Methyl Bromide Critical Use Nomination for Preplant Soil Use for Peppers
Grown in Open Fields on Plastic Tarpaulins

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                                   CUN:



Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Preplant Soil Use for Peppers Grown in Open Fields on
Plastic Tarpaulins (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 Division Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U.S.A.

Telephone:	(703) 308-8200

Fax:	(703) 308-8090

E-mail:	  HYPERLINK "mailto:Richard.kegwin@epa.gov" 
Richard.kegwin@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 "_Toc125780304"  Part A: Summary	 
PAGEREF _Toc125780304 \h  8  

  HYPERLINK \l "_Toc125780305"  1. Nominating Party	  PAGEREF
_Toc125780305 \h  8  

  HYPERLINK \l "_Toc125780306"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125780306 \h  8  

  HYPERLINK \l "_Toc125780307"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125780307 \h  8  

  HYPERLINK \l "_Toc125780308"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125780308 \h  8  

  HYPERLINK \l "_Toc125780309"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125780309 \h  8  

  HYPERLINK \l "_Toc125780310"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125780310 \h  11  

  HYPERLINK \l "_Toc125780311"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125780311 \h  12  

  HYPERLINK \l "_Toc125780312"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125780312 \h  13  

  HYPERLINK \l "_Toc125780313"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125780313 \h  13  

  HYPERLINK \l "_Toc125780314"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780314 \h  14  

  HYPERLINK \l "_Toc125780315"  Michigan - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc125780315 \h  14  

  HYPERLINK \l "_Toc125780316"  Michigan - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125780316 \h  14  

  HYPERLINK \l "_Toc125780317"  Michigan - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc125780317 \h  15  

  HYPERLINK \l "_Toc125780318"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125780318 \h  17  

  HYPERLINK \l "_Toc125780319"  Michigan - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125780319 \h  17  

  HYPERLINK \l "_Toc125780320"  Michigan - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125780320 \h  20  

  HYPERLINK \l "_Toc125780321"  Michigan - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125780321 \h  21  

  HYPERLINK \l "_Toc125780322"  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 _Toc125780322 \h  21  

  HYPERLINK \l "_Toc125780323"  Michigan - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125780323 \h  22  

  HYPERLINK \l "_Toc125780324"  Michigan - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125780324 \h  23  

  HYPERLINK \l "_Toc125780325"  Michigan - Summary of Technical
Feasibility	  PAGEREF _Toc125780325 \h  23  

  HYPERLINK \l "_Toc125780326"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Part B: Crop Characteristics and Methyl
Bromide Use	  PAGEREF _Toc125780326 \h  24  

  HYPERLINK \l "_Toc125780327"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 10. Key Diseases and Weeds for which
Methyl Bromide Is Requested and Specific Reasons for this Request	 
PAGEREF _Toc125780327 \h  24  

  HYPERLINK \l "_Toc125780328"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 11. Characteristics of Cropping System
and Climate	  PAGEREF _Toc125780328 \h  25  

  HYPERLINK \l "_Toc125780329"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 12. Historic Pattern of Use of Methyl
Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125780329 \h  27  

  HYPERLINK \l "_Toc125780330"  Southeast Peppers Consortium excluding
Florida and Georgia - Part C: Technical Validation	  PAGEREF
_Toc125780330 \h  28  

  HYPERLINK \l "_Toc125780331"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 13. Reason for Alternatives Not Being
Feasible	  PAGEREF _Toc125780331 \h  28  

  HYPERLINK \l "_Toc125780332"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:	  PAGEREF _Toc125780332 \h  32
 

  HYPERLINK \l "_Toc125780333"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives	  PAGEREF
_Toc125780333 \h  33  

  HYPERLINK \l "_Toc125780334"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 16. State Relative Effectiveness of
Relevant Alternatives Compared to Methyl Bromide for the Specific Key
Target Pests and Weeds for which It Is Being Requested	  PAGEREF
_Toc125780334 \h  33  

  HYPERLINK \l "_Toc125780335"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia –17.  Are There Any Other Potential
Alternatives Under Development Which Are Being Considered to Replace
Methyl Bromide?	  PAGEREF _Toc125780335 \h  35  

  HYPERLINK \l "_Toc125780336"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide?	  PAGEREF
_Toc125780336 \h  36  

  HYPERLINK \l "_Toc125780337"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia – Summary of Technical Feasibility	 
PAGEREF _Toc125780337 \h  36  

  HYPERLINK \l "_Toc125780338"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780338 \h  37  

  HYPERLINK \l "_Toc125780339"  Georgia - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc125780339 \h  37  

  HYPERLINK \l "_Toc125780340"  Georgia - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125780340 \h  38  

  HYPERLINK \l "_Toc125780341"  Georgia - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125780341 \h  40  

  HYPERLINK \l "_Toc125780342"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125780342 \h  41  

  HYPERLINK \l "_Toc125780343"  Georgia - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125780343 \h  41  

  HYPERLINK \l "_Toc125780344"  Georgia - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125780344 \h  45  

  HYPERLINK \l "_Toc125780345"  Georgia - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125780345 \h  46  

  HYPERLINK \l "_Toc125780346"  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 _Toc125780346 \h  46  

  HYPERLINK \l "_Toc125780347"  Georgia - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125780347 \h  47  

  HYPERLINK \l "_Toc125780348"  Georgia - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125780348 \h  48  

  HYPERLINK \l "_Toc125780349"  Georgia - Summary of Technical
Feasibility	  PAGEREF _Toc125780349 \h  48  

  HYPERLINK \l "_Toc125780350"  Florida - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780350 \h  49  

  HYPERLINK \l "_Toc125780351"  Florida - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc125780351 \h  49  

  HYPERLINK \l "_Toc125780352"  Florida - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125780352 \h  50  

  HYPERLINK \l "_Toc125780353"  Florida - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125780353 \h  51  

  HYPERLINK \l "_Toc125780354"  Florida - Part C: Technical Validation	 
PAGEREF _Toc125780354 \h  52  

  HYPERLINK \l "_Toc125780355"  Florida - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125780355 \h  52  

  HYPERLINK \l "_Toc125780356"  Florida - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125780356 \h  57  

  HYPERLINK \l "_Toc125780357"  Florida - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125780357 \h  58  

  HYPERLINK \l "_Toc125780358"  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 _Toc125780358 \h  58  

  HYPERLINK \l "_Toc125780359"  Florida - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125780359 \h  59  

  HYPERLINK \l "_Toc125780360"  Florida - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125780360 \h  60  

  HYPERLINK \l "_Toc125780361"  Georgia - Summary of Technical
Feasibility	  PAGEREF _Toc125780361 \h  60  

  HYPERLINK \l "_Toc125780362"  Part D: Emission Control	  PAGEREF
_Toc125780362 \h  62  

  HYPERLINK \l "_Toc125780363"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125780363 \h  62  

  HYPERLINK \l "_Toc125780364"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125780364 \h  63  

  HYPERLINK \l "_Toc125780365"  Part E: Economic Assessment	  PAGEREF
_Toc125780365 \h  63  

  HYPERLINK \l "_Toc125780366"  21. Operating Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125780366 \h
 64  

  HYPERLINK \l "_Toc125780367"  22. Gross and Net Revenue	  PAGEREF
_Toc125780367 \h  65  

  HYPERLINK \l "_Toc125780368"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125780368 \h  65  

  HYPERLINK \l "_Toc125780369"  Summary of Economic Feasibility	 
PAGEREF _Toc125780369 \h  67  

  HYPERLINK \l "_Toc125780370"  Part F. Future Plans	  PAGEREF
_Toc125780370 \h  69  

  HYPERLINK \l "_Toc125780371"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125780371 \h  69  

  HYPERLINK \l "_Toc125780372"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125780372 \h  70  

  HYPERLINK \l "_Toc125780373"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125780373 \h  70  

  HYPERLINK \l "_Toc125780374"  26. Citations	  PAGEREF _Toc125780374 \h
 72  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125780172"  Part A:
Summary	  PAGEREF _Toc125780172 \h  8  

  HYPERLINK \l "_Toc125780173"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125780173 \h  8  

  HYPERLINK \l "_Toc125780174"  Table A.1: Executive Summary	  PAGEREF
_Toc125780174 \h  11  

  HYPERLINK \l "_Toc125780175"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125780175 \h  12  

  HYPERLINK \l "_Toc125780176"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125780176 \h  13  

  HYPERLINK \l "_Toc125780177"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780177 \h  14  

  HYPERLINK \l "_Toc125780178"  Michigan - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125780178 \h 
14  

  HYPERLINK \l "_Toc125780179"  Michigan - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc125780179 \h  14  

  HYPERLINK \l "_Toc125780180"  Michigan - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125780180 \h  14  

  HYPERLINK \l "_Toc125780181"  Michigan - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125780181 \h  16  

  HYPERLINK \l "_Toc125780182"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125780182 \h  17  

  HYPERLINK \l "_Toc125780183"  Michigan – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125780183 \h  17  

  HYPERLINK \l "_Toc125780184"  Michigan – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125780184 \h  21  

  HYPERLINK \l "_Toc125780185"  Michigan – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125780185 \h  22  

  HYPERLINK \l "_Toc125780186"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Part B: Crop Characteristics and Methyl
Bromide Use	  PAGEREF _Toc125780186 \h  24  

  HYPERLINK \l "_Toc125780187"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request	  PAGEREF _Toc125780187 \h  24  

  HYPERLINK \l "_Toc125780188"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 11.1: Characteristics of Cropping
System	  PAGEREF _Toc125780188 \h  25  

  HYPERLINK \l "_Toc125780189"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 11.2 Characteristics of Climate
and Crop Schedule – January Fumigation (Spring, Early Summer Harvest)	
 PAGEREF _Toc125780189 \h  25  

  HYPERLINK \l "_Toc125780190"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 11.3 Characteristics of Climate
and Crop Schedule – Spring Fumigation (Fall Harvest)	  PAGEREF
_Toc125780190 \h  25  

  HYPERLINK \l "_Toc125780191"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 12.1 Historic Pattern of Use of
Methyl Bromide	  PAGEREF _Toc125780191 \h  27  

  HYPERLINK \l "_Toc125780192"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia  - Part C: Technical Validation	  PAGEREF
_Toc125780192 \h  28  

  HYPERLINK \l "_Toc125780193"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia –Table 13.1: Reason for Alternatives Not
Being Feasible	  PAGEREF _Toc125780193 \h  28  

  HYPERLINK \l "_Toc125780194"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia – Table 14.1: Technically Infeasible
Alternatives Discussion	  PAGEREF _Toc125780194 \h  32  

  HYPERLINK \l "_Toc125780195"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia – Table 15.1: Present Registration
Status of Alternatives for Peppers	  PAGEREF _Toc125780195 \h  33  

  HYPERLINK \l "_Toc125780196"  Southeast U.S. Peppers Consortium
excluding Florida and Georgia Table 16.1.  Fumigant Alternatives to
Methyl Bromide for Polyethylene-Mulched Tomato	  PAGEREF _Toc125780196
\h  33  

