Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Eggplant 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 Preplant Soil Use for Eggplant Grown in Open Fields
(Submitted in 2006 for 2008 Use Season)



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:	  HYPERLINK "mailto:ThompsonJE2@state.gov" 
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:







Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting 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) 308-8200

Fax:	(703) 308-8090

E-mail:	Keigwin.Richard@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

Paper Documents:

Title of Paper Documents and Appendices	Number of Pages	Date Sent to
Ozone Secretariat



















electronic copies of all paper documents: 

Title of Electronic Files	Size of File (kb)	Date Sent to Ozone
Secretariat



















Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125775924"  Part A: Summary	 
PAGEREF _Toc125775924 \h  7  

  HYPERLINK \l "_Toc125775925"  1. Nominating Party	  PAGEREF
_Toc125775925 \h  7  

  HYPERLINK \l "_Toc125775926"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125775926 \h  7  

  HYPERLINK \l "_Toc125775927"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125775927 \h  7  

  HYPERLINK \l "_Toc125775928"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125775928 \h  7  

  HYPERLINK \l "_Toc125775929"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125775929 \h  10  

  HYPERLINK \l "_Toc125775930"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125775930 \h  10  

  HYPERLINK \l "_Toc125775931"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125775931 \h  11  

  HYPERLINK \l "_Toc125775932"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125775932 \h  11  

  HYPERLINK \l "_Toc125775933"  Florida - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125775933 \h  12  

  HYPERLINK \l "_Toc125775934"  Florida - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125775934 \h  12  

  HYPERLINK \l "_Toc125775935"  Florida - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125775935 \h  14  

  HYPERLINK \l "_Toc125775936"  Florida - Part C: Technical Validation	 
PAGEREF _Toc125775936 \h  15  

  HYPERLINK \l "_Toc125775937"  Florida - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125775937 \h  15  

  HYPERLINK \l "_Toc125775938"  Florida - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125775938 \h  16  

  HYPERLINK \l "_Toc125775939"  Florida - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125775939 \h  16  

  HYPERLINK \l "_Toc125775940"  Florida - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested	
 PAGEREF _Toc125775940 \h  17  

  HYPERLINK \l "_Toc125775941"  Florida - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125775941 \h  18  

  HYPERLINK \l "_Toc125775942"  Florida - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125775942 \h  18  

  HYPERLINK \l "_Toc125775943"  Florida - Summary of Technical
Feasibility	  PAGEREF _Toc125775943 \h  18  

  HYPERLINK \l "_Toc125775944"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125775944 \h  20  

  HYPERLINK \l "_Toc125775945"  Georgia - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc125775945 \h  20  

  HYPERLINK \l "_Toc125775946"  Georgia - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125775946 \h  20  

  HYPERLINK \l "_Toc125775947"  Georgia - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125775947 \h  22  

  HYPERLINK \l "_Toc125775948"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125775948 \h  23  

  HYPERLINK \l "_Toc125775949"  Georgia - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125775949 \h  23  

  HYPERLINK \l "_Toc125775950"  Georgia - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125775950 \h  25  

  HYPERLINK \l "_Toc125775951"  Georgia - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125775951 \h  25  

  HYPERLINK \l "_Toc125775952"  Georgia - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested	
 PAGEREF _Toc125775952 \h  26  

  HYPERLINK \l "_Toc125775953"  Georgia - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125775953 \h  27  

  HYPERLINK \l "_Toc125775954"  Georgia - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125775954 \h  27  

  HYPERLINK \l "_Toc125775955"  Georgia - Summary of Technical
Feasibility	  PAGEREF _Toc125775955 \h  28  

  HYPERLINK \l "_Toc125775956"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125775956 \h  29  

  HYPERLINK \l "_Toc125775957"  Michigan - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc125775957 \h  29  

  HYPERLINK \l "_Toc125775958"  Michigan - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125775958 \h  29  

  HYPERLINK \l "_Toc125775959"  Michigan - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc125775959 \h  31  

  HYPERLINK \l "_Toc125775960"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125775960 \h  32  

  HYPERLINK \l "_Toc125775961"  Michigan - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125775961 \h  32  

  HYPERLINK \l "_Toc125775962"  Michigan - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125775962 \h  33  

  HYPERLINK \l "_Toc125775963"  Michigan - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125775963 \h  34  

  HYPERLINK \l "_Toc125775964"  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	
 PAGEREF _Toc125775964 \h  35  

  HYPERLINK \l "_Toc125775965"  Michigan - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125775965 \h  36  

  HYPERLINK \l "_Toc125775966"  Michigan - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125775966 \h  36  

  HYPERLINK \l "_Toc125775967"  Michigan - Summary of Technical
Feasibility	  PAGEREF _Toc125775967 \h  37  

  HYPERLINK \l "_Toc125775968"  Part D: Emission Control	  PAGEREF
_Toc125775968 \h  38  

  HYPERLINK \l "_Toc125775969"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125775969 \h  38  

  HYPERLINK \l "_Toc125775970"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125775970 \h  38  

  HYPERLINK \l "_Toc125775971"  Part E: Economic Assessment	  PAGEREF
_Toc125775971 \h  39  

  HYPERLINK \l "_Toc125775972"  21. Operating Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125775972 \h
 39  

  HYPERLINK \l "_Toc125775973"  22. Gross and Net Revenue	  PAGEREF
_Toc125775973 \h  40  

  HYPERLINK \l "_Toc125775974"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125775974 \h  41  

  HYPERLINK \l "_Toc125775975"  Summary of Economic Feasibility	 
PAGEREF _Toc125775975 \h  42  

  HYPERLINK \l "_Toc125775976"  Part F. Future Plans	  PAGEREF
_Toc125775976 \h  44  

  HYPERLINK \l "_Toc125775977"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125775977 \h  44  

  HYPERLINK \l "_Toc125775978"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125775978 \h  45  

  HYPERLINK \l "_Toc125775979"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125775979 \h  45  

  HYPERLINK \l "_Toc125775980"  26. Citations	  PAGEREF _Toc125775980 \h
 46  

  HYPERLINK \l "_Toc125775981"  Citations Reviewed but Not Applicable	 
PAGEREF _Toc125775981 \h  47  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125775982"  Part A:
Summary	  PAGEREF _Toc125775982 \h  7  

  HYPERLINK \l "_Toc125775983"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125775983 \h  7  

  HYPERLINK \l "_Toc125775984"  Table A.1: Executive Summary	  PAGEREF
_Toc125775984 \h  10  

  HYPERLINK \l "_Toc125775985"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125775985 \h  10  

  HYPERLINK \l "_Toc125775986"  Florida - Table 8.1: Amount of Methyl
Bromide Requested for Critical Use	  PAGEREF _Toc125775986 \h  11  

  HYPERLINK \l "_Toc125775987"  Florida - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125775987 \h  12  

  HYPERLINK \l "_Toc125775988"  Florida - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125775988 \h 
12  

  HYPERLINK \l "_Toc125775989"  Florida - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125775989 \h  12  

  HYPERLINK \l "_Toc125775990"  Florida - Table 11.2: Characteristics of
Climate and Eggplant Crop Schedule Not Double-Cropped	  PAGEREF
_Toc125775990 \h  13  

  HYPERLINK \l "_Toc125775991"  Florida - Table 11.3 Characteristics of
Climate and Eggplant Crop Schedule; Double Cropped	  PAGEREF
_Toc125775991 \h  13  

  HYPERLINK \l "_Toc125775992"  Florida - Table 12.1 Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc125775992 \h  14  

  HYPERLINK \l "_Toc125775993"  Florida - Part C: Technical Validation	 
PAGEREF _Toc125775993 \h  15  

  HYPERLINK \l "_Toc125775994"  Florida – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125775994 \h  15  

  HYPERLINK \l "_Toc125775995"  Florida – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125775995 \h  16  

  HYPERLINK \l "_Toc125775996"  Florida – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125775996 \h  16  

  HYPERLINK \l "_Toc125775997"  Florida  – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125775997 \h  17  

  HYPERLINK \l "_Toc125775998"  Table 16.1.  Fumigant Alternatives to
Methyl Bromide for Polyethylene-Mulched Tomato (Locascio et al., 1997	 
PAGEREF _Toc125775998 \h  17  

  HYPERLINK \l "_Toc125775999"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125775999 \h  20  

  HYPERLINK \l "_Toc125776000"  Georgia - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125776000 \h 
20  

  HYPERLINK \l "_Toc125776001"  Georgia - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125776001 \h  20  

  HYPERLINK \l "_Toc125776002"  Georgia - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125776002 \h  21  

  HYPERLINK \l "_Toc125776003"  Georgia - Table 12.1 Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc125776003 \h  22  

  HYPERLINK \l "_Toc125776004"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125776004 \h  23  

  HYPERLINK \l "_Toc125776005"  Georgia – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125776005 \h  23  

  HYPERLINK \l "_Toc125776006"  Georgia – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125776006 \h  25  

  HYPERLINK \l "_Toc125776007"  Georgia – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125776007 \h  25  

  HYPERLINK \l "_Toc125776008"  Southeastern USA except Georgia –
Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125776008
\h  26  

  HYPERLINK \l "_Toc125776009"  Table 16.1.  Fumigant Alternatives to
Methyl Bromide for Polyethylene-Mulched Tomato (Locascio et al., 1997	 
PAGEREF _Toc125776009 \h  27  

  HYPERLINK \l "_Toc125776010"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125776010 \h  29  

  HYPERLINK \l "_Toc125776011"  Michigan - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125776011 \h 
29  

  HYPERLINK \l "_Toc125776012"  Michigan - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc125776012 \h  29  

  HYPERLINK \l "_Toc125776013"  Michigan - Table 11.2 Characteristics of
Climate and Crop Schedule for Eggplants	  PAGEREF _Toc125776013 \h  30  

  HYPERLINK \l "_Toc125776014"  Michigan - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125776014 \h  31  

  HYPERLINK \l "_Toc125776015"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125776015 \h  32  

  HYPERLINK \l "_Toc125776016"  Michigan – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125776016 \h  32  

  HYPERLINK \l "_Toc125776017"  Michigan – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125776017 \h  34  

  HYPERLINK \l "_Toc125776018"  Michigan – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125776018 \h  36  

  HYPERLINK \l "_Toc125776019"  Part D: Emission Control	  PAGEREF
_Toc125776019 \h  38  

  HYPERLINK \l "_Toc125776020"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125776020 \h  38  

  HYPERLINK \l "_Toc125776021"  Part E: Economic Assessment	  PAGEREF
_Toc125776021 \h  39  

  HYPERLINK \l "_Toc125776022"  Table 21.1: Eggplant – Operating Costs
of Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc125776022 \h  40  

  HYPERLINK \l "_Toc125776023"  Table 22.1: Eggplant - Year 1, 2, and 3
Gross and Net Revenues	  PAGEREF _Toc125776023 \h  40  

  HYPERLINK \l "_Toc125776024"  Florida Eggplant - Table E.1: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125776024 \h  41  

  HYPERLINK \l "_Toc125776025"  Georgia Eggplant – Table E.2: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125776025 \h  41  

  HYPERLINK \l "_Toc125776026"  Michigan Eggplant - Table E.3: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125776026 \h  42  

  HYPERLINK \l "_Toc125776027"  Part F. Future Plans	  PAGEREF
_Toc125776027 \h  44  

  HYPERLINK \l "_Toc125776028"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125776028 \h  48  

 

Part A: Summary  TC "Part A: Summary" \f F \l "1"    TC "Part A:
Summary" \f C \l "1"  



1. Nominating Party  TC "1. Nominating Party" \f C \l "2"  :



The United States of America (U.S.)



2. Descriptive Title of Nomination  TC "2. Descriptive Title of
Nomination" \f C \l "2"  :



Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Eggplant Grown in Open Fields (Submitted in 2006 for 2008 Use Season)



3. Crop and Summary of Crop System  TC "3. Crop and Summary of Crop
System" \f C \l "2"  :



This is a request for eggplant grown in the States of Florida, Georgia,
and Michigan.  In Florida, eggplant can be grown year-round, and are
often double cropped with pepper or cucumber following eggplant harvest.
The vegetable crop that follows eggplant in a double cropping production
system depends upon prevailing environmental and economic factors.
Growers in Florida often put eggplant in as an extra crop, and grow
okra, squash, or cucumbers after the eggplant has been harvested.  A
spring crop of eggplant may follow as a second crop after a fall crop of
pepper or tomato.  Eggplant does best on well-drained, fertile,
sandy-loam soils at a pH of 6.0-6.5.  Poorly drained soils may result in
slow plant growth, reduced root systems, and low yields. Eggplant
requires a long, warm, frost-free growing season, usually of 14-16
weeks. Cold temperatures below 5oC injure this crop. The best
temperatures are 27-32oC during the day and 21-32oC during the night. 
Plant growth is curtailed at temperatures below 16oC.  Additionally,
soil temperature below 16oC restricts germination. However, most
eggplant is started in the field from transplants.  Methyl bromide (MB)
is always used in the full-bed mulch process. Until 1999, the chemical
formulation primarily used was 98 percent methyl bromide and two percent
chloropicrin. Since then, growers have shifted to formulations with
lower concentrations of methyl bromide and higher amounts of
chloropicrin due to the phase-out schedule of methyl bromide (USDA,
2002). 

