Methyl Bromide Critical Use Nomination for Preplant Soil Use

For Forest Seedlings 

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 Forest Seedlings (Submitted in 2006
for 2008 Use Season)



Nominating Party Contact Details

Contact Person:	John E. Thompson, Ph. D.

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U. S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U. S. A.

Telephone:	(202) 647-9799

Fax:	(202) 647-5947

E-mail:	  HYPERLINK "mailto:ThompsonJE2@state.gov" 
ThompsonJE2@state.gov 



	

Following the requirements of Decision IX/6 paragraph (a)(1), the United
States of America has determined that the specific use detailed in this
Critical Use Nomination is critical because the lack of availability of
methyl bromide for this use would result in a significant market
disruption.

( Yes                                  ( No











Signature

Name

Date

Title:







Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U. S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U. S. A.

Telephone:	(703) 308-8200

Fax:	(703) 308-8090

E-mail:	Keigwin.Richard@epa.gov



	

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

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

Paper Documents:

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



















electronic copies of all paper documents: 

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



















Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125862830"  Part A: Summary	 
PAGEREF _Toc125862830 \h  9  

  HYPERLINK \l "_Toc125862831"  1. Nominating Party	  PAGEREF
_Toc125862831 \h  9  

  HYPERLINK \l "_Toc125862832"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125862832 \h  9  

  HYPERLINK \l "_Toc125862833"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125862833 \h  9  

  HYPERLINK \l "_Toc125862834"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125862834 \h  10  

  HYPERLINK \l "_Toc125862835"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125862835 \h  10  

  HYPERLINK \l "_Toc125862836"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125862836 \h  11  

  HYPERLINK \l "_Toc125862837"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125862837 \h  12  

  HYPERLINK \l "_Toc125862838"  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.	  PAGEREF _Toc125862838 \h  12  

  HYPERLINK \l "_Toc125862839"  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?	  PAGEREF _Toc125862839 \h  12  

  HYPERLINK \l "_Toc125862840"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125862840 \h  13  

  HYPERLINK \l "_Toc125862841"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125862841 \h  15  

  HYPERLINK \l "_Toc125862842"  Region A – Southern Forest Nursery
Management Cooperative - Part B: Crop Characteristics and Methyl Bromide
Use	  PAGEREF _Toc125862842 \h  16  

  HYPERLINK \l "_Toc125862843"  Region A. Southern Forest Nursery
Management Cooperative. 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request	  PAGEREF
_Toc125862843 \h  16  

  HYPERLINK \l "_Toc125862844"  Region A – Southern Forest Nursery
Management Cooperative - 11. (i) Characteristics of Cropping System and
Climate	  PAGEREF _Toc125862844 \h  17  

  HYPERLINK \l "_Toc125862845"  Region A – Southern Forest Nursery
Management Cooperative - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862845 \h  17  

  HYPERLINK \l "_Toc125862846"  Region A – Southern Forest Nursery
Management Cooperative - 12. Historic Pattern of Use of Methyl Bromide,
and/or Mixtures Containing Methyl Bromide, for which an Exemption Is
Requested	  PAGEREF _Toc125862846 \h  18  

  HYPERLINK \l "_Toc125862847"  Region B - International Paper - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862847 \h 
19  

  HYPERLINK \l "_Toc125862848"  Region B. International Paper. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862848 \h  19  

  HYPERLINK \l "_Toc125862849"  Region B. International Paper. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862849
\h  19  

  HYPERLINK \l "_Toc125862850"  Region B - International Paper - 11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862850 \h  20  

  HYPERLINK \l "_Toc125862851"  Region B. International Paper. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862851 \h  21  

  HYPERLINK \l "_Toc125862852"  Region C. Illinois Department of Natural
Resources. Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125862852 \h  22  

  HYPERLINK \l "_Toc125862853"  Region C. Illinois Department of Natural
Resources. 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request	  PAGEREF _Toc125862853
\h  22  

  HYPERLINK \l "_Toc125862854"  Region C. Illinois Department of Natural
Resources. 11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125862854 \h  22  

  HYPERLINK \l "_Toc125862855"  Region C - Illinois Department of
Natural Resources - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862855 \h  23  

  HYPERLINK \l "_Toc125862856"  Region C. Illinois Department of Natural
Resources. 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested	
 PAGEREF _Toc125862856 \h  23  

  HYPERLINK \l "_Toc125862857"  Region D. Weyerhaeuser-South. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862857 \h 
24  

  HYPERLINK \l "_Toc125862858"  Region D. Weyerhaeuser-South. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862858 \h  24  

  HYPERLINK \l "_Toc125862859"  Region D. Weyerhaeuser-South. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862859
\h  24  

  HYPERLINK \l "_Toc125862860"  Region D - Weyerhaeuser-South - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862860 \h  25  

  HYPERLINK \l "_Toc125862861"  Region D. Weyerhaeuser-South. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862861 \h  25  

  HYPERLINK \l "_Toc125862862"  Region E. Weyerhaeuser-West. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862862 \h 
26  

  HYPERLINK \l "_Toc125862863"  Region E. Weyerhaeuser-West. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862863 \h  26  

  HYPERLINK \l "_Toc125862864"  Region E. Weyerhaeuser-West. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862864
\h  26  

  HYPERLINK \l "_Toc125862865"  Region E - Weyerhaeuser-West - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862865 \h  27  

  HYPERLINK \l "_Toc125862866"  Region E. Weyerhaeuser-West. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862866 \h  27  

  HYPERLINK \l "_Toc125862867"  Region F. Weyerhaeuser-South. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862867 \h 
28  

  HYPERLINK \l "_Toc125862868"  Region F. Northeastern Forest and
Conservation Nursery Association. 10. Key Diseases and Weeds for which
Methyl Bromide Is Requested and Specific Reasons for this Request	 
PAGEREF _Toc125862868 \h  28  

  HYPERLINK \l "_Toc125862869"  Region F. Northeastern Forest and
Conservation Nursery Association. 11. Characteristics of Cropping System
and Climate	  PAGEREF _Toc125862869 \h  28  

  HYPERLINK \l "_Toc125862870"  Region F - Northeastern Forest &
Conservation Nursery Association - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862870 \h  29  

  HYPERLINK \l "_Toc125862871"  Region F. Northeastern Forest and
Conservation Nursery Association. 12. Historic Pattern of Use of Methyl
Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125862871 \h  29  

  HYPERLINK \l "_Toc125862872"  Region G. Michigan Seedling Association.
Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125862872 \h  30  

  HYPERLINK \l "_Toc125862873"  Region G. Michigan Seedling Association.
10. Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request	  PAGEREF _Toc125862873 \h  30  

  HYPERLINK \l "_Toc125862874"  Region G. Michigan Seedling Association.
11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125862874 \h  31  

  HYPERLINK \l "_Toc125862875"  Region G - Michigan Seedling Association
- 11. (ii) Indicate if any of the above characteristics in 11. (i)
prevent the uptake of any relevant alternatives?	  PAGEREF _Toc125862875
\h  32  

  HYPERLINK \l "_Toc125862876"  Region G. Michigan Seedling Association.
12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862876 \h  32  

  HYPERLINK \l "_Toc125862877"  Regions A-G. Forest Seedlings. Part C:
Technical Validation	  PAGEREF _Toc125862877 \h  33  

  HYPERLINK \l "_Toc125862878"  Regions A-G. Forest Seedlings. 13.
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125862878 \h 
33  

  HYPERLINK \l "_Toc125862879"  Regions A-G. Forest Seedlings. 14. List
and Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:	 
PAGEREF _Toc125862879 \h  37  

  HYPERLINK \l "_Toc125862880"  Regions A-G. Forest Seedlings. 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125862880 \h  37  

  HYPERLINK \l "_Toc125862881"  Regions A-G. Forest Seedlings.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 _Toc125862881 \h  38  

  HYPERLINK \l "_Toc125862882"  Regions A-G. Forest Seedlings. 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125862882 \h  43  

  HYPERLINK \l "_Toc125862883"  Regions A-G. Forest Seedlings. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125862883 \h  45  

  HYPERLINK \l "_Toc125862884"  Regions A-G. Forest Seedlings. Summary
of Technical Feasibility	  PAGEREF _Toc125862884 \h  46  

  HYPERLINK \l "_Toc125862885"  Part D: Emission Control	  PAGEREF
_Toc125862885 \h  48  

  HYPERLINK \l "_Toc125862886"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125862886 \h  48  

  HYPERLINK \l "_Toc125862887"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125862887 \h  50  

  HYPERLINK \l "_Toc125862888"  Part E: Economic Assessment	  PAGEREF
_Toc125862888 \h  51  

  HYPERLINK \l "_Toc125862889"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125862889 \h  51  

  HYPERLINK \l "_Toc125862890"  22. Gross and Net Revenue	  PAGEREF
_Toc125862890 \h  52  

  HYPERLINK \l "_Toc125862891"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125862891 \h  53  

  HYPERLINK \l "_Toc125862892"  Summary of Economic Feasibility	 
PAGEREF _Toc125862892 \h  58  

  HYPERLINK \l "_Toc125862893"  Part F. Future Plans	  PAGEREF
_Toc125862893 \h  60  

  HYPERLINK \l "_Toc125862894"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125862894 \h  60  

  HYPERLINK \l "_Toc125862895"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125862895 \h  61  

  HYPERLINK \l "_Toc125862896"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125862896 \h  61  

  HYPERLINK \l "_Toc125862897"  26. Citations	  PAGEREF _Toc125862897 \h
 62  

  HYPERLINK \l "_Toc125862898"  APPENDIX B.  Estimated Costs Of
Converting A Loblolly Forest Tree Seedling Nursery From Soil-Based To
Containerized Soilless Culture1	  PAGEREF _Toc125862898 \h  67  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125862900"  Part A:
Summary	  PAGEREF _Toc125862900 \h  9  

  HYPERLINK \l "_Toc125862901"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125862901 \h  10  

  HYPERLINK \l "_Toc125862902"  Table A.1: Executive Summary	  PAGEREF
_Toc125862902 \h  11  

  HYPERLINK \l "_Toc125862903"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125862903 \h  12  

  HYPERLINK \l "_Toc125862904"  Table 8.1. Region A - Southern Forest
Nursery Management Cooperative:  Amount of Methyl Bromide Requested for
Critical Use	  PAGEREF _Toc125862904 \h  13  

  HYPERLINK \l "_Toc125862905"  Table 8.2. Region B - International
Paper: Amount of Methyl Bromide Requested for Critical Use	  PAGEREF
_Toc125862905 \h  13  

  HYPERLINK \l "_Toc125862906"  Table 8.3. Region C - Illinois
Department of Natural Resources:  Amount of Methyl Bromide Requested for
Critical Use	  PAGEREF _Toc125862906 \h  14  

  HYPERLINK \l "_Toc125862907"  Table 8.4. Region D -
Weyerhaeuser-South:  Amount of Methyl Bromide Requested for Critical Use
  PAGEREF _Toc125862907 \h  14  

  HYPERLINK \l "_Toc125862908"  Table 8.5. Region E - Weyerhaeuser-West:
 Amount of Methyl Bromide Requested for Critical Use	  PAGEREF
_Toc125862908 \h  14  

  HYPERLINK \l "_Toc125862909"  Table 8.6. Region F - Northeastern
Forest and Conservation Nursery Association:  Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125862909 \h  15  

  HYPERLINK \l "_Toc125862910"  Table 8.7. Region G - Michigan Seedling
Association:  Amount of Methyl Bromide Requested for Critical Use	 
PAGEREF _Toc125862910 \h  15  

  HYPERLINK \l "_Toc125862911"  Region A – Southern Forest Nursery
Management Cooperative - Part B: Crop Characteristics and Methyl Bromide
Use	  PAGEREF _Toc125862911 \h  16  

  HYPERLINK \l "_Toc125862912"  Region A – Southern Forest Nursery
Management Cooperative - Table 10.1: Key Diseases and Weeds and Reason
for Methyl Bromide Request	  PAGEREF _Toc125862912 \h  16  

  HYPERLINK \l "_Toc125862913"  Region A – Southern Forest Nursery
Management Cooperative - Table 11.1: Characteristics of Cropping System	
 PAGEREF _Toc125862913 \h  17  

  HYPERLINK \l "_Toc125862914"  Region A – Southern Forest Nursery
Management Cooperative - Table 11.2 Characteristics of Climate and Crop
Schedule	  PAGEREF _Toc125862914 \h  17  

  HYPERLINK \l "_Toc125862915"  Region A – Southern Forest Nursery
Management Cooperative - Table 12.1 Historic Pattern of Use of Methyl
Bromide	  PAGEREF _Toc125862915 \h  18  

  HYPERLINK \l "_Toc125862916"  Region B - International Paper - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862916 \h 
19  

  HYPERLINK \l "_Toc125862917"  Region B. International Paper. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request	 
PAGEREF _Toc125862917 \h  19  

  HYPERLINK \l "_Toc125862918"  Region B. International Paper. Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125862918 \h  19 


  HYPERLINK \l "_Toc125862919"  Region B. International Paper. Table
11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125862919 \h  20  

  HYPERLINK \l "_Toc125862920"  Region B. International Paper. Table
12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862920
\h  21  

  HYPERLINK \l "_Toc125862921"  Region C. Illinois Department of Natural
Resources. Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request	  PAGEREF _Toc125862921 \h  22  

  HYPERLINK \l "_Toc125862922"  Region C. Illinois Department of Natural
Resources. Table 11.1: Characteristics of Cropping System	  PAGEREF
_Toc125862922 \h  22  

  HYPERLINK \l "_Toc125862923"  Region C. Illinois Department of Natural
Resources. Table 11.2 Characteristics of Climate and Crop Schedule	 
PAGEREF _Toc125862923 \h  22  

  HYPERLINK \l "_Toc125862924"  Region C. Illinois Department of Natural
Resources. Table 12.1 Historic Pattern of Use of Methyl Bromide	 
PAGEREF _Toc125862924 \h  23  

  HYPERLINK \l "_Toc125862925"  Region D. Weyerhaeuser-South. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request	 
PAGEREF _Toc125862925 \h  24  

  HYPERLINK \l "_Toc125862926"  Region D. Weyerhaeuser-South. Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125862926 \h  24 


  HYPERLINK \l "_Toc125862927"  Region D. Weyerhaeuser-South. Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125862927 \h 
24  

  HYPERLINK \l "_Toc125862928"  Region D. Weyerhaeuser-South. Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862928 \h  25
 

  HYPERLINK \l "_Toc125862929"  Region E. Weyerhaeuser-West. Table 10.1:
Key Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125862929 \h  26  

  HYPERLINK \l "_Toc125862930"  Region E. Weyerhaeuser-West. Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125862930 \h  26  

  HYPERLINK \l "_Toc125862931"  Region E. Weyerhaeuser-West. Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125862931 \h 
26  

  HYPERLINK \l "_Toc125862932"  Region E. Weyerhaeuser-West. Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862932 \h  27
 

  HYPERLINK \l "_Toc125862933"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request	  PAGEREF _Toc125862933 \h  28  

  HYPERLINK \l "_Toc125862934"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125862934 \h  28  

  HYPERLINK \l "_Toc125862935"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 11.2 Characteristics of Climate
and Crop Schedule	  PAGEREF _Toc125862935 \h  28  

  HYPERLINK \l "_Toc125862936"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 12.1 Historic Pattern of Use of
Methyl Bromide	  PAGEREF _Toc125862936 \h  30  

  HYPERLINK \l "_Toc125862937"  Region G. Michigan Seedling Association.
Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
  PAGEREF _Toc125862937 \h  30  

  HYPERLINK \l "_Toc125862938"  Region G. Michigan Seedling Association.
Table 11.1: Characteristics of Cropping System	  PAGEREF _Toc125862938
\h  31  

  HYPERLINK \l "_Toc125862939"  Region G. Michigan Seedling Association.
Table 11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125862939 \h  31  

  HYPERLINK \l "_Toc125862940"  Region G. Michigan Seedling Association.
Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125862940 \h  32  

  HYPERLINK \l "_Toc125862941"  Regions A-G. Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125862941 \h  33  

  HYPERLINK \l "_Toc125862942"  Regions A-G. Forest Seedlings. Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125862942 \h  37  

  HYPERLINK \l "_Toc125862943"  Regions A-G. Forest Seedlings. Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125862943 \h  37  

  HYPERLINK \l "_Toc125862944"  Regions A-G. Forest Seedlings. Table
16.1.A: Effectiveness of Alternatives–Weeds	  PAGEREF _Toc125862944 \h
 38  

  HYPERLINK \l "_Toc125862945"  Regions A-G. Forest Seedlings. Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125862945 \h  43
 

  HYPERLINK \l "_Toc125862946"  Part D: Emission Control	  PAGEREF
_Toc125862946 \h  48  

  HYPERLINK \l "_Toc125862947"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125862947 \h  49  

  HYPERLINK \l "_Toc125862948"  Part E: Economic Assessment	  PAGEREF
_Toc125862948 \h  51  

  HYPERLINK \l "_Toc125862949"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125862949 \h
 51  

  HYPERLINK \l "_Toc125862950"  Table 22.1: Year 1 Gross and Net Revenue
  PAGEREF _Toc125862950 \h  52  

  HYPERLINK \l "_Toc125862951"  Region A - Table E.1: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc125862951 \h  53  

  HYPERLINK \l "_Toc125862952"  Region B - International Paper - Table
E.2: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862952 \h  54  

  HYPERLINK \l "_Toc125862953"  Region C - Illinois Department of
Natural Resources - Table E.3: Economic Impacts of Methyl Bromide
Alternatives	  PAGEREF _Toc125862953 \h  55  

  HYPERLINK \l "_Toc125862954"  Region d - Weyerhaeuser South - Table
E.4: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862954 \h  56  

  HYPERLINK \l "_Toc125862955"  Region E - Weyerhaeuser West - Table
E.5: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862955 \h  56  

  HYPERLINK \l "_Toc125862956"  Region F - Northeastern Forest &
Conservation Nursery Association - Table E.6: Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125862956 \h  57  

  HYPERLINK \l "_Toc125862957"  Region G - Michigan Seedling Association
- Table E.7: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862957 \h  58  

  HYPERLINK \l "_Toc125862958"  Part F. Future Plans	  PAGEREF
_Toc125862958 \h  60  

  HYPERLINK \l "_Toc125862959"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125862959 \h  66  

 

Part A: Summary  TC "Part A: Summary" \f C \l "1"    TC "Part A:
Summary" \f F \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 (MB) Critical Use Nomination for Preplant Soil Use for
Forest Seedlings (Submitted in 2006 for 2008 Use Season)

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



Forest seedling nurseries in the U.S. supply conifer and hardwood
seedlings that are used for reforestation, forest establishment, fiber
production, and wildlife and conservation uses.  In a survey conducted
in 2001-2002 (Southern Forest Nursery Management Cooperative, Appendix 1
of their request), there were approximately 1.7 billion pine seedlings
produced in the southern region of the U.S., which accounted for 80% of
U. S. pine seedling production.  Nurseries in the U.S. are located in
eight climate zones (Zones 3 to 10) and have mostly light or medium
soils.  The majority of seedlings are species of conifers, especially
pine.  In addition, 30-60 species of hardwoods, such as oaks, hickory,
poplars, and ash, are produced.  Nurseries produce seedlings adapted to
their respective regional conditions, with variables such as climate and
soil type.  Forest seedling nurseries requesting critical use of MB
include both public and private nursery operations.