  HYPERLINK \l "_Toc125780197"  Southeast U.S. Pepper Consortium –
Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125780197
\h  34  

  HYPERLINK \l "_Toc125780198"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780198 \h  37  

  HYPERLINK \l "_Toc125780199"  Georgia - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125780199 \h 
37  

  HYPERLINK \l "_Toc125780200"  Georgia - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125780200 \h  38  

  HYPERLINK \l "_Toc125780201"  Georgia - Table 11.2 Characteristics of
Climate and Crop Schedule – July Fumigation Event, Pepper Crop is
Harvested in Fall	  PAGEREF _Toc125780201 \h  38  

  HYPERLINK \l "_Toc125780202"  Georgia - Table 11.3 Characteristics of
Climate and Crop Schedule – Spring (Late February – March)
Fumigation Event, Pepper Crop is Harvested in Early Summer	  PAGEREF
_Toc125780202 \h  39  

  HYPERLINK \l "_Toc125780203"  Georgia - Table 12.1 Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc125780203 \h  40  

  HYPERLINK \l "_Toc125780204"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125780204 \h  41  

  HYPERLINK \l "_Toc125780205"  Georgia – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125780205 \h  41  

  HYPERLINK \l "_Toc125780206"  Georgia – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125780206 \h  45  

  HYPERLINK \l "_Toc125780207"  Georgia – Table 15.1: Present
Registration Status of Alternatives for Peppers	  PAGEREF _Toc125780207
\h  46  

  HYPERLINK \l "_Toc125780208"  Georgia Table 16.1.  Fumigant
Alternatives to Methyl Bromide for Polyethylene-Mulched Tomato	  PAGEREF
_Toc125780208 \h  46  

  HYPERLINK \l "_Toc125780209"  Georgia – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125780209 \h  47  

  HYPERLINK \l "_Toc125780210"  Florida  - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125780210 \h  49  

  HYPERLINK \l "_Toc125780211"  Florida - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125780211 \h 
49  

  HYPERLINK \l "_Toc125780212"  Florida - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125780212 \h  50  

  HYPERLINK \l "_Toc125780213"  Florida - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125780213 \h  50  

  HYPERLINK \l "_Toc125780214"  Florida - Table 11.3 Characteristics of
Climate and Crop Schedule – Peppers Double Cropped with another
Vegetable Crop (usually Cucurbits)	  PAGEREF _Toc125780214 \h  51  

  HYPERLINK \l "_Toc125780215"  Florida - Table 12.1 Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc125780215 \h  52  

  HYPERLINK \l "_Toc125780216"  Florida - Part C: Technical Validation	 
PAGEREF _Toc125780216 \h  52  

  HYPERLINK \l "_Toc125780217"  Florida – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125780217 \h  52  

  HYPERLINK \l "_Toc125780218"  Florida – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125780218 \h  57  

  HYPERLINK \l "_Toc125780219"  Florida – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125780219 \h  58  

  HYPERLINK \l "_Toc125780220"  Florida - Table 16.1.  Fumigant
Alternatives to Methyl Bromide for Polyethylene-Mulched Tomato	  PAGEREF
_Toc125780220 \h  58  

  HYPERLINK \l "_Toc125780221"  Florida – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125780221 \h  59  

  HYPERLINK \l "_Toc125780222"  Part D: Emission Control	  PAGEREF
_Toc125780222 \h  62  

  HYPERLINK \l "_Toc125780223"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125780223 \h  62  

  HYPERLINK \l "_Toc125780224"  Part E: Economic Assessment	  PAGEREF
_Toc125780224 \h  63  

  HYPERLINK \l "_Toc125780225"  Table 21.1: Peppers – Operating Costs
of Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc125780225 \h  64  

  HYPERLINK \l "_Toc125780226"  Table 22.1: Peppers - Year 1, 2, and 3
Gross and Net Revenues	  PAGEREF _Toc125780226 \h  65  

  HYPERLINK \l "_Toc125780227"  Florida Pepper - Table E.1: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125780227 \h  65  

  HYPERLINK \l "_Toc125780228"  Georgia Pepper – Table E.2: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125780228 \h  66  

  HYPERLINK \l "_Toc125780229"  Michigan Pepper - Table E.3: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125780229 \h  66  

  HYPERLINK \l "_Toc125780230"  Southeastern USA (except Georgia) Pepper
- Table E.4: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125780230 \h  67  

  HYPERLINK \l "_Toc125780231"  Part F. Future Plans	  PAGEREF
_Toc125780231 \h  69  

  HYPERLINK \l "_Toc125780232"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125780232 \h  77  

 

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 Peppers
Grown in Open Fields on Plastic Tarpaulins (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"  



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



4. Methyl Bromide Nominated  TC "4. Methyl Bromide Nominated" \f C \l
"2"   



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	919,006	7,057

This amount includes 2,844 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 U.S. nomination is only for those areas where the alternatives are
not suitable.  In U.S. pepper production there are several factors that
make the potential alternatives to methyl bromide unsuitable.  These
include:

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

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

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

Potential delay in planting and harvesting: e.g., the plant-back
interval for 1,3 D + Chloropicrin may be up to two weeks longer than
methyl bromide + chloropicrin.  In Michigan an additional delay would
occur because soil temperature must be higher to fumigate with
alternatives.  Delays in planting and harvesting may result in users
missing key market windows, and adversely affect revenues through lower
prices.

Michigan, Florida, Georgia, and the Southeastern U.S. (except Georgia
and Florida) are each presented as separate regions in this nomination
to reflect the separate applications from growers in these areas. A
brief description of their need for MB follows, also presented on a
regional basis.

Michigan

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

 

Based on the small-plot trial conducted on Michigan peppers (cited
above), the best-case yield loss estimate for Michigan using the best
available MB alternative (1,3-D + chloropicrin) was estimated to be 6 %,
based on plant loss.  In a second trial undertaken by Hausbeck and
Cortright (2004), yields from pepper plots treated with metam potassium,
alone or in combination with chloropicrin, and from plots treated with
1,3-D + chloropicrin were comparable to yields from plots treated with
MB + chloropicrin and yields from untreated (control plots).  These
results Likely indicate a very low pest pressure in all treated and
control plots.  It is also unfortunate that these trials occurred later
in the growing season (June) that is not the early season (April) that
this nomination pertains to.

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

Southeastern United States (Including Florida and Georgia)

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

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

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

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

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

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

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

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

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

Region	Michigan	Southeastern U.S. except Georgia and Florida	Georgia
Florida

Requested Amount

2008   Kilograms	15,195	270,477	347,183	1,377,786

Nominated Amount

2008   Kilograms	14,208	95,237	174,128	632,587

*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"  :



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

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

 

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

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



7. (i) Proportion of Crops Grown Using Methyl Bromide  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 In 2003
(ha)	Proportion of Request For methyl bromide (%)

Michigan	816	16

Southeastern U.S. except Georgia and Florida	5,806	31

Georgia	2,899	80

Florida	7,893	104

National Total*	17,414	71

* 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 Michigan, areas not treated apparently do not have any infestation
(i.e., zero oospores per unit soil) of the key fungal pests.  Applicant
states that soil infestation is spreading in the region annually.  In
southeastern U.S., Florida, and Georgia, areas not treated do not have
nutsedges or nematodes naturally present in pepper fields. Simple
absence of all pests is the only reason these areas are not presently
treated with MB.

7. (iii) Would it be feasible to expand the use of these methods to
cover at least part of the crop that has requested use of methyl
bromide?  What changes would be necessary to enable this?

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

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



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

Region: 	Michigan 	Southeastern U.S. except Georgia and Florida 	Georgia
Florida

Year of Exemption Request	2008	2008	2008	2008

Kilograms of Methyl Bromide	15,195	270,477	347,183	1,377,786

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

Formulation to be used for the CUE (methyl bromide/chloropicrin)	67:33

or 50:50	67:33	67:33	Mostly 67:33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	127	1,801	2,312	8,195

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



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 three applicants that included growth in their request
had the growth amount removed.  

Quarantine and pre-shipment (QPS) hectares is the area in the
applicant’s request subject to QPS treatments.  Not applicable in this
sector.

Only the acreage experiencing one or more of the following impacts were
included in the nominated amount:  moderate to heavy key pest pressure,
regulatory impacts, karst geology, buffer zones, unsuitable terrain, and
cold soil temperatures. 

Michigan - Part B: Crop Characteristics and Methyl Bromide Use   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	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide is needed 



Michigan	Crown and root rots caused by soil-borne fungus Phytophthora
capsici. 

	Fumigation operations need to be completed by the first week of May to
allow growers to plant early and capture the early market for premium
prices, as well as ensuring demand for their crop during the entire
growing season (especially during the mid and late season).



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: 	Pepper transplants for fruit production 

Annual or Perennial Crop:	Annual; generally 1 year

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Pepper – usually followed by an eggplant or pepper crop

Soil Types: 	Sandy loam; clay loam

Frequency of methyl bromide Fumigation: 	1 time every 2 years

Other relevant factors:	Key marketing opportunities have been
established with Michigan’s vegetable crop diversification and aims
toward stable demands in the late spring and through the summer for
Midwestern markets.



Michigan - Table 11.2 Characteristics of Climate and Crop Schedule for
Peppers  TC " Michigan - 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	USDA Plant Hardiness zone 5b

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

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

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

Fumigation Schedule

X











Planting 

Schedule

	X









	Key  Market Window



	X	X	X	X







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



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

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

Michigan - 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested 
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"   



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

Please see Table 12.1 for further information.

Michigan  - Table 12.1 Historic Pattern of Use of Methyl Bromide on
Peppers  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)	98	117	130	135	128	139

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	No pepper area in Michigan uses flat fumigation
application.

Amount of methyl bromide active ingredient used 

(total kilograms)	11,747	14,001	15,618	16,230	15,391	16,715

formulations of methyl bromide 

(methyl bromide /chloropicrin) A	67:33	67:33	67:33 or 50:50	67:33 or
50:50	67:33 or 50:50	67:33 or 50:50

Methods by which methyl bromide applied 	Injected

20-25 cm	Injected

20-25 cm	Injected

20-25 cm	Injected

20-25 cm	Injected

20-25 cm

	Injected

20-25 cm



Dosage rate* (g/m2) for the active ingredient	12.0	12.0	12.0 or

8.9	12.0 or 8.9	12.0 or 8.9	12.0 or 8.9

A Growers have just started switching to the 50/50 formulation of
MB/Chloropicrin since 2000 (about 5% of production acreage) to reduce
cost per acre.