4. Methyl Bromide Nominated



Table 4.1: Methyl Bromide Nominated  TC "Table 4.1: Methyl Bromide
Nominated" \f F \l "1"  

Year	Nomination Amount (kg)	Nomination Area (ha)

2008	79,546	611

*This amount includes 433 kg for research.

5. Brief Summary of the Need for Methyl Bromide as a Critical Use  TC
"5. Brief Summary of the Need for Methyl Bromide as a Critical Use" \f C
\l "2"  : 



The US nomination is only for those areas where the alternatives are not
suitable.  In US eggplant 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
eggplant 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
eggplants 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 Florida and
Georgia 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.

Methyl bromide is the only fumigant that consistently provides reliable
control of target weeds, nematodes, and pathogens.  There are no
technically or economically feasible alternatives.  The best
alternatives (e.g. 1,3-D + chloropicrin, metam sodium) are not as
effective in controlling nutsedge and have a long waiting period for
planting that would disrupt planting schedules and cause growers to miss
key market windows.  Furthermore, regulatory restrictions due to
concerns over human exposure and ground water contamination, along with
technical limitations, result in potential economic infeasibility of
1,3-D alone or in combination as a practical MB alternative. Key among
these factors are a 28 day planting delay due both to label
restrictions, low soil temperatures, and a mandatory 30.4 m buffer for
treated fields near inhabited structures.  

  

5.1  Michigan

In Michigan eggplant the key target pest is Phytophthora capsici.  These
soil fungi can easily destroy the entire harvest from affected areas if
left uncontrolled.  In small plot trials with peppers and cucurbits in
Michigan (Hausbeck and Cortright 2004), the level of control provided by
1, 3 D + chloropicrin or metam-potassium was comparable to that afforded
by MB. No trials were done with eggplants specifically, but since
peppers are also a solanaceous crop, these results are promising.
However, it is noteworthy that P. capsici has recently been shown to
occur in irrigation water in Michigan (Gevens and Hausbeck 2003).  This
will increase the likelihood of repeated re-infestation of this
pathogen. It is also not yet clear whether these small-scale results
accurately reflect efficacy of MB alternatives in commercial fresh
vegetable (peppers, eggplant, and cucurbit) production.  These trials
were done at a single location that only had cucurbit crops grown on it
in the past, and other studies of these MB alternatives (described in
the regional discussions later in this document) have not shown such
promising results, suggesting that the pathogen in this Michigan study
may not have adapted to solanaceous crops. Perhaps more importantly,
this study used fumigants applied in June when soil temperatures are
much warmer than in April, which is typically when fumigation must be
done by eggplant growers who need to plant according to premium market
price windows.  Given the lower dissipation of these MB alternatives at
temperatures around 4 oC, it is unlikely that the good efficacy seen in
this trial would be consistently repeated if fumigations were timed more
typically. Furthermore, regulatory restrictions (e.g., mandatory 30 m
buffer zone for treated fields near inhabited structures) due to
concerns over human exposure and ground water contamination, along with
technical and economic limitations, result in potential infeasibility of
this formulation as a practical MB alternative. Also, variations in soil
temperatures or rainfall could easily cause delays in fumigation events,
since the most likely MB substitutes (1,3 D + chloropicrin and
metam-sodium/potassium) currently available have label restrictions or
efficacy limitations permitting use only above certain temperatures or
when rain is not imminent . Label restrictions on these aMB alternatives
also mandate planting delays based on rates used; at higher rates these
delays can be as much as 2 weeks longer than those for MB itself. There
could thus be unpredictable but potentially significant economic effects
created by the planting delays (described above), which will disrupt the
schedule of delivery of fresh eggplant harvest to wholesale buyers.

Florida and Georgia

Nutsedges, when present at moderate to severe infestations, are key
pests which require MB for control in the Southeastern U.S., including
Florida and Georgia.  Other pest problems in this region that are
managed with MB include southern blight, damping-off, and wilt.  Of MB
alternatives, only 1,3-D + chloropicrin has some efficacy against
Phytophthora.  However, 1,3-D cannot be applied in areas overlying karst
geology which is common throughout the Southeast. 

Growers in this region also face root-knot nematodes and the fungal
pathogens described above as key pests. Left uncontrolled, any of these
pests could completely destroy the harvests from affected areas. 
Halosulfuron, which is effective against nutsedges, can be applied only
in row middles, but cannot be applied in raised beds, where nutsedge
competition is critical (Florida CUE #03-0054).

Metam-sodium offers erratic, inconsistent control of nutsedges and
nematodes, while 1,3-D + chloropicrin provides adequate control of
nematodes and diseases (Eger 2000, Noling et al. 2000).  However,
metam-sodium has yield losses of up to 44 percent compared to MB where
weed infestations are moderate to severe (Locascio et al. 1997). 
Metam-sodium also creates a planting delay as long as 30 days to avoid
risk of phytotoxic injury to crops compared to a 14-day delay for MB.
Further, due to regulatory restrictions resulting from groundwater
contamination concerns, 1,3-D + chloropicrin cannot be used in large
portions of the southeastern U.S. due to the presence of karst geology.
There is up to a 28-day planting delay (vs. 14 days for MB) due to
regulatory restrictions for 1,3-D + chloropicrin also.  Any apparent
technical feasibility of metam-sodium and 1,3 D + chloropicrin (and
various combinations thereof) are based on small plot research trials
that done on crops other than eggplant.  For fungi and nutsedge pests at
least, no on-farm, large scale trials have yet been done.  In a recent
small-plot field study conducted in Tifton, Georgia by Culpepper and
Langston (2004) on peppers, 1,3-D + chloropicrin,  followed by more
chloropicrin, was more effective than MB against yellow nutsedge, but
less effective against purple nutsedge.  Although this treatment
performed as well as MB in terms of spring pepper yield, its fall yield
performance was inferior to that of MB.  

In a second treatment, 1,3-D by itself, followed by chloropicrin, was
significantly less effective than  methyl bromide for the control of
both purple and yellow nutsedge, but as effective as MB for the control
soil nematodes.  In terms of spring and fall pepper yield, however, this
treatment performed as well as MB.  In a third treatment, 1,3-D +
chloropicrin, followed by metam sodium, was as effective as MB against
yellow nutsedge, 36% less effective than MB against purple nutsedge, and
as effective as MB for the control of soil nematodes.  This treatment
also performed as well as MB in terms of both spring and fall pepper
yield. It must be noted that nutsedge pressure in this study was
relatively low and populations were composed primarily of yellow
nutsedge, as opposed to the hardier purple nutsedge. Also, even this
promising study did not use eggplants as a test crop system.

Thus, although these MB alternatives show some promise, they will
require further testing and larger-scale validation.

Some researchers have also reported that these MB alternatives are
degraded more rapidly in areas where they are applied repeatedly due to
enhanced metabolism by soil microorganisms. This phenomenon may
compromise long-term efficacy of these compounds and appears to need
further scientific scrutiny.

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

Implications of MB loss for individual growers

If MB were to be removed as a pest control option for U.S. eggplant, the
particular growers in each region cited in this nomination would have to
stop crop production or suffer substantial losses. These growers would
either leave agriculture entirely or switch to other crops that do not
rely on pre-plant fumigation for soil pest control. The extent of this
impact on the affected growers is debatable, but given the current
embryonic state of commercial deployment of MB alternatives, it is
possible that growers who currently treat their land routinely with MB
would face this outcome. 

Table A.1: Executive Summary for eggplant*  TC "Table A.1: Executive
Summary" \f F \l "1"  

Region	Florida	Georgia	Michigan

Amount of Applicant Request

2008     Kilograms	108,862	48,868	3,799

Amount of Nomination

2008      Kilograms	53,307	22,017	3,788

* See Appendix A for a complete description of how the nominated amount
was calculated.

6. Summarize Why Key Alternatives Are Not Feasible  TC "6. Summarize
Why Key Alternatives Are Not Feasible" \f C \l "2"  :



In Florida and Georgia, where weeds, especially nutsedge, are the main
methyl bromide target pests neither 1,3-D nor metam sodium, alone or in
combination with chloropicrin, adequately control moderate to high
nutsedge populations.  In Florida and, to a lesser extent in Georgia,
the use of 1,3-D is prohibited in areas overlying karst geology because
of groundwater contamination concerns.  It is estimated that 40% of the
Florida’s production area overlies karst geology.  The 1,3-D label
prohibits its use in Dade County, Florida.  Moreover, for Florida and
Georgia farmers, using products containing 1,3-D and metam sodium in the
fall may be impractical because of the required longer waiting periods
for planting following application, 28 days for 1,3-D and 21 days for
metam sodium, compared to 14 days for methyl bromide.  Such delays could
cause Florida and Georgia growers to miss part of the key market
windows.  

In Michigan, where soil-borne pathogens are the key methyl bromide
target pests, neither 1,3-D nor metam sodium is effective against
soil-borne fungi.  Furthermore, the 28 and 21 day planting delays for
1,3-D and metam sodium, respectively, might disrupt this state’s
carefully-timed planting and harvesting schedules, causing growers to
miss part of the market windows.  The 1,3-D + chloropicrin combination
may be as effective as methyl bromide against soil-borne pathogens. 
However, the 21-day planting delay would hinder grower adoption of this
alternative. 

7. (i) Proportion of Crops Grown Using Methyl Bromide  TC "7. Proportion
of Crops Grown Using Methyl Bromide" \f C \l "2"  



Table 7.1: Proportion of Crops Grown Using Methyl Bromide*  TC "Table
7.1: Proportion of Crops Grown Using Methyl Bromide" \f F \l "1"  

Region where Methyl Bromide use is requested	Total crop area 2001-2002
Average (ha)	Proportion of total crop area treated with methyl bromide
(%)

Florida	647	100

Georgia	539	60%

Michigan	Not available	Not available

National Total*	2197	51

* Includes States not requesting MB

7. (ii) If only part of the crop area is treated with methyl bromide,
indicate the reason why methyl bromide is not used in the other area,
and identify what alternative strategies are used to control the target
pathogens and weeds without methyl bromide there.



In Georgia, areas are not treated with MB only when they do not have
nutsedges or nematodes naturally present in eggplant fields. Simple
absence of all pests is the only reason these areas are not presently
treated with MB.  In Michigan, areas not treated apparently do not have
any infestation (i.e., zero oospores or chlamydospores per unit soil) of
the key fungal pests. The applicant states that soil infestation is
spreading in the region annually.

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?



Growers have the option to use halosulfuron only in row middles.

8. Amount of Methyl Bromide Requested for Critical Use  TC "8. Amount of
Methyl Bromide Requested for Critical Use" \f C \l "2"   



Florida - Table 8.1: Amount of Methyl Bromide Requested for Critical Use
 TC "Florida - Table 8.1: Amount of Methyl Bromide Requested for
Critical Use" \f F \l "1"  

Region	Florida	Georgia	michigan

Year of Exemption Request	2008	2008	2008

Kilograms of Methyl Bromide	108,862	48,868	3,799

Use: Flat Fumigation or Strip/Bed Treatment	Strip Bed	Predominantly
Strip Bed	Predominantly Strip Bed

Formulation to be used for the CUE	67:33	67:33	67:33 or 50:50

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	647	325	32

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of methyl bromide	16.8	15.0	12.0

*Predominately strip/bed treatment 

9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity
Nominated for Each Region:  TC "9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region" \f C \l "2"
 

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

The percent of regional hectares in the applicant’s request was
divided by the total area planted in that crop in the region covered by
the request.  Values greater than 100 percent are due to the inclusion
of additional varieties in the applicant’s request that were not
included in the USDA National Agricultural Statistics Service surveys of
the crop.  

Hectares counted in more than one application or rotated within one year
of an application to a crop that also uses methyl bromide were
subtracted.  There was no double counting in this sector. 

 Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.  The applicant 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. 

Florida- Part B: Crop Characteristics and Methyl Bromide Use  TC
"Florida - Part B: Crop Characteristics and Methyl Bromide Use" \f F \l
"1"    TC "Florida - Part B: Crop Characteristics and Methyl Bromide
Use" \f C \l "1"  



Florida - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request



Florida - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "Florida - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Target  pests (weeds,
plant-parasitic nematodes) and pathogens

	Specific reasons why methyl bromide is needed 



Florida	Purple and yellow nutsedge (Cyperus rotundus & C. esculentus),
root-knot nematodes (Meloidogyne spp.), nightshade (Solanum spp.),
southern blight (Sclerotium rolfsii), white clover (Trifolium repens)
Methyl bromide is the only fumigant that consistently controls key
target weeds affecting eggplant in Florida.  Neither 1,3-D nor metam
sodium is effective under high nutsedge population pressures.  1,3-D
cannot be applied in areas overlying karst geology (about 40% of the
production area in Florida).  