Nurseries of this sector produce mostly conifer seedlings, which are
typically grown for one or two years in seedling beds.  After harvest,
beds have one or two years of fallow or cover crops.  Managers typically
fumigate a particular conifer seedling bed with MB once every 3-4 years,
i.e., one-quarter to one-third of the total nursery land is fumigated
each year to produce two or three harvestable forest seedling crops per
single bed fumigation.  Effective fumigants, such as MB, permit less
frequent bed fumigation per harvestable seedling crop.  For hardwood
seedlings, fumigation is usually provided prior to each seedling crop,
as hardwood species are generally more prone to root rots and
damping-off diseases than conifers, although the production volume of
hardwoods is smaller than overall conifer production.

At the appropriate stage of maturity, forest seedlings are harvested in
the nursery, packaged, and transported to the planting site.  Seedlings
are usually culled or sized during the harvesting process, with culled
trees discarded.  Nurseries that grade their seedlings may sell lower
grade seedlings at a reduced price, or discard all but the highest grade
seedlings.  The impact of seedling quality, particularly seedling size,
on the success of plantation establishment cannot be overstated.  The
production of large and healthy planting stock is essential to the
economic viability of reforestation processes.  These typically include
soil preparation at the planting site, transportation to the planting
site, planting, and weed control after planting.  The quality of
seedlings is highly correlated with the success of the regeneration
process and corresponding long-term economic and use benefits, where
seedling quality results in greater survival rates and faster growth. 
Maintaining pest-free nursery soils is the backbone of an integrated
pest management approach to producing healthy seedlings and the
foundation for establishing economically viable forests.  

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	133,140	527



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 for those areas where the alternatives are not
effective against key pests when pressure is moderate to high.  The use
of MB is considered critical where alternatives are not suitable because
of regulatory, economic, or technical constraints.  Although alternative
treatments can be foreseen as long-term solutions to MB use, transition
from MB will depend on the development of application technologies to
better deliver these alternatives to soils containing target pests.  In
addition, because of MB efficacy, two or three seedling crops can be
grown with each MB application—generally applied once in three or four
years.  Alternative treatments are likely to be a combination of
treatments, both chemical and non-chemical, which may involve increased
costs and environmental pesticide burdens.  

Forest nurseries throughout the U. S. contend with a variety of pests. 
Effective fumigation is relied on to manage fungal pathogens (e.g.,
Fusarium, Alternaria, Phytophthora, Pythium, Rhizoctonia,
Cylindrocladium spp., Cylindrocarpon, and Macrophomina), nematodes
(e.g., Circonemoides, Helicotylenchus), and yellow and purple nutsedges
(species of Cyperus) (Cram and Fraedrich, 1997).  Nutsedges are
generally considered among the major pests of forest seedling nurseries
in the southeastern U.S. and the pests most difficult to manage.  

Concerns for crop damage and worker exposure of some alternatives have
been expressed by nursery growers after a significant outgassing
incident from metam-sodium, in 1999, resulted in destruction of millions
of nursery seedlings (described in the request by International Paper). 
Because of the importance placed on seedling quality, failure to achieve
consistently healthy seedlings in even a fraction of the production beds
can have a devastating effect on this sector's ability to provide
acceptable seedlings.  

Inconsistency in pest management performance by alternatives has been
the primary concern for this sector, and the reason that MB is currently
critical for maintaining high quality seedlings.  While direct yield
losses, in terms of seedlings/hectare, were not large on average,
intensive seedling production relies on the ability of nursery managers
to meet quality, as well as yield, goals.  In addition, economic issues
such as increased application costs (e.g., costs associated with
application of metam-sodium and a separate chloropicrin application) may
have an impact on overall feasibility of these alternatives for the
forest seedlings sector.  

As research identifies the most effective alternatives and application
methodologies with alternative treatments, industry transition to these
alternatives will accelerate.  Research is ongoing to develop protocols
for likely alternatives, such as 1,3-D and metam-sodium, and integrated
methods with chemicals and non-chemicals.  The requesting consortia are
developing timelines that will help determine how the transition from MB
will be achieved, most likely by implementing an integrated management
strategy with a combination of chemical and non-chemical treatments. 
While field trials proceed, however, there is a critical need for MB for
this sector for the 2008 use season.

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

Region	SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE	International
Paper	Illinois Department of Natural Resources	Weyerhaeuser South
Weyerhaeuser West	Northeastern Forest & Conservation Nursery Assoc
Michigan Seedling Association

Kilograms (kg)	246,032	15,728	4,264	17,962	16,506	29,276	7,050

Amount of Applicant Request

2008 Kilograms (kg)	246,032	15,714	4,264	17,962	16,491	29,250	6,908

Amount of Nomination *

2008 Kilograms (kg)	60,764	10,627	3,819	13,889	16,491	20,946	6,604

*See Appendix A for 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"  :



Alternatives to MB are currently problematic for optimal seedling
production because of their inconsistent performance from season to
season, for nurseries with moderate to high pest (especially weed)
pressure (e.g., Fraedrich and Dwinell, 2003a, 2003b, 2003c; Carey, 2000;
Carey, 1996; Carey, 1994; Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10,
1994-96).  While chemicals such as chloropicrin, metam-sodium, dazomet,
herbicides, or 1,3-D can be effective in some situations in reducing
pest infestations, including weed problems, inconsistency in pest
management by chemical alternatives is the primary concern for this
sector, and the reason that MB is currently critical for maintaining
high quality seedlings.  For example, Fraedrich and Dwinell (2003b)
found that dazomet had some efficacy against nutsedge in field trials
one year in two southern nurseries.  But in one of the nurseries in
Georgia, nutsedge plant populations increased over the course of the
summer.  They cautioned that “…[i]f dazomet is to be used for
nutsedge control, additional efforts will be necessary to better define
the optimal use conditions”.  Fraedrich and Dwinell (2003c) also
conducted studies with glyphosate as a possible control for nutsedge. 
Two years of study suggested that glyphosate in broadcast treatments
might be a feasible treatment.  However, an integrated system of pest
management must first be developed to achieve acceptable levels of
control.  

Research studies with organic and inorganic soil amendments (Fraedrich
and Dwinell, 1998; James et al., 1997; James et al., 2001; Lantz, 1997;
Stone et al., 1998) resulted in reduction in populations of certain
pathogens, but the effects were variable depending on the nursery
locations and species of seedlings.  Furthermore, it was unclear if
pathogen population size was correlated with disease incidence.  More
research is required before there can be commercial application of these
methods as independent treatments.  

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



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

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

A. Southern Forest Nursery Management Cooperative 	Not available	Not
available

B. International Paper 	Not available	Not available

C. Illinois Dept of Natural Resources 	Not available	Not available

D. Weyerhaeuser-South 	Not available	Not available

E. Weyerhaeuser-West 	Not available	Not available

F. Northeastern Forest and Conservation Nursery Association 	Not
available	Not available

G. Michigan Seedling Association 	Not available	Not available





National Total**:	51,506	2%

*Typically, only a fraction of a nursery’s beds are fumigated in a
given year.

**National average may include states not requesting methyl bromide.

7. (ii) If only part of the crop area is treated with methyl bromide,
indicate the reason why methyl bromide is not used in the other area,
and identify what alternative strategies are used to control the target
pathogens and weeds without methyl bromide there.  TC "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." \f C \l "2"  



Alternatives such as metam-sodium, chloropicrin, dazomet are used in
approximately half of nursery hectares, especially those without severe
nutsedge problems.  Where soil types and temperatures are conducive, and
especially where pest pressure is not high, these alternatives can be
effective.  This nomination, however, applies to those nurseries where
alternatives are not effective.  MB allows conifer seedling beds to be
fumigated after two or three crops (as opposed to after every crop)
because of the effectiveness of MB, which usually makes a second-year
treatment unnecessary.  Moreover, during the subsequent two years, beds
are fallowed or an unfumigated cover crop is planted.  With severe
infestations of pests alternative products usually are applied more
often, or several treatments with more than one alternative are used. 
Higher costs can be incurred if appropriate pest management strategies
have not been properly designed.

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?  TC "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?" \f C \l "2"  



Nurseries of this sector have been implementing some methods (cover crop
or fallow) that can reduce pest infestations.  Strategies to replace MB
are being studied by all of the nurseries involved.  Within the next few
years there will be considerable empirical data to identify the
effectiveness of MB alternatives feasible for this sector, probably by
implementing an integrated management strategy with a combination of
chemical and non-chemical treatments.  Until this time, however, there
is a critical need for MB for this sector.

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



Table 8.1. Region A – Southern Forest Nursery Management Cooperative: 
Amount of Methyl Bromide Requested for Critical Use  TC "Table 8.1.
Region A - Southern Forest Nursery Management Cooperative:  Amount of
Methyl Bromide Requested for Critical Use" \f F \l "1"  

Year of Exemption Request	2008

Kilograms of MB	246,032

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	656

Application rate* (kg/ha) for the Active Ingredient	375

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	37.5



Table 8.2. Region B - International Paper: Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.2. Region B - International
Paper: Amount of Methyl Bromide Requested for Critical Use" \f F \l "1" 
 

Year of Exemption Request	2008

Kilograms of MB	15,714

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	41

Application rate* (kg/ha) for the Active Ingredient	386

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	30.4



Table 8.3. Region C - Illinois Department of Natural Resources:  Amount
of Methyl Bromide Requested for Critical Use  TC "Table 8.3. Region C -
Illinois Department of Natural Resources:  Amount of Methyl Bromide
Requested for Critical Use" \f F \l "1"   

Year of Exemption Request	2008

Kilograms of MB	4264

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	16

Application rate* (kg/ha) for the Active Ingredient	263

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	26.3



Table 8.4. Region D - Weyerhaeuser-South:  Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.4. Region D -
Weyerhaeuser-South:  Amount of Methyl Bromide Requested for Critical
Use" \f F \l "1"   

Year of Exemption Request	2008

Kilograms of MB	17,962

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	53

Application rate* (kg/ha) for the Active Ingredient	336

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	33.6



Table 8.5. Region E - Weyerhaeuser-West:  Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.5. Region E - Weyerhaeuser-West:
 Amount of Methyl Bromide Requested for Critical Use" \f F \l "1"   

Year of Exemption Request	2008

Kilograms of MB	16,491

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	69

Application rate* (kg/ha) for the Active Ingredient	239

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	23.9



Table 8.6. Region F - Northeastern forest and Conservation Nursery
Association:  Amount of Methyl Bromide Requested for Critical Use  TC
"Table 8.6. Region F - Northeastern Forest and Conservation Nursery
Association:  Amount of Methyl Bromide Requested for Critical Use" \f F
\l "1"   

Year of Exemption Request	2008

Kilograms of MB	29,250

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	81

Application rate* (kg/ha) for the Active Ingredient	363

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	36.3



Table 8.7. Region G - Michigan Seedling Association:  Amount of Methyl
Bromide Requested for Critical Use  TC "Table 8.7. Region G - Michigan
Seedling Association:  Amount of Methyl Bromide Requested for Critical
Use" \f F \l "1"   

Year of Exemption Request	2008

Kilograms of MB	6,908

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	26

Application rate* (kg/ha) for the Active Ingredient	266

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	26.6



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 MB 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.  No adjustment was made for this sector. 

Hectares counted in more than one application, or rotated within one
year of an application to a crop that also uses MB, were subtracted. 
The double counted hectares were removed.

Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.  The five applicants that included growth in their request
had the growth amount removed.  

Quarantine and pre-shipment (QPS) hectares were removed from each
applicant’s request.

Only the hectares with moderate to heavy key pest pressure were included
in the nominated amount.  

Region A – Southern Forest Nursery Management Cooperative - Part B:
Crop Characteristics and Methyl Bromide Use  TC "Region A – Southern
Forest Nursery Management Cooperative - Part B: Crop Characteristics and
Methyl Bromide Use" \f F \l "1"    TC "Region A – Southern Forest
Nursery Management Cooperative - Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"  



Region A – Southern Forest Nursery Management Cooperative - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request  TC "Region A. Southern Forest Nursery
Management Cooperative. 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request" \f C \l "2" 




Region A – Southern Forest Nursery Management Cooperative - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request  TC
"Region A – Southern Forest Nursery Management Cooperative - 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

Southern Forest Nursery Management Cooperative	Fungi [100% at times]:
Fusarium, Macrophomina, Rhizoctonia, Pythium, Phytophthora;	For areas
where pest pressure is high, MB provides sufficient protection for three
successive seedling crops, with one fumigation treatment (one treatment
every four years). Until protocols are developed to improve efficacy of
alternative treatments, there may be a need to provide additional
fumigation treatments, or use a combination of chemicals and other
effective treatments that may increase costs, beyond what is feasible.

	Weeds [100% at times]: broadleaf, grasses, sedges



Nematodes [100% at times]: Circonemoides, Helicotylenchus

	

Region A – Southern Forest Nursery Management Cooperative - 11. (i)
Characteristics of Cropping System and Climate  TC "Region A –
Southern Forest Nursery Management Cooperative - 11. (i) Characteristics
of Cropping System and Climate" \f C \l "2"  



Region A – Southern Forest Nursery Management Cooperative - Table
11.1: Characteristics of Cropping System  TC " Region A – Southern
Forest Nursery Management Cooperative - Table 11.1: Characteristics of
Cropping System" \f F \l "1"  

Characteristics	Southern Forest Nursery Management Cooperative

Crop Type: 	Bareroot forest seedlings (91-96% pine, 4-9% hardwood
species)

Annual or Perennial Crop: 	Conifers: Typically grown for 1 year for each
of two or three crops before fumigation on fourth year;

Hardwoods: Prior to each crop

Typical Crop Rotation  and use of methyl bromide for other crops in the
rotation: 	Cover crops are used to reduce pest pressure on target crops;
cover crops used include sorghum and corn 

Soil Types: 	Light (85%); medium (15%)

Frequency of methyl bromide Fumigation: 	Typically, fumigated once in
3-4 years

Other relevant factors:	No other relevant factors were identified.



Region A - Southern Forest Nursery Management Cooperative - Table 11.2
Characteristics of Climate and Crop Schedule  TC "Region A – Southern
Forest Nursery Management Cooperative - Table 11.2 Characteristics of
Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA zones 7a, 7b, 8a, 8b (nurseries in: Alabama,
Arkansas, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma,
South Carolina, Tennessee, Texas, Virginia)

Rainfalla (mm)	125	128	155	135	91	100	141	118	76	52	87	131

Outside Temp. ((C)	7.7	10.0	13.9	18.3	22.2	26.1	27.2	27.2	25.0	18.9	13.9
10.0

Fumigation Schedule	1st year











	Planting  Scheduleb

2nd 3rd 4th years











aThe rainfall and temperature data are for Alabama, which may be
considered typical of the region.

bFumigation generally occurs once in three or four years.  According to
this consortium, “The typical crop cycle would include a period of
cover crop and fallow, nine to 24 months, after the second harvest
(months 25-48).  After the cover crop and/or fallow period, the area
would be fumigated again and the crop cycle would continue.”

Region A - Southern Forest Nursery Management Cooperative - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?  TC "Region A – Southern Forest
Nursery Management Cooperative - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?" \f C \l "2"  



Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden. 