Michigan – Part C: Technical Validation -Peppers  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 	Is the alternative
considered cost effective

Chemical Alternatives 

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

In addition, control of the key pest is inconsistent (Locascio et al.
1997, Martin 2003).  Gilreath et al. (1994) found that metam-sodium
treatments did not match MB in terms of plant vigor at the end of the
season; P. capsici was, however, not present.  In the cool conditions of
Michigan, metam-sodium is likely to be slow to transform into the active
ingredient (methyl isothiocyanate), which also suggests that pest
control will not be as effective as with MB (Ashley et al. 1963).  In a
recent study conducted in Oceana County, Michigan by Hausbeck and
Cortright  (2004), yields from pepper plots treated with metam potassium
(K-Pam) were comparable to yields from control plots and plots treated
with MB + chloropicrin, indicating e a very low pest (P. capsici)
pressure at the test site.  	No

Non Chemical Alternatives

Soil solarization	Michigan’s climate is typically cool (often less
than 11 oC through May) and cloudy, particularly early in the growing
season when control of the key pests is especially important.  In
Michigan, the growing season is short (May to September), and the time
needed to utilize solarization is likely to render the subsequent
growing of crops impossible, even if it did somehow eliminate all fungal
pathogens.  Since solarization has shown promise in other crops and
regions (e.g., tomatoes in Florida), the potential for adoption exists
(Schneider et al. 2003). However, because of climate, solarization is
not feasible in Michigan.	No

Steam	While steam has been used effectively against fungal pests in
protected production systems, such as greenhouses, there is no evidence
that it would be effective in open field pepper crops in Michigan.  Any
such system would also require large amounts of energy and water to
provide sufficient steam necessary to sterilize soil down to the rooting
depth of field crops (at least 20-50 cm).  	No

Biological Control	Biological control agents are not technically
feasible alternatives to MB because they alone cannot control the soil
pathogens that afflict peppers in Michigan. The bacterium Burkholderiaia
cepacia and the fungus Gliocladium virens have shown some potential in
controlling some fungal plant pathogens (Larkin and Fravel 1998).
However, in a test conducted by the Michigan applicants, P. capsici was
not controlled adequately in summer squash by either of these beneficial
microorganisms.	No

Cover crops and mulching	There is no evidence these practices
effectively substitute for the control MB provides against P. capsici. 
Control of P.capsici is imperative for pepper production in Michigan. 
Plastic mulch is already in widespread use in Michigan vegetables, and
regional crop experts state that it is not an adequate protectant when
used without MB.  The longevity and resistance of P. capsici oospores
renders cover crops ineffective as a management alternative to MB.	No

Crop rotation and fallow land	The crop rotations available to growers in
Michigan region are also susceptible to these fungi, particularly to P.
capsici.  Fallow land can still harbor P. capsici oospores (Lamour and
Hausbeck 2003).  Thus fungi would persist and attack peppers if crop
rotation/fallow land was the main management regime.	No

Endophytes	Though these organisms (bacteria and fungi that grow
symbiotically or as parasites within plants) have been shown to suppress
some plant pathogens in cucumber, there is no such information for the
other pepper crops grown in Michigan.  Furthermore, the pathogens
involved did not include Phytophthora species, which are arguably the
greatest single threat to Michigan peppers.	No

Flooding/Water management	Flooding is not technically feasible as an
alternative because it does not have any suppressive effect on P.
capsici (Allen et al. 1999), and is likely to be impractical for
Michigan pepper growers.  It is unclear whether irrigation methods in
this region could be adapted to incorporate flooding or alter water
management for pepper fields.  In any case, there appears to be no
supporting evidence for its use against the hardy oospores of P.
capsici.	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	Due to the paucity of scientific
information on the utility of these alternatives as MB replacements in
peppers, they have been grouped together for discussion in this
document. There are no studies documenting the commercial availability
of resistant rootstock immune to the fungal pathogens listed as major
pepper pests.  Grafting and plant breeding are thus also rendered
technically infeasible as MB alternatives for control of Phytophthora
fungi. Soilless culture, organic production, and substrates/plug plants
are also not technically viable alternatives to MB for fungi. One of the
fungal pests listed by Michigan can spread through water (Gevens and
Hausbeck 2003), making it difficult to keep any sort of area (with or
without soil) disease free. Various aspects of organic production -
e.g., cover crops, fallow land, and steam sterilization - have already
been addressed in this document and assessed to be technically
infeasible methyl bromide alternatives.	No

Combinations of Alternatives

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

In addition, trials in tomato have shown inconsistent efficacy of this
formulation against fungal pests, though it is generally better than
metam-sodium alone (Locascio and Dickson 1998, Csinos et al. 1999).
These studies apparently did not measure yield impacts, and did not
involve peppers.  Hausbeck and Cortright  (2004) evaluated several soil
fumigants for control of P. capsici on several vegetable crops,
including peppers, in Michigan.  Results show that yields from pepper
plots treated with metam potassium + chloropicrin were comparable to
yields from control plots and from plots treated with MB + chloropicrin.
 These results point to a very low pest pressure in the study area. 
Further studies are necessary to clearly identify MB alternatives. 	No

1,3 dichloropropene + chloropicrin	Regulatory restrictions and
Michigan’s cool and wet soils may result in a delay of up to 28 days
in planting after treatment with this combination. This delay could
result in growers missing key market windows, with consequent negative
economic impacts (detailed in other sections below).  In a small plot
study conducted in Michigan by Hausbeck and Cortright  (2004) pepper
yields from plots treated with 1,3-D + chloropicrin were comparable to
yields from control plots and plots treated with MB + chloropicrin. 
These results seem to indicate a very low pest (P. capsici) pressure at
the test site.  Further studies are necessary to clearly identify MB
alternatives.  	No

1,3 dichloropropene + Metam-sodium	Trials in tomato have shown
inconsistent efficacy of this combination against fungal pests, though
it is generally better than metam-sodium alone (Csinos et al. 1999). Low
efficacy in even small-plot trials indicates that this is not a
technically feasible alternative for commercially produced peppers in
Michigan at this time. These studies apparently did not measure yield
impacts, and did not involve peppers.	No

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

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"  



Table 14.1 Technically Infeasible Alternatives Discussion.

Name of Alternative	Discussion

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



Michigan 15. List Present (and Possible Future) Registration Status of
Any Current and Potential Alternatives  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:

Methyl iodide	Not registered in the U.S. for peppers, although
registration is being pursued for tomatoes, strawberries, peppers, and
ornamental crops.	Yes	Unknown

Furfural 	Not registered in the U.S. for peppers.  Registration is
currently being pursued only for non-food greenhouse uses.	No (for
peppers)	Unknown

Sodium azide	Not registered.  No registration requests submitted to U.S.
No (for any crop/commodity)	Unknown

Propargyl bromide	Not registered.  No registration requests submitted to
U.S.	No (for any crop/commodity)	Unknown

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"  : 



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

Few studies have focused on peppers in Michigan’s growing conditions. 
A recent study, conducted in Oceana County, Michigan by Hausbeck and
Cortright  (2004), was undertaken to evaluate soil fumigants for
managing P. capsici on several solanaceous and cruciferous crops. 
Results, however, show that yields from pepper plots treated with metam
potassium (K-Pam), alone or in combination with chloropicrin, and from
plots treated with 1,3-D + chloropicrin (Telone C35) were comparable to
yields from plots treated with MB + chloropicrin and to yields from
control plots.  These results seem to indicate a very low pest pressure
in treated and control plots.  However, with the best available MB
alternative, revenue losses would be possible from planting delays and
missing of key market windows. 

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

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

1,3 dichloropropene + Chloropicrin	P. capsici	0 – 6 % PLUS loss of
revenue due to planting delays	6 % loss of revenue due to planting
delays

Overall Loss Estimate for All Alternatives to Pests	6 % likely with the
best alternative (1,3 D + chloropicrin)



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

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

2003 – 2005: Test for efficacy of identified alternatives.  

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

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

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

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

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

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

Based on the new trials conducted in vegetable crops in Michigan in 2003
(described above in Section 16), EPA has determined that only 1,3 D +
chloropicrin has some technical feasibility against the key pest of
peppers in this region.  

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

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

There are also no non-chemical alternatives that are currently viable
for MB replacement for commercial pepper growers. In sum, while the
potential exists for a combination of chemical and non-chemical
alternatives to replace MB use in Michigan pepper, this goal appears be
at least a few years away. 

Southeast U.S. Peppers Consortium excluding Florida and Georgia - Part
B: Crop Characteristics and Methyl Bromide Use On Peppers   TC
"Southeast U.S. Peppers Consortium excluding Florida and Georgia - Part
B: Crop Characteristics and Methyl Bromide Use" \f F \l "1"    TC
"Southeast U.S. Peppers Consortium excluding Florida and Georgia - Part
B: Crop Characteristics and Methyl Bromide Use" \f C \l "1"  



Southeast U.S. Peppers Consortium excluding Florida and Georgia   TC
"Southeast U.S. Peppers Consortium excluding Florida and Georgia - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request" \f C \l "2"   [U.S. States of
Alabama, Arkansas, Kentucky*, Louisiana*, North Carolina, South
Carolina, Tennessee and Virginia; *States added in 2005 for use in 2008]
- 10. Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request 



Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request for
Peppers  TC " Southeast U.S. Peppers Consortium excluding Florida and
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

 (Weed & plant-parasitic Nematodes) pathogens,  and [% degree of
infestation, if reported ]	Specific reasons why methyl bromide is needed




Southeast U.S. Peppers Consortium excluding Florida and Georgia	Yellow
and purple nutsedge (Cyperus esculentus, C. rotundus),  [30%];
plant-parasitic nematodes (Meloidogyne incognita; Pratylenchus sp.);
pythium root and collar rots (P.irregulare, P. myriotylum, P. ultimum,
P. aphanidermatum); crown and root rot (Phytophthora capsici) 

	Only MB can effectively control the target pests found in the
southeastern United States where pest pressures commonly exist at
moderate to severe levels. Most, if not all of these states, are limited
in the use of the alternative 1,3-D because of underlying karst
topography throughout the region.  Halosulfuron, while effective against
nutsedge, is only registered for use on row middles in peppers. 
Metam-sodium has limited pest control capabilities and should never be
used as a stand-alone fumigant (Noling, 2003).  



Southeast U.S. Peppers Consortium excluding Florida and Georgia - 11.
(i) Characteristics of Cropping System and Climate for Peppers  TC "
Southeast U.S. Peppers Consortium excluding Florida and Georgia - 11.
Characteristics of Cropping System and Climate" \f C \l "2"  



Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
11.1: Characteristics of Cropping System  TC " Southeast U.S. Peppers
Consortium excluding Florida and Georgia - Table 11.1: Characteristics
of Cropping System" \f F \l "1"  

Characteristics	Southeast U.S. Peppers Consortium excluding Florida and
Georgia

Crop Type: 	Pepper transplants for fruit production

Annual or Perennial Crop:	Annual; generally 1 year

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Pepper – usually double-cropped with a high-value cucurbit
crop (muskmelon, cucumber, or squash).  

