Methyl Bromide Critical Use Nomination for Preplant Soil Use for
cucurbits Grown in Open Fields 

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                              CUN:



Nominating Party:	The United States of America 

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Preplant Soil Use for Cucurbits Grown in Open Fields
(Submitted in 2006 for 2008 Use Season)



Nominating Party Contact Details

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

Title:

	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 "_Toc125427543"  Part A: Summary	 
PAGEREF _Toc125427543 \h  8  

  HYPERLINK \l "_Toc125427544"  1. Nominating Party	  PAGEREF
_Toc125427544 \h  8  

  HYPERLINK \l "_Toc125427545"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125427545 \h  8  

  HYPERLINK \l "_Toc125427546"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125427546 \h  8  

  HYPERLINK \l "_Toc125427547"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125427547 \h  8  

  HYPERLINK \l "_Toc125427548"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125427548 \h  8  

  HYPERLINK \l "_Toc125427549"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125427549 \h  10  

  HYPERLINK \l "_Toc125427550"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125427550 \h  11  

  HYPERLINK \l "_Toc125427551"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125427551 \h  12  

  HYPERLINK \l "_Toc125427552"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125427552 \h  12  

  HYPERLINK \l "_Toc125427553"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125427553 \h  12  

  HYPERLINK \l "_Toc125427554"  Michigan - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc125427554 \h  12  

  HYPERLINK \l "_Toc125427555"  Michigan - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125427555 \h  13  

  HYPERLINK \l "_Toc125427556"  Michigan – 11 (ii). Indicate if any of
the above characteristics in 11 (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125427556 \h  14  

  HYPERLINK \l "_Toc125427557"  Michigan - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc125427557 \h  14  

  HYPERLINK \l "_Toc125427558"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125427558 \h  15  

  HYPERLINK \l "_Toc125427559"  Michigan - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125427559 \h  15  

  HYPERLINK \l "_Toc125427560"  Michigan - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125427560 \h  18  

  HYPERLINK \l "_Toc125427561"  Michigan - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125427561 \h  18  

  HYPERLINK \l "_Toc125427562"  Michigan - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested	
 PAGEREF _Toc125427562 \h  18  

  HYPERLINK \l "_Toc125427563"  Michigan - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125427563 \h  20  

  HYPERLINK \l "_Toc125427564"  Michigan - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125427564 \h  20  

  HYPERLINK \l "_Toc125427565"  Michigan - Summary of Technical
Feasibility	  PAGEREF _Toc125427565 \h  20  

  HYPERLINK \l "_Toc125427566"  Southeastern U.S. (except Georgia) -
Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125427566 \h  21  

  HYPERLINK \l "_Toc125427567"  Southeastern U.S. (except Georgia) - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request	  PAGEREF _Toc125427567 \h  21  

  HYPERLINK \l "_Toc125427568"  Southeastern U.S. (except Georgia) - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125427568
\h  21  

  HYPERLINK \l "_Toc125427569"  Southeastern U.S. (except Georgia) –
11 (ii). Indicate if any of the above characteristics in 11 (i) prevent
the uptake of any relevant alternatives?	  PAGEREF _Toc125427569 \h  22 


  HYPERLINK \l "_Toc125427570"  Southeastern U.S. (except Georgia) - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125427570 \h  23  

  HYPERLINK \l "_Toc125427571"  Southeastern U.S. (except Georgia) -
Part C: Technical Validation	  PAGEREF _Toc125427571 \h  24  

  HYPERLINK \l "_Toc125427572"  Southeastern U.S. (except Georgia) - 13.
 Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125427572 \h 
24  

  HYPERLINK \l "_Toc125427573"  Southeastern U.S. (except Georgia) - 14.
List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:	  PAGEREF _Toc125427573 \h  27  

  HYPERLINK \l "_Toc125427574"  Southeastern U.S. (except Georgia) - 15.
List Present (and Possible Future) Registration Status of Any Current
and Potential Alternatives	  PAGEREF _Toc125427574 \h  28  

  HYPERLINK \l "_Toc125427575"  Southeastern U.S. (except Georgia) - 16.
State Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested	  PAGEREF _Toc125427575 \h  29  

  HYPERLINK \l "_Toc125427576"  Southeastern U.S. (except Georgia) - 17.
Are There Any Other Potential Alternatives Under Development which Are
Being Considered to Replace Methyl Bromide?	  PAGEREF _Toc125427576 \h 
30  

  HYPERLINK \l "_Toc125427577"  Southeastern U.S. (except Georgia) - 18.
Are There Technologies Being Used to Produce the Crop which Avoid the
Need for Methyl Bromide?	  PAGEREF _Toc125427577 \h  30  

  HYPERLINK \l "_Toc125427578"  Southeastern U.S. (except Georgia) -
Summary of Technical Feasibility	  PAGEREF _Toc125427578 \h  31  

  HYPERLINK \l "_Toc125427579"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125427579 \h  32  

  HYPERLINK \l "_Toc125427580"  Georgia - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc125427580 \h  32  

  HYPERLINK \l "_Toc125427581"  Georgia - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125427581 \h  33  

  HYPERLINK \l "_Toc125427582"  Georgia - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125427582 \h  34  

  HYPERLINK \l "_Toc125427583"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125427583 \h  37  

  HYPERLINK \l "_Toc125427584"  Georgia - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125427584 \h  37  

  HYPERLINK \l "_Toc125427585"  Georgia - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125427585 \h  40  

  HYPERLINK \l "_Toc125427586"  Georgia - 15. List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125427586 \h  41  

  HYPERLINK \l "_Toc125427587"  Georgia - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested	
 PAGEREF _Toc125427587 \h  41  

  HYPERLINK \l "_Toc125427588"  Georgia - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125427588 \h  42  

  HYPERLINK \l "_Toc125427589"  Georgia - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?	
 PAGEREF _Toc125427589 \h  42  

  HYPERLINK \l "_Toc125427590"  Georgia - Summary of Technical
Feasibility	  PAGEREF _Toc125427590 \h  43  

  HYPERLINK \l "_Toc125427591"  Part D: Emission Control	  PAGEREF
_Toc125427591 \h  45  

  HYPERLINK \l "_Toc125427592"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125427592 \h  45  

  HYPERLINK \l "_Toc125427593"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125427593 \h  45  

  HYPERLINK \l "_Toc125427594"  Part E: Economic Assessment	  PAGEREF
_Toc125427594 \h  46  

  HYPERLINK \l "_Toc125427595"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125427595 \h  46  

  HYPERLINK \l "_Toc125427596"  22. Gross and Net Revenue	  PAGEREF
_Toc125427596 \h  47  

  HYPERLINK \l "_Toc125427597"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125427597 \h  49  

  HYPERLINK \l "_Toc125427598"  Summary of Economic Feasibility	 
PAGEREF _Toc125427598 \h  56  

  HYPERLINK \l "_Toc125427599"  Part F. Future Plans	  PAGEREF
_Toc125427599 \h  58  

  HYPERLINK \l "_Toc125427600"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125427600 \h  58  

  HYPERLINK \l "_Toc125427601"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125427601 \h  58  

  HYPERLINK \l "_Toc125427602"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125427602 \h  58  

  HYPERLINK \l "_Toc125427603"  26. Citations	  PAGEREF _Toc125427603 \h
 59  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125427482"  Part A:
Summary	  PAGEREF _Toc125427482 \h  8  

  HYPERLINK \l "_Toc125427483"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125427483 \h  8  

  HYPERLINK \l "_Toc125427484"  Table A.1: Executive Summary	  PAGEREF
_Toc125427484 \h  10  

  HYPERLINK \l "_Toc125427485"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125427485 \h  11  

  HYPERLINK \l "_Toc125427486"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125427486 \h  12  

  HYPERLINK \l "_Toc125427487"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125427487 \h  12  

  HYPERLINK \l "_Toc125427488"  Michigan - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125427488 \h 
12  

  HYPERLINK \l "_Toc125427489"  Michigan - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc125427489 \h  13  

  HYPERLINK \l "_Toc125427490"  Michigan - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125427490 \h  13  

  HYPERLINK \l "_Toc125427491"  Michigan - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125427491 \h  14  

  HYPERLINK \l "_Toc125427492"  Michigan - Part C: Technical Validation	
 PAGEREF _Toc125427492 \h  15  

  HYPERLINK \l "_Toc125427493"  Michigan – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125427493 \h  15  

  HYPERLINK \l "_Toc125427494"  Michigan – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125427494 \h  18  

  HYPERLINK \l "_Toc125427495"  Michigan – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125427495 \h  18  

  HYPERLINK \l "_Toc125427496"  Michigan – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125427496 \h  19  

  HYPERLINK \l "_Toc125427497"  Southeastern USA (except Georgia) - Part
B: Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125427497
\h  21  

  HYPERLINK \l "_Toc125427498"  Southeastern U.S. (except Georgia) -
Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
  PAGEREF _Toc125427498 \h  21  

  HYPERLINK \l "_Toc125427499"  Southeastern U.S. (except Georgia) -
Table 11.1: Characteristics of Cropping System	  PAGEREF _Toc125427499
\h  21  

  HYPERLINK \l "_Toc125427500"  Southeastern U.S. (except Georgia) -
Table 11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125427500 \h  22  

  HYPERLINK \l "_Toc125427501"  Southeastern U.S. (except Georgia) -
Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125427501 \h  23  

  HYPERLINK \l "_Toc125427502"  Southeastern U.S. (except Georgia) -
Part C: Technical Validation	  PAGEREF _Toc125427502 \h  24  

  HYPERLINK \l "_Toc125427503"  Southeastern U.S. (except Georgia) –
Table 13.1: Reason for Alternatives Not Being Feasible	  PAGEREF
_Toc125427503 \h  24  

  HYPERLINK \l "_Toc125427504"  Southeastern U.S. (except Georgia) –
Table 14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125427504 \h  27  

  HYPERLINK \l "_Toc125427505"  Southeastern U.S. (except Georgia) –
Table 15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125427505 \h  28  

  HYPERLINK \l "_Toc125427506"  Southeastern U.S. (except Georgia) –
Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125427506
\h  30  