Region A – Southern Forest Nursery Management Cooperative - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested  TC "Region A –
Southern Forest Nursery Management Cooperative - 12. Historic Pattern of
Use of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for
which an Exemption Is Requested" \f C \l "2"   



Region A - Southern Forest Nursery Management Cooperative - Table 12.1
Historic Pattern of Use of Methyl Bromide  TC "Region A – Southern
Forest Nursery Management Cooperative - Table 12.1 Historic Pattern of
Use of Methyl Bromide" \f F \l "1"  

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

Area Treated (hectares)	656	656	656	656	656	656

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	not available	flat fumigation	flat fumigation	flat
fumigation	flat fumigation	flat fumigation

Amount of methyl bromide active ingredient used 

(total kilograms)	246,032	246,032	246,032	246,032	246,032	246,032

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 )	shank injected w/tarp	shank
injected w/tarp 	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

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

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

* For flat fumigation treatment application rate and dosage rate may be
the same.

aData are based on a survey of consortium members in 2000.  Consortium
does not keep records of seedling production data but assumes that use
rates and production information do not vary significantly from year to
year.

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



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



Region B - International Paper - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region B. International Paper.
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

International Paper	Fungi: Rhizoctonia (root rot);	For areas where pest
pressure is high, MB allows two successive seedling crops with one
fumigation treatment (one treatment every four years).  Alternative
treatments will require more frequent fumigation due to reduced efficacy
until protocols are developed to improve efficacy.

	Weeds: Cyperus esculentus/rotundus (purple/yellow nutsedge)

	

Region B - International Paper - 11. (i) Characteristics of Cropping
System and Climate  TC "Region B. International Paper. 11.
Characteristics of Cropping System and Climate" \f C \l "2"  



Region B – International Paper - Table 11.1: Characteristics of
Cropping System  TC " Region B. International Paper. Table 11.1:
Characteristics of Cropping System" \f F \l "1"  

Characteristics	International Paper

Crop Type: 	Forest seedlings (all pine species) and some hardwoods

Annual or Perennial Crop:	Typically grown for each of two years followed
by two years of unfumigated cover crops before fumigation in the fourth
year just before sowing the first seedling crop

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

Soil Types: 	Light, medium, heavy

Frequency of methyl bromide Fumigation: 	Fumigation once in four years

Other relevant factors:	No other relevant factors were identified.



Region B – International Paper - Table 11.2 Characteristics of Climate
and Crop Schedule  TC "Region B. International Paper. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA zones 6b, 7a, 7b, 8a, 8b (Alabama, Arkansas, Georgia,
South Carolina, Texas)

Rainfall (mm)	Not available, but varies with diverse climates 

Outside Temp. ((C)	Not available, but varies with diverse climates

Fumigation Schedule







1st year





Planting  Schedulea

2nd 3rd 4th years











aFumigation occurs once in four years for conifers after two or three
crops are harvested.

Region B - International Paper - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region B - International Paper - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"  



Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden.   International Paper
estimated in 2003 (Dr. George Lowerts, personal communication), that
typically, a 10-day delay would be incurred with alternative treatments
such as 1,3-D to avoid phytotoxic effects.  

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



Region B - International Paper - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region B. International Paper. 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)	185	121	115	101	130	131

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 	68,975	43,646	38,666
34,853	49942	50253

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 	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	374	362	338	344	384	384

Actual dosage rate [active ingredient] (g/m2)*	37.4	36.2	33.8	34.4	38.4
38.4

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region C - Illinois Department of Natural Resources - Part B: Crop
Characteristics and Methyl Bromide Use  TC "Region C. Illinois
Department of Natural Resources. Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"  



Region C - Illinois Department of Natural Resources - 10. Key Diseases
and Weeds for which Methyl Bromide Is Requested and Specific Reasons for
this Request  TC " Region C. Illinois Department of Natural Resources.
10. Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request" \f C \l "2"  



Region C - Illinois Department of Natural Resources - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request  TC "Region C.
Illinois Department of Natural Resources. 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

Illinois Department of Natural Resources	Fusarium spp.	Consistency in
production for the variety of nursery plants grown in small public
nursery.

	weeds



nematodes

	

Region C - Illinois Department of Natural Resources - 11. (i)
Characteristics of Cropping System and Climate  TC " Region C. Illinois
Department of Natural Resources. 11. Characteristics of Cropping System
and Climate" \f C \l "2"  



Region C - Illinois Department of Natural Resources - Table 11.1:
Characteristics of Cropping System  TC " Region C. Illinois Department
of Natural Resources. Table 11.1: Characteristics of Cropping System" \f
F \l "1"  

Characteristics	Illinois Department of Natural Resources

Crop Type: 	Hardwood seedlings (13 ha); shrubs (2 ha); prairie forbs (1
ha)

Annual or Perennial Crop: 	Typically grown for 1 or 2 years

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

Soil Types:  	Light

Frequency of methyl bromide Fumigation: 	Fumigation every year

Other relevant factors:	No other relevant factors were identified.



Region C - Illinois Department of Natural Resources - Table 11.2
Characteristics of Climate and Crop Schedule  TC " Region C. Illinois
Department of Natural Resources. Table 11.2 Characteristics of Climate
and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA zones 5b, 6b

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedule





X







Planting 

Schedule







X







Region C - Illinois Department of Natural Resources - 11. (ii) Indicate
if any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?  TC "Region C - Illinois Department of Natural
Resources - 11. (ii) Indicate if any of the above characteristics in 11.
(i) prevent the uptake of any relevant alternatives?" \f C \l "2"  



For this small, public consortium, fumigation in the fall followed by
planting is the most effective means of meeting production goals. 
Alternatives will require delays due to increased labor costs for hand
weeding, and potential outgassing damage to already planted beds.

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



Region C - Illinois Department of Natural Resources - Table 12.1
Historic Pattern of Use of Methyl Bromide  TC "Region C. Illinois
Department of Natural Resources. 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)	17	16	13	16	15	15

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 

(total kilograms)	4,370	4,211	3,411	4,232	3,869	3,869

formulations of methyl bromide (methyl bromide:chloropicrin)	67:33	67:33
67:33	67:33	67:33	67:33

Method by which methyl bromide applied 	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	263	263	263	263	263	263

Actual dosage rate [active ingredient] (g/m2)*	26.3	26.3	26.3	26.3	26.3
26.3

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region D - Weyerhaeuser-South - Part B: Crop Characteristics and Methyl
Bromide Use  TC "Region D. Weyerhaeuser-South. Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"  



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



Region D - Weyerhaeuser-South - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region D. Weyerhaeuser-South.
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

Weyerhaeuser-South	Fungi: Fusarium, Pythium, Rhizoctonia;	Only #1 grade
seedlings are sold; grade #2 and culls are discarded.  To economically
manage the range of pests (where infestation of fungal pathogens and
nutsedges is severe), MB is necessary since no alternatives currently
provide both reliable control and economic sustainability for #1 grade
seedlings.

	Weeds: Cyperus (nutsedges)

	

Region D - Weyerhaeuser-South - 11. (i) Characteristics of Cropping
System and Climate  TC " Region D. Weyerhaeuser-South. 11.
Characteristics of Cropping System and Climate" \f C \l "2"  



Region D - Weyerhaeuser-South - Table 11.1: Characteristics of Cropping
System  TC " Region D. Weyerhaeuser-South. Table 11.1: Characteristics
of Cropping System" \f F \l "1"  

Characteristics	Weyerhaeuser-South

Crop Type: 	Primarily loblolly pine; some hardwood species

Annual or Perennial Crop:	Typically grown for 1 year

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

Soil Types: 	Light (62%); Medium (22%)

Frequency of methyl bromide Fumigation: 	Fumigation once in four years
(conifers)

Other relevant factors:	No other relevant factors were identified.



Region D - Weyerhaeuser-South - Table 11.2 Characteristics of Climate
and Crop Schedule  TC " Region D. Weyerhaeuser-South. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA 7b, 8a (includes Alabama, Arkansas, North Carolina,
and South Carolina)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedule







1st year





Planting  Schedulea

2nd 3rd 4th years











aFumigation occurs once in four years, one year old conifer seedlings
are harvested.

Region D - Weyerhaeuser-South - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region D - Weyerhaeuser-South - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"  



Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden.

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



Region D - Weyerhaeuser-South - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region D. Weyerhaeuser-South. 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)	72	66	61	64	66	72

73

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)	29,649	21,516
21,709	24,231	26,079	29803

formulations of methyl bromide (methyl bromide:chloropicrin)	98:2	90:10
90:10	90:10	98:2	98:2

Method by which methyl bromide applied )	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	412	327	355	379	398	406

Actual dosage rate [active ingredient] (g/m2)*	41.2	32.7	35.5	37.9	39.8
40.6

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region E - Weyerhaeuser-West - Part B: Crop Characteristics and Methyl
Bromide Use  TC "Region E. Weyerhaeuser-West. Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"  



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




Region E - Weyerhaeuser-West - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region E. Weyerhaeuser-West.
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

Weyerhaeuser-West	Fungi [100% at times]: Cylindrocarpon (root rot);
Pythium (damping-off, root rot), Fusarium (damping-off, root rot),
Phoma, Fusarium, Botrytis (stem cankers);	Cylindrocarpon root rot is an
increasingly important disease, with no registered chemicals.  Applicant
states that increased area reflects increased losses to the disease and
necessity of continued production numbers.  High pathogen populations
and potential for contamination with Phytophthora ramorum (sudden oak
death) leave little room for production variability.

	Weeds: Cyperus (yellow nutsedge) [100% at times]

	

Region E - Weyerhaeuser-West - 11. (i) Characteristics of Cropping
System and Climate  TC " Region E. Weyerhaeuser-West. 11.
Characteristics of Cropping System and Climate" \f C \l "2"  



Region E - Weyerhaeuser-West - Table 11.1: Characteristics of Cropping
System  TC " Region E. Weyerhaeuser-West. Table 11.1: Characteristics of
Cropping System" \f F \l "1"  

Characteristics	Weyerhaeuser-West

Crop Type: 	Pine, Christmas trees, some hardwoods 

Annual or Perennial Crop: 	Typically one year seedling bed, one year
transplant bed; transplants can be grown for 2, 3, or 4 years

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

Soil Types: 	Light (60%), Medium (40%)

Frequency of methyl bromide Fumigation: 	Fumigation once in 3 years

Other relevant factors:	No other relevant factors were identified.



Region E - Weyerhaeuser-West - Table 11.2 Characteristics of Climate and
Crop Schedule  TC " Region E. Weyerhaeuser-West. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA zones 8a, 8b (includes Washington and western Oregon)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea





1st year







Planting Schedule

2nd

3rd











aTypically fumigation occurs once in three years, one year old seedlings
are harvested.

Region E - Weyerhaeuser-West - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region E - Weyerhaeuser-West - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"  



Fumigation occurs once in a three year cycle.  Typically, two successive
annual seedling crops are produced for each fumigation event. 
Alternatives may require more frequent fumigation (with 1,3-D +
chloropicrin, for example) or a combination of treatments that could
significantly increase the costs and environmental burden.  

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



Region E - Weyerhaeuser-West - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region E. Weyerhaeuser-West. 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)	43	70	65	70	76	95

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 

(total kilograms)	11,360	17,864	17,125	14,647	16,935	19,122

formulations of methyl bromide 

(methyl bromide:chloropicrin)	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied 

(e.g. injected at 25cm depth, hot gas)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	262	255	263	210	224	201

Actual dosage rate [active ingredient] (g/m2)*	26.2	25.5	26.3	21.0	22.4
20.1

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region F - Northeastern Forest & Conservation Nursery Association - Part
B: Crop Characteristics and Methyl Bromide Use  TC "Region F.
Weyerhaeuser-South. Part B: Crop Characteristics and Methyl Bromide Use"
\f C \l "1"  



Region F - Northeastern Forest & Conservation Nursery Association - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request  TC " Region F. Northeastern Forest
and Conservation Nursery Association. 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request"
\f C \l "2"  



Region F - Northeastern Forest & Conservation Nursery Association -
Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
 TC "Region F. Northeastern Forest and Conservation Nursery Association.
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

Northeastern Forest & Conservation Nursery Association	Fungi:
Phytophthora (damping-off, root rot) [80%], Fusarium (damping-off, root
rot) [80%], Cylindrocladium [50%];	In humid, warm conditions damping-off
is a significant problem; as with much of industry, weed problems,
especially nutsedge and Canada thistle, are difficult to manage without
MB. 

	Weeds: Cyperus (yellow nutsedge) [40%], Cirsium (Canada thistle) [70%]

	

Region F - Northeastern Forest & Conservation Nursery Association - 11.
(i) Characteristics of Cropping System and Climate  TC " Region F.
Northeastern Forest and Conservation Nursery Association. 11.
Characteristics of Cropping System and Climate" \f C \l "2"  



Region F - Northeastern Forest & Conservation Nursery Association -
Table 11.1: Characteristics of Cropping System  TC " Region F.
Northeastern Forest and Conservation Nursery Association. Table 11.1:
Characteristics of Cropping System" \f F \l "1"  

Characteristics	Northeastern Forest and Conservation Nursery Association

Crop Type: 	Conifers (10-15 spp.)= 1-yr, 8%; 2-yr, 4%; 3-yr, 14%;
hardwoods (30-50 spp.)= 1-yr, 55%; 2-yr, 9%; shrubs and forbs (>75
spp.)= 10%

Annual or Perennial Crop: 	Bareroot cuttings, and transplants, typically
grown 1-3 years

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

Soil Types: 	Light, Medium

Frequency of methyl bromide Fumigation: 	Fumigation minimum, once in two
years; depending on species, can be once in two to four years

Other relevant factors:	No other relevant factors were identified.



Region F - Northeastern Forest & Conservation Nursery Association -
Table 11.2 Characteristics of Climate and Crop Schedule  TC " Region F.
Northeastern Forest and Conservation Nursery Association. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	USDA zones 3a, 4b, 5a, 5b, 6a, 6b, 7a (includes
state-owned nurseries in Illinois, Indiana, Kentucky, Maryland,
Missouri, New Jersey, Ohio, Pennsylvania, West Virginia, and Wisconsin)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea





	X





	Planting  Schedulea	X	X	X



	X	X	X



aDue to the large number of species and wide geographical area
represented in this consortium, seedlings can be planted at various
times in the fall or spring.  Generally, fumigation occurs once in two
or three years, but beds for certain hardwood species may be treated
every year.

Region F - Northeastern Forest & Conservation Nursery Association - 11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?  TC "Region F - Northeastern Forest
& Conservation Nursery Association - 11. (ii) Indicate if any of the
above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?" \f C \l "1"  



Fumigation occurs once in a two to three year cycle.  Numerous species
are grown by nurseries in this consortium, but typically, two successive
annual seedling crops are produced for each fumigation event.  Until
effective combination treatments can be devised, alternatives (e.g.,
dazomet) may require application to each crop, or application of several
different treatments, which could increase significantly the costs and
environmental burden.

Region F - Northeastern Forest & Conservation Nursery Association - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested  TC "Region F.
Northeastern Forest and Conservation Nursery Association. 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested" \f C \l "2"   



Variation in MB use is due to changes in products, and may be determined
by market demand and/or availability of seed.  Changes in product will
affect area planted (and therefore treated).  For example, hardwoods are
grown at densities of 65-130 seedlings/m2, while conifer seedlings are
grown at densities of 215-320 seedlings/m2.  Changes in the proportion
of hardwood and pine seedlings, therefore, will affect the area
requiring fumigation.

Region F - Northeastern Forest & Conservation Nursery Association -
Table 12.1 Historic Pattern of Use of Methyl Bromide  TC "Region F.
Northeastern Forest and Conservation Nursery Association. 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)	91	87	80	72	87	78

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 

(total kilograms)	31,961	28,308	26,844	26,273	30,798	29,027

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)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	352	326	337	363	359	372

Actual dosage rate [active ingredient] (g/m2)*	35.2	32.6	33.7	36.3	35.9
37.2

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region G - Michigan Seedling Association - Part B: Crop Characteristics
and Methyl Bromide Use  TC "Region G. Michigan Seedling Association.
Part B: Crop Characteristics and Methyl Bromide Use" \f C \l "1"  



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



Region G - Michigan Seedling Association - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request  TC "Region G. Michigan
Seedling Association. 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 Seedling Association	Primarily annual and perennial weeds
(e.g., nutsedge, Canada thistle); also, fungal pathogens; nematodes
Nutsedge (50% of area), common groundsel (95% of area), hairy
bittercress (60% of area), Canada thistle (25% of area), and mugwort
(20% of area); Soil-borne diseases are also of concern; dazomet and
metam-sodium are not reliable in this region because of cooler soil
temperatures.



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



Region G - Michigan Seedling Association - Table 11.1: Characteristics
of Cropping System  TC "Region G. Michigan Seedling Association. Table
11.1: Characteristics of Cropping System" \f F \l "1"  

Characteristics	Michigan Seedling Association

Crop Type: 	Conifers, hardwoods

Annual or Perennial Crop: 	Conifers: bareroot and transplants, typically
1, 2, or 3 years growth; Hardwood: 1-year (80%) and 2-year (20%)

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Crop grown on half the area.  Land not in production are left
fallow for 1-2 years, and planted with rye in Oct-Nov and Sudex in
March-April.