Soil Types:  	Sandy loam; clay loam

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

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



Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
11.2 Characteristics of Climate and Crop Schedule – January Fumigation
(spring, Early Summer Harvest)  TC " Southeast U.S. Peppers Consortium
excluding Florida and Georgia - Table 11.2 Characteristics of Climate
and Crop Schedule – January Fumigation (Spring, Early Summer Harvest)"
\f F \l "1"  

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

Climatic Zone	U.S. Plant Hardiness Zones 6b, 7a, 7b, 8a, 8b

Fumigation Schedule	X	X	X









	Planting 

Schedule

X	X	X









Key  harvest  Window



X	X	X	X





	

Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
11.3 Characteristics of Climate and Crop Schedule – Spring Fumigation
(Fall Harvest)  TC " Southeast U.S. Peppers Consortium excluding Florida
and Georgia - Table 11.3 Characteristics of Climate and Crop Schedule
– Spring Fumigation (Fall Harvest)" \f F \l "1"  

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

Climatic Zone	U.S. Plant Hardiness Zones 6b, 7a, 7b, 8a, 8b

Fumigation Schedule



	X	X







Planting 

Schedule





X	X





	Key  harvest Window







X	X	X	X

	

Southeast U.S. Peppers Consortium excluding Florida and Georgia – 11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?

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

Alternatives like 1,3-dichloropropene and metam sodium require,
respectively, a 7-28 day interval and a 14-30 day interval before
planting, compared to 14 days for MB.  This interval may cause delays
and adjustments in production schedules that could lead to missing
specific market windows, thus reducing profits for pepper growers
(Kelley, 2003).

Southeast U.S. Peppers Consortium excluding Florida and Georgia - 12.
Historic Pattern of Use of Methyl Bromide on Peppers, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested  TC "
Southeast U.S. Peppers Consortium excluding Florida and Georgia - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested" \f C \l "2"   



Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
12.1 Historic Pattern of Use of Methyl Bromide on Peppers  TC "
Southeast U.S. Peppers Consortium excluding Florida and 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)A	880	809	809	991	1,153	1,329

ratio of Flat Fumigation methyl bromide use to strip/bed 	Not available

Amount of methyl bromide active ingredient used A

(total kilograms)	132,199	121,563	121,563	148,914	173,227	199,667

formulations of methyl bromide 

(methyl bromide /chloropicrin)	No definitive/substantiated information
available	67:33	67:33	67:33

Methods by which methyl bromide applied 	No information available
Injected 15 to 25 cm deep	Injected 15 to 25 cm deep	Injected 15 to 25 cm
deep

Dosage rate* (g/ha) for the active ingredient	15.0	15.0	15.0	15.0	15.0
15.0



A An increase in the acreage of peppers produced in the Southeastern
U.S. (relative to the initial nomination) is due to the addition of two
new states (added since 2001): Kentucky and Louisiana.

B Based on estimated area: 2,023 to 2,415 m2 (Lewis, 2003, personal
communication).

Southeast U.S. Peppers Consortium excluding Florida and Georgia  - Part
C: Technical Validation for Peppers  TC "Southeast U.S. Peppers
Consortium excluding Florida and Georgia  - Part C: Technical
Validation" \f F \l "1"    TC "Southeast Peppers Consortium excluding
Florida and Georgia - Part C: Technical Validation" \f C \l "1"  



Southeast U.S. Peppers Consortium excluding Florida and Georgia - 13.
Reason for Alternatives Not Being Feasible  TC "Southeast U.S. Peppers
Consortium excluding Florida and Georgia - 13. Reason for Alternatives
Not Being Feasible" \f C \l "2"   



Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Table 13.1: Reason for Alternatives Not Being Feasible  TC "Southeast
U.S. Peppers Consortium excluding Florida and 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   	Is the alternative
considered cost effective?

Chemical Alternatives

Metam Sodium	Metam sodium provides limited and erratic performance at
suppressing all major pepper pathogens and pests.  In addition, there is
a 14-30 day waiting period at the time of application until planting,
compared to 14 days for MB.  Such a delay could cause the higher-end
market windows to be missed, particularly for the spring plantings
(i.e., fall harvests).  Beginning the application cycle earlier is not
an option since crops from the previous fumigation cycle must be cleaned
up prior to metam application.  (Georgia CUE # 03-0049; Kelley, 2003). 
Repeated applications of MITC (the breakdown product of metam sodium)
are known to enhance its biodegradation and reduce efficacy as a result
of increased populations of adapted microorganisms (Dungan and Yates,
2003).	No

Non Chemical Alternatives

Soil solarization	For nutsedge control in the southeastern United
States, solarization is not technically feasible as a methyl bromide
alternative.  Response of Cyperus species to solarization is sporadic
and not well understood; data show solarization to provide, at best,
suppression of nutsedge populations (Chase et al. 1999).  Research
indicates that the lethal temperature for nutsedge tubers is 50oC or
higher.  Trials conducted in mid-summer in Georgia resulted in maximum
soil temperatures of 43 oC at 5 cm depth (Chase et al. 1999).  Thus,
solarization, even in the warmer months in southern states, did not
result in temperatures high enough to destroy nutsedge tubers.  Also,
tubers lodged deeper in the soil would be completely unaffected.  In
addition, solarization would take fields out of production since it
would be needed during the spring and into the summer months, which are
optimal for pepper production.	No

Steam	Steam is not a technically feasible alternative for open field
pepper production because it requires sustained heat over a required
period of time (UNEP 1998). While steam has been used effectively
against fungal pests in protected production systems, such as
greenhouses, there is no evidence that it would be effective in open
field pepper crops.  Any such system would also require large amounts of
energy and water to provide sufficient steam necessary to sterilize soil
down to the rooting depth of field crops (at least 20-50 cm).	No

Biological Control	Biological control agents alone cannot control
nutsedge and/or the soil pathogens that afflict peppers. The bacterium
Burkholderia cepacia and the fungus Gliocladium virens have shown some
potential in controlling some fungal plant pathogens (Larkin and Fravel
1998). However, no biological control agent has been identified to
effectively control nutsedge or Phytophthora. Therefore, biological
control is not a stand-along replacement for methyl bromide in pepper
crops.  Only a limited number of biological organisms are effectively
used to manage soil borne diseases and pests.  Biocontrol agents are
usually very specific regarding the organisms they control and their
successful establishment is highly dependent on environmental
conditions.

	No

Cover crops and mulching	Cover crops and mulches have been integrated
into solanaceous crop production systems.  However there is no evidence
these practices effectively substitute for the control methyl bromide
provides against nutsedges (Burgos and Talbert 1996).  Some cover crops
that have been shown to reduce weed populations also reduced or delayed
crop maturity and/or emergence, as well as yields (Burgos and Talbert
1996, Galloway and Weston 1996).  Mulching has also been shown to be
ineffective in controlling nutsedges, which are able to penetrate
through both organic and plastic mulches (Munn 1992, Patterson 1998).	No

Crop rotation and fallow land	Crop rotation/fallow is not a technically
feasible alternative to methyl bromide because it does not provide
adequate control of nutsedges or fungal pathogens.  The crop rotations
available to growers are also susceptible to fungi; fallow land can
still harbor fungal oospores (Lamour and Hausbeck 2003). Tubers of the
perennial nutsedges provide new plants with larger energy reserves than
annual weeds that can be more easily controlled by crop rotations and
fallow. (Thullen and Keeley 1975).  Furthermore, nutsedge plants can
produce tubers within 2 weeks after emergence (Wilen et al. 2003). This
enhances their survival across different cropping regimes that can
disrupt other plants that rely on a longer undisturbed growing period to
produce seeds to propagate the next generation.	No

Flooding/Water management	Flooding has been used effectively to manage
various soil borne pest and diseases, especially nematodes and some
weeds.   However, nutsedges have shown tolerance to this treatment. 
Submerging nutsedge tubers for 8 days to 4 weeks showed no effect on the
sprouting capabilities of the tubers (Horowitz, 1972).  Studies in
Florida showed ineffective nematode, disease, and nutsedge control after
flooding (Allen, 1999).  Regulatory issues concerning water management,
as well as economic feasibility, also preclude its viability as an
alternative to methyl bromide.  Land structure, frequent and severe
droughts, and the economics of developing and managing flood
capabilities prevent flooding from being a viable, cost effective
alternative in the Southeastern United States.	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	Due to the paucity of scientific
information on the utility of these alternatives as methyl bromide
replacements in peppers, they have been grouped together for discussion
in this document.  The U.S. EPA was unable to locate any studies showing
any potential for grafting, resistant rootstock or plant breeding as
technically feasible alternatives to methyl bromide control of
nutsedges.  Plug plants are extensively used on high value vegetable
crops like pepper but they do not control competition from nutsedges. 
There are no studies documenting the commercial availability of
resistant rootstock immune to the fungal pathogens listed as major
pepper pests.  Grafting and plant breeding are thus also rendered
technically infeasible as methyl bromide alternatives for control of
Phytophthora and Fusarium fungi.  Soilless culture, organic production,
and substrates/plug plants are also not technically viable alternatives
to methyl bromide for fungi. Various aspects of organic production –
e.g., cover crops, fallow land, and steam sterilization - have already
been addressed in this document and assessed to be technically
infeasible methyl bromide alternatives.	No

Combinations of Alternatives

Metam sodium + Chloropicrin	Although this combination would likely be
more effective than metam-sodium alone where fungal pests are the only
concern, it may not prevent yield losses due to nutsedges, particularly
where weed pressure is high.  In a study with vegetables it provided
control of yellow nutsedge, but weed pressure in that small plot test
was low, according to the authors (Csinos et al. 1999). 	No

1,3 dichloropropene  (Telone II) + metam-sodium

	This combination controls nematodes but not nutsedges.  In a study with
vegetables, it provided control of yellow nutsedge, but weed pressure in
that small plot test was low, according to the authors (Csinos et al.
1999).  It is inconsistently effective against fungal pests (see
Michigan sections for more discussion). 1,3-D is also subject to
regulatory prohibition of use on Karst geology.	

No

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

1,3 dichloropropene + chloropicrin

	This combination does not adequately control nutsedge.  Because of
ground water contamination concerns, 1,3-D cannot be used in pepper
growing areas of the U.S. where karst topography exists.  Where 1,3-D
use is allowed, set back restrictions (~ 100 meters from occupied
structures; ~ 30 meters for emulsified formulations applied via
chemigation) may limit the portion of a field that can be treated.  In
addition, because of a 28-day waiting period between application and
planting (compared to 14 days for MB), growers could lose half of the
harvest season and miss higher-end market windows, mainly for spring
fumigations  (i.e., fall harvests). 	No



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

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

Fumigant combination + herbicide partners	Current research suggests that
in areas of low pest pressure this combination may be suitable for some
growers as an alternative for methyl bromide.  In these situations
growers may employ a marginal strategy without major economic
dislocation if given a reasonable time frame for the transition.	Yes

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

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



Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Table 14.1: Technically Infeasible Alternatives Discussion  TC "
Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Table 14.1: Technically Infeasible Alternatives Discussion" \f F \l "1" 


Name of Alternative	Discussion

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

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

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



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

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

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

Southeast U.S. Peppers Consortium excluding Florida and Georgia 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives  TC "Southeast U.S. Peppers Consortium excluding
Florida and Georgia - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives" \f C \l
"2"  :



Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Table 15.1: Present Registration Status of Alternatives for Peppers  TC
"Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Table 15.1: Present Registration Status of Alternatives for Peppers" \f
F \l "1"  

Name of Alternative	Present Registration Status

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

Methyl iodide	Not registered	Yes 	Unknown

Furfural 	Not registered. 	No	Unknown

Sodium azide	Not registered. No registration application received.	No
Unknown

Propargyl bromide	Not registered.  No registration application received.
No 	Unknown

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



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



Southeast U.S. Peppers Consortium excluding Florida and Georgia - Table
16.1.  Fumigant Alternatives to Methyl Bromide for Polyethylene-Mulched
Tomato (Locascio et al. 1997)  TC "Southeast U.S. Peppers Consortium
excluding Florida and Georgia Table 16.1.  Fumigant Alternatives to
Methyl Bromide for Polyethylene-Mulched Tomato" \f F \l "1"  

Chemicals	Rate (kg/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

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

Untreated (control)	-	300 ab	20.1 a	59.1

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

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

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

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

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

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

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

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

    pest pressure and marketable yields for all treatments shown.