Florida - 11. (i) Characteristics of Cropping System and Climate  TC "
Florida - 11. Characteristics of Cropping System and Climate" \f C \l
"2"  



Florida - Table 11.1: Characteristics of Cropping System  TC " Florida -
Table 11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Florida

Crop Type: 	Vegetable crop for fresh market

Annual or Perennial Crop: 	Annual

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Peppers, cucurbits

Soil Types:  	Sandy and sandy-loam soils

Frequency of methyl bromide Fumigation:	Annually

Other relevant factors:	Double-cropped with cucurbit; may be preceded by
pepper.



Florida - Table 11.2:  Characteristics of Climate and Eggplant Crop
Schedule: Not Double-cropped  TC " Florida - Table 11.2: Characteristics
of Climate and Eggplant Crop Schedule Not Double-Cropped" \f F \l "1"  

	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	Zones: 9a, 10a, 10b - In 1997, 80% of the state’s
eggplant production was in the southeast; remainder of about 20%
distributed in the rest of the state, mostly in the central and northern
regions.

Rainfall (mm)	65.5	50.0	72.5	134.1	175.8	193.3	152.7	65.0	42.7	158.8
62.0	66.8

Outside Temp.((C)	19.4	22.1 	25.3	27.6	28.2	28.2	27.3	24.1	19.2	17.3
16.0	16.9

Fumigation Schedule;A



X	X	X	X	X	X	X	X

	Planting ScheduleB



	E	E	E	E	E	E	E	E

Key Harvest Window;C	E	E	E	E	E



E	E	E	E

ANon-double cropped, earliest start date: June 15.

B For Non-Double cropped eggplant production, planting eggplants is
usually initiated around July 1; shaded cells represent variation in
transplanting dates 

CFor Non-Double Cropped Eggplants; Harvest Period usually begins as
early as Nov. 1, may continue until July 31, depending on when planted
and weather conditions.

Florida - Table 11.3: Characteristics of Climate and Eggplant Crop
Schedule; Double-cropped  TC "Florida - Table 11.3 Characteristics of
Climate and Eggplant Crop Schedule; Double Cropped" \f F \l "1"  

	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	Zones 9a, 10a, 10b - In 1997, 80% of the state’s
eggplant production was in the southeast; remainder of about 20%
distributed in the rest of the state, mostly in the central and northern
regions.

Rainfall (mm)	65.5	50.0	72.5	134.1	175.8	193.3	152.7	65.0	42.7	158.8
62.0	66.8

Outside Temp.((C)	19.4	22.1 	25.3	27.6	28.2	28.2	27.3	24.1	19.2	17.3
16.0	16.9

Fumigation ScheduleA



X	X	X	X





	Planting  ScheduleB



	E	E	E	E



2C

Key harvest WindowF	E	E	2C	2C	2C



E	E	E	E

A Double-cropped; assumed to be with cucurbits; earliest start date is
June 15.

B For Double-Cropped eggplant production, planting  (E) is typically
initiated on July 1; variance can be until October 1.  The second crop
of cucurbits transplants would typically be initiated around Feb 1, and
may vary until end of Feb, or 1st part of March.

C For Double Cropped Eggplants, Harvest Period usually begins as early
as Nov. 15  (E), may continue until April 15, depending on when planted
and weather conditions; Harvesting of second crop (2C) may start around
May 1 and continue until mid-July 

Florida – 11. (ii) Indicate if any of the above characteristics in 11.
(i) prevent the uptake of any relevant alternatives?



The karst geology prevalent in Florida and, to a lesser extent, Georgia
severely limits the use of 1,3-D in those States.  There are no atypical
characteristics identified in the nomination which might prevent the
utility of Devrinol( (napromide) and trifluralin for nutsedge control
and for control of broad-leaved weed species, such as morningglory. 
Halosulfuron, however has several label limitations (e.g., reduced
effectiveness if rain events follow within 4 hours of application), and
plant-back restrictions (0 to 36 months) (U.S. EPA, CUN 2003/050).

Florida - 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested  TC
"Florida - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested"
\f C \l "2"   



Florida - Table 12.1 Historic Pattern of Use of Methyl Bromide  TC
"Florida - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F \l
"1"  

For as many years as possible as shown specify:	1999	2000	2001	2002	2003
2004

Area Treated (hectares)	809	728	728	728	647	647

Amount of methyl bromide active ingredient used (total kilograms)
127,384	114,646	114,623	114,623	101,888 	100,284 

formulations of methyl bromide 

 MB /chloropicrin)	67:33 or 98:2	67:33 or 98:2	67:33 or 98:2	67:33 or
98:2	67:33 or 98:2	67:33 or 98:2

Method by which methyl bromide applied 	Mostly injected 25-30 cm depth
Mostly injected 25-30 cm depth	Mostly injected 25-30 cm depth	Mostly
injected 25-30 cm depth	Mostly injected 25-30 cm depth	Mostly injected
25-30 cm depth

Actual dosage rate for the active ingredient (g/m2)*	15.7	15.7	15.7	15.7
15.7	15.5



Florida - Part C: Technical Validation  TC "Florida - Part C: Technical
Validation" \f F \l "1"    TC "Florida - Part C: Technical Validation"
\f C \l "1"  



Florida - 13. Reason for Alternatives Not Being Feasible  TC "Florida -
13. Reason for Alternatives Not Being Feasible" \f C \l "2"  



Florida – Table 13.1: Reason for Alternatives Not Being Feasible  TC
"Florida – Table 13.1: Reason for Alternatives Not Being Feasible" \f
F \l "1"  

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 –D (Telone()	Limestone solution channels potentially leading to
groundwater (karst geology) underlies a portion of FL production areas. 
Label restriction states that these products cannot be used where karst
geology exists, estimated to be about 40% in 2002 for eggplant area;
Telone is not labeled for use in Dade County.	No

Halosulfuron	Registered for use on eggplant (Dec. 2002, US EPA, Aug.
2003); use restricted to the row middle only; potential crop injury;
severe plant back restrictions from 3 to 36 months for most vegetables;
severe restrictions when used in pest management strategy that includes
soil-applied organophosphates. 	No 

Metam-sodium (Vapam()	Does not work under high pest pressure.  Limited
niche as a complementary treatment with other fumigants and herbicides,
never stand alone (Noling, 2003).  Considered as best available
alternative for Dade County only (Aerts, 2003).	No

Napromide (Devrinol()	Weak in terms of nutsedge efficacy; does not
control established weeds (CUE 03-0017); waste of money (Noling, 2003).
No

Trifluralin	Aids in control of annual grasses; does not manage broadleaf
weeds. May cause excessive crop stress leading to reductions in stands
and yields.	No

Non Chemical Alternatives

Solarization 	Weed density (yellow and purple nutsedge was greater in
the solarized treatments compared to the methyl bromide treatment. 
Worked for the 1st year in FL peppers; if pest threshold is low
(Chellemi, et al., 1997) 	No

Myrothecium verrucaria(Ditera()	Biological nematicide; registered on
broad range of crops, field efficacy is untested	No

Combinations of Alternatives

1,3-D + chloropicrin  (Telone II or Telone C-35) + Devrinol  +
trifluralin	Strategy involves applying 1,3-D Flat Fumigation, followed
by chloropicrin 3-4 wks post fumigation + both herbicides before laying
plastic.  Chloropicrin may not be efficacious in managing white mold
(Sclerotium rolfsii).   Producers in Dade County are prohibited from
using Telone products.  	Yes, except for areas with underlying karst
geology.

Solarization + 1,3-D	May work in areas with low weed, pest or disease
pressure.  Eliminated root galling and high density of root-knot
nematodes.  

(Chellemi, D.O., et al. 1997. Application of soil solarization to Fall
Production of cucurbits and pepper. Proc. Fla. State Hort. 110:333-336.)
No

Solarization + biocontrol fungus, Gliocladium virens	Ristaino, J.B.,
Perry, K.B. and R. D. Lumsden. 1996. Soil solarization and Gliocladium
virens reduce the incidence of southern blight (Sclerotium rolfsii) in
bell pepper in the field.  Biocon.Sci. and Tech. 6:583-593.	No

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.

Florida - 14. List and Discuss Why Registered (and Potential) Pesticides
and Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC "Florida - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:" \f C \l "2"  



Florida – Table 14.1: Technically Infeasible Alternatives Discussion 
TC "Florida – Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"  

Name of Alternative	Discussion

None	Other than options discussed elsewhere, no alternatives exist for
the control of the key pests when they are present in the soil and/ or
afflict the below ground portions of eggplants.



Florida - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives  TC "Florida - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives" \f C \l "2"  :



Florida – Table 15.1: Present Registration Status of Alternatives  TC
"Florida – Table 15.1: Present Registration Status of Alternatives" \f
F \l "1"  

Name of Alternative	Present Registration Status

	Registration being considered by national authorities? (Y/N)	Date of
possible future registration:

Iodomethane	Pre-plant soil fumigant. Not registered yet.	Yes	Unknown

Trifloxysulfuron sodium	Herbicide. Registration pending ONLY in tomato,
FL only.  Crop Injury issues exist.	Yes	Unknown

Fosthiazate	OP nematicide.  Not registered. 	Yes 	Unknown

Furfural (Multigard()	Not registered.	Yes	Unknown

Sodium azide	Not registered.  Registration application not yet
submitted.	No	Unknown

Propargyl bromide	Not registered.  Registration application not yet
submitted.	No	Unknown

Paecilomyces lilacinus 	 Biological nematicide.  Registration pending.
Yes	Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



Florida - 16. State Relative Effectiveness of Relevant Alternatives
Compared to Methyl Bromide for the Specific Key Target Pests and Weeds
for which It Is Being Requested  TC "Florida - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested"
\f C \l "2"  : 



florida – Table C.1: Alternatives Yield Loss Data Summary  TC "Florida
 – Table C.1: Alternatives Yield Loss Data Summary" \f F \l "1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3 D + chloropicrin	Nutsedges, fungal pathogens	0-40 %

(0 % would be possible only in lightly infested areas; these areas are
not included in this request for MB)	29 % (Locascio et al., 1997)

Metam-sodium (with or without chloropicrin)	Nutsedges, fungal pathogens
0-66 %

(0 % would be possible only in lightly infested areas; these areas are
not included in this request for MB)	44 % (Locascio et al., 1997)

Overall Loss Estimate for All Alternatives to Pests	29 % where 1,3 D can
be used; 44 % where only metam sodium can be used



Data (narrative only) and information are bridged for eggplants from the
best available information (Locascio et al. 1997).  

Locascio et al. (1997) studied MB alternatives on tomatoes grown in
small plots at two Florida locations.  Various treatments were tested on
plots that had multiple pests.  At the Bradenton site there was moderate
to heavy Fusarium infestation; heavy purple nutsedge infestation and
light root-knot nematode pressure.  At Gainesville there was heavy
infestation of yellow and purple nutsedge and moderate infestation of
root-knot nematode.  The treatments at both locations included MB (67%)
+ chloropicrin (33%) chisel-injected at 390 kg/ha; metam-sodium
(chisel-injected) at 300L/ha; metam-sodium drip-irrigated at 300L/ha;
and 1,3-D + 17% chloropicrin chisel-injected at 327L/ha.  In pairwise
statistical comparisons, the yield was significantly lower in
metam-sodium treatments compared to MB at both sites.  At Bradenton, the
average yield from both metam-sodium treatments was 33% of the MB
yields, suggesting a 67% yield loss from not using MB.  At Gainesville,
the average yield of the two metam-sodium treatments was 56% of the MB
yield, suggesting a 44% yield loss from not using MB.  The yield of the
1,3-D treatment at Gainesville was 71% of the MB standard suggesting a
29% loss by not using MB (yield data for 1,3-D were not reported for
Bradenton).  In considering 1,3 D results, one must keep in mind that
this MB alternative cannot be used in areas where karst geology exists. 

An additional study on some alternative fumigants was performed in 2004
by Culpepper and Langston in Tifton, Georgia. A summary is presented
both in the sections discussing Georgia and in the “Summary of
technical feasibility” section for Florida (below). While the results
were promising, this trial was not used as the basis for yield loss
estimates primarily because nutsedge pressure was relatively low and 
weed populations did not contain many purple nutsedge plants. Reliable
control of these weeds (which are arguably hardier than yellow nutsedge)
would have to be demonstrated before such a study could be used to
revise yield losses.