Soil Types:  	Light

Frequency of methyl bromide Fumigation: 	Fumigation every year on land
in production (approximately half the land).  Therefore, an average area
of nursery is fumigated once in two years.

Other relevant factors:	No other relevant factors were identified.



Region G - Michigan Seedling Association - Table 11.2 Characteristics of
Climate and Crop Schedule  TC " Region G. Michigan Seedling Association.
Table 11.2 Characteristics of Climate and Crop Schedule" \f F \l "1"   

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

Climatic Zone	USDA zones 4b, 5a, 5b

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

	(sometimes) Spring

	(usually) Fall	(usually) Fall





	Planting Schedule

	for conifers, after Fall fumigation



	for hardwoods, after Fall fumigation



	aFumigation schedules depend on growth as annual seedlings or
additional bed requirements as transplants.  Generally, fumigation
occurs each year on the production land (half of the total nursery
land)—therefore a particular parcel of land will receive fumigation
once in two years.

Region G - Michigan Seedling Association - 11. (ii) Indicate if any of
the above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region G - Michigan Seedling Association - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?" \f C \l "2"  



Michigan Seedling Association working with Michigan State University is
in the midst of conducting research (with grants from USDA MB
Alternatives program) to assess the efficacy of alternatives with an
economic survey conducted to define costs associated with alternatives. 
Results of this research that will be available in 2006-2007, should
help identify true alternatives to MB.  Feasible alternatives should be
identified and available by 2007-2008 growing season, according to the
requesting consortium.  Until this time, MB is critical for the
continuation of this industry.  The consortium has stated that growers
have been transitioning to use of 1,3-D for pest problems that can be
effectively managed by this treatment.  Tarp studies and studies of
various herbicides are being conducted and hold promise to manage key
weed problems.

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



Region G - Michigan Seedling Association - Table 12.1 Historic Pattern
of Use of Methyl Bromide  TC "Region G. Michigan Seedling Association.
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)	46	51	34	35	26	26

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 

(total kilograms)	13,825	9,144	9689	9493	9420	9420

formulations of methyl bromide 

(methyl bromide:chloropicrin)	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied 

(e.g. injected at 25cm depth, hot gas)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	302	178	285	270	364	364

Actual dosage rate [active ingredient] (g/m2)*	30.2	17.8	28.5	27.0	36.4
36.4

* For flat fumigation treatment application rate and dosage rate may be
the same.

 Part C: Technical Validation  TC "Regions A-G. Forest Seedlings. Part
C: Technical Validation" \f C \l "1"  



13. Reason for Alternatives Not Being Feasible  TC "Regions A-G. Forest
Seedlings. 13. Reason for Alternatives Not Being Feasible" \f C \l "2"  



Table 13.1: Reason for Alternatives Not Being Feasible  TC "Regions A-G.
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: 

Also, see Section 14 for additional chemicals not listed by MBTOC.

Dazomet

(400 kg/ha)	Inconsistent results with weeds, especially w/moderate to
high weed pressure.  Does not consistently provide acceptable levels of
nutsedge control, nor does it manage some diseases associated with
fungal pathogens (root rot and damping-off pathogens).  Most effective
use will probably be incorporated with other methods, but protocols must
be developed (Fraedrich and Dwinell, 2003b).  Field trials show that
seedling size (diameter and height) and root volume were inconsistent,
non-uniform, and reduced with dazomet, leading to higher counts of Grade
#2 seedlings and culls compared to greater numbers of Grade #1 seedlings
with MB.  Reduced efficacy requires production cycle compensation by
increasing the frequency of fumigation or lengthening the fallow period
in order to obtain better control of weeds and other pests.  These
strategies result in reduced seedling production.  Damage to seedlings
growing adjacent to beds being fumigated with dazomet has resulted in
significant loss of seedlings due to fumigant drift.  Soil temperature
requirements (above 6° C/ optimal 12-18° C) of dazomet, due to vapor
pressure properties, constrains use in some areas (north and west)
(Landis and Campbell, 1989); (Fraedrich and Dwinell, 2003b; Campbell and
Kelpsas, 1988; Carey, 1996; Carey, 1994; Enebak et al., 1990;
Weyerhaeuser, #3, 1984-87; Weyerhaeuser, #4, 1985-87; Weyerhaeuser, #6,
1992; Weyerhaeuser, #7, 1994-96; Weyerhaeuser, #8, 1992-95;
Weyerhaeuser, #9, 1994-95; Weyerhaeuser, #10, 1994-96) 	No

Metam-sodium 

(485 kg/ha)	Inconsistent results with weeds, especially w/high weed
pressure.  Average yield losses are estimated to be approximately 5%
with metam-sodium, although the addition of other pesticides to provide
broader control could reduce losses.  As with dazomet, reduced efficacy
requires production cycle compensation by increasing the frequency of
fumigation or lengthening the fallow period in order to obtain better
control of weeds and other pests.  These strategies result in reduced
seedling production.  As with dazomet, seedling quality is inconsistent
resulting in less predictable seedling production factors.  Damage to
seedlings growing adjacent to beds being fumigated with metam-sodium has
resulted in significant loss of seedlings due to fumigant drift. 
Fumigant drift may result in issues related to human safety and legal
liability.  Soil temperature requirements (above 4° C) of metam-sodium,
due to vapor pressure properties, can constrain use in some areas (north
and west) (Landis and Campbell, 1989); (Campbell and Kelpsas, 1988;
Carey, 1996; Carey, 1994, Darrow, 2002; Weyerhaeuser, #4, 1985-87;
Weyerhaeuser, #6, 1992)	No

Non Chemical Alternatives

Containerized production	Containerization of nursery production would
(1) require a large capital investment by all participants in the
sector, (2) increase seedling production costs by 300 to 600%, (3)
reduce reforestation rates as public nurseries opt out of reforestation
as expenditures go up.  (see Section 18 and Appendix B.).  Some
nurseries with specialized markets have a portion of their production in
containers (Barnett and McGilvrary, 1997; Darrow, 2002; Lowerts, 2003).
For seedling production goals, is not cost effective for the complex
production system. [see Section 18 and Appendix B.]

Virtually Impermeable Film (VIF)	Current technology does not allow the
gluing together of overlapping sheets and therefore makes this product
non-functional for flat fumigation treatments, and currently available
products are relatively weak and torn by wind or pressure. However,
manufacturers believe problems can be resolved (Rimini and Wigley,
2004).  Both factors combine to make VIF film impractical using current
technology.  In the future, VIF might have a role in reducing MB use
rates while maintaining efficacy, due to reduced emissions.  Ongoing
studies may help assess value of VIF with MB and chemical alternatives.
(Carey and Godbehere, 2004; Guillino et al., 2002; Martin, 2003).  	Not
currently cost effective; not allowed in California

 Solarization	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.  Conceivably,
solarization could be optimized for efficacy and incorporated into an
integrated pest management (IPM) program that would help reduce chemical
use for bed preparation, but because of intensive scheduling of seedling
production, solarization is inadequate as a sole replacement for MB in
the forest seedling industry even in the southern U. S. (Weyerhaeuser,
#8, 1992-95)	Not cost effective as drop-in replacement

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.  However, this alternative is
not considered feasible due to the difficulty in obtaining sufficient
biomass to produce effective amounts of MITC to manage diseases and
weeds under nursery conditions.  11,500 kg per ha of Brassica
plants—an amount that is considered very high production—is
equivalent to approximately 25 kg dazomet, an amount significantly less
than effective fumigation rates.  In addition, increased Fusarium
populations due to favorable conditions provided by Brassica plants have
been reported to increase seedling diseases after biofumigation
treatments.  While some Petri dish studies (e.g., Charron and Sams) have
indicated a reduction in growth of some fungal pathogens limited field
studies have been conducted to verify effects. 	Not able to provide
sufficient biomass

Flooding/Water management	Nursery beds generally are designed and graded
for good drainage to prevent standing water.  Flooding could increase
incidence of Phytophthora and Pythium, which cause important damping-off
and root rot diseases.  Therefore, this alternative is not considered
technically feasible.	No

General Integrated Pest Management (IPM)	Nurseries currently use IPM
techniques, but these measures do not provide adequate weed and disease
control.  Therefore, this alternative is not considered technically
feasible.	Not as drop-in replacement

Plowing/Tillage	Nursery beds, especially medium type soils with higher
clay or organic matter than light soil beds, are susceptible to damage
to soil structure and development of an impermeable "plow pan" layer. 
Increased plowing can result in less productive seedling beds,
therefore, this alternative is not considered feasible.	No

Physical Removal/ Sanitation	Appropriate sanitation practices are
already followed by nurseries, as this improves productivity.  Weed
control by mechanical means would not be technically feasible for
large-scale nursery seedling production.  	No

Organic Amendments/ Compost	Not acceptably effective alone in weed
management; often cover crops are already used for beds not in current
production, as part of general IPM program; can be issue with weed
introduction by plant-based mulches (James et al., 1997; James et al.,
2001; Stone et al., 1998).  Most nurseries employ various soil
amendments to enhance seedling growth and quality, but these measures do
not provide adequate weed and disease control, therefore, this
alternative is not considered feasible.	No

Combinations of ALTERNATIVES

 See Section 14 for non-MBTOC alternatives

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

14. List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC "Regions A-G. Forest Seedlings. 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" 




Chloropicrin and 1,3-D were not listed as one of the MB alternatives by
MBTOC.  These have been investigated by the industry as potential
alternatives, and in certain circumstances (e.g., low weed pressure),
can be effective in reducing weed, fungi and nematode populations.

Table 14.1: Technically Infeasible Alternatives Discussion  TC "Regions
A-G. Forest Seedlings. Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"  

Name of Alternative	Discussion

Chloropicrin

(340 kg/ha)	A good fungicide, but not acceptably effective with moderate
or high weed pressure, some reports of enhanced weed seed germination
(Carey, 2000; Carey, 1996; Enebak et al., 1990; Weyerhaeuser, #7,
1994-96; Weyerhaeuser, #10, 1994-96).  Weed pressure will likely
increase overtime.

Metam-sodium (485 kg/ha) + chloropicrin (115 kg/ha)	Can be effective
against weeds and fungi, especially with low to moderate pressure and
light soils (Carey, 2000; Carey, 1996; Carey, 1994; Weyerhaeuser, #10,
1994-96).  There is a history of outgassing problems and significant
seedling damage.

1,3-D (260 kg/ha) + chloropicrin (140 kg/ha)	A good nematicide, requires
light soils with optimal moisture content.  Not sufficiently effective
against weeds, especially with even moderate weed pressure; may have
legal restrictions on use (Carey, 1996; Carey, 1994; Weyerhaeuser, #7,
1994-96; Weyerhaeuser, #10, 1994-96) 

Herbicides	Research will help to identify herbicides (e.g., glyphosate)
that can effectively reduce high populations of nutsedge with consistent
and reliable activity, most likely as part of an integrated program of
alternatives (e.g., Fraedrich and Dwinell, 2003c).



15. List Present (and Possible Future) Registration Status of Any
Current and Potential Alternatives  TC "Regions A-G. Forest Seedlings.
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 "Regions
A-G. Forest Seedlings. 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

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



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 "Regions A-G. Forest Seedlings.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"  .



16.1.A: Effectiveness of Alternatives – Weeds  TC " Regions A-G.
Forest Seedlings. Table 16.1.A: Effectiveness of Alternatives–Weeds"
\f F \l "1"  

Research Results for Weed Management with Methyl Bromide (MB) and/or
Alternatives

Treatment	# Trials	Yield	Quality	Relative Quality	Weed Severity	Weed
Incidence	Citation 

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 193b

[2] 236a

[3] 236a	Average Grade #1 Yield (per m2)

[1] 6b

[2] 19ab

[3] 45a	Quality (% Grade #1 compared to total)

[1] 3%

[2] 8%

[3] 19%	(# Nutsedge rhizomes per m2)

[1] 91a

[2] 43b

[3] 5b	No MB trt	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (285 kg/ha)

[3] Chloropicrin (285 kg/ha) + metam sodium (240 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 150b

[2] 214ab

[3] 246a	Average Grade #1 Yield (per m2)

[1] 8b

[2] 15ab

[3] 53a	Quality (% Grade #1 compared to total)

[1] 5%

[2] 7%

[3] 22%	(Nutsedge dry wt, kg/ha)

[1] 551a

[2] 40b

[3] 11b	No MB trt	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)

[4] MB (385 kg/ha) + Pic (8 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 150b

[2] 193a

[3] 204a

[4] 204a	Average Grade #1 Yield (per m2)

[1] 27b

[2] 114ab

[3] 150a

[4] 131a	Quality (% Grade #1 compared to total)

[1] 18%

[2] 59%

[3] 74%

[4] 64%	Not reported	Not reported	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)

[4] MB (385 kg/ha) + Pic (8 kg/ha)	1

(W/

Slash pine)	Average Total Yield (per m2)

[1] 107a

[2] 150a

[3] 150a

[4] 129a	Average Grade #1 Yield (per m2)

[1] 63b

[2] 109ab

[3] 136a

[4] 109ab	Quality (% Grade #1 compared to total)

[1] 59%

[2] 73%

[3] 91%

[4] 84%	Not reported	Not reported	Carey, 2000

“Heavy” soil (57% silt, 14% clay, 29% sand) [Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (285 kg/ha)

[3] Metam sodium (455 kg/ha)

[4] Chloropicrin (130 kg/ha) + metam sodium (455 kg/ha)

[5] 1,3-D (240 kg/ha) + Pic (100 kg/ha)

[6] Dazomet (285 kg/ha)

[7] MB (265 kg/ha)+Pic(130kg/ha)	1 (w/

Loblolly pine	

Average Total Yield (per m2)

[1] 194

[2] 181

[3] 204

[4] 192

[5] 238

[6] 214

[7] 188

[LSD, 0.05=20]	

Average Grade #1 Yield (per m2)

[1] 41

[2] 31

[3] 35

[4] 31

[5] 28

[6] 25

[7] 23

[LSD, 0.05=40]	

Quality (% Grade #1 compared to total)

[1] 21%

[2] 17%

[3] 17%

[4] 16%

[5] 12%

[6] 12%

[7] 12%

	

(# Total weeds/ m2; 53 days after treatment)

[1] 37

[2] 16

[3] 25

[4] 7

[5] 12

[6] 12

[7] 6

[LSD, 0.05=14]	(% Coverage of weeds per plot (30 m2); 53 days after
treatment)

[1] 39%a

[2] 14%bc

[3] 25%ab

[4] 11%bc

[5] 21%bc

[6] 22%bc

[7] 6%c

	Carey, 1996

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] 1,3-D (240 kg/ha) + chloropicrin (100 kg/ha)

[3] Metam sodium (455 kg/ha)

[4] Chloropicrin (130 kg/ha) + metam sodium (455 kg/ha)

[5] Dazomet (340 kg/ha) 

[6] Dazomet (170 kg/ha) +Pic (130kg/ha)

[7] MB (265 kg/ha)+Pic(130kg/ha)	Not reported	Not reported	Not reported
Not reported	(# Nutsedge /m2; 7 months after treatment)

[1] 85abc

[2] 5c

[3] 27bc

[4] 15bc

[5] 98abc

[6] 127abc

[7] 1c

[LSD, 0.05=38]	(% Coverage of weeds per plot (175 m2)7 months after
treatment)

[1] 100%a

[2] 35%c

[3] 36%c

[4] 38%c

[5] 95%a

[6] 46%c

[7] 29%c

[LSD, 0.05=16]	Carey, 1994

[1] Metam-sodium (485 kg/ha)

[2] MB (235 kg/ha) + chloropicrin (115 kg/ha) [spring trt]

[3] MB (235 kg/ha) + chloropicrin (115 kg/ha) [fall trt]	1

(1st year Ponderosa pine)	Average Total Yield (per m2)

[1] 245/m2 

[2] 221/m2

[3] 208/m2	Not reported	Not reported	Not reported	Not reported
Weyer-haeuser #2, 1980

[1] MB (235 kg/ha) + chloropicrin (115 kg/ha)

[2] Metam-sodium (485 kg/ha)

[3] Dazomet (400 kg/ha)	1

(2nd year crop Douglas fir)	(# Of packable seedlings relative to MB trt)

[2] –54/m2

[3] –5/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 11%

[3] 1%	Consortium (CUE 03-0021) Comment: “Height, caliper, shoot
weight were greater w/ MBC treated soil”	Not reported	Not reported
Weyer-haeuser #4, 1985-1987

[1] MB (235 kg/ha) + chloropicrin (115 kg/ha) 

[2] Dazomet (285 kg/ha)

[3] Dazomet (400 kg/ha)

[4] Control	1 (2nd year crop w/ Douglas fir)	(# Of packable seedlings
relative to MB trt)

[2] –88/m2

[3] –13/m2

[4] –75/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 18%

[3] 3%

[4] 16%	Consortium (CUE 03-0021) Comment: “Seedling size not
significantly different between MBC and dazomet at 285 kg/ha; size
reduced w/ dazomet at 400 kg/ha (toxicity?”)	Not reported	Not reported
Weyer-haeuser #5, 1985-1987

[1] MB (400 kg/ha) + chloropicrin (10 kg/ha) 

[2] Metam sodium (485 kg/ha)

[3] Dazomet (400 kg/ha)

[4] Control	1 (1st year crop w/ loblolly pine)	(# Of packable seedlings
relative to MB trt)

[2] –27/m2

[3] –13/m2

[4] –27/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 6%

[3] 3%

[4] 6%	Consortium (CUE 03-0021) Comment:

“Seedling height averaged 5 cm shorter for dazomet and 10 cm shorter
for metam sodium and control.”  “Caliper (diameter) was reduced by 1
mm in metam sodium and control seedlings.”	Not reported	Not reported
Weyer-haeuser #6, 1992

[1] MB (390 kg/ha) + chloropicrin (8 kg/ha) [tarped] 

[2] MB (300 kg/ha) + chloropicrin (100 kg/ha) ) [tarped]

[3] Dazomet (400 kg/ha) [tarped]

[4] Dazomet (400 kg/ha) [un-tarped]

[5] Pic-chlor (400 kg/ha) [tarped]

[6] Chloropicrin (340 kg/ha) [tarped]

[7] Control	1 (1st and 2nd year crops w/loblolly pine)	(# Of packable
seedlings relative to MB trt)

1st year crop:

[1] =[2]

[3] –64/m2

[4] –99/m2

[5] +11/m2

[6] +19/m2

[7] –88/m2

2nd year crop:

[1] =[2]

[3] –83/m2

[4] –59/m2

[5] –59/m2

[6] –19/m2

[7] Not reported	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[1] =[2]

[3] 13%

[4] 21%

[5] 2% gain

[6] 4% gain

[7] 18%

2nd year crop:

[1] =[2]

[3] 17%

[4] 12%

[5] 12%

[6] 4%

[7] Not reported	Consortium (CUE 03-0021) Comment:

[1st year crop reduction with dazomet due to stunting, and reduced root
volume]

[2nd year crop yield reduction due to stunting, and reduced root volume]
Not reported	Not reported	Weyer-haeuser #7, 1994-1996

[1] MB (390 kg/ha) + chloropicrin (8 kg/ha) [tarped] 

[2] Dazomet (400 kg/ha) [tarped]

[3] Dazomet (400 kg/ha) [tarped & solarized 3 mo.]