Locascio et al. (1997) studied MB alternatives on tomatoes grown in
small plots at two Florida locations with high nutsedge infestation. 
The data from this tomato study are being cited because comparable
pepper data are not available.  Various treatments were tested on plots
that had multiple pests.  At the Bradenton site there was moderate to
heavy Fusarium infestation; heavy purple nutsedge infestation and light
root-knot nematode pressure.  At Gainesville there was heavy infestation
of yellow and purple nutsedge and moderate infestation of root-knot
nematode.  The treatments at both locations included MB (67%) +
chloropicrin (33%) 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 considering1,3 D results, one must keep in mind that
this MB alternative cannot be used in areas where karst geology exists
which is approximately 40% of the Florida pepper production area. 

For root knot nematodes, both metam-sodium and 1,3 D + 35 % chloropicrin
have shown good efficacy in trials with tomato and pepper. For example,
Locascio and Dickson (1998) reported that metam-sodium + 35 %
chloropicrin (295 l/ha of metam-sodium, shank-injected) reduced nematode
galls significantly over untreated control plots, though not as much as
did MB + 35 % chloropicrin treatments (500kg MB/ha, shank-injected), in
Florida tomatoes. Analysis of 35 tomato and 5 pepper trials conducted
from 1993 – 1995 indicated that 1,3 D (with either 17 % or 35 %
chloropicrin) provided control of nematodes that was equal or superior
to that seen with MB, in 95 % of the tomato and 100 % of pepper trials
(Eger 2000). However, it is not clear whether yields were also
comparable to those obtained with MB. Noling et al (2000) also studied
the effects of metam-sodium (115 l/ha, syringe-injected), 1,3 D + 17 %
chloropicrin (53.6 l/ha, soil-injected), and 1,3 D + 35 % chloropicrin
(39.8 l/ha), among other treatments, in tomato plots. Galls inflicted by
root knot nematodes were reduced significantly by all these MB
alternatives, as compared to untreated control plots. Yields were also
significantly higher as compared to the control plots; all MB
alternatives resulted in similar high yields. However, the effects of MB
formulations were not reported in this study. Further, it is the opinion
of some U.S. crop experts that metam sodium, in particular, is
inconsistent as a nematode control agent (Dr. S. Culpeper, University of
Georgia, personal communication).

Southeast U.S. Pepper Consortium - Table C.1:  Alternatives Yield Loss
Data Summary  TC "Southeast U.S. Pepper Consortium – 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 dichloropropene + chloropicrin	Nutsedges, fungal pathogens	20 - 100
29%

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

Overall Loss Estimate for All Alternatives to Pests	29 % if 1,3 D + pic
is used; 44 % if metam-sodium is used



Southeast U.S. Peppers Consortium excluding Florida and Georgia –17. 
Are There Any Other Potential Alternatives Under Development Which Are
Being Considered to Replace Methyl Bromide?  TC "Southeast U.S. Peppers
Consortium excluding Florida and Georgia –17.  Are There Any Other
Potential Alternatives Under Development Which Are Being Considered to
Replace Methyl Bromide?" \f C \l "2"    



Future plans to minimize MB use include:

Optimizing use of plastic (VIF) tarps and drip irrigation equipment for
applying at-plant herbicides.

Conducting studies on tomato, pepper, and cucurbit crops with
combinations of fumigants and herbicides including halosulfuron,
metolachlor, rimsulfuron, and dimethenamid.  Telone C-35 will be used as
a fumigant because of nematode and disease problems.

Changing MB:chloropicrin formulations from 98:2 to 67:33

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

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

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

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

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

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

Southeast U.S. Peppers Consortium excluding Florida and Georgia - 18.
Are There Technologies Being Used to Produce the Crop which Avoid the
Need for Methyl Bromide?  TC " Southeast U.S. Peppers Consortium
excluding Florida and Georgia - 18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide?" \f C \l "2"  




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



Southeast U.S. Peppers Consortium excluding Florida and Georgia –
Summary of Technical Feasibility  TC "Southeast U.S. Peppers Consortium
excluding Florida and Georgia – Summary of Technical Feasibility" \f C
\l "2"  



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

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

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

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

Research on the effectiveness of non-chemical alternatives to methyl
bromide is still in a preliminary stage, particularly for high value,
minor-use crops such as peppers.

Georgia - Part B: Crop Characteristics and Methyl Bromide Use On
Peppers   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 for Peppers  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

 (Weed & plant-parasitic Nematodes) pathogens,  and [% degree of
infestation, if reported ]	Specific reasons why methyl bromide is needed




Georgia	Yellow and purple nutsedge  (Cyperus esculentus, C. rotundus)
[100%]; crown and Root rot (Phytophthora capsici) [40%]; 
plant-parasitic nematodes (Meloidogyne incognita; Pratylenchus sp)
[70%]; southern blight (Sclerotium rolfsii) [70%]; 

Pythium root and collar rots (P.irregulare, P. myriotylum, P. ultimum,
P. aphanidermatum) [100%]	Only MB can effectively control the target
pests found in the southeast U.S. where pest pressures commonly exist at
moderate to severe levels.  Most, if not all of these states are limited
in the use of the alternative 1,3-D because of underlying karst geology
throughout the region.  Halosulfuron, which is registered only for
middle-of-row use, does not control nutsedge near pepper plants where
most competition occurs.  Metam-sodium has limited pest control
capabilities and should never be used as a stand-alone fumigant (Noling,
2003).  Refer to Item 13 for additional detail.



Georgia - 11. (i) Characteristics of Cropping System and Climate for
Peppers  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: 	Pepper transplants for fruit production

Annual or Perennial Crop: 	Annual; generally 1 year

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Pepper – usually followed by a cucurbit crop (cucumbers or
squash).  Occasionally eggplants follow pepper crops.

Soil Types:  	Sandy loam; clay loam

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

Other relevant factors:	Actual frequency may be between 12 and 15 months
depending on the number of crops grown per fumigation cycle.



Georgia - Table 11.2 Characteristics of Climate and Crop Schedule –
July Fumigation Event, Pepper Crop is Harvested in FAll.  TC " Georgia -
Table 11.2 Characteristics of Climate and Crop Schedule – July
Fumigation Event, Pepper Crop is Harvested in Fall" \f F \l "1"  

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

Climatic Zone

	U.S. Plant Hardiness Zones 7a, 7b, 8a, 8b



Soil Temp. (( F) 	64.1	72.5	80.8	85.9	87.8	86.8	82.2	73.9	34.0	54.0	51.1
55.5

Rainfall (inches)	5.0	3.8	3.5	4.5	5.6	4.8	3.4	2.3	2.3	4.5	4.5	4.2

Average  Air

Temp. ((C ) 	69.8	77.7	84.7	89.4	90.7	90.5	87.3	79.3	69.8	63.1	61.5	64.0

Fumigation Schedule



	X







	Planting 

Schedule	2C



P







	Key  Harvest Windows

	2C	2C	2C

P	P	P



	Methyl bromide applied in July allows the grower to economically
produce at least two crops from one annual fumigation event.   P =
planting or harvest of pepper crop; 2C = planting and/or harvest of 2nd
crop.

Georgia - Table 11.3.  Characteristics of Climate and Crop Schedule –
Spring (Late February -March) Fumigation Event, Pepper Crop is Harvested
in Early Summer   TC "Georgia - Table 11.3 Characteristics of Climate
and Crop Schedule – Spring (Late February – March) Fumigation Event,
Pepper Crop is Harvested in Early Summer" \f F \l "1"  

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

Climatic Zone	U.S. Plant Hardiness Zones 7a, 7b, 8a, 8b

Soil Temp. ((C) 	Same as above- Table 11.2

Rainfall (mm)	Same as above- Table 11.2

Air Temp. ((C) 	Same as above- Table 11.2

Fumigation ScheduleA	X











	Planting 

ScheduleA,

P



2C







Key  harvest

WindowA,



P	P	P

2C	2C	2C



AFumigation is an early spring event. Two crops are shown as being
produced from one fumigation event.

P = planting and/or harvest of pepper crop;  2C =   planting and/or
harvest of second crop.

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



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

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

Alternatives like 1,3-dichloropropene and metam sodium require,
respectively, a 14-28 day interval and a 14-30 day interval before
planting, compared to 14 days for MB.  This interval can cause
delays/adjustments in production schedules that could lead to missing
specific market windows, thus reducing profits on pepper crops (Kelley,
2003).





Georgia - 12. Historic Pattern of Use of Methyl Bromide on Peppers,
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
Peppers  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)	1,767	2,263	2,252	2,312	2,117	2,432

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	All production acreage is strip/bed fumigation and
tarped with LDPE films.  Approximately 58% of the field is treated with
MB and covered with plastic mulch.

Amount of methyl bromide active ingredient used 

(total kilograms)	337,163	347,944	338,248	347,183	317,886	365,235

formulations of methyl bromide 

(methyl bromide /chloropicrin)	98:2	98:2 (15% acreage)

67:33 (85% Of acreage)	67:33	67:33	67:33	67:33

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

Dosage rate*(g/m2) of Active Ingredient 	19.1	15.4	15.0	15.0	15.0	15.0





Georgia - Part C: Technical Validation for Peppers  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 	Is the alternative
considered cost effective?