  HYPERLINK \l "_Toc125427507"  Georgia - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125427507 \h  32  

  HYPERLINK \l "_Toc125427508"  Georgia - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125427508 \h 
32  

  HYPERLINK \l "_Toc125427509"  Georgia - Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125427509 \h  33  

  HYPERLINK \l "_Toc125427510"  Georgia - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125427510 \h  33  

  HYPERLINK \l "_Toc125427511"  Georgia – Squash - Table 12.1 Historic
Pattern of Use of Methyl Bromide	  PAGEREF _Toc125427511 \h  34  

  HYPERLINK \l "_Toc125427512"  Georgia – Cucumbers - Table 12.2
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125427512 \h  35
 

  HYPERLINK \l "_Toc125427513"  Georgia – Melons - Table 12.3 Historic
Pattern of Use of Methyl Bromide	  PAGEREF _Toc125427513 \h  36  

  HYPERLINK \l "_Toc125427514"  Georgia - Part C: Technical Validation	 
PAGEREF _Toc125427514 \h  37  

  HYPERLINK \l "_Toc125427515"  Georgia – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125427515 \h  37  

  HYPERLINK \l "_Toc125427516"  Georgia – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125427516 \h  40  

  HYPERLINK \l "_Toc125427517"  Georgia – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125427517 \h  41  

  HYPERLINK \l "_Toc125427518"  Southeastern USA except Georgia –
Table C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125427518
\h  42  

  HYPERLINK \l "_Toc125427519"  Part D: Emission Control	  PAGEREF
_Toc125427519 \h  45  

  HYPERLINK \l "_Toc125427520"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125427520 \h  45  

  HYPERLINK \l "_Toc125427521"  Part E: Economic Assessment	  PAGEREF
_Toc125427521 \h  46  

  HYPERLINK \l "_Toc125427522"  Table 21.1: Michigan Cucurbits- Costs of
Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc125427522 \h  46  

  HYPERLINK \l "_Toc125427523"  Table 21.2: Southeastern U.S. (except
Georgia) Cucurbits - Costs of Alternatives Compared to Methyl Bromide
Over 3-Year Period	  PAGEREF _Toc125427523 \h  47  

  HYPERLINK \l "_Toc125427524"  Table 21.3: Georgia Cucurbits - Costs of
Alternatives Compared to Methyl Bromide Over 3-Year Period	  PAGEREF
_Toc125427524 \h  47  

  HYPERLINK \l "_Toc125427525"  Table 22.1: Michigan Cucurbits- Year 1,
2, and 3 Gross and Net Revenues	  PAGEREF _Toc125427525 \h  48  

  HYPERLINK \l "_Toc125427526"  Table 22.2: Southeastern U.S. (except
Georgia) Cucurbits - Year 1, 2, and 3 Gross and Net Revenues	  PAGEREF
_Toc125427526 \h  48  

  HYPERLINK \l "_Toc125427527"  Table 22.3: Georgia Cucurbits- Year 1,
2, and 3 Gross and Net Revenues	  PAGEREF _Toc125427527 \h  48  

  HYPERLINK \l "_Toc125427528"  Michigan Cucumber- Table E.1: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427528 \h  49  

  HYPERLINK \l "_Toc125427529"  Michigan Melon - Table E.2: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427529 \h  50  

  HYPERLINK \l "_Toc125427530"  Michigan Winter Squash - Table E.3:
Economic Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427530
\h  50  

  HYPERLINK \l "_Toc125427531"  Michigan Zucchini - Table E.4: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427531 \h  51  

  HYPERLINK \l "_Toc125427532"  All Michigan Cucurbits - Table E.5:
Economic Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427532
\h  51  

  HYPERLINK \l "_Toc125427533"  Southeastern U.S. (except Georgia)
Cucumber - Table E.6: Economic Impacts of Methyl Bromide Alternatives	 
PAGEREF _Toc125427533 \h  52  

  HYPERLINK \l "_Toc125427534"  Southeastern U.S. (except Georgia) Melon
- Table E.7: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125427534 \h  52  

  HYPERLINK \l "_Toc125427535"  Southeastern U.S. (except Georgia)
Squash - Table E.8: Economic Impacts of Methyl Bromide Alternatives	 
PAGEREF _Toc125427535 \h  53  

  HYPERLINK \l "_Toc125427536"  Southeastern U.S. (except Georgia)
Cucurbits - Table E.9: Economic Impacts of Methyl Bromide Alternatives	 
PAGEREF _Toc125427536 \h  53  

  HYPERLINK \l "_Toc125427537"  Georgia Cucumber – Table E.10:
Economic Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427537
\h  54  

  HYPERLINK \l "_Toc125427538"  Georgia Melon - Table E.11: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427538 \h  54  

  HYPERLINK \l "_Toc125427539"  Georgia Squash - Table E.12: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427539 \h  55  

  HYPERLINK \l "_Toc125427540"  Georgia Cucurbits - Table E.13: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125427540 \h  55  

  HYPERLINK \l "_Toc125427541"  Part F. Future Plans	  PAGEREF
_Toc125427541 \h  58  

  HYPERLINK \l "_Toc125427542"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125427542 \h  63  

 

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



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



The United States of America (U.S.)



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



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



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

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



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



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

Year

	Nomination Amount (kg)	Nomination Area (ha)

2008

	588,949	4,540



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



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

The efficacy of alternatives may be significantly less effective than MB
in some areas, making these alternatives technically and/or economically
infeasible for use in cucurbit production.

Some alternatives may be comparable to MB as long as key pests occur at
low pressure, and in such cases the U.S. is only nominating a critical
use exemption (CUE) for cucurbits where the key pest pressure is
moderate to high such as nutsedge in the Southeastern U.S.

Regulatory constraints prevent use of some chemicals, e.g.,
1,3-dichloropropene (1,3-D) use is limited in Georgia due to the
presence of karst geology.

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

In Michigan cucurbits, metam sodium/potassium + chloropicrin are the
best registered alternative for the control of the key target pests. 
These pests are the soil borne fungi Phytophthora capsici and Fusarium
oxysporum, both of which can easily destroy the entire harvest from
affected areas if left uncontrolled.  At least one of these pests, P.
capsici, has recently been shown to occur in irrigation water in
Michigan (Gevens and Hausbeck, 2003) and has probably contributed to the
spread of this pathogen.  Due to widespread pest distribution, virtually
all of the cucurbit hectares in Michigan currently use MB (plus
chloropicrin) as a prophylactic control.  While metam sodium/potassium +
chloropicrin provided some control of fungi in recent small-plot trials
with cucurbits in Michigan (Hausbeck and Cortwright, 2004), there were
yield losses (approximately 6%) relative to the MB + chloropicrin
standard.

It is also not yet clear whether these small-scale results accurately
reflect efficacy of MB alternatives in commercial cucurbit production. 
Furthermore, regulatory restrictions due to concerns over human exposure
and ground water contamination, along with the lower yields, result in
potential economic infeasibility of this formulation as a practical MB
alternative.  Key among these factors are a delay in planting up to 14
days relative to MB, due to a combination label restrictions and the low
soil temperatures typical of Michigan, as well as a mandatory 30 m
buffer for treated fields with 1,3-D + chloropicrin near inhabited
structures.  Delays in planting may result in growers missing key market
windows and premium harvest prices, and buffer zones will result in some
areas remaining vulnerable to pests in the absence of MB.

In the Southeastern U.S. (including Georgia), nutsedges are the primary
target pest of concern. Some growers in this region also face root-knot
nematodes and the soil-borne fungal pathogens (described above) as key
pests.  Left uncontrolled, any of these pests could completely destroy
the harvests from affected areas.  Metam-sodium offers some control of
nutsedges and nematodes, while 1,3-D + chloropicrin provides good
control of nematodes (e.g., Eger, 2000; Noling et al., 2000).  However,
in areas where nutsedge infestations are moderate to severe and fungal
pathogens are present, metam-sodium results in an estimated 44 % yield
loss relative to MB (Locascio, et al., 1997).  In such areas, use of 1,
3-D + chloropicrin is likely to lead to an estimated 29 % yield loss
relative to MB (Locascio, et al., 1997).  In addition to these estimated
losses, it must be noted that 1,3-D + chloropicrin cannot be used in
large portions of the southeastern U.S. (primarily Kentucky and Georgia
as regards this nomination) due to the presence of karst geology.  1,3-D
cannot be used on such soil due to label restrictions created in
response to concerns over groundwater contamination.  Together, these
yield losses and regulatory restrictions render these promising MB
alternatives technologically and economically infeasible. 

It should be noted also that all studies of yield losses for
metam-sodium and 1,3-D + chloropicrin relative to MB are based on small
plot research trials done on non-cucurbit crops.  Large-scale on-farm
trials will need to be conducted in cucurbits with high fungal and
nutsedge pest pressure to determine the long term potential for these
alternatives.

Some researchers have also reported that these MB alternatives are
degraded more rapidly in areas where they are applied repeatedly, due to
enhanced metabolism by soil microbes.  This phenomenon may compromise
long-term efficacy of these compounds and appears to need further
scientific scrutiny.  Neither of these promising MB alternatives is
presently adequate for control of key pests, and MB remains a critical
use for cucurbits in Michigan and in the southern states.

Michigan, Southeastern U.S. (except Georgia), and Georgia are presented
as separate regions in this nomination to reflect the separate
applications from growers in these areas.  

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

Region	Michigan	Southeastern U.S. (except Georgia)	Georgia - Squash
Georgia – Cucumber	Georgia - Melons

Amount of Applicant Request

	2008	Kilograms	26,592	1,038,753	92,874	67,224	245,739

Amount of Nomination

	2008	Kilograms	26,521	357,235	42,350	31,812	130,090



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



Our review of available research on all other MB alternatives discussed
by MBTOC for cucurbits suggests that, of registered (i.e., legally
available) chemistries only metam sodium and 1,3 D + chloropicrin have
shown potential as commercially viable replacement to MB. Non-chemical
alternatives are either unviable for US cucurbits or require more
research and commercial development before they can be technically and
economically feasible.  