Table 16.1.  Fumigant Alternatives to Methyl Bromide for
Polyethylene-Mulched Tomato (Locascio et al. 1997  TC "Table 16.1. 
Fumigant Alternatives to Methyl Bromide for Polyethylene-Mulched Tomato
(Locascio et al., 1997" \f F \l "1"  )

Chemicals	Rate (/ha)	Average Nutsedge Density (#/m2)	Average Marketable
Yield

(ton/ha)	% Yield Loss (compared to MB)

Untreated (control)	-	300 ab	20.1 a	59.1

MB + Pic (67-33), chisel-injected	390 kg	 90 c	49.1 b	---

1,3 D + Pic (83-17), chisel-injected	327 l	340 a	34.6 c	29.5

Metam Na, Flat Fumigation	300 l	320 a	22.6 a	54.0

Metam Na, drip irrigated	300 l	220 b	32.3 c	34.2

Notes:  	(1) Numbers followed by the same letter (within a column) are
not significantly different at the 0.05 level of probability, using
Duncan’s multiple range test.

(2) Data shown are from the Gainesville/Horticultural Unit site, 1994
season (this was one of three sites included in this study). This site
had relatively high nutsedge pressure, and data for both pest pressure
and marketable yields for all treatments shown.

Yield loss estimates could likely be lower for growers who can legally
use 1,3-D products.  For example, evidence from one tomato and bell
pepper grower using Telone II on 30 percent of his total area suggests
that average yields declined 6.16 % across all fields, while average
yield declines were 15.77 % in side-by-side plantings (FFVA, 2002).  The
standard deviation on these yields did not change, which resulted in an
increase in the coefficient of variation from 32.7 percent on fields
planted to methyl bromide to 38.3 percent on fields planted to Telone
II.  These results suggest that alternatives to methyl bromide reduce
yields by as much as 15.7 % and that risk associated with yield
variability would likewise increase. 

Florida - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"Florida - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"  :



Iodomethane is under consideration for potential methyl bromide
replacement.  Although it is currently being considered for registration
by regulatory authorities, it is unknown when it will be registered. 
Please refer to Table 15.1.

Florida - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?:  TC "Florida - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?" \f C \l "2"   



The U. S. Government is presently unaware of large scale, commercial
greenhouse operations for eggplants.  It might be expected, however that
there are local (or small community) operations of organic eggplant
production that target fresh market and/or temporal (seasonal) sectors. 

Florida - Summary of Technical Feasibility  TC "Florida - Summary of
Technical Feasibility" \f C \l "2"  



In Florida neither 1,3-D nor metam sodium, alone or in combination with
chloropicrin, adequately control moderate to high nutsedge populations. 
In addition, 1,3-D cannot be applied in areas overlying karst geology,
estimated to be 40% of the production area in the State.  Furthermore,
using products containing 1,3-D and metam sodium in the fall would mean
longer waiting periods for planting following application, 28 days for
1,3-D and 21 days for metam sodium, compared to 14 days for methyl
bromide.  Such delays may cause Florida growers to miss part of the key
market windows.  

The top priority of control associated with each major segment of pest
management across Florida eggplant production regions remained weeds,
especially the nutsedges, because of the lack of registered herbicides
that do not cause crop injury, or have severe plant-back restrictions. 
When nutsedge pressure is moderate to severe, the 1,3-D + chloropicrin
combination is not technically feasible because it needs to be coupled
with an effective herbicide to provide control for the entire growing
season (U.S. EPA, 2002).  There are no herbicides which control nutsedge
in the crop row.  Paraquat and glyphosate will suppress emerged
nutsedge, but cannot be used in the crop row because of potential crop
injury (SE Pepper Consortium CUE 02-0041).  

In the study reported in Item 16 (Table 16.1 ), 1,3-D + chloropicrin
treatments did not adequately control moderate to high nutsedge
populations, and yield losses occurred when compared to MB plus
chloropicrin treatments.  Additional research on this alternative to
improve efficacy against nutsedge is needed in areas with moderate to
high nutsedge pressure.  Lack of an effective, registered herbicide
impairs adoption in crops such as eggplant (Banks, 2002). 

Culpepper and Langston (2004) recently compared the effectiveness of
several soil fumigants in managing soil pests affecting peppers in
Tifton, Georgia.  Eggplants were not used as a test crop, so here,
again, data from peppers are used to “bridge” a discussion. Results
show that 1,3-D followed by chloropicrin was significantly less
effective than  methyl bromide for the control of both purple and yellow
nutsedge, but as effective as MB for the control soil nematodes.  In
terms of spring and fall crop yield, this treatment performed as well as
MB.  1,3-D + chloropicrin,  followed by more chloropicrin was more
effective than MB for the control of yellow nutsedge, but less effective
against purple nutsedge.  This treatment performed as well as MB in
terms of spring crop yield, but poorly in terms of fall yield.  1,3-D +
chloropicrin, followed by metam sodium was 36% less effective than 
methyl bromide for the control of purple nutsedge, but as effective as
MB for the control of yellow nutsedge.  This combination was as
effective as MB against soil nematodes.  In terms of spring and fall
crop yield, this treatment performed as well as MB.  This suggests that
these treatments are showing promise and will require further testing
and validation in commercial fields. However, it should also be noted
that nutsedge populations were relatively low and predominantly composed
of yellow nutsedge, which may be easier to control than purple nutsedge.


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

Nematode pests, such as the root knot nematode species of Meloidogyne,
were third to weed pests in terms of priority of pest management
strategies in Florida eggplant production.  Pre-plant control of
nematodes is critical since nematode root feeding and damage may
predispose plant tissues to invasion by fungal pathogens, potentially
leading to wilt, loss of plant vigor, and significant yield losses. 
Fumigant alternatives such as metam-sodium have proven inconsistent
(Noling, 2003; FFVA, 2002).

Approximately 40 percent of the eggplant production area in Florida has
karst geology.  Because it is illegal for producers to use 1,3-D
products (Telone II, Telone C-35) on these soils, growers would likely
use a combination of metam-sodium + a herbicide, such as halosulfuron or
napropamide.  

Georgia - Part B: Crop Characteristics and Methyl Bromide Use  TC
"Georgia - Part B: Crop Characteristics and Methyl Bromide Use" \f F \l
"1"    TC "Georgia - Part B: Crop Characteristics and Methyl Bromide
Use" \f C \l "1"  



Georgia - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request  TC " Georgia - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request" \f C \l "2"  



Georgia - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "Georgia - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Target  pests (weeds,
plant-parasitic nematodes) and pathogens

	Specific reasons why methyl bromide needed 



Georgia	1. Yellow and Purple Nutsedge  (Cyperus esculentus, C. rotundus)
[100%]

2.  Crown and Root rot (Phytophthora capsici) [40%]

3. Plant-parasitic nematodes (Meloidogyne incognita; Pratylenchus sp)
[70%]

4. Southern Blight (Sclerotium rolfsii) [70%]

5. Pythium root and collar rots (P. irregulare, P. myriotylum, P.
ultimum, P. aphanidermatum) [100%]	

Registered alternatives are not as effective as methyl bromide.  Methyl
bromide is needed for timely management of targeted pests and pathogens.
 Using products containing 1,3-D and metam sodium in the fall is
impractical because of the long waiting periods for planting following
application under plastic mulch. For 1,3-D there is a 28 day waiting
period; for metam sodium, there is a 21-day waiting period.  Such delays
could cause growers to miss part of the higher market windows.



Georgia - 11. (i) Characteristics of Cropping System and Climate  TC "
Georgia - 11. Characteristics of Cropping System and Climate" \f C \l
"2"  



Georgia - Table 11.1: Characteristics of Cropping System  TC " Georgia -
Table 11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Georgia

Crop Type: 	Vegetable crop for the fresh market

Annual or Perennial Crop: 	Annual; generally 1 year

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation:	Eggplants, followed by a cucurbit crop (cucumbers, or squash)
or pepper.  

Soil Types:	Sandy loam; clay loam

Frequency of methyl bromide Fumigation:	1 time per year; (either in
spring or fall)

Other relevant factors:	The grower may complete two, three or even four
crops in one fumigation cycle.



Georgia - Table 11.2 Characteristics of Climate and Crop Schedule  TC
"Georgia - Table 11.2 Characteristics of Climate and Crop Schedule" \f F
\l "1"  

	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone

“plant hardiness zone”	Climate zones 7a, 7b, 8a, and 8b noted in the
application.  

Zone 7a: -15.0 to –17.7  (C (0 to 5 (F): Oklahoma City, OK; South
Boston, VA

Zone 7b: -12.3 to 14.9   (C  (5 to 10  (F); Griffin, GA

Zone 8a: -9.5 to -12.2  ( C  (10 to 15 (F); Tifton, GA

Zone 8b: -6.7 to –9.4   (C (15 to 20  (F); Austin, TX; Gainesville, FL

Portions of GA fall into all four of these zones.

Soil Temp. ((C) 	17.8	22.5	27.1	29.9	31.0	30.4	27.9	23.3	12.2	12.2	10.6
13.1

Rainfall (mm)	127	97	89	114	142	122	86	58	58	114	114	107

ambient Temp. ((C) 	21.0	25.4	29.3	31.9	32.6	32.5	30.7	26.3	21.0	17.3
16.4	17.8

Fumigation ScheduleA



	((







	Planting 

ScheduleA,B	((



((







	Key  harvest (Market) WindowA,B

	(

(

	(	(



	Shaded areas represent typical duration of activity.  Darker shaded
areas represent duration of activities for the second crop.

A Methyl bromide applied either in the spring or fall allows the grower
to economically produce at least two crops (sometimes 3 or 4), the
second crop usually cucumbers, from one fumigation event. 

BTwo crops are represented from one fumigation event.

(= initiation of fumigation or planting and/or harvest of first crop; (
= termination of fumigation or planting and/or harvest of first crop.  (
= initiation of planting and/or harvest of second crop; ( = termination
of planting and/or harvest of second crop.

Georgia – 11. (ii) Indicate if any of the above characteristics in 11.
(i) prevent the uptake of any relevant alternatives?



Nearly all of the vegetable production occurs on Coastal Plain Soils,
which are subject to high temperatures and excess heat.  In addition to
weed pests, soil-borne fungal pathogens and plant-parasitic nematodes
are endemic to the region and nearly all production areas have severe
infestations, thereby necessitating annual treatment with a soil
fumigant.   

Georgia - 12. Historic Pattern of Use of Methyl Bromide on Eggplants,
and/or Mixtures Containing Methyl Bromide, for which an Exemption Is
Requested  TC "Georgia - 12. Historic Pattern of Use of Methyl Bromide,
and/or Mixtures Containing Methyl Bromide, for which an Exemption Is
Requested" \f C \l "2"   



Georgia - Table 12.1 Historic Pattern of Use of Methyl Bromide on
Eggplants  TC "Georgia - Table 12.1 Historic Pattern of Use of Methyl
Bromide" \f F \l "1"  

For as many years as possible as shown specify:	1999	2000	2001	2002	2003
2004

Area Treated (hectares)	251	333	315	321	346	291

Amount of methyl bromide active ingredient used 

(total kilograms)	47,723	50,023	47,288	48,139	51,968	43,763

formulations of methyl bromide 	98:2 (15% of area )

67:33 (85% of area)	67:33	67:33	67:33	67:33	67:33

Methods by which methyl bromide applied 	Injected, 20.3 to 30.5 cm,
under tarp	Injected, 20.3 to 30.5 cm, under tarp	Injected, 20.3 to 30.5
cm, under tarp	Injected, 20.3 to 30.5 cm, under tarp	Injected, 20.3 to
30.5 cm, under tarp	Injected, 20.3 to 30.5 cm, under tarp

Actual dosage rate for the active ingredient (g/m2)*	19.1	15.0	15.0	15.0
15.0	15.0



Georgia - Part C: Technical Validation  TC "Georgia - Part C: Technical
Validation" \f F \l "1"    TC "Georgia - Part C: Technical Validation"
\f C \l "1"  



Georgia - 13. Reason for Alternatives Not Being Feasible  TC "Georgia -
13. Reason for Alternatives Not Being Feasible" \f C \l "2"   



Georgia – Table 13.1: Reason for Alternatives Not Being Feasible  TC
"Georgia – Table 13.1: Reason for Alternatives Not Being Feasible" \f
F \l "1"  

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 products (includes Telone II, Telone EC, & Telone C-35)

	Products will not adequately control nutsedge.  Label restriction
states that these products cannot be used where karst geology exists
(~8% of the production area).  Up to 2 applications of Telone II,
in-line, or EC formulations may be needed to manage moderate to severe
pest population levels.  Also, there is a 28-day waiting period at the
time of application until planting, which could cause loss of over half
of the harvest season and the higher-end market windows to be missed. 
These are plantings made in July and harvested in the fall (Georgia CUE
# 03-0049; Kelley, 2003).  This only applies to light to moderate
infestations and only with Telone C-35.	No

Metam-sodium	Product does not adequately control nutsedge.  Also, there
is a 21-day waiting period at the time of application until planting
(40% of harvest season missed), which may cause part of the higher-end
market windows to be missed.  These are plantings made in July and
harvested in the fall.  Beginning the application cycle earlier is not
an option, since crops from the previous fumigation cycle must be
terminated and cleaned up prior to metam application (Georgia CUE #
03-0049; Kelley, 2003).  Repeated applications of MITC (the breakdown
product of metam sodium) are known to enhance its biodegradation as a
result of adapted microorganisms (Duncan and Yates, 2003).	No

Halosulfuron	Registered for specific uses in eggplant (Dec. 2002, US
EPA, Aug. 2003); application for eggplant is for ROW MIDDLE application
and would not provide control of nutsedge in the eggplant bed; potential
crop injury; severe plant back restrictions from 3 to 36 months for most
vegetables. 	No

Combinations of Alternatives ---

1. 1,3-D products and a herbicide, e.g. napropamide

2. Metam-sodium and a herbicide, e.g. napropamide

3. Iodomethane and a herbicide, e.g. napropamide

4. Glyphosate treatment of plots between the first and second crops
(Webster, et al. 2001)  

5.  Pest-resistant cultivars combined with alternative fumigant
strategies 1, 2, and 3

	Currently, there are no data to substantiate transition toward a
suitable alternative to annual methyl bromide fumigation.  Alternative
chemicals and cultural practices that are under consideration include
various combinations of currently registered and unregistered fumigants
and/or herbicides.   