[4] Solarization [tarped, solar. 3 mo]

[5] Control	1 (1st and 2nd year crops w/loblolly pine) (bare fallow from
harvest Feb., 1992 through fumigation and tarp (3 mo.) summer 1992	(# Of
packable seedlings relative to MB trt)

1st year crop:

[2] –8/m2

[3] –5/m2

[4] –11/m2

[5] = [1]

2nd year crop:

[2] –8/m2

[3] –5/m2

[4] –11/m2

[5] +19/m2	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[2] 2%

[3] 1%

[4] 2%

[5] no loss

2nd year crop:

[2] 2%

[3] 1%

[4] 2%

[5] 4% gain	[# weeds/m2 May, 1993; dominant species: Amaranthaceae spp.,
Mollugo verticillata, Euphorbia supine]

[1] 31b

[2] 25b

[3] 35b

[4] 54ab

[5] 104a	[# weeds/m2 June, 1993;

dominant species: Euphorbia supine, Digitaria ciliaris, Digitaria
ischaemun]

[1] 13b

[2] 10b

[3] 17b

[4] 28a

[5] 36a	Not reported	Weyer-haeuser #8, 1992-1995

[1] MB (400 kg/ha) + chloropicrin (8 kg/ha) [tarped] 

[2] Dazomet (400 kg/ha) [tarped]

[3] Dazomet (400 kg/ha) [un-tarped]

[4] Control	1 (1st year crop w/loblolly pine)	(# Of packable seedlings
relative to MB trt)

[2] –19/m2

[3] –35/m2

[4] –5/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 4%

[3] 7%

[4] 1%	Consortium (CUE 03-0021)Comment: Short trees and poor root
structure were main cull factors	Not reported	Not reported	Weyer-haeuser
#9, 1994-1995



[1] MB (400 kg/ha) + chloropicrin (8 kg/ha)

[2] 1,3-D (260 kg/ha) + chloropicrin (140 kg/ha)

[3] Chloropicrin (130 kg/ha) + metam sodium (240 kg/ha) [tarped]

[4] Dazomet (400 kg/ha)[tarped] 

[5] Dazomet (400 kg/ha)[untarped]

[6] Chloropicrin (340 kg/ha) [tarped]

[7] Control	1 (1st and 2nd year crops w/loblolly pine)	(# Of packable
seedlings relative to MB trt [1])

1st year crop:

[2] –40/m2

[3] –8/m2

[4] +3/m2

[5] –29/m2

[6] –13/m2

[7] –46/m2

2nd year crop:

[2] –3/m2

[3] –3/m2

[4] +3/m2

[5] Not reported

[6] +3/m2

[7] Not reported	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[2] 8%

[3] 2%

[4] no loss

[5] 6%

[6] 3%

[7] 10%

2nd year crop:

[2] No loss

[3] No loss

[4] No loss

[5] Not reported

[6] No loss

[7] Not reported	1st year crop:

Culls were short with small diameters

2nd year crop:

Study was suspended due to high nutsedge populations

	Not reported	Not reported	Weyer-haeuser #10, 1994-1996



Table 16.1.B: Effectiveness of Alternatives – Disease

Research Results for Disease (Fusarium, Pythium, Rhizoctonia) Management
with Methyl Bromide (MB) and/or Alternatives 

Treatment	# Trials	Yield	Percent Survival	Average Yield Post Emergence

(per m2)	Percent Healthy Root Tips (1 year old seedlings)	Stand density,
seedlings/m2 (fumigation Sept. 1986, seeding Oct., 1986)	Citation Number







May 1987	Sept 1987

	[1] Control (no fumigation)

[2] Chloropicrin (196 kg/ha)

[3] MB (392 kg/ha]

[4] MB (263 kg/ha) + chloropicrin (65 kg/ha)

[5] MB (130 kg/ha) + chloropicrin (131 kg/ha)

[6] Dazomet (280 kg/ha) 

[7] Captan (6 kg/ha) [soil drench]

[8] Thiram (38 g/kg seed) [seed trt.]

[9] Captan (6 kg/ha) [soil drench] + thiram (38 g/kg seed) [seed trt.]

[10] Silica sand (overlay seeds)	6 reps (w/white pine in WI)	[Yield per
m2 at seedling emergence, based on survival from damping-off diseases,
calculated rate of 720 seedlings/ m2 at seeding rate of 14 g seed/ m2]

[1] 496b

[2] 550a

[3] 570a

[4] 566a

[5] 564a

[6] 522ab

[7] 474b

[8] 404c

[9] 408c

[10] 366c	

Percent survival from damping-off at seedling emergence

[1] 69%ab

[2] 76%a

[3] 79%a

[4] 79%a

[5] 78%a

[6] 73%a

[7] 66%ab

[8] 57%c

[9] 57%c

[10] 51%c	[Yield per m2 after seedling emergence based on survival from
damping-off diseases at cotyledon or primary needle stage]

[1] 592d

[2] 702a

[3] 694ab

[4] 710a

[5] 682abc

[6] 686ab

[7] 580d

[8] 646c

[9] 670abc

[10] 662bc	

[1] 20%c

[2] 55%ab

[3] 68%a

[4] 72%a

[5] 76%a

[6] 31%bc

[7] 8%c

[8] 18%c

[9] 16%c

[10] 38%bc	

[1] 464

[2] 464

[3] 464

[4] 464

[5] 464 

[6] 464

[7] 320

[8] 360

[9] 360

[10] 320	

[1] 110

[2] 464

[3] 464

[4] 464

[5] 464

[6] 250

[7] 106

[8] 106

[9] 106

[10] 80	Enebak et al., 1990

[1] Control (no fumigation)

[2] MB (266 kg/ha) + chloropicrin (130 kg/ha)

[3] Metam sodium (485 kg/ha)

[4] Dazomet (400 kg/ha)	4 reps (w/

pon- derosa  pine in Pacific NW)	[% Mortality due to Pythium, and
Fusarium, during 1st growing season]

[1] 25%a

[2] 12%b

[3] 8%b

[4] 10%b	[# Of seedlings after 1st growing season] (per m2)

[1] 150a

[2] 300b

[3] 343b

[4] 300b



	Campbell and Kelpsas, 1988

[1] Control (no fumigation)

[2] MB (266 kg/ha) + chloropicrin (130 kg/ha) 

[3] MB (580 kg/ha) + chloropicrin (285 kg/ha)

[4] Dazomet (400 kg/ha)	1 (with Douglas fir)	1st crop year:

Seedlings/m2

[1] 429

[2] 482

[3] 455

[4] 469





Weyer-haeuser #3, 1984-1987



Table C.1: Alternatives Yielda Loss Data Summary  TC "Regions A-G.
Forest Seedlings. 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	Nematodes, Weeds, Fungi	+5% to –8%	0-3% loss

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

aYield loss estimates for the forest nursery sector do not adequately
address the greater effect of seedling quality for forest plantings. 
Forests planted with undersized seedlings will have reduced survival and
slowed growth if initial seedling health is compromised.  No
alternatives have been sufficiently tested to currently be substituted
for MB.

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



According to one applicant (CUE 05-0007), “an IPM system using true
fallow, pathogen resistant cover crops, increased supplemental organic
matter applications, increased herbicide and insecticide use, and annual
chloropicrin and Telone fumigation for bareroot pine production” are
the likely alternatives that could replace MB.  Combinations of
chemicals, such as chloropicrin, metam-sodium, or 1,3-D appear to be
effective for some nurseries in reducing pest infestations, including
some weed problems (e.g., Carey, 2000; Carey, 1996; Carey, 1994;
Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10, 1994-96).  Combinations of
these compounds and application techniques (such as deep injection) to
achieve the same pest control efficiencies as MB are being studied along
with integrating non-chemical treatments, such as bed-fallow or cover
crops.  So far, none have proven cost effective and have generally
resulted in an increased input of pesticides.  Because of their physical
limitations (e.g., low vapor pressure of metam-sodium), these products
are frequently not used by nursery managers due to their lack of
consistency.  Conclusions based on individual research trials may be
skewed since large-scale production may result in greater differences
between treatments due to scale-up and different pest pressure.  In
addition, economic issues may have an impact on overall acceptability of
these alternatives for the forest seedling nursery sector.  Tests are
being conducted with methyl iodide, which has potential as a MB
replacement, although it is unknown when, or if, registration might
occur.

As MBTOC has stated in questions to the U.S. in summer, 2005, the use of
metam without tarping is not feasible due to crop injury and worker
exposure issues.  It might appear appropriate, then, to tarp the
material to prevent out-gassing problems.  However, the application of
metam followed by chloropicrin under flat-tarping, considering the large
number of hectares treated each year, is not practical or cost
effective, and currently, not technically feasible (personal
communication, International Paper [Region B]; Southern Forest Nursery
Management Cooperative [Region A]).  A three-step process would be
required, first application of metam, then chloropicrin, and finally,
application of the tarp.  Incorporation of metam using a rotovator is an
extremely slow process, and the area to be treated within a given
treatment window (determined by weather: temperature, moisture, wind) is
limited.  This window of application is generally 4-6 weeks, and even
under the best application methods, this treatment takes four times as
long to apply as the typical MB treatment.  Therefore, to treat the
necessary hectares each year would require a four-fold increase in labor
and additional available equipment in order to apply metam, chloropicrin
and cover with tarp.  According to the label, and depending on soil and
weather conditions, there would be a two to six week delay before
planting after application of metam, chloropicrin and tarp-covering. 
This would affect market production costs.  

The equipment needed to treat the area in spring and fall would not be
available without the purchase of four additional applicator units and
would greatly increase the cost to growers, as would the “set-up”
time for the treatment with additional machinery.  In order for tarps to
be placed on the treated metam areas, workers must return into the
treated area to lay down tarps after chloropicrin has been injected into
the soil.  In this case, out-gassing occurs, and workers must wear
personal protection equipment that is not practical given the
temperatures that normally occur at the time of application.  Nursery
growers of these regions are currently using high density films to
decrease emissions of MB, but have found that for current production VIF
is not an option due to excessive costs and technical difficulties of
gluing during application.  Nursery members of the Southern Forest
Nursery Cooperative, among others, are experimenting with VIF, but are
not able to adopt this technology for the 2008 season.

The use of virtually impermeable film (VIF) may offer a means of
reducing MB use rates while maintaining efficacy and production goals
(Carey and Godbehere, 2004).  However, in the U.S. availability of VIF
is limited and nursery applicators do not currently have experience
laying this material.  Research is being conducted to determine if this
type of film is feasible in the U. S. (e.g., does it hold up physically
in field conditions? can it be glued to acceptable specifications?, is
the cost acceptable?).  VIF manufacturers believe that technical
problems will be solved (Rimini and Wigley, 2004).  However, the
efficacy of VIF for U. S. agriculture may be different than that for
Europe (Federal Register, 1998); California does not permit the use of
VIF and costs are higher in the U.S. due to transportation and greater
areas treated.  There has been research examining the effects of certain
fertilizer salts (e.g., ammonium thiosulfate, see Gan and Yates, 1998),
which may act as barriers to volatile compounds (e.g., 1,3-D, MB) when
applied to the soil surface, thus reducing emissions and improving
efficacy, although this method is in the beginning stages of testing.  

A major limitation with respect to ongoing research is the general lack
of information to accurately assess pest control in large scale,
compared to small research trials.  Topics, such as outgassing damage as
a result of metam-sodium applications and application of VIF and
associated costs, are being studied.  Technical difficulties in
extrapolating research scale plots to “real world” applications make
it difficult to transition away from MB and calculate implementation
timelines, since production consistency is frequently compromised.  As
discussed in Section 23 below, considerable research dollars have been
spent on research of MB alternatives.  However, phasing out MB for many
current uses may be foreseeable.  A combination of methods can
conceivably be used to reduce MB, but this will require several seasons
of testing and analyses.  

In research plots, the reduction of MB from 98:2 to 65:35 or 50:50,
increased periods of cover crop growth, use of herbicides glyphosate
(Fraedrich and Dwinell, 2003c), and an increased use of mechanical
cultivation might reduce pest populations, and the overall use of MB. 
However, nursery managers are unlikely to adopt the use of glyphosate
immediately, since it kills both hardwoods and conifers.  More research
will be necessary to devise special application technology if the use of
glyphosate is to be employed.  Experiments have indicated that some soil
amendments can reduce possible adverse growth effects of some
alternatives (e.g., dazomet).  Work in Wisconsin (Enebak et al., 1990;
Iver, undated) suggested that white pine seedlings subjected to dazomet,
but supplied with various nutrients, could reduce chlorosis sometimes
observed in dazomet treated beds.  Large scale trials will be necessary
to confirm this effect.  For disease control, studies (James et al.,
1997) comparing cultivation practices, such as till vs. no-till and
organic amendments indicate that effects vary according to the species
grown, thus each nursery may have to consider alternatives with species
and local environment in mind, unlike the more consistent effects of MB
fumigation.  Promising results in disease management have been observed
(Lantz, 1997; Stone et al., 1998) with organic amendments, but
successful weed management has not been adequately achieved.

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



Containerization is used for seedling production in a limited capacity
throughout the forest nursery sector.  One Michigan grower (CUE 04-0039)
produces greenhouse-grown plug plants, which are grown for 1-2 years,
then planted in beds for an additional 1-3 years.  Containers can also
be for special circumstances where species survival or an genetic value
of the planting stock make them economically feasible.  Recent surveys
indicate that of the 1.2 billion seedlings grown in the southeastern U.
S. in the 2002-2003 season, fewer than 5% were produced in containers
(McNabb and VandersSchaaf, 2003).  An estimate can be made that less
than 10% of the national forest seedling production is containerized. 
Container production is used for specialty purposes, for example, to
reforest mine-spoil sites which are extremely harsh edaphic environments
requiring a soil plug system to obtain adequate seedling survival
(Lowerts, 2003).  

A large investment would be necessary to shift the national production
to containerization, as well as a shift for many nurseries in the well
established protocols of growing seedlings.  According to Darrow (2002)
(also see Appendix B) the transition from bed to container production
would require additional capital and operating costs.  Investment would
be necessary for the purchases of greenhouses, container filling and
sowing machines, containers, outdoor holding areas, fertigation systems,
and new seedling transport systems both in the nursery and in the field.
 Not all sectors of seedling production would have this capital
available to them.  It is likely that smaller bareroot operations would
close and many state-run nurseries would opt to close rather than budget
state funds for such a significant capital outlay.  There is little
doubt that seedling prices could increase by up to six times current
prices.  A typical one year old bareroot seedling currently sells for
$0.04 each, while the typical container seedling of the same species
begins at $0.12 each.  In addition to an increase in seedling costs,
there are significant cost increases associated with transportation and
planting container stock.  Fewer container plants can be transported per
truck and fewer seedlings can be carried by individual tree planters. 
More trucks and more fuel are needed to get seedlings to the planting
site and more labor and time are needed to plant a given area.  One
study found that daily production decreased from 9.7 ha per day with
bareroot seedlings to 7.3 ha per day with containerized seedlings, a
decrease of 25%, without increasing planting crew size (Lowerts, 2003). 