Chemical Alternatives

Metam Sodium	Metam sodium provides limited and erratic performance at
suppressing all nutsedge weed species and pepper pathogens.  Also, there
is a 14-30 day waiting period at the time of application until planting
compared to 14 days for MB.  Such a delay may cause the higher-end
market windows to be missed—particularly for the spring plantings
(i.e., fall harvests).  Beginning the application cycle earlier is not
an option since crops from the previous fumigation cycle must be cleaned
up prior to metam application.  (Georgia CUE # 03-0049; Kelley, 2003). 
Repeated applications of MITC (the breakdown product of metam sodium)
are known to enhance its biodegradation (and reduce efficacy) as a
result of increased populations of adapted microorganisms (Dungan and
Yates, 2003).	No

Non Chemical Alternatives

Soil solarization	For nutsedge control in the southeastern United
States, solarization is not technically feasible as a methyl bromide
alternative.  Response of Cyperus species to solarization is sporadic
and not well understood; data show solarization to provide, at best,
suppression of nutsedge populations (Chase et al. 1999).  Research
indicates that the lethal temperature for nutsedge tubers is 50 oC or
higher (Chase et al. 1999).  Trials conducted in mid-summer in Georgia
resulted in maximum soil temperatures of 43 oC at 5 cm depth.  Thus,
solarization, even in the warmer months in southern states, did not
result in temperatures high enough to destroy nutsedge tubers.  Also,
tubers lodged deeper in the soil would be completely unaffected.  In
addition, solarization would take fields out of production since it
would be needed during the spring and into the summer months, which are
optimal for pepper production. 	No

Steam	Steam is not a technically feasible alternative for open field
pepper production because it requires sustained heat over a required
period of time (UNEP 1998). While steam has been used effectively
against fungal pests in protected production systems, such as
greenhouses, there is no evidence that it would be effective in open
field pepper crops.  Any such system would also require large amounts of
energy and water to provide sufficient steam necessary to sterilize soil
down to the rooting depth of field crops (at least 20-50 cm).  	No

Biological Control	Biological control agents alone cannot control
nutsedge and/or the soil pathogens that afflict peppers. The bacterium
Burkholderia cepacia and the fungus Gliocladium virens have shown some
potential in controlling some fungal plant pathogens (Larkin and Fravel
1998). However, no biological control agent has been identified to
effectively control nutsedge or Phytophthora. Therefore, biological
control is not a stand-along replacement for methyl bromide in pepper
crops.  Only a limited number of biological organisms are effectively
used to manage soil borne plant pathogens and pests.  Biocontrol agents
are usually very specific regarding the organisms they control and their
successful establishment is highly dependent on environmental
conditions. 	No

Cover crops and mulching	Cover crops and mulches have been integrated
into solanaceous crop production systems.  However there is no evidence
these practices effectively substitute for the control methyl bromide
provides against nutsedges (Burgos and Talbert 1996).  Some cover crops
that have been shown to reduce weed populations also reduced or delayed
crop maturity and/or emergence, as well as yields (Burgos and Talbert
1996, Galloway and Weston 1996).  Mulching has also been shown to be
ineffective in controlling nutsedges, which are able to penetrate
through both organic and plastic mulches (Munn 1992, Patterson 1998).  
No

Crop rotation and fallow land	Crop rotation/fallow is not a technically
feasible alternative to methyl bromide because it does not provide
adequate control of nutsedges or fungal pathogens.  The crop rotations
available to growers are also susceptible to fungi; fallow land can
still harbor fungal oospores (Lamour and Hausbeck 2003). Tubers of the
perennial nutsedges provide new plants with larger energy reserves than
annual weeds that can be more easily controlled by crop rotations and
fallow. (Thullen and Keeley 1975).  Furthermore, nutsedge plants can
produce tubers within 2 weeks after emergence (Wilen et al. 2003). This
enhances their survival across different cropping regimes that can
disrupt other plants that rely on a longer undisturbed growing period to
produce seeds to propagate the next generation. 	No

Flooding/Water management	Flooding has been used effectively to manage
various soil borne pest and plant pathogens, especially nematodes and
some weeds.   However, nutsedges have shown tolerance to this treatment.
 Submerging nutsedge tubers for 8 days to 4 weeks showed no effect on
the sprouting capabilities of the tubers (Horowitz, 1972).  Studies in
Florida showed ineffective nematode, plant pathogen, and nutsedge
control after flooding (Allen, 1999).  Regulatory issues concerning
water management, as well as economic feasibility, also preclude its
viability as an alternative to methyl bromide.  Land structure, frequent
and severe droughts, and the economics of developing and managing flood
capabilities prevent flooding from being a viable, cost effective
alternative in the Southeastern United States.	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	Due to the paucity of scientific
information on the utility of these alternatives as methyl bromide
replacements in peppers, they have been grouped together for discussion
in this document.  The United States was unable to locate any studies
showing any potential for grafting, resistant rootstock or plant
breeding as technically feasible alternatives to methyl bromide control
of nutsedges.  Plug plants are extensively used on high value vegetable
crops like pepper but they do not control competition from nutsedges. 
There are no studies documenting the commercial availability of
resistant rootstock immune to the fungal pathogens listed as major
pepper pests.  Grafting and plant breeding are thus also rendered
technically infeasible as methyl bromide alternatives for control of
Phytophthora and Fusarium fungi.  Soilless culture, organic production,
and substrates/plug plants are also not technically viable alternatives
to methyl bromide for fungi. Various aspects of organic production –
e.g., cover crops, fallow land, and steam sterilization - have already
been addressed in this document and assessed to be technically
infeasible methyl bromide alternatives.	No

Combinations of Alternatives

Metam sodium + Chloropicrin	Would possibly be more effective than
metam-sodium alone where fungal pests are the only concern (see Michigan
sections for more discussion), but this combination may not prevent
yield losses due to nutsedges, particularly where the weed pressure is
high. U.S. EPA is aware of one vegetable study that showed control of
yellow nutsedge with this chemical combination, but weed pressure in
that small plot test was low, according to the authors (Csinos et al.
1999). 	No

1,3 dichloropropene + Metam-sodium	Controls nematodes but not nutsedges.
U.S. EPA is aware of one vegetable study that showed control of yellow
nutsedge with this chemical combination, but weed pressure in that small
plot test was low, according to the authors (Csinos et al. 1999).
Inconsistently effective against fungal pests (see Michigan sections for
more discussion). 1,3-D also subject to regulatory prohibition of use on
Karst geology.	No

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

1,3 dichloropropene + chloropicrin

	This combination does not adequately control nutsedge.  Due to
ground-water contamination concerns, 1,3-D cannot be used in pepper
growing areas of the U.S. where karst topography exists.  Where
1,3-dichloropropene use is allowed, set back restrictions (~ 100 meters
from occupied structures; ~ 30 meters for emulsified formulations
applied via chemigation) may limit the proportion of the field that can
be treated.   In addition, because of a 28-day waiting period between
application and planting (compared to 14 days for MB), growers could
lose half of the harvest season and miss higher-end market windows,
mainly for spring fumigations  (i.e., fall harvests).  (SE Pepper
Consortium, CUE # 03-0041).	No

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

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

Fumigant combination + herbicide partners	Current research suggests that
in areas of low pest pressure this combination may be suitable for some
growers as an alternative for methyl bromide.  In these situations
growers may employ a marginal strategy without major economic
dislocation if given a reasonable time frame for the transition.	Yes

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

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

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

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

Paraquat	For nutsedges: Non-selective; will not control nutsedge in the
plant rows; does not provide residual control



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

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

 

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

The applicant supplied information indicating pepper yield in fields
treated with 1,3-D was 43% below MB-treated fields, though these results
are as yet unpublished. 

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 for
Peppers  TC "Georgia – Table 15.1: Present Registration Status of
Alternatives for Peppers" \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

Furfural (Multigard()	Not registered	No	Unknown

Sodium azide	Not registered.  No registration application received.	No
Unknown

Propargyl bromide	Not registered.  No registration application received.
No	Unknown

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

Chemicals	Rate (kg/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

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

Untreated (control)	-	300 ab	20.1 a	59.1

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

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

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

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

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

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

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

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

    pest pressure and marketable yields for all treatments shown.

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

Various treatments were tested on plots that had multiple pests.  At the
Bradenton site there was moderate to heavy Fusarium infestation; heavy
purple nutsedge infestation and light root-knot 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.} 

Georgia – Table C.1: Alternatives Yield Loss Data Summary  TC "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, fungal pathogens	20 – 100	29

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

Overall Loss Estimate for All Alternatives to Pests	29 % if 1,3 D + pic
is used; 44 % if metam-sodium is used



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"  



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

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

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

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

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

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



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



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

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





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

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

Research on the effectiveness of non-chemical alternatives to methyl
bromide is still in a preliminary stage, particularly for high value,
minor-use crops.



Part B: Florida -Crop Characteristics and Methyl Bromide Use on Peppers 
 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  TC "Florida - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request" \f C \l "2"   



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 Pathogens, nematodes
and/or  weed(s) to genus and, if known, to species level	Specific
reasons why methyl bromide is needed 

Florida 	Weeds: yellow & purple nutsedges

(Cyperus rotundus & C. esculentus), nightshade (Solanum spp.), white
clover (Trifollium repens), ragweed (Ambrosia artemisifolia)

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

Nematodes: root-knot nematodes (Meloidogyne spp.), 

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



Florida - 11. (i) Characteristics of Cropping System and Climate  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: 	Pepper transplants for fruit production

Annual or Perennial Crop: 	Annual (usually 1 yr)

Typical Crop Rotation) and use of methyl bromide for other crops in the
rotation: 	Eggplants or cucurbits

Soil Types:	Sandy and sandy-loam soils

Frequency of methyl bromide Fumigation: 	1 time per year 

Other relevant factors:	Double-cropped with cucurbits



Florida - Table 11.2 Characteristics of Climate and Crop Schedule  TC
"Florida - 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 Zones	Plant Hardiness Zones 9a; 9b; 10a, 10.



Rainfall (mm),

Tampa, FL	65.5	50.0	72.5	134.1	175.8	193.3	152.7	65.0	42.7	158.8	62.0
66.8,

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

Fumigation ScheduleA





X	X	X	X	X	X

	Transplanting 

Schedule; , non double-croppedB	X





X	X	X	X	X	X

Key harvest Window; non double-croppedC	X	X	X	X



	X	X	X	X

A Non-double cropped: earliest start date: August 15; cells marked with
an “x” represent variation in fumigation initiation amongst pepper
growers.

B For Non-Double cropped pepper production, transplanting peppers is
usually initiated around September 1; cells marked with an “x”
represent variation in transplanting dates amongst pepper growers.

.C For Non-Double Cropped Peppers:  Harvest Period usually begins as
early as Nov. 15, and may continue until June 15, depending on when
planted and weather conditions.

Florida - Table 11.3 Characteristics of Climate and Crop Schedule –
Peppers Double Cropped with another Vegetable (usually Cucurbits)  TC
"Florida - Table 11.3 Characteristics of Climate and Crop Schedule –
Peppers Double Cropped with another Vegetable Crop (usually Cucurbits)"
\f F \l "1"  

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

Climatic Zones	Plant Hardiness Zones 9a; 9b; 10a, 10.



Rainfall (mm),

Tampa, FL	65.5	50.0	72.5	134.1	175.8	193.3	152.7	65.0	42.7	158.8	62.0
66.8,

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

Fumigation Schedule,; double-croppedA





X	X





	Transplanting 

Schedule; double-croppedB	2C	2C



	P	P



2C

Key  harvest Window; double-croppedC	P	P	2C	2C	2C



P	P	P	P

ADouble-cropped; assumed to be with cucurbits; earliest start date is
August 15; shaded cells represent variation in fumigation initiation
among pepper growers who double-crop.

