Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Ornamentals Grown in Open Fields or in Protected Environments

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 Ornamentals Grown in Open Fields or
in Protected Environments  (Submitted in 2006 for Use in 2008)



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) 305-8200

Fax:	(703) 308-8090

E-mail:	keigwin.richard@epa.gov



	

List of Documents Sent to the Ozone Secretariat in Official Nomination
Package

List all paper and electronic documents submitted by the Nominating
Party to the Ozone Secretariat

Paper Documents:

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



















electronic copies of all paper documents: 

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

CUN2008 USA Ornamental Photos 1-23-2006	2.15













	

Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125774758"  Part A: Summary	 
PAGEREF _Toc125774758 \h  7  

  HYPERLINK \l "_Toc125774759"  1. Nominating Party	  PAGEREF
_Toc125774759 \h  7  

  HYPERLINK \l "_Toc125774760"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125774760 \h  7  

  HYPERLINK \l "_Toc125774761"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125774761 \h  7  

  HYPERLINK \l "_Toc125774762"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125774762 \h  8  

  HYPERLINK \l "_Toc125774763"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125774763 \h  8  

  HYPERLINK \l "_Toc125774764"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125774764 \h  9  

  HYPERLINK \l "_Toc125774765"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125774765 \h  10  

  HYPERLINK \l "_Toc125774766"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125774766 \h  12  

  HYPERLINK \l "_Toc125774767"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125774767 \h  12  

  HYPERLINK \l "_Toc125774768"  California Ornamentals - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125774768 \h  13  

  HYPERLINK \l "_Toc125774769"  California Ornamentals - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125774769 \h  13  

  HYPERLINK \l "_Toc125774770"  California Ornamentals - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125774770
\h  14  

  HYPERLINK \l "_Toc125774771"  California Ornamentals - 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested	  PAGEREF _Toc125774771 \h 
19  

  HYPERLINK \l "_Toc125774772"  California Ornamentals – Part C:
Technical Validation	  PAGEREF _Toc125774772 \h  19  

  HYPERLINK \l "_Toc125774773"  California Ornamentals - 13. Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125774773 \h  19  

  HYPERLINK \l "_Toc125774774"  California Ornamentals - 14. List and
Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:	 
PAGEREF _Toc125774774 \h  25  

  HYPERLINK \l "_Toc125774775"  California Ornamentals - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125774775 \h  25  

  HYPERLINK \l "_Toc125774776"  California Ornamentals - 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 _Toc125774776 \h  25  

  HYPERLINK \l "_Toc125774777"  California Ornamentals - 17. Are There
Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125774777 \h  32  

  HYPERLINK \l "_Toc125774778"  California Ornamentals - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?	  PAGEREF _Toc125774778 \h  32  

  HYPERLINK \l "_Toc125774779"  California Ornamentals - Summary of
Technical Feasibility	  PAGEREF _Toc125774779 \h  33  

  HYPERLINK \l "_Toc125774780"  Florida Ornamentals - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125774780 \h  34  

  HYPERLINK \l "_Toc125774781"  Florida Ornamentals - 10. Key Diseases
and Weeds for which Methyl Bromide Is Requested and Specific Reasons for
this Request	  PAGEREF _Toc125774781 \h  34  

  HYPERLINK \l "_Toc125774782"  Florida Ornamentals - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125774782
\h  35  

  HYPERLINK \l "_Toc125774783"  Florida Ornamentals - 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested	  PAGEREF _Toc125774783 \h 
38  

  HYPERLINK \l "_Toc125774784"  Florida Ornamentals - Part C: Technical
Validation	  PAGEREF _Toc125774784 \h  39  

  HYPERLINK \l "_Toc125774785"  Florida Ornamentals - 13. Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125774785 \h  39  

  HYPERLINK \l "_Toc125774786"  Florida Ornamentals - 14. List and
Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:	 
PAGEREF _Toc125774786 \h  46  

  HYPERLINK \l "_Toc125774787"  Florida Ornamentals - 15. List Present
(and Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125774787 \h  46  

  HYPERLINK \l "_Toc125774788"  Florida Ornamentals - 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 _Toc125774788 \h  46  

  HYPERLINK \l "_Toc125774789"  Florida Ornamentals - 17. Are There Any
Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125774789 \h  50  

  HYPERLINK \l "_Toc125774790"  Florida Ornamentals - 18. Are There
Technologies Being Used to Produce the Crop which Avoid the Need for
Methyl Bromide?	  PAGEREF _Toc125774790 \h  50  

  HYPERLINK \l "_Toc125774791"  Florida Ornamentals - Summary of
Technical Feasibility	  PAGEREF _Toc125774791 \h  51  

  HYPERLINK \l "_Toc125774792"  Michigan Herbaceous Perennials. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125774792 \h 
51  

  HYPERLINK \l "_Toc125774793"  Michigan Herbaceous Perennials. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125774793 \h  51  

  HYPERLINK \l "_Toc125774794"  Michigan Herbaceous Perennials. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125774794
\h  51  

  HYPERLINK \l "_Toc125774795"  Michigan Herbaceous Perennials. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125774795 \h  53  

  HYPERLINK \l "_Toc125774796"  Michigan Herbaceous Perennials - Part C:
Technical Validation	  PAGEREF _Toc125774796 \h  53  

  HYPERLINK \l "_Toc125774797"  Michigan Herbaceous Perennials. 13.
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125774797 \h 
53  

  HYPERLINK \l "_Toc125774798"  Michigan Herbaceous Perennials. 14. List
and Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:	 
PAGEREF _Toc125774798 \h  56  

  HYPERLINK \l "_Toc125774799"  Michigan Herbaceous Perennials. 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125774799 \h  57  

  HYPERLINK \l "_Toc125774800"  Michigan Herbaceous Perennials - 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 _Toc125774800 \h  57  

  HYPERLINK \l "_Toc125774801"  Michigan Herbaceous Perennials. 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125774801 \h  59  

  HYPERLINK \l "_Toc125774802"  Michigan Herbaceous Perennials. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125774802 \h  59  

  HYPERLINK \l "_Toc125774803"  Michigan Herbaceous Perennials. Summary
of Technical Feasibility	  PAGEREF _Toc125774803 \h  59  

  HYPERLINK \l "_Toc125774804"  Part D: Emission Control	  PAGEREF
_Toc125774804 \h  60  

  HYPERLINK \l "_Toc125774805"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125774805 \h  60  

  HYPERLINK \l "_Toc125774806"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125774806 \h  60  

  HYPERLINK \l "_Toc125774807"  Part E: Economic Assessment	  PAGEREF
_Toc125774807 \h  61  

  HYPERLINK \l "_Toc125774808"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125774808 \h  62  

  HYPERLINK \l "_Toc125774809"  22. Gross and Net Revenue	  PAGEREF
_Toc125774809 \h  62  

  HYPERLINK \l "_Toc125774810"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125774810 \h  64  

  HYPERLINK \l "_Toc125774811"  Summary of Economic Feasibility	 
PAGEREF _Toc125774811 \h  65  

  HYPERLINK \l "_Toc125774812"  Part F. Future Plans	  PAGEREF
_Toc125774812 \h  68  

  HYPERLINK \l "_Toc125774813"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125774813 \h  68  

  HYPERLINK \l "_Toc125774814"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125774814 \h  69  

  HYPERLINK \l "_Toc125774815"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125774815 \h  69  

  HYPERLINK \l "_Toc125774816"  26. Citations	  PAGEREF _Toc125774816 \h
 70  

  HYPERLINK \l "_Toc125774817"  APPENDIX A.  2008 Methyl Bromide Usage
Numerical Index (BUNI)	  PAGEREF _Toc125774817 \h  73  

  HYPERLINK \l "_Toc125774818"  Appendix B – Key Pests of Select Cut
Flower Species	  PAGEREF _Toc125774818 \h  74  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125867701"  Part A:
Summary	  PAGEREF _Toc125867701 \h  7  

  HYPERLINK \l "_Toc125867702"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125867702 \h  8  

  HYPERLINK \l "_Toc125867703"  Table A.1: Executive Summary	  PAGEREF
_Toc125867703 \h  9  

  HYPERLINK \l "_Toc125867704"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125867704 \h  10  

  HYPERLINK \l "_Toc125867705"  Ornamentals - Table 8.1: Amount of
Methyl Bromide Requested for Critical Use	  PAGEREF _Toc125867705 \h  11
 

  HYPERLINK \l "_Toc125867706"  California Ornamentals - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125867706 \h  12  

  HYPERLINK \l "_Toc125867707"  California Ornamentals - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125867707 \h  12  

  HYPERLINK \l "_Toc125867708"  California Ornamentals - Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125867708 \h  13  

  HYPERLINK \l "_Toc125867709"  California Ornamentals - Table 11.2
Characteristics of Climate and Crop Schedule – Fall Plantings	 
PAGEREF _Toc125867709 \h  14  

  HYPERLINK \l "_Toc125867710"  California Ornamentals - Table 11.3
Characteristics of Climate and Crop Schedule – Spring Plantings	 
PAGEREF _Toc125867710 \h  14  

  HYPERLINK \l "_Toc125867711"  California Ornamentals - Table 11.4
Characteristics of Climate and Crop Schedule - Ranunculus	  PAGEREF
_Toc125867711 \h  14  

  HYPERLINK \l "_Toc125867712"  California Ornamentals - Table 11.5
Characteristics of Climate and Crop Schedule – Multiple Crop Rotation
Scenario One	  PAGEREF _Toc125867712 \h  15  

  HYPERLINK \l "_Toc125867713"  California Ornamentals - Table 11.6
Characteristics of Climate and Crop Schedule – Multiple Crop Rotation
Scenario Two	  PAGEREF _Toc125867713 \h  15  

  HYPERLINK \l "_Toc125867714"  California Ornamentals - Table 11.6
Production of Major Species	  PAGEREF _Toc125867714 \h  16  

  HYPERLINK \l "_Toc125867715"  California Ornamentals - Table 11.7
Partial Listing and Estimate of Cut Flower and Foliage Area Produced in
California in 2002	  PAGEREF _Toc125867715 \h  17  

  HYPERLINK \l "_Toc125867716"  California Ornamentals - Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125867716 \h  18
 

  HYPERLINK \l "_Toc125867717"  California Ornamentals - Part C:
Technical Validation	  PAGEREF _Toc125867717 \h  18  

  HYPERLINK \l "_Toc125867718"  California Ornamentals – Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125867718 \h 
19  

  HYPERLINK \l "_Toc125867719"  California Ornamentals – Table 14.1:
Technically Infeasible Alternatives Discussion	  PAGEREF _Toc125867719
\h  24  

  HYPERLINK \l "_Toc125867720"  California Ornamentals – Table 15.1:
Present Registration Status of Alternatives	  PAGEREF _Toc125867720 \h 
24  

  HYPERLINK \l "_Toc125867721"  Ornamentals –Liatris- Table 16.1:
Effectiveness of Alternatives – Diseases and Weeds	  PAGEREF
_Toc125867721 \h  25  

  HYPERLINK \l "_Toc125867722"  Ornamentals – Ranunculus - Table 16.2:
Effectiveness of Alternatives – Weeds	  PAGEREF _Toc125867722 \h  27  

  HYPERLINK \l "_Toc125867723"  Ornamentals – Ranunculus – Table
16.3: Effectiveness of Alternatives – Weeds	  PAGEREF _Toc125867723 \h
 30  

  HYPERLINK \l "_Toc125867724"  California Ornamentals – Table C.1:
Alternatives Yield Loss Data Summary	  PAGEREF _Toc125867724 \h  30  

  HYPERLINK \l "_Toc125867725"  Florida Ornamentals - Part B: Crop
Characteristics and Methyl Bromide Use	  PAGEREF _Toc125867725 \h  33  

  HYPERLINK \l "_Toc125867726"  Florida Ornamentals - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125867726 \h  33  

  HYPERLINK \l "_Toc125867727"  Florida Ornamentals - Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125867727 \h  34  

  HYPERLINK \l "_Toc125867728"  Florida Ornamentals - Table 11.2
Characteristics of Climate and Crop Schedule - Caladium	  PAGEREF
_Toc125867728 \h  34  

  HYPERLINK \l "_Toc125867729"  Florida Ornamentals - Table 11.3
Characteristics of Climate and Crop Schedule – Cut Flowers	  PAGEREF
_Toc125867729 \h  35  

  HYPERLINK \l "_Toc125867730"  Florida Ornamentals - Table 11.4 Crop
Production for Certain Cut Flower Species	  PAGEREF _Toc125867730 \h  36
 

  HYPERLINK \l "_Toc125867731"  Florida Ornamentals - Table 11.5 Other
Cut Flower Species Grown in Florida	  PAGEREF _Toc125867731 \h  36  

  HYPERLINK \l "_Toc125867732"  Florida Ornamentals - Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125867732 \h  37
 

  HYPERLINK \l "_Toc125867733"  Florida Ornamentals - Part C: Technical
Validation	  PAGEREF _Toc125867733 \h  38  

  HYPERLINK \l "_Toc125867734"  Florida Ornamentals – Table 13.1:
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125867734 \h 
38  

  HYPERLINK \l "_Toc125867735"  Florida Ornamentals – Table 14.1:
Technically Infeasible Alternatives Discussion	  PAGEREF _Toc125867735
\h  45  

  HYPERLINK \l "_Toc125867736"  Florida Ornamentals – Table 15.1:
Present Registration Status of Alternatives	  PAGEREF _Toc125867736 \h 
45  

  HYPERLINK \l "_Toc125867737"  Ornamentals – Snapdragon – Table
16.1: Effectiveness of Alternatives – Weeds	  PAGEREF _Toc125867737 \h
 47  

  HYPERLINK \l "_Toc125867738"  Ornamentals – Snapdragon – Table
16.2: Effectiveness of Alternatives – Weeds	  PAGEREF _Toc125867738 \h
 48  

  HYPERLINK \l "_Toc125867739"  Florida Ornamentals – Table C.1:
Alternatives Yield Loss Data Summary	  PAGEREF _Toc125867739 \h  48  

  HYPERLINK \l "_Toc125867740"  Michigan Herbaceous Perennials. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request	 
PAGEREF _Toc125867740 \h  50  

  HYPERLINK \l "_Toc125867741"  Michigan Herbaceous Perennials. Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125867741 \h  50 


  HYPERLINK \l "_Toc125867742"  Michigan Herbaceous Perennials. Table
11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125867742 \h  51  

  HYPERLINK \l "_Toc125867743"  Michigan Herbaceous Perennials. Table
12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125867743
\h  52  

  HYPERLINK \l "_Toc125867744"  Michigan Herbaceous Perennials – Table
13.1: Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125867744
\h  53  

  HYPERLINK \l "_Toc125867745"  Michigan Herbaceous Perennials – Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125867745 \h  56  

  HYPERLINK \l "_Toc125867746"  Michigan Herbaceous Perennials. Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125867746 \h  56  

  HYPERLINK \l "_Toc125867747"  Michigan Herbaceous Perennials
–Hosta– Table 16.1: Effectiveness of Alternatives – Inula
brittannica	  PAGEREF _Toc125867747 \h  57  

  HYPERLINK \l "_Toc125867748"  Michigan Herbaceous Perennials. Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125867748 \h  58
 

  HYPERLINK \l "_Toc125867749"  Part D: Emission Control	  PAGEREF
_Toc125867749 \h  59  

  HYPERLINK \l "_Toc125867750"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125867750 \h  59  

  HYPERLINK \l "_Toc125867751"  Part E: Economic Assessment	  PAGEREF
_Toc125867751 \h  60  

  HYPERLINK \l "_Toc125867752"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125867752 \h
 61  

  HYPERLINK \l "_Toc125867753"  Table 22.1: Year 1 Gross and Net Revenue
  PAGEREF _Toc125867753 \h  61  

  HYPERLINK \l "_Toc125867754"  Table 22.2: Year 2 Gross and Net Revenue
  PAGEREF _Toc125867754 \h  62  

  HYPERLINK \l "_Toc125867755"  Table 22.3: Year 3 Gross and Net Revenue
  PAGEREF _Toc125867755 \h  63  

  HYPERLINK \l "_Toc125867756"  Table E.1: California Calla Lily & Bulbs
- Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125867756 \h  63  

  HYPERLINK \l "_Toc125867757"  Table E.2: Florida Cut Flowers - Lilies
- Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125867757 \h  64  

  HYPERLINK \l "_Toc125867758"  Table E.3: Florida - Caladium - Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125867758 \h  64  

  HYPERLINK \l "_Toc125867759"  Region H - Michigan Herbaceous
Perennials - Table E.4: Economic Impacts of Methyl Bromide Alternatives	
 PAGEREF _Toc125867759 \h  64  

  HYPERLINK \l "_Toc125867760"  Part F. Future Plans	  PAGEREF
_Toc125867760 \h  67  

 

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 Cut
Flower, Bulb, and Herbaceous Perennial Ornamentals Grown in Open Fields
or in Protected Environments (Submitted in 2006 for Use in 2008)



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



In the United States cut flower, cut foliage and bulb crops are grown in
open fields and under cover (including glass, poly, and saran).  In
1997, eight percent of the ornamentals in the United States were grown
under cover and 92 percent were grown in the open.  There are three
basic systems in place for ornamentals.  Annuals are shallow rooted
crops that represent 50 to 60 percent of the industry.  They are often
planted to a depth of 6 to 8 inches.  Fumigants can be shanked into the
preformed beds or drip-applied from drip tapes placed on top of beds
under plastic mulch.  Bulb crops represent about 30 percent of the
industry.  Fumigants are applied by deep shanking.  Bedding up generally
occurs after planting the bulbs.  Perennials are deep-rooted multi-year
crops and represent 10 to 20 percent of the industry in California. 
Fumigation needs to penetrate to a depth of 2 to 3 feet and may require
multi-level shanking.  

