METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
TOMATO
GROWN
IN
OPEN
FIELDS
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
Pre­
plant
Soil
Use
for
Tomato
Grown
in
Open
Fields
(
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.
Tomatoes
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.
Tomatoes
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
____________________________________________________________
8
1.
Nominating
Party
_________________________________________________________
8
2.
Descriptive
Title
of
Nomination______________________________________________
8
3.
Crop
and
Summary
of
Crop
System___________________________________________
8
4.
Methyl
Bromide
Nominated
_________________________________________________
8
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
9
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
10
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
10
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
11
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
12
California
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
______________
12
California
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
12
California
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
13
California
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
14
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
____________________________________
14
California
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
15
California
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
17
California
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
17
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
___
17
California
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
18
California
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
18
California
­
Summary
of
Technical
Feasibility
___________________________________
19
Michigan
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_______________
19
Michigan
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
19
Michigan
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
20
Michigan
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
21
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________
22
Michigan
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
22
Michigan
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
23
Michigan
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
24
U.
S.
Tomatoes
iv
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
___
24
Michigan
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
25
Michigan
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
25
Michigan
­
Summary
of
Technical
Feasibility
____________________________________
26
South­
Eastern
United
States
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
26
South­
Eastern
United
States
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
26
South­
Eastern
United
States
­
11.
Characteristics
of
Cropping
System
and
Climate_______
27
South­
Eastern
United
States
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested___________________
28
SOUTH­
EASTERN
UNITED
STATES
­
PART
C:
TECHNICAL
VALIDATION
___________________
29
South­
Eastern
United
States
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________
29
South­
Eastern
United
States
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
32
South­
Eastern
United
States
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
32
South­
Eastern
United
States
­
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
___________________________________________________________
34
South­
Eastern
United
States
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
35
South­
Eastern
United
States
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
35
South­
Eastern
United
States
­
Summary
of
Technical
Feasibility
_____________________
36
PART
D:
EMISSION
CONTROL
___________________________________________________
37
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
37
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
37
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
39
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
39
22.
Gross
and
Net
Revenue___________________________________________________
39
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
40
Summary
of
Economic
Feasibility
_____________________________________________
42
PART
F.
FUTURE
PLANS
_______________________________________________________
45
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
45
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
46
25.
Additional
Comments
on
the
Nomination
____________________________________
46
26.
Citations
______________________________________________________________
47
U.
S.
Tomatoes
v
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).________________
49
APPENDIX
B.
2006
Methyl
Bromide
Reconsideration
for
Tomatoes.
_________________
53
U.
S.
Tomatoes
vi
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
8
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
8
Table
A.
1:
Executive
Summary
for
Tomatoes
_______________________________________
9
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
11
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________________
12
California
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request__
12
California
­
Table
11.1:
Characteristics
of
Cropping
System___________________________
13
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
13
California
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____________________
14
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
14
California
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
15
California
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
_________________
17
California
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
17
California
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
18
California
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
18
MICHIGAN
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
__________________
19
Michigan
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
__
19
Michigan
­
Table
11.1:
Characteristics
of
Cropping
System
___________________________
20
Michigan
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule____________________
20
Michigan
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
______________________
21
MICHIGAN
­
PART
C:
TECHNICAL
VALIDATION________________________________________
22
Michigan
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
22
Michigan
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
__________________
23
Michigan
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
24
Michigan
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
24
Michigan
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
25
SOUTH­
EASTERN
UNITED
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_
26
South­
Eastern
United
States
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
26
South­
Eastern
United
States
­
Table
11.1:
Characteristics
of
Cropping
System
____________
27
South­
Eastern
United
States
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule_____
27
South­
Eastern
United
States
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_______
28
SOUTH­
EASTERN
UNITED
STATES
­
PART
C:
TECHNICAL
VALIDATION_______________________
29
South­
Eastern
United
States
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
_____
29
South­
Eastern
United
States
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___
32
South­
Eastern
United
States
 
Table
15.1:
Present
Registration
Status
of
Alternatives
______
33
South­
Eastern
United
States
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
______
35
South­
Eastern
United
States
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_________
35
PART
D:
EMISSION
CONTROL
____________________________________________________
37
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
37
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
39
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
39
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
39
U.
S.
Tomatoes
vii
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________________________
40
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
40
California
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
40
Michigan
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
41
Southeastern
US
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________
41
PART
F.
FUTURE
PLANS
________________________________________________________
45
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
__________________
49
Page
8
PART
A:
SUMMARY
1.
NOMINATING
PARTY:

The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION:

Methyl
Bromide
Critical
Use
Nomination
for
Pre­
plant
Soil
Use
for
Tomato
Grown
in
Open
Fields
(
Prepared
in
2005)

3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
Tomato
Crops
Grown
in
Open
Fields
for
Fruit.
In
California,
Michigan
and
South­
Eastern
United
States
(
Alabama,
Arkansas,
Florida,
Georgia,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee).
These
crops
are
grown
in
open
fields
on
plastic
tarps,
often
followed
by
various
other
crops.
Harvested
fruit
is
destined
for
the
fresh
market.

4.
METHYL
BROMIDE
NOMINATED:

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

2007
2,334,047
15,235
*
Includes
research
amount
Page
9
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
Currently
registered
alternatives
to
methyl
bromide
do
not
consistently
provide
effective
control
of
nutsedge
weed
species
and
more
time
is
needed
to
evaluate
relationship
between
fumigant
alternatives,
various
mulches,
and
herbicide
systems
under
different
growing
conditions.

The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
tomato
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
tomato
production.
­
geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
US
is
only
nominating
a
CUE
for
tomato
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
townships
caps
and
in
Florida
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin,
and
in
Michigan
an
additional
delay
would
occur
because
soil
temperature
must
be
higher
to
fumigate
with
alternatives.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

TABLE
A.
1:
EXECUTIVE
SUMMARY
FOR
TOMATOES
*

Region
California
Region
Michigan
Region
South­
Eastern
United
States
AMOUNT
OF
APPLICANT
REQUEST
2007
Kilograms
40,823
30,391
4,651,126
AMOUNT
OF
NOMINATION*

2007Kilograms
40,823
10,333
2,277,389
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
10
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Research
results
confirm
that
methyl
bromide
alternatives
options
provide
inconsistent
control
of
nutsedge
weed
species.
Nutsedge
is
an
extremely
competitive
weed
in
tomato
and
can
cause
significant
yield
losses
in
the
Southeast.
Methyl
bromide
alternatives
also
provide
incomplete
control
of
soil
pathogens
in
Michigan.

In
addition,
there
is
a
regulatory
prohibition
on
the
use
of
1,3­
D
on
karst
geology
in
the
South­
Eastern
United
States,
including
Florida.
In
Michigan,
1,3­
D
can
only
be
used
when
soil
temperature
are
higher
than
required
for
using
methyl
bromide,
and
this
results
in
a
planting/
harvesting/
marketing
delay.
In
California,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

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
AVERAGE
OF
2001
AND
2003
(
HA)
PROPORTION
OF
REQUEST
FOR
METHYL
BROMIDE
IN
2003
(%)
California
Region
13,355
3
Michigan
Region
769
33
South­
Eastern
United
States
26,703
100
NATIONAL
TOTAL
:
*
51,506
63
*
National
total
includes
other
regions
not
requesting
methyl
bromide
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

The
primary
reason
that
some
tomatoes
may
be
grown
without
methyl
bromide
in
all
three
regions
is
the
absence
of
key
target
pests
(
i.
e.,
nutsedge
in
the
Southeast,
soil
pathogens
in
Michigan,
and
pathogens
and
nematodes
in
California).

In
Florida,
areas
without
karst
geology
and
having
low
nutsedge
pressure
can
successfully
employ
a
fumigation
system
relying
on
1,3­
D
and
chloropicrin.

In
Michigan,
the
majority
of
tomato
producing
acres
do
not
have
Phytopthora
spp.,
and
do
not
use
methyl
bromide.

In
California,
areas
with
flat
terrain
successfully
employ
1,3­
D
with
chloropicrin
as
a
fumigant.
Page
11
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,
areas
that
use
methyl
bromide
do
so
because
hilly
terrain,
cold
soil
temperatures,
and
heavy
pest
pressure
preclude
the
use
of
fumigants
that
are
employed
when
these
conditions
are
not
present.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
California
Michigan
South­
Eastern
U.
S.**
YEAR
OF
EXEMPTION
REQUEST
2007
KILOGRAMS
OF
METHYL
BROMIDE
40,823
30,391
4,722,340
USE:
BROADCAST
OR
STRIP/
BED
TREATMENT
Broadcast
Strip/
Bed
Mostly
Strip/
Bed
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
or
50:
50
67/
33
Mostly
67/
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
364
253
29,255
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
18.0
13.1
15.0
*
Only
36.7%
percent
of
an
hectare
receives
this
amount
of
methyl
bromide
formulation
**
Includes
Alabama,
Arkansas,
Florida,
Georgia,
Kentucky,
Louisiana,
North
Carolina,
South
Carolina,
and
Tennessee
Page
12
9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
methyl
bromide
nominated
by
the
US
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.

CALIFORNIA
REGION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
REGION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
REGION
­
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
Fusarium
wilt
Verticillium
wilt
Root
Knot
nematodes
Pythium
spp.
Registered
alternatives
do
not
provide
consistent,
efficient
and
economical
control
of
listed
pests.
Page
13
CALIFORNIA
REGION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA
REGION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
REGION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
for
tomato
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Tomato
 
Strawberry
or
Barley
or
fallow
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
Loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
No
additional
information
was
provided
CALIFORNIA
REGION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
Plant
Hardiness
Zone)
9A,
9B,
10A
RAINFALL
(
mm)
0.25
0.00
0.25
3.05
51.8
2.29
OUTSIDE
TEMP.
(
°
C)*
17.8
20.5
22.2
20.0
14.4
11.7
FUMIGATION
SCHEDULE
(
DATES)
X
X
X
X
X
PLANTING
SCHEDULE
(
DATES)
X
X
X
X
KEY
MARKET
WINDOW
(
DATES)
X
X
X
X
X
X
*
Norton
et
al.,
2000.

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

Telone
fumigation
controls
nematodes.
Chloropicrin
controls
fungal
pathogens.
A
combination
of
telone
and
chloropicrin
may
be
a
technically
feasible
alternative
for
methyl
bromide
on
flat
terrain.
However,
this
portion
of
the
CUE
for
California
is
only
for
hilly,
rolling
terrain
where
these
alternatives
would
not
be
uniformly
distributed
by
the
irrigation
systems.