The inevitable result of containerization would be a significant
increase in reforestation costs and a decrease in the rate of
reforestation.  According to the U. S. Forest Service, 48% of all
reforestation in the U. S. is done on non-industrial private lands, an
additional 42% is done on industrial lands, and 10% on government lands
(Moulton and Hernandez, 2000).  It is well established that
non-industrial forest owners are very sensitive to reforestation costs,
decreasing their investment in direct proportion to increasing costs
(Hardie and Parks, 1991; Royer, 1987).  Given the importance of
non-industrial owners on the general timber supply, a reduction in
reforestation efforts by this group may have serious long-term negative
impacts on the sustainability of the forest economy.  Industrial owners
will also be negatively impacted by increased reforestation costs as raw
material costs will increase (typically about 40-60% of the cost of
final fiber products), impacting the competitiveness of their industry. 


Conclusion:  The infrastructure investment necessary for
containerization is enormous and would probably force many nurseries out
of business.  Seedling production costs would increase, resulting in
seedling price increases of over 250%.  New transportation and planting
systems would have to be adopted.  Reforestation costs would go up
significantly and probably result in fewer non-industrial forest owners
reforesting after harvest.  The potential long-term effect of these
changes on the forestry economy is enormous.  Overall, containerization
would result in a significant increase in seedling production,
transportation, and planting costs and would most likely decrease
reforestation rates.  

Summary of Technical Feasibility  TC "Regions A-G. Forest Seedlings.
Summary of Technical Feasibility" \f C \l "2"  



This nomination includes requests for MB for those nurseries where
sufficient pest control can not be achieved otherwise.  While
combinations of chemicals, such as chloropicrin, metam-sodium, and 1,3-D
appear to be effective for some nurseries in reducing pest infestations,
including some weed problems (e.g., Carey, 2000; Carey, 1996; Carey,
1994; Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10, 1994-96), currently
all nurseries 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 use of a formulation with
chloropicrin and use of VIF).  Its overall use may be limited by local
legal restrictions and pest-free permit requirements, and VIF has
technical problems and is restricted in California (e.g., Carey, 1996;
Carey, 1994; Weyerhaeuser #10, 1994-96).  In addition, economic issues
such as application costs may have an impact on overall acceptability of
these alternatives for the forest seedling nursery sector.  

Recent studies with dazomet in Georgia and North Carolina nurseries
(Fraedrich and Dwinell, 2003b) and glyphosate (Fraedrich and Dwinell,
2003c) suggest that both might have potential as nutsedge treatments,
but will be used in seedling production after research can “…better
define the optimal use conditions”.  However issues remaining
preventing immediate implementation.  For example, seedling nurseries
have stated that forest tree seedlings cannot be exposed to glyphosate
as the herbicide kills both hardwood and conifer species (personal
communication, International Paper [Region B]; Southern Forest Nursery
Management Cooperative [Region A]).  While ‘shielded sprayers’ with
glyphosate have been tested in small trials, seedling mortality from
over-spray does occur.  An International Paper nursery, for example,
will typically produce 300 million seedlings per year, and so, even 1%
mortality due to herbicide sprays could result in significant seedling
loss.  Consequently, glyphosate would not be an option to control
nutsedge in nursery beds.  

Statistically analyzed trials measuring quantity and quality losses due
to specific pests (e.g., weeds or pathogens) are not readily available. 
More commonly found are trials indicating overall yield (and sometimes
quality assessments), allowing a comparison of treatments based on
yield, but making it difficult to ascribe losses to particular pests. 
This is particularly a problem since the numerous forest seedling
nurseries can experience various problems unique to the combination of
climate, soil, seedling species, market forces, and customer base (e.g.,
public vs. private nursery, or commercial vs. recreational end uses). 
Overall yield losses with the best alternatives, compared to MB, were
estimated at 0-3% based on research data.  In estimating the yield of
alternatives in comparison to MB, it should be remembered that these
figures are for the general case, and individual nurseries will likely
experience greater or lesser efficacy with a given treatment, depending
on soil, climate, production practices, market requirements, species of
seedling, etc.  The yield estimates listed in Table C.1 are based on
research results described in Section 16.  Quality factors are as
important in this industry as yield, and may affect the efficacy of a
given alternative beyond considerations of yield alone (e.g., “Percent
‘Healthy Root Tips’” in Table 16.1B, Enebak et al., 1990).

Larger seedling size and improved seedling vigor translate to improved
reforestation success and increased growth rate of young plantations. 
This positive contribution to reforestation is well documented for
seedlings produced in MB fumigated soil.  Increases in seedling size and
quality resulting from fumigation with MB alternatives have been
variable.  The long-term impact on reforestation success with
alternatives is not known.  An important factor is the long-term
implication associated with forest growth and health over a 20-40 year
period of forest life.  Seedling quality has been highly correlated with
productive and healthy forests impacting both commercial and public
interests.  

The industry is continuing to sponsor research alternatives and test
improved chemical application technologies to increase the efficacy of
some of the most viable alternatives.  The use of metam without tarping
is not feasible due to crop injury and worker exposure issues.  However,
the application of metam followed by chloropicrin under flat-tarping,
considering the large number of hectares treated each year, is not
practical or cost effective either, and currently, not technically
feasible (personal communication, International Paper [Region B];
Southern Forest Nursery Management Cooperative [Region A]).  A
three-step process would be required—first, application of metam, then
chloropicrin, and finally, application of the tarp.  Incorporation of
metam using a rotovator is an extremely slow process, and the area to be
treated within a given treatment window (determined by weather:
temperature, moisture, wind) is limited.  This window of application is
generally 4-6 weeks, and even under the best application methods, this
treatment takes four times as long to apply as the typical MB treatment.
 Therefore, to treat the necessary hectares each year would require a
four-fold increase in labor and additional available equipment in order
to apply metam, chloropicrin and cover with tarp.  According to the
label, and depending on soil and weather conditions, there would be a
two to six week delay before planting after application of metam,
chloropicrin and tarp-covering.  This would affect market production
costs.  

The equipment needed to treat the area in spring and fall would not be
available without the purchase of four additional applicator units and
would greatly increase the cost to growers, as would the “set-up”
time for the treatment with additional machinery.  In order for tarps to
be placed on the treated metam areas, workers must return into the
treated area to lay down tarps after chloropicrin has been injected into
the soil.  In this case, out-gassing occurs, and workers must wear
personal protection equipment that is not practical given the
temperatures that normally occur at the time of application.  Nursery
growers of these regions are currently using high density films to
decrease emissions of MB, but have found that for current production VIF
is not an option due to excessive costs and technical difficulties of
gluing during application.  Nursery members of the Southern Forest
Nursery Cooperative, among others, are experimenting with VIF, but are
not able to adopt this technology for their 2007 production.

MB 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 advanced enough to rely on in the
foreseeable future.  Research with organic and inorganic soil amendments
(Fraedrich and Dwinell, 1998; James et al., 1997; James et al., 2001;
Lantz, 1997; Stone et al., 1998) have had some successes under certain
conditions, but the effects appear to be variable depending on the
nursery locations and species of seedlings.  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"  



The Forest Seedlings sector has reduced its MB consumption through
several techniques developed over the past several years.  First, the
sector has incorporated the use of high-density polyethylene (HDPE) tarp
material that has helped increase fumigation efficiencies and reduced
application rates.  HDPE increases MB soil residence time, increasing
efficiency and reducing application rates.  VIF is likely to be an
important means of further reducing emissions if a method can be
developed to efficiently glue overlapping sheets of VIF film (e.g.,
Carey and Godbehere, 2004).  VIF film becomes impractical if adjacent
overlapping sheets cannot be glued.  In addition, there is a problem
with film breakage during application.  Suppliers believe technical
problems can be fixed (Rimini and Wigley, 2004), however, currently
regulations prevent the use of VIF in California.

Second, MB fumigation in the forest seedlings sector increasingly has
been made using deep injection that places the material deeper into the
soil than previously.  Deeper placement contributes to longer residence
time in the soil and greater application efficiency.  This has been
accomplished at considerable capital investment on the part of
applicators.

Third, forest seedlings nurseries have increased the percentage of
chloropicrin in fumigation mixtures.  While 98% MB and 2% chloropicrin
was the most widely used compound a few years ago, a 66:33 formulation
is now more common, especially in areas without heavy nutsedge
infestations.  Growers still applying 98:2 formulations, such as
International Paper, are currently examining the effects of 66:33 in
their nursery trials.  Some efficiency in weed control has been
sacrificed by this change in procedure, however, and higher
concentrations of chloropicrin become increasingly less satisfactory as
weed pressure, particularly nutsedge, increases.  Some nurseries are
investigating use of herbicides as an economic means of weed control
(e.g., Fraedrich and Dwinell, 2003c; Northeastern Consortium request,
Worksheet 4).  

Fourth, forest seedlings nurseries routinely use integrated pest
management (IPM) techniques to develop their fumigation strategies. 
Nurseries fumigate once every four years, growing two seedling crops and
two cover crops following fumigation.  Soil organic matter content, weed
populations, and disease incidence are carefully monitored during the
crop rotation to ensure the correct timing and rate of MB application. 
Monitoring pest populations is an integral part of an IPM approach and
helps ensure MB efficiency.

Finally, the forest seedlings sector has devoted considerable resources
to investigating MB alternatives and continues to search for
methodologies to reduce MB use rates.  The industry is committed to
continuing research to address the issue of improved consistency
(especially for nutsedge control) with available chemical alternatives
and to test new products in order to determine efficacy and obtain the
information necessary for U. S. registrations

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.	No trend was identified.	Research is
ongoing examining lower proportion of MB	No trend was identified.

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 MB will motivate growers to try high barrier film.
The U. S. anticipates that the decreasing supply of MB will motivate
growers to try dosage reduction.	The U. S. anticipates that the
decreasing supply of MB will motivate growers to try increasing the
chloropicrin percentage in formulations.	The U. S. anticipates that the
decreasing supply of MB will motivate growers to try less frequent
applications.

Other measures (please describe)	Unknown	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"  :



As stated previously, emission reduction technologies are being
addressed by the sector (e.g., VIF, reduced MB component of formulation,
use of advanced delivery techniques to make alternative chemicals more
effective at deeper soil levels).

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



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: Operating Costs  with 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)

Region A - 

Southern Forest Nursery Management Cooperative	Methyl Bromide	100	 $    
 17,820 	 $      17,820 	 $      17,820 

	Dazomet	95	 $      20,750 	 $      20,750 	 $      20,750 

	1,3-D + Chloropicrin	97	 $      19,865 	 $      19,865 	 $      19,865 

	Metam Sodium + Chloropicrin	97	 $      20,258 	 $      20,258 	 $     
20,258 

Region B - International Paper	Methyl Bromide	100	 $     15,740 	 $    
15,740 	 $     15,740 

	Dazomet	95	 $     18,284 	 $     18,284 	 $     18,284 

	1,3-D + Chloropicrin	97	 $     18,343 	 $     18,343 	 $     18,343 

	Metam Sodium + Chloropicrin	97	 $     18,621 	 $     18,621 	 $    
18,621 

Region C - Illinois Department of Natural Resources	Methyl Bromide	100	
$       46,031 	 $       46,031 	 $       46,031 

	Dazomet	95	 $       48,442 	 $       48,442 	 $       48,442 

	1,3-D + Chloropicrin	97	 $       48,442 	 $       48,442 	 $      
48,442 

	Metam Sodium + Chloropicrin	97	 $       48,442 	 $       48,442 	 $    
  48,442 

Region d - Weyerhaeuser South	Methyl Bromide	100	 $     16,960 	 $    
16,960 	 $     16,960 

	Dazomet	95	 $     17,758 	 $     17,758 	 $     17,758 

	1,3-D + Chloropicrin	97	 $     17,736 	 $     17,736 	 $     17,736 

	Metam Sodium + Chloropicrin	97	 $     17,656 	 $     17,656 	 $    
17,656 

region e - Weyerhaeuser West	Methyl Bromide	100	 $     10,187 	 $    
10,187 	 $     10,187 

	Dazomet	95	 $     11,748 	 $     11,748 	 $     11,748 

	1,3-D + Chloropicrin	97	 $     11,748 	 $     11,748 	 $     11,748 

	Metam Sodium + Chloropicrin	97	 $     10,342 	 $     10,342 	 $    
10,342 

region f - Northeastern Forest & Conservation Nursery Association	Methyl
Bromide	100	 $      32,718 	 $      32,718 	 $      32,718 

	Dazomet	95	 $      38,747 	 $      38,747 	 $      38,747 

	1,3-D + Chloropicrin	97	 $      37,994 	 $      37,994 	 $      37,994 

	Metam Sodium + Chloropicrin	97	 $      37,994 	 $      37,994 	 $     
37,994 

region g - Michigan Seedling Association	Methyl Bromide	100	 $     
94,908 	 $      94,908 	 $      94,908 

	Dazomet	95	 $      96,186 	 $      96,186 	 $      96,186 

	1,3-D + Chloropicrin	97	 $      96,394 	 $      96,394 	 $      96,394 

	Metam Sodium + Chloropicrin	97	 $      95,959 	 $      95,959 	 $     
95,959 

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

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

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)

Region A - 

Southern Forest Nursery Management Cooperative	Methyl Bromide	 $     
33,682 	 $        15,862 

	Dazomet	 $      31,998 	 $        11,247 

	1,3-D + Chloropicrin	 $      32,671 	 $        12,806 

	Metam Sodium + Chloropicrin	 $      32,671 	 $        12,413 

Region B - International Paper	Methyl Bromide	 $    31,096 	 $    15,356


	Dazomet	 $    29,541 	 $    11,257 

	1,3-D + Chloropicrin	 $    30,163 	 $    11,820 

	Metam Sodium + Chloropicrin	 $    30,163 	 $    11,542 

Region C - Illinois Department of Natural Resources	Methyl Bromide	 $   
  178,824 	 $     132,794 

	Dazomet	 $      169,883 	 $     121,441 

	1,3-D + Chloropicrin	 $      173,460 	 $     125,018 

	Metam Sodium + Chloropicrin	 $      173,460 	 $     125,018 

Region d - Weyerhaeuser South	Methyl Bromide	 $    26,719 	 $      9,759


	Dazomet	 $    25,383 	 $      7,626 

	1,3-D + Chloropicrin	 $    25,918 	 $      8,182 

	Metam Sodium + Chloropicrin	 $    25,918 	 $      8,262 

region e - Weyerhaeuser West	Methyl Bromide	 $    18,759 	 $       
8,571 

	Dazomet	 $    17,821 	 $        6,073 

	1,3-D + Chloropicrin	 $    18,196 	 $        6,448 

	Metam Sodium + Chloropicrin	 $    18,196 	 $        7,854 

region f - Northeastern Forest & Conservation Nursery Association	Methyl
Bromide	 $    48,759 	 $     16,041 

	Dazomet	 $    46,321 	 $       7,574 

	1,3-D + Chloropicrin	 $    47,296 	 $       9,302 

	Metam Sodium + Chloropicrin	 $    47,296 	 $       9,302 

region g - Michigan Seedling Association	Methyl Bromide	 $    143,815 	
$       48,907 

	Dazomet	 $    136,624 	 $       40,438 

	1,3-D + Chloropicrin	 $    139,501 	 $       43,107 

	Metam Sodium + Chloropicrin	 $    139,501 	 $       43,542 

* 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"  



Region a - Southern Forest Nursery Management Cooperative - Table E.1:
Economic Impacts of Methyl Bromide Alternatives  TC "Region A - Table
E.1: Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Region a - Southern Forest Nursery Management Cooperative	Methyl Bromide
Dazomet 	1,3-D + Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%)	0%	5%	3%	3%

   Yield (seedling) per Hectare Pine 	779,617	740,636	756,228	756,228

* Price per Unit (U.S. $/seedling)	$  0.04	$   0.04	$  0.04	$  0.04

Gross Revenue per Proportion  (88%)	$  27,443	$  26,070	$  26,619	$ 
26,619

   Yield (seedling) per Hectare Longleaf Pine 	423,785	402,596	411,072
411,072

* Price per Unit (U.S. $/seedling)	$  0.06	$  0.06	$  0.06	$  0.06

Gross Revenue per Proportion  (3%)	$  763	$  725	$  740	$  740

   Yield (seedling) per Hectare Hardwood 	243,399	231,229	236,097
236,097

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

Gross Revenue per Proportion  (9%)	$  5,476	$  5,203	$  5,312	$  5,312

= Aggregate Gross Revenue per Hectare (U.S. $)	$  33,682	$  31,998	$ 
32,671	$  32,671

-  Operating Costs per Hectare (U.S. $)	$  17,820	$  20,750	$  19,865	$ 
20,258

= Net Revenue per Hectare (U.S. $)	$  15,862	$  11,247	$  12,806	$ 
12,413

Loss Measures 

1. Loss per Hectare (U.S. $)	$  0	$  4,614	$  3,055	$  3,449

2. Loss per Kilogram of MB (U.S. $)	$  0	$  49.21	$  32.59	$  36.78

3. Loss as a Percentage of Gross Revenue (%)	0%	14%	9%	10%

4. Loss as a Percentage of Net Revenue (%)	0%	29%	19%	22%



Region B - International Paper - Table E.2: Economic Impacts of Methyl
Bromide Alternatives  TC "Region B - International Paper - Table E.2:
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Region B - International Paper	Methyl Bromide	Dazomet 	1,3-D +
Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield (seedling) per Hectare 	      741,315 	     704,250 	    
719,076 	     719,076 