For Michigan pests metam sodium/potassium + chloropicrin is the only key
alternative with efficacy comparable to MB. However, it has regulatory
restrictions due to human exposure concerns, along with technical
limitations, that result in economic infeasibility of this formulation
as a practical MB alternative. Key among these factors are a delay in
planting as long as 30 days, due both to label restrictions and low soil
temperatures, and a mandatory 30 m buffer for treated fields near
inhabited structures. 

For Southeastern U.S. and Georgia, metam-sodium and 1,3 D + chloropicrin
are the most promising alternatives for nutsedges and nematodes,
respectively, which are the key target pests in these regions. However,
where nutsedges are severe, metam-sodium is technically and economically
infeasible due to planting delays and yield losses, while 1,3 D +
chloropicrin is infeasible due to (1) its use being prohibited on Karst
geology, which are widespread in these regions, (2) a 21 day planting
delay, and (3) yield losses.  These effects have been discussed in
Section 5 (above). 

There is also evidence that the pesticidal efficacy of both 1,3 D and
metam-sodium declines in areas where it is repeatedly applied, due to
enhanced degradation of methyl isothiocyanate by soil microbes (Ou et
al., 1995; Verhagen et al., 1996; Dungan and Yates, 2003; Gamliel et
al., 2003). 

All other potential or available MB alternatives are also technically
infeasible for U.S. cucurbits (see Section 13 of each region for further
details).





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
(%)

Michigan	8,620	3%

Southeastern U.S (except Georgia)	18,858	36%

Georgia 	25,204	11%

National Total:	52,682	19%



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

In Michigan, all acreage is treated with MB due to cool weather
conditions and high pest pressure from diseases and weeds.

In Southeastern U.S. and Georgia, areas not treated do not have
nutsedges or pathogens naturally present in cucurbit fields.  Simple
absence of all pests is the only reason these areas are not presently
treated with MB. 



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



The primary reason that some cucurbits may be grown without methyl
bromide in all three regions is the absence of key target pests (i.e.,
nutsedge in the Southeast, and Georgia, soil pathogens and cold soil
temperatures in Michigan, and karst geology in Georgia.





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



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

Region:	Michigan Cucurbits	Southeast Cucurbits	Georgia Squash	Georgia
Cucumbers	Georgia melons

Year of Exemption Request	2008	2008	2008	2008	2008

Kilograms of Methyl Bromide	26,592	1,038,753	92,874	67,224	245,739

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

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

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	221	6,916	618	448	1,637

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

* Only strip treatments are made.

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



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

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

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

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

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

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



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



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

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide is needed 



Michigan	Soilborne fungal diseases: Phytophthora capsici and Fusarium
oxysporum	No effective post-emergence control available; 1,3- D +
chloropicrin is not feasible as a MB alternative due to regulatory and
technical restrictions on use. Low soil temperatures and regulatory
restriction also means that use of 1,3 D or metam sodium cannot be used
with low soil temperatures.  While a recent trial in Michigan indicated
good yields when alternatives were used at higher soil temperatures,
data were highly variable and the study needs to be repeated in larger
plots before technical feasibility can be confirmed. 



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



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

Characteristics	Michigan

Crop Type: 	Transplants grown for cucurbit fruit production. 

Annual or Perennial Crop: 	Annual

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation:	Corn, soybeans, tomatoes, strawberries, other cucurbit crops.
MB is not used for the other crops if applied once already in a given
year.

Soil Types: 	Light to medium loam

Frequency of methyl bromide Fumigation: 	Once every year for a given
field

Other relevant factors:	Soil temperatures are low relative to the rest
of the US cucurbit growing regions (see below)



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

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

Climatic Zone	Temperate

USDA Plant Hardiness Zone 5b

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

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

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

Fumigation Schedule

X











Planting 

Schedule

X	X	X	X







	Key Market Window





X









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



Low soil temperatures (often below 10o C) prior to the typical planting
window inhibit dissipation of 1,3-D + chloropicrin (Martin, 2003), which
can delay planting due to phytotoxicity to crop plants.  There is also a
21-day planting delay as per registration label language.  Combined,
this results in a delay as long as 30 days in planting crops, which may
negatively affect the economics of cucurbit production in this region.
Metam sodium transformation into the active ingredient, methyl
isothiocyanate, is also slowed by low soil temperatures (Ashley et al.
1963).  Thus, optimal use of metam-sodium/potassium (even if effective
against target pests) is likely to result in significant planting
delays.

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



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

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

Area Treated (hectares)	427	508	567	589	224	239

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	100% strip	100% strip	100% strip	100% strip	100% strip
100% strip

Amount of methyl bromide active ingredient used 

(total kilograms)	20,556	24,502	27,331	28,403	26,934	28,719

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

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

Actual dosage rate of active ingredient (g/m2)*	12.0	12.0	12.0	12.0	12.0
12.0

* Applications are made as strip treatments.  Last year’s application
indicted a lower use rate that was incorrect.

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



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



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

Name of Alternative	Technical and regulatory* reasons for the
alternative not being feasible or available  + citations	Is the
alternative considered cost effective?

Chemical Alternatives

1,3 D + chloropicrin	In small plot trials conducted in Michigan, this
formulation showed some efficacy against the key pests (Hausbeck and
Cortright, 2004).  Plant loss was about 6 % as compared to 0 % with MB. 
Perhaps more significantly, the average yield loss for the four cucurbit
crops evaluated (zucchini, acorn squash, melons, and watermelons) was
44%, as compared to the MB standard.  Furthermore, regulatory
restrictions and Michigan’s cool and wet soils result in a delay of up
to 30 days in planting after treatment with this formulation.  This
results in growers missing key harvest windows, with consequent negative
economic impacts (detailed in other sections below).	No

Metam-sodium (and metam potassium)	Control of the key pests is
inconsistent at best.  Trials with metam-potassium applied in the summer
(June) on small plots in Michigan showed yields of four cucurbit crops
to be statistically similar to those obtained with MB (Hausbeck and
Cortright, 2004).  Another trial showed control of Fusarium in tomato,
but this was performed in the much warmer conditions of southwest
Florida (Webster et al., 2001).  In the cool conditions of Michigan,
metam-sodium is likely to be slow to transform into the active
ingredient (methyl isothiocyanate), which suggests that pest control
will not be as effective as in the more favorable Florida conditions. 
However, given the high variability of data in those trials, and the
inconsistent results cited for tomato, it is not clear that this
combination of alternatives will provide reliable pest management in the
absence of MB.  	No

Non Chemical Alternatives

Soil solarization	Michigan’s climate is typically cool (less than 11o
C frequently through May) and cloudy, particularly early in the growing
season when control of the key pests is particularly important. In
Michigan, the growing season is particularly short (May to September),
so the time needed to utilize solarization is likely to render the
subsequent growing of crops impossible, even if it did somehow eliminate
all fungal pathogens. 	No

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

Biological Control	Biological control agents are not technically
feasible alternatives to methyl bromide because they alone cannot
control the soil pathogens that afflict cucurbits in Michigan. The
bacterium Burkholderia cepacia and the fungus Gliocladium virens have
shown some potential in controlling some fungal plant pathogens (Larkin
and Fravel, 1998). However, in a test conducted by the Michigan
applicants (included in the 2002 application from this region), P.
capsici was not controlled adequately in summer squash, a cucurbit crop,
by either of these beneficial microorganisms.	No

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

Crop rotation and fallow land	The crop rotations available to growers in
Michigan region are also susceptible to these fungi, particularly to P.
capsici.  Fallow land can still harbor P. capsici oospores (Lamour and
Hausbeck, 2003).  Thus fungi would persist and attack cucurbits if crop
rotation/fallow land was the main management regime.

	No

Endophytes	Though these organisms (bacteria and fungi that grow
symbiotically or as parasites within plants) apparently suppress some
plant pathogens in cucumber (MBTOC, 1994), there is no such information
for the other cucurbit crops grown in Michigan.  Furthermore, the target
pathogens of the study did not include P. capsici, probably the greatest
threat to Michigan cucurbits.	No

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

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

Combinations of Alternatives

Metam sodium + Chloropicrin	Trials in tomato have shown inconsistent
efficacy of this formulation against fungal pests, though it is
generally better than metam-sodium alone (Locascio and Dickson, 1998;
Csinos et al., 1999). Low efficacy in even small-plot trials indicates
that this is not a technically feasible alternative for commercially
produced cucurbits at this time. These studies apparently did not
measure yield impacts, and did not involve cucurbits.  Trials with
metam-potassium + chloropicrin on small plots in Michigan showed yields
of 4 cucurbit crops to be statistically similar to those obtained with
MB (Hausbeck and Cortright, 2003).  However, given the high variability
of data in those trials, and the inconsistent results cited for tomato,
it is not clear that this combination of alternatives will provide
reliable pest management in the absence of MB.	No

1,3 D + Metam-sodium	Trials in tomato have shown inconsistent efficacy
of this formulation against fungal pests, though it is generally better
than metam-sodium alone (Csinos et al., 1999). Low efficacy in even
small-plot trials indicates that this is not a technically feasible
alternative for commercially produced cucurbits in Michigan at this
time. These studies apparently did not measure yield impacts, and did
not involve cucurbits. The study in Michigan mentioned for other
alternatives (Hausbeck and Cortright, 2003) did not address this
combination.	No

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

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




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

Name of Alternative	Discussion

Other than those options discussed elsewhere, no alternatives exist for
the control of the key pests when they are present in the soil and/or
afflict the belowground portions of cucurbit plants.  A number of
effective fungicides are available for treatment of these fungi when
they infect aerial portions of crops.  However, these infections are not
the focus of MB use, which is meant to keep newly planted transplants
free of these fungi. 



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



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

Name of Alternative	Present Registration Status

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

Methyl iodide	Not registered in the U.S.  Registration is currently
being pursued only for tomatoes, strawberries, peppers, and ornamental
crops.	Not currently for cucumbers	Unknown

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

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

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

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



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



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

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

In another study conducted on tomatoes, Gilreath et al. (1994) found
that metam-sodium treatments did not match MB in terms of plant vigor at
the end of the season; again, Fusarium (but not P. capsici) was one of
several pests present. 