Metam
sodium
alone
or
metam
sodium
plus
chloropicrin
will
not
control
root
knot
nematodes.
In
addition,
rolling
field
topography
having
varied
soil
textures
does
not
allow
uniform
application
of
metam
sodium.
This
may
result
in
pockets
of
high
and
low
concentrations
of
metam
sodium.
High
concentrations
of
metam
sodium
can
be
phytotoxic
to
the
tomatoes,
limiting
its
usefulness
as
an
alternative
in
areas
of
hilly
or
rolling
terrain.
The
surviving
fungal
pathogen
populations
can
build
up
quickly
to
kill
tomato
plants
(
Burnette,
2003).
Page
14
CALIFORNIA
REGION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
REGION
­
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)
1,039
671
1,087
693
1,089
677
1,080
683
900
624
546
RATIO
OF
FLAT
FUMIGATION
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
100%
flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
85,102
85,667
83,795
79,688
73,607
64,632
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
Mostly
Shank
at
25­
30
cm
depth
APPLICATION
RATE
OF
ACTIVE
INGREDIENT
IN
kg/
ha*
127
124
124
117
118
118
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)
12.7
12.4
12.4
11.7
11.8
11.8
CALIFORNIA
REGION
­
PART
C:
TECHNICAL
VALIDATION
Page
15
CALIFORNIA
REGION
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
REGION
 
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
Effective
against
nematodes
but
not
against
fungal
plant
pathogens.
Not
effective
on
hilly,
rolling
terrain.
No
Metam
sodium
Effective
against
fungal
plant
pathogen
if
applied
uniformly.
The
petitioner
states
that
metam
sodium
cannot
be
applied
uniformly
because
of
uneven
land
topography
and
soil
texture,
which
results
in
pockets
of
very
high
and
very
low
metam
sodium
concentrations.
Surviving
populations
of
the
fungal
pathogen
can
build
up
quickly
and
kill
tomato
plants
(
Burnette,
2003).
In
addition,
the
applicant
claims
that
high
concentration
can
be
phytotoxic
and
low
concentrations
do
not
control
fungal
pathogens
(
data
not
submitted).
No
Chloropicrin
Chloropicrin
is
effective
against
many
soil
pathogens,
but
not
against
nematodes
when
it
is
applied
alone.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
The
CUE
is
for
tomatoes
grown
in
the
coastal
areas
of
California,
where
mild
weather
conditions
(
15
­
25
°
C
temperatures)
prevail.
These
weather
conditions
restrict
soil
solarization
as
alternative
to
methyl
bromide.
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
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
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
and/
or
nematodes.
While
biological
control
may
have
utility
as
part
of
plant
pathogen
management
strategy,
by
itself
this
approach
cannot
be
a
methyl
bromide
alternative
No
Cover
crops
and
mulching
There
is
no
evidence
that
these
practices
effectively
substitute
for
the
control
methyl
bromide
provides
against
fungal
pathogens
and
nematodes.
No
Crop
rotation
and
fallow
land
The
land
is
very
expensive
in
this
region,
and
there
are
not
enough
hectares
in
tomato
growing
areas
to
rotate.
Furthermore,
since
fungal
pathogens
survive
for
many
years
in
soil,
rotation
is
not
a
viable
option.
No
Endophytes
No
information
is
available
on
tomato
endophytes
that
will
control
fungal
and
plant
pathogens.
No
Page
16
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Flooding/
Water
management
Flooding
is
not
technically
feasible
as
an
alternative
because
it
does
not
have
any
suppressive
effect
on
fungal
plant
pathogens
and
nematodes.
In
addition,
it
is
prohibitively
expensive
and
there
are
water
management
restrictions.
No
Grafting,
resistant
rootstock,
soilless
culture,
plant
breeding,
organic
production,
substrates,
plug
plants.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
target
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
methyl
bromide
alternatives
for
control
of
fungal
pathogens
and
nematodes.
No
COMBINATIONS
OF
ALTERNATIVES
Metam
sodium
+
Chloropicrin
Undulating
land
topography
and
variable
soil
texture
will
result
in
uneven
concentration
of
metam
sodium
through
drip
irrigation
that
may
affect
field
performance
and
can
result
in
phytotoxicity
to
tomato
transplants.
This
mixture
will
not
control
nematodes.
No
Metam
sodium
+
Crop
rotation
Same
as
metam
sodium
No
1,3
D
+
Metam­
sodium
This
mixture
may
control
fungi
and
nematodes,
but
undulating
land
topography
will
result
in
uneven
concentration
of
metam
sodium
through
drip
irrigation
that
may
result
in
phytotoxicity
to
tomato
transplants.
No
1,3­
D
+
Chloropicrin
Telone
is
effective
against
nematodes.
Chloropicrin
is
effective
against
fungal
plant
pathogens.
The
combination
is
a
technically
feasible
alternative
to
methyl
bromide,
but
undulating
topography
can
reduce
its
uniformity
of
application
and,
hence,
its
effectiveness.
No
1,3­
D
+
metam
sodium
+
pebulate
This
mixture
cannot
be
used
as
a
methyl
bromide
alternative
because
pebulate
is
no
longer
registered
in
the
United
States
(
during
2002
its
registration
expired
and
the
manufacturer
went
out
of
business).
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.
Page
17
CALIFORNIA
REGION
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
REGION
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Foliar
fungicides
are
not
suitable
because
the
key
pests
are
soil
borne
and
afflict
the
belowground
portion
of
the
tomato
plant.
There
are
no
other
alternatives
that
exist
for
the
control
of
these
key
pests
on
hilly
or
rolling
terrain
when
they
are
present
in
the
soil.
A
number
of
fungicides
are
available
that
may
control
fungal
pathogens
when
they
attack
aerial
plant
parts.
Fusarium
spp.
results
in
plant
wilting
and
there
is
no
remedy
once
plant
is
systemically
infected.

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

CALIFORNIA
REGION
 
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
Application
submitted
to
the
US­
EPA
during
February
2002.
Not
registered
Yes
Unknown
Sodium
azide
No
application
submitted
to
the
US­
EPA
till
date.
Not
registered
No
Unknown
Propargyl
bromide
No
application
submitted
to
the
US­
EPA
till
date.
Not
registered
No
Unknown
CALIFORNIA
REGION
­
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:

For
California
there
are
results
of
two
field
trials
conducted
in
San
Diego
and
Ventura
counties
on
the
efficacy
of
methyl
bromide
and
its
alternatives
in
controlling
listed
pests
(
Fusarium
wilt,
Verticillium
wilt,
Root­
knot
nematode,
and
Pythium
spp.).
Metam
sodium
and
1,3­
D
are
both
not
viable
options
because
of
hilly,
rolling
terrain.
Varied
soil
texture
and
undulating
land
topography
can
create
high
and
low
concentration
spots
of
metam
sodium
and
1,3­
D,
affecting
its
efficacy
in
controlling
the
pests
(
Burnette,
2003).
Low
concentrations
may
results
in
lower
efficacy
and
high
concentration
in
phytotoxicity.
Growers
may
suffer
15­
20%
yield
losses.
The
applicant
did
not
submit
any
data
on
the
effect
of
low
and
high
concentration
spots
of
metam
sodium
on
tomato
yield.
Therefore,
we
are
unable
to
validate
whether
or
not
these
losses
are
reasonable.
Page
18
CALIFORNIA
REGION
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available
to
present.

CALIFORNIA
REGION
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
Metam
sodium
Fusarium
wilt
Verticillium
wilt
Root
Knot
nematodes
Pythium
spp.
15­
20%,
based
on
professional
opinion
15­
20%

1,3­
D
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.
1,3­
D
+
Chloropicrin
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.
1,3­
D
+
metam
sodium
+
Chloropicrin
As
above
Not
a
viable
option
because
of
hilly,
rolling
terrain.

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
15­
20%

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

Methyl
iodide,
sodium
azide
and
propargyl
bromide
are
potential
alternatives
to
MB
that
could
be
used
in
California
to
control
fungal
pathogens
and
nematodes.
However,
none
of
them
have
been
widely
tested
in
the
fields
or
registered
for
use
in
any
crop
by
the
United
States
Environmental
Protection
Agency.

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

Tomatoes
are
grown
in
fields.
It
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.
Page
19
CALIFORNIA
REGION
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
US
EPA
has
determined
that
in
flat
terrain,
only
1,3­
D
+
chloropicrin
and
metam
sodium
+
chloropicrin
can
be
technically
feasible
against
the
key
pests
of
tomatoes
grown
in
California.
Metam­
sodium
alone
will
not
control
nematodes
and
may
be
phytotoxic
to
plants
because
of
undulating
land
topography
of
tomato
fields.
A
mixture
of
metam
sodium
and
chloropicrin
will
not
control
nematodes.
In
addition,
this
mixture
may
also
be
phytotoxic
due
to
undulating
land
topography.
A
mixture
of
1,3­
D
and
chloropicrin
is
unreliable
in
undulating
topography
because
of
uneven
distribution
of
the
fumigant
through
drip
irrigation
systems.
Currently
unregistered
alternatives,
such
as
methyl
iodide,
sodium
azide
or
propargyl
bromide
have
shown
good
efficacy
against
the
key
pests.
However,
even
if
registration
is
pursued
soon
the
commercial
tomato
growers
will
need
transition
period
for
adoption
in
California.

There
are
no
non­
chemical
alternatives
that
are
currently
viable
for
MB
replacement
for
commercial
tomato
growers.

MICHIGAN
REGION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
MICHIGAN
REGION
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
MICHIGAN
REGION
­
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
NEEDED
Michigan
Region
1.
Crown,
root
and
fruit
rot
caused
by
Phytophthora
capsici
2.
Fusarium
oxysporum
wilt
MB
is
currently
the
only
product
that
can
control
these
soil­
borne
pathogens
and
allow
MI
growers
to
deliver
their
produce
during
premium
priced
early
market
windows.
Other
control
measures
have
plant
back
restrictions
that
put
MI
tomatoes
outside
the
premium
priced
fresh
market.
Resistant
varieties
have
not
been
identified.
Page
20
MICHIGAN
REGION
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
MICHIGAN
REGION
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
MICHIGAN
REGION
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
tomatoes
to
produce
fruit
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Squash,
cucumber,
eggplant
and
melons.
All
are
susceptible
to
Phytpphthora
capsici.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
Loam
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
Low
soil
temperatures
during
late
March
do
not
allow
effective
soil
fumigation
with
telone,
telone+
chloropicrin
or
metam
sodium
for
tomato
planting
in
April.