Methyl bromide is used in almost all saran house production – snap
dragons, asters, gerbera daisies, mums, etc, as a broadcast solid tarp
treatment.  It is used in field grown statice and gypsophila as an
in-bed treatment.  In some gladiolus production, methyl bromide is used
broadcast solid tarp for increased of cormels and tissue culture stock
(Ragsdale, 2004).

This nomination is for multiple species (see Appendix B).  Only a subset
of the cropping systems will be explained.  For Florida this will
include caladiums and general cut flower production.  In California,
ranunculus will be used as an example.  Herbaceous perennials in
Michigan and Illinois will also be described.  This industry changes
rapidly and therefore, the species and varieties grown also changes. 
For example, several years ago, sunflowers were not a major crop in
Florida but now they are.

Caladiums are grown in Florida on either sandy or muck soils.  They are
planted from the middle of March until mid April.  Caladiums are dug
annually from November until the middle of March.  The tubers are
cleaned, graded, repacked, and stored until shipment to customers
throughout the world.  Methyl bromide is applied in the short time
period between the end of harvest of one crop and the planting of the
next.

In Florida, some of the typical cut flowers grown are snapdragons,
lilies, gladiolus, lisianthus, delphinium, and sunflowers.  Growers
rotate to other cut flower species, but not to other crops.  Planting
occurs between August and March, with harvesting occurring October
through May.  Two to three plantings occur each year, with only one
application of methyl bromide each year.  

Ranunculus are grown as annuals in the field.  In fall, seeds are
planted on beds.  Flowers are harvested in the spring and the tubers are
harvested in July and August.  These tubers are used in landscaping and
are planted in the fall (Elmore et al., 2003b).  The tubers, which are
distributed worldwide, are also used in commercial production.

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

Without methyl bromide, growers will suffer both yield and quality
losses.  There is a need to control previous planted varieties to
eliminate contamination, as well as control other weeds and pathogens. 
Some of the alternatives that have been found for other crops are not
feasible for some floriculture crops because of high cost, difficulties
with quickly treating and replanting fields for multi-cropping, and
buffer zone requirements.  In California, township caps limit the use of
1,3-D as an alternative.  Although some alternatives have shown
potential to replace methyl bromide use in some situations, the in-field
feasibility of the alternatives for each of the major species of
ornamentals grown in the United States remains to be demonstrated.  The
industry has made progress in reducing the use of methyl bromide and
additional research is ongoing.  Additional time is needed to complete
the phase-out of methyl bromide in this sector due to the complexity of
production (numerous species, each with its own pests and implementation
issues) and the lack of scientifically proven alternatives.

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	138,538	516

* Includes research amount of 4,060 kgs.

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. ornamental 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
ornamental production.

Key target pests:   the U.S. is only nominating a CUE where the key pest
pressure is moderate to high.

Regulatory constraints: e.g., in some areas of the United States
1,3-Dichloropropene use is limited due to township caps in California.

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

Overall, the ornamentals industry has hundreds of crop species and
thousands of varieties.  This diversity makes finding methyl bromide
alternatives for each crop species complex, time consuming and costly
(Schneider, 2003).  

As part of the overall ornamentals industry, the cut flower, foliage,
and bulb industry is very complex.  For example, a single grower in
California may grow as many as 100 species and/or varieties in a single
year.  Growers must find methyl bromide alternatives that will control
previous crops grown on the site, as well as a diversity of key pests,
which vary for each crop variety.  For example, in ranunculus, residual
tubers, bulbs, and seeds from the previous crop must be killed because
they are reservoirs for nematodes and soil pathogens and considered to
be weeds themselves as they are off-variety.  Along with these issues,
there are concerns about phytotoxicity and registration with alternative
chemicals (Schneider, 2003; Elmore et al., 2003b).  Recent experiences
with iodomethane indicate that new chemistries can take several years to
be registered by the U.S. EPA and the state regulatory agencies, such as
California Department of Pesticide Regulation.  In addition, township
caps in California restrict the amount of 1,3-Dichloropropene that can
be used in a given area (Trout, 2001).  Buffer zones may also limit the
adoption of alternatives.

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

Region	California	Florida	Michigan

Amount of Applicant Request

2008  Kilograms	204,116	622,328	4,763

Amount of Nomination*

2008  Kilograms	67,946	63,232	3,300

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

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



In California, township caps for 1, 3-Dichloropropene limit the number
of growers that are able to use 1,3-D + chloropicrin.  Further, because
the ornamentals industry is complex, time is needed to determine methyl
bromide alternatives for all species and varieties grown, including
determining whether there are any phytotoxicity issues from using methyl
bromide alternatives (Schneider, 2003).  Some of the alternatives that
have been found for other crops are not  feasible for floriculture
because of their high cost, difficulties with quickly treating and
replanting fields for multi-cropping, and/or buffer zone requirements
(Elmore, 2003a).  Ornamentals have a high value; as a result many
manufacturers now avoid registering materials for ornamental crops
because of liability due to potential phytotoxicity issues.

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 (ha)
Proportion of total crop area treated with methyl bromide (%)

Ornamentals – California1	10,054	Not Available

Cut Flower and Foliage – FL2	7,111	Not Available

Caladium – FL2	642	Not Available

Michigan and Illinois - Floriculture Crops3	2662	<1

Regional Total:	17,807	Not available

National Total:	Not Available	Not Available

1 2000 California Department of Pesticide Regulation Data

2 Based on information from experts in Florida

3  USDA 2002 Census of Agriculture

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.



Given the number and diversity of species grown in the industry, there
are a number of reasons why methyl bromide is not used.  Some crops have
been able to switch to alternatives.  For example, growers in Oregon are
now using 1,3-Dichloropropene for Easter lilies. Also, some species may
not need methyl bromide, depending on their key pests and the ability to
use alternatives.

Growers are also maximizing their use of methyl bromide.  Instead of
fumigating after each crop (more than once a year), producers may grow
several crops over 1 to 2 years on the same piece of land, using methyl
bromide only when necessary instead of after every crop, and thus
reducing the amount used.  Cropping systems have been changed to allow
most sensitive crops to be planted immediately following a fumigation
followed by several other types of plants in decreasing sensitivity to
soil pathogens.  Costs of fumigation alone made this a critical change
in cut flower production.  In addition, some perennials may be grown for
5 to 25 years.  Methyl bromide would only be used once during this
cycle.  

In this industry, the fumigation situation and need for methyl bromide
varies by species.  Although there are some potential alternatives,
there is not enough scientific or grower experience for all crop species
to switch to alternatives at this time.  One major difficulty is that
market desires require a high degree of flexibility in scheduling
certain species and new cultivars.  Therefore, the information on the
sensitivity of each crop to fumigant alternatives as well as the pests
is not known until crops have been in production for at least a few
cycles.

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?



Not all of the above methods and alternatives being used are feasible
for other crops.  However, the industry is working to find alternatives
to methyl bromide.  New products will be incorporated into commercial
practice as they become available.

Specifically, township caps in California limit the use of
1,3-Dichloropropene.  Many of the crops are grown in coastal areas,
where cut flowers are also grown.  It is expected that about 30 percent
of the 2000 fumigated cut flower acres could not have used 1,3-D at the
current 2X cap, which is expected to apply through at least 2004.  This
number would be higher with the standard (1X) caps.  Affecting some
rotations are plant back times, which can be 1 to 2 weeks longer with
1,3-D.  Combined regulatory and plant back limitations could restrict
use of 1,3-D in California to less than 50 percent of the current
fumigated area  (Trout, 2003; Ragsdale, 2004).  In addition, an
alternative that works for one crop species may not control the key
pests of another species or it could be phytotoxic to the other species.
The industry needs additional time to complete ongoing research to find
and implement alternatives for each species. 

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

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

Region: 	California	Florida	Michigan

Year of Exemption Request	2008	2008	2008

Kilograms of Methyl Bromide	204,116	622,328	4,763

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

Formulation (ratio of methyl bromide/Chloropicrin mixture) to be used
for the CUE	67:33	67:33	98:2

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	809	1,416	12

Application rate* (kg/ha) for the Active Ingredient	252	439	392

Dosage rate* (kg/ha) of Active Ingredient used to calculate requested kg
of methyl bromide	25.2	43.9	39.2



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

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

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



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



California Ornamentals - Table 10.1: Key Diseases and Weeds and Reason
for Methyl Bromide Request  TC "California Ornamentals - 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 needed 

California	All soil borne diseases, weeds, and nematodes.  Includes
Fusarium spp., Rhizoctonia spp., Phytoplithora, Stromatinia, Pythium
spp., and most soil nematodes i.e. Meloidogyne spp., and previous crop
propagules.  Specific pest problems vary by individual crop and variety.
 See Appendix C for more detailed information.	Due to the diversity and
complexity of the cut flower and foliage industry, additional time is
needed to complete ongoing research into implementation of methyl
bromide alternatives and to allow time for registering materials. 
Alternatives have not been found for all species.  Some of the
alternatives that have been found for other crops may not be feasible
for floriculture because of high cost, phytotoxicity issues,
difficulties with quickly treating and replanting fields for
multi-cropping, township caps, and buffer zone requirements (Elmore et
al., 2003a).  



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



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

Characteristics	Ornamentals

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Cuttings, bulbs

Annual or Perennial Crop: (# of years between replanting) 	Annual and
perennial

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	A California cut flower producer may grow more
than 20 ornamental species and hundreds of individual varieties.  Crops
are grown in rotation on an 8 to 16 week interval per year on the same
parcel of land.  Although species are rotated, the complex nature of
this crop makes a typical crop rotation difficult to identify.  Instead,
an example of a rotation will be described here.  

A crop rotation system for a grower may involve several annuals.  The
first annual crop is planted and harvested 90 to 180 days later.  A
different species is planted immediately after the first harvest. 
Harvest follows approximately 90 to 180 days later.  A third crop is
then planted.  Fumigation would occur when the production starts to
decline, which may be an interval of one to two years.

Most growers produce numerous species, including annuals, perennials,
and bulbs, throughout the farm.  The rotation involving all of these
species would be more complex than the example above.  

Soil Types:  (Sand, loam, clay, etc.)	All.  Cut flowers in California
are primarily produced in the coastal environment where nearly all types
of soil are present.

Frequency of methyl bromide Fumigation: (e.g. every two years)	In
general, once every year although it may occur less often on a
substantial portion of the acreage in this sector that produce
perennials and gladiolus. 

Other relevant factors:	None identified.



Tables 11.2, 11.3, and 11.4 are examples of the characteristics of
climate and crop schedule for cut flowers, foliage and bulbs planted in
the fall and in the spring, and ranunculus.  These characteristics may
vary for different species.

California Ornamentals - Table 11.2 Characteristics of Climate and Crop
Schedule – Fall Plantings  TC " California Ornamentals - Table 11.2
Characteristics of Climate and Crop Schedule – Fall Plantings" \f F \l
"1"  

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

Climatic Zone	

9a – 11 Plant hardiness zone.



Rainfall (mm)*	0	Trace	1.0	Trace	0	44.7	56.9	9.9	30.5	16.0	72.1	17.3

Outside Temp. ((C)*	25.7	30.3	27.4	25.1	18.4	13.4	9.6	10.3	10.6	14.4
14.8	20.8

Land Preparation	X	X	X	X	X







	Fumigation Schedule

X	X	X	X







	Planting 

Schedule

X	X	X	X







	Harvest Schedule







X	X	X	X	X

*Data for Jan-Aug, 2003 and Sep-Dec 2002 for Fresno, California.

California Ornamentals - Table 11.3 Characteristics of Climate and Crop
Schedule – Spring Plantings  TC " California Ornamentals - Table 11.3
Characteristics of Climate and Crop Schedule – Spring Plantings" \f F
\l "1"  

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

Climatic Zone	

9a – 11 Plant hardiness zone.



Rainfall (mm)*	16.0	72.1	17.3	0	Trace	1.0	Trace	0	44.7	56.9	9.9	30.5

Outside Temp. ((C)*	14.4	14.8	20.8	25.7	30.3	27.4	25.1	18.4	13.4	9.6
10.3	10.6

Land Preparation	X











	Fumigation Schedule	X	X











Planting 

Schedule

X	X	X	X







	Harvesting Schedule



X	X	X	X	X





*Data for Jan-Aug, 2003 and Sep-Dec 2002 for Fresno, California.

California Ornamentals - Table 11.4 Characteristics of Climate and Crop
Schedule – Ranunculus  TC " California Ornamentals - Table 11.4
Characteristics of Climate and Crop Schedule - Ranunculus" \f F \l "1"  

The ranunculus crop is different from other cut flower, foliage, and
bulb crops because they have two planting sequences to ensure long
season availability of the product.  The first sequence occurs on a very
small percent of the acreage and used only to produce cut flowers.  It
begins with land preparation in May followed by fumigation in June. 
Planting occurs in June and July and flowers are harvested from
September through February.  The main planting is used to produce both
cut flowers and bulbs.  Land preparation occurs in August followed by
fumigation in September and October.  Planting occurs from September
through December with harvesting of cut flowers occurring from February
through May (possibly into June in some years).  

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

Climatic Zone	

9a – 11 Plant hardiness zone.



Rainfall (mm)*	16.0	72.1	17.3	0	Trace	1.0	Trace	0	44.7	56.9	9.9	30.5

Outside Temp. ((C)*	14.4	14.8	20.8	25.7	30.3	27.4	25.1	18.4	13.4	9.6
10.3	10.6

Fumigation Schedule



X

Land prep	X	X





Planting 

Schedule



	X (very small area)

X	X	X	X



Key Market Window	X	X	X	X

	X	X	X	X	X	X

*Data for Jan-Aug, 2003 and Sep-Dec 2002 for Fresno, California.

Tables 11.5 and 11.6 provide examples of potential scenarios involving
multi-crop rotations after a single methyl bromide fumigation.  There
are other crop species that could also be planted.  These crops are
often susceptible to the same pests.

California Ornamentals - Table 11.5 Characteristics of Climate and Crop
Schedule – Multiple Crop Rotation Scenario One  TC "California
Ornamentals - Table 11.5 Characteristics of Climate and Crop Schedule
– Multiple Crop Rotation Scenario One" \f F \l "1"  

	Win 1 	Spr 1	Sum 1	Aut 1	Win 2	Spr 2	Sum 2	Aut 2	Win 3	Spr 3	Sum 3	Aut
3

Chrysanthemums

	X	X	X







	Iris (Dutch)



	X	X







Liatris





X	X





	Hypericum





	X	X	X	X	X	(continuing until summer 5)

Win = winter, spr = spring, sum = summer, aut = autumn

California Ornamentals - Table 11.6 Characteristics of Climate and Crop
Schedule – Multiple Crop Rotation Scenario Two  TC "California
Ornamentals - Table 11.6 Characteristics of Climate and Crop Schedule
– Multiple Crop Rotation Scenario Two" \f F \l "1"  

	Win 1 	Spr

1	Sum 1	Aut 1	Win 2	Spr 2	Sum 2	Aut 2	Win 3	Spr 3	Sum 3	Aut 3

Ranunculus

	X	X	X







	Stock



	X	X	X





	Iris (Dutch)







X	X



	Liatris







	X	X	X

	Win = winter, spr = spring, sum = summer, aut = autumn

In one study, the schedule for liatris was fumigation in November,
planting in December, and harvest in April (Gerik, 2005a).

It is difficult to determine acreage information for cut flowers. 
However, production data for the major cut flower and bulb species grown
is available (See Table 11.5) and estimates of the acreage have been
made (See Table 11.6).

California Ornamentals - Table 11.6 Production of Major Species  TC
"California Ornamentals - Table 11.6 Production of Major Species" \f F
\l "1"  

Species	# Flower Bunches in 2003

Alstroemeria	892,789

Carnations	1,694,870

Delphinium	3,617,186

Gladiolus	Data not released

Gerbera	62,638,650

Iris	5,823,242

Lilium	6,247,027

Chrysanthemums	1,273,742

Pompons	6,350,127

Roses	7,360,729

Snapdragons	2,976,219

	Source: Prince & Prince, Inc. Survey, 2003

This survey is the only source of information but may under report data.
 Also, the number of stems/bunch is not the same for all crops.

California Ornamentals - Table 11.7 Partial Listing and Estimate of Cut
Flower and Foliage Area Produced in California in 2002  TC "California
Ornamentals - Table 11.7 Partial Listing and Estimate of Cut Flower and
Foliage Area Produced in California in 2002" \f F \l "1"  

Crop	Area (usually field) - ha	Area (usually greenhouse) – m2

Alstroemeria	8 (0.3%)	47,100 (3.2 %)

Antirrhinum (snapdragon)	126 (5%)	164,898 (11.3%)

Aster

57,598 (4%)

Calla lily	16 (0.6%)

	Carnation	30 (1.2%)	21,739 (1.5%)

Chrysanthemum	88 (3.3%)	281,023 (19 %)

Delphinium	22 (0.8%)

	Eucalyptus	54 (2%)

	Gerbera

214,413 (14.7%)

Gypsophila	55 (2%)

	Iris (Dutch)	18 (0.7%)

	Larkspur	6 (0.2%)

	Lilium	32 (1.2%)	205,959 (14.2%)

Limonium spp.	13 (0.5%)

	Lisianthus	13 (0.5%)

	Protea	190 (7.3%)

	Rose	41 (1.6% - all greenhouse)	123,557 (8.5%)

Stock (Matthiola)	26 (1%)

	Wax flower	317 (12%)

	Other	791 (30%)	59,177 (4%)

Greenhouse misc.	70 (2.7%)	278,700 (19%)

Field misc.	303 (11.6%)

	Cut greens misc.	389 (15%)

	Total	2609	1,454,164 (145 ha)



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



Cut flowers are often marketed for a certain time of year or holiday. 
Missing specific dates can be detrimental to the grower.