Taken together, these studies indicate that, while the recent trials in
Michigan are promising for the use of metam-sodium/potassium +
chloropicrin, there is still great inconsistency in efficacy and
protection from yield losses. Further, no large scale field trials have
yet been performed to demonstrate reliable, consistent pest control
similar to that of MB in the cucurbit growing regions of Michigan. Given
the highly variable results with this MB alternative, EPA decided that
the best case yield loss scenario would be a level similar to what was
assessed in the 2003 Critical Use Nomination.  Hence Table C.1 and the
associated economic loss analyses (Part E) are based on the level used
in that Nomination.

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

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

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

	For plantings done in cold conditions, losses are incurred due to
regulatory constraints.

Overall Loss Estimate for All Alternatives to Pests	Regulatory
constraints



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



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

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

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

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

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

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



Research is ongoing in Michigan to find new technologies, chemicals, and
application methods that will reduce the use of MB.

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

The U.S. EPA has determined that only metam potassium (with or without
chloropicrin) has some technical feasibility against the key pests of
cucurbits in this region.  1,3 D + chloropicrin, which has shown promise
against these pests in trials in other regions and crops, did not
provide control comparable to MB in new tests conducted in Michigan in
2003.  Metam sodium/potassium has also been inconsistent across
different studies, and no large-plot studies have been performed to show
commercial feasibility in cucurbits (e.g., Martin 2003, Hausbeck and
Cortright, 2003; Csinos et al., 1999).  Important technical and
regulatory constraints on both 1,3 D and metam-sodium/potassium
formulations must also be considered: a 21 – 30 day planting delay,
mandatory 100 foot buffers (for 1,3 D) near inhabited structures –
both of which will cause negative economic impacts, and potentially
lower dissipation (and thus efficacy) in the cool soils of this region. 

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

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

Southeastern U.S. (except Georgia) - Part B: Crop Characteristics and
Methyl Bromide Use  TC "Southeastern USA (except Georgia) - Part B: Crop
Characteristics and Methyl Bromide Use" \f F \l "1"    TC "Southeastern
U.S. (except Georgia) - Part B: Crop Characteristics and Methyl Bromide
Use" \f C \l "1"  



Southeastern U.S. (except Georgia) - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request 
TC "Southeastern U.S. (except Georgia) - 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request"
\f C \l "2"  :



Southeastern U.S. (except Georgia) - Table 10.1: Key Diseases and Weeds
and Reason for Methyl Bromide Request  TC " Southeastern U.S. (except
Georgia) - Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request" \f F \l "1"  

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide needed 



“Southeastern U.S. (except Georgia)”. A consortium of cucurbit
growers in Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South
Carolina, Tennessee, and Virginia is included here	Nutsedges: yellow
(Cyperus esculentus), and purple (Cyperus rotundus); to a lesser extent:
fungal diseases (Phytophthora, Fusarium spp.) and root knot nematodes
(Meloidogyne incognita)	No effective alternatives exist for control of
the nutsedge, due to either lack of registration, planting delays (due
to regulatory restriction or phytotoxicity) or low efficacy, or lack of
registration of potentially effective herbicides, all of which result in
significant economic loss. In part of this region, fungal diseases may
also have no effective control in the absence of MB, due to regulatory
restrictions and planting delays associated with 1,3 D + chloropicrin
use.



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



Southeastern U.S. (except Georgia) - Table 11.1: Characteristics of
Cropping System  TC " Southeastern U.S. (except Georgia) - Table 11.1:
Characteristics of Cropping System" \f F \l "1"  

Characteristics	Southeastern U.S. (except Georgia)

Crop Type:	Transplants grown for cucurbit fruit production.

Annual or Perennial Crop: 	Annual

Typical Crop Rotation  and use of methyl bromide for other crops in the
rotation: 	Other cucurbits, tobacco, grains, cotton

Soil Types:  	Low organic content, light to medium loam

Frequency of methyl bromide Fumigation: 	Once every year

Other relevant factors:

	

Southeastern U.S. (except Georgia) - Table 11.2 Characteristics of
Climate and Crop Schedule  TC "Southeastern U.S. (except Georgia) -
Table 11.2 Characteristics of Climate and Crop Schedule" \f F \l "1"  

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

Climatic Zone	Temperate

USDA Plant Hardiness Zones 6b – 8b

Soil Temp. ((C)	Not available.

Rainfall (mm)	163	124	109	87	78	146	113	202	109	116	54	76

Outside Temp. ((C)	9.4	14.5	17.7	23.4	26	25.9	22.6	14.9	7.7	3.4	2.9	4.2

Fumigation Schedule	X	X









X

Planting 

Schedule	X	X	X

X	X







Key Market Window





	X





	

Southeastern U.S. (except Georgia) – 11. (ii) Indicate if any of the
above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Southeastern U.S. (except Georgia) – 11 (ii).
Indicate if any of the above characteristics in 11 (i) prevent the
uptake of any relevant alternatives?" \f C \l "2"  



Alternatives have not been effective against some of the key pests in
this sector in certain areas of the southeastern U.S.

Southeastern U.S. (except Georgia) - 12. Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested  TC "Southeastern U.S. (except Georgia) - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested" \f C \l "2"   



Southeastern U.S. (except Georgia) - Table 12.1 Historic Pattern of Use
of Methyl Bromide  TC "Southeastern U.S. (except Georgia) - Table 12.1
Historic Pattern of Use of Methyl Bromide" \f F \l "1"  

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

Area Treated (hectares)	3,976	4,532	5,034	5,253	5,658	5,941

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	Strip beds	Strip beds	Strip beds	Strip beds	Strip beds
Strip beds

Amount of methyl bromide active ingredient used 

(total kg)	597,177	680,751	756,120	788,942	849,723	892,270

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

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

Actual dosage rate of active ingredient (g/m2)*	15.0	15.5	15.0	15.0	15.0
15.0

* Applications are made as strip treatments.

Southeastern U.S. (except Georgia) - Part C: Technical Validation  TC
"Southeastern U.S. (except Georgia) - Part C: Technical Validation" \f F
\l "1"    TC "Southeastern U.S. (except Georgia) - Part C: Technical
Validation" \f C \l "1"  



Southeastern U.S. (except Georgia) - 13. Reason for Alternatives Not
Being Feasible  TC "Southeastern U.S. (except Georgia) - 13.  Reason for
Alternatives Not Being Feasible" \f C \l "2"   



Southeastern U.S. (except Georgia) – Table 13.1: Reason for
Alternatives Not Being Feasible  TC "Southeastern U.S. (except Georgia)
– Table 13.1: Reason for Alternatives Not Being Feasible" \f F \l "1" 


Name of Alternative	Technical and regulatory* reasons for the
alternative not being feasible or available + citations	Is the
alternative considered cost effective?

Chemical Alternatives

1,3 D + chloropicrin	Effective (in small plot studies) in controlling
disease and nematode pests, but not nutsedges (Locascio et al., 1997;
Csinos et al., 1999; Noling et al., 2000). Subject to regulatory
restrictions in some areas (where Karst geology exists).	No

Metam-sodium	Provides control of nutsedges only close to application
site (Dowler, 1999; Locascio and Dickson, 1998). Surviving nutsedge
tubers can potentially recolonize the crop field (Webster, 2002). Not
effective against the disease or nematode pests in this region.
Approximate yield losses due to nutsedge are 3 – 25 %; losses would be
higher in areas facing the other key pests along with nutsedges.
Technically and economically infeasible due to these yield losses (see
economic analyses in Part E)	No

Non Chemical Alternatives

Soil solarization	For nutsedge control in the southeastern U.S. states,
solarization is unlikely to be technically feasible as a methyl bromide
alternative.  Research indicates that the lethal temperature for
nutsedge tubers is 50o C or higher (Chase et al., 1999).  While this may
be achieved for some portion of the autumn cropping in southern cucurbit
growing regions, it is very unlikely for any portion of the spring
crops.  Trials conducted in mid-summer in Georgia resulted in maximal
soil temperatures of 43o C at 5 cm depth.  Thus, solarization, even in
the warmer months in southern states, did not result in temperatures
reliably high enough to destroy nutsedge tubers, and tubers lodged
deeper in the soil would be completely unaffected.  	No

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

Biological Control	Biological control agents are not technically
feasible alternatives to methyl bromide because they alone cannot
control the soil pathogens and/or nutsedges that afflict cucurbits.
While some fungal pathogens showed potential as control agents (Phatak,
1983), no work has yet been done on using these pathogens as reliable
pest management tools in open-field cucurbit crops. Season-long field
tests have shown low levels of pest control or lack of persistence of
the control agents (Kadir et al., 2000) 	No

Cover crops and mulching	Cover crops and mulches appear to control many
weeds, but not nutsedges (Burgos and Talbert, 1996). The effect of cover
crops on cucurbit crop growth and yield remains unknown; this
contributes to the technical obstacles this strategy faces as a methyl
bromide alternative.  In some studies cover crops have delayed crop
maturity and reduced height and yield of plants (Burgos and Talbert,
1996, Galloway and Weston, 1996).  Mulching has also been shown to be
ineffective in controlling nutsedges, since these plants are able to
penetrate through both organic and plastic mulches (Munn, 1992;
Patterson, 1998).  	No

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

Endophytes	Though these organisms (bacteria and fungi that grow
symbiotically or as parasites within plants) have shown potential
against some pathogens in cucumber (MBTOC, 1994), there is no such
information for the other cucurbit crops. Similarly, the U.S. found no
evidence that endophytes control nutsedges	No