MICHIGAN
REGION
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
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
17.7
20.6
20.9
18.1
8.0
2.4
­
2.9
­
8.0
­
7.0
FUMIGATION
SCHEDULE
X
PLANTING
SCHEDULE
X
X
KEY
MARKET
WINDOW
X
X
X
*
HAUSBECK
AND
CORTRIGHT
(
2003).
**
DATA
SOURCE
"
http://
www.
crh.
noaa.
gov/
grr/
climate/
f6/
preliminary.
php?
site=
LAN"

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

In
Michigan,
low
soil
temperatures
during
late
March
to
early
April
make
the
use
of
in­
kind
(
metam­
sodium,
1,3­
D
+
chloropicrin)
fumigants
impractical
because
soil
temperatures
may
be
below
the
labeled
minimums
or
plant
back
restrictions
may
be
too
long
(
14
to
30
days)
to
allow
April
transplanting
of
tomato
seedlings
in
the
field.
Page
21
MICHIGAN
REGION
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
MICHIGAN
REGION
­
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)
191
195
233
260
270
256
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
100%
strip
100%
strip
100%
strip
100%
strip
100%
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
22,964
23,493
28,003
31,235
32,461
30,781
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
Injected
20­
25
cm
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
12.0
12.0
12.0
12.0
12.0
12.0
*
Only
36.7
percent
land
area
is
treated
in
the
form
of
beds
and
therefore
dosage
rate
(
g/
m2)
is
higher.
Page
22
MICHIGAN
REGION
­
PART
C:
TECHNICAL
VALIDATION
MICHIGAN
REGION
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
MICHIGAN
REGION
 
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
D
It
is
not
effective
against
fungal
plant
pathogens.
No
Metam
sodium
Metam
sodium
is
effective
against
soil
fungi.
However,
Michigan
soil
temperatures
during
April
are
too
low
to
use
this
fumigant
for
an
early
fresh
market
tomato
crop.
Product
label
states
that
tomatoes
cannot
be
transplanted
to
the
field
for
up
to
21
days
after
fumigation.
Technically,
it
is
MB
alternative,
but
economically
it
is
not
a
viable
alternative.
No
Chloropicrin
Chloropicrin
is
ineffective
as
a
soil
fumigant
when
applied
alone.
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
Michigan
is
a
northern
state
with
cold
weather
conditions
and
therefore
it
is
not
a
viable
option.
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
the
open
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
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
MB
because
they
alone
cannot
control
the
soil
pathogens
and/
or
nematodes.
While
biological
control
may
have
utility
as
part
of
plant
pathogen
management
strategy,
it
can
not
be
a
methyl
bromide
alternative
No
Cover
crops
and
mulching
There
is
no
evidence
that
these
practices
effectively
substitute
for
the
control
MB
provides
against
fungal
pathogens
and
nematodes.
No
Crop
rotation
and
fallow
land
The
land
is
very
expensive
and
there
are
not
enough
hectares
in
tomato
growing
areas
to
rotate.
The
fungal
pathogen
survive
for
many
years
in
soil
and
therefore
crop
rotation
and
fallow
are
not
a
viable
options
(
Lamour
and
Hausbeck,
2003*)
No
Endophytes
No
information
is
available
on
tomato
endophytes
that
will
control
fungal
and
plant
pathogens.
No
Page
23
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
+
CITATIONS**
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Flooding/
Water
management
Flooding
is
not
technically
feasible
because
it
does
not
suppress
fungal
plant
pathogens
and
nematodes.
No
Grafting/
resistant
rootstock/
plant
breeding/
soilless
culture/
organic
production/
substrates/
plug
plants.
There
are
no
studies
documenting
the
commercial
availability
of
resistant
rootstock
immune
to
the
fungal
pathogens
listed
as
target
pests.
Grafting
and
plant
breeding
are
thus
also
rendered
technically
infeasible
as
MB
alternatives
for
control
of
fungal
pathogens
and
nematodes.
No
COMBINATIONS
OF
ALTERNATIVES
Telone
+
chloropicrin
Telone
is
effective
against
nematodes.
Chloropicrin
is
effective
against
fungal
plant
pathogens.
Their
combination
is
a
technically
feasible
alternative,
but
Michigan's
low
soil
temperature
does
not
allow
soil
fumigation
during
April
months
for
early
fresh
market
tomato
crop.
No
Metam
sodium
+
crop
rotation
Same
as
for
metam
sodium.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

MICHIGAN
REGION
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
None
Other
than
those
options
discussed
above,
there
are
no
alternatives
that
may
control
the
key
pest.
Registered
fungicides
(
such
as
azoxystrobin,
mefenoxam
and
mancozeb)
may
control
aerial
infections
of
Phytophthora
capsici,
but
are
not
effective
against
crown
and
root
rot
phase
of
this
pathogen.
Soil
fumigation
with
methyl
bromide
kills
soil­
borne
primary
inoculum
of
this
pest
and
therefore
fungicide
use
is
also
reduced
(
Lamour
and
Hausbeck,
2003*)
Page
24
MICHIGAN
REGION
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

MICHIGAN
REGION
 
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.
Yes
Unknown
Sodium
azide
Not
registered.
No
registration
package
has
been
received.
No
Unknown
Furfural
Not
registered.
Registration
package
has
been
received.
No
Unknown
Propargyl
Bromide
Not
registered.
No
registration
package
has
been
received.
No
Unknown
MICHIGAN
REGION
­
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:

In
2003,
the
applicant
submitted
the
results
of
one
small
scale
field
trial
on
the
efficacy
of
methyl
bromide
alternatives
in
controlling
Phytophthora
capsici
and
its
effect
on
tomato
yield
(
Hausbeck
and
Cortwright,
2003).
This
study
focused
on
tomato
and
a
number
of
vegetable
crops
(
cucurbits,
winter
squash,
and
melons).
As
of
July
2003,
results
showed
that
methyl
bromide+
chloropicrin
(
67/
33,
shank
injected
@
390
Kg/
Hectare),
metam
sodium
(
drip
applied)
@
355
KG
ai/
ha),
1,
3­
D+
chloropicrin
(
65/
35,
shank
injected
@
150
liters/
ha)
resulted
in
0,
12.9,
6.4
percent
plant
loss.
Untreated
control
suffered
7.1%
plant
loss.
The
fields
were
treated
on
May
15
and
16,
2003,
and
the
weather
was
unusually
cooler
than
normal
during
May
and
early
June
of
the
year
2003.
Results
were
inconclusive.
The
state
expert
claims
that
the
growers
may
suffer
6.4
and
12.9
percent
yield
losses
using
1,
3­
D
+
chloropicrin
and
metam
sodium
if
fields
are
fumigated
in
early
May
instead
of
April
(
using
methyl
bromide
+
chloropicrin).
In
addition,
growers
may
also
experience
revenue
losses
if
they
miss
early
tomato
market
when
prices
are
higher.

This
study
was
repeated
during
the
2004
growing
season.
Results
show
that
yields
from
tomato
plots
treated
with
metam
potassium
(
K­
Pam),
alone
or
in
combination
with
chloropicrin,
and
from
plots
treated
with
1,3­
D
+
chloropicrin
(
Telone
C35)
are
not
significantly
different
from
yields
from
plots
treated
with
MB
+
chloropicrin
or
from
yields
from
untreated
control
plots
(
Hausbeck
and
Cartright,
2004).
As
for
the
2003
trial
discussed
above,
results
of
the
2004
study
are
still
inconclusive,
probably
because
of
the
occurrence
of
low
pest
pressure
in
the
study
area.

MICHIGAN
REGION
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available.
Page
25
MICHIGAN
REGION
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
methyl
bromide+
chloropicrin
Phytophthora
capsici
0.0
 
0.0
0.0
metam
sodium
Phytophthora
capsici
0.0
 
12.9
12.9
1,
3­
D+
chloropicrin
Phytophthora
capsici
0.0
 
6.4
6.4
chloropicrin
Phytophthora
capsici
0.0
 
6.4
6.4
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
0
­
13
%
plus
revenue
losses
due
to
planting
delays;
Most
likely
losses
are
6
%
using
1,3
D
+
chloropicrin
(
the
best
alternative)

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

In
Michigan
the
critical
use
exemption
application
states
that
1,3­
D
+
chloropicrin,
metamsodium
methyl
iodide,
sodium
azide,
and
furfural
will
continue
to
be
under
investigation
as
methyl
bromide
alternatives.
Most
of
these
alternatives
are
currently
unregistered
for
use
on
tomato,
and
there
are
presently
no
commercial
entities
pursuing
registration
in
the
United
States.
The
timeline
for
developing
the
above­
mentioned
MB
alternatives
in
Michigan
is
as
follows:
2003
 
2005:
Test
for
efficacy
(
particularly
against
the
more
prevalent
Phytophthora)
2005
 
2007:
Establish
on­
farm
demonstration
plots
for
effective
MB
alternatives
2008
 
2010:
Work
with
growers
to
implement
commercial
use
of
effective
alternatives.

Research
is
also
under
way
to
optimize
the
use
of
a
50
%
methyl
bromide:
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
REGION
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

Tomatoes
are
grown
in
fields.
In
Michigan,
it
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.
Page
26
MICHIGAN
REGION
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Although
metam
sodium
and
a
combination
of
1,3­
D
+
chloropicrin
can
control
the
key
target
pest,
Phytophthora,
the
resulting
planting
and
harvesting
delays
due
to
cold
soil
temperatures
and
longer
plant­
back
interval
lead
to
a
shorter
growing
season
and
missing
key
market
windows
when
commodity
prices
are
most
favorable.
These
alternatives
have
plant
back
restriction
that
delay
tomato
harvest
by
14­
28
days,
resulting
in
lower
net
revenues
per
acre
because
tomato
prices
decline
as
season
progresses.

Currently
unregistered
alternatives,
such
as
methyl
iodide,
sodium
azide,
propargyl
bromide
and
furfural
have
good
efficacy
against
the
key
pests
involved.
However,
even
if
registration
is
pursued,
the
growers
will
need
transition
time
to
adopt
them.

SOUTH­
EASTERN
UNITED
STATES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
SOUTH­
EASTERN
UNITED
STATES
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
SOUTH­
EASTERN
UNITED
STATES
­
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
NEEDED
South­
Eastern
United
States
Nutsedges
(
Cyperus
rotundus
and
C.
esculentus)

Root­
Knot
nematodes
Phytophthora
Crown
and
Root
Rot.
Fusarium
Wilt
(
F.
oxysporum)
None
of
the
listed
MBTOC
alternatives
is
effective
in
controlling
the
key
pests
in
the
South­
Eastern
United
States.
Page
27
SOUTH­
EASTERN
UNITED
STATES
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
SOUTH­
EASTERN
UNITED
STATES
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
SOUTH­
EASTERN
UNITED
STATES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplant
for
tomato
fruit
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Tomato.
Tomato­
Cucumber
or
Squash
or
Watermelon
or
Cantaloupe.
Tomato­
Cucurbits.

SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
loam,
over
karst
geology
in
many
areas
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annual
OTHER
RELEVANT
FACTORS:
No
other
information
provided.