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



California Ornamentals - Table 12.1 Historic Pattern of Use of Methyl
Bromide  TC "California Ornamentals - 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)	552	576	332	364	281	Not Available

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Nearly all Flat Fumigation	Nearly all Flat Fumigation
Nearly all Flat Fumigation	Nearly all Flat Fumigation	Nearly all Flat
Fumigation	Nearly all Flat Fumigation

Amount of methyl bromide active ingredient used 

(total kg)	163,506	157,401	85,211	65,079	70,813	Not Available

formulations of methyl bromide

(methyl bromide /chloropicrin)	67:33; 98:2	67:33; 98:2	67:33; 98:2
67:33; 98:2	67:33; 98:2	67:33; 98:2

Method by which methyl bromide applied 	Chiseled or shanked	Chiseled or
shanked	Chiseled or shanked	Chiseled or shanked	Chiseled or shanked
Chiseled or shanked

Application rate of Active Ingredient in kg/ha*	296	273	256	179	252	Not
Available

Actual dosage rate of Active Ingredient (g/m2)*	29.6	27.3	25.6	17.9	25.2
Not Available



The application rate includes both outdoor and greenhouse use.  The
outdoor use rate is lower than the greenhouse rate.  For example, in
2002 the outdoor use rate was 178 kg/ha and the greenhouse rate was 318
kg/ha.  

Growers are expected to use a 67:33 formulation in the future, although
this may vary depending on the crop grown and the pest situation.  The
50:50 formulation is not feasible because adequate control of weeds
cannot be achieved.  

California Ornamentals - Part C: Technical Validation  TC "California
Ornamentals - Part C: Technical Validation" \f F \l "1"    TC
"California Ornamentals – Part C: Technical Validation" \f C \l "1"  



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



California Ornamentals – Table 13.1: Reason for Alternatives Not Being
Feasible  TC "California Ornamentals – 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 is not very efficacious on its own for weed
and disease control. Buffer zones make using this alternative difficult
because flowers are often produced on small parcels of land, often near
homes.  1,3-D cannot be used in greenhouses.

Township caps are in place for 1,3-D that limit its use in California. 
Many of the crops are grown in coastal areas, where cut flowers are also
grown.  It is expected that about 30 percent of the 2000 fumigated cut
flower acres could not have used 1,3-D at the current 2X cap, which is
expected to apply through at least 2004. This number would be higher
with the standard (1X) caps.  Affecting some rotations are plant back
times, which can be 1 to 2 weeks longer with 1,3-D.  Combined regulatory
and plant back limitations could restrict use of 1,3-D in California to
less than 50 percent of the current fumigated area  (Trout, 2003;
Ragsdale, 2004).  

	No.

Metam sodium	Performance with metam sodium is erratic and inconsistent,
depending on soil type, moisture content, and temperature. Many years of
research have indicated difficulty achieving consistent efficacy with
metam sodium on high value crops.  Also, pest populations tend to build
up over time with metam sodium.  Repeat use results in an increase in
the population of bio-degraders of the active ingredient.  Problematic
for bulb growers is the fact that it suppresses active nematodes, and
not the eggs.  

Buffer zones make using this alternative difficult because flowers are
produced on small parcels of land.  Also, this alternative is not
labeled for greenhouse use in California.  In addition, the plant back
restrictions may cause some growers to be able to grow fewer crops in a
year.  

This fumigant is currently used and will continue to be used where it
gives adequate pest control.  In some cases it is used to suppress pest
populations between methyl bromide treatments.  While this reduces the
number of times methyl bromide must be applied, it does not eliminate
the need for methyl bromide.  It is unlikely that metam sodium will
replace significant portions of the current use of methyl bromide.

	No

Dazomet (Basamid)	In some cut flowers (carnation and chrysanthemum)
dazomet was effective against Fusarium, Rhizoctonia, Erwinia, and
Pseudomonas.  Appropriate aeration times, which are dependent on soil
temperature, are needed to avoid phytotoxicity (Semer, 1987).  In
addition, plant back restrictions may cause some growers to be able to
grow fewer crops in a year.

	No.

Chloropicrin	Chloropicrin may not currently be used in greenhouses in
California.  In California, buffer zones vary with county and condition
in California.  Buffer zones of 30 meters in sensitive areas make using
this alternative difficult because flowers are produced on small parcels
of land.  There is reluctance to use chloropicrin in many areas due to
the proximity of cut flower fields to residences.  Several California
counties impose large buffers (>152 meters) and restrict rates to less
than 224 kg/ha.  Weed control is also poorer than with methyl bromide
(Ragsdale, 2004).  Adequate efficacy for the pest complex cannot be
achieved with lower use rates.  

	No.

MITC	Same issues described above for metam sodium and dazomet.	No.

Non Chemical Alternatives

Biofumigation	Biofumigation is still largely in the experimental stages.
 (Pizano, 2001).  Specific brassicas as well as specific years yield
variable amounts of activity.  While this alternative may provide some
control, the control of all target pests is not sufficient.  Also,
brassica waste must be available in huge quantities to provide at best
minor effects.  The extremely large volume of raw material required
makes this impractical.	No.

Solarization	Solarization takes several weeks to control many pests to a
depth of 30 cm.  This length of time for a treatment is not economically
feasible in the intensive, year-round production situation of the cut
flower industry (Pizano, 2001).  Production areas in California are
mainly coastal where solarization is not feasible due to cool
temperatures and cloud cover most of the year.	No.

Steam	Steam can be a technically effective alternative in some cases. 
Reasons cited for not using steam for this crop system are high initial
cost and high application costs limit widespread use.  Some greenhouse
growers have adapted this approach already in crops where it works
better (such as Freesia).  In-field steaming is not a feasible
alternative due to lack of machinery that can deliver the steam,
differences in soil type, and environmental impact of fuel use.	No.

Biological control 	Results with biological control agents may vary with
field or environmental conditions (Pizano, 2001).  Even in small
containers, biological control is not reliable for soil-borne pathogens.
No.

Crop residue compost/Crop rotation/fallow	Rotation with other cut flower
species is used extensively in cut flower production.  However, in
annual cropping they are generally too short for the full effects of
rotating schemes to be effective. The previous crop (bulbs, corms) often
contaminate the following crop or may harbor pathogens.  In addition,
crop rotation is not really a solution to pest problems in floriculture
because either the crop cycle is too long (perennials) or the pests
persist in the soil for a long time (Pizano, 2001).  Most cut flower
species are sensitive to the same pathogens.  Flower rotations are
generally not a true rotation in the pest control sense.  

Some growers have had success with crop rotation.  In California, some
gladiolus growers are leasing land to strawberry growers.  The
strawberry growers fumigate the land with methyl bromide, and a crop of
gladiolus can follow without additional methyl bromide fumigation.  This
practice is most feasible for large growers and requires flexibility. 
This arrangement is not feasible for calla lily growers because calla
lilies are very susceptible to the root disease complex supported by
strawberries and raspberries.  	No.

Flooding and water management	Beds are generally designed and graded for
good drainage to prevent standing water.  Flooding could increase the
incidence of certain diseases and is also time restrictive. 
Environmental laws prohibit run-off in most of the state of California
making use (and often access) to water in this manner impossible.	No.

General IPM	Although IPM is currently practiced, this alone will not
control weed and disease pests.	No.

Grafting/resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding are not feasible alternatives.  Given the
thousands of varieties of ornamentals, plant breeding for the variety of
pests is not practical.	No.

Organic amendments/compost	Not effective alone in weed or pest
management; may be incorporated as part of an IPM program.  Does not
provide adequate weed and disease control.	No.

Physical removal/sanitation	Appropriate sanitation practices are already
used extensively.  Also, a recent law banning hand weeding restricts the
use of this practice in California.	No.

Resistant cultivars	Given the thousands of varieties of ornamentals,
developing resistant cultivars for each variety, each with unique pest
problems, is not practical.  Choices are often market driven.	No.

Soilless culture / Substrates /plug plants	Container production may be
possible in higher value cut flower crops but it is not generally
feasible, especially for deeper rooted crops and on large acreage.  	No.

Combinations of Alternatives

1,3-Dichloropropene + chloropicrin	In California, 1,3-D use is limited
by township caps, buffer zones, and plant back times, which could affect
some rotations.  1,3-D cannot be used in greenhouses. 

In California, limitations to chloropicrin include buffer zones, poorer
weed control than methyl bromide, and that it may not currently be used
in greenhouses.  There is reluctance to use chloropicrin in many areas
due to the proximity of cut flower fields to residences.

In Florida, 1,3-D + chloropicrin, followed by metam sodium a week later,
has shown control of diseases and nematodes, but does not adequately
control weeds.  However, consistent efficacy has not been seen in
California.	No.

1,3-Dichloropropene + chloropicrin + pebulate	Pebulate is currently not
registered.  

In California, 1,3-D use is limited by township caps, buffer zones, and
plant back times, which could affect some rotations.  1,3-D cannot be
used in greenhouses. 

In California, limitations to chloropicrin include buffer zones, poorer
weed control than methyl bromide, and that it may not currently be used
in greenhouses.  There is reluctance to use chloropicrin in many areas
due to the proximity of cut flower fields to residences.	No.

Dazomet (Basamid) + chloropicrin	In some cut flowers (carnation and
chrysanthemum) dazomet was effective against Fusarium, Rhizoctonia,
Erwinia, and Pseudomonas.  Appropriate aeration times, which are
dependent on soil temperature, are needed to avoid phytotoxicity (Semer,
1987).  In addition, plant back restrictions may cause some growers to
be able to grow fewer crops in a year.

In California, limitations to chloropicrin include buffer zones, poorer
weed control than methyl bromide, and that it may not currently be used
in greenhouses.  There is reluctance to use chloropicrin in many areas
due to the proximity of cut flower fields to residences.	No.

Metam sodium + chloropicrin	In California, limitations to metam sodium
include buffer zones, greenhouse uses are not labeled, and plant back
restrictions.  In addition, many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops. 

Good disease control can be provided by chloropicrin.  In California,
limitations to chloropicrin include buffer zones, poorer weed control
than methyl bromide, and that it may not currently be used in
greenhouses.  There is reluctance to use chloropicrin in many areas due
to the proximity of cut flower fields to residences.  

In general, weed and nematode control is not adequate with this
combination.  In addition, these chemicals would have to be applied
separately, requiring two applications.

	No.

Metam sodium + crop rotation	In California, limitations to metam sodium
include buffer zones, greenhouse uses are not labeled, and plant back
restrictions.  In addition, many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops. 

Rotation would be to other flower crops.  In annual cropping they are
generally too short for the full effects of rotating schemes to be
effective. The previous crop (bulbs, corms) often contaminate the
following crop or may harbor pathogens.  In addition, crop rotation is
not really a solution to pest problems in floriculture because either
the crop cycle is too long (perennials) or the pests persist in the soil
for a long time (Pizano, 2001).

Instead of applying methyl bromide several times per year, some growers
are rotating to less sensitive crops and treating with metam sodium to
keep pest pressures low.  However, eventually methyl bromide needs to be
applied again or pest pressures will become too high.  In California,
some gladiolus growers are leasing land to strawberry growers.  The
strawberry growers fumigate the land with methyl bromide, and a crop of
gladiolus can follow without additional methyl bromide fumigation.  This
arrangement is not feasible for calla lily growers because calla lilies
are very susceptible to the root disease complex supported by
strawberries and raspberries.  

Complicating crop rotation is the high number of crop species and
varieties, with uncertainties as to their susceptibilities to nematodes
and diseases.   	No.

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

California Ornamentals - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:  TC "California Ornamentals -
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"  



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

Name of Alternative	Discussion

Herbicides and fumigation with methyl bromide, 1,3-D and chloropicrin,
metam sodium and chloropicrin	Herbicides are more feasible for
perennials if they are registered.  The short time interval between
crops (a crop cycle may only last 90 days) often restricts the use of
herbicides due to replant intervals or phytotoxicity.  Also, herbicides
are often selective and there are a limited number registered.  There
are liability concerns due to phytotoxicity concerns on ornamentals.

Sodium azide	Preliminary results in a calla trial suggest that sodium
azide may not be a feasible alternative in this crop due to reduced crop
vigor and increased mortality (Gerik, 2003).



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



California Ornamentals – Table 15.1: Present Registration Status of
Alternatives  TC "California Ornamentals – 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:

Sodium azide	Not registered	Registration package not submitted	Unknown

Propargyl bromide	Not registered	Registration package not submitted
Unknown

Iodomethane	Not registered	Yes	Unknown

Furfural	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.



California Ornamentals - 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 "California
Ornamentals - 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"  



For additional studies on ornamentals, see data included for Florida. 
These studies were separated by location of the study, but some of the
crop species, pests, and other issues are the same.

Evaluation of Soil Fumigants Applied by Drip Irrigation for Liatris
Production (Gerik, 2005a):

In this study, all fumigants were applied through drip irrigation tapes
and high-density polyethylene was used.  A methyl bromide + chloropicrin
comparison was not used because the plots were too small to use a shank
application.  See Table 16.1 for the 2003 results.  Some data from the
study, including 2002 data, are not included in the table.

Near harvest, there was no significant difference in the percent weed
cover in all treatments, although weed control was not considered
adequate.  In addition, the number of inflorescences was not
significantly different among the treatments, although longer stems were
observed with some treatments.  The results for weed control with
drip-applied alternatives are consistent with preliminary results from
another study (see Ajwa, 2005).  

 

Ornamentals – Liatris - Table 16.1: Effectiveness of Alternatives –
Diseases and Weeds  TC "Ornamentals –Liatris- Table 16.1:
Effectiveness of Alternatives – Diseases and Weeds” \f F \l "1"   

Key Pest: Diseases and Weeds	Average disease or Weed % or rating and
yields in 2003

Methyl Bromide formulations and Alternatives 

	# of Reps	Disease Control (CFU/g dry soil)	Weed Control (mean #
weeds/m2)	LIatris Plant Vigor 

	Liatris Avg Height 



Pythium ultimum	Fusarium oxysporum	Total Weeds	rating 1-5	cm

Iodomethane (213 kg/ha) + chloropicrin (213 kg/ha)	6	0	1,113	78	3.8	93

Metham sodium (356 kg/ha)	6	5	1,160	90	3.1	92

Chloropicrin (355 kg/ha), followed by metham sodium (356 kg/ha)	6	1
1,217	50	3.1	93

1,3-Dichloropropene (153 kg/ha) + chloropicrin (83.6 kg/ha)	6	8	1,205
109	3.4	92

1,3-Dichloropropene (153 kg/ha) + chloropicrin (83.6 kg/ha), followed by
metham sodium (178kg/ha)	6	7	1,559	112	3.9	93

1,3-Dichloropropene (153 kg/ha) + chloropicrin (83.6 kg/ha), followed by
metham sodium (356 kg/ha)	6	21	1,420	172	3.9	96

Sodium azide (112 kg/ha)	6	40	1,900	139	3.8	95

Furfural (674 kg/ha) 	6	53	775	128	3.0	86

Fufural (337 kg/ha) + metham sodium (337 kg/ha)	6	2	749	219	3.7	91

DMDS (473 kg/ha)	6	57	620	95	3.1	89

DMDS (237 kg/ha) + chloropicrin ()237 kg/ha)	6	34	1,489	154	3.3	93

Untreated control	6	59	562	78	3.0	88

LSD

37	ns	ns	0.6	4

Gerik, 2005a

Methyl Bromide Alternatives Research and Education for California Cut
Flowers (Ajwa and Elmore, 2005):

Trials were conducted in Carlsbad, California with the crop Ranunculus
during the 2004 production season.  The treatments included:  an
untreated control; and untreated control followed by metam sodium
350.625 L/ha; InLine (1,3-D/chloropicrin) 224 kg/ha; InLine
(1,3-D/chloropicrin) 224 kg/ha followed by metam sodium 350.625 L/ha;
Pic (chloropicrin) 224 kg/ha; Pic (chloropicrin) 224 kg/ha followed by
metam sodium 350.625 L/ha; Midas 33/67 (iodomethane/chloropicrin) 224
kg/ha; and Midas 33/67 (iodomethane/chloropicrin) 224 kg/ha followed by
metam sodium 350.625 L/ha.  There were four replicates for each
treatment and all treatments were drip applied.  For weeds, there was
high variability between replicates and no significant difference
between treatments.  In addition, there was no significant difference in
hand weeding time.  Bulbs from a previous Ranunculus crop were not
controlled by the treatments.  The control actually had fewer residual
Ranunculus bulbs compared to the alternatives, which may be due to
pathogen pressure in the control plots controlling the residual bulbs. 
Diseases, including Fusarium in sachets and in the soil, and Pythiaceous
fungi, were controlled with all treatments except the control.  The
addition of metam sodium likely improved control of Trichoderma across
all treatments.  Crop vigor, flower yield, and bulb yield were
significantly better across all treatments compared to the control.   

In addition, 2005 trials include all of the treatments described above
plus drip applied methyl bromide/chloropicrin and all treatments were
split between HDPE and VIF mulch.  Another trial also compared methyl
bromide/chloropicrin and Midas (iodomethane/chloropicrin) shank applied
using HDPE and VIF mulch.  In a different location, a trial with callas
was conducted using broadcast applied methyl bromide/chloropicrin and
Midas (iodomethane/chloropicrin) under HDPE and VIF mulch.  These
fumigations will be followed by applications of furfural, dimethyl
disulfide, iodomethane, and 2-bromo ethanol.  Drip applied fumigation
trials were also started at this location.  The results are expected in
the future.