Iodomethane is not registered in the U.S.  Please refer to Table 15.

	No

1,3 dichloropropene  followed by chloropicrin	Culpepper and Langston
(2004) have tested the effectiveness of several soil fumigant
combinations for the management of nutsedges and nematodes affecting
peppers in Tifton, Georgia.  Results show that 1,3-D followed by
chloropicrin was significantly less effective than MB for the control of
both purple and yellow nutsedge, but as effective as MB for the control
soil nematodes.  In terms of spring and fall crop yield, however, this
combination performed as well as MB.  This treatment is promising and
will require further testing and validation in commercial fields.   
Yes, except for areas with underlying karst geology

1,3 dichloropropene + chloropicrin (Telone C35) followed by chloropicrin
Culpepper and Langston (2004) have tested the effectiveness of several
soil fumigant combinations for the management of nutsedges and nematodes
affecting peppers in Tifton, Georgia.  In this study, 1,3-D +
chloropicrin,  followed by more chloropicrin was more effective than MB
for the control of yellow nutsedge, but less effective against purple
nutsedge.  This treatment performed as well as MB in terms of spring
crop yield, but poorly in terms of fall yield.  This combination does
not appear to show promise as a MB alternative.    	No

1,3 dichloropropene + chloropicrin (Telone C35) followed by metam sodium
	Culpepper and Langston (2004) have tested the effectiveness of several
soil fumigant combinations for the management of nutsedges and nematodes
affecting peppers in Tifton, Georgia.  In this study, 1,3-D +
chloropicrin, followed by metam sodium was 36% less effective than MB
for the control of purple nutsedge, but as effective as MB for the
control of yellow nutsedge and soil nematodes.  In terms of spring and
fall crop yield, this treatment performed as well as MB.  This
combination is promising and will require further testing and validation
in commercial fields.     	No, but shows promise

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.

Georgia - 14. List and Discuss Why Registered (and Potential) Pesticides
and Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC "Georgia - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:" \f C \l "2"  



Georgia – Table 14.1: Technically Infeasible Alternatives Discussion 
TC "Georgia – Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"  

Name of Alternative	Discussion

None	Other than options discussed elsewhere, no alternatives exist for
the control of the key pests when they are present in the soil and/ or
afflict the below ground portions of eggplants.



The U.S. EPA only considered those technically feasible registered
alternatives which are relevant for managing severe pathogen and pest
pressures.  

Paraquat and glyphosate will suppress emerged nutsedge, but cannot be
used in the crop row because of potential crop injury (SE Pepper
Consortium CUE for 2004).  

Fumigation of products containing 1,3-D and metam sodium (Vapam and/or
K-pam) in the summer or fall is practically impossible because of the
waiting periods for planting following application under plastic mulch.
For 1,3-D there is a 28-day waiting period; for metam sodium, there is a
21-day waiting period.  Such delays may cause reduction in yields and
market windows missed.  Thus, since the fall crop is dependent upon
timely planting, a long waiting period (e.g., 28 days) would cost
growers at least half of the harvest season, thereby missing the higher
market windows (Kelley, 2003).

Georgia - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives  TC "Georgia - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives" \f C \l "2"  :



Georgia – Table 15.1: Present Registration Status of Alternatives  TC
"Georgia – Table 15.1: Present Registration Status of Alternatives" \f
F \l "1"  

Name of Alternative	Present Registration Status

	Registration being considered by national authorities? (Y/N)	Date of
possible future registration:

Iodomethane	Not registered	Yes	Unknown

Fosthiazate	Not registered.	Yes	Unknown

Furfural (Multigard()	Not registered	Yes	Unknown

Sodium azide	Not registered.  Registration application not yet
submitted.	No	Unknown

Propargyl bromide	Not registered.  Registration application not yet
submitted.	No	Unknown

Paecilomyces lilacinus	Not registered. Registration pending.	Yes	Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



Georgia - 16. State Relative Effectiveness of Relevant Alternatives
Compared to Methyl Bromide for the Specific Key Target Pests and Weeds
for which It Is Being Requested  TC "Georgia - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested"
\f C \l "2"  



Georgia – Table C.1: Alternatives Yield Loss Data Summary  TC "
Southeastern USA except Georgia – Table C.1: Alternatives Yield Loss
Data Summary" \f F \l "1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

1,3 D + chloropicrin	Nutsedges	0-40 %

(0 % would be possible only in lightly infested areas; these areas are
not included in this request for MB)	29 % (Locascio et al., 1997)

Metam-sodium (with or without chloropicrin)	Nutsedges	0-66 %

(0 % would be possible only in lightly infested areas; these areas are
not included in this request for MB)	44 % (Locascio et al., 1997)

Overall Loss Estimate for All Alternatives to Pests	29 % where 1,3 D can
be used; 44 % where only metam sodium can be used



Data (narrative only) and information are bridged for eggplants from the
best available information.

Locascio et al. (1997) studied MB alternatives on tomatoes grown in
small plots at two Florida locations.  Various treatments were tested on
plots that had multiple pests (Table 16.1).  At the Bradenton site there
was moderate to heavy Fusarium infestation; heavy purple nutsedge
infestation and light root-knot nematode pressure.  At Gainesville there
was heavy infestation of yellow and purple nutsedge and moderate
infestation of root-knot nematode.  The treatments at both locations
included MB (67%) + chloropicrin (33%) chisel-injected at 390 kg/ha;
metam-sodium (chisel-injected) at 300L/ha; metam-sodium drip-irrigated
at 300L/ha; and 1,3-D + 17% chloropicrin chisel-injected at 327L/ha.  In
pairwise statistical comparisons, the yield was significantly lower in
metam-sodium treatments compared to MB at both sites.  At Bradenton, the
average yield from both metam-sodium treatments was 33% of the MB
yields, suggesting a 67% yield loss from not using MB.  At Gainesville,
the average yield of the two metam-sodium treatments was 56% of the MB
yield, suggesting a 44% yield loss from not using MB.  The yield of the
1,3-D treatment at Gainesville was 71% of the MB standard suggesting a
29% loss by not using MB (yield data for 1,3-D were not reported for
Bradenton).  In considering 1,3 D results, one must keep in mind that
this MB alternative cannot be used in areas where karst geology exists. 

An additional study on some alternative fumigants was performed in 2004
by Culpepper and Langston in Tifton, Georgia. A summary is presented in
the “Summary of Technical Feasibility” section for Georgia (below).
While the results were promising, this trial was not used as the basis
for yield loss estimates primarily because nutsedge pressure was
relatively low and  weed populations did not contain many purple
nutsedge plants. Reliable control of these weeds (which are arguably
hardier than yellow nutsedge) would have to be demonstrated before such
a study could be used to revise yield losses.

Table 16.1.  Fumigant Alternatives to Methyl Bromide for
Polyethylene-Mulched Tomato (Locascio et al. 1997  TC "Table 16.1. 
Fumigant Alternatives to Methyl Bromide for Polyethylene-Mulched Tomato
(Locascio et al., 1997" \f F \l "1"  )

Chemicals	Rate (/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

(ton/ha)	% Yield Loss (compared to MB)

Untreated (control)	-	300 ab	20.1 a	59.1

MB + Pic (67-33), chisel-injected	390 kg	 90 c	49.1 b	---

1,3 D + Pic (83-17), chisel-injected	327 l	340 a	34.6 c	29.5

Metam Na, Flat Fumigation	300 l	320 a	22.6 a	54.0

Metam Na, drip irrigated	300 l	220 b	32.3 c	34.2

Notes:  (1) Numbers followed by the same letter (within a column) are
not significantly different at the 0.05    

                   level of probability, using Duncan’s multiple range
test.

             (2) Data shown are from the Gainesville/Horticultural Unit
site, 1994 season (this was one of three

    sites included in this study). This site had relatively high
nutsedge pressure, and data for both

    pest pressure and marketable yields for all treatments shown.

Georgia - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"Georgia - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"  



Iodomethane is under consideration for potential methyl bromide
replacement.   Although it is currently being considered for
registration by regulatory authorities, it is currently unknown when it
will be registered.  Please refer to Table 15.1.

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

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

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

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

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

Georgia - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?  TC "Georgia - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?" \f C \l "2"  



No.  Any organic production of eggplants is presumed insignificant and
probably not cost-effective because of the intensive management of pests
(for organic production) and the long growing season.  

Georgia - Summary of Technical Feasibility  TC "Georgia - Summary of
Technical Feasibility" \f C \l "2"  

Neither 1,3-D nor metam sodium, alone or in combination with
chloropicrin, adequately control moderate to high nutsedge populations
in Georgia.  In addition, 1,3-D cannot be applied in areas overlying
karst geology (~ 8 % of the eggplant area; CUE #03-0050).  Furthermore,
using products containing 1,3-D and metam sodium in the fall is
impractical because of the required long waiting periods for planting
following application, 28 days for 1,3-D and 21 days for metam sodium. 
Such delays would cost Georgia farmers at least half of the harvest
season, thereby missing key market windows.  

In studies on peppers (Csinos et al. 1999, Noling et al. 2000), 1,3-D +
chloropicrin treatments did not adequately control moderate to high
nutsedge populations, and yield losses occurred when compared to MB plus
chloropicrin treatments.  Additional research on this alternative to
demonstrate efficacy against nutsedge is needed in areas with moderate
to high nutsedge pressure, considered to be approximately 58% of the
current eggplant production area (Culpepper, 2004).  Lack of an
effective, registered herbicide impairs adoption in crops such as pepper
(Banks, 2002), and probably other high value vegetable crops for the
fresh market (Monks, Southeast Peppers Consortium, CUE 03-0041).

Culpepper and Langston (2004) recently compared the effectiveness of
several soil fumigants in managing soil pests affecting peppers in
Tifton, Georgia.  Eggplants were not used as a test crop, so here,
again, data from peppers are used to “bridge” a discussion. Results
show that 1,3-D followed by chloropicrin was significantly less
effective than  methyl bromide for the control of both purple and yellow
nutsedge, but as effective as MB for the control soil nematodes.  In
terms of spring and fall crop yield, this treatment performed as well as
MB.  1,3-D + chloropicrin, followed by more chloropicrin was more
effective than MB for the control of yellow nutsedge, but less effective
against purple nutsedge.  This treatment performed as well as MB in
terms of spring crop yield, but poorly in terms of fall yield.  1,3-D +
chloropicrin, followed by metam sodium was 36% less effective than
methyl bromide for the control of purple nutsedge, but as effective as
MB for the control of yellow nutsedge.  This combination was as
effective as MB against soil nematodes.  In terms of spring and fall
crop yield, this treatment performed as well as MB.  This suggests that
these treatments are showing promise and will require further testing
and validation in commercial fields. However, it should also be noted
that nutsedge populations were relatively low and predominantly composed
of yellow nutsedge, which may be easier to control than purple nutsedge.


Nematode pests, such as the root knot nematode species of Meloidogyne,
were third to nutsedge and fungal pathogens in terms of priority of pest
management strategies in Georgia eggplant production.  Pre-plant control
of nematodes is critical since nematode root feeding and damage may
predispose plant tissues to invasion by fungal pathogens, potentially
leading to wilt, loss of plant vigor, and significant yield losses. 
Fumigant alternatives such as metam-sodium have proven inconsistent
(Noling, 2003; FFVA, 2002).