SOUTH­
EASTERN
UNITED
STATES
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
Plant
Hardiness
Zone)
6b,
7a,
7b,
8a,
8b,
9b,
10a,
10b
SOIL
TEMP.
(
°
C)
**
17­
20
17­
21
21­
24
22­
26
25­
29
26­
29
27­
30
28­
32
27­
29
25­
27
21­
23
19­
21
RAINFALL
(
mm)*
51­
203
51­
203
51­
203
51­
203
102­
203
102­
203
51­
203
51­
203
25­
102
25­
102
25­
102
25­
102
OUTSIDE
TEMP.
(
°
C)*
11­
22
16­
23
21­
25
25­
28
26­
28
25­
28
23­
25
17­
25
10­
22
7­
19
7­
19
8­
19
FUMIGATION
SCHEDULE
X
X
X
X
X
X
X
X
PLANTING
SCHEDULE
X
X
X
X
X
X
X
KEY
MARKET
WINDOW
X
X
X
X
X
X
X
X
*
JACOB
(
1977).
**
FLORIDA
SOIL
TEMPERATUTES
SOURCE
IS
WWW.
IMOK.
UFL/
EDU/
WEATHER/
ARCHIVES/
200/
CLIM00
SOUTH­
EASTERN
UNITED
STATES
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

In
the
Southeastern
U.
S.,
karst
geology
inhibits
the
use
of
all
fumigants
that
contain
1,3­
D
in
a
significant
portion
of
the
tomato
production
areas.
Page
28
SOUTH­
EASTERN
UNITED
STATES
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
SOUTH­
EASTERN
UNITED
STATES
­
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)
24,002
25,814
27,831
28,931
29,409
29,581
RATIO
OF
FLAT
FUMIGATION
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
Approx.
50%
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
4,747,976
4,491,580
4,462,390
4,514,006
4,472,250
4,962,683
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
Chloropicrin)
67/
33
67/
33
67/
33
67/
33
67/
33
67/
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
Mostly
Injected
at
25­
30
cm
depth
ACTUAL
DOSAGE
RATE
OF
ACTIVE
INGREDIENT
(
g/
m2)*
19.6
17.5
16.3
15.8
15.2
16.8
Page
29
SOUTH­
EASTERN
UNITED
STATES
­
PART
C:
TECHNICAL
VALIDATION
SOUTH­
EASTERN
UNITED
STATES
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
SOUTH­
EASTERN
UNITED
STATES
 
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
(
Telone)
Effective
against
nematodes,
but
not
against
fungal
plant
pathogens
and
nutsedge
weeds.
Approximately
40%
of
tomato
land
has
Karst
geology.
Growers
with
Karst
geology
cannot
use
1,3­
D
because
of
underground
water
contamination.
No
Metam
sodium/
potassium
Metam
(
sodium
or
potassium)
will
control
many
weeds,
but
control
of
nutsedge
is
very
inconsistent,
and
this
fumigant
is
not
very
effective
against
soil
nematodes.
No
Chloropicrin
Chloropicrin
controls
soil
fungi,
but
may
also
stimulate
nutsedge
weed
growth,
and
therefore
it
is
not
a
viable
option.
It
occasionally
controls
nutsedge
as
noted
in
the
literature.
Again,
the
issue
is
its
inability
to
get
consistent
control
(
Culpepper,
2004).
No
NON
CHEMICAL
ALTERNATIVES
Soil
solarization
For
nutsedge
control
in
the
southeastern
U.
S.
states,
solarization
is
unlikely
to
be
technically
feasible
as
a
methyl
bromide
alternative.
Research
indicates
that
the
lethal
temperature
for
nutsedge
tubers
is
50oC
or
higher
(
Chase
et
al.
1999).
While
this
may
be
achieved
for
some
portion
of
the
autumn
cropping
in
southern
growing
regions,
it
is
very
unlikely
for
any
portion
of
the
spring
crops.
Trials
conducted
in
mid­
summer
in
Georgia
resulted
in
maximal
soil
temperatures
of
43oC
at
5
cm
depth,
not
high
enough
to
destroy
nutsedge
tubers,
and
tubers
lodged
deeper
in
the
soil
would
be
completely
unaffected.
No
Steam
Steam
is
not
a
technically
feasible
alternative
for
open
field
tomato
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
tomato
fields.
Any
such
system
would
also
require
large
amounts
of
energy
and
water
to
provide
sufficient
steam
necessary
to
pasteurize
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,
nematodes
and
nutsedges.
No
Page
30
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
Cover
crops
and
mulches
appear
to
reduce
weed
population,
but
not
nutsedges
(
Burgos
and
Talbert
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
Crop
rotation
and
fallow
land
It
is
not
a
technically
or
economically
(
cannot
afford
to
take
land
out
of
production)
feasible
alternative
to
MB
because
it
does
not,
by
itself,
provide
adequate
control
of
fungi
and/
or
nutsedges.
Crops
available
for
rotation
to
growers
are
also
susceptible
to
fungi,
while
fallow
land
can
still
harbor
fungal
oospores.
The
nutsedge
tubers
provide
new
plants
with
larger
energy
reserves
than
the
annual
weeds
that
can
be
frequently
controlled
by
crop
rotations
and
fallow
land.
Furthermore,
nutsedge
plants
can
produce
tubers
within
8
weeks
after
emergence.
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
Endophytes
This
is
not
a
technically
viable
option
because
it
has
never
been
shown
to
work
against
the
key
pests
in
tomato
or
similar
crops.
No
Flooding/
Water
management
Flooding
has
never
been
shown
to
control
nutsedge
species.
Nutsedges
are
much
more
tolerant
of
watery
conditions
than
many
other
weed
pests.
For
example,
Horowitz
(
1972)
showed
that
submerging
nutsedge
in
flowing
or
stagnant
water
(
for
8
days
and
4
weeks,
respectively)
did
not
affect
the
sprouting
capacity
of
tubers.
There
are
also
serious
practical
obstacles
to
implementing
flood
management
approaches
in
cucurbit
production
in
the
southern
and
southeastern
U.
S.
states.
Droughts
are
common
in
many
parts
of
these
regions,
and
the
soil
composition
may
not
support
flooding
and
still
remain
productive.
No
Grafting/
resistant
rootstock/
plant
breeding/
soil­
less
culture/
organic
production/
substrates/
plug
plants.
These
technologies
have
never
been
shown
to
control
listed
key
pests
under
field
conditions.
Resistant
root
stock
or
cultivars
may
control
one
pest,
but
not
the
other.
It
is
almost
impossible
to
breed
or
genetically
engineer
tomato
cultivars
that
has
all
agronomic
characters
and
is
resistant
to
all
key
pests.
This
has
no
effect
on
managing
nutsedge
weeds.
No
COMBINATIONS
OF
ALTERNATIVES
1,3
D
+
chloropicrin+
a
herbicide
(
such
as
napropamide
+
smetolachlor
+
halosulfuron)
A
combination
of
fumigants
and
herbicide
partners
is
the
most
promising
alternative
for
the
control
of
all
key
pests
in
southeastern
region.
The
executive
summary
of
dozens
of
research
trials
show
that
the
growers
may
harvest
tomato
yield
that
is
nearly
equal
to
yields
obtained
using
MB
and
chloropicrin.
With
this
combination,
in
areas
where
it
can
be
used,
growers
may
lose
an
average
of
6.2%
yield
(
Chellemi
et
al.,
2001).
Some
combinations
are
promising
Page
31
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

Metam
sodium
+
Chloropicrin
Although
this
combination
may
be
more
effective
than
metam
sodium
alone
in
controlling
fungal
pests,
it
would
not
prevent
yield
losses
caused
by
nutsedges
and
some
species
of
nematodes.
This
mixture
along
with
a
herbicide
(
for
controlling
nutsedge
weeds)
may
be
a
viable
MB
alternative
in
the
South­
Eastern
United
States,
where
growers
cannot
use
telone
due
to
karst
geology.
Further
studies
need
to
be
undertaken
to
ascertain
whether
or
not
it
is
technically
and
economically
viable.
It
shows
promise
Telone
+
Chloropicrin
This
combination
is
effective
against
nematodes
and
fungal
plant
pathogens,
but
not
against
nutsedge
and
other
weeds.
Approximately
40
and
8.0%
of
tomato
land
in
Florida
and
Georgia,
respectively,
has
Karst
geology.
Growers
in
these
areas
cannot
use
telone
because
of
state
regulations
and
underground
water
contamination
issues.
No
Telone
+
metam
sodium
+
herbicide
(
such
as
napropamide
+
smetolachlor
+
halosulfuron)
This
mixture
could
provide
reasonable
control
of
pests
when
weed
pressure
is
low
to
moderate
and
land
does
not
have
Karst
geology.
Growers
will
need
to
use
one
of
the
newly
registered
herbicides
if
they
use
this
combination,
although
they
will
be
constrained
by
certain
limitations
(
described
below).
No
Metam
sodium
+
Crop
rotation
Same
as
metam
sodium.

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.
Page
32
SOUTH­
EASTERN
UNITED
STATES
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

SOUTH­
EASTERN
UNITED
STATES
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Glyphosate
It
is
a
non­
selective
herbicide
that
can
be
applied
to
row
middles
only,
since
direct
application
to
the
rows
would
cause
injury
to
the
tomato
crop.
It
does
not
provide
residual
control.
As
a
post­
emergence
treatment,
glyphosate
will
not
provide
season
long
control
of
yellow
and/
or
purple
nutsedge
in
tomatoes.

Paraquat
It
is
a
non­
selective
herbicide
that
will
not
control
nutsedge
in
the
plant
rows.
It
does
not
provide
residual
control.
Repetitive
applications
are
required
to
achieve
fair
control
of
annual
weeds
in
the
row
middle
(
Culpepper,
2003).
It
may
also
be
applied
prior
to
crop
emergence.
Direct
application
to
the
rows
would
cause
injury
to
the
tomato
crop.
For
perennial
weeds,
such
as
nutsedge,
it
will
burn
down
the
top
portion
of
the
plant,
but
would
not
affect
tuber
viability,
allowing
the
weed
to
grow
again.
Thus,
paraquat
cannot
provide
season
long.

SOUTH­
EASTERN
UNITED
STATES
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:
Page
33
SOUTH­
EASTERN
UNITED
STATES
 
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:

Halosulfuronmethyl
There
are
a
number
of
restrictions
limiting
the
potential
to
use
this
herbicide
in
tomatoes
in
the
Southeast
(
see
additional
notes
below).
Among
these
are
potential
crop
injury
and
plant
back
restrictions
for
rotational
crops.
Efficacy
is
lowered
in
rainy
conditions
(
which
are
common
in
this
region).
Need
more
time
to
experiment
under
field
conditions.
Yes
Recently
registered
Pebulate
For
nutsedges:
Was
registered
for
use
in
tomatoes
only,
but
its
registration
expired
in
December,
2002
(
the
manufacturer
went
out
of
business)
No
Unknown
S­
metolachlor
For
nutsedges:
Not
registered
in
some
states
of
concern.
It
is
effective
against
yellow
nutsedge
and
not
effective
against
purple
nutsedge
(
Culpepper,
2004).
Yes
Already
registered
Terbacil
For
nutsedges:
Registered
only
in
strawberries.
The
manufacturer
claims
that
it
is
partially
effective
against
yellow
nutsedge
and
does
not
control
purple
nutsedge.
No
Unknown
Rimsulfuron
Registered
for
use
on
tomatoes.
The
product
label
states
that
it
is
partially
effective
against
nutsedges.
Y
Already
registered
Trifloxysulfuron
For
nutsedges:
Newly
Registrated
for
use
in
tomato.
Efficacy
needs
to
be
tested
under
large
scale
field
trials.
Labeled
for
use
in
Florida
only.
It
provides
good
postemergence
control
of
nutsedge
but
rotational
restrictions
may
limit
its
large
scale
adoption.
Y
Already
registered
Methyl
Iodide
Not
yet
registered
in
the
United
States
Y
unknown
Sodium
azide
Not
registered
in
the
United
States
No
unknown
Sulfuryl
Floride
It
is
not
registered
for
preplant
soil
treatment.
It
is
registered
only
for
postharvest
treatment
of
agricultural
produce
(
tomato
not
included).
No
unknown
Additional
notes
on
specific
herbicides
listed:
Halosulfuron­
methyl
In
December
2002,
halosulfuron­
methyl
(
Sandea
®
)
was
registered
for
weed
control
(
including
nutsedge)
in
tomatoes,
peppers,
eggplant,
and
cucurbits.
This
recent
registration
was
not
on
the
list
of
alternatives
from
MBTOC
and
several
years
are
needed
to
see
if
it
will
be
adopted.
Historically,
in
the
United
States
it
has
taken
three
to
five
years
for
an
herbicide
to
be
adopted
by
a
significant
number
of
vegetable
crop
growers.

