit
existing
alternatives'
usability
and
efficacy
from
place
to
place.
These
include
pest
complex,
climate,
and
regulatory
restrictions.
MBTOC
does
not
appear
to
have
taken
into
account
planting
delays
resulting
from
use
of
alternative
pesticide
treatments.
These
delays
cause
growers
to
lose
all
or
part
of
a
market
window.
In
the
case
of
peppers
(
in
particular)
missing
the
early
part
of
the
winter
growing
season
causes
hugely
disproportionate
losses
in
grower
net
revenues.

18
Daniel
Legard,
PhD,
personal
communication.
January
9,
2005.
19
The
common
use
rate
on
strawberries
in
California
20
The
main
concern
associated
with
broadcast
fumigation
with
telone
C35
is
related
to
the
telone
township
cap.
There
are
different
emission
ratios
used
for
the
different
application
methods
that
adjusts
the
amount
of
telone
applied
to
the
township
cap.
The
lbs
used
are
"
adjusted"
by
the
following
factors
(
1x
for
deep
shank,
1.1x
for
drip
applied,
1.8x
for
shallow
shank).
Hopefully,
most
growers
would
use
deep
shank
where
possible
for
broadcast
telone
applications.
However,
broadcast
applications
still
involve
treating
approximately
40%
more
acreage
than
drip
(
2
row
bed
and
slightly
lower
for
3
and
4
row
beds,
which
are
becoming
more
popular
in
the
North).
The
net
result
of
both
changes
is
to
reduce
the
maximum
treatable
area
to
between
30­
40%
of
the
area
that
can
be
treated
using
drip
applied
1,3­
D.

21
From
a
theoretical
perspective
there
are
additional
losses
that
should
be
included:
differences
in
costs
between
methyl
bromide
and
the
alternatives
and
changes
in
yield
quality.
Cost
differences
between
methyl
bromide
and
the
alternatives
can
occur
because
the
prices
of
the
materials
differ,
amounts
used
differ,
equipment
needs
differ,
additional
materials
are
needed,
such
as
an
additional
herbicide,
an
additional
application
step,
either
of
the
alternative
or
of
some
ancillary
material
is
required,
or
there
are
additional
land
preparation
or
other
costs.
In
practice,
cost
differences
between
methyl
bromide
and
alternatives
are
generally
small
and
can
usually
be
ignored.

Quality
difference
in
the
yield,
such
as
smaller,
scarred,
less
sweet,
or
other
differences
in
fruit
quality
would
also
be
factors
in
assessing
economic
loss.
In
practice
quality
differences
have
not
been
reported
in
the
available
literature
and
so
losses
from
his
source
cannot
be
incorporated
into
the
analysis.
U.
S.
Pepper
Page
113
c.
rate
reduction
to
200kg/
ha
under
treated
strips
MBTOC
has
also
reduced
the
amount
recommended
for
peppers
stating:
"
A
further
adjustment
was
applied
to
reduce
the
dosage
to
the
guideline
level
of
200kg/
ha
under
the
strips."
When
this
issue
was
discussed
with
MBTOC
members
during
the
16th
MOP,
U.
S.
experts
agreed
to
clarify
whether
the
reported
rates
were
in
fact
the
rates
used
under
the
strips
(
as
the
U.
S.
believed)
or
whether
they
were
the
average
for
an
acre
as
MBTOC
believed22.
The
U.
S.
has
verified
that
the
application
rates
provided
in
the
quantitative
assessment
(
the
Methyl
Bromide
Usage
Numerical
Index,
or
BUNI)
are
in
fact
the
rates
under
the
strips.
The
number
of
acres
reported
is
the
"
treated
acres".
A
strip
application
that
results
in
two
thirds
of
an
acre
being
fumigated
while
one­
third
is
untreated
is
reported
as
two
thirds
of
an
acre,
not
as
an
acre.

Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.

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

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

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

22
If
the
rates
were
an
average
per
acre,
as
MBTOC
believed,
given
that
in
strip
treatments
approximately
one­
third
of
the
acre
is
left
untreated,
the
rates
applied
would,
in
some
cases,
exceed
the
MBTOC
recommended
dosage
of
200kg/
ha.
U.
S.
Pepper
Page
114
Aerts,
M.
2004.
Asst.
Director,
Environmental
and
Pest
Management
Division,
FFVA
(
Florida
Fruit
and
Vegetable
Association).
Personal
Communication
with
A.
Jones
and
N.
Mallampalli,
U.
S.
EPA,
February
13,
2004.

Allen,
L.
H.,
S.
J.
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D.
W.
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D.
J.
Mitchell,
and
S.
D.
Nelson.
1999.
Flooding
(
soil
anoxia)
for
control
of
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of
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S.
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58­
6617­
6­
013.

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M.
G.,
B.
L.
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1963.
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