Diseases caused by soil-borne plant pathogenic fungi, (e.g.,
Phytophthora spp., Pythium spp. and Sclerotium rolfsii) may be curtailed
if weather conditions are detrimental for disease development.  These
pathogens are endemic in many vegetable production areas in Georgia. 
Fungicides such as chlorothalonil, and azoxystrobilurin are considered
to be only prophylactic, and may not offer sufficient pest management. 
Resistance of Phytophthora spp to metalaxyl and mefenoxam (Ridomil and
Ridomil Gold, respectively) has been reported in tomato crop areas, and
most recently pepper (Lamour and Hausbeck, 2003)

The use of products containing 1,3-D and metam sodium in the fall is
impractical because of the long waiting periods for planting following
application under plastic mulch. For 1,3-D there is a 28 day waiting
period; for metam sodium, there is a 21-day waiting period.  Such delays
would cost growers at least half of the harvest season, thereby missing
the higher market windows.  Thus, since the fall crop is dependent upon
timely planting, the required waiting period would cost growers at least
half of the harvest season, thereby missing the higher market windows
(Kelley, 2003).

Michigan - Part B: Crop Characteristics and Methyl Bromide Use  TC
"Michigan - Part B: Crop Characteristics and Methyl Bromide Use" \f F \l
"1"    TC "Michigan - Part B: Crop Characteristics and Methyl Bromide
Use" \f C \l "1"  



Michigan - 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request  TC " Michigan - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request" \f C \l "2"  



Michigan - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request  TC "Michigan - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Target  pests (weeds,
plant-parasitic nematodes) and pathogens

	Specific reasons why methyl bromide needed 



Michigan	Crown and root rots caused by Soil-borne Fungus - Phytophthora
capsici. 	Methyl bromide alone allows growers to fumigate and plant
early in order to capture the key market window (July - September) and
have their product available for premium prices, as well as ensuring
demand for their crop during the entire growing season, especially
during the mid and late season.  

The fumigation and planting schedule allow growers to maintain market
diversity, as well.



Michigan - 11. (i) Characteristics of Cropping System and Climate  TC "
Michigan - 11. Characteristics of Cropping System and Climate" \f C \l
"2"  



Michigan - Table 11.1: Characteristics of Cropping System  TC " Michigan
- Table 11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Michigan

Crop Type: 	Vegetable crop for the fresh market

Annual or Perennial Crop: 	Annual -- generally 1 year

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Rotation sequence commonly followed by a pepper or cucurbit
crop

Soil Types:  	Sandy loam, clayish loam

Frequency of methyl bromide Fumigation: 	1 time every 2 years

Other relevant factors:	Michigan’s diversified vegetable crop
production is designed to meet key late spring and summer market demands
in Midwestern states. 



Michigan - Table 11.2 Characteristics of Climate and Crop Schedule for
Eggplants  TC " Michigan - Table 11.2 Characteristics of Climate and
Crop Schedule for Eggplants" \f F \l "1"  

	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone

“plant hardiness zone”

(e.g. temperate, tropical)	Generally characterized as 5b according to
the USDA Hardiness Zone Map, with annual minimum temperature ranges
(average) as –23.4 to –26.1 (C   (-15 to –10  (F).  Example
cities: Columbia, Missouri and Mansfield, Pennsylvania. 

Soil Temp. ((C)	<10	10 - 15	15-20	20-25	20-25	20-25	20	10-15	<10	<10	<10
<10

Rainfall (mm)	40	72	101	48	47	32	17	31	36	20	6	8

Outside Temp. ((C)	0.2	7.4	12.1	17.5	20.6	20.9	18.1	8	2.4	-2.9	-8	-7

Fumigation Schedule

(-(











Planting 

Schedule

	(-(









	Key  harvest (Market) Window



	(

	(





Shaded areas represent typical duration of activity;   ( = typical
initiation of activity, ( = typical termination of activity

Michigan – 11. (ii) Indicate if any of the above characteristics in
11. (i) prevent the uptake of any relevant alternatives?



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

All fumigation practices need to be completed by the first week of May
to allow growers to plant early and capture the early market
(July-September).

Significant rainfall events (>25.4 mm) or cold soil temperatures (<4.4
(C) could delay fumigation and planting. Such cold soil temperatures
often occur in early spring (March – April) in this region (Schaetzl
and Tomczak 2001).

Lighter soil types may make drip application difficult (Cortright,
2003).

Michigan - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested 
TC "Michigan - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested"
\f C \l "2"   



Michigan’s use of methyl bromide for vegetable production has declined
steadily since the mid-1990s, when growers switched to different
application methods (i.e. from Flat Fumigation to tarped beds) and
formulations, from 98:2 to 67:33 (methyl bromide:chloropicrin).  Since
1997, all methyl bromide is applied to tarped beds, with 100% of low
density polyethylene sheeting and 95% of the area was treated with the
67:33 formulation.  Since 2000, about 5% of the area used the 50:50
methyl bromide:chloropicrin formulation.  Growers are using anti-drip
valves to eliminate loss of MB at the end of rows when the machinery is
removed from the ground. 

Please see Table 12.1 for further information.

Michigan - Table 12.1 Historic Pattern of Use of Methyl Bromide  TC
"Michigan - Table 12.1 Historic Pattern of Use of Methyl Bromide" \f F
\l "1"  

For as many years as possible as shown specify:	1999	2000	2001	2002	2003
2004

Area Treated (hectares)	24	29	32	34	32	35

Amount of methyl bromide active ingredient used

(total kg)	2,937	3,500	3,905	4,057	3,848	4,179

formulations of methyl bromide 

methyl bromide/ Chloropicrin)	67:33	67:33 or 50:50	67:33 or 50:50	67:33
or 50:50	67:33 or 50:50	67:33 or 50:50

Method by which methyl bromide applied 	Injected

20-25 cm

strip treatment	Injected

20-25 cm

strip treatment	Injected

20-25 cm

strip treatment	Injected

20-25 cm

strip treatment	Injected

20-25 cm

strip treatment	Injected

20-25 cm

strip treatment

Actual dosage rate for the active ingredient (g/m2)*	12.1	12.0 or 9.0
12.1 or 9.0	12.1 or 9.0	12.0 or 9.0	12.0 or 9.0



Michigan - Part C: Technical Validation  TC "Michigan - Part C:
Technical Validation" \f F \l "1"    TC "Michigan - Part C: Technical
Validation" \f C \l "1"  



Michigan - 13. Reason for Alternatives Not Being Feasible  TC "Michigan
- 13. Reason for Alternatives Not Being Feasible" \f C \l "2"  



Michigan – Table 13.1: Reason for Alternatives Not Being Feasible  TC
"Michigan – Table 13.1: Reason for Alternatives Not Being Feasible" \f
F \l "1"  

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-Dichloropropene (1,3-D)	Inconsistently effective against soil-borne
fungi.  

In a recent study conducted in Oceana County, Michigan by Hausbeck and
Cortright (2004), yields from pepper plots treated with
1,3-D+chloropicrin were comparable to yields from control plots and
plots treated with MB + chloropicrin. These results, while promising,
were from fumigation conducted under the optimally warm conditions of
June, and require further validation in cooler conditions and at larger
scales.  However, there is also a Federal label restriction of a 30.4 m
buffer zone between treated fields and inhabited structures, which will
reduce overall pest control in a field. 28-day waiting period for
planting may be disruptive to timely eggplant production and marketing. 
 	No

Chloropicrin	Does not distribute evenly throughout the soil profile when
used by itself, resulting in poor efficacy.  Does not control
Phytophthora capsici when used at maximum label rates. (California
Pepper Commission, CUE 02-0017; CUE03-0017)	No

Metam Sodium (or metam potassium)	Poor fumigant with erratic results and
inconsistent distribution in soil profiles; does not control
Phytophthora (California Pepper Commission, CUE 02-0017; CUE03-0017). 
Repeated applications of MITC (the breakdown product of metam sodium)
are known to enhance its biodegradation as a result of adapted
microorganisms (Duncan and Yates, 2003).  Phytotoxicity has been
reported with this fumigant.  21-day day waiting period for planting may
be disruptive to timely eggplant production and marketing.  In a recent
study conducted in Oceana County, Michigan by Hausbeck and Cortright
(2004), yields from pepper plots treated with metam potassium (K-Pam)
were comparable to yields from control plots and plots treated with MB +
chloropicrin. These results, while promising, were from fumigation
conducted under the optimally warm conditions of June, and require
further validation in cooler conditions and at larger scales.  	No

Combinations of Alternatives

1,3-D + chloropicrin (Telone C-35)

	The 28-day waiting period for planting could disrupt the eggplant
production and marketing timing.   Regulatory restrictions due to
concerns over human exposure and ground water contamination, along with
technical limitations, result in potential economic infeasibility of
this formulation as a practical MB alternative. In a recent study
conducted in Oceana County, Michigan by Hausbeck and Cortright (2004),
yields from pepper plots treated with 1,3-D+chloropicrin were comparable
to yields from control plots and plots treated with MB + chloropicrin.
These results, while promising, were from fumigation conducted under the
optimally warm conditions of June, and require further validation in
cooler conditions and at larger scales.  	No

Metam Sodium/Crop Rotation	The limitations of metam-sodium/potassium
have been discussed previously (above). As regards rotation, A 4-5 year
rotation cycle is necessary to reduce inoculum levels. The economic
threshold of Phytophthora capsici is presumed to be 1 oospore/ft2
(Michigan CUE 03-0061). Because of high land costs, very few crops are
of high enough economic value to be rotated with eggplants.  Also,
21-day day waiting period for planting after metam sodium fumigation may
be disruptive to timely eggplant production and marketing.  	No

Metam Sodium/Furfural (Multigard()	Results of a 2003 small plot field
study demonstrated practically equivalent soil pest control of targeted
pests (plot vigor) and slightly lesser yields than methyl bromide.
(Hausbeck and Cortright, 2004).  However, furfural is not yet registered
by the U.S.EPA, though it is under consideration by federal authorities.
 	Insufficient data and trials to estimate cost-effectiveness at this
time.

* Regulatory reasons include local restrictions (e.g. occupational
health and safety, local environmental regulations) and lack of
registration.

Michigan - 14. List and Discuss Why Registered (and Potential)
Pesticides and Herbicides Are Considered Not Effective as Technical
Alternatives to Methyl Bromide:  TC "Michigan - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:" \f C \l "2"  



A number of effective fungicides are available for treatment of these
fungi when they infect aerial portions of crops.  However, these
infections are not the focus of MB use, which is meant to keep newly
planted transplants free of these fungi. Potential yield losses to
Phytophthora capsici affect up to 10% of the production area, especially
if the plants are infected early in the growing season. The pest
situation is exacerbated by the widespread occurrence of indigenous
populations of P. capsici, (Michigan CUE #03-0061; Gevens and Hausbeck,
2003), significant rainfall events (greater than 254 mm) which trigger
rapid disease development (Cortright, personal communication, 2003),
metalaxyl and mefenoxam-insensitivity reported among Phytophthora  spp.
populations in several vegetable production areas (Lamour and Hausbeck,
2003; Parra and Ristaino, 1998), and planting restrictions for
registered alternative fumigants (e.g. 1,3-D + chloropicrin and
metam-sodium).  

Label-mandated planted delays of up to 30 days for the alternative
fumigants 1,3 D or metam-sodium/potassium + chloropicrin imply that, if
growers who must plant eggplant early in the season are forced to use
only these options, they would face losses of their target markets even
if pests were adequately controlled. For these growers, fumigation needs
to be completed by the first week of May to allow them to plant early
and capture the early market (July - September) in order to have their
product available for premium prices, as well as to ensure demand for
their crop during the entire growing season (especially during the mid
and late season). According to the applicant, Michigan’s diversified
vegetable crop industry is designed to meet market demands in the late
spring and through the summer for Midwestern market and therefore
requires carefully-timed planting and harvesting schedules.  The
fumigation with methyl bromide and planting schedule allow growers to
maintain market diversity, as well.  

Michigan - 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives  TC "Michigan - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives" \f C \l "2"  :



Michigan – Table 15.1: Present Registration Status of Alternatives  TC
"Michigan – Table 15.1: Present Registration Status of Alternatives"
\f F \l "1"  

Name of Alternative	Present Registration Status

	Registration being considered by national authorities? (Y/N)	Date of
possible future registration:

Iodomethane	Not registered.	Yes	unknown

Fosthiazate	OP nematicide.  Under review. 	Yes	Unknown

Furfural (Multigard()	Not registered.	Yes	Unknown

Sodium azide	Not registered.  	Yes	Unknown

Diallyl sulfide	Registered to control Sclerotinia spp. (plant-pathogenic
fungi).  Very limited and narrow spectrum of uses.  	Uses may be
expanded	Unknown

Metam sodium	Registered	Yes	Reregistration scheduled for  2005-06

Propargyl bromide	Not registered.	Yes	Unknown

Paecilomyces lilacinus	Not registered.  Registration pending.	Yes
Unknown

Muscador albus Strain QST 20799 	Registration package has been received.
Yes	Registered but not yet for sale in the U.S.