Halosulfuron­
methyl
has
a
number
of
limitations
which
may
affect
its
widespread
adoption,
that
include:
(
1)
phyto­
toxicity
with
moderate
rainfall
immediately
after
application;
(
2)
cool
temperatures,
(
3)
susceptible
varieties,
and
(
4)
plant
back
restrictions.
Specifically:
 
Rainfall
or
sprinkler
irrigation
greater
than
2.5
cm,
soon
after
a
pre­
emergent
application
of
halosulfuronmethyl
may
cause
crop
injury.
Sudden
storms
with
greater
than
2.5
cm
of
rainfall
are
common
in
Florida
Page
34
and
other
areas
of
the
southeastern
United
States.
In
addition,
rainfall
within
four
hours
after
a
postemergence
application
of
halosulfuron­
methyl
may
reduce
effectiveness
and
cause
crop
injury.
 
Under
cool
temperatures
that
can
delay
early
seedling
emergence
or
growth,
halosulfuron
methyl
can
cause
injury
or
crop
failure.
This
is
especially
likely
to
occur
during
the
first
planting
of
the
season.
In
addition,
not
all
hybrids/
varieties
of
tomatoes
have
been
tested
for
sensitivity
to
halosulfuron­
methyl.
Halosulfuron
may
also
delay
maturity
of
treated
crops.
 
Halosulfuron
methyl
plant
back
restrictions
are
up
to
36
months.
Many
of
the
vegetable
crops
fall
within
the
4
to
12
month
range,
although
some
are
longer.
There
are
label
limitations
for
halosulfuron
methyl.
As
per
product
label,
halosulfuron
methyl
should
not
be
applied
if
the
crop
or
target
weeds
are
under
stress
due
to
drought,
water
saturated
soils,
low
fertility,
or
other
poor
growing
conditions.
This
herbicide
can
not
be
applied
to
soil
that
has
been
treated
with
organophosphate
insecticides.
Foliar
applications
of
organophosphate
insecticides
may
not
be
made
within
21
days
before
or
7
days
after
halosulfuron
methyl
application.
Note:
All
the
limitations
above
are
listed
in
the
US
registration
label
for
halosulfuron,
which
in
turn
is
based
on
proprietary
data
submitted
to
EPA
by
the
registrant
company.

S­
metolachlor
It
was
registered
for
use
in
tomatoes
in
April
2003.
However,
it
is
not
registered
in
states
of
concern,
and
does
not
control
purple
nutsedge
or
nightshade
species.
Further,
it
does
not
provide
commercially
acceptable
weed
control
in
plasticulture
systems.

Rimsulfuron
There
is
evidence
that
rimsulfuron
only
provides
suppressive
control
of
yellow
nutsedge
(
40
to
70
percent
control)
(
Nelson
et
al,
2002).
In
addition,
the
label
warns
against
tank
mixing
with
organophosphate
insecticides
because
injury
to
the
crop
may
occur.
Also,
for
most
of
the
vegetable
crops
besides
tomatoes
there
is
a
12­
month
plant
back
restriction.
This
plant
back
restriction
can
seriously
compromise
the
rotational
interval
needed
for
second
crop
production
and
IPM
programs.

SOUTH­
EASTERN
UNITED
STATES
­
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
Telone
C35
(
1,3
D
+
35
%
chloropicrin)
plus
pebulate
herbicide
has
been
found
to
be
the
best
alternative
to
methyl
bromide
in
controlling
listed
key
pests
under
Florida
growing
conditions
(
Chellemi
et
al.,
2001).
Pebulate
is
no
longer
registered
in
the
U.
S.,
however,
so
another
herbicide
would
have
to
be
substituted
into
the
fumigation
mixture.
The
results
of
many
trials
show
that
growers
may
harvest
tomato
yields
that
are
nearly
equal
to
yields
obtained
using
methyl
bromide
and
chloropicrin.
Assuming
that
an
herbicide
is
used
that
is
as
effective
as
pebulate,
growers
using
a
1,3­
D
+
chloropicrin
+
herbicide
mixture
may
suffer
an
average
of
6.2
percent
yield
losses
(
Chellemi
et
al.,
2001).
Florida
and
Georgia
crop
experts
maintain
that
tomato
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
herbicides
will
be
higher
than
6.2
percent
because
pebulate
is
no
longer
registered
and
other
herbicides
have
limitations.
However,
in
areas
of
low
to
moderate
pest
pressure,
information
suggests
that
some
growers
may
employ
a
marginal
strategy
without
major
economic
dislocation
if
given
a
reasonable
time
frame
for
the
transition.
The
assessment
of
need
was
adjusted
to
account
for
this.
The
crop
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials
and
maintain
that
more
time
is
needed
to
evaluate
various
MB
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.
Page
35
SOUTH­
EASTERN
UNITED
STATES
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
No
additional
information
is
available.

SOUTH­
EASTERN
UNITED
STATES
 
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
+
herbicide
Fungi,
Nematodes
and
Nutsedges
1.3
 
10.1
(
Chellemi
et
al.,
2001)
6.2
OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
6.2%

SOUTH­
EASTERN
UNITED
STATES
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:

A
combination
of
1,3
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
herbicide
is
no
longer
available
then
the
growers
will
have
to
substitute
another
herbicide
for
postemergence
application,
listed
in
table
14.1
and
15.1
(
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
to
achieve
similar
pest
control).
Florida
and
Georgia
state
expert
claim
the
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
herbicides
will
be
higher
than
6.2
losses
because
pebulate
is
no
longer
registered
and
other
herbicides
have
limitations.
The
crop
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials.
The
experts
claim
that
more
time
is
needed
to
evaluate
various
methyl
bromide
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.

SOUTH­
EASTERN
UNITED
STATES
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

Tomatoes
are
grown
in
fields.
In
South­
eastern
united
states,
it
is
neither
technically
feasible
nor
economically
viable
to
grow
tomatoes
in
soil­
less
culture
or
in
containers.
Page
36
SOUTH­
EASTERN
UNITED
STATES
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
The
submitted
data
showed
that
using
the
above
best
alternative
the
growers
are
expected
to
suffer
6.2%
yield
losses
(
Chellemi,
Botts
and
Noling.
2001).
A
combination
of
1,3­
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
is
no
longer
available
then
the
growers
will
need
to
substitute
another
herbicides
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
for
postmergence
application
to
control
nutsedge
weeds.
But,
these
herbicides
have
significant
limitations,
as
described
in
the
notes
to
Table
15.1.
In
addition,
losses
will
be
higher
in
areas
of
Karst
geology,
where
1,3­
D
may
not
be
used.

Florida
and
Georgia
state
experts
claim
that
the
yield
losses
using
a
combination
of
1,3
D
+
chloropicrin
+
other
herbicides
will
be
higher
than
6.2
losses
because
of
limitations
of
other
herbicides
(
see
table
14.1
and
15.1).
The
experts
were
unable
to
provide
yield
loss
estimate
without
2­
3
years
of
field
trials.
The
experts
claim
that
more
time
is
needed
to
evaluate
various
methyl
bromide
fumigant
alternatives,
mulches
and
herbicides
systems
to
study
their
effects
on
tomato
yields.
Page
37
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?
Began
research
during
2003
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future.
Between
1997
and
2002,
the
US
has
achieved
a
27
%
reduction
in
use
rates.
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
The
US
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Began
research
during
2003
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
Already
using
67:
33
with
the
potential
to
use
lower
ratios
in
the
future
Not
applicable
OTHER
MEASURES
(
please
describe)
Not
applicable
Not
applicable
Not
applicable
Not
applicable
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
methyl
bromide.
The
use
of
methyl
bromide
in
the
growing
of
tomato
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
has,
for
the
last
40
years,
been
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
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
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
application
for
tomatoes
is
most
often
machine
injected
into
soil
to
specific
depths.

As
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
Page
38
methyl
bromide
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
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
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
methyl
bromide.
In
addition,
cultural
practices
are
utilized
by
tomato
growers.

Reduced
methyl
bromide
concentrations
in
mixtures,
cultural
practices,
and
the
extensive
use
of
tarpaulins
to
cover
land
treated
with
methyl
bromide
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.
Page
39
PART
E:
ECONOMIC
ASSESSMENT
The
following
economic
analysis
is
organized
by
MeBr
critical
use
application.
Cost
of
MeBr
and
alternatives
are
given
first
in
table
21.1.
This
is
followed
in
table
22.1
by
a
listing
of
net
and
gross
revenues
by
applicant.
Expected
losses
when
using
MeBr
alternatives
are
then
decomposed
in
tables
E1
through
E3.