Preliminary results are available from phytotoxicity greenhouse trials
conducted on callas.  Iodomethane was applied post-plant to three
varieties of calla at the following rates: 0, 25, 50, 75, 100, and 200
mg/L.  The callas were planted in pots containing 3 kg soil.  Generally,
injury from the treatments was not observed or was minor and
inconsistent across replicates. At iodomethane rates of 75 mg/L and
above, the callas were smaller compared to the control.  However, by 27
days after treatment, the differences were negligible.  In addition,
bulb yield was not affected in terms of weight and size up to a
concentration of 100 mg/L.  These trials are ongoing.

Preliminary Weeding Data from Ajwa MBr Alts Experiment at Silverlake
Ranch in Soledad CA. (Ajwa, 2005): 

Preliminary results from this study indicate that drip-applied fumigants
do not provide adequate weed control in calla lily production compared
to broadcast-applied fumigants.  The treatments evaluated were an
untreated control, methyl bromide/chloropicrin 67:33,
iodomethane/chloropicrin, chloropicrin, and
1,3-dichloropropene/chloropicrin (Inline®).  Each treatment was tested
with and without the addition of metam-potassium and with either
standard or VIF tarp.  There were six replications.  

Preplant Pest Management in Ranunculus Production (Elmore et al.,
2003b):  Results from this study do not compare most of the alternatives
to methyl bromide because most of the alternatives were used in higher
moisture fields and methyl bromide was used in lower moisture fields. 
In lower moisture areas, the plots were treated with methyl
bromide/chloropicrin or iodomethane/chloropicrin.  In the higher
moisture areas, the plots were treated with dazomet or metam sodium.  In
addition, these treatments were followed with either Telone C-35 or
1,3-D plus chloropicrin.  Controls were used in both the low and high
moisture areas. Other treatments included drip applied metam sodium,
iodomethane/chloropicrin, chloropicrin, sodium azide, or 1-3-D
+chloropicrin, but yield results are not available.  In all studies
there were no statistical differences between treatments in either weed
pressure or yield among the alternatives.  In the lower moisture
treatments, there was a 34 percent yield loss between methyl bromide and
the untreated control.  See Table 16.2 below for more detail.  The lack
of differences in the treatments is likely due to the lack of pest
pressure in the higher moisture fields.  The higher moisture fields
needed for certain alternatives were only available in areas not
previously planted to ranunculus, and therefore there was not a buildup
of pest pressure over time (Mellano, 2003).

Ornamentals – Ranunculus - Table 16.2: Effectiveness of Alternatives
– Weeds  TC "Ornamentals – Ranunculus - Table 16.2: Effectiveness of
Alternatives – Weeds” \f F \l "1"  

Key Pest: Weeds	Average disease % or rating and yields in past 3~5 years

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Reps	Weed Control
(Weed Counts per 5 Square Feet)	# of Reps	Actual Yields (Total Bunches)

Lower moisture areas

Malva	Clover



Methyl bromide/chloropicrin (50:50) 358 kg/ha	4	0.8 b	55.5	4	431.8 a

Iodomethane/chlorpicrin (50:50) 336 kg/ha	4	0.5 b	61.1	4	457.6 a

Iodomethane/chloropicrin (50:50) 392 kg/ha	4	0.5 b	43.6	4	426.5 a

Untreated – tarped	4	2.1 a	62.5	4	287.0 b

Higher moisture areas





	Metam sodium + Telone C-35 358 kg/ha + 327 L/ha	4	2.0 b	6.2	4	353.2

Metam sodium + 1,3-D + chloropicrin 358 kg/ha + 140 L/ha + 224 kg/ha	4
2.1 b	4.5	4	357.0

Metam sodium 358 kg/ha	4	3.1 b	3.2	4	357.3

Dazomet + Telone C-35 224 kg/ha + 327 L/ha	4	2.8 b	6.1	4	358.3

Dazomet + 1,3-D + chloropicrin 224 kg/ha + 140 L/ha + 224 kg/ha	4	2.1 b
5.5	4	332.5

Untreated – tarped	4	7.8 a	6.8	4	348.3

Elmore et al., 2003b

Evaluation of Alternatives to Methyl Bromide for Floriculture Crops
(Gerik, 2003 and 2004):  In Trial 1, the following chemical treatments
were evaluated:  untreated control; sodium azide (112 kg ai/ha);
furfural 50% + metam sodium 50% (672 kg ai/ha); 1,3-dichloropropene (272
kg/ha); 1,3-dichloropropene 65% + chloropicrin 35% (627 kg/ha);
iodomethane 50% + chloropicrin 50% (336 kg/ha); iodomethane 33% +
chloropicrin 66% (448 kg/ha); chloropicrin (448 kg/ha).  Drip
applications were used in all treatments.  Sachets with malva and
mustard seed, and nutsedge and calla rhizomes were buried in the plots
before treatment to evaluate weed control efficacy.  None of the
treatments killed the malva seeds.  Chloropicrin controlled the nutsedge
and calla rhizomes.  Mustard seed, Pythium spp. and Fusarium oxysporum
were controlled or reduced by all treatments compared to the untreated
control, in addition to overall weed emergence.  Sodium azide was the
only chemical treatment that did not reduce Phytophthora spp.
populations and resulted in reduced crop vigor and mortality in the
planted calla.  The following factors were all increased across all
treatments, except sodium azide, compared to the control:  number of
flowers per plot, plant height, the number of total bulbs, and number of
salable bulbs.

In Trial 3, the following treatments were evaluated: 1) untreated
control; 2) Multiguard Protect/Metham 50/50 672 kg/ha; 3) Sodium Azide
112 kg/ha; 4) Multiguard FFA; 5) Vapam 935 L/ha; 6) Chloropicrin 336
kg/ha; 7) Inline 468 L/ha; 8) Iodomethane/Chloropicrin 30/70 448 kg/ha
(Midas).  The crop in this trial was liatris.  With the exception of
iodomethane/chloropicrin and the control, the alternatives controlled
Pythium.  The alternatives, except iodomethane/chloropicrin,
chloropicrin, and the control, controlled Fusarium.  Weed control was
comparable among the alternatives in most cases, with Multiguard FFA and
the control providing the least level of control.  Although
iodomethane/chloropicrin did not control pathogens, it is suspected that
it may be due to an application malfunction.  At harvest, there was no
significant difference in yield (stems/m²) 

The crop in trial 8 was freesia.  This trial compared five rates of
Inline: 187 L/ha, 280.5 L/ha, 374 L/ha, 467.5 L/ha, and 523.6 L/ha and a
control.  Control of Pythium ultimum and weeds, including mustard, was
good across all treatments compared to the control.  Also, stems were
taller, and there was better plant vigor across all treatments compared
to the control.  Fusarium yellows was not significantly different for
any of the treatments (including the control).

Freesia was again used in Trial 9.  This trial compared an untreated
control, Midas (50:50) 448 kg/ha, Inline 523.6 L/ha, Multiguard 672
kg/ha, and Multiguard + Vapam 672 kg/ha. Weed counts were lower with all
treatments except the control.  Pythium ultimum control was better with
all treatments with the treatments compared to the control, with the
other treatments providing better control than Multiguard alone. 

Trial 10 was conducted with liatris.  Treatments were:  untreated
control, Midas (50:50) 448 kg/ha, chloropicrin 336 kg/ha followed by
Vapam 701.25 L/ha, InLine 187 L/ha, Inline 187 L/ha + Vapam 350.625
L/ha, Inline 187 L/ha + Vapam 701.25 L/ha, dimethyl disulfide 448 kg/ha,
dimethyl disulfide + chloropicrin (50:50) 448 kg/ha, Vapam 701.25 L/ha,
sodium azide 112 kg/ha, Multiguard 672 kg/ha, and Multiguard + Vapam
(50:50) 672 kg/ha.  Weed pressure was high, and all treatments provided
poor control.  The lowest counts of Pythium ultimum were found with
Midas, chloropicrin + Vapam, Multiguard + Vapam, and Vapam.  Treatements
that did not provide control were Multiguard, sodium azide, dimethyl
disulfide + chloropicrin, and dimethyl disulfide.  The Multiguard,
Vapam, Inline and both dimethyl disulfide treatments did not have better
plant vigor than the control.  Both Multiguard and the dimethyl
disulfide alone treatments did not have improved plant height compared
to the control.  The other treatments did have better plant vigor and
height compared to the control.

Several trials were in progress at the time of the report and not all of
the trials are discussed here.  These trials will be included in a
future report (see below).

Evaluation of Alternatives to Methyl Bromide for Floriculture Crops
(Gerik, 2005b):  

All of the trials described below were conducted using drip irrigation
for the alternatives.  Only three of the trials include a methyl bromide
control but the results of all of the trials are summarized below.

A trial with calla lilies was conducted as Los Coches Rancho near
Soledad, California.  The treatments were: Midas 50/50
(iodomethane/chloropicrin) 336 kg/ha; Midas 50/50
(iodomethane/chloropicrin) 168 kg/ha; Inline (1,3-D/chloropicrin) 359
L/ha; Inline (1,3-D/chloropicrin) 191.675 L/ha; Vapam (metam-sodium)
701.25 L/ha; chloropicrin 336 kg/ha followed by Vapam (metam sodium)
701.25 L/ha a week later; and an untreated control.  The treatments were
made on April 10, 2003.  Nutsedge pressure was high.  The treatments
provided significantly better control of nutsedge compared to the
control during sampling in late April, but the number of nutsedge per
plot was significantly higher than the control for a number treatments
in late June.  All treatments provided significantly better control than
the untreated control for pigweed, lambsquarters, and total weeds per
plot.  Compared to the control, populations of Pythium spp. were
significantly lower with all treatment and populations of Fusarium
oxysporum were lower with all treatments except 1,3-D/Pic at the 191.675
L/ha rate. There were no significant differences for average stand,
percent disease in June 2003, weed counts, number of flowers, total
bulbs, salable bulbs and percent rot.  It is expected that a factor
other than disease or weed pressure, such as a residual herbicide,
affected the growth of the crop in this trial.  

Two trials were conducted at the Amesti Ranch near Watsonville,
California.  The crop in both trials was calla (Z. albomaculata (Hook)
Baill.).  The treatments in the first trial were: Midas 50/50
(iodomethane/chloropicrin) 336 kg/ha; Midas 50/50
(iodomethane/chloropicrin)168 kg/ha; Midas 30/70
(iodomethane/chloropicrin) 448 kg/ha; Midas 30/70
(iodomethane/chloropicrin) 224 kg/ha; Inline (1,3-D/chloropicrin) 359
L/ha; Inline (1,3-D/chloropicrin) 191.675 L/ha; chloropicrin 336 kg/ha
followed by Vapam (metam sodium) 701.25 L/ha a week later; chloropicrin
224 kg/ha followed by Vapam (metam sodium) 701.25 L/ha a week later; and
an untreated control.  Treatments were made in May 2003 and there were
six replications.  Compared to the control, all treatments provided
significantly greater volunteer calla control, Pythium control, higher
vigor ratings, lower disease ratings in July 2004, greater numbers of
total and salable bulbs and higher wholesale value.  In addition,
disease counts in October 2003 and the percent of root rot were
generally better with the treatments compared to the control.  There
were no significant differences between the treatments and control for
the number of nusedge, Fusarium control, and stand counts.  

The second trial at the Amesti Ranch included the following treatments: 
Multiguard FFA 672 kg/ha; SEP-100 840 kg/ha (sodium azide 168 kg ai/ha);
Multiguard Protect + Vapam 50/50) 672 kg/ha; Propylene Oxide 464.8
kg/ha; Agent 2B 448 kg/ha; SEP-100 560 kg/ha (sodium azide 112 kg
ai/ha); dimethyl disulfide (DMDS) 672 kg/ha; DMDS + chloropicrin 50/50
672 kg/ha; and an untreated control.  Only the sodium azide treatments
and the Multiguard + Vapam treatment significantly reduced volunteer
callas.  Treatments had significantly higher vigor rating than the
control except for sodium azide at 168 kg/ha, Multiguard FFA and DMDS
alone.  Vigor ratings taken at a later date showed that DMDS alone and
Multiguard FFA were not significantly better than the control.  There
were no significant differences between the treatments and the control
for stand counts, disease counts, number of nutsedge, Pythium spp.
populations, Fusarium oxysporum populations, percent root rot, total
bulbs, salable bulbs, and value.

A trial with Mellano & Company in San Luis Rey with myrtle (Myrtus
communis L.) was conducted with the following treatments:  untreated
control; Midas 50/50 (iodomethane/chloropicrin) 448 kg/ha; Midas 33/67
(iodomethane/chloropicrin) 448 kg/ha; Inline (1,3-D/chloropicrin) 523.6
L/ha; and Inline (1,3-D/chloropicrin) 359 L/ha.  Significantly fewer
dead myrtle plants were observed with the iodomethane/chloropicrin
treatments and the 1,3-D/chloropicrin 523.6 L/ha treatment compared to
the control.  Compared to the control, F. oxysporum populations were
significantly lower with the 1,3-D/Pic treatments.  Pythium spp.
populations were below the detection limit.  No significant differences
were found for the percentage of plant with new growth and vigor.  This
trial is ongoing.

At Por La Mar Nursery in Goleta, three trials were conducted with the
following treatments:  Methyl bromide/chloropicrin 50/50 448 kg/ha;
Midas 50/50 (iodomethane/chloropicrin) 448 kg/ha; InLine
(1,3-D/chloropicrin) 359 L/ha; and an untreated control.  The crops
planted in these trials were snapdragon, Dutch iris, or stock.  These
trials were conducted on virgin soil.  In all trials, the treatments
provided significantly greater control Pythium spp. than the control. In
the Dutch iris trial, Midas significantly reduced Fusarium populations
compared to the untreated control and methyl bromide/chloropicrin
treatment.  In the stock trial, weed control was considered fair but the
incidence of weeds was low.  Also, all treatments provided inadequate
control of Sclerotinia stem rot.  There were no significant differences
between treatments for Fusarium in the snapdragon and stock trial.  Crop
height was not significantly different between the control and
treatments in any of the trials.

Ornamentals – Ranunculus – Table 16.3: Effectiveness of Alternatives
– Weeds  TC "Ornamentals – Ranunculus – Table 16.3: Effectiveness
of Alternatives – Weeds" \f F \l "1"  

Key Pest: Weeds in Ranunculus	Weed Control and Ranunculus vigor after
preplant Drip application of pesticides in Sandy soil

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Reps	Disease (% or
rating)	# of Reps	Plant Vigor*



Clover (#/linear M)	Total Weeds (#/ Linear M



Metam sodium 364 kg/ha	6	13.5 a	13.7 a	6	9.2 ab

Iodomethane/chloropicrin 392 kg/ha	6	15.3 a	15.3 a	6	8.7 b

Chloropicrin 168 kg/ha	6	9.7 a	10.3 a	6	9.7 ab

Chloropicrin 336 kg/ha	6	12.8 a	13.3 a	6	9.7 ab

Sodium azide 112 kg/ha	6	12.2 a	12.2 a	6	8.7 b

1,3-D/chloropicrin 168 kg/ha	6	11.5 a	11.5 a	6	10.0 a

1,3-D/chloropicrin 336 kg/ha	6	8.3 a	8.3 a	6	9.5 ab

Untreated-tarped	6	15.3 a	16.8 a	6	6.0 c

(Elmore et al., 2003a)

* Visual evaluation: 10 = vigorous, 0 = dead

California Ornamentals – Table C.1: Alternatives Yield Loss Data
Summary



  TC "California Ornamentals – 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 plus chloropicrin 	Nematodes and Diseases (no control of weeds or
previous crop)	10 to 25 %	25%

Dazomet	Multiple

25%

Metam Sodium	Multiple

20%

Overall Loss Estimate for All Alternatives to Pests	20 to 25%



Yield losses will vary by species but, based on expert opinion for two
representative crops, ranunculus and caladiums, an estimate has been
determined.  The experts are a cut flower producer and a researcher
located in different areas of the country.  Based on grower experience,
it is estimated that 10 to 35 percent yield losses could occur without
methyl bromide.  These yield losses may be higher in highly diseased
fields. Quality is also a major concern for the industry. In addition,
ranunculus exported to Japan, Canada, and Europe need a certificate
stating that it has been grown in a manner not conducive to certain
diseases, which generally means in a field fumigated with methyl
bromide.  Even in crops without these regulations, consumers expect a
high quality product.  Selling a product that is not of high quality
will cause growers to lose customers.  There are some promising
alternatives for many crops, but more time is needed to determine what
particular alternatives will work with individual crops to meet customer
standards and avoid yield losses if methyl bromide can no longer be used
(Mellano, 2003).  In ranunculus, a 50 percent yield loss (flowers and
tubers) can occur due to soil pathogens (Elmore et al., 2003b).  

Currently, the applicants do not consider any alternative to be a
feasible replacement for methyl bromide in this diverse sector. 
However, in an attempt to provide an estimate the potential impacts from
the adoption of the most common methyl bromide alternatives, the table
above presents likely yield losses. 

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



Research is currently being conducted to identify potential
alternatives.  Please refer to Section 16 and Section 23.



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



A number of technologies are currently being used in this sector,
including integrated pest management, crop rotation, fallow periods,
hand weeding, etc.  However, these practices are still not sufficient to
control the key target pests without the use of methyl bromide.  The
growers are also trialing plastic culture for medium term crops that
would mimic strawberry production.  However, most crops fall into short
and long term.