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  TC "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"
\f C \l "2"  



A field trial was conducted in small plots in 2004 in Michigan by
Hausbeck and Cortright (2004) of Michigan State University.  This study
examined a number of vegetable crops including eggplant.  Results,
submitted with their 2004 CUE request, indicated that 1,3 D + 35 %
chloropicrin treatments (shank-injected at 56.7 liters/ha) showed an
average of 44% yield loss compared to MB (due to both Phytophthora and
Fusarium combined).  Chloropicrin alone (shank-injected at 233.6 l/ha)
showed an average 15.5% loss compared to MB. Metam-potassium +
chloropicrin showed yields similar to those seen with MB. Metam-sodium
was not tested, but can reasonably be assumed to be equivalent to
metam-potassium (since the active ingredient is identical).  Methyl
iodide (currently unregistered for eggplant) with 33% chloropicrin
(shank-injected, at 36.8 kg/ha, respectively), also showed yields
similar to that of MB.  It should be noted that even large differences
in average yields across various treatments were often not statistically
significant, suggesting that there was high variability in the data.
Thus far, no new data have been generated to complement this work,
though further research is planned (see Section 17 below).

In studies with other vegetable crops, 1, 3 D + chloropicrin has
generally shown better control of fungi than metam-sodium formulations
(though still not as good as control with MB).  For example, in a study
using a bell pepper/squash rotation in small plots, Webster et al.
(2001) found significantly lower fungal populations with 1,3 D + 35 %
chloropicrin (drip applied, 146 kg/ha of 1,3 D), as compared to the
untreated control.  However, MB (440 kg/ha, shank-injected) reduced
fungal populations even more.  It should be noted that P. capsici was
not present in test plots, though Fusarium spp. were.  Methyl iodide had
no significant suppressive effect, as compared to the untreated control.
 However, neither of these MB alternatives increased squash fruit weight
significantly over the untreated control.  Indeed, as compared to the MB
standard treatment plots, squash fruit weight was 63 % lower in the 1,3
D plots, and 41 % lower in the methyl iodide plots.  The proportion of
marketable squash fruit (defined only as those fruit so bad as to have
to be discarded) in the 1,3 D plots was 30 % lower than that in the MB
plots, although in the methyl iodide plots it was equivalent to MB. In
another study, conducted on tomatoes, Gilreath et al. (1994) found that
metam-sodium treatments did not match MB in terms of plant vigor at the
end of the season; again, Fusarium (but not P. capsici) was one of
several pests present. 

Taken together, these studies indicate that, while the recent trials in
Michigan are promising for the use of metam-sodium/potassium +
chloropicrin, there is still great inconsistency in efficacy and
protection from yield losses. However, the Michigan trials were
conducted in the warm conditions of June, so growers cannot be confident
that similar results would be seen if fumigation were done in the cooler
conditions of springtime in this region. Further, no large scale field
trials have yet been performed to demonstrate reliable, consistent pest
control similar to that of MB in the cucurbit growing regions of
Michigan. Given the highly variable results with this MB alternative,
EPA decided that the best case yield loss scenario would be a level
similar to what was assessed in the 2003 Critical Use Nomination.  Hence
Table C.1 and the associated economic loss analyses (Part E) are based
on the level used in that Nomination.

Michigan – Table C.1: Alternatives Yield Loss Data Summary  TC "
Michigan – Table C.1: Alternatives Yield Loss Data Summary" \f F \l
"1"  

Alternative	List Type of Pest	Range of Yield Loss	Best Estimate of Yield
Loss

Metam-sodium/potassium + chloropicrin	Soil borne fungal diseases	Under
cold soil conditions (below 10o C) this alternative cannot be used due
to label restrictions. However, under warmer soil temperatures (typical
of June or later) we anticipate no yield losses (based on results from
Hausbeck and Cortright 2004), but there is potentially a 2 week planting
delay as per label restrictions.	For plantings done in cold conditions,
losses are incurred due to regulatory constraints.

Overall Loss Estimate for All Alternatives to Pests	Regulatory
constraints



Michigan - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?  TC
"Michigan - 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"   (If so, please specify.)



The critical use exemption applicant states that 1,3 D + chloropicrin,
metam-sodium, furfural, propylene oxide, and sodium azide will continue
to be the subjects of field studies of utilization and efficacy
enhancement where Phytophthora is the target pest. It should be kept in
mind that furfural, propylene oxide, and sodium azide are currently
unregistered for use on eggplants, and there are presently no commercial
entities pursuing registration in the U.S.  The regulatory restrictions
on 1,3 D discussed elsewhere will also remain as negative influences on
the economics of this MB alternative.  The timeline for developing the
above-mentioned MB alternatives in Michigan (by Michigan State
University) is as follows: 

2003 – 2005: Test for efficacy (particularly against the more
prevalent Phytophthora fungi)

2005 – 2007: Establish on-farm demonstration plots for effective MB
alternatives

2008 – 2010: Work with growers to implement widespread commercial use
of effective alternatives.

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

Michigan - 18. Are There Technologies Being Used to Produce the Crop
which Avoid the Need for Methyl Bromide?  TC "Michigan - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?" \f C \l "2"  



The Agency is presently unaware of large scale, commercial greenhouse
operations for eggplants. It might be expected, however that there are
local (or small community) operations of both organic and hothouse
eggplant production that target fresh market, and/or temporal (seasonal)
sectors, e.g., farmers’ markets.  Large-scale production is probably
not cost-effective, because of the intensive management of pests and the
long growing season for eggplants.

Michigan - Summary of Technical Feasibility  TC "Michigan - Summary of
Technical Feasibility" \f C \l "2"  



The U.S. EPA has determined that only metam-potassium (or metam-sodium)
with chloropicrin has some technical feasibility against the key pest of
eggplants in this region.  1,3 D + chloropicrin, which has shown promise
against these pests in trials in other regions and crops, did not
provide control comparable to MB in new tests conducted in Michigan in
2003.  Metam sodium/potassium has also been inconsistent across
different studies, and no large-plot studies have been performed to show
commercial feasibility in eggplants (e.g., Martin 2003, Hausbeck and
Cortright, 2004; Csinos et al., 1999).  Important technical and
regulatory constraints on both 1,3 D and metam-sodium/potassium
formulations must also be considered: a 21 – 30 day planting delay,
mandatory 100 foot buffers (for 1,3 D) near inhabited structures –
both of which will cause negative economic impacts, and potentially
lower dissipation (and thus efficacy) in the cool soils of this region. 

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

There are currently no non-chemical alternatives that are currently
viable for MB replacement for commercial eggplant growers.  In sum,
while the potential exists for a combination of chemical and
non-chemical alternatives to replace MB use in Michigan eggplants,
analysis of ongoing research will help determine the timeline of
transition from MB to alternatives.

Part D: Emission Control  TC "Part D: Emission Control" \f F \l "1"   
TC "Part D: Emission Control" \f C \l "1"  



19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use
and Emissions in the Particular Use  TC "19. Techniques That Have and
Will Be Used to Minimize Methyl Bromide Use and Emissions in the
Particular Use" \f C \l "2"  :



Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions  TC
"Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions" \f
F \l "1"  

Technique or Step Taken	VIF or High Barrier Films	methyl bromide dosage
reduction	Increased % chloropicrin in methyl bromide formulation	Less
frequent application

What use/emission reduction methods are presently adopted?	Currently
some growers use HDPE tarps.	Growers have switched from a 98% MB
formulation to a 67 % formulation. Between 1997 and 2001, the US has
achieved a 36 % reduction in use rates. 	From 2 % to 33 % 	No

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Research is underway to develop use in
commercial production systems 	Research is underway to develop use of a
50 % MB formulation in Michigan commercial production systems. Not known
if other regions are planning similar work.	Research is underway to
develop use of a 50 % MB formulation in Michigan commercial production
systems. Not known if other regions are planning similar work.	The US
anticipates that the decreasing supply of methyl bromide will motivate
growers to try less frequent applications.

Other measures 	Examination of promising but presently unregistered
alternative fumigants and herbicides, alone or in combination with
non-chemical methods, is planned in all regions (Please see Section 17
for each region for details)	Measures adopted in Michigan will likely be
used in the other regions when fungi are the only key pests involved
Measures adopted in Michigan will likely be used in the other regions
when fungi are the only key pests involved	Unknown



20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used,
or Are Not Planned for the Circumstances of the Nomination, State
Reasons  TC "20. If Methyl Bromide Emission Reduction Techniques Are Not
Being Used, or Are Not Planned for the Circumstances of the Nomination,
State Reasons" \f C \l "2"  



  SEQ CHAPTER \h \r 1 In accordance with the criteria of the critical
use exemption, each party is required to describe ways in which it
strives to minimize use and emissions of MB.  The use of MB in the
growing of eggplant in the U.S. 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 U.S.  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
eggplant is most often machine injected into soil to specific depths.  

As MB has become scarcer, users in the U.S. have, where possible,
experimented with different mixes of methyl bromide and chloropicrin. 
Specifically, in the early 1990s, MB was typically sold and used in
mixtures made up of 98% MB and 2% chloropicrin, with the chloropicrin
being included solely to give the chemical a smell enabling those in the
area to be alerted if there was a risk.  However, with the outset of
very significant controls on methyl bromide, users have been
experimenting with significant increases in the level of chloropicrin
and reductions in the level of MB.  While these new mixtures have
generally been effective at controlling target pests, at low to moderate
levels of infestation, it must be stressed that the long term efficacy
of these mixtures is unknown.  

	

Tarpaulin (high density polyethylene) is also used to minimize use and
emissions of MB.  In addition, cultural practices are utilized by
eggplant growers.

Reduced MB 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.  

Part E: Economic Assessment  TC "Part E: Economic Assessment" \f F \l
"1"    TC "Part E: Economic Assessment" \f C \l "1"  



Economic data from the 2005 submission for all applicants were not
substantially different from those in 2004 (greater or less than a 10%
change in costs and revenue).  Given these insignificant differences,
the economic analyses were not updated for any applicants other than
Michigan, which was updated to reflect a change in the requested pounds
of MeBr.

The economic assessment is organized by MeBr critical use application. 
Cost of MeBr and alternatives are given first in table 21.1.  This is
followed in table 22.1 by a listing of net and gross revenues by
applicant.  Expected losses when using MeBr alternatives are then
further decomposed in tables E1 through 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. Operating Costs of Alternatives Compared to Methyl Bromide Over
3-Year Period  TC "21. Operating Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period" \f C \l "2"  :



Table 21.1: Eggplant – Operating Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period  TC "Table 21.1: Eggplant –
Operating Costs of Alternatives Compared to Methyl Bromide Over 3-Year
Period" \f F \l "1"  

Alternative	Yield*	Cost in year 1 (US$/ha)	Cost in year 2 (US$/ha)	Cost
in year 3 (US$/ha)

Florida

Methyl Bromide	100%	$15,322	$15,322	$15,322

1,3-D + Chloropicrin	71%	$14,272	$14,272	$14,272

Metam-Sodium	56%	$13,557	$13,557	$13,557

Georgia

Methyl Bromide	100%	$32,365	$32,365	$32,365

1,3-D + Chloropicrin	71%	$27,530	$27,530	$27,530

Metam-Sodium	56%	$24,493	$24,493	$24,493

Michigan

Methyl Bromide	100%	$23,598	$23,598	$23,598

1,3-D + Chloropicrin	94%	$23,185	$23,185	$23,185

* 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  TC "22. Gross and Net Revenue" \f C \l "2"  :



Table 22.1: Eggplant – Year 1, 2, and 3 Gross and Net Revenues   TC
"Table 22.1: Eggplant - Year 1, 2, and 3 Gross and Net Revenues" \f F \l
"1"  

Year 1, 2, and 3

Alternatives 

(as shown in question 21)	Gross revenue for last reported year

(US$/ha)	Net Revenue for last reported year 

(US$/ha)

Florida

Methyl Bromide	$21,730	$6,408

1,3-D + Chloropicrin	$15,428	$1,156

Metam-Sodium	$12,169	$(1,388)

Georgia



Methyl Bromide	$42,857	$10,491

1,3-D + Chloropicrin	$30,428	$2,899

Metam-Sodium	$24,000	$(493)

Michigan

Methyl Bromide	$34,074	$10,476

1,3-D + Chloropicrin	$29,627	$6,442

Note: Year 1 equals year 2 and 3.