Flooding/Water management	As with many of the other alternatives to
methyl bromide, flooding has been shown to control a number of weeds,
but not nutsedge species. Nutsedge is much more tolerant of watery
conditions than many other weed pests.  For example, Horowitz (1972)
showed that submerging nutsedge in flowing or stagnant water (for 8 days
and 4 weeks, respectively) did not affect the sprouting capacity of
tubers.  Another practical obstacle to implementing flood management
approaches in cucurbit production in the southern and southeastern U.S.
states is that the soil composition may not support flooding and still
remain productive. 	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	The U.S. was unable to locate any
studies showing any potential for grafting, resistant rootstock or plant
breeding as technically feasible alternatives to methyl bromide control
of nutsedges in cucurbits. While in theory plant breeding may improve
the ability of cucurbits to compete with these weeds for nutrients,
light, etc., it would certainly not provide alternatives within the time
span considered in this critical use exemption nomination. The effect on
the quality of the crops involved is unknown also. For resistant
rootstock at least, there are no studies documenting the commercial
availability of resistant rootstock immune to the fungal pathogens
listed as major cucurbit pests. Grafting and plant breeding are thus
also rendered technically infeasible as methyl bromide alternatives. 
US-EPA found no evidence that soilless culture or substrates/plug plants
can be used to produce cucurbit crops on a large scale, or that they
will control nutsedges, which like soil fungi are particularly hardy. 
Various aspects of organic production – organic mulches, cover crops,
fallow land, steam sterilization have already been addressed in this
document and assessed to be technically infeasible methyl bromide
alternatives.	No

Combinations of Alternatives

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

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

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

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



Southeastern U.S. (except Georgia) – Table 14.1: Technically
Infeasible Alternatives Discussion  TC " Southeastern U.S. (except
Georgia) – Table 14.1: Technically Infeasible Alternatives Discussion"
\f F \l "1"  

Name of Alternative	Discussion

Halosulfuron-methyl	Herbicide: causes potential crop injury; has plant
back restrictions. Efficacy is lowered in rainy conditions (common
during the period of initial planting of these crops).  Also, a 24-month
plant back restriction may cause significant economic disruption if
growers must rely on this control option.  Halosulfuron is only allowed
for the row middles for cucurbits, due to its phytotoxicity.  This would
result in nutsedges surviving close to crop plants.  Thus this herbicide
is not technically feasible as a stand-alone replacement for MB, and its
use in conjunction with other pest management methods has not yet been
investigated.

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

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



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



Southeastern U.S. (except Georgia) – Table 15.1: Present Registration
Status of Alternatives  TC "Southeastern U.S. (except Georgia) – Table
15.1: Present Registration Status of Alternatives" \f F \l "1"  

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

Methyl iodide	For nutsedges and fungi: Not registered in the USA for
cucurbits. Registration is currently being pursued only for tomatoes,
strawberries, peppers, and ornamental crops	No (for cucurbits)	N/A

Pebulate	For nutsedges: Was registered for use in tomatoes only, but
even this registration lapsed December 31, 2002 (registrant corporation
went out of business)	No (for cucurbits)	N/A

S-metolachlor	For nutsedges: registered for crops other than cucurbits
No (for cucurbits)	N/A

Terbacil	For nutsedges: registered for crops other than cucurbits	No
(for cucurbits)	N/A

Rimsulfuron	For nutsedges: registered for crops other than cucurbits	No
(for cucurbits)	N/A

Trifloxysulfuron	For nutsedges: registered for crops other than
cucurbits	No (for cucurbits)	N/A

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



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



For a discussion of relative effectiveness of MB alternatives against
fungal pests, please see Section 16 for the Michigan region.  Few
studies have specifically targeted cucurbits for alternatives to MB.  In
the southeastern U.S., both metam-sodium and 1,3 D + 35 % chloropicrin
have shown good efficacy against root knot nematodes, in trials with
tomato and pepper.  For example, Locascio and Dickson (1998) reported
that metam-sodium + 35 % chloropicrin (295 l/ha of metam-sodium,
shank-injected) reduced nematode galls significantly over untreated
control plots, though not as much as did MB + 35 % chloropicrin
treatments (500kg MB/ha, shank-injected), in Florida tomatoes.  Analysis
of 35 tomato and 5 pepper trials conducted from 1993 – 1995 indicated
that 1,3 D (with either 17 % or 35 % chloropicrin) provided control of
nematodes that was equal or superior to that seen with MB, in 95 % of
the tomato and 100 % of pepper trials (Eger, 2000).  However, it is not
clear whether yields were also comparable to those obtained with MB.
Noling et al (2000) also studied the effects of metam-sodium (115 l/ha,
syringe-injected), 1,3 D + 17 % chloropicrin (53.6 l/ha, soil-injected),
and 1,3 D + 35 % chloropicrin (39.8 l/ha), among other treatments, in
tomato plots.  Galls inflicted by root knot nematodes were reduced
significantly by all these MB alternatives, as compared to untreated
control plots.  Yields were also significantly higher as compared to the
control plots; all MB alternatives resulted in similar high yields.
However, the effects of MB formulations were not reported in this study.
 Further, it is the opinion of some US crop experts that metam sodium,
in particular, is very inconsistent in its beneficial effects as a
nematode control agent (Dr. S. Culpepper, University of Georgia,
personal communication).

For nutsedges, metam-sodium and 1,3 D (with and without chloropicrin)
have shown inconsistent efficacy that is often inferior to that of MB
formulations. For example, Locascio et al. (1997) studied MB
alternatives on tomatoes grown in small plots in Florida. Various
treatments were tested on plots that had multiple pests.  At the
Bradenton site there was moderate to heavy Fusarium infestation; heavy
purple nutsedge infestation and light root-knot nematode pressure.  At
Gainesville there was heavy infestation of yellow and purple nutsedge
and moderate infestation of root-knot nematode.  The treatments at both
locations included MB (67%) + chloropicrin (33%) chisel-injected at 390
kg/ha; metam-sodium (chisel-injected) at 300L/ha; metam-sodium
drip-irrigated at 300L/ha; and 1,3-D + 17% chloropicrin chisel-injected
at 327L/ha.  In pair wise statistical comparisons, the yield was
significantly lower in metam-sodium treatments compared to MB at both
sites.  At Bradenton, the average yield from both metam-sodium
treatments was 33% of the MB yields, suggesting a 67% yield loss from
not using MB.  At Gainesville, the average yield of the two metam-sodium
treatments was 56% of the MB yield, suggesting a 44% yield loss from not
using MB.  The yield of the 1,3-D treatment at Gainesville was 71% of
the MB standard suggesting a 29% loss by not using MB (yield data for
1,3-D were not reported for Bradenton). In considering 1,3 D results,
the reader must keep in mind that this MB alternative cannot be used in
areas where karst geology exists. No farm scale trials appear to have
been done to validate these results as yet. 

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

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

1,3 D + chloropicrin	Nutsedges	10-40 %

(for areas included in this request)	29 % (Locascio, et al., 1997)

Metam-sodium (with or without chloropicrin)	Nutsedges	10-66 % 

(for areas included in this request)	44 % (Locascio, et al., 1997)

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



Southeastern U.S. (except Georgia) - 17. Are There Any Other Potential
Alternatives Under Development which Are Being Considered to Replace
Methyl Bromide?  TC "Southeastern U.S. (except Georgia) - 17. Are There
Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?" \f C \l "2"  : 

The applicant states that research has been conducted on nutsedge
control with halosulfuron, 1,3 D + chloropicrin, and metam-sodium. 
Future research will focus on halosulfuron and crop rotation for control
of nutsedges.  Approximately 3 to 5 years are expected as a timeframe
for developing effective MB alternatives for nutsedge control in
cucurbits produced in this region. Research will be conducted in
cooperation with commercial cucurbit growers, by faculty and extension
staff at various land-grant universities in the states encompassed by
this region. Also, it is reasonable to expect that the results from
Michigan research on fungicidal alternatives to MB will be used to
develop options for fungal pests of southeastern US cucurbits. 

Future plans to minimize MB use also include:

Using research and on-farm evaluations optimize a combination of
nutsedge control in fallow fields, crop rotation, and use of
post-emergent herbicide in crops. Herbicides will include halosulfuron,
sulfentrazone, and glyphosate.

Optimize the combined use of plastic (e.g., LDPE) tarps and drip
irrigation equipment for applying at-plant herbicides.

Southeastern U.S. (except Georgia) - 18. Are There Technologies Being
Used to Produce the Crop which Avoid the Need for Methyl Bromide?:  TC
"Southeastern U.S. (except Georgia) - 18. Are There Technologies Being
Used to Produce the Crop which Avoid the Need for Methyl Bromide?" \f C
\l "2"   



No.  Areas where MB is not used in this region do not face moderate to
severe populations of the key pests.

Southeastern U.S. (except Georgia) - Summary of Technical Feasibility 
TC "Southeastern U.S. (except Georgia) - Summary of Technical
Feasibility" \f C \l "2"  

As regards the key pests cited by the applicants from this region,
technically feasible alternatives appear to exist for root knot
nematodes, namely 1,3 D + chloropicrin and metam-sodium (by itself or
with chloropicrin). 1, 3 D + chloropicrin also shows efficacy against
the fungal pests in this region. However, this MB alternative has
significant regulatory and technical limitations that are likely to
result in negative economic impacts (please see the summary of technical
feasibility for Michigan for a discussion of these limitations). In
addition to the limitations faced by Michigan growers, farmers in the
southeastern USA who farm on Karst geology are prohibited from even
considering this option due to regulatory restrictions intended to
mitigate groundwater contamination. When 1,3 D cannot be used, growers
in this region will have no technically feasible control option where
fungi are the major pests.

For nutsedge pests, which are widespread in this region, cucurbit
growers do not currently have technically feasible alternatives to MB
use at planting. Metam-sodium and 1,3 D + chloropicrin have shown some
efficacy in small-plot trials in other vegetable crops (e.g, tomato).
However, at best, metam sodium may allow at least 44 % yield loss, while
1,3 D may allow at least 29 % loss. Both often show less control than MB
(in terms of population suppression) of nutsedges. These factors suggest
that even this alternative will not be economically feasible even in the
best-case technical scenario. It should be noted that there is evidence
that both 1,3 D and methyl isothiocynate levels decline more rapidly,
thus further compromising efficacy, in areas where these are repeatedly
applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003).
This is due to enhanced degradation of these chemicals by soil microbes
(Dungan and Yates, 2003). 