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

21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

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

22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3 
D
+
Chloropicrin
$
33,772
$
8,825
Page
40
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3 
D
+
Chloropicrin
$
33,772
$
8,825
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
REGION
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
83,367
$
33,127
Metam
Sodium
(
15%)
$
70,862
$
24,509
CALIFORNIA
Metam
Sodium
(
20%)
$
66,694
$
22,068
Methyl
Bromide
$
39,996
$
9,438
1,3 
D
+
Chloropicrin
$
32,880
$
3,325
Metam
Sodium
$
34,931
$
5,192
MICHIGAN
Chloropicrin
$
32,880
$
3,325
Methyl
Bromide
$
40,914
$
14,533
SOUTHEASTERN
US
1,3 
D
+
Chloropicrin
$
33,772
$
8,825
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
METAM
SODIUM
PRODUCTION
LOSS
(%)
0%
15%
20%

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

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

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

**
Note
that
the
measures
in
the
tables
below
must
be
interpreted
carefully.
Operating
costs
do
not
include
fixed
costs
and
net
revenue
equals
gross
revenue
minus
operating
costs.
Page
41
MICHIGAN
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
MICHIGAN
METHYL
BROMIDE
1,3­
D
+
PIC
METAM
SODIUM
CHLOROPICRIN
PRODUCTION
LOSS
(%)
0%
6%
13%
6%
PRODUCTION
PER
HECTARE
4,414
4,132
3,845
4,132
*
PRICE
PER
UNIT
(
US$)
$
9.44
$
9.44
$
9.44
$
9.448
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
41,652
$
38986
$
36,279
$
38986
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
37,055
$
32453
$
31,170
$
32,453
=
NET
REVENUE
PER
HECTARE
(
US$)
$
4596
$
6,533
$
5,109
$
6,533
FIVE
LOSS
MEASURES
*

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

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

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

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

SOUTHEASTERN
US
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
SOUTHEASTERN
US
METHYL
BROMIDE
1,3­
D
+
PIC
PRODUCTION
LOSS
(%)
0%
6%
PRODUCTION
PER
HECTARE
4,551
4,269
*
PRICE
PER
UNIT
(
US$)
$
10
$
10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
46,986
$
44,073
­
OPERATING
COSTS
PER
HECTARE
(
US$)**
$
26,660
$
29,860
=
NET
REVENUE
PER
HECTARE
(
US$)
$
20,326
14,212
FIVE
LOSS
MEASURES
*

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

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

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

**
Note
that
the
measures
in
the
tables
below
must
be
interpreted
carefully.
Operating
costs
do
not
include
fixed
costs
and
net
revenue
equals
gross
revenue
minus
operating
costs.
Page
42
SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
of
the
tomato
application
compared
data
on
yields,
crop
prices,
revenues
and
costs
using
methyl
bromide
and
using
alternative
pest
control
regimens
in
order
to
estimate
the
loss
of
methyl
bromide
availability.
The
alternatives
identified
as
technically
feasible
­
in
cases
of
low
pest
infestation
­
by
the
U.
S.
are:
(
a)
1,3­
Dichloropropene
and
Chloropicrin;
(
b)
Metam
sodium;
and
(
c)
Chloropicrin.
Changes
in
pest
control
costs
for
tomatoes
are
less
than
4
percent
of
total
variable
costs
therefore
they
would
have
little
impact
on
any
of
the
economic
measures
used
in
the
analysis.

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

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

(
1)
Loss
per
Hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production.

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

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

(
5)
Operating
Profit
Margin.
We
define
operating
profit
margin
to
be
net
operating
revenue
divided
by
gross
revenue
per
hectare.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult,
therefore
fixed
costs
were
not
included
in
the
analysis.
Page
43
These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
tomato
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

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

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

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

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

Southeastern
US
We
conclude
that,
at
present,
no
economically
feasible
alternatives
to
MeBr
exist
for
use
in
Southeastern
US
tomato
production.
Two
factors
have
proven
most
important
in
our
conclusion.
These
are
yield
loss
and
missed
market
windows.
Page
44
Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
price
declines.
In
order
to
maximize
their
revenues,
tomato
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
tomatoes
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
tomato
operations.

To
describe
these
conditions
in
Southeastern
US
tomato
production,
we
used
weekly
tomato
sales
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
three
years
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
we
assume
that
if
tomato
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
accumulate
gross
revenues
reduced
by
approximately
12%.
We
reduced
the
season
average
price
by
12%
in
our
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
we
believe
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Southeastern
US.
Page
45
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.

As
per
Culpepper
(
2004),
over
50
vegetable
trials,
focusing
on
weed
management,
were
conducted
by
the
University
of
Georgia.
Four
of
these
trials
compared
methyl
bromide
alternatives
and
another
30
trials
searched
for
the
development
and
labeling
of
new
herbicides
for
vegetables.
During
2004,
these
experiments
will
be
continued
to
find
methyl
bromide
alternatives.

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
tomatoes
research
will
require
5501
kg
per
year
of
methyl
bromide
for
2005
and
2007.
This
research
request
also
includes
the
amounts
for
asparagus,
cabbage,
ginseng,
and
nutsedge
for
74
kg
per
year.
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
Page
46
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
root­
knot
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.

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

Georgia
experts
(
Culpepper,
2004)
claims
that
the
ability
to
reduce
the
use
of
methyl
bromide
will
rely
on
the
interaction
of
fumigant
alternatives,
plastic
mulches
and
herbicide
systems
under
specific
growing
conditions.
More
time
is
needed
to
develop
these
systems.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?)

Research
efforts
began
in
the
early
1990'
s
to
find
out
methyl
bromide
alternatives
in
various
crops
including
tomato.
With
each
year
of
experimentation
the
researchers
became
more
familiar
and
efficient
with
methyl
bromide
fumigant
alternatives
for
nutsedge
management.
The
researchers
learned
strengths
and
weakness
of
each
fumigant
system,
plastic
film
types,
herbicide
system,
and
various
production
environments.
The
researchers
need
a
few
more
years
to
evaluate
and
refine
these
systems
in
large
scale
trials
prior
to
large
scale
implementation
at
growers
field
level.
Page
47
26.
CITATIONS
Chellemi,
D.,
Botts,
D.
A.
and
Noling,
J.
W.
2001.
Field
scale
demonstration/
validation
studies
of
methyl
bromide
in
plastic
mulch
culture
in
Florida,
USDA
ARS
specific
co­
operative
agreement
SCA
#
58­
6617­
6­
013,
Executive
Summary
(
1996­
2001)
submitted
to
the
USEPA

Burnette,
G.
2003.
Personal
communication,
November
25,
2003.

Culpepper,
Stanley.
2004.
Faculty,
University
of
Georgia,
Athens,
GA.
Comments
on
methyl
bromide
Critical
use
nomination
for
preplant
soil
use
for
tomato
grown
in
open
fields.

Florida.
2000.
Florida
soil
temperatures.
Web
address:
www.
imok.
ufl/
edu/
weather/
archive/
200/
clim00
Hausbeck,
M.
and
Cortright,
B.
2003.
Soil
temperature
data
submitted
to
BEAD
(
OPP,
US­
EPA)
in
support
of
methyl
bromide
critical
use
exemption
application.

Jacob,
W.
C.
1977.
Range
of
mean
outside
temperature
and
rainfall
in
South­
Eastern
United
States.
Climatic
Atlas
of
the
United
States.
Published
by
the
US
Department
of
Commerce.

Lamour,
H.
H.
and
Hausbeck,
M.
2003.
Effect
of
crop
rotation
on
the
survival
of
Phytophthora
capsici
in
Michigan.
Plant
Disease
87:
841­
845.

Locasio,
S.
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.,
Kucharek,
T.
A.,
Jones,
J.
P.
and
Noling,
J.
W.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene­
mulched
tomato.
HortScience
32(
7)
1208­
1211.

Morales,
J.
P.,
Santos,
B.
M.,
Stall,
W.
M.
and
Bewick.
T.
A.
1997.
Effects
of
purple
nutsedge
(
Cyprus
rotundus)
on
tomato
and
bell
pepper
vegetative
growth
and
fruit
yield.
Weed
Science
Technology
11:
672­
676.

Nelson,
K.
A.
and
Renner,
K.
A.
2002.
Yellow
nutsedge
(
Cyprus
esculentus)
control
and
tuber
production
with
glyphosate
and
ALS­
inhibiting
herbicides.
Weed
Technology
16(
3):
512­
519.

Norton,
J.,
Nelson,
R.
D.,
Nelson,
M.
D.,
Olson,
B.
O.,
Mey,
B.
V.
and
Lepez,
G.
2000.
Field
evaluation
of
alternatives
to
methyl
bromide
for
pre­
plant
soil
fumigant
in
California
tomatoes.
USDA
IR­
4
methyl
bromide
alternatives
program
for
minor
crop.
Report
submitted
to
the
US­
EPA
during
2003
in
support
of
methyl
bromide
critical
use
exemption.

Stall,
W.
M.
and
Morales­
Payan,
J.
P.
2003.
The
critical
period
of
nutsedge
interference
in
tomato,
Florida.
Web
address:
http://
www.
imok.
ufl.
edu/
liv/
groups/
ipm/
weed_
con/
nutsedge.
htm
Page
48
U.
S.
Environmental
Protection
Agency.
1998.
Re­
registration
Eligibility
Decision
(
RED)
1,3
dichloroprppene.
Available
at
http://
www.
epa.
gov/
REDs/
0328red.
pdf
U.
S.
Environmental
Protection
Agency.
1998.
Feasibility
of
using
gas
permeable
tarps
to
reduce
methyl
bromide
emissions
associated
with
soil
fumigation
in
the
United
States.
Page
49
APPENDIX
A.
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
%
of
2001
&
2002
Avg
%
of
Request
769
34%
33%

13,355
5%
3%

26,703
109%
107%

40,827
74%
72%

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

10,333
10,333
10,333
86
120
40,823
40,823
40,823
364
112
2,665,180
2,158,264
2,277,389
14,785
154
2,716,336
2,209,420
2,328,546
15,235
153
42%
53%
51%
48%
5%

Low
EPA
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
%
Adopt
%
per
Year
120
120
0%
0%
0%
0%
34%
34%
0%
0%
0%
0%
34%
34%
34%
34%
0%
0%

112
112
0%
0%
0%
0%
0%
0%
9%
1%
100%
100%
0%
0%
100%
100%
0%
0%

154
154
32%
32%
0%
0%
50%
29%
0%
0%
0%
0%
0%
0%
66%
53%
83%
10%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Yes
Yes
Yes
Tarp
No
­
Yes
1/
year
16
$
5%
42%

Yes
Yes
Yes
Tarp
No
­
Yes
1/
year
22
$
7%
21%

Yes
Yes
Yes
Tarp
No
­
Yes
1/
year
36
$
13%
30%

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

****
Adoption
/
Transition
in
the
Southeastern
US
is
the
weighted
average
based
on
the
weight
of
their
request
and
the
estimate
that
can
be
transitioned.
MOST
LIKELY
IMPACT
VALUE
*
Georgia
rotates
crops
with
solanaceous
crops
therefore
we
had
to
balance
the
distribution
with
the
other
sectors
in
Georgia's
application.
2,453,015
48%

30,391
­
­

2007
Request
Adoption
/
Transition****

Most
Likely
Impact
Value:

40,823
2,401,858
***
Michigan
rates
are
higher
for
2007
based
on
more
current
information.
10,333
­
Regulatory
Issues
(%)

4%

California
Southeastern
US
REGION
California
Southeastern
US
40,823
­

4,651,126
­

REGION
Michigan
(­)
QPS
(­)
Double
Counting
(­)
Growth
­

(­)
Use
Rate
Adjustment
REGION
Michigan
Other
Considerations
%
Reduction
from
Initial
Request
TOTAL
Combined
Impacts
(%)

Cold
Soil
Temp
(%)

Unsuitable
Terrain
(%)

Adjustments
to
Requested
Amounts
0%
0%
4,535,675
4,535,675
3,019,356
Other
Issues
California
Southeastern
US
Use
Rate
(
kg/
ha)
(%)
Karst
(
Telone)
(%)
100
ft
Buffer
Zones
(%)
Key
Pest
Distribution
Dichotomous
Variables
(
Y/
N)