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




Without methyl bromide, certain growers of various species will suffer
both yield and quality losses.  In addition growers who rotate several
species of ornamentals on a particular field need to kill crop residue
from previous crops to eliminate contamination, as well as control other
weeds and pathogens.  Due to the diversity and complexity of the cut
flower and foliage industry, an additional 2 to 3 years are needed to
complete ongoing research into implementation of methyl bromide
alternatives.  Alternatives have not been found for all species.  Some
of the alternatives that have been found for other crops (such as 1,3-D
for Easter lilies in Oregon) may not be feasible for floriculture in
general because of high cost, difficulties with quickly treating and
replanting fields for multi-cropping, and buffer zone requirements.  In
addition, township caps limit the use of 1,3-Dichloropropene in
California.  Other alternatives provide inconsistent control or have
restrictions that limit their use at this time.  Growers also need time
to transition to the alternatives.

In this industry, the fumigation situation and need for methyl bromide
varies by species.  Although there are some potential alternatives,
there is not enough grower experience and research to justify to
switching to alternatives by the 2008 growing season.







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



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



Florida Ornamentals - Table 10.1: Key Diseases and Weeds and Reason for
Methyl Bromide Request  TC "Florida Ornamentals - 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 needed 



Florida	All soil borne diseases, weeds, and nematodes.  Includes
Fusarium spp., Rhizoctonia spp., Phytoplithora, Stromatinia, Pythium
spp., Erwinia, and most soil nematodes i.e. Meliodogyne spp., and
previous crop propagules. Specific pest problems vary by individual crop
and variety.  See Appendix C for more detailed information.	These
diseases are common, abundant, and spread through/by water.  Florida has
areas of tropical and sub-tropical climate, which is conducive to the
spread of these diseases. Alternatives have not been found for all
species.  Some of the alternatives that have been found for other crops
may not be feasible for floriculture because of high cost, difficulties
with quickly treating and replanting fields for multi-cropping, and
buffer zone requirements (Elmore et al., 2003a).  Due to the diversity
and complexity of the cut flower and foliage industry, additional time
is needed to complete ongoing research into implementation of methyl
bromide alternatives and to allow time for registering materials.  



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

(Place major attention on the key characteristics that affect the uptake
of alternatives):



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

Characteristics	Ornamentals

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Cuttings, bulbs

Annual or Perennial Crop: (# of years between replanting) 	Annual and
perennial

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	Caladiums are planted between the middle of
March and the middle of April each year.  Caladiums are dug annually
from November until the middle of March.  The fields are fumigated
between harvest and the next planting.

A more complex production system for a grower may involve several
species.  The typical cut flowers grown are snapdragons, lilies,
gladiolus, lisianthus, delphinium, and sunflowers.  Growers rotate to
other cut flower species but not to other crops.  Planting occurs
between August and February, with harvesting occurring October through
May.  Two to three plantings occur each year, with only one application
of methyl bromide each year.  

Most growers produce numerous species, including annuals, perennials,
and bulbs, throughout the farm.  The rotation involving all of these
species would be more complex than the examples above.  

Soil Types:  (Sand, loam, clay, etc.)	All.  Caladiums are grown in
central Florida, mostly on muck but with new acreage on sand. 
Applications on muck soil require a higher application rate because it
is more difficult for the fumigant to be distributed evenly in this soil
type.

Frequency of methyl bromide Fumigation: (e.g. every two years)	In
general, once every year although it may occur less often on a
substantial portion of the acreage in this sector that produce
perennials and gladiolus.  With one methyl bromide application/year,
growers usually get 2 to 3 plantings/year.

Other relevant factors:	None identified.



Tables 11.2 and 11.3 are examples of the characteristics of climate and
crop schedule for two species – caladium and cut flowers.  These
characteristics may vary for individual species.

Florida Ornamentals - Table 11.2 Characteristics of Climate and Crop
Schedule – Caladium  TC " Florida Ornamentals - Table 11.2
Characteristics of Climate and Crop Schedule - Caladium" \f F \l "1"  

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

Climatic Zone	9a – 11 Plant hardiness zone

Rainfall (mm)*	65.5	50.0	72.6	134.1	175.8	193.3	152.7	65.0	42.7	158.8
62.0	66.8

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

Fumigation Schedule	X











	Planting 

Schedule

X











Harvesting Schedule







	X	X	X	X

* Date based on Tampa, Florida records for 1971–2000.

Florida Ornamentals - Table 11.3 Characteristics of Climate and Crop
Schedule – Cut Flowers   TC "Florida Ornamentals - Table 11.3
Characteristics of Climate and Crop Schedule – Cut Flowers" \f F \l
"1"  

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

Climatic Zone	9a – 11 Plant hardiness zone.

Rainfall (mm)*	65.5	50.0	72.6	134.1	175.8	193.3	152.7	65.0	42.7	158.8
62.0	66.8

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

Fumigation Schedule



X	X	X	X	X	X	X	X	X

Planting 

Schedule





X	X	X	X	X	X	X

Harvesting Schedule	X	X	X



	X	X	X	X	X

Date based on Tampa, Florida records for 1971–2000.

According to the 2002 Census of Agriculture, cut flowers and florist
greens were grown on 3,402 ha (outdoors) and foliage plants were grown
on 1,198 ha (outdoors).  Approximately 2,511 additional ha of cut
flowers, florist greens, and foliage plants were grown indoors (under
glass) (2002 Census of Agriculture).

Caladiums are grown on 642 ha.  The remaining area is for other species
of cut flowers, foliage and bulb crops (See Tables 11.4 and 11.5). 
Although it would be useful to have more accurate acreage information
for each species this has been difficult to obtain for several reasons. 
1) There are hundreds of species of cut flowers, foliage, and bulb crops
grown, and often several species are grown in the same field in the same
year.  2) The species grown are constantly changing and fluctuations may
occur at any time.  For example, several years ago sunflowers were not a
major commercial crop in Florida but currently it is a major crop.  3) 
There are no records available that show which crops are grown at any
one time.  Due to the sheer number of species, and the constant
fluctuation in the industry, the acreage of each species is unable to be
determined.  Table 11.4 shows a few of the major crops grown and the
number of spikes or stems produced, although acreage information was not
available.  This information indicates that gladioli are another major
crop grown in Florida, and would be expected to be grown on more acreage
than some of the other crops.  

The only three cut flower species identified by the Florida Agricultural
Statistics Service are gladioli, lilies and snapdragon.  These are
assumed to have the highest acreage (See Table 11.1b below for
production information).  These crops have also been identified by the
applicant as using MB. 

Florida Ornamentals - Table 11.4 Crop Production for Certain Cut Flower
Species2  TC "Florida Ornamentals - Table 11.4 Crop Production for
Certain Cut Flower Species" \f F \l "1"    

	2001	2002	2003

Crop	# of producers	Quantity sold (1000 spikes)1	# of producers	Quantity
sold (1000 spikes)1	# of producers	Quantity sold (1000 spikes)

Gladioli	4	40,331	4	49,581	4	39,444

Snapdragons	5	6,806	4	4,415	4	4,757

Lilies	4	3,031	3	2,257	-	-

Other cut flowers	-	-	9	-	10	-

1 Quantity of lilies sold 1000 stems.

2 This table only includes data for growers with sales over $100,000.

Source: Foliage, Floriculture, and Cut Greens, 2003; Foliage,
Floriculture, and Cut Greens, 2004 

Using several data sources, a rough estimate of the number of acres of
gladioli grown can be obtained.  The quantity sold, shown in Table 11.4,
was averaged and divided by an average yield, which was calculated using
data from 1991 to 1998.  This method resulted in approximately 638 ha of
gladioli.  This number does not take into account the variability in
yield in an individual year or if yields have changed since 1998 (USDA,
1999). 

Florida Ornamentals - Table 11.5 Other Cut Flower Species Grown in
Florida  TC "Florida Ornamentals - Table 11.5 Other Cut Flower Species
Grown in Florida" \f F \l "1"    

Crop	Crop Rotation Limitation

Delphinium	These species are often sensitive to the same insects and
pests as the other cut flower, foliage and bulb species.

Larkspur

	Gerbera

	Lisianthus

	Sunflower

	Aster

	Chrysanthemum

	

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



Caladium

Caladiums are dug annually from November through March 15.  The time
frame between lifting the previous year’s crop and planting the new
crop is about 30 days, or possibly shorter when severe cold temperatures
or unexpected rainfall occurs.  Any product with a fallow
(post-treatment) time of 30 days or more will not work for this industry
as fields must be planted before April 15 each year and cannot be
prepared for planting until the middle of March.  

Cut Flowers

Cut flowers are often marketed for a certain time of year or holiday. 
Missing specific dates can be detrimental to the grower.



Florida Ornamentals - 12. Historic Pattern of Use of Methyl Bromide,
and/or Mixtures Containing Methyl Bromide, for which an Exemption Is
Requested  TC "Florida Ornamentals - 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 Ornamentals - Table 12.1 Historic Pattern of Use of Methyl
Bromide**  TC "Florida Ornamentals - 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)	1,416	1,416	1,416	1,416	1,416	1,416

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Nearly all Flat Fumigation	Nearly all Flat Fumigation
Nearly all Flat Fumigation	Nearly all Flat Fumigation	Nearly all Flat
Fumigation	Nearly all Flat Fumigation

Amount of methyl bromide active ingredient used 

(total kg)	622,328	622,328	622,328	622,328	622,328	622,328

formulations of methyl bromide

(methyl bromide /chloropicrin)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied (e.g. injected at 25cm depth, hot
gas)	Chiseled or shanked	Chiseled or shanked	Chiseled or shanked
Chiseled or shanked	Chiseled or shanked	Chiseled or shanked

Application rate of Active Ingredient in kg/ha*	439	439	439	439	439	439

Actual dosage rate of Active Ingredient (g/m2)	43.9	43.9	43.9	43.9	43.9
43.9

**Based on industry assumptions.

In Florida (FL), the higher rates tend to be used on muck soils and the
lower rates on sandy soils.  Growers are expected to use a 67:33
formulation in the future, although this may vary depending on the crop
grown and the pest situation.  It is not clear that a 50:50 formulation
is feasible.



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



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



Florida Ornamentals – Table 13.1: Reason for Alternatives Not Being
Feasible  TC "Florida Ornamentals – 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 is not very efficacious on its own for weed
and disease control.  Buffer zones make using this alternative difficult
because often flowers are produced on small parcels of land, often near
homes.  1,3-D cannot be used in greenhouses.  

For caladiums, chloropicrin was needed in addition to 1,3-D to reach the
same yield as methyl bromide plus chloropicrin (Overman and Harbaugh,
1983).  The plant-back window for caladiums is variable and the 1,3-D
plant-back interval will limit use on some acres.  In addition, caladium
growers are reluctant to use 1,3-D because it does not control weeds. 
Growers also have to tarp 1,3-D and do not have the equipment to do it
themselves (they can apply metam sodium themselves) (Gilreath, 2004).
No.

Metam sodium	Performance with metam sodium is erratic and inconsistent,
depending on soil type, moisture content, and temperature. Many years of
research have indicated difficulty achieving consistent efficacy with
metam sodium on high value crops.  Also, pest populations tend to build
up over time with metam sodium.  Repeat use results in an increase in
the population of bio-degraders of the active ingredient.  Problematic
for bulb growers is the fact that it suppresses active nematodes, and
not the eggs.  

Buffer zones make using this alternative difficult because flowers are
produced on small parcels of land.  In addition, the plant back
restrictions may cause some growers to be able to grow fewer crops in a
year.  

Metam sodium is used by some growers of caladiums in rotation with
methyl bromide, due to the expense of methyl bromide.  Growers feel that
they can use metam sodium if they used methyl bromide the previous year.
 The growers that have tried using metam sodium 2 years in a row had bad
nematode infestations the second year and will now only use it once
every 2 years.  Most growers will not use metam sodium because they must
meet certification requirements (free of nematodes) for certain markets
(several U.S. states and some international markets) (Gilreath, 2004).  

Studies conducted on snapdragon by McSorley and Wang (2003 and 2004)
showed that this combination provided comparable control to methyl
bromide.  However, the first study contained soils with light pest
pressure because it had previously been treated with methyl bromide +
chloropicrin.  In addition, this site had sandy soils, and different
results could be obtained with other soil types.  In the second year,
the sites were contaminated with weeds seeds and Fusarium spp., so the
results are more difficult to interpret.  Snapdragons reproduce by seed,
so it is not clear if metam sodium is effective for bulb crops,
especially over the long term.  Additional research is needed.  

This fumigant is currently used and will continue to be used where it
gives adequate pest control.  In some cases it is used to suppress pest
populations between methyl bromide treatments.  While this reduces the
number of times methyl bromide must be applied, it does not eliminate
the need for methyl bromide.  It is unlikely that metam sodium will
replace significant portions of the current use of methyl bromide.	No

Dazomet	In some cut flowers (carnation and chrysanthemum) dazomet was
effective against Fusarium, Rhizoctonia, Erwinia, and Pseudomonas. 
Appropriate aeration times, which are dependent on soil temperature, are
needed to avoid phytotoxicity (Semer, 1987).  In addition, plant back
restrictions may cause some growers to be able to grow fewer crops in a
year.	No.

Chloropicrin	There is reluctance to use chloropicrin in many areas due
to the proximity of cut flower fields to residences.  Weed control is
also poorer than with methyl bromide (Ragsdale, 2004).  Adequate
efficacy for the pest complex cannot be achieved with lower use rates.  
No.

MITC	Same issues described above for metam sodium and dazomet.	No.

Non Chemical Alternatives

Biofumigation	Biofumigation is still largely in the experimental stages.
 (Pizano, 2001).  Specific brassicas as well as specific years yield
variable amounts of activity.  While this alternative may provide some
control, the control of all target pests is not sufficient.  Also,
brassica waste must be available in huge quantities to provide at best
minor effects.  The extremely large volume of raw material required
makes this impractical.	No.

Solarization	Solarization takes several weeks to control many pests to a
depth of 30 cm.  This length of time for a treatment is not economically
feasible in the intensive, year-round production situation of the cut
flower industry (Pizano, 2001). 

In a study conducted on snapdragon, McSorley and Wang (2004) showed that
this option had similar yields to the other treatments but the plants
were shorter.  The site was treated with methyl bromide/chloropicrin the
previous crop season, so it is not clear if this could have impacted
results.  The site also had sandy soils, and different results could be
obtained with other soil types.  In addition, the sites were
contaminated with weeds seeds and Fusarium spp. after fumigation and
before planting, so the results are difficult to interpret.  Snapdragons
reproduce by seed, so it is not clear if this combination is effective
for bulb crops, especially over the long term.  Additional research is
needed.  

The study mentioned in the above paragraph also referred to another
study in which solarization in Florida has been successful with
impatiens and vinca. 	No.

Steam	Steam can be a technically effective alternative in some cases. 
Reasons cited for not using steam for this crop system are high initial
cost and an adverse affect on soil organic matter in enclosed
structures.  Some greenhouse growers have adapted this approach already
in crops where it works better (such as Freesia).  In-field steaming is
not a feasible alternative due to lack of machinery that can deliver the
steam, differences in soil type, and environmental impact of fuel use.
No.

Biological control 	Results with biological control agents may vary with
field or environmental conditions (Pizano, 2001).  Even in small
containers, biological control is not reliable for soil-borne pathogens.
No.

Crop residue compost/Crop rotation/fallow	Rotation with other cut flower
species is used extensively in cut flower production.  However, in
annual cropping they are generally too short for the full effects of
rotating schemes to be effective.  The previous crop (bulbs, corms)
often contaminate the following crop or may harbor pathogens.  In
addition, crop rotation is not really a solution to pest problems in
floriculture because either the crop cycle is too long (perennials) or
the pests persist in the soil for a long time (Pizano, 2001).  Most cut
flower species are sensitive to the same pathogens.  Flower rotations
are generally not a true rotation in the pest control sense.  	No.

Flooding and water management	Beds are generally designed and graded for
good drainage to prevent standing water.  Flooding could increase the
incidence of certain diseases and is also time restrictive. 	No.

General IPM	Although IPM is currently practiced, this alone will not
control weed and disease pests.	No.

Grafting/resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding are not feasible alternatives.  Given the
thousands of varieties of ornamentals, plant breeding for the variety of
pests is not practical.	No.

Organic amendments/compost	Not effective alone in weed or pest
management; may be incorporated as part of an IPM program.  Does not
provide adequate weed and disease control.	No.

Physical removal/sanitation	Appropriate sanitation practices are already
used extensively.  	No.

Resistant cultivars	Given the thousands of varieties of ornamentals,
developing resistant cultivars for each variety, each with unique pest
problems, is not practical.  Choices are often market driven.	No.

Soilless culture / Substrates /plug plants	Container production may be
possible in higher value cut flower crops but it not generally feasible,
especially for deeper rooted crops and on large acreage.  	No.

Combinations of Alternatives

1,3-Dichloropropene + chloropicrin	For caladiums, chloropicrin was
needed in addition to 1,3-D to reach the same yield as methyl bromide
plus chloropicrin (Overman and Harbaugh, 1983).  1,3-D is also limited
by the plant-back interval, the lack of weed control, and the lack of
equipment necessary to fumigate with 1,3-D (Gilreath, 2004).

Limitations to chloropicrin include poorer weed control than methyl
bromide, and a reluctance to use chloropicrin in many areas due to the
proximity of cut flower fields to residences.

In Florida, 1,3-D + chloropicrin, followed by metam sodium a week later,
has shown control of diseases and nematodes, but does not adequately
control weeds.  	No.