BFor Double-Cropped pepper production, transplanting (P) is typically
initiated on September 1; variance can be until October 31.  The second
crop of cucurbits (usually) transplants (indicated by “2C”) would
typically be initiated around Feb 15, and may vary until April 30

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

 Climate Zone designation (  HYPERLINK
"http://www.usna.usda.gov/Hardzone"  http://www.usna.usda.gov/Hardzone )


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



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

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



Florida - 12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested  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)	8,903	8,741	8,741 	8,195 	8,417	8,701

ratio of Flat Fumigation methyl bromide use to strip/bed use 	100% strip
treatments are used in this region

Amount of methyl bromide active ingredient used 

(total kilograms)	1,644,501	1,431,639	1,406,135	1,285,199	1,320,860
1,338,006

formulations of methyl bromide 

(methyl bromide /chloropicrin)A	98:2 &

67:33	98:2 &

67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied A	Sweptback chisel-shank, 25-30.5
cm.deep	Sweptback chisel-shank, 25-30.5 cm.deep	Sweptback chisel-shank,
25-30.5 cm.deep	Sweptback chisel-shank, 25-30.5 cm.deep	Sweptback
chisel-shank, 25-30.5 cm.deep	Sweptback chisel-shank, 25-30.5 cm.deep

Dosage rate of Strip/ bed, g MB/m2	18.5	16.4	16.1	15.7	15.7	15.4

A Sources: personal communication, Professor J.W. Noling, November 25,
2003; M. Aerts, December 2, 2003.

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 dichloropropene	1,3-D provides control of nematode populations, but
poor control of plant pathogens and weeds.  Control of nematodes is
erratic, due to poor distribution of the fumigant in the sandy soils of
Florida. 1,3-D’s use is prohibited due to groundwater contamination in
key pepper growing areas with karst geology, which is estimated to be
about 40% in of FL pepper area in 2002.  In Dade County, a major pepper
production area, 100% of pepper acreage is affected by a label
prohibition that addresses groundwater contamination concerns.  In areas
where 1,3-D use is allowed, set back restrictions (~ 100 meters from
occupied structures; ~ 30 meters for emulsified formulations applied via
chemigation) may limit the portion of a field that can be treated.   In
addition, the 28-day waiting period between application and planting can
cause delays/adjustments in production schedules that could lead to
missing specific higher-end market windows.	No

Metam-sodium/potassium 	Provides limited and erratic performance for
suppressing major pepper pathogens and pests. Does not work under high
pest pressure.  This soil fumigant is considered the best available
alternative for Dade County only, where 1,3 D use is prohibited (Aerts,
2003).  This is at best a treatment that complements other fumigants and
herbicides, and is not a stand-alone option (Noling, 2003).  Metam
sodium has a lower vapor pressure than methyl bromide, and therefore
cannot penetrate and diffuse throughout the soil as effectively as MB. 
In addition, the effectiveness of metam sodium is dependent on the
organic matter and moisture content of the soil.  Metam sodium tends to
degrade rapidly in warm soils where it has been previously used.     	No

Non Chemical Alternatives

Solarization 	Solarization is not technically feasible as a methyl
bromide alternative for control of nutsedges.  Research indicates that
the lethal temperature for nutsedge tubers is 50 oC or higher (Chase et
al. 1999.  Trials conducted in mid-summer in Georgia resulted in maximal
soil temperatures of 43 oC at 5 cm depth.  Thus, solarization, even in
the warmer months in southern states, did not result in temperatures
reliably high enough to destroy nutsedge tubers, and tubers lodged
deeper in the soil would be completely unaffected.  Response of Cyperus
species to solarization is sporadic and not well understood and data
show solarization to provide, at best, suppression of nutsedge
populations (Chase et al. 1999).  In addition, solarization will take
fields out of production since it would be needed during the spring and
into the summer months, which are optimal for pepper production. 	No

Steam	Steam is not a technically feasible alternative for open field
pepper production because it requires sustained heat over a required
period of time (UNEP 1998). While steam has been used effectively
against fungal pests in protected production systems, such as
greenhouses, there is no evidence that it would be effective in open
field pepper crops.  Any such system would also require large amounts of
energy and water to provide sufficient steam necessary to sterilize soil
down to the rooting depth of field crops (at least 20-50 cm).  	No

Biological Control	Biological control agents alone cannot control
nutsedge and/or the soil pathogens that afflict peppers. The bacterium
Burkholderia cepacia and the fungus Gliocladium virens have shown some
potential in controlling some fungal plant pathogens (Larkin and Fravel
1998). However, no biological control agent has been identified to
effectively control nutsedge or Phytophthora. Therefore, biological
control is not a stand-along replacement for methyl bromide in pepper
crops.  Only a limited number of biological organisms are effectively
used to manage soil borne plant pathogens and pests.  	No

Cover crops and mulching	Cover crops and mulches have been integrated to
solanaceous crop production management.  However there is no evidence
these practices effectively substitute for the control methyl bromide
provides against nutsedges (Burgos and Talbert 1996).  Some cover crops
that have been shown to reduce weed populations also reduced or delayed
crop maturity and/or emergence, as well as yields (Burgos and Talbert
1996, Galloway and Weston 1996).  Mulching has also been shown to be
ineffective in controlling nutsedges, since these plants are able to
penetrate through both organic and plastic mulches (Munn 1992, Patterson
1998).  	No

Crop rotation and fallow land	Crop rotation/fallow is not a technically
feasible alternative to methyl bromide because it does not provide
adequate control of nutsedges or fungal pathogens.  The crop rotations
available to growers are also susceptible to fungi; fallow land can
still harbor fungal oospores (Lamour and Hausbeck 2003). As regards to
nutsedges, tubers of these perennial species provide new plants with
larger energy reserves than the annual weeds that can be frequently
controlled by crop rotations and fallow land (Thullen and Keeley 1975). 
Furthermore, nutsedge plants can produce tubers within 2 weeks after
emergence (Wilen et al. 2003). This enhances their survival across
different cropping regimes that can disrupt other plants that rely on a
longer undisturbed growing period to produce seeds to propagate the next
generation. 	No

Flooding/Water management	South Florida is generally subject to natural
flooding during summer months, but other areas cannot be flooded because
of lack of a shallow, impermeable layer.  Although flooding is a pest
management tool that has been used effectively to manage various soil
borne pest and plant pathogens, nutsedges have shown tolerance to this
treatment.  Submergence of nutsedge tubers for periods of 8 days to 4
weeks showed no effect on the sprouting capabilities of the tubers
(Horowitz, 1972).  Studies in Florida (Allen, 1999) showed ineffective
nematode, plant pathogen, and nutsedge control.  Regulatory issues
concerning water management, as well as economic feasibility, also
preclude its viability as an alternative to methyl bromide.  Land
structure, frequent and severe droughts, and the economics of developing
and managing flood capabilities will prevent flooding from being a
viable, cost effective alternative in the Southeastern states.	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	Due to the paucity of scientific
information on the utility of these alternatives as methyl bromide
replacements in peppers, they have been grouped together for discussion
in this document.   The U.S. was unable to locate any studies showing
any potential for grafting, resistant rootstock or plant breeding as
technically feasible alternatives to methyl bromide control of
nutsedges.  Plug plants are extensively used on high value vegetable
crops like pepper but they do not control competition from nutsedges.
There are no studies documenting the commercial availability of
resistant rootstock immune to the fungal pathogens listed as major
pepper pests.  Grafting and plant breeding are thus also rendered
technically infeasible as methyl bromide alternatives for control of
Phytophthora and Fusarium fungi.  Soilless culture, organic production,
and substrates/plug plants are also not technically viable alternatives
to methyl bromide for fungi.  Various aspects of organic production –
e.g., cover crops, fallow land, and steam sterilization - have already
been addressed in this document and assessed to be technically
infeasible methyl bromide alternatives.	No

Combinations of Alternatives

Metam sodium + Chloropicrin	This combination has been used in Florida
since the 1970s.  It is being tested as a leading alternative to MB in
Dade County because of label restrictions for 1,3-D,  which do not allow
its use in that county.  However, it has shown erratic performance
suppressing weeds, nematodes, and plant pathogens in the sandy soils of
Florida.  MB has higher vapor pressure than metam sodium and can
penetrate and diffuse throughout the soil more effectively.  Trials in
tomato have shown inconsistent efficacy of this combination against soil
pathogens, though it is generally better than metam-sodium alone
(Locascio and Dickson 1998, Csinos et al. 1999).  This alternative will
require further testing and validation on commercial fields.       	No,
but shows promise

1,3 dichloropropene + chloropicrin (Telone C35) 	Although this
combination, by itself, is not effective in areas with moderate to high
nutsedge pressure, it can provide season long control when coupled with
herbicides (Chellemi et al.  2001; Gilreath and Santos, 2003).  Trials
comparing Flat Fumigation applications with standard in-row applications
indicated the need to increase the amount of chloropicrin to compensate
for the potential decrease in efficacy of 1,3-D applied via Flat
Fumigation.  Applications via micro-irrigation systems have yielded
mixed results, probably due to poor lateral distribution of the chemical
in the soil (Martin 2003; Dungan and Yates, 2003).  In addition,
1,3-D’s use is prohibited due to groundwater contamination in areas
with karst geology, estimated to be about 40% in of FL pepper area in
2002.  In Dade County this combination is not allowed at all.  A Telone
C35 application, along with a herbicide mix (e.g. clomazone +
metolachlor) applied at bed formation, has been identified by the
Florida Fruit and Vegetable Association as the recommended best MB
alternative outside karst geology areas.  Although promising, this
alternative will require further testing and validation on commercial
fields.     	No, but shows promise for non-karst geology areas.

1,3 dichloropropene + Metam-sodium	Trials in tomato have shown
inconsistent efficacy of this formulation against fungal pests, though
it is generally better than metam-sodium alone (Csinos et al. 1999). 
Low efficacy in even small-plot trials indicates that this is not a
technically feasible alternative for commercially produced peppers at
this time.  In addition, 1,3-D’s use is prohibited due to groundwater
contamination in all pepper growing areas with karst geology, estimated
to be about 40% in of FL pepper area in 2002.  In Dade County 100% of
pepper acreage is affected by this limitation.  	No

Fumigant combination + herbicide partners	Current research suggests that
in areas of low pest pressure this combination may be suitable for some
growers as an alternative for methyl bromide.  In these situations
growers may employ a marginal strategy without major economic
dislocation if given a reasonable time frame for the transition	Yes

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

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

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

Glyphosate	For nutsedges: Non-selective; will not control nutsedge in
the plant rows; does not provide residual control

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



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

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

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

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 - recently registered for tomato in FL
only.  Crop injury potential exist	No	Unknown

Fosthiazate	Not registered on peppers	No	Unknown

Furfural (Multigard()	Not registered	No	Unknown

Sodium azide	Not registered. No registration application received.	No
Unknown

Propargyl bromide	Not registered.  No registration application received.
No	Unknown

Paecilomyces lilacinus 	Biological nematicide; not registered	Yes
Unknown

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

Chemicals	Rate (kg/ha)	Average Nutsedge Density

(#/m2)	Average Marketable Yield

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

Untreated (control)	-	300 ab	20.1 a	59.1

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

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

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

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

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

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

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

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

    pest pressure and marketable yields for all treatments shown.