Other chemical alternatives to MB that have shown promise against
nutsedges (e.g, pebulate) are currently unregistered for cucurbits, and
are often not being developed for registration by any commercial entity.


In a new study, Culpepper and Langston (2004) conducted studies at 2
sites in spring 2003 and 1 site in fall 2004. Plot sizes were 20 feet X
32 inches (4.94 m2). Treatments were: Methyl bromide standard (67:33
formulation), untreated control, 2 formulations of telone (1,3 D +
chloropicrin) at various doses, followed by an additional application of
either chloropicrin or metam-sodium, a third formulation of 1,3 D +
chloropicrin (“Inline”), and methyl iodide. An additional set of
plots received the same fumigant treatments but also received an
herbicide treatment (clomazone + halosulfuron) later in the season. 

Watermelon – the only cucurbit crop addressed in these experiments –
showed no significant (final) yield differences across any fumigant
treatment. The same lack of difference was observed when herbicides were
added. In fact, there was no difference in yield even when pesticide
treatments were compared to the untreated control. However, nutsedge
populations in the study appeared to be relatively low (e.g., 667 plants
per plot or 135/m2, in the untreated control, at the end of the study).

Furthermore, a number of important caveats must be mentioned when
considering these results:

Plots used were quite small, and it is not at all clear if the promising
results will hold reliably in larger commercial fields. This is
particularly worrisome given the highly variable results reported by
other researchers for the same MB alternatives.

The nutsedge populations in this study were dominated by yellow nutsedge
(90 % of the total number). It is not clear if populations where purple
nutsedge is dominant will be controlled as effectively. A number of
other studies have indicated that purple nutsedge is a hardier species,
and even in Culpepper and Langston’s study, it appeared more resistant
to the MB alternatives. For example, methyl iodide gave “77 %
control” of yellow nutsedge, but only “37 % control” of purple
nutsedge. Control in this case was apparently defined as the reduction
in nutsedge populations as compared to populations in the untreated
control. 

This study was done only with watermelons, and it is not clear if other
cucurbits will respond so favorably in terms of yield, or lack of
phytotoxic response. Also, a custom-built applicator had to be used for
the metam-sodium applications to eliminate worker exposure risks,
according to the authors. It is not yet clear if such an applicator can
be mass-produced and/or used reliably in a commercial setting.

The other key pest cited for cucurbits in this region, Pythium rot, was
not examined in this study. Thus these results do not shed additional
light on whether alternative soil fumigants could be used against that
pest.

Large-scale, on-farm demonstrations of optimal application methodology
in a commercial setting are lacking for cucurbit crops, adding to the
current lack of viability of MB alternatives in this crop system. While
a combination of alternatives may replace MB in future cucurbit
production in this region, it remains some years away from technical
feasibility. Research and on-farm trials are planned or are on-going,
but have not as yet generated results significant enough to change the
need for methyl bromide dramatically.

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



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



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

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to genus and, if known, to species level	Specific reasons why methyl
bromide needed 

Georgia	Nutsedges: yellow (Cyperus esculentus), and purple (Cyperus
rotundus); fungal diseases (mainly Pythium spp.); to a lesser extent:
root knot nematodes (Meloidogyne incognita)	No effective alternatives
exist for control of the nutsedge, due to either lack of registration,
planting delays (due to regulatory restriction or phytotoxicity) or low
efficacy, both of result in significant economic loss, or lack of
registration of potentially effective herbicides. In part of this
region, fungal diseases may also have no effective control in the
absence of MB, due to regulatory restrictions on the only effective
alternative (1,3 D + chloropicrin).  Georgia may have a higher level of
nematode pressure than the other southeastern states.



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



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

Characteristics	Georgia

Crop Type:	Transplants grown for cucurbit fruit production.

Annual or Perennial Crop: 	Annual (one)

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Other cucurbits, bell pepper, squash, eggplant

Soil Types:  	Light to medium loam, low organic matter

Frequency of methyl bromide Fumigation: 	Once every year

Other relevant factors:	Karst geology are widespread in Georgia.



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

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

Climatic Zone	Temperate

USDA Plant Hardiness Zones 7a – 8b

Soil Temp. ((C)	Applicant is requested to supply any available data

Rainfall (mm)	206	108	148	248	0	158	84	122	109	137	37	131

Outside Temp. ((C)	15	17.7	22.9	25.6	27.2	27.5	25.1	20	11.4	7.5	6.2	9.7

Fumigation Schedule



	X





	X*

Planting 

Schedule	X



X	X







Key Market Window





X**



X**



Notes: 

* = This fumigation period is for a cantaloupe typically double cropped
with squash, which is typically a spring application cycle; the other
fumigation period shown is for cucumber usually double cropped with bell
peer and squash usually double cropped with cabbage, both typically a
fall cycle.

** = US-EPA assumes these are the key market windows based on harvest
schedule supplied by the applicant. According to the applicant, harvests
for fall cycle crops occur in October & November, those for spring cycle
crops occur in May through July. 

Planting schedule is July and August for crops with a fall application
cycle; March for those with a spring cycle.

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

Karst geology prevent widespread application of 1,3 D + chloropicrin as
an alternative for disease and nematode control, because regulatory
restrictions prohibit use of this chemical on the overlying soils.

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



Georgia – Squash - Table 12.1 Historic Pattern of Use of Methyl
Bromide  TC "Georgia – Squash - 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)	824	662	618	578	572	550

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	100% Strip	100% Strip	100% Strip	100% Strip	100% Strip
100% Strip

Amount of methyl bromide active ingredient used

(total kg)	157,271	101,863	92,874	86,857	85,945	82,602

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

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

Actual dosage rate of active ingredient (g/m2)*	19.1	15.4	15.0	15.0	15.0
15.0

* Applications are made as strip treatments.

Georgia – Cucumbers - Table 12.2 Historic Pattern of Use of Methyl
Bromide  TC "Georgia – Cucumbers - Table 12.2 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)	824	662	618	608	584	590

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	100% Strip	100% Strip	100% Strip	100% Strip	100% Strip
100% Strip

Amount of methyl bromide active ingredient used

(total kg)	157,271	101,863	92,874	91,294	87,642	88,558

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

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

Actual dosage rate of active ingredient (g/m2)*	19.1	15.4	15.0	15.0	15.0
15.0

* Applications are made as strip treatments.

Georgia – Melons - Table 12.3 Historic Pattern of Use of Methyl
Bromide  TC "Georgia – Melons - Table 12.3 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)	760	738	1,636	1,581	1,776	1,591

ratio of Flat Fumigation methyl bromide use to strip/bed use if strip
treatment is used	100% Strip	100% Strip	100% Strip	100% Strip	100% Strip
100% Strip

Amount of methyl bromide active ingredient used

(total kg)	145,149	113,451	245,739	237,473	266,769	238,992

formulations of methyl bromide 	67:33	67:33	67:33	67:33	67:33	67:33

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

Actual dosage rate of active ingredient (g/m2)*	19.1	15.4	15.0	15.0	15.0
15.0

* Applications are made as strip treatments.

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



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



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

Name of Alternative	Technical and regulatory* reasons for the
alternative not being feasible or available + citations	Is the
alternative considered cost effective?

Chemical Alternatives

1,3 D + chloropicrin	Effective (in small plot studies) in controlling
disease and nematode pests, but control of nutsedges is inconsistent at
best (Locascio et al., 1997; Csinos et al., 1999; Noling et al., 2000;
Culpepper and Langston, 2004). Subject to regulatory restrictions in
some areas (where Karst geology exist).	No

Metam-sodium	Provides control of nutsedges only close to application
site (Dowler, 1999; Locascio and Dickson, 1998). Surviving nutsedge
tubers can recolonize the crop field (Webster, 2002). Not effective
against the disease or nematode pests in this region. Approximate yield
losses due to nutsedge are 3-66%; losses would be higher in areas facing
the other key pests along with nutsedges. This alternative is both not
feasible due to these yield losses.	No

Non Chemical Alternatives

Soil solarization	For nutsedge control in the southeastern U.S. states,
solarization is unlikely to be technically feasible as a methyl bromide
alternative.  Research indicates that the lethal temperature for
nutsedge tubers is 50o C or higher (Chase et al., 1999).  While this may
be achieved for some portion of the autumn cropping in southern cucurbit
growing regions, it is very unlikely for any portion of the spring
crops.  Trials conducted in mid-summer in Georgia resulted in maximal
soil temperatures of 43o C at 5 cm depth.  Thus, solarization, even in
the warmer months in southern states, did not result in temperatures
reliably high enough to destroy nutsedge tubers, and tubers lodged
deeper in the soil would be completely unaffected.  	No

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

Biological Control	Biological control agents are not technically
feasible alternatives to methyl bromide because they alone cannot
control the soil pathogens and/or nutsedges that afflict cucurbits.
While some fungal pathogens showed potential as control agents (Phatak,
1983), no work has yet been done on using these pathogens as reliable
pest management tools in open-field cucurbit crops. Season-long field
tests have shown low levels of pest control or lack of persistence of
the control agents (Kadir et al., 2000) 	No

Cover crops and mulching	Cover crops and mulches appear to control many
weeds, but not nutsedges (Burgos and Talbert,1996). The effect of cover
crops on cucurbit crop growth and yield remains unknown; this
contributes to the technical obstacles this strategy faces as a methyl
bromide alternative.  In some studies cover crops have delayed crop
maturity and reduced height and yield of plants (Burgos and Talbert,
1996; Galloway and Weston, 1996).  Mulching has also been shown to be
ineffective in controlling nutsedges, since these plants are able to
penetrate through both organic and plastic mulches (Munn, 1992;
Patterson, 1998).  	No

Crop rotation and fallow land	Crop rotation/fallow is not a technically
feasible alternative to methyl bromide because it does not, by itself,
provide adequate control of fungi or nutsedges. The crop rotations
available to growers are also susceptible to fungi; fallow land can
still harbor fungal oospores. As regards nutsedges, tubers of these
perennial species provide new plants with larger energy reserves than
the annual weeds that can be frequently controlled by crop rotations and
fallow land.  Furthermore, nutsedge plants can produce tubers within 8
weeks after emergence. This enhances their survival across different
cropping regimes that can disrupt other plants that rely on a longer
undisturbed growing period to produce seeds to propagate the next
generation.	No