1,3-Dichloropropene + chloropicrin + pebulate	Pebulate is currently not
registered.  

For caladiums, chloropicrin was needed in addition to 1,3-D to reach the
same yield as methyl bromide plus chloropicrin (Overman and Harbaugh,
1983).  1,3-D is also limited by the plant-back interval, the lack of
weed control, and the lack of equipment necessary to fumigate with 1,3-D
(Gilreath, 2004).

Limitations to chloropicrin include poorer weed control than methyl
bromide, and a reluctance to use chloropicrin in many areas due to the
proximity of cut flower fields to residences.	No.

Dazomet (Basamid) + chloropicrin	In some cut flowers (carnation and
chrysanthemum) dazomet was effective against Fusarium, Rhizoctonia,
Erwinia, and Pseudomonas.  Appropriate aeration times, which are
dependent on soil temperature, are needed to avoid phytotoxicity (Semer,
1987).  In addition, plant back restrictions may cause some growers to
be able to grow fewer crops in a year.

Limitations to chloropicrin include poorer weed control than methyl
bromide, and a reluctance to use chloropicrin in many areas due to the
proximity of cut flower fields to residences.	No.

Metam sodium + chloropicrin	Good disease control can be provided by
chloropicrin.  Metam sodium is used by some growers of caladiums in
rotation with methyl bromide.  The growers that have tried using metam
sodium 2 years in a row had bad nematode infestations the second year
and will now only use it once every 2 years.  Most growers will not use
metam sodium because they must meet certification requirements (free of
nematodes) for certain markets (several U.S. states and some
international markets) (Gilreath, 2004).  

This fumigant is currently used and will continue to be used where it
gives adequate pest control.  It will be unlikely to replace significant
portions of current use of methyl bromide.

Limitations to chloropicrin include poorer weed control than methyl
bromide and a reluctance to use chloropicrin in many areas due to the
proximity of cut flower fields to residences.

In general, weed and nematode control is not adequate with this
combination.  In addition, these chemicals would have to be applied
separately, requiring two applications.

Studies conducted on snapdragon by McSorley and Wang (2003 and 2004)
showed that this combination provided comparable control to methyl
bromide.  However, the first study contained soils with light pest
pressure because it had previously been treated with methyl bromide +
chloropicrin.  In addition, this site had sandy soils, and different
results could be obtained with other soil types.  In the second year,
the sites were contaminated with weeds seeds and Fusarium spp., so the
results are more difficult to interpret.  Snapdragons reproduce by seed,
so it is not clear if this combination is effective for bulb crops,
especially over the long term.  Additional research is needed on this
alternative.	No.

Metam sodium + crop rotation	Metam sodium is used by some growers of
caladiums in rotation with methyl bromide.  The growers that have tried
using metam sodium 2 years in a row had bad nematode infestations the
second year and will now only use it once every 2 years.  Most growers
will not use metam sodium because they must meet certification
requirements (free of nematodes) for certain markets (several U.S.
states and some international markets) (Gilreath, 2004).  

This fumigant is currently used and will continue to be used where it
gives adequate pest control.  It will be unlikely to replace significant
portions of current use of methyl bromide.

Rotation would be to other flower crops.  In annual cropping they are
generally too short for the full effects of rotating schemes to be
effective. The previous crop (bulbs, corms) often contaminate the
following crop or may harbor pathogens.  In addition, crop rotation is
not really a solution to pest problems in floriculture because either
the crop cycle is too long (perennials) or the pests persist in the soil
for a long time (Pizano, 2001).  Also, other cut flower species are
often sensitive to the same pests and diseases, making rotation an
infeasible option for pest management.

Instead of applying methyl bromide several times per year, some growers
are rotating to less sensitive crops and treating with metam sodium to
keep pest pressures low.  However, eventually methyl bromide needs to be
applied again or pest pressures will become too high.  In California,
some gladiolus growers are leasing land to strawberry growers.  The
strawberry growers fumigate the land with methyl bromide, and a crop of
gladiolus can follow without additional methyl bromide fumigation.  This
arrangement is not feasible for calla lily growers because calla lilies
are very susceptible to the root disease complex supported by
strawberries and raspberries.  

Complicating crop rotation is the high number of crop species and
varieties, with uncertainties as to their susceptibilities to nematodes
and diseases.   	No.

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

Florida Ornamentals - 14. List and Discuss Why Registered (and
Potential) Pesticides and Herbicides Are Considered Not Effective as
Technical Alternatives to Methyl Bromide:  TC "Florida Ornamentals - 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 Ornamentals – Table 14.1: Technically Infeasible Alternatives
Discussion  TC "Florida Ornamentals – Table 14.1: Technically
Infeasible Alternatives Discussion" \f F \l "1"  

Name of Alternative	Discussion

Herbicides and fumigation with methyl bromide, 1,3-D and chloropicrin,
metam sodium and chloropicrin	Caladium - All were effective for weeds
but positive results may have been influenced by previous years of MeBr
fumigation (Gilreath, et al, 1999).  However, there was control of
Fusarium and only MeBr reduced Pythium.  Herbicides are more feasible
for perennials if they are registered.  The short time interval between
crops (a crop may only take 90 days) often restricts the use of
herbicides due to replant intervals or phytotoxicity.  Also, herbicides
are often selective and there are a limited number registered. 

Hot water dips	Caladium tubers are cleaned with hot water dips (49-50°C
for 30 minutes).  A fungicide/bactericide dip may follow.  Some growers
may spray the rhizomes with a fungicide to protect them from diseases. 
The hot water dip is effective at reducing root knot nematode on the
rhizomes but fumigation is needed to maintain the control.  Controlling
Fusarium on the rhizomes will not control losses if the soil is
contaminated by the previous year’s pests.

Sodium azide	Preliminary results in a calla trial suggest that sodium
azide may not be a feasible alternative in this crop due to reduced crop
vigor and increased mortality (Gerik, 2003).



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



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

Name of Alternative	Present Registration Status

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

Iodomethane	Not registered	Yes	Unknown

Sodium azide	Not registered	Registration package not submitted	Unknown

Propargyl bromide	Not registered	Registration package not submitted
Unknown

Furfural	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 Ornamentals - 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 Ornamentals
- 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"  



For additional studies on ornamentals, see data included for California.
 These studies were separated by location of the study, but some of the
crop species, pests, and other issues are the same.

Evaluation of DMDS for Production of Ornamental Cockscomb (Celosia
argentea) (Church and Rosskopf):

A study with the crop ornamental cockscomb (Celosia argentea) was
conducted with the following treatments: methyl bromide: chloropicrin
98:2 at 448 kg/ha; dimethyl disulfide (DMDS) 784.63 kg/ha; DMDS:
chloropicrin 224.18 kg/ha, and an untreated control.  In one trial, the
study was not completed due to flooding but weed counts were taken at 4
and 8 weeks after treatment before the end of the study.  This site had
high weed pressure and the treatments all provided significantly better
control compared to the untreated control.  The DMDS treatments and the
methyl bromide treatment were not statistically different.  

A second trial was done with the same treatments described above, except
DMDS: chloropicrin, at a separate location.  This site had low weed
pressure and there were no significant differences between treatments
for weed control.  Both DMDS and methyl bromide provided statistically
significant better control of Pythium root rot and nematodes
(Meloidogyne spp.).  Plant height with the methyl bromide treatment was
significantly higher than the untreated control and the DMDS treatment. 
The number of stems harvested was not significantly different for all
treatments; however, the number of marketable stems was significantly
greater with the DMDS and methyl bromide treatments compared to the
control.

Soil Fumigant and Herbicide Combinations for Caladium (Gilreath,
McSorley, and McGovern):

Near Lake Placid, Florida during the 1998 production season, a study was
conducted with caladium using the following treatments:  untreated
control (no herbicide and no fumigant applied); methyl
bromide/chloropicrin 90/10 at 504 kg/ha; 1,3-D/chloropicrin 83/17 at
327.25 L/ha; metam sodium at 701.25 L/ha + chloropicrin at 224 kg/ha. 
All treatments, except the untreated control, received an application of
oryzalin, and the 1,3-D and metam sodium treatments also received an
application of metolachlor.  The area was previously fumigated with
methyl bromide.  

The study looked at weed control, nematodes, Fusarium, Pythium,
Rhizoctonia, and tuber production.  The actual data was not provided but
the results were summarized.  The study found that a potential
alternative may be 1,3-D + chloropicrin + metolachlor applied at
planting + oryzalin applied midsummer.  In addition, the application of
metolachlor at planting, after methyl bromide fumigation, would have
improved weed control.

Screening of Reduced Risk Compounds for Fungicidal and Herbicidal
Activity (Rosskopf and Basinger):

This study screened several compounds, including AJMC-330 and AJMC-334,
using laboratory and greenhouse bioassays.  Benomyl was used as the
control in the fungicide trial, which evaluated the compounds for
activity on Fusarium oxysporum.  Herbicidal activity of these compounds
was evaluated using the following weeds:  purple nutsedge, smooth
pigweed, and barnyardgrass.  AJMC-330 and AJMC-334 both performed well
in the screens.

Report for IR-S Advanced Stage Biopesticide Program 2002-03

Three trials were conducted to evaluate various biopesticides on plant
diseases for the crops liripoe, ivy and periwinkle.  The trials did not
include a methyl bromide control.  In the liriope and ivy trials,
BioPhos was tested for efficacy again Phytophthora palmivora and for
phytotoxic effects on the crops.  There was limited success with the
liriope trial so this trial is not discussed here.  In the ivy trial,
foliar and drench applications of BioPhos were applied at three
concentrations: 0 percent, 2 percent, and 3 percent.  BioPhos caused
phytotoxic effects to the crop, particularly with the foliar
application.  However, BioPhos did result in lower disease ratings
compared to the control.

In the periwinkle trial, several treatments were evaluated for their
effect on Phytophthora nicotianae.  These treatments include: an
untreated control; Actigard (plant defense activator); DieHard (mixture
of endo- and ectomycorrhizal fungi), 6% solution, root dip; DiTera
(biological nematicide); BioPhos (AgBio 222, FNX-100); FNX-2500; MBI600
(Bacillus subtillus); Mycostop (Streptomyces griseoviridis); Primastop;
and Soligard (Trichoderma virens).  Periwinkle plants were inoculated
with the disease.  Most treatments provided significantly better control
compared to the untreated control.  FNX-100 and FNX-100 provided
significantly better control than all other treatments.

Ornamentals – Snapdragon – Table 16.1: Effectiveness of Alternatives
– Weeds  TC "Ornamentals – Snapdragon – Table 16.1: Effectiveness
of Alternatives – Weeds" \f F \l "1"  

This study was conducted with soils consisting of 96 percent sand. 
Also, this study was conducted in an area with low pest pressure because
it had been treated with methyl bromide for several years.  The
researchers stated the need to conduct additional tests to determine
long term control with the alternative fumigants, because methyl bromide
may have reduced pest populations for all sites.  

Key Pests: Weeds in Snapdragon	Weed rating and yields

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Reps	Weed Rating	# of
Reps	Harvested Plants per m of row



Total Weeds/ 7.6 m of row 

(9 Oct.)	Total Weeds/ 7.6 m of row

 (14 Nov.)



Methyl bromide/chloropicrin (98:2)  broadcast injection, 504 kg/ha	4
1.25 b	4.75 b	4	117.8 a

Metam sodium, drenched + rototilled, 701 L/ha	4	1.50 b	3.75 b	4	118.0 a

Metam sodium, drenched + rototilled, 701 L/ha +chloropicrin, injected,
168 kg/ha	4	0.50 b	2.00 b	4	116.8 a

Untreated	4	16.25 a	37.00 a	4	109.6 b

(McSorley and Wang, 2003)

Ornamentals – Snapdragon – Table 16.2: Effectiveness of Alternatives
– Weeds  TC "Ornamentals – Snapdragon – Table 16.2: Effectiveness
of Alternatives – Weeds" \f F \l "1"  

This study was conducted at the same site discussed above (See Table
16.1).  Except for solarization, the fields received the same treatment
as the year before.  The solarization plots were treated with methyl
bromide + chloropicrin the previous season.  In this study, a rain event
washed weed seeds and Fusarium spp. from untreated border areas into the
site, after fumigation had taken place.  Plots showed effects from this
event during November and plots in two of the replications were
destroyed due to the high number of dead plants (these were the areas
most affected by the rain).  All plots had substantial losses from this
event and also caused yields for methyl bromide + chloropicrin yields to
be intermediate. The solarized plants also had shorter plants compared
to the best fumigation treatment. 

Key Pest: Weeds in Snapdragon	Weed Rating and Yields

Methyl Bromide formulations and Alternatives 

(include dosage rates and application method)	# of Reps	Weed Rating	# of
Reps	Harvested Plants Per m of Row



Total Weeds/m2(2 Oct. 2003)	Total Weeds/m2 (20 Nov. 2003)



Methyl bromide/chloropicrin (98:2)  broadcast injection, 504 kg/ha	4	0.0
b	9.0 a	2	62.0 bc

Metam sodium, drenched + rototilled, 701 L/ha	4	0.0 b	10.2 a	2	84.6 ab

Metam sodium, drenched + rototilled, 701 L/ha +chloropicrin, injected,
168 kg/ha	4	0.0 b	15.0 a	2	92.3 a

Solarization	4	0.0 b	19.2 a	2	77.4 ab

Untreated	4	79.8 a	23.5 a	2	39.2 c

(McSorley and Wang, 2004)

Florida Ornamentals – Table C.1: Alternatives Yield Loss Data Summary



  TC "Florida Ornamentals – 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 plus chloropicrin 	Nematodes and Diseases (no control of weeds or
previous crop)	10 to 25 %	25%

Dazomet	Multiple

25%

Metam Sodium	Multiple

20%

Overall Loss Estimate for All Alternatives to Pests	20 to 25%



Yield losses will vary by species but, based on expert opinion for two
representative crops, ranunculus and caladiums, an estimate has been
determined.  The experts are a cut flower producer and a researcher
located in different areas of the country.  Based on grower experience,
it is estimated that 10 to 35 percent yield losses could occur without
methyl bromide.  These yield losses may be higher in highly diseased
fields.  Quality is also a major concern for the industry.  Consumers
expect a high quality product.  Selling a product that is not of high
quality will cause growers to lose customers.  There are some promising
alternatives for many crops, but more time is needed to determine which
particular alternatives will work with individual crops to meet customer
standards and avoid yield losses if methyl bromide can no longer be used
(Mellano, 2003).  In ranunculus, a 50 percent yield loss (flowers and
tubers) can occur due to soil pathogens (Elmore et al., 2003b).  The
situation is similar for caladiums.  Studies conducted on caladiums did
not necessarily show yield or quality losses but any losses would depend
on pest populations.  Herbicides were also used to control weeds that
wouldn’t be controlled by the fumigant alone.  In the first year,
growers may experience a 5% reduction in the number of tubers in the
most desirable size grades, with a 30% reduction in production in the
second year possible.  Losses are not likely to exceed 35 to 40%. 
Growers will likely find successful alternatives but more time is needed
to transition to these alternatives (Gilreath, 2004).

Currently, the applicants do not consider any alternative to be a
feasible replacement for methyl bromide in this diverse sector. 
However, in an attempt to provide an estimate of the potential impacts
from the adoption of the most common methyl bromide alternatives, the
table above presents likely yield losses. 

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



Research is currently being conducted to identify potential
alternatives.  Please refer to Section 16 and Section 23.



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



A number of technologies are currently being used in this sector,
including integrated pest management, crop rotation, fallow periods,
hand weeding, etc.  However, these practices are still not sufficient to
control the key target pests without the use of methyl bromide.

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

Without methyl bromide, certain growers will suffer both yield and
quality losses.  In addition growers who rotate several species of
ornamentals on a particular field, need to kill crop residue from
previous crops to eliminate contamination, as well as control other
weeds and pathogens.  Due to the diversity and complexity of the cut
flower and foliage industry, an additional 2 to 3 years are needed to
complete ongoing research into implementation of methyl bromide
alternatives.  Alternatives have not been found for all species.  Some
of the alternatives that have been found for other crops (such as 1,3-D
for Easter lilies in Oregon) may not be feasible for floriculture in
general because of high cost, difficulties with quickly treating and
replanting fields for multi-cropping, and buffer zone requirements. 
Other alternatives provide inconsistent control or have restrictions
that limit their use at this time.  Growers also need time to transition
to the alternatives.

In this industry, the fumigation situation and need for methyl bromide
varies by species.  Although there are some potential alternatives,
there is not enough grower experience and research to justify to
switching to alternatives by the 2008 growing season.

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



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



Michigan Herbaceous Perennials - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Michigan Herbaceous Perennials.
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 Pests 	Specific reasons
why methyl bromide is needed

Michigan Herbaceous Perennials	Nematodes: Meloidogyne hapla,
Pratylenchus spp., Ditylenchus spp.;

Fungi: Pythium (damping-off, root rot), Fusarium (damping-off, root
rot), Phytophthora, Rhizoctonia; Weeds: Cyperus esculentus (yellow
nutsedge), Inula brittanica, Oxalis stricta, Cirsium arvense, Rorippa
sylvestris	Research for effective alternatives to MeBr is ongoing with
USDA supported research due to be analyzed and reported after 2006
studies end.  Until field-tested alternatives can be identified and
protocols developed for them, MeBr will be critical to pest management
for this industry.