Michigan
***
REGION
Michigan
California
Southeastern
US
4%
4%
36%

4,722,340
4,722,340
4,535,675
186,665
­
­
2,968,200
10,333
­
40,823
­
­

2007
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)

4,601,624
30,088
153
0%

TOTAL
OR
AVERAGE
4,722,340
29,255
161
4,651,126
28,638
162
4,493,128
29,170
154
0%

265
120
0%

653
117
0%

40,823
364
112
76,648
Kilograms
(
kgs)
Use
Rate
(
kg/
ha)

30,391
253
120
31,848
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Adoption
/
Transition
Adjustment
(
kgs)

**
Georgia
Acreage
estimates
verified
at
http://
www.
caed.
uga.
edu/
2003gafgveg.
pdf
Methyl
Bromide
Critical
Use
Exemption
Process
2007
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Combined
Impacts
Adjustment
(
kgs)

HIGH
LOW
2007
Amount
of
Request
2001
&
2002
Average
Use
Quarantine
and
Pre­
Shipment
Marginal
Strategy
1,3­
D
+
Pic
Metam­
Sodium
1,3­
D+
Pic+
herbicide
Research
Amount
(
kgs)
5501
Average
Hectares
in
the
US:

%
of
Average
Hectares
Requested:

Regional
Hectares**
48,603
60%

Date:
Sector:
1/
27/
2005
TOMATOES
Conversion
Units:

Economic
Analysis
Loss
per
Hectare
(

US$/

ha)
1,937
$
5,391
$
6,113
$
15%
Yield
Loss,
Range
15
to
20%

21%,
6.2%
Yield
Loss+
14.8%
delay
Quality/
Time/
Market
Window/
Yield
Loss
(%)

22%,
6%
Yield
Loss
+
16%
delay
Page
50
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
Page
51
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2007
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2007
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
geology
 
Percent
karst
geology
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
geology.
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
geology,
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
geology.
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.
Page
52
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.
Page
53
APPENDIX
B.
2006
Methyl
Bromide
Reconsideration
for
Tomatoes.

Overview
of
the
US
Nomiation
The
U.
S.
is
requesting
2,844.985
metric
tons
of
methyl
bromide
for
use
on
field­
grown
tomatoes
in
the
following
areas:
Michigan
(
10.746
metric
tons),
California
(
102.058
metric
tons),
and
the
southeastern
U.
S.
Florida
and
Georgia
as
well
as
other
states
in
the
southeast
(
2,
726.68
metric
tons)
with
a
small
additional
amount
(
5.501
metric
tons)
for
research
purposes.

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

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


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


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


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


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


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

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

MBTOC
suggests
that
California
can
use
shank
injected
1,3­
D/
pic
and
avoid
the
problems
that
drip
applied
poses
on
the
hilly
terrain
that
forms
the
basis
for
the
California
request.
MBTOC
asserts
that
only
9%
of
the
California
terrain
is
precluded
from
this
option
due
to
binding
township
caps.
In
the
case
of
the
southeastern
states,
MBTOC
has
indicated
their
view
that
alternatives
are
technically
and
economically
feasible
and
applies
a
20%
phasein
factor.
MBTOC
further
states
that
the
dosage
can
be
reduced
for
a
maximum
applied
rate
of
200kg/
ha
for
the
treated
areas
and
may
be
further
reduced
if
high
density
films,
including
VIF
are
used.
Page
54
California
MBTOC
has
suggested
that
shank­
injected
1,3­
D/
Pic
can
be
used
in
all
areas
that
are
not
currently
impacted
by
the
township
caps.
In
making
this
suggestion
they
are
ignoring
both
the
technical
and
regulatory
factors
described
above
and
the
actual
working
of
the
township
caps
in
California.
The
township
cap
is
a
maximum
that
can
be
applied
assuming
that
the
method
of
application
is
deep
shank
injection.
For
all
other
forms
of
injection
an
`
application
factor'
is
applied.
The
purpose
of
this
application
factor
is
to
reduce
the
amount
of
1,3­
D
that
can
be
applied
to
a
given
area,
reducing
exposure
to
the
population
to
a
level
comparable
to
that
experienced
when
deep
shank
injection
is
used.

Deep
shank
injection
cannot
be
used
to
control
pests
in
California
tomato
production.
Unlike
Florida,
where
the
soils
are
sandy
to
a
considerable
depth,
in
California
the
soils
are
prepared
for
planting
to
a
depth
of
12­
18
inches1.
The
deep
shank
method
injects
1,3­
D
below
this
level
where
the
soil
is
not
prepared
and
breaks
into
clumps.
The
soil
must
be
re­
tilled
before
planting
which
risks
introducing
pathogens
back
into
the
planting
zone.
When
shallow­
shank
injection
is
used,
the
higher
application
factors
mean
that
a
much
smaller
area
can
be
injected.

Dr.
Legard2
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
acre3
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
treated4.

The
U.
S.
assessment
that
the
alternatives
are
not
technically
and
economically
feasible
rests
on
two
kinds
of
losses5:
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
1
This
corresponds
to
30­
45
cm.
2
Daniel
Legard,
PhD,
personal
communication.
January
9,
2005.
3
The
common
use
rate
on
strawberries
in
California
4
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).

5
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.
Page
55
(
missed
market
windows,
shorter
harvest
periods,
the
inability
to
grow
a
second
crop).
The
proportion
of
loss
attributable
to
each
component
differs
from
sector
to
sector,
and
within
sectors,
depending
on
the
local
circumstances
of
the
nomination.
As
an
example,
for
tomatoes
in
both
Michigan
and
the
southeastern
United
States,
approximately
70%
to
75%
of
the
loss
is
attributable
to
missing
the
high
value
market
time
and
25%
to
30%
of
the
loss
is
attributable
to
lower
yield
Southeastern
United
States
MBTOC
has
asserted
that
for
the
southeastern
United
States
alternatives
are
technically
and
economically
feasible.
Using
this
assertion
as
a
basis
they
recommend
a
20%
reduction
for
phase­
in
of
alternatives
such
as
1,3D/
Pic
or
metam
sodium
with
or
without
Pic.

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

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


Included
an
untreated
control
for
comparison
purposes
on
pest
levels

Included
methyl
bromide
as
a
treatment
standard

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

Give
estimates
of
yield
changes
(
differences)

The
U.
S.
nomination
was
restricted
to
those
situations
where
the
presence
and
prevalence
of
pests
(`
key'
pests)
that
could
not
be
controlled
by
alternatives
to
methyl
bromide
was
moderate
to
severe6
and
would
result
in
yield
loss.

As
we
understand
it
from
discussions
at
MOP­
16,
MBTOC
used
what
they
describe,
interchangeably
as
a
"
meta
analysis"
or
an
`
average'.
The
procedure
MBTOC
used
was
not
a
meta
analysis
in
thata
meta
analysis
includes
only
studies
which
are
similar
enough
from
a
statistical
standpoint
that
they
can
be
combined
and
analyzed
as
if
they
comprised
one
study,
and
the
studies
need
to
be
identified,
appraised
and
summarized
according
to
an
explicit
and
reproducible
methodology
that
is
designed
to
answer
a
specific
research
question.
In
this
case,
the
appropriate
research
question
would
be
the
performance
of
alternatives
to
methyl
bromide
under
the
conditions
of
the
U.
S.
nomination
(
i.
e.
with
moderate
to
severe
pressure
from
key
pests).
The
null
hypothesis
would
be
that
alternatives
work
as
well
as
methyl
bromide
in
the
conditions
of
the
U.
S.
nomination.
The
U.
S.
nomination
is
specifically
for
the
use
of
methyl
bromide
where
key
pests
(
pests
not
adequately
controlled
by
alternatives
to
methyl
bromide)
are
present
at
moderate
to
severe
levels
and/
or
soil,
climate,
terrain,
or
regulatory
conditions
are
such
that
alternatives
to
methyl
bromide
either
cannot
be
used
or
result
in
significant
economic
losses
when
used.
These
economic
losses
must
be
of
sufficient
magnitude
that
they
render
the
alternative
"
not
economically
feasible"
which
presents
a
serious
problem
in
applying
the
meta
analysis.
Our
understanding
is
that
this
analysis
includes
some
studies
conducted
under
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.
Page
56
circumstances
that
are
not
similar
to
the
limited
conditions
included
in
the
U.
S.
nomination,
such
as
the
presence
of
moderate
to
severe
pest
pressure.

Although
it
is
difficult
to
be
certain
how
the
MBTOC
analysis
was
conducted
and
what
it
includes
because
it
has
not
been
reviewed
and
published
and
was
not
provided
to
the
U.
S.
experts
to
evaluate7,
we
are
able
to
make
some
educated
guesses
about
the
analysis8.
The
analysis
for
strawberry
fruit
is
described
in
a
paper
is
listed
as
being
"
in
press"
as
conference
proceedings
with
a
date
after
the
MBTOC
recommendations
on
the
U.
S.
nomination
were
tendered.

A
version
of
the
paper
was
presented
by
Dr.
Ian
Porter
at
the
Methyl
Bromide
Alternatives
Organization
meeting
in
San
Diego,
November
2003
and
was
the
subject
of
some
controversy
and
concern
among
a
number
of
participants.
Dr.
Porter's
paper
included
a
number
of
papers
which
U.
S.
experts
believe
are
not
appropriate
for
use
in
determining
the
usefulness
of
alternatives
because
the
research
was
carried
out
under
conditions
of
no
pest
pressure,
and
are
therefore
not
relevant
to
the
specific
circumstances
of
our
nomination9.
If
no
pests
are
present
any
alternative,
or
indeed
not
using
any
pesticide
at
all,
will
all
work
equally
well.
By
including
situations
where
there
is
no
pest
pressure
one
in
effect
adds
(
many)
"
100"
to
the
equation10
describing
the
differences
in
yield
between
crops
grown
using
methyl
bromide
and
those
grown
using
an
alternative.
This
has
the
effect
of
lowering
the
average
difference
between
yields
using
methyl
bromide
and
yields
using
an
alternative.
If
a
sufficient
number
of
"
100"
are
added,
the
result
will
be
to
(
falsely)
eliminate
the
yield
differences
between
methyl
bromide
and
the
alternatives.

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

7
The
US
Government
requested
references
from
two
of
the
authors
of
the
paper
to
allow
us
to
better
understand
the
analysis,
but
this
information
has
not
yet
been
provided
8
Some
of
this
material
with
references
had
been
previously
presented
at
the
Methyl
Bromide
Alternatives
Organization
2003
meeting
(
San
Diego).
At
that
time
U.
S.
experts
expressed
their
view
that
many
if
not
most
of
the
studies
were
not
an
appropriate
application
of
the
information.

9
For
example,
some
trials
are
used
for
residue
tests.
These
tests
are
likely
to
be
carried
out
in
conditions
of
little
or
no
pest
pressure
in
order
to
have
enough
harvested
fruit
to
test
for
residue.
The
Porter
paper
does
not
indicate
which
of
the
studies
used
(
but
not
cited)
where
for
the
purposes
of
examining
pesticide
residues.