						All fumigants were injected 15-20 cm deep, with three chisels per
bed, 30 cm apart  

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

Various treatments were tested on plots that had multiple pests.  At the
Bradenton site there was moderate to heavy Fusarium infestation; heavy
purple nutsedge infestation and light root-knot nematode pressure.  At
Gainesville there was heavy infestation of yellow and purple nutsedge
and moderate infestation of root-knot nematode.  The treatments at both
locations included MB (67%) + chloropicrin (33%) chisel-injected at 390
kg/ha; metam-sodium (chisel-injected) at 300L/ha; metam-sodium
drip-irrigated at 300L/ha; and 1,3-D + 17% chloropicrin chisel-injected
at 327L/ha.  In pairwise statistical comparisons, the yield was
significantly lower in 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, or anywhere in Dade county, a major
production area. 

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 dichloropropene + chloropicrin	Nutsedges, fungal pathogens	20 - 100
29

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

Overall Loss Estimate for All Alternatives to Pests	29 % if 1,3 D + pic
is used; 44 % if metam-sodium is used



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 being considered for registration as a methyl bromide
replacement.   Its registration date is not known.  Please refer to
Table 15.1 for details.





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

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



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





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

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

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

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

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

Research on the effectiveness of non-chemical alternatives to methyl
bromide is still in a preliminary stage, particularly for high value,
minor-use crops.

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 U.S. has
achieved a 36 % reduction in use rates. 	From 2 % to 33 % 	No

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Research is underway to develop use in
commercial production systems 	A 50 % MB formulation is being tested in
Michigan pepper fields.   A similar formulation was tested in Florida
and found to be ineffective.	A 50 % MB formulation is being tested in
Michigan pepper fields.   A similar formulation was tested in Florida
and found to be ineffective.	The U.S. anticipates that the decreasing
supply of methyl bromide will motivate growers to try less frequent
applications.

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



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 peppers in the United States is minimized in several ways. 
First, because of its toxicity, MB has, for the last 40 years, been
regulated as a restricted use pesticide in the United States.  As a
consequence, MB can only be used by certified applicators who are
trained at handling these hazardous pesticides.  In practice, this means
that MB is applied by a limited number of very experienced applicators
with the knowledge and expertise to minimize dosage to the lowest level
possible to achieve the needed results.  In keeping with both local
requirements to avoid “drift” of methyl bromide into inhabited
areas, as well as to preserve MB and keep related emissions to the
lowest level possible, MB application for cucurbits is most often
machine injected into soil to specific depths.  

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

	

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

Reduced MB concentrations in mixtures, cultural practices, and the
extensive use of tarpaulins to cover land treated with MB has resulted
in reduced emissions and an application rate that we believe is among
the lowest in the world for the uses described in this nomination.  





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 2004 submission for all applicants were not
substantially different from those in 2003 (greater or less than a 10%
change in costs and revenue).  Given these insignificant differences,
the economic analyses were not updated for any applicants other than
Michigan, which was updated to reflect a change in the requested pounds
of MeBr.

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

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

21. Operating Costs of Alternatives Compared to Methyl Bromide Over
3-Year Period  TC "21. Operating Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period" \f C \l "2"  :



Table 21.1: Peppers – Operating Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period  TC "Table 21.1: Peppers – 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%	$20,341	$20,341	$20,341

1,3-D + Chloropicrin	71%	$18,510	$18,510	$18,510

Metam-Sodium	56%	$16,999	$16,999	$16,999

Georgia

Methyl Bromide	100%	$28,623	$28,623	$28,623

1,3-D + Chloropicrin	71%	$25,790	$25,790	$25,790

Metam-Sodium	56%	$23,598	$23,598	$23,598

Michigan

Methyl Bromide	100%	$23,938	$23,938	$23,938

1,3-D + Chloropicrin	94%	$25,607	$25,607	$25,607

Southeast USA

Methyl Bromide	100%	$18,758	$18,758	$18,758

1,3-D + Chloropicrin	71%	$18,844	$18,844	$18,844

Metam-Sodium	56%	$16,731	$16,731	$16,731

* As percentage of typical or 3-year average yield, compared to methyl
bromide e.g. 10% more yield, write 110. 

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



Table 22.1: Peppers – Year 1, 2, and 3 Gross and Net Revenues   TC
"Table 22.1: Peppers - 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	$29,498	$9,158

1,3-D + Chloropicrin	$20,944	$2,433

Metam-Sodium	$16,519	$(479)

Georgia

Methyl Bromide	$35,176	$6,553

1,3-D + Chloropicrin	$24,975	$(816)

Metam-Sodium	$19,698	$(3,900)

Michigan

Methyl Bromide	$24,056	$118

1,3-D + Chloropicrin	$20,916	$(2,994)

Southeastern USA

Methyl Bromide	$30,579	$11,822

1,3-D + Chloropicrin	$21,711	$2,867

Metam-Sodium	$17,124	$393

Note: Year 1 equals year 2 and 3.

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



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

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

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	2,922	2,074	1,636

* Price per Unit (us$)	$10	$10	$10

= Gross Revenue per Hectare (us$)	$29,498	$20,944	$16,519

- Operating Costs per Hectare (us$)	$20,341	$18,510	$16,999

= Net Revenue per Hectare (us$)	$9,158	$2,433	$(479)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$6,724	$9,637

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$45	$64

3. Loss as a Percentage of Gross Revenue (%)	0%	23%	33%

4. Loss as a Percentage of Net Revenue (%)	0%	73%	105%

5. Profit Margin (%)	31%	12%	-3%



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

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

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	4,440	3,152	2,486

* Price per Unit (us$)	$8	$8	$8

= Gross Revenue per Hectare (us$)	$35,176	$24,975	$19,698

- Operating Costs per Hectare (us$)	$28,623	$25,790	$23,598

= Net Revenue per Hectare (us$)	$6,553	$(816)	$(3,900)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$7,368	$10,453

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$49	$70

3. Loss as a Percentage of Gross Revenue (%)	0%	21%	30%

4. Loss as a Percentage of Net Revenue (%)	0%	112%	160%

5. Profit Margin (%)	19%	-3%	-20%



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

michigan pepper	Methyl Bromide	1, 3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	4,530	4,258

* Price per Unit (us$)	$5	$5

= Gross Revenue per Hectare (us$)	$24,056	$20,916

- Operating Costs per Hectare (us$)	$23,938	$25,607

= Net Revenue per Hectare (us$)	$118	$(4,690)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$4,808

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$40

3. Loss as a Percentage of Gross Revenue (%)	0%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	100%

5. Profit Margin (%)	0%	-22%



Southeastern USA (except Georgia) Pepper - Table E.4: Economic Impacts
of Methyl Bromide Alternatives  TC "Southeastern USA (except Georgia)
Pepper - Table E.4: Economic Impacts of Methyl Bromide Alternatives" \f
F \l "1"  

Southeastern USA (Except Georgia) pepper	Methyl Bromide	1, 3-D +
Chloropicrin	Metam-Sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	3,707	2,632	2,076

* Price per Unit (us$)	$8	$8	$8

= Gross Revenue per Hectare (us$)	$30,579	$21,711	$17,124

- Operating Costs per Hectare (us$)	$18,758	$18,844	$16,731

= Net Revenue per Hectare (us$)	$11,822	$2,867	$393

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$8,954	$11,429

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$60	$76

3. Loss as a Percentage of Gross Revenue (%)	0%	29%	37%

4. Loss as a Percentage of Net Revenue (%)	0%	76%	97%

5. Profit Margin (%)	39%	13%	2%



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

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

1. Yield Loss

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

2. Missed Market Windows

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

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

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

Florida

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

Georgia

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

Southeastern USA Except Georgia

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

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

As one incentive for the pesticide industry to develop alternatives to
methyl bromide, the Agency has worked to reduce the burdens on data
generation, to the extent feasible while still ensuring that the
Agency’s registration decisions meet the Federal statutory safety
standards.  Where appropriate from a scientific standpoint, the Agency
has refined the data requirements for a given pesticide application,
allowing a shortening of the research and development process for the
methyl bromide alternative.  Furthermore, Agency scientists routinely
meet with prospective methyl bromide alternative applicants, counseling
them through the preregistration process to increase the probability
that the data is done right the first time and rework delays are
minimized

The U.S. EPA has also co-chaired the 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 peppers research will
require 2844 kg per year of methyl bromide for 2005 and 2006.  This
amount of methyl bromide is necessary to conduct research on
alternatives and is in addition to the amounts requested in the
submitted CUE applications.  One example of the research is a field
study testing the comparative performance of methyl bromide, host
resistance, cultural practices, pest management approaches for control
of 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"   



See Section 23 above.

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"  



New data used in this CUN

1.  Southeastern states, including Georgia

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

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

In addition, the Florida Fruit and Vegetable Association has been
screening, as stand-alone MB replacements, 1,3-D, chloropicrin, metam
sodium, and dazomet evaluated against 98:2 and 67:33 MB + chloropicrin
formulations at the maximum allowable label rate at multiple locations. 
Results indicate that the best alternatives will likely include a
pre-plant application of 1,3-D + chloropicrin, followed by an
application of chloropicrin injected into the raised bed and a herbicide
mix applied to the raised bed at plastic laying. 



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



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the effectiveness of Telone II.    HYPERLINK
"http://ucdnema.ucdavis.edu/imagemap/nemmap/ent156html/204NEM/204INDEX" 
http://ucdnema.ucdavis.edu/imagemap/nemmap/ent156html/204NEM/204INDEX ,

		  HYPERLINK
"http://ucdnema.ucdavis.edu/imagemap/nemmap/ent156html/204NEM/CHEM/XTELC
HRT" 
http://ucdnema.ucdavis.edu/imagemap/nemmap/ent156html/204NEM/CHEM/XTELCH
RT 

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

Verhagen, C., G. Lebbink, and J. Bloem. 1996. Enhanced biodegradation of
the nematicides 1,3-dichloropropene and methyl isothiocyanate in a
variety of soils. Soil Biol. Biochem. 28:1753–1756.

Webster, T.M. 2002. Nutsedge eradication: impossible dream? National
Nursery Proc. RMRS-P-000. U.S.DA Forest Service, Rocky Mtn Res. Station,
Ogden, Utah.

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.

Wilen, C. A., M. E. McGiffen, and C. L. Elmore. 2003. Nutsedge:
Integrated Pest Management for Home Gardeners and Landscape
Professionals. University of California IPM Publication # 4732.
Available on the Web at   HYPERLINK "http://www.ipm.ucdavis.edu" 
www.ipm.ucdavis.edu .

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.

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