Endophytes	Though these organisms (fungi that grow symbiotically or as
parasites within plants) have been shown to suppress some plant
pathogens in cucumber, there is no such information for the other
cucurbit crops. Similarly, the U.S. found no evidence that endophytes
control nutsedges	No

Flooding/Water management	As with many of the other alternatives to
methyl bromide, flooding has been shown to control a number of weeds,
but not nutsedge species. Nutsedge is much more tolerant of watery
conditions than many other weed pests.  For example, Horowitz (1972)
showed that submerging nutsedge in flowing or stagnant water (for 8 days
and 4 weeks, respectively) did not affect the sprouting capacity of
tubers.  Another practical obstacle to implementing flood management
approaches in cucurbit production in the southern and southeastern U.S.
states is that the soil composition may not support flooding and still
remain productive.	No

Grafting/resistant rootstock/plant breeding/soilless culture/organic
production/substrates/plug plants.  	The U.S. was unable to locate any
studies showing any potential for grafting, resistant rootstock or plant
breeding as technically feasible alternatives to methyl bromide control
of nutsedges in cucurbits. While in theory plant breeding may improve
the ability of cucurbits to compete with these weeds for nutrients,
light, etc., it would certainly not provide alternatives within the time
span considered in this critical use exemption nomination. The effect on
the quality of the crops involved is unknown also. For resistant
rootstock at least, there are no studies documenting the commercial
availability of resistant rootstock immune to the fungal pathogens
listed as major cucurbit pests. Grafting and plant breeding are thus
also rendered technically infeasible as methyl bromide alternatives. The
U.S. found no evidence that soilless culture or substrates/plug plants
can be used to produce cucurbit crops on a large scale, or that they
will control nutsedges, which like soil fungi are particularly hardy. 
Various aspects of organic production – organic mulches, cover crops,
fallow land, steam sterilization have already been addressed in this
document and assessed to be technically infeasible methyl bromide
alternatives.	No

Combinations of Alternatives

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

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

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

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



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

Name of Alternative	Discussion

Halosulfuron-methyl	For nutsedges: potential crop injury; plant back
restrictions.  Efficacy is lowered in rainy conditions (common during
the period of initial planting of these crops).  Also, a 24-month plant
back restriction may cause significant economic disruption if growers
must rely on this control option.  Halosulfuron is only allowed on the
row middles for cucurbits, due to its phytotoxicity. This would result
in weeds surviving close to crop plants.  Thus this herbicide is not
technically feasible as a stand-alone replacement for MB, and its use in
conjunction with other pest management methods has not yet been
investigated.

Glyphosate	For nutsedges: Non-selective; will not control nutsedge in
the plant rows; does not provide residual control.  Thus this herbicide
is not technically feasible as a stand-alone replacement for MB, and its
use in conjunction with other pest management methods has not yet been
investigated.

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



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



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

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

Methyl iodide	For nutsedges: Not registered in the USA for cucurbits.
Registration is currently being pursued only for tomatoes, strawberries,
peppers, and ornamental crops	No (for cucurbits)	N/A

Pebulate	For nutsedges: Was registered for use in tomatoes only, but
even this registration lapsed December 31, 2002 (registrant corporation
went out of business)	No (for cucurbits)	N/A

S-metolachlor	For nutsedges: registered for crops other than cucurbits
No (for cucurbits)	N/A

Terbacil	For nutsedges: registered for crops other than cucurbits	No
(for cucurbits)	N/A

Rimsulfuron	For nutsedges: registered for crops other than cucurbits	No
(for cucurbits)	N/A

Trifloxysulfuron	For nutsedges: registered for crops other than
cucurbits	No (for cucurbits)	N/A

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



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



For a discussion of relative effectiveness of MB alternatives against
fungal pests, please see Section 16 for the Michigan region.  Though the
fungal pest cited by Georgia growers is in a different genus (Pythium),
the relative effectiveness of relevant MB alternatives is likely to be
similar to that where the other soil borne fungal pests are concerned. 
For a discussion of relative effectiveness of MB alternatives against
root knot nematodes and nutsedges, please see Section 16 for the
Southeastern U.S. region. 

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

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

1,3 D + chloropicrin	Nutsedges	10-40 %

(for areas included in this request)	29 % (Locascio et al., 1997)

Metam-sodium (with or without chloropicrin)	Nutsedges	10-66 %

(for areas included in this request)	44 % (Locascio et al., 1997)

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



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



For Georgia cucurbits, research focusing on the deployment of MB
alternatives for control of nutsedges and Phytophthora fungi is planned.
 Field trials will include treatments with methyl iodide in combination
with halosulfuron, 1,3 D in combination with chloropicrin and
halosulfuron, and a combination of metam-potassium, 1,3 D, and
halosulfuron.  The Georgia applicants provided no specific timeline for
development and deployment, but it is reasonable to expect that the 3-5
year timeframe cited by cucurbit growers in the other southeastern US
states will probably apply.  University of Georgia research and
extension staff will conduct trials, presumably in collaboration with
cooperating growers.

Future plans to minimize MB use also include:

(1) Using research and on-farm evaluations optimize a combination of
nutsedge control in fallow fields, crop rotation, and use of
post-emergent herbicides in crops.  Herbicides will include
halosulfuron, sulfentrazone, and glyphosate.

(2) Optimize the combined use of plastic (LDPE) tarps and drip
irrigation equipment for applying at-plant herbicides.

It is also reasonable to expect that growers in this region will adopt
measure shown in Michigan to be successful in minimizing MB use where
fungal pests are the only key pests involved.

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



No.  Areas where MB is not used in this region do not face moderate to
severe populations of the key pests.

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



As regards the key pests cited by the applicants from this region,
technically feasible alternatives appear to exist for root knot
nematodes, namely 1,3 D + chloropicrin and metam-sodium (by itself or
with chloropicrin). 1, 3 D + chloropicrin also shows efficacy against
the fungal pests in this region.  However, this MB alternative has
significant regulatory and technical limitations that are likely to
result in negative economic impacts (please see the summary of technical
feasibility for Michigan for a discussion of these limitations).  In
addition to the limitations faced by Michigan growers, farmers in
Georgia who farm on Karst geology are prohibited from even considering
this option due to regulatory restrictions intended to mitigate
groundwater contamination.  When 1,3 D cannot be used, growers in this
region will have no technically feasible control option where fungi are
the major pests.

For nutsedge pests, which are widespread in this region, cucurbit
growers do not currently have technically feasible alternatives to MB
use at planting.  Metam-sodium and 1,3 D + chloropicrin have shown some
efficacy in small-plot trials in other vegetable crops (e.g, tomato). 
However, at best, metam sodium may allow at least 44 % yield loss, while
1,3 D may allow at least 29 % loss.  Both often show less control than
MB (in terms of population suppression) of nutsedges.  These factors
suggest that even this alternative will not be economically feasible
even in the best-case technical scenario.  It should be noted that there
is evidence that both 1,3 D and methyl isothiocynate levels decline more
rapidly, thus further compromising efficacy, in areas where these are
repeatedly applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al.,
2003).  This is due to enhanced degradation of these chemicals by soil
microbes (Dungan and Yates, 2003). 

Other chemical alternatives to MB that have shown promise against
nutsedges (e.g., pebulate) are currently unregistered for cucurbits, and
are often not being developed for registration by any commercial entity.

In a new study, Culpepper and Langston (2004) conducted studies at 2
sites in spring 2003 and one site in Fall, 2004.  Plot sizes were 20
feet X 32 inches (4.94 m2).  Treatments were: Methyl bromide standard
(67:33 formulation), untreated control, 2 formulations of Telone (1,3 D
+ chloropicrin) at various doses, followed by an additional application
of either chloropicrin or metam-sodium, a third formulation of 1,3 D +
chloropicrin (“Inline”), and methyl iodide.  An additional set of
plots received the same fumigant treatments but also received an
herbicide treatment (clomazone + halosulfuron) later in the season. 

Watermelon – the only cucurbit crop addressed in these experiments –
showed no significant (final) yield differences across any fumigant
treatment.  The same lack of difference was observed when herbicides
were added.  In fact, there was no difference in yield even when
pesticide treatments were compared to the untreated control.  However,
nutsedge populations in the study appeared to be relatively low (e.g.,
667 plants per plot or 135/m2, in the untreated control, at the end of
the study).

Furthermore, a number of important caveats must be mentioned when
considering these results:

Plots used were quite small, and it is not at all clear if the promising
results will hold reliably in larger commercial fields.  This is
particularly worrisome given the highly variable results reported by
other researchers for the same MB alternatives.

The nutsedge populations in this study were dominated by yellow nutsedge
(90 % of the total number).  It is not clear if populations where purple
nutsedge is dominant will be controlled as effectively.  A number of
other studies have indicated that purple nutsedge is a hardier species,
and even in Culpepper and Langston’s study, it appeared more resistant
to the MB alternatives.  For example, methyl iodide gave “77 %
control” of yellow nutsedge, but only “37 % control” of purple
nutsedge.  Control in this case was apparently defined as the reduction
in nutsedge populations as compared to populations in the untreated
control. 

This study was done only with watermelons, and it is not clear if other
cucurbits will respond so favorably in terms of yield, or lack of
phytotoxic response.  Also, a custom-built applicator had to be used for
the metam-sodium applications to eliminate worker exposure risks,
according to the authors.  It is not yet clear if such an applicator can
be mass-produced and/or used reliably in a commercial setting.

The other key pest cited for cucurbits in this region, Pythium rot, was
not examined in this study.  Thus these results do not shed additional
light on whether alternative soil fumigants could be used against that
pest.

Large-scale, on-farm demonstrations of optimal application methodology
in a commercial setting are lacking for cucurbit crops, adding to the
current lack of viability of MB alternatives in this crop system.  While
a combination of alternatives may replace MB in future cucurbit
production in this region, it remains some years away from technical
feasibility.