* Price per Unit (U.S. $/seedling)	 $       0.04 	 $        0.04 	 $    
   0.04 	 $        0.04 

= Gross Revenue per Hectare (U.S. $)	 $     31,096 	 $    29,541 	 $   
30,163 	 $    30,163 

-  Operating Costs per Hectare (U.S. $)	 $     15,740 	 $    18,284 	 $ 
  18,343 	 $    18,621 

= Net Revenue per Hectare (U.S. $)	 $     15,356 	 $    11,257 	 $   
11,820 	 $    11,542 

Loss Measures 

1. Loss per Hectare (U.S. $)	$  0	 $      4,099 	 $      3,536 	 $     
3,814 

2. Loss per Kilogram of MB (U.S. $)	$  0	 $      78.97 	 $      68.13 	
$      73.49 

3. Loss as a Percentage of Gross Revenue (%)	0%	13%	11%	12%

4. Loss as a Percentage of Net Revenue (%)	0%	27%	23%	25%



Region C - Illinois Department of Natural Resources - Table E.3:
Economic Impacts of Methyl Bromide Alternatives  TC "Region C - Illinois
Department of Natural Resources - Table E.3: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"  

Region C - Illinois Department of Natural Resources	Methyl Bromide
Dazomet 	1,3-D + Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield (seedling) per Hectare - Tree 	        295,564 	        280,786
	         286,697 	         286,697 

* Price per Unit (U.S. $/seedling)	 $          0.55 	 $          0.55 	
$            0.55 	 $           0.55 

Gross Revenue per Proportion  (81.6%)	 $     132,615 	 $     125,984 	 $
      128,636 	 $      128,636 

   Yield (shrub) per Hectare - Shrub Seedling	        249,107 	       
236,651 	         241,634 	         241,634 

* Price per Unit (U.S. $/shrub)	 $          0.31 	 $          0.31 	 $  
         0.31 	 $           0.31 

Gross Revenue per Proportion  (13.2%)	 $       10,161 	 $        9,653 	
$          9,856 	 $         9,856 

   Yield per Hectare - Forb Root Stock	        123,298 	        117,134 
         119,600 	         119,600 

* Price per Unit (U.S. $/root stock)	 $          0.04 	 $          0.04 
 $            0.04 	 $           0.04 

Gross Revenue per Proportion  (5.3%)	 $           260 	 $           247 
 $             252 	 $            252 

   Yield (kilograms) per Hectare - Forb Seed	              411 	        
     390 	                399 	               399 

* Price per Unit (U.S. $/kilogram)	 $        87.08 	 $        87.08 	 $ 
        87.08 	 $         87.08 

Gross Revenue per Proportion	 $       35,789 	 $       34,000 	 $       
34,715 	 $        34,715 

= Aggregate Gross Revenue per Hectare (U.S. $)	 $     178,824 	 $    
169,883 	 $       173,460 	 $      173,460 

-  Operating Costs per Hectare (U.S. $)	 $       46,031 	 $       48,442
	 $        48,442 	 $        48,442 

= Net Revenue per Hectare (U.S. $)	 $     132,794 	 $     121,441 	 $   
   125,018 	 $      125,018 

Loss Measures 

1. Loss per Hectare (U.S $)	$  0	 $       11,352 	 $          7,776 	 $ 
       7,776 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$  0	 $        43.10 	 $
         29.52 	 $         29.52 

3. Loss as a Percentage of Gross Revenue (%)	0%	6%	4%	4%

4. Loss as a Percentage of Net Revenue (%)	0%	9%	6%	6%



Region d - Weyerhaeuser South - Table E.4: Economic Impacts of Methyl
Bromide Alternatives  TC "Region d - Weyerhaeuser South - Table E.4:
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Region D - Weyerhaeuser South	Methyl Bromide	Dazomet 	1,3-D +
Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield (seedling) per Hectare 	      574,612 	     545,882 	    
557,374 	     557,374 

* Price per Unit (U.S. $/seedling)	 $        0.05 	 $        0.05 	 $   
    0.05 	 $        0.05 

= Gross Revenue per Hectare (U.S. $)	 $     26,719 	 $    25,383 	 $   
25,918 	 $    25,918 

-  Operating Costs per Hectare (U.S. $)	 $     16,960 	 $    17,758 	 $ 
  17,736 	 $    17,656 

= Net Revenue per Hectare (U.S. $)	 $       9,759 	 $      7,626 	 $    
 8,182 	 $      8,262 

Loss Measures 

1. Loss per Hectare (U.S. $)	$  0	 $      2,134 	 $      1,578 	 $     
1,497 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$  0	 $      25.38 	 $  
   18.77 	 $      17.81 

3. Loss as a Percentage of Gross Revenue (%)	0%	8%	6%	6%

4. Loss as a Percentage of Net Revenue (%)	0%	22%	16%	15%



Region E - Weyerhaeuser West - Table E.5: Economic Impacts of Methyl
Bromide Alternatives  TC "Region E - Weyerhaeuser West - Table E.5:
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Region E - Weyerhaeuser West	Methyl Bromide	Dazomet 	1,3-D +
Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield (seedling) per Hectare 	        60,610 	       57,579 	      
58,792 	       58,792 

* Price per Unit (U.S. $/seedling)	 $        0.31 	 $        0.31 	 $   
    0.31 	 $        0.31 

= Gross Revenue per Hectare (U.S. $)	 $     18,759 	 $    17,821 	 $   
18,196 	 $    18,196 

-  Operating Costs per Hectare (U.S. $)	 $     10,187 	 $    11,748 	 $ 
  11,748 	 $    10,342 

= Net Revenue per Hectare (U.S. $)	 $       8,571 	 $      6,073 	 $    
 6,448 	 $      7,854 

Loss Measures 

1. Loss per Hectare (U.S. $)	$  0	 $      2,499 	 $      2,124 	 $      
  718 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$  0	 $      28.52 	 $  
   24.24 	 $        8.19 

3. Loss as a Percentage of Gross Revenue (%)	0%	13%	11%	4%

4. Loss as a Percentage of Net Revenue (%)	0%	29%	25%	8%



Region F - Northeastern Forest & Conservation Nursery Association -
Table E.6: Economic Impacts of Methyl Bromide Alternatives  TC "Region F
- Northeastern Forest & Conservation Nursery Association - Table E.6:
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"  

Region F - Northeastern Forest & Conservation Nursery Association	Methyl
Bromide	Dazomet 	1,3-D + Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield per Hectare Conifer Seedling 1-0 	       247,105 	      234,750
	     239,692 	     239,692 

* Price per Unit (U.S. $/seedling)	 $          0.22 	 $         0.22 	 $
       0.22 	 $        0.22 

Gross Revenue per Proportion  (8%)	 $        4,349 	 $       4,132 	 $  
   4,219 	 $      4,219 

   Yield per Hectare Conifer Seedling 2-0 	       247,105 	      234,750
	     239,692 	     239,692 

* Price per Unit (U.S. $/seedling)	 $          0.22 	 $         0.22 	 $
       0.22 	 $        0.22 

Gross Revenue per Proportion  (4%)	 $        2,175 	 $       2,066 	 $  
   2,109 	 $      2,109 

   Yield per Hectare Conifer Seedling 3-0 	       135,908 	      129,112
	     131,831 	     131,831 

* Price per Unit (U.S. $/seedling)	 $          0.31 	 $         0.31 	 $
       0.31 	 $        0.31 

Gross Revenue per Proportion  (14%)	 $        5,898 	 $       5,603 	 $ 
    5,721 	 $      5,721 

   Yield per Hectare Deciduous Tree Seedling 1-0 	       185,329 	     
176,062 	     179,769 	     179,769 

* Price per Unit (U.S. $/seedling)	 $          0.28 	 $         0.28 	 $
       0.28 	 $        0.28 

Gross Revenue per Proportion  (55%)	 $      28,541 	 $     27,114 	 $   
27,684 	 $    27,684 

  Yield per Hectare Deciduous Tree Seedling 2-0 	       123,553 	     
117,375 	     119,846 	     119,846 

* Price per Unit (U.S. $/seedling)	 $          0.34 	 $         0.34 	 $
       0.34 	 $        0.34 

Gross Revenue per Proportion  (9%)	 $        3,781 	 $       3,592 	 $  
   3,667 	 $      3,667 

   Yield per Hectare Deciduous. Shrub Seedling 1-0 	       154,441 	    
 146,719 	     149,808 	     149,808 

* Price per Unit (U.S. $/seedling)	 $          0.26 	 $         0.26 	 $
       0.26 	 $        0.26 

Gross Revenue per Proportion  (10%)	 $        4,015 	 $       3,815 	 $ 
    3,895 	 $      3,895 

= Aggregate Gross Revenue per Hectare (U.S. $)	 $      48,759 	 $    
46,321 	 $    47,296 	 $    47,296 

-  Operating Costs per Hectare (U.S. $)	 $      32,718 	 $     38,747 	
$    37,994 	 $    37,994 

= Net Revenue per Hectare (U.S. $)	 $      16,041 	 $       7,574 	 $   
  9,302 	 $      9,302 

Loss Measures 

1. Loss per Hectare (U.S. $)	$ 0	 $       8,467 	 $      6,738 	 $     
6,738 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$ 0	 $       49.38 	 $  
   39.30 	 $      39.30 

3. Loss as a Percentage of Gross Revenue (%)	0%	17%	14%	14%

4. Loss as a Percentage of Net Revenue (%)	0%	53%	42%	42%



Region G - Michigan Seedling Association - Table E.7: Economic Impacts
of Methyl Bromide Alternatives  TC "Region G - Michigan Seedling
Association - Table E.7: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

Region G - Michigan Seedling Association	Methyl Bromide	Dazomet 	1,3-D +
Chloropicrin	Metam-Sodium + Chloropicrin

Yield Loss (%) 	0%	5%	3%	3%

   Yield per Hectare Conifer Seedlings	    1,070,789 	    1,017,250 	   
 1,038,665 	       1,038,665 

* Price per Unit (U.S. $/seedling)	 $          0.14 	 $          0.14 	
$          0.14 	 $            0.14 

Gross Revenue per Proportion  (60%)	 $      89,946 	 $      85,449 	 $  
    87,248 	 $        87,248 

   Yield per Hectare Conifer Transplants	         74,132 	        
70,425 	         71,908 	           71,908 

* Price per Unit (U.S. $/ transplants)	 $          0.60 	 $         
0.60 	 $          0.60 	 $            0.60 

Gross Revenue per Proportion  (10%)	 $        4,448 	 $        4,225 	 $
       4,314 	 $          4,314 

   Yield per Hectare Deciduous Transplants	       329,474 	      
313,000 	        319,589 	         319,589 

* Price per Unit (U.S. $/ transplants)	 $          0.50 	 $         
0.50 	 $          0.50 	 $            0.50 

Gross Revenue per Proportion  (30%)	 $      49,421 	 $      46,950 	 $  
    47,938 	 $        47,938 

= Aggregate Gross Revenue per Hectare (U.S. $)	 $    143,815 	 $   
136,624 	 $     139,501 	 $       139,501 

-  Operating Costs per Hectare (U.S. $)	 $      94,908 	 $      96,186 	
$       96,394 	 $        95,959 

= Net Revenue per Hectare (U.S. $)	 $      48,907 	 $      40,438 	 $   
   43,107 	 $        43,542 

Loss Measures 

1. Loss per Hectare (U.S. $)	$  0	 $        8,469 	 $        5,800 	 $  
       5,365 

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$  0	 $        95.26 	 $
       65.24 	 $          60.35 

3. Loss as a Percentage of Gross Revenue (%)	0%	6%	4%	4%

4. Loss as a Percentage of Net Revenue (%)	0%	17%	12%	11%



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



An economic assessment was made for three technically feasible in-kind
(chemical) alternatives for the forest seedlings sector: dazomet, 1-3 D
+ chloropicrin, and metam-sodium + chloropicrin.  The economic
assessment of feasibility for pre-plant uses of MB included an
evaluation of economic losses from three basic sources: (1) yield
losses, referring to reductions in the quantity produced, (2) quality
losses, which generally affect the price received for the goods, and (3)
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.  

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

(1) Losses as a percent of gross revenues.  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.

	

(2) Absolute losses 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.

(3) Losses per kilogram of MB requested.  This measure indicates the
value of MB to crop production but is also useful for structural and
post-harvest uses.

(4) Losses as a percent of net revenues.  We define net 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.

These measures represent different ways to assess the economic
feasibility of MB alternatives for MB users, who are forest seedling
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 MB.  The economic measures provide
the basis for making that determination.

Economic reviewers analyzed potential economic losses from using
dazomet, 1-3 D + chloropicrin, and metam-sodium + chloropicrin because
they are currently considered technically feasible alternatives for
nursery seedlings production.  

Total losses are similar for both 1-3-D + chloropicrin and metam-sodium
+ chloropicrin.  Quantifiable losses originate from yield losses and
cost increases.  Dazomet has slightly higher yield losses than 1-3-D +
chloropicrin, and metam-sodium + chloropicrin, but similar treatment
costs.  Indirect yield losses occurred due to lengthening of the
production cycle, which resulted in less land in production and more in
fallow or longer time for seedlings to reach appropriate size. 
Additional losses may also arise due to a shift from high quality Grade
#1 seedlings to lower quality Grade #2, which causes a loss of about 30%
of value, and more seedlings that must be culled.  Unfortunately, data
were lacking to measure this shift.  Thus, total losses are
underestimated.

Tables E.1 - E.8 provides a summary of the estimated economic losses.  A
measure of net revenue loss may not be completely accurate partly
because many nurseries are publicly owned and seedling prices or
production costs are subsidized.  Although attempts were made to
appropriately value the seedlings at a true market price, losses as a
percentage of gross revenues and of net revenue should be viewed with
caution.  Direct yield losses are similar across the regions, mainly
because the same studies were used to predict impacts.  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.  In the
Northern region this impact is expected to be more pronounced due to
cooler temperatures and longer time required for production of a
seedling crop.  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 and within the Western
region, which is highly diverse, because of differences in pests,
production systems and regional differences in costs of water and labor.
 Costs are higher in the South, in part because warmer temperatures
increase pest pressure.

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"  



Because of high costs associated with forest seedlings considerable
resources have been spent examining methods to reduce costs and improve
efficiency in seedling production.  The Southern Forest Nursery
Management Cooperative has spent $1.2 million on MB alternatives since
1992.  This is significant, since several of the nurseries are publicly
owned and have limited resources for independent research.  Research has
included trials conducted to assess the effectiveness of the most likely
chemical and non-chemical alternatives (two year cover crops—see
International Paper request CUE 03-0007) to MB, including some potential
alternatives that are not currently listed by MBTOC, including
combinations of chemicals such as 1,3-D, chloropicrin, metam-sodium, and
methyl iodide (not currently registered in the U. S.).  Development of
technologies to improve efficacy of alternatives are underway and
include work with deep injection application methods, soil moisture
management by improving drip technologies, and trials with VIF to
increase efficacy and decrease emissions while allowing reasonable cost
effectiveness.  Even where MB is considered critical, an improvement in
efficient delivery techniques will result in reduction of MB use
requirements.  As of 2005, International Paper is testing “an IPM
system using true fallow, pathogen resistant cover crops, increased
supplemental organic matter applications, increased herbicide and
insecticide use, and annual chloropicrin and Telone fumigation for
bareroot pine production”.

One difficulty in identifying alternatives to MB is that information
obtained from research plots must be transferred to large-scale
commercial production requirements.  Fumigants applied to small plots
may not exhibit similar effects when applied to commercial seedling
beds.  Overall, especially for nurseries with high pest pressure,
protocols for alternative chemicals have not been sufficiently developed
to provide consistent and effective production results.  Continued
research on alternatives that will be adaptable to large-scale
applications will shift the industry to MB alternatives.

Weyerhaeuser Corporation, one of the largest growers of forest
seedlings, suggested their preference for MB alternatives (in descending
order): 1) chloropicrin, 340 kg/ha; 2) 1,3-D at 260 kg/ha + chloropicrin
at 140 kg/ha; 3) metam-sodium, (485 kg/ha) and chloropicrin (115 kg/ha);
4) dazomet, 400 kg/ha; 5) non-chemical treatments such as steam; 6)
biological control agents.  

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

24. Are There Plans 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"  



It may be possible to reduce MB in formulations to 65% or 50% mixed with
chloropicrin, especially in locations where pathogens are the key pests.
 Reduction in MB may be achieved with use of VIF if technological and
cost issues can be resolved (Carey and Godbehere, 2004).  Weed
management is the issue of most concern by most nurseries and work is
ongoing to study the strategic use of herbicides (e.g., $370,701 USDA
grant for MB alternatives research by Michigan State University that
will test numerous herbicides and other weed control methods).  Also
cultural practices are being examined to increase mechanical cultivation
and/or soil amendments and fertilizers to maximize productivity and
reduce reliance on MB.  Development of predictive models to
strategically determine when fumigation is appropriate can reduce
overall use of fumigants (e.g., Fraedrich and Dwinell, 1998).  As stated
in Section 23, minimizing use of MB can be achieved through the
development of technologies to improve efficacy of alternatives such as
deep injection methods, soil moisture management by improving drip
technologies, experience with virtually impermeable films to increase
efficacy and decrease emissions, and still have reasonable cost
effectiveness.  Even where MB is considered critical, an improvement in
efficient delivery techniques will result in reduction of MB use
requirements.