Measures of Economic Impacts of Methyl Bromide Alternatives  TC
"Measures of Economic Impacts of Methyl Bromide Alternatives" \f C \l
"2"  

 

Florida Eggplant - Table E.1: Economic Impacts of Methyl Bromide
Alternatives  TC "Florida Eggplant - Table E.1: Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"  

florida eggplant	Methyl Bromide	1,3-D + Chloropicrin	Metam-Sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	1,893	1,344	1,060

* Price per Unit (us$)	$11	$11	$11

= Gross Revenue per Hectare (us$)	$21,730	$15,428	$12,169

- Operating Costs per Hectare (us$)	$15,322	$14,272	$13,557

= Net Revenue per Hectare (us$)	$6,408	$1,156	$(1,388)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$5,252	$7,796

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$35	$52

3. Loss as a Percentage of Gross Revenue (%)	0%	24%	36%

4. Loss as a Percentage of Net Revenue (%)	0%	82%	122%

5. Profit Margin (%)	29%	7%	-11%



Georgia Eggplant - Table E.2: Economic Impacts of Methyl Bromide
Alternatives  TC “Georgia Eggplant – Table E.2: Economic Impacts of
Methyl Bromide Alternatives” \f F \l “1”  

Georgia eggplant	Methyl Bromide	1,3-D + Chloropicrin	Metam-Sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	6,326	4,491	3,542

* Price per Unit (us$)	$7	$7	$7

= Gross Revenue per Hectare (us$)	$42,857	$30,428	$24,000

- Operating Costs per Hectare (us$)	$32,365	$27,530	$24,493

= Net Revenue per Hectare (us$)	$10,491	$2,899	$(493)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$7,593	$10,985

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$51	$73

3. Loss as a Percentage of Gross Revenue (%)	0%	18%	26%

4. Loss as a Percentage of Net Revenue (%)	0%	72%	105%

5. Profit Margin (%)	24%	10%	-2%



Michigan Eggplant- Table E.3: Economic Impacts of Methyl Bromide
Alternatives  TC "Michigan Eggplant - Table E.3: Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"  

michigan eggplant	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	3,665	3,445

* Price per Unit (us$)	$9	$8.60

= Gross Revenue per Hectare (us$)	$34,074	$29,627

- Operating Costs per Hectare (us$)	$23,598	$23,185

= Net Revenue per Hectare (us$)	$10,476	$6,442



1. Loss per Hectare (us$)	$0	$4,034

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$34

3. Loss as a Percentage of Gross Revenue (%)	0%	12%

4. Loss as a Percentage of Net Revenue (%)	0%	39%

5. Profit Margin (%)	31%	22%



Summary of Economic Feasibility  TC "Summary of Economic Feasibility" \f
C \l "2"  



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

Michigan

The US concludes that, at present, no economically feasible alternatives
to MeBr exist for use in Michigan eggplant production.  Yield losses and
missed market windows are the factors that have proven most important in
this conclusion, which are discussed individually below. 

1. Yield Loss

The US anticipates yield losses of 6% throughout Michigan eggplant
production.  

2. Missed Market Windows

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

The analysis of this effect is based on the fact that prices farmers
receive for their eggplants 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 eggplants 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, eggplant growers manage their
production systems with the goal of harvesting the largest possible
quantity of eggplants when the prices are at their highs.  The ability
to sell produce at these higher prices makes a significant contribution
toward the profitability of eggplant operations.

Specific data representing these market fluctuations are not available
for Michigan eggplant.  However, because of the similar production
system and growing conditions, Michigan pepper price data was used to
represent price fluctuations in Michigan eggplant and their impact on
growers’ gross revenues.  Though data availability is limiting, it was
assumed that if eggplant growers adjust the timing of their production
system, as required when using 1,3-D + chloropicrin, that they will,
over the course of the growing season, receive gross revenues reduced by
approximately 7.5%.  The season average price was reduced by 7.5% in
analysis of the alternatives to reflect this.  Based on currently
available information, the US believes this reduction in gross revenues
serves as a reasonable indicator of the typical effect of planting
delays resulting when MeBr alternatives are used in Michigan eggplant
production.

Florida

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

Florida’s application for MeBr critical use indicated that more than
one crop is typically grown per growing season but did not provide
specific production and sales data for this crop.  As a result of this
gap in data, economic assessment of Florida eggplant production was
based on a single crop production system.  This characterization of
growing conditions could result in the critical need for MeBr appearing
smaller than it actually is, because the value the second crop derives
from methyl bromide is not included in the analysis.

Other potentially significant economic factors, such as price reductions
due to missed market windows, were not analyzed for this region, as the
case for critical use of MeBr is sufficiently strong based solely on
yield loss.

Georgia

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

Other potentially significant economic factors, such as price reductions
due to missed market windows, were not analyzed for this region, as the
case for critical use of MeBr is sufficiently strong based solely on
yield loss.

Part F. Future Plans  TC "Part F. Future Plans" \f F \l "1"    TC "Part
F. Future Plans" \f C \l "1"  



23. What Actions Will Be Taken to Rapidly Develop and Deploy
Alternatives for This Crop?  TC "23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?" \f C \l "2"  



Since 1997, the U.S. 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 USDA/EPA Methyl Bromide
Alternatives Work Group since 1993 to help coordinate research,
development and the registration of viable alternatives.  This
coordination has resulted in key registration issues (such as worker and
bystander exposure through volatilization, township caps and drinking
water concerns) being directly addressed through USDA’s Agricultural
Research Service’s U.S.$15 million per year research program conducted
at more than 20 field evaluation facilities across the country.  Also
EPA’s participation in the evaluation of research grant proposals each
year for USDA’s U.S.$2.5 million per year methyl bromide alternatives
research has further ensured close coordination between the U.S.
government and the research community.

The amount of methyl bromide requested for research purposes is
considered critical for the development of effective alternatives. 
Without methyl bromide for use as a standard treatment, the research
studies can never address the comparative performance of alternatives. 
This would be a serious impediment to the development of alternative
strategies.  The U.S. government estimates that eggplant research will
require 433 kg per year of methyl bromide for 2005 and 2006.  This
amount of methyl bromide is necessary to conduct research on
alternatives and is in addition to the amounts requested in the
submitted CUE applications.  One example of the research is a field
study testing the comparative performance of methyl bromide, host
resistance, cultural practices, pest management approaches for control
of 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?  TC "24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?" \f C \l "2"   



For further details regarding the transition plans for this sector
please consult the national management strategy.

25. Additional Comments on the Nomination?  TC "25. Additional Comments
on the Nomination" \f C \l "2"  



26. Citations  TC "26. Citations" \f C \l "2"  



Aerts, M. 2003. Asst. Director, Environmental and Pest Management
Division, Florida Fruit and Vegetable Association.  Personal
Communication with G. Tomimatsu, December 2, 	2003.

Banks, H. J.  2002.  2002 Report of the Methyl Bromide Technical Options
Committee, 2002 Assessment.  Pg 46.

Chellemi, D.O., R. C. Hochmuth, T. Winsberg, W. Guetler, K. D. Shuler,
L. E. Datnoff, D. T. Kaplan, R. McSorley, R. A. Dunn, and S. M. Olson.
1997. Application of soil solarization to fall production of cucurbits
and pepper. Proc. Fla. State Hort. Soc. 10:333-	336.

Cortright, B. 2003.  Field Research Associate University of Michigan. 
Personal Communication with G. Tomimatsu, November 24, 2003.

Cortright, B.D. and M.K. Hausbeck. 2004. Evaluation of fumigants for
managing Phytophthora crown and fruit rot of solanaceous and cucurbit
crops, plot two, 2003.  Unpublished study (MI CUE # 03-0061).

Csinos, A.S., D.R. Sumner, R.M. McPherson, C. Dowler, C.W. Johnson, and
A.W. Johnson. 1999. Alternatives for methyl bromide fumigation of
tobacco seed beds, pepper, and tomato seedlings.  Proc. Georgia Veg.
Conf. Available on the Web at
http://www.tifton.uga.edu/veg/Publications/Gfvga99.pdf

Duncan, R. S. and S. R. Yates. 2003. Degradation of fumigant pesticides:
1,3-Dichloropropene, Methyl isothiocyanate, chloropicrin, and methyl
bromide.  Vadose Zone Journal 2:279-286.

Florida Fruit and Vegetable Association (FFVA).  2002. Application for
the Methyl Bromide Critical Use Exemption on Solanaceous Crops (other
than tomato).  September 9, 2002.

Frank, J.R., P. H. Schwartz and W.E. Potts. 1992. Modeling the effects
of weed interference periods and insects on bell peppers (Capsicum
annuum). Weed Sci. 40:308-312.

Gevens, A.J. and M.K. Hausbeck. 2003. A first report of Phytophthora
capsici in irrigating water near cucurbit fields in Michigan (Abstr).

Kelley, W. T. 2003, Professor, University of Georgia. Personal
communication with G. Tomimatsu, November 24, 2003.

Lamour, K. H.  and M. Hausbeck.  2003.  Effect of Crop Rotation on the
survival of Phytophthora capsici in Michigan. Plant Dis. 87:841-845.

Lewis, C. 2003 (President, Hy-Yield Bromine).  Personal communication
through S.A. Toth (  HYPERLINK "mailto:steve_toth@ncsu.edu" 
steve_toth@ncsu.edu ) , Extension Entomologist & Pest Management
Information Specialist, North Carolina State University; message
forwarded electronically to G. Tomimatsu, December 29, 2003.

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

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

Noling, J.W., E. Rosskopf, and D.L. Chellemi. 2000. Impacts of
alternative fumigants on soil pest control and tomato yield. Proc.
Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions
Reductions. Available on the web at   HYPERLINK
"http://www.mbao.org/mbrpro98.html"  http://www.mbao.org/mbrpro00.html .

Stall, W.M. and J. Morales-Payan. 2000. The critical period of nutsedge
interference in tomato. S.W. Florida Research & Education Center.  
HYPERLINK "http://www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.htm"
 www.imok.ufl.edu/liv/groups/IPM/weed_con/nutsedge.htm 

USDA.  2002.  Crop Profiles: Florida Eggplant. 
http://pestdata.ncsu.edu/cropprofiles/docs/FLeggplant_.html 

U.S. EPA. 2002. Peppers-Field. Peppers Grown Outdoors on Plastic Mulch. 
CUN2003/058

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

Citations reviewed but not applicable  TC "Citations Reviewed but Not
Applicable" \f C \l "2"  



Jones, J. 2003. Regulatory Status of Soil Fumigants. Plenary Session 1. 
Presentation at the 2003 Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions, San Diego, CA.

Webster, T. M., A.S. Csinos, A.W. Johnson, C. C. Dowler, D. R. Sumner,
R. L. Fery. 2001.  Methyl bromide alternatives in a bell pepper-squash
rotation. Crop Protection 20:605-14.

APPENDIX A.  2008 Methyl Bromide Usage Newer Numerical Index (BUNNI).

  TC "APPENDIX A.  2008 Methyl Bromide Usage Newer Numerical Index
(BUNNI)." \f F \l "1"  

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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.

Strip Bed Treatment – Strip bed treatment is ‘yes’ if the
applicant uses such treatment, no otherwise.

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.

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.

Pest-free cert. Required - This variable is a ‘yes’ when the product
must be certified as ‘pest-free’ in order to be sold

Other Issues.- Other issues is a short reminder of other elements of an
application that were checked

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.

Quarantine and Pre-Shipment Removed? – This indicates whether the
Quarantine and pre-shipment (QPS) hectares subject to QPS treatments
were removed from the nomination.

Most Likely Combined Impacts (%) – 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. 

(%) 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.

(%) 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.

(%) 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.

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.  

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.

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.

Total 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.

Most Likely Baseline Transition – Most Likely Baseline Transition
amount was determined by the DELPHI process and was calculated by
determining the maximum share of industry that can transition to
existing alternatives.

(%) Able to Transition – Maximum share of industry that can transition

Minimum # of Years Required – The minimum number of years required to
achieve maximum transition.

(%) Able to Transition per Year – The Percent Able to Transition per
Year is the percent able to transition divided by the number of years to
achieve maximum transition.

EPA Adjusted Use Rate - Use rate is the lower of requested use rate for
2008 or the historic average use rate or is determined by MBTOC
recommended use rate reductions.

EPA Adjusted Strip Dosage Rate – The dosage rate is the use rate
within the strips for strip / bed fumigation.

2008 Amount of Request – The 2008 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. 

EPA Preliminary Value – The EPA Preliminary Value is the lowest of the
requested amount from 2005 through 2008 with MBTOC accepted adjustments
(where necessary) included in the preliminary value.

EPA Baseline Adjusted Value – The EPA Baseline Adjusted Value has been
adjusted for MBTOC adjustments, QPS, Double Counting, Growth, Use Rate/
Strip Treatment, Miscellaneous adjustments, MBTOC recommended Low
Permeability Film Transition adjustment, and Combined Impacts.

EPA Transition Amount – The EPA Transition Amount is calculated by
removing previous transition amounts since transition was introduced in
2007 and removing the amount of the percent (%) Able to Transition per
Year multiplied by the EPA Baseline Adjusted Value. 

Most Likely Impact Value – The qualified amount of the initial request
after all adjustments have been made given in total kilograms of
nomination, total hectares of nomination, and final use rate of
nomination.

Sector Research Amount – The total U.S. amount of methyl bromide
needed for research purposes in each sector.

Total US Sector Nomination - Total U.S. sector nomination is the most
likely estimate of the amount needed in that sector.

 PAGE   

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U.S. Eggplant

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U.S. Eggplant