10
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.
Page
57
If
the
issue
had
been
to
average
all
papers,
describing
some
"
average"
worldwide
situation,
the
procedure
followed
in
this
approach
would
be
appropriate.
However,
The
U.
S.
submitted
requests
for
continued
methyl
bromide
use
only
instances
of
sufficiently
high
pest
pressure
(
not
average)
for
pests
which
cannot
be
controlled
by
alternatives
to
methyl
bromide.

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

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

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

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

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

It
is
difficult
to
determine
the
basis
MBTOC
used
in
determining
that
alternatives
for
methyl
bromide
are
both
technically
and
economically
feasible
in
tomato
production.
USG
technical
Page
58
experts
asked
MBTOC
to
explain
the
basis
for
their
decision11
and
were
told
that
in
some
cases
a
meta
analysis
served
as
the
basis,
and
in
other
cases
the
basis
was
experience.
When
asked
for
references,
USG
experts
were
directed
to
"
the
Porter
paper
in
press".
USG
experts
have
examined
a
"
Porter
paper
in
press"
12
and
have
a
number
of
concerns
over
its
applicability
to
the
specific
circumstances
of
the
U.
S.
CUE.
Although
it
has
a
publication
date
of
one
year
later
than
the
San
Diego
presentation,
we
find
that
our
concerns
over
its
applicability
have
not
been
resolved.
The
studies
used
in
the
meta
analysis
are
not
listed
and
no
indication
is
given
of
the
criteria
used
to
include
or
exclude
a
study
from
the
analysis.

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

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

1.
Yield
Loss
­
Expected
yield
losses
of
somewhat
over
6%
13
are
anticipated
throughout
southeastern
U.
S.
tomato
production.

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

Our
analysis
of
this
effect
is
based
on
the
fact
that
prices
farmers
receive
for
their
tomatoes
vary
widely
over
the
course
of
the
growing
season.
Driving
these
fluctuations
are
the
forces
of
supply
and
demand.
Early
in
the
growing
season,
when
relatively
few
tomatoes
are
harvested,
the
supply
is
at
is
lowest
and
the
market
price
is
at
its
highest.
As
harvested
quantities
increase,
the
11
MBTOC
suggests
that
alternatives
were
both
technically
and
economically
feasible
for
the
pre­
plant
sectors
of
field
grown
peppers,
strawberries,
and
tomatoes.
The
same
assertions
were
made
for
portions
of
other
countries'
nominations
as
well.
12
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.
13
The
submitted
data
showed
that
using
the
above
best
alternative
the
growers
are
expected
to
suffer
6.2%
yield
losses
(
Chellemi,
Botts
and
Noling.
2001).
A
combination
of
1,3­
D
+
chloropicrin
+
pebulate
appeared
to
be
the
best
alternative
in
controlling
key
pests
in
tomato
fields.
Since
pebulate
is
no
longer
available
then
the
growers
will
need
to
substitute
another
herbicides
such
as
halosulfuron,
rimsulfuron
or
trifloxysulfuron
to
control
nutsedge
weeds.
These
herbicides,
however,
have
significant
limitations.
In
addition,
losses
will
be
higher
in
areas
of
Karst
geology,
where
1,3­
D
may
not
be
used.
Page
59
price
declines.
In
order
to
maximize
their
revenues,
tomato
growers
manage
their
production
systems
with
the
goal
of
harvesting
the
largest
possible
quantity
of
tomatoes
when
the
prices
are
at
their
highs.
The
ability
to
sell
produce
at
these
higher
prices
makes
a
significant
contribution
toward
the
profitability
of
tomato
operations.

To
describe
these
conditions
in
Southeastern
U.
S.
tomato
production,
we
used
weekly
tomato
sales
data
from
the
U.
S.
Department
of
Agriculture
for
the
previous
three
years
to
gauge
the
impact
of
early
season
price
fluctuations
on
gross
revenues.
Though
data
availability
is
limiting,
we
assume
that
if
tomato
growers
adjust
the
timing
of
their
production
system,
as
required
when
using
1,3­
D
+
Chloropicrin,
that
they
will,
over
the
course
of
the
growing
season,
accumulate
gross
revenues
reduced
by
approximately
15%.
We
reduced
the
season
average
price
by
15%
in
our
analysis
of
the
alternatives
to
reflect
this.
Based
on
currently
available
information,
we
believe
this
reduction
in
gross
revenues
serves
as
a
reasonable
indicator
of
the
typical
effect
of
planting
delays
resulting
when
MeBr
alternatives
are
used
in
Southeastern
US.

MBTOC
has
suggested
that
rates
can
be
reduced
to
a
maximum
level
of
200kg/
ha
MBTOC
has
also
reduced
the
amount
recommended
for
tomatoes
stating:
"
A
further
adjustment
was
applied
to
reduce
the
dosage
to
the
guideline
level
of
200kg/
ha
under
the
strips."
When
this
issue
was
discussed
with
MBTOC
members
during
the
16th
MOP,
U.
S.
experts
agreed
to
clarify
whether
the
reported
rates
were
in
fact
the
rates
used
under
the
strips
(
as
the
U.
S.
believed)
or
whether
they
were
the
average
for
an
acre
as
MBTOC
believed14.
The
U.
S.
has
verified
that
the
application
rates
provided
in
the
quantitative
assessment
(
the
Methyl
Bromide
Usage
Numerical
Index,
or
BUNI)
are
in
fact
the
rates
under
the
strips.
The
number
of
acres
reported
is
the
"
treated
acres",
so
that
a
strip
application
results
in
two
thirds
of
an
acre
being
fumigated
while
one­
third
is
the
untreated
is
reported
as
two
thirds
of
an
acre.

They
have
further
suggested
that
rates
can
be
reduced
still
further
if
higher
density
tarps,
including
VIF,
are
used.
One
of
the
papers
cited
in
support
of
this
proposal
is
Fennimore
et
el,
2003.
Fennimore
was
contacted
to
determine
whether,
in
his
opinion,
his
work
could
be
appropriately
used
to
support
lower
application
rates.
His
reply,
reproduced
below,
indicates
that
he
is
very
uncomfortable
with
this
interpretation
of
his
results15.

14
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.
15
From:
Steven
Fennimore
[
mailto:
safennimore@
ucdavis.
edu]
Sent:
Fri
Jan
07
16:
24:
43
2005
To:
Dan
Legard
Cc:
jmduniway@
ucdavis.
edu;
haajwa@
ucdavis.
edu
Subject:
MBTOC
VIF
stance
Hi
Dan
I
am
a
bit
disturbed
to
learn
from
you
that
the
some
in
MBTOC
may
have
come
to
the
conclusion
that
VIF
will
allow
reduced
rates
of
methyl
bromide.
While
I
stand
behind
my
research
that
indicates
clearly
that
the
weed
control
efficacy
of
drip­
applied
chloropicrin
and
Inline
are
improved
under
VIF
compared
to
standard
film,
these
fumigants
are
used
to
Page
60
Technical
and
Economic
Assessment
of
MBTOC/
TEAP
Report.
We
have
not
been
provided
by
MBTOC
with
information
on
their
technical
assessment
of
the
performance
of
alternatives,
ortheir
economic
assessment
on
the
impact
of
converting
to
alternatives.
To
support
the
MBTOC's
recommended
change
in
the
U.
S.
request
citations
of
the
research
references
and
economic
assessments
that
led
to
the
MBTOC
conclusions
are
needed
so
we
can
understand
the
justification.
The
technical
references
should
describe
the
species
tested,
pest
numbers,
concentrations,
times,
and
commodity
volumes.
Economic
references
should
describe
the
costs
of
converting
from
methyl
bromide
to
alternatives,
the
impact
of
higher
yield
losses,
longer
plant
back
intervals,
the
economic
feasibility
if
key
market
windows
are
missed,
and
the
economic
impact
of
a
20%
transition
to
alternatives
including
estimates
of
management
costs
for
more
intensive
programs
and
how
the
impact
of
less
reliable
alternatives
is
calculated.
The
sources
of
estimates
of
the
extent
of
pest
pressure
should
describe
the
rationale
for
using
other
estimates,
a
complete
description
of
the
questions,
species
being
surveyed
and
quantitative
levels
used.

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

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

control
many
other
pests
besides
weeds.
For
example,
results
do
not
necessarily
suggest
that
VIF
improves
phytopthora
cactorum
control.
Our
research
results
presented
at
MBAO
are
preliminary
and
we
are
currently
preparing
peer
reviewed
publications.
When
those
are
written
we
will
have
a
more
clear
understanding
of
the
potential
benefits
and
limitations
of
VIF
than
we
have
now.
I
do
believe
that
VIF
offers
real
potential
benefits,
however
I
caution
anyone
to
make
policy
decisions
about
VIF
based
on
my
preliminary
results
presented
at
MBAO
Steve
Fennimore
Extension
Specialist
University
of
California,
Davis
1636
East
Alisal
St
Salinas,
CA
93905
831­
755­
2896
Page
61
Burnette,
G.
2003.
Personal
communication,
November
25,
2003.

Culpepper,
Stanley.
2004.
Faculty,
University
of
Georgia,
Athens,
GA.
Comments
on
methyl
bromide
Critical
use
nomination
for
preplant
soil
use
for
tomato
grown
in
open
fields.

Florida.
2000.
Florida
soil
temperatures.
Web
address:
www.
imok.
ufl/
edu/
weather/
archive/
200/
clim00
Hausbeck,
M.
and
Cortright,
B.
2003.
Soil
temperature
data
submitted
to
BEAD
(
OPP,
US­
EPA)
in
support
of
methyl
bromide
critical
use
exemption
application.

Jacob,
W.
C.
1977.
Range
of
mean
outside
temperature
and
rainfall
in
South­
Eastern
United
States.
Climatic
Atlas
of
the
United
States.
Published
by
the
US
Department
of
Commerce.

Lamour,
H.
H.
and
Hausbeck,
M.
2003.
Effect
of
crop
rotation
on
the
survival
of
Phytophthora
capsici
in
Michigan.
Plant
Disease
87:
841­
845.

Locasio,
S.
J.,
Gilreath,
J.
P.,
Dickson,
D.
W.,
Kucharek,
T.
A.,
Jones,
J.
P.
and
Noling,
J.
W.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene­
mulched
tomato.
HortScience
32(
7)
1208­
1211.

Morales,
J.
P.,
Santos,
B.
M.,
Stall,
W.
M.
and
Bewick.
T.
A.
1997.
Effects
of
purple
nutsedge
(
Cyprus
rotundus)
on
tomato
and
bell
pepper
vegetative
growth
and
fruit
yield.
Weed
Science
Technology
11:
672­
676.

Nelson,
K.
A.
and
Renner,
K.
A.
2002.
Yellow
nutsedge
(
Cyprus
esculentus)
control
and
tuber
production
with
glyphosate
and
ALS­
inhibiting
herbicides.
Weed
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