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



The MB critical use exemption nomination for Forest 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 MB for those nurseries where sufficient pest
control can not be achieved otherwise.  This use is considered critical
because there are conditions in some nurseries within this sector with
high pest pressure where no feasible alternatives are currently
effective.  High production nurseries require a consistent and reliable
pre-plant fumigation treatment that will allow production goals to be
met.  Currently MB is the only consistent provider of this requirement
for nurseries with severe pest infestations and where other treatments
are not effective.  The loss of MB, therefore, would result in a
significant market disruption.  The effort to avoid market disruption
provides the basis for nomination of this sector for critical use
exemption of MB.

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



Barnett, J. P. and McGilvrary, J. M. 1997. Practical guidelines for
producing longleaf pine seedlings in containers.  Gen. Tech. Rep.
SRS-14. Asheville, NC. U. S. Department of Agriculture, Forest Service,
Southern Research Station. 28 p.    HYPERLINK
"http://www.bugwood.org/container/guidelines.html" 
http://www.bugwood.org/container/guidelines.html 

Campbell, S. J. and Kelpsas, B. R. 1988. Comparison of three soil
fumigants in a bareroot conifer nursery. Tree Planters’ Notes 39
(4):16-22.

Carey, W. A. 2000. Fumigation with chloropicrin, metham sodium, and EPTC
as replacements for methyl bromide in southern pine nurseries.  Southern
Journal of Applied Forestry 24:135-139.

Carey, W. A. 1996. Testing alternatives to methyl bromide fumigation at
the Winona Nursery.  Southern Forest Nursery Management Cooperative
Research Report 96-2.

Carey, W. A. 1994. Chemical alternatives to methyl bromide. In: Landis,
T. D., Dumroese, R. K., tech. cords. National Proceedings, Forest and
Conservation Nursery Associations. Gen. Tech. Rep. RM-257. Fort Collins,
CO.  U. S. Department of Agriculture, Forest Service, Rocky Mountain
Forest and Range Experiment Station. pp. 4-11. 

Carey, W. A. and Godbehere, S. 2004. Effects of VIF and solvent carrier
on control of nutsedge and on populations of Trichoderma at two
nurseries in 2003.  Annual International Research Conference on Methyl
Bromide Alternatives (2004).   HYPERLINK "http://mbao.org/" 
http://mbao.org/ 

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.

Cram, M. M., Enebak, S. A., Fraedrich, S. W., and Dwinell, L. D. 2002.
Chloropicrin, EPTC, and plant growth-promoting Rhizobacteria for
managing soilborne pests in pine nurseries. National Proceedings, Forest
and Conservation Nursery Associations, 1999, 2000, and 2001. Gen. Tech.
Rep. RMRS-P—24. Fort Collins, CO.  U. S. Department of Agriculture,
Forest Service, Rocky Mountain Forest and Range Experiment Station. pp
69-74.

Cram, M. M. and Fraedrich, S. W. 1997. Survey of southern forest
nurseries: fumigation practices and pest management concerns.  
HYPERLINK "http://www.epa.gov/spdpublic/mbr/airc/1997/096cram.pdf" 
www.epa.gov/spdpublic/mbr/airc/1997/096cram.pdf 

Darrow, K.  2002.  Personal communication (see Appendix B)

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.

Enebak, S. A., Palmer, M. A., and Blanchette, R. A. 1990. Managing
soilborne pathogens of white pine in a forest nursery.  Plant Disease
74:195-198.

Federal Register, February 5, 1998, 40 CFR, part 82. Control of methyl
bromide emissions through use of tarps.
http://frwebgate5.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=82648432
0000+6+0+0&WAISaction=retrieve.

Fraedrich, S. W. and Dwinell, L. D. 2003a. The effects of soil
fumigation on pine seedling production, weeds, foliar and soil
nutrients, and soilborne microorganisms at a south Georgia (U.S.A.)
forest tree nursery. Canadian Journal of Forest Research 33:1698-1708.

Fraedrich, S. W. and Dwinell, L. D. 2003b. An evaluation of dazomet
incorporation methods on soilborne organisms and pine seedling
production in southern nurseries. Southern Journal of Applied Forestry
27:41-51.

Fraedrich, S. W. and Dwinell, L. D. 2003c. Broadcast applications of
glyphosate control [of] nutsedge at a South Georgia forest tree nursery.
Southern Journal of Applied Forestry 27:176-179.

Fraedrich, S. W. and Dwinell, L. D. 1998. Evaluation of fumigants for
pest management and seedling production in southern pine nurseries.
Annual International Research Conference on Methyl Bromide Alternatives
(1998).   HYPERLINK "http://mbao.org/"  http://mbao.org/ 

Gan, J. and Yates, S. R. 1998. Ammonium thiosulfate fertilizer reduces
methyl bromide emissions from soil. Methyl Bromide Alternatives, USDA,
ARS. vol 4 (3), July,1998.
http://www.ars.usda.gov/is/np/mba/july98/ammonium.htm

Hardie I. W. and Parks, P. J. 1991. Individual choice and regional
acreage response to cost-sharing in the South, 1971-1981. Forest Science
37(1) 175-190.

Iver, J. G. (undated). Nursery fertility and related
problems—yellowing of white pine.  Wisconsin Department of Natural
Resources State Nursery Managers (cooperators).  in CUE 03-0032
application.

James, R. L., Stone, J. K., Hildebrand, D. M., Frankel, S. M., and
Gemandt, D. S. 1997. Alternatives to chemical soil fumigation in western
federal bareroot conifer nurseries. Annual International Research
Conference on Methyl Bromide Alternatives (1997).   HYPERLINK
"http://mbao.org/"  http://mbao.org/ 

James, R. L., Stone, J. K., Hildebrand, D. M., Frankel, S. M., and
Harris, J. L. 2001. Alternatives to pre-plant soil fumigation in western
bareroot forest nurseries. Annual International Research Conference on
Methyl Bromide Alternatives (2001).   HYPERLINK "http://mbao.org/" 
http://mbao.org/ 

Landis, T. D. and Campbell, S. J. 1989.  Soil fumigation in bareroot
tree nurseries. In: Landis, T. D., (tech. coord.), Proc. Intermountain
Forest Nursery Association, Bismarck, ND. USDA, Forest Service, Ft.
Collins, CO.    HYPERLINK
"http://www.fcnanet.org/proceedings/1989/landis.pdf" 
http://www.fcnanet.org/proceedings/1989/landis.pdf 

Lantz, C. W. 1997. Alternatives to methyl bromide in southern forest
tree nurseries. Annual International Research Conference on Methyl
Bromide Alternatives (1997).   HYPERLINK "http://mbao.org/" 
http://mbao.org/ 

Lowerts, G.  2003.  Personal communication.

Mc Nabb, K. and VanderSchaaf, C. 2003. A survey of forest tree seedling
production in the South for the 2003-2003 planting season. Southern
Forest Nursery Management Cooperative Technical Note 03-02.

Moulton, R. J. and Hernandez, G. 2000. Tree planting in the United
States, 1998. Tree Planters Notes V49(2). USDA Forest Service.  pp 1-36.

Rimini, R. and Wigley, S. 2004. VIF: A supplier’s view. Annual
International Research Conference on Methyl Bromide Alternatives (2004).
  HYPERLINK "http://mbao.org/"  http://mbao.org/ 

Royer, J. P. 1987. Determinants of reforestation behavior among southern
landowners. Forest Science 33(3) 654-667.

Stone, J. K., Hildebrand, D. M., James, R. L., Frankel, S. M. 1998.
Alternatives to methyl bromide fumigation for control of soil borne
diseases in bareroot forest nurseries. Annual International Research
Conference on Methyl Bromide Alternatives (1998).   HYPERLINK
"http://mbao.org/"  http://mbao.org/ 

USDA-APHIS (Animal and Plant Health Inspection Service), Plant
Protection and Quarantine. 2002. Sudden Oak Death.   HYPERLINK
"http://www.aphis.usda.gov/ppq/ispm/sod/" 
http://www.aphis.usda.gov/ppq/ispm/sod/ 

Weyerhaeuser In-house Research Study 2 (Bonanza Nursery, Molin, Oregon).
1980.  MB-chloropicrin (spring and fall), Vorlex (MITC+) and Vapam
(metam sodium) trial.  2002 CUE request package.

Weyerhaeuser In-house Research Study 3 (Mima Nursery, Olympia,
Washington). 1984-1987.  MB-chloropicrin, Basamid (dazomet) trial.  2002
CUE request package.

Weyerhaeuser In-house Research Study 4 (Mima Nursery, Olympia,
Washington). 1985-1987.  MB-chloropicrin, Basamid (dazomet), soil
preparation trial.  2002 CUE request package.

Weyerhaeuser In-house Research Study 5 (Mima Nursery, Olympia,
Washington). 1985-1987.  MB-chloropicrin, Basamid (dazomet) rate trial. 
2002 CUE request package.

Weyerhaeuser In-house Research Study 6 (Aiken Nursery, Aiken, South
Carolina). 1992.  MB-chloropicrin, Basamid (dazomet), Busan
(metam-sodium) trial.  2002 CUE request package.

Weyerhaeuser In-house Research Study 7 (Fort Towson Nursery, Ft. Towson,
Oklahoma). 1994-1996.  MB-chloropicrin alternatives trial.  2002 CUE
request package.

Weyerhaeuser In-house Research Study 8 (Magnolia Nursery, Magnolia,
Arkansas). 1992-1995.  MB-chloropicrin alternatives trial.  2002 CUE
request package and Appendices A and C, 2003 CUE request package.

Weyerhaeuser In-house Research Study 9 (G.H.W. Nursery, Washington,
North Carolina). 1994-1995.  Basamid (dazomet) trial.  2002 CUE request
package.

Weyerhaeuser In-house Research Study 10 (G.H.W. Nursery, Washington,
North Carolina). 1994-1996.  Alternative fumigant trial.  2002 CUE
request package.

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

Dichotomous Variables – dichotomous variables are those which take one
of two values, for example, 0 or 1, yes or no.  These variables were
used to categorize the uses during the preparation of the nomination.

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

Currently Use Alternatives – Currently use alternatives is ‘yes’
if the applicant uses alternatives for some portion of pesticide use on
the crop for which an application to use methyl bromide is made.

Tarps/ Deep Injection Used – Because all pre-plant methyl bromide use
in the US is either with tarps or by deep injection, this variable takes
on the value ‘tarp’ when tarps are used and ‘deep’ when deep
injection is used.

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

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

Frequency of Treatment – This indicates how often methyl bromide is
applied in the sector.  Frequency varies from multiple times per year to
once in several decades.

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

Most Likely Combined Impacts (%) – Adjustments to requested amounts
were factors that reduced to total amount of methyl bromide requested by
factoring in the specific situations were the applicant could use
alternatives to methyl bromide.  These are calculated as proportions of
the total request.  We have tried to make the adjustment to the
requested amounts in the most appropriate category when the adjustment
could fall into more than one category. 

(%) Karst geology – Percent karst geology is the proportion of the
land area in a nomination that is characterized by karst formations.  In
these areas, the groundwater can easily become contaminated by
pesticides or their residues.  Regulations are often in place to control
the use of pesticide of concern.  Dade County, Florida, has a ban on the
use of 1,3D due to its karst geology.

(%) 100 ft Buffer Zones – Percentage of the acreage of a field where
certain alternatives to methyl bromide cannot be used due the
requirement that a 100 foot buffer be maintained between the application
site and any inhabited structure.

(%) Key Pest Impacts - Percent (%) of the requested area with moderate
to severe pest problems.  Key pests are those that are not adequately
controlled by MB alternatives.  For example, the key pest in Michigan
peppers, Phytophthora spp. infests approximately 30% of the vegetable
growing area.  In southern states the key pest in peppers is nutsedge.

Regulatory Issues (%) - Regulatory issues (%) is the percent (%) of the
requested area where alternatives cannot be legally used (e.g., township
caps) pursuant to state and local limits on their use.  

Unsuitable Terrain (%) – Unsuitable terrain (%) is the percent (%) of
the requested area where alternatives cannot be used due to soil type
(e.g., heavy clay soils may not show adequate performance) or terrain
configuration, such as hilly terrain. Where the use of alternatives
poses application and coverage problems.

Cold Soil Temperatures – Cold soil temperatures is the proportion of
the requested acreage where soil temperatures remain too low to enable
the use of methyl bromide alternatives and still have sufficient time to
produce the normal (one or two) number of crops per season or to allow
harvest sufficiently early to obtain the high prices prevailing in the
local market at the beginning of the season.

Total Combined Impacts (%) - Total combined impacts are the percent (%)
of the requested area where alternatives cannot be used due to key pest,
regulatory, soil impacts, temperature, etc.  In each case the total area
impacted is the conjoined area that is impacted by any individual
impact.  The effects were assumed to be independently distributed unless
contrary evidence was available (e.g., affects are known to be mutually
exclusive).   For example, if 50% of the requested area had moderate to
severe key pest pressure and 50% of the requested area had karst
geology, then 75% of the area was assumed to require methyl bromide
rather than the alternative.  This was calculated as follows: 50%
affected by key pests and an additional 25% (50% of 50%) affected by
karst geology.

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

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

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

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

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

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

2008 Amount of Request – The 2008 amount of request is the actual
amount requested by applicants given in total pounds active ingredient
of methyl bromide, total acres of methyl bromide use, and application
rate in pounds active ingredient of methyl bromide per acre.  U.S. units
of measure were used to describe the initial request and then were
converted to metric units to calculate the amount of the US nomination. 

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

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

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

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

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

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

APPENDIX B.  Estimated Costs Of Converting A Loblolly Forest Tree
Seedling Nursery From Soil-Based To Containerized Soilless Culture1  TC
"APPENDIX B.  Estimated Costs Of Converting A Loblolly Forest Tree
Seedling Nursery From Soil-Based To Containerized Soilless Culture1" \f
C \l "1"  

The costs below are based on the conversion of a 10 million bareroot
seedling, soil-based, nursery [typical nurseries in the southern U. S.
can produce 20-60 million bareroot seedlings] to a container, soilless,
nursery for the raising of Loblolly pine seedlings in the southern USA. 
The cost estimates include estimates of additional expenditures (over
and above $.04 per seedling cost for soil-based system) for:

A.  Capital Infrastructure

B.  Operating Costs

Limitations of analysis:

There are also expected to be additional shipping costs, due to the
larger size and weight of containerized plants, but estimating these
costs were beyond the scope of this analysis.  Economy of scale can be
significant and regional costs vary, making it difficult to provide a
precise cost.

Additional note:

The capital costs associated with conversion from a soil-based to a
soilless nursery are much less than the capital costs of establishing a
new soilless nursery.  All of the basic infrastructure and much of the
equipment would already be in place with a soil-based nursery.

A.  Capital Infrastructure:

Many of the facilities required for the operation of a soil-based
seedling nursery are required for a soilless nursery, so conversion
costs and the conversion costs are

	Conversion cost:

	Water supply	  					$  0

	Power							$  0

	Buildings						$  0

	Landscaping/leveling/roads				$  0

	Equipment - assuming no trade-ins			$ 100,000		

	Nursery structures + irrigation			$ 130,000

B.  Operating costs:

Working capital requirements are greater in a soilless nursery than a
soil-based nursery as more labor is used.  The cost of conversion from a
soil-based nursery to a soilless nursery should include the need for
additional working capital.

Working capital:

	Additional container system cost				$ 150,000

	(Over and above ~$50,000 cost for soil-based system)

	Containers							$ 410,000

C.  Land

The soil-based nursery requires 13.3 hectares exclusive of buildings,
storage and administrative area.  The soilless nursery requires 4
hectares for the same production.

Assuming the soil-based nursery owner is able to sell or exchange the
surplus land, the change from soil-based to soilless will be a source of
revenue.  A review of land prices in the southern USA, in localities
where forest tree nurseries are situated reveals an average of $12,350
per hectare.

Land Savings:  

Land	(9.3 hectares at $12,350 per hectare)		($ 114,855)

D.  Analysis of Net Costs: 

Converting 10 million Seedling Nursery from Bareroot to Containerized,
Soilless Culture

	Capital Cost	Years of Use*	Annual Cost	Cost per Seedling

Equipment	$100,000	10	$11,723	$0.0012

Nursery Structures	$130,000	10	$15,240	$0.0015

Running Container System 

	$150,000	$0.015

Containers

	$410,000	$0.041

Total Additional Cost**

	$586,963	$0.059

Land rent savings***

	($3,450)	($0.0003)

Net additional cost



$0.0583

Base production cost 

(for bareroot and soilless system)



$0.04

Total Cost per Seedling



$0.0983

*Incorporates real interest cost at 3% per year.

**Does not include additional cost of shipping due to larger and heavier
containers.

***Using land capitalization rate of 3%.

Conclusion:

Converting to a soilless containerized system would increase the cost of
production by approximately 250%, and could be higher when the increased
cost of shipping containerized seedlings is included.

1 Based on communication with Kevin Darrow, Sept. 2002

 PAGE   

 PAGE   ii 

U.S. Forest Seedlings

Page  PAGE   9 

U.S. Forest Seedlings