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



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

Characteristics	Michigan Herbaceous Perennials

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Ornamental
herbaceous perennials (e.g., Delphinium, Hosta, Phlox)

Annual or Perennial Crop: (# of years between replanting) 	Perennial:
2-year seeded (6% of treated area) and 2-year transplants (29% of
treated area) are on a 2 year replant/fumigation cycle; 3-year
transplants (65% of treated area) are on a 3 year replant/fumigation
cycle

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None

Soil Types:  (Sand, loam, clay, etc.)	Various, light to heavy

Frequency of methyl bromide Fumigation: 

(e.g. every two years)	Once in 2 to 3 years

Other relevant factors:	No other relevant factors identified.



Michigan Herbaceous Perennials - Table 11.2 Characteristics of Climate
and Crop Schedule  TC "Michigan Herbaceous Perennials. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"   

Year 1 of two-year cycle.

Year 1	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	USDA zones 4a - 6a

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

	2-year transplants

	2-year seedlings; 3-year transplants







Planting Schedule

	2-year transplants



3-year transplants	3-year transplants







Year 2 of two-year cycle.

Year 1	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	USDA zones 4a - 6a

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea













Planting Schedule

	2-year seedlings









	

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



Long term research results are to be compiled and analyzed in 2006-2007,
to assess the efficacy of alternatives.  In addition, the consortium is
developing timelines to determine a strategy to transition from MB. 
Fumigation schedule with MeBr is based on the effectiveness in managing
the numerous pests.  With alternatives, fumigation will likely have to
be increased and timing of seedling and transplant production will be
affected.  Consequently, the ongoing research program must be completed
to address implementation of production processes with newly identified
alternatives.  

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



Michigan Herbaceous Perennials - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC " Michigan Herbaceous Perennials. 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)	248	228	129	130	110	110

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	flat fumigation	flat fumigation	flat fumigation	flat
fumigation	flat fumigation	flat fumigation

Amount of methyl bromide active ingredient used (kg)	97,477	89,539
50,485	50,961	41,153	41,153

formulations of methyl bromide 

(MB:PIC)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied 	injected	injected	injected
injected	injected	injected

Application rate [Active Ingredient] (kg/ha)	392	392	392	392	375	375

Actual dosage rate [active ingredient] (g/m2)	39.2	39.2	39.2	39.2	37.5
37.5



In 2002, 1,316.6 kg of methyl bromide applied to herbaceous perennials
in the program states (California, Florida, Michigan, Oregon,
Pennsylvania, and Texas).  In Michigan, the percent of herbaceous
perennials treated with methyl bromide was 1 percent (USDA Agricultural
Chemical Usage, 2004).  

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



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




Michigan Herbaceous Perennials – Table 13.1: Reason for Alternatives
Not Being Feasible  TC "Michigan Herbaceous Perennials – 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 is not very efficacious on its own for weed
and disease control.  Some growers have found adequate control when
1,3-D is combined with other fumigants or herbicides.

	No.

Metam sodium	Performance with metam sodium is erratic and inconsistent,
depending on soil type, moisture content, and temperature. Many years of
research have indicated difficulty achieving consistent efficacy with
metam sodium on high value crops.  Also, pest populations tend to build
up over time with metam sodium.  Repeat use results in an increase in
the population of bio-degraders of the active ingredient.  

Buffer zones make using this alternative difficult because ornamentals
are produced on small parcels of land.  This fumigant cannot be used in
urbanized areas.

	No

Dazomet	Appropriate aeration times, which are dependent on soil
temperature, are needed to avoid phytotoxicity (Semer, 1987).  In
addition, plant back restrictions may cause some growers to be able to
grow fewer crops in a year.	No.

Chloropicrin	Weed control is poorer than with methyl bromide (Ragsdale,
2004).  Nematodes and weeds are not controlled adequately. Adequate
efficacy for the pest complex cannot be achieved with lower use rates.  
No.

MITC	Same issues described above for metam sodium and dazomet.	No.

Non Chemical Alternatives

Biofumigation	This is a process where mustard species (Brassica spp.)
are grown and ultimately disked into soils.  A bioactive breakdown
product of some of these species is MITC.  Biofumigation is still
largely in the experimental stages.  (Pizano, 2001).  Specific brassicas
as well as specific years yield variable amounts of activity.  While
this alternative may provide some control, the control of all target
pests is not sufficient.  Also, brassica waste must be available in huge
quantities to provide at best minor effects.  	No.

Solarization	Solarization is not feasible under Michigan field
conditions.  Not able to generate acceptable heat to allow spring
planting; most effective time for solarization is not compatible with
timing for production; uses solar radiation to heat soil under clear
plastic, and under certain conditions in some locations in the summer,
soil can be heated to as high as 60 C to a depth of 7.5 cm.  Effective
solarization would likely require several months of covered bed
treatments, to heat soil to a sufficient depth (25-30 cm) in order to
affect soil-borne pathogens.  Seeds of some weed species are resistant
even to higher temperatures obtained with solarization.  Nutsedges,
Fusarium spp., Macrophomina spp. are not controlled, or unpredictably
controlled, by solarization (Elmore et al., 1997).  Therefore, this
alternative is not considered technically feasible.  	No.

Steam	Steam can be a technically effective alternative in some cases. 
Reasons cited for not using steam for this crop system are high initial
cost and high application costs limit widespread use, it is slow, best
suited to small acreages, and continuous cropping.  Some greenhouse
growers have adapted this approach already in crops where it works
better (such as Freesia).  In-field steaming is not a feasible
alternative due to lack of machinery that can deliver the steam,
differences in soil type, and environmental impact of fuel use.	No.

Biological control 	No biological controls are developed to cover all of
the pests.  Results with biological control agents may vary with field
or environmental conditions (Pizano, 2001).  Even in small containers,
biological control is not reliable for soil-borne pathogens.	No.

Crop residue compost/Crop rotation/fallow	Crop rotation/fallow does not
adequately control the target pests.  Rotation would be to other
ornamental crops.  In addition, crop rotation is not really a solution
to pest problems in floriculture because either the crop cycle is too
long (perennials) or the pests persist in the soil for a long time
(Pizano, 2001).  Rotations are generally not a true rotation in the pest
control sense.   	No.

Flooding and water management	Beds are generally designed and graded for
good drainage to prevent standing water.  Flooding could increase the
incidence of certain diseases and is also time restrictive.	No.

General IPM	Although IPM is currently practiced, this alone will not
control weed and disease pests.	No.

Grafting/resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding are not feasible alternatives.  None of the
herbaceous perennials grown are grafted and very few are resistant. 
Given the thousands of varieties of ornamentals, plant breeding for the
variety of pests is not practical.	No.

Organic amendments/compost	Not effective alone in weed or pest
management; may be incorporated as part of an IPM program.  Does not
provide adequate weed and disease control.	No.

Physical removal/sanitation	Appropriate sanitation practices are already
used extensively.  	No.

Resistant cultivars	Given the thousands of varieties of ornamentals,
developing resistant cultivars for each variety, each with unique pest
problems, is not practical.  Choices are often market driven.	No.

Soilless culture / Substrates /plug plants	Container production may be
possible in higher value cut flower crops but it is not generally
feasible, especially for deeper rooted crops and on large acreage.  	No.

Combinations of Alternatives

1,3-Dichloropropene + chloropicrin	This combination provides poorer weed
control than methyl bromide.

	No.

Dazomet + chloropicrin	Appropriate aeration times, which are dependent
on soil temperature, are needed to avoid phytotoxicity (Semer, 1987). 
In addition, plant back restrictions may cause some growers to be able
to grow fewer crops in a year.

Weed control is poorer than with methyl bromide (Ragsdale, 2004). 
Nematodes and weeds are not controlled adequately. Adequate efficacy for
the pest complex cannot be achieved with lower use rates.  	No.

Metam sodium + chloropicrin	Many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops. 

Good disease control can be provided by chloropicrin.  However,
chloropicrin provides poorer weed control than methyl bromide.  

In general, weed and nematode control is not adequate with this
combination.  In addition, these chemicals would have to be applied
separately, requiring two applications.

	No.

Metam sodium + crop rotation	Many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops. 

Rotation would be to other ornamental crops.  In addition, crop rotation
is not really a solution to pest problems in floriculture because either
the crop cycle is too long (perennials) or the pests persist in the soil
for a long time (Pizano, 2001).  ).  Rotations are generally not a true
rotation in the pest control sense.	No.



14. List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC "Michigan Herbaceous Perennials. 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"  



  TC "Michigan Herbaceous Perennials – Table 14.1: Technically
Infeasible Alternatives Discussion" \f F \l "1"  

Name of Alternative	Discussion

Herbicides and fumigation with methyl bromide, 1,3-D and chloropicrin,
metam sodium and chloropicrin	Herbicides are more feasible for
perennials if they are registered.  Herbicides are often selective and
there are a limited number registered.  There are liability concerns due
to phytotoxicity concerns on ornamentals.

Sodium azide	Preliminary results in a calla trial suggest that sodium
azide may not be a feasible alternative in this crop due to reduced crop
vigor and increased mortality (Gerik, 2003).



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



Table 15.1: Present Registration Status of Alternatives  TC "Michigan
Herbaceous Perennials. 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:

Sodium Azide	Not registered in U. S.  No registration package has been
received.	No	Unknown

Propargyl bromide	Not registered in U. S.  No registration package has
been received.	No	Unknown

Iodomethane	Not registered in U. S.	Yes	Unknown

Furfural	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.



Michigan Herbaceous Perennials - 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
Herbaceous Perennials - 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"  



Currently, limited research is available for herbaceous perennials
because long term research with USDA is ongoing.  This research is due
to be analyzed and reported after 2006 studies end.  However, some
preliminary research is available and is described below.  For
additional studies on ornamentals, see data included for California and
Florida.  These studies are separated by location of the study, but some
of the crop species, pests, and other issues are the same.

Michigan Herbaceous Perennials – Hosta – Table 16.1: Effectiveness
of Alternatives – Inula brittannica  TC "Michigan Herbaceous
Perennials –Hosta– Table 16.1: Effectiveness of Alternatives –
Inula brittannica" \f F \l "1"  

Key Pest: Inula Brittannica	Average Percent weed control and Average
Percent Crop Injury

Methyl Bromide formulations and Alternatives 

	# of Reps	October 15, 2001	June 20, 2002



Percent Weed Control	Percent Crop Injury	Percent Weed Control	Percent
Crop Injury

Triclopyr + clopyralid (1.68 kg ai/ha)	n/a	100	19	89	89

Dicamba (2.24 kg ai/ha)	n/a	100	41	67	78

Clopyralid (0.28 kg ai/ha)	n/a	100	19	67	26

Clopyralid (0.56 kg ai/ha)	n/a	100	22	81	33

2,4-D + clopyralid (1.5 kg ai/ha)	n/a	100	22	78	37

2,4-D (3.36 kg ai/ha)	n/a	97	37	74	56

Triclopyr (2.24 kg ai/ha)	n/a	89	3	70	81

Glyphosate (4.48 kg ai/ha)	n/a	48	41	26	89

Diquat (1.5 kg ai/ha)	n/a	52	97	26	14

Dicamba + diflufenzopyr (0.196 kg ai/ha)	n/a	89	26	8	78

LSD

10	23	30	16

(Richardson, Zandstra, and Dudek)

These herbicides are currently not registered for control of this weed. 
Some limitations to this study include no methyl bromide control
treatment and no data from an untreated control.

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

Alternative	List Type of Pest	Range of Yield Loss (compared to MB)	Best
Estimate of Yield Loss

Chloropicrin	Fungi	+3% to –13%	5% loss

Metam-sodium	Weeds	+3% to –13%	5% loss

Dazomet	Weeds	+3% to –13%	5% loss

1,3-D	Nematodes, Weeds	+3% to –13%	5% loss

Metam-sodium + chloropicrin	Weeds, Fungi	+5% to –8%	0-3% loss

1,3-D + chloropicrin	Weeds, Fungi	+5% to –8%	0-3% loss

Overall Loss Estimate for All Alternatives to Pests	3-5%



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



Research is currently being conducted to identify potential
alternatives.  Please refer to Section 16 and Section 23.

The use of 1,3-D or 1,3-D/chloropicrin under tarp combined with
post-emergence herbicides is considered a potential alternative.  Some
growers have already made the transition to 1,3-D.  However, increased
research on herbicides, including the evaluation of carryover and
phytotoxicity, is needed.  In addition, some herbicides may need
expanded labeling, which could take time.  Iodomethane is also expected
to help growers transition away from methyl bromide, although it is
unknown when registration might occur.  This region expects to have
workable alternatives by 2007 or 2008. 

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



A number of technologies are currently being used in this sector,
including integrated pest management, crop rotation, fallow periods,
hand weeding, etc.  However, these practices are still not sufficient to
control the key target pests without the use of methyl bromide.

Summary of Technical Feasibility  TC "Michigan Herbaceous Perennials.
Summary of Technical Feasibility" \f C \l "2"  





This nomination includes requests for MeBr only for those nurseries
where sufficient pest control can not be achieved otherwise.  While
combinations of chemicals, such as 1,3-D + chloropicrin + herbicides
appear to be effective for some growers, currently all growers can not
rely solely on alternatives.  

For example, 1,3-D is an effective nematicide that may have some
efficacy against plant pathogens, but for efficacy for weed management
additional inputs will be required, such as the use of herbicides.  In
addition, these alternatives may not be economically feasible.  

The industry is continuing to sponsor research on alternatives and to
test improved chemical application technologies to increase the efficacy
of some of the most viable alternatives.  MeBr is considered to be
critical in the short-term, with chemical alternatives the likely
long-term solution.  Non-chemical and biological control methodologies
are not adequate to control the key pests.  Integration of several
alternative treatments is the most likely alternative to MB. 

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.	Some growers have switched from a 98% MeBr
formulation to a 67 % formulation.	Unknown.	Unknown 

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	The U.S. anticipates that the decreasing
supply of methyl bromide will motivate growers to try high density
films.	The U.S. anticipates that the decreasing supply of methyl bromide
will motivate growers to try lowering methyl bromide dosages.	The U.S.
anticipates that the decreasing supply of methyl bromide will motivate
growers to try increasing the chloropicrin percentage.	The U.S.
anticipates that the decreasing supply of methyl bromide will motivate
growers to try less frequent applications.  However, limited grower
experience and scientific data suggest current applications are critical
for production.

Other measures (please describe)	Water seals of newer products	Unknown
Unknown	Unknown



20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used

or Are Not Planned for the Circumstances of the Nomination

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

As methyl bromide has become more scarce, users in the United States
have, where possible, experimented with different mixes of methyl
bromide and chloropicrin.  Specifically, in the early 1990s, methyl
bromide was typically sold and used in methyl bromide mixtures made up
of 95% methyl bromide and 5% chloropicrin, with the chloropicrin being
included solely to give the chemical a smell enabling those in the area
to be alerted if there was a risk.  However, with the outset of very
significant controls on methyl bromide, users have been experimenting
with significant increases in the level of chloropicrin and reductions
in the level of methyl bromide.  While these new mixtures have generally
been effective at controlling target pests, at low to moderate levels of
infestation, it must be stressed that the long term efficacy of these
mixtures is unknown.  

	

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

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

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



(Pull Economics from previous Forest Seedling CUNs?)

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 for an enterprise, is
gross revenue minus the sum of operating and fixed costs.  Net income is
smaller than the net revenue measured in this study, often substantially
so.  We did not include fixed costs because they are difficult to
measure and verify.

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



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

REGION	Alternative	Yield*	Cost in year 1 (U.S.$/ha)	Cost in year 2
(U.S.$/ha)	Cost in year 3 (U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	100	$5,421
$5,421	$5,421

	Dazomet	75	$5,421	$5,421	$5,421

	1,3-d + pic	75	$5,421	$5,421	$5,421

	Metam Sodium	80	$5,421	$5,421	$5,421

Florida Cut Flowers - Lilies	Methyl Bromide	100	$14,085	$14,085	$14,085

	Dazomet	75	$14,085	$14,085	$14,085

	1,3-d + pic	75	$14,085	$14,085	$14,085

	Metam Sodium	80	$14,085	$14,085	$14,085

Florida Cut Flowers - Caladium	Methyl Bromide	100	$7,660	$7,660	$7,660

	Dazomet	75	$7,660	$7,660	$7,660

	1,3-d + pic	75	$7,660	$7,660	$7,660

	Metam Sodium	80	$7,660	$7,660	$7,660

region h - Michigan Herbaceous Perennials	Methyl Bromide	100	 $   
37,311 	 $    37,311 	 $    37,311 

	Various Alternatives*	95	 $    58,414 	 $    58,414 	 $    58,414 

*As percentage of typical or 3-year average yield, compared to methyl
bromide.

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



Table 22.1: Year 1 Gross and Net Revenue  TC "Table 22.1: Year 1 Gross
and Net Revenue" \f F \l "1"  

Year 1

Region	Alternatives

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

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$   
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

Table 22.2: Year 2 Gross and Net Revenue  TC "Table 22.2: Year 2 Gross
and Net Revenue" \f F \l "1"  

Year 1

Region	Alternatives

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

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$   
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

Table 22.3: Year 3 Gross and Net Revenue  TC "Table 22.3: Year 3 Gross
and Net Revenue" \f F \l "1"  

Year 3

Region	Alternatives

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

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$   
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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



Table E.1: California Calla Lily & Bulbs - Economic Impacts of Methyl
Bromide Alternatives  TC "Table E.1: California Calla Lily & Bulbs -
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

California Cut Flowers – 

Calla Lily & Bulbs	Methyl Bromide	Dazomet	1,3-D + Pic	Metam Sodium

Yield Loss (%) 	0	25 %	25%	20%

   Yield per Hectare 	236,630	177,473	177,473	189,304

* Price per Unit (U.S.$)	$0.72	$0.72	$0.72	$0.72

= Gross Revenue per Hectare (U.S.$)	$171,286	$128,465	$128,465	$137,029

- Operating Costs per Hectare (U.S.$)	$149,035	$149,035	$149,035
$149,035

= Net Revenue per Hectare (U.S.$)	$22,251	($20,570)	($20,570)	($12,006)

1. Loss per Hectare (U.S.$)	$0	$42,822	$42,822	$34,257

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$170	$170	$136

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	192%	192%	154%



Table E.2: Florida Cut Flowers - Lilies - Economic Impacts of Methyl
Bromide Alternatives  TC "Table E.2: Florida Cut Flowers - Lilies -
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Florida Cut Flowers - Lilies	Methyl Bromide	Dazomet	1,3-D + Pic	Metam
Sodium

Yield Loss (%) 	0	25 %	25%	20%

   Yield per Hectare 	30,806	23,104	23,104	24,645

* Price per Unit (U.S.$)	$7.50	$7.50	$7.50	$7.50

= Gross Revenue per Hectare (U.S.$)	$231,043	$173,283	$173,283	$184835

- Operating Costs per Hectare (U.S.$)	$159,506	$159,506	$159,506
$159,506

= Net Revenue per Hectare (U.S.$)	$71,537	$13,776	$13,776	$25,328

1. Loss per Hectare (U.S.$)	$0	$57,761	$57,761	$46,209

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$131	$131	$105

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	81%	81%	65%



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

Florida - Caladium	Methyl Bromide	Dazomet	1,3-D + Pic	Metam Sodium

Yield Loss (%) 	0	25 %	25 %	25 %

   Yield per Hectare 	111,197	83,398	83,398	88,958

* Price per Unit (U.S.$)	$0.25	$0.25	$0.25	$0.25

= Gross Revenue per Hectare (U.S.$)	$27,799	$20,850	$20,850	$22,239

- Operating Costs per Hectare (U.S.$)	$24,340	$24,340	$24,340	$24,340

= Net Revenue per Hectare (U.S.$)	$3,459	($3,490)	($3,490)	($2,100)

1. Loss per Hectare (U.S.$)	$0	$6,950	$6,950	$5,560

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$23	$23	$19

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	201%	201%	161%



Table E.4: Economic Impacts of Methyl Bromide Alternatives  TC "Region H
- Michigan Herbaceous Perennials - Table E.4: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"  

Michigan Herbaceous Perennials	Methyl Bromide	Various Alternatives**

Yield Loss (%) 	0%	5%

   Yield per Hectare Conifer Seedlings	144,920	137,674

* Price per Unit (U.S. $/seedling)	 $        0.97 	 $         0.97 

= Gross Revenue per Proportion  (60%)	 $   140,956 	 $   133,908 

-  Operating Cost per Hectare (U.S. $)	 $     37,311 	 $     58,414 

= Net Revenue per Hectare (U.S. $)	 $   103,645 	 $     75,494 

Loss Measures

1. Loss per Hectare (U.S. $)	$0	 $     28,151 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$0	 $     143.52 

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

4. Loss as a Percentage of Net Revenue (%)	0%	37%

** The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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



The economic analysis evaluated methyl bromide alternative control
scenarios for cut flower production for Florida, California, and
Michigan by comparing the economic outcomes of methyl bromide oriented
production systems to those using alternatives.  However, due to the
fact that there are over 100 species of ornamentals grown in all regions
of the country, the data from these xamples are used to derive a proxy
estimate for the entire industry.   

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

	

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

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

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

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

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

(5) Operating Profit Margin.  We define operating profit margin to be
net operating revenue divided by gross revenue per hectare.  This
measure would provide the best indication of the total impact of the
loss of methyl bromide to an enterprise.  Again, operating costs may be
difficult to measure and fixed costs even more difficult, therefore
fixed costs were not included in the analysis.

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

Several methodological approaches will help interpret the findings.
Economic estimates were first calculated in pounds and acres and then
converted to kilograms and hectares.  Costs for alternatives are based
on market prices for the control products multiplied by the number of
pounds of active ingredient that would be applied.  Baseline costs were
based on the average number of annual applications necessary to treat
cut flowers with methyl bromide.

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.  Fixed costs were not included because
they are difficult to measure and verify.  

Loss per hectare measures the value of methyl bromide based on changes
in operating costs and/or changes in yield.  Loss expressed as a
percentage of the gross revenue is based on the ratio of the revenue
loss to the gross revenue.  Likewise for the loss as a percentage of net
revenue.  The profit margin percentage is the ratio of net revenue to
gross revenue per hectare.   The values to estimate gross revenue and
the operating costs for each alternative were derived for three
alternative control scenarios for Florida and California, relative to
methyl bromide: 1) Dazomet; 2) 1,3-d + chloropicrin; and 3) metam
sodium.  Yield loss estimates were based on data from the CUE’s and
U.S. EPA data, as well as expert opinion.

Regulatory constraints. 

In California, 1,3-d plus chloropicrin would also be the primary
replacement for methyl bromide.  California restricts total use of
1,3-d, at the local level (township cap).  In Florida, the use of 1,3-d
also requires a 100-foot buffer around inhabited structures.  This would
reduce the production acreage an estimated 10%.  Nematodes and weeds and
pathogens are key pests in Florida and California bulb grower and are
controlled with methyl bromide.  Chloropicrin is not as effective in
controlling weeds as methyl bromide.  Using chloropicrin adds to
production costs through increased chemical, weeding and labor costs.

Tables E.1 - E.4 provides a summary of the estimated economic losses.  A
measure of net revenue loss may not be completely accurate partly
because some nurseries are publicly owned and seedling prices or
production costs are subsidized.  The range of losses in the studies is
rather large because both dazomet and metam-sodium provide inconsistent
pest control.  Indirect losses arising from shifts in the production
cycle were not quantified.  Changes in production costs arise due to
differences between the costs of methyl bromide and the alternatives,
shifts in the production cycle (increasing the frequency of fumigation
or lengthening the fallow period) and additional expenses such as
supplementary irrigation.  These costs vary across regions

Michigan Herbaceous Perennials

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

Note: Market price data was not available for the United States cut
flower industry but it is assumed that the net effect of shifting from
methyl bromide to any of the alternatives other than metam sodium would
result in additional revenue reductions due to fluctuations in market
price due to changes in production and harvesting times.

It should be noted that the applicants do not consider any alternative
to be feasible and that these estimates are an attempt to measure
potential impacts.

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"  



Between 1992 and 2003, the California Cut Flower Commission has spent
$260,000 in research related to methyl bromide alternatives in addition
to hundreds of thousands of dollars spent by individual growers trying
to find workable alternatives.  In 2004, $90,000 was spent on research
and $100,000 was spent in 2005.  One researcher was recently warded
$322,000 to continue research on methyl bromide alternatives in the
California ornamentals industry.  Future research will focus on the
following pests:  weeds, Fusarium oxysporum, Pythium spp., Meloidogyne
spp., and previous crop debris, such as bulblets, cormlets, etc. from
crops such as callas, caladiums, and gladiolus.  1,3-D, metam sodium,
dazomet, chloropicrin, sodium azide, and iodomethane have already been
tested.  Future research will focus on iodomethane, combinations of
1,3-D, metam sodium, and chloropicrin.

In Florida, research trials for 2003 are in place for caladiums in muck,
aster, and snapdragons, and caladiums in sand are planned for 2004. 
Several alternatives will be tested, including metam sodium,
1,3-D/chloropicrin, iodomethane/chloropicrin, and sodium azide. 
Research, including projects on Celosia and DMDS, is ongoing.

The Michigan Field Grown Herbaceous Perennial Growers Association is
currently assisting in field trials with Michigan State University in
research supported in part by the USDA MeBr Alternatives Grant Program. 
For 2002-2004, $68,979 has been allocated and $370,701 has been granted
for a study that runs from 2003-2006.  This work is a large investment
in identifying alternatives for Michigan growers.

The Agricultural Research Service (United States Department of
Agriculture) has two full time employees (since 2000) working on methyl
bromide alternatives for flowers and ornamentals.  This represents about
a $600,000 annual investment.  In addition, a recent grant and other
money, about $100,000 has provided two CCC grants for flower
alternatives.

 

The amount of methyl bromide requested for research purposes is
considered critical for the development of effective alternatives. 
Without methyl bromide for use as a standard treatment, the research
studies can never address the comparative performance of alternatives. 
This would be a serious impediment to the development of alternative
strategies.  The U.S. government estimates that ornamentals research
will require ??? kg per year of methyl bromide for 2008?.  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 five year field study
testing the comparative performance of methyl bromide, 1,3-D, metam
sodium, and new reduced risk chemicals for control of soilborne pests
with emphasis on nematodes and weeds. 

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.





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



The MeBr critical use exemption nomination for Ornamentals Seedlings has
been reviewed by the U. S. Environmental Protection Agency and the U. S.
Department of Agriculture and meets the guidelines of The Montreal
Protocol on Substances That Deplete the Ozone Layer.  This nomination
includes requests for MeBr only for those ornamental operations where
sufficient pest control can not be achieved otherwise.  





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



2002 Census of Agriculture, State and County Profiles.  Web address:   
HYPERLINK "http://www.nass.usda.gov/fl/rtoc0ho.htm" 
http://www.nass.usda.gov/fl/rtoc0ho.htm 

Ajwa, H.  Preliminary Weeding Data from Ajwa MBr Alts Experiment at
Silverlake Ranch in 

Soledad CA. see CUE-0018 request California Floriculture 2005 submission

Ajwa, H. and Elmore, C.  2005.  Methyl Bromide Alternatives Research and
Education for 	California Cut Flowers.  Annual Report – California Cut
Flower Commission.  see CUE-	0018 request California Floriculture 2005
submission 

Charron, C. S. and Sams, C. E.  Macerated Brassica leaves suppress
Pythium ultimum and Rhizoctonia solani mycelial growth.  see CUE-0066
request Michigan Field Grown Herbaceous Perennial Growers consortium in
2003 submission.

Church, G. T. and Rosskopf, E. N., Evaluation of DMDS for Production of
Ornamental Cockscomb (Celosia argentea), USDA, ARS, U.S. Horticultural
Research Laboratory, Fort Pierce, FL.

Elmore, C. L., Stapleton, J. J., Bell, C. E., DeVay, J. E. 1997.  Soil
Solarization.  Univ. California, Div. Agriculture and Natural Resources,
Publ. 21377.  Oakland, CA. pp. 13.

Elmore, C., J. MacDonald, H. Ferris, I. Zasada, S. Tsjvold, K. Robb, C.
Wilen, L. Bolkin, L. Yahaba, J. Roncoroni, 2003a, Alternatives to Methyl
Bromide for Control of Weeds, Nematodes, and Soil-Borne Fungi, Bacteria
in Coastal Ornamental Crops – Draft.

Elmore, C., J. Roncoroni, K. Robb, C. Wilen, and H. Ajwa, 2003b,
Preplant Pest Production in Ranunculus Production, Proceeding from the
2003 Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions, Web address:  www.mbao.org

Foliage, Floriculture, and Cut Greens.  May 2003.  Florida Agricultural
Statistics Service.  Web address:  http://www.nass.usda.gov/fl

Foliage, Floriculture, and Cut Greens.  July 2004.  Florida Agricultural
Statistics Service.  Web address:  http://www.nass.usda.gov/fl

Gerik, J., 2003, Evaluation of Alternatives to Methyl Bromide for
Floriculture Crop – Progress Report submitted by USDA-ARS.

Gerik, J., 2004.Final report submitted by USDA-ARS for cooperative
agreement number 58-5302-3-104.

Gerik, J. S. 2005a, Evaluation of Soil Fumigants Applied by Drip
Irrigation for Liatris Production, Plant Dis. 89: 883-887.

Gerik, J., 2005b.Evaluation of Alternatives to Methyl Bromide for
Floriculture Crops.  CCFC Agreement No. 58-5302-4-455.

Gilreath, J.P., R. McSorley, and R.J. McGovern, 1999, Soil Fumigant and
Herbicide Combinations for Soilborne Pest Control in Caladium, Proc Fla
State Hort Soc 112: 285-290.

Gilreath, J., 2004, University of Florida – IFAS, Personal
communication.

McSorley, R. and K.-H. Wang., 2003, Fumigant Alternatives to Methyl
Bromide for Managing Nematodes and Weeds in Snapdragon, Proc Fla State
Hort Soc.

McSorley, R. and K.-H. Wang, 2004, Impact of Soilborne Pest Problems on
Field-Grown Snapdragons, Proc Fla State Hort Soc.

Mellano, M, Mellano and Company, 2003, Personal communication.  

Overman, A.J. and B. K. Harbaugh, 1983, Soil Fumigation Increases
Caladium Tuber Production on Sandy Soil, Proc Fla State Hort Soc 96:
248-250.

Pizano, M., 2001, Floriculture and the Environment:  Growing Flowers
without Methyl Bromide, United Nations Environment Programme.

Prince & Prince, Inc. Survey, 2003.  Conducted for California Cut Flower
Commission.

Ragsdale, N., USDA-ARS National Program Staff, 2004, Personal
communication.

Richardson, R., B. Zandstra, and T. Dudek.  Evaluation of Herbicidal
Controls for Inula brittannica. ee CUE-0066 request Michigan Field Grown
Herbaceous Perennial Growers consortium in 2004 submission

Rosskopf, E. N., W. Basinger, Screening Reduced Risk Compounds for
Fungicidal and Herbicidal Activity.  USDA, ARS, Fort Pierce, FL and Ajay
North America, LLC, Powder Springs, GA.

Rosskopf, E., C. Yandoc, J. Albano, and E. Lamb, Report for IR-4
Advanced Stage Biopesticide Program 2002-03, United States Horticultural
Research Laboratory, USDA, ARS, Fort Pierce, FL and Indian River
Research and Education Center, University of Florida, Fort Pierce, FL. 

Schneider, S., E. Rosskopf, J. Leesch, D. Chellemi, C. Bull, and M.
Mazzola, 2003, United States Department of Agriculture – Agricultural
Research Service Research on Alternatives to Methyl Bromide: Pre-plant
and Post-harvest, Pest Manag Sci 59: 814-826.

Semer, C. R. IV, 1987, Basamid and Methyl Bromide Compounds as Fumigants
in Carnation and Chrysanthemum Production in Selected Propagation Media,
Proc Fla State Hort Soc 100: 330-334.

Trout, T., 2001, Impact of Township Caps on Telone Use in California.

Trout, T., 2003, Impact of Township Caps on Telone Use in California,
Proc. Annual International Research Conference on MB Alternatives and
Emission Reductions, p. 109.

USDA Agricultural Chemical Usage, Nursery and Floriculture, 2004, Web
address:    HYPERLINK
"http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcn0904.pdf
" 
http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcn0904.pdf 

USDA ERS, 1999, Table 30—Cut gladioli: Growers, production, and value
of sales, major States, 1991-98,   Web address:    HYPERLINK
"http://usda2.mannlib.cornell.edu/data-sets/specialty/99003/" 
http://usda2.mannlib.cornell.edu/data-sets/specialty/99003/  

APPENDIX A.  2008 Methyl Bromide Usage Numerical Index (BUNI).  TC
"APPENDIX A.  2008 Methyl Bromide Usage Numerical Index (BUNI)" \f C \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.



Appendix B – Key Pests of Select Cut Flower Species  TC "Appendix B
– Key Pests of Select Cut Flower Species" \f C \l "1"  



The following list is not comprehensive, but is intended to demonstrate
the complexity of the industry. In addition to the diseases and
nematodes listed below, there are numerous weed species that are major
problems in cut flower production.  These species include the bulbs,
tubers, or cormlets from a previous crop, yellow nutsedge (Cyperus
esculentus), little mallow (Malva parviflora), and common sow thistle
(Sonchus oleracea).

 Diseases and Nematodes of cut flower crops currently controlled with
Methyl Bromide.

Crop	Key Pests	Scientific name

Antirrhinum	Nematodes

	 Belanolaimus longidorus, Criconomella spp., Dolichodorus
heterocephalus

	Pythium root rot	Pythium irregulare (documented resistance to mefenoxam
is 25-50%)

Calla lily	Erwinia soft rot	Erwinia carotovora

	Pythium root rot	Pythium spp. (resistance to mefenoxam suspected to be
widespread

Delphinium	Sclerotinia stem rot	Sclerotinia spp.

Dianthus	Fusarium wilt	Fusarium oxysporum fsp. dianthii

Eustoma	Fusarium wilt, root rot, and stem rot	Fusarium oxysporum, F.
solani, and F. avenaceaum 

Freesia	Fusarium wilt	Fusarium spp.

Gladiolus	Fusarium wilt	Fusarium oxysporum fsp. gladioli

	Stromatinia neck rot	Stromatinia gladioli

Helianthus	Downy mildew	Plasmopara halstedii (this is a soil-borne
pathogen)

Hypericum 	Root knot nematode	Meloidogyne spp.

	Pythium root rot	Pythium spp.

Iris	Fusarium wilt	Fusarium oxysporum fsp. iridis

Larkspur	Sclerotinia stem rot	Sclerotinia sclerotiorum

Liatris spicata	Sclerotinia stem rot	Sclerotinia sclerotiorum

Lilium	Pythium root rot	Pythium spp.

Matthiola	Sclerotinia stem rot	Sclerotinia sclerotiorum

	Xanthomonas leaf spot	Xanthomonas campestris pv. campestris

Ranunculus	Pythium root rot	Pythium spp.

	Xanthomonas leaf spot	Xanthomonas campestris



 

 

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