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



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



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

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

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

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

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



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



Reduced methyl bromide concentrations in mixtures, cultural practices,
and the extensive use of tarpaulins to cover land treated with MB has
resulted in reduced emissions. 

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



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

The following economic assessment is organized by MB critical use
application. Individual crops within each application are examined first
and are followed by aggregate measures for each application.  Cost of MB
and alternatives are given in table 21.1.  Table 22.1 lists net and
gross revenues.  Expected losses when using MB r alternatives are
further decomposed in tables E1 through E13.

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

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



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

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

Cucumber

Methyl Bromide	100%	$3,477	$3,477	$3,477

1,3-D + Chloropicrin	94%	$3,537	$3,537	$3,537

Melon

Methyl Bromide	100%	$1,342	$1,342	$1,342

1,3-D + Chloropicrin	94%	$1,354	$1,354	$1,354

Winter Squash

Methyl Bromide	100%	$3,477	$3,477	$3,477

1,3-D + Chloropicrin	94%	$3,537	$3,537	$3,537

Zucchini

Methyl Bromide	100%	$1,342	$1,342	$1,342

1,3-D + Chloropicrin	94%	$1,354	$1,354	$1,354

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

Table 21.2 : Southeastern U.S. (Except Georgia) Cucurbits - Costs of
Alternatives Compared to Methyl Bromide Over 3-Year Period  TC "Table
21.2: Southeastern U.S. (except Georgia) Cucurbits - Costs of
Alternatives Compared to Methyl Bromide Over 3-Year Period" \f F \l "1" 


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

Cucumber

Methyl Bromide	100%	$2,214	$2,214	$2,214

1,3-D + Chloropicrin	71%	$2,585	$2,585	$2,585

Metam-sodium	54%	$2,585	$2,585	$2,585

Melons

Methyl Bromide	100%	$2,214	$2,214	$2,214

1,3-D + Chloropicrin	71%	$2,585	$2,585	$2,585

Metam-sodium	54%	$2,585	$2,585	$2,585

Squash

Methyl Bromide	100%	$2,214	$2,214	$2,214

1,3-D + Chloropicrin	71%	$2,585	$2,585	$2,585

Metam-sodium	54%	$2,585	$2,585	$2,585

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

Table 21.3 : Georgia Cucurbits - Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period  TC "Table 21.3: Georgia Cucurbits -
Costs of Alternatives Compared to Methyl Bromide Over 3-Year Period" \f
F \l "1"  

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

Cucumber

Methyl Bromide	100%	$3,642	$3,642	$3,642

1,3-D + Chloropicrin	71%	$3,242	$3,242	$3,242

Metam-sodium	54%	$3,027	$3,027	$3,027

Melon

Methyl Bromide	100%	$3,642	$3,642	$3,642

1,3-D + Chloropicrin	71%	$3,242	$3,242	$3,242

Metam-sodium	54%	$3,027	$3,027	$3,027

Squash

Methyl Bromide	100%	$3,642	$3,642	$3,642

1,3-D + Chloropicrin	71%	$3,242	$3,242	$3,242

Metam-sodium	54%	$3,027	$3,027	$3,027

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

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



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

Year 1, 2, and 3

Alternatives 

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

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

(US$/ha)

Cucumber

Methyl Bromide	$25,656	$7,807

1,3-D + Chloropicrin	$22,911	$5,728

Melon



Methyl Bromide	$14,069	$5,848

1,3-D + Chloropicrin	$12,563	$4,431

Winter Squash

Methyl Bromide	$13,282	$1,427

1,3-D + Chloropicrin	$11,860	$(210)

Zucchini

Methyl Bromide	$13,484	$(3,038)

1,3-D + Chloropicrin	$12,041	$(3,423)

All Michigan Cucurbits

Methyl Bromide	$19,149	$17,100

1,3-D + Chloropicrin	$17,100	$1,825

Note: Year 1 equals year 2 and 3.

Table 22.2: Southeastern U.S. (Except Georgia) Cucurbits – Year 1, 2,
and 3 Gross and Net Revenues   TC "Table 22.2: Southeastern U.S. (except
Georgia) Cucurbits - Year 1, 2, and 3 Gross and Net Revenues" \f F \l
"1"  

Year 1, 2, and 3

Alternatives 

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

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

(US$/ha)

Cucumber

Methyl Bromide	$11,589	$1,468

1,3-D + Chloropicrin	$8,228	$1,581

Metam-sodium	$(6,490)	$(2,848)

Melon

Methyl Bromide	$12,775	$3,608

1,3-D + Chloropicrin	$9,070	$(5)

Metam-sodium	$7,154	$(1,640)

Squash

Methyl Bromide	$7,628	$1,777

1,3-D + Chloropicrin	$5,416	$(755)

Metam-sodium	$4,272	$(1,754)

All Southeastern USA Cucurbits

Methyl Bromide	$12,315	$4,131

1,3-D + Chloropicrin	$8,744	$1,249

Metam-sodium	$6,896	$23

Note: Year 1 equals year 2 and 3.

Table 22.3: Georgia Cucurbits – Year 1, 2, and 3 Gross and Net
Revenues   TC "Table 22.3: Georgia Cucurbits- Year 1, 2, and 3 Gross and
Net Revenues" \f F \l "1"  

Year 1, 2, and 3

Alternatives 

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

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

(US$/ha)

Cucumber

Methyl Bromide	$34,491	$6,565

1,3-D + Chloropicrin	$24,488	$(103)

Metam-sodium	$19,315	$(2,992)

Melon

Methyl Bromide	$27,915	$9,201

1,3-D + Chloropicrin	$19,820	$3,560

Metam-sodium	$15,633	$668

Squash

Methyl Bromide	$32,603	$11,522

1,3-D + Chloropicrin	$23,148	$5,440

Metam-sodium	$18,258	$2,251

All Georgia Cucurbits

Methyl Bromide	$34,621	$13,840

1,3-D + Chloropicrin	$24,581	$6,610

Metam-sodium	$19,388	$2,969

Note: Year 1 equals year 2 and 3.

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



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

Michigan Cucumber	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	2,018	1,897

* Price per Unit (us$)	$12	$12

= Gross Revenue per Hectare (us$)	$25,655	$22,910

- Operating Costs per Hectare (us$)	$17,848	$17,182

= Net Revenue per Hectare (us$)	$7,807	$5,728

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$2,079

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$17

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

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

5. Operating Profit Margin (%)	30%	25%



Michigan Melon - Table E.2: Economic Impacts of Methyl Bromide
Alternatives  TC "Michigan Melon - Table E.2: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"  

Michigan melon	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	145	136

* Price per Unit (us$)	$97	$92

= Gross Revenue per Hectare (us$)	$14,069	$12,563

- Operating Costs per Hectare (us$)	$8,220	$8,132

= Net Revenue per Hectare (us$)	$5,848	$4,431

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$1,417

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$12

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

4. Loss as a Percentage of Net Revenue (%)	0%	24%

5. Operating Profit Margin (%)	42%	35%



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

Michigan Winter squash	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	1,063	999

* Price per Unit (us$)	$13	$12

= Gross Revenue per Hectare (us$)	$13,282	$11,861

- Operating Costs per Hectare (us$)	$11,855	$12,071

= Net Revenue per Hectare (us$)	$1,427	$(210)

Five Loss Measures *

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

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$14

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

4. Loss as a Percentage of Net Revenue (%)	0%	115%

5. Operating Profit Margin (%)	11%	-2%



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

Michigan Zucchini	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	2,368	2,226

* Price per Unit (us$)	$6	$5

= Gross Revenue per Hectare (us$)	$13,484	$12,041

- Operating Costs per Hectare (us$)	$16,522	$15,464

= Net Revenue per Hectare (us$)	$(3,038)	$(3,423)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$385

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$3

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

4. Loss as a Percentage of Net Revenue (%)	0%	-13%

5. Operating Profit Margin (%)	-23%	-28%



All Michigan Cucurbits - Table E.5: Economic Impacts of Methyl Bromide
Alternatives  TC "All Michigan Cucurbits - Table E.5: Economic Impacts
of Methyl Bromide Alternatives" \f F \l "1"  

All Michigan cucurbits	Methyl Bromide	1,3-D + Chloropicrin

Yield Loss (%) 	0%	6%

   Yield per Hectare 	1,708	1,606

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

= Gross Revenue per Hectare (us$)	$19,149	$17,100

- Operating Costs per Hectare (us$)	$15,091	$15,275

= Net Revenue per Hectare (us$)	$4,058	$1,825

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$2,232

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$18

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

4. Loss as a Percentage of Net Revenue (%)	0%	55%

5. Operating Profit Margin (%)	21%	11%



Southeastern U.S. (except Georgia) Cucumber - Table E.6: Economic
Impacts of Methyl Bromide Alternatives  TC "Southeastern U.S. (except
Georgia) Cucumber - Table E.6: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

Southeast U.S. (except Georgia) cucumber	Methyl Bromide	1,3-D +
Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	828	588	464

* Price per Unit (us$)	$14	$14	$14

= Gross Revenue per Hectare (us$)	$11,589	$8,228	$6,490

- Operating Costs per Hectare (us$)	$10,121	$9,809	$9,338

= Net Revenue per Hectare (us$)	$1,468	$(1,581)	$(2,848)

Five Loss Measures 

1. Loss per Hectare (us$)	$0	$3,049	$4,316

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$20	$29

3. Loss as a Percentage of Gross Revenue (%)	0%	26%	37%

4. Loss as a Percentage of Net Revenue (%)	0%	208%	294%

5. Operating Profit Margin (%)	13%	-19%	-44%



Southeastern U.S. (except Georgia) Melon - Table E.7: Economic Impacts
of Methyl Bromide Alternatives  TC "Southeastern U.S. (except Georgia)
Melon - Table E.7: Economic Impacts of Methyl Bromide Alternatives" \f F
\l "1"  

Southeast U.S. (except Georgia) Melon	Methyl Bromide	1,3-D +
Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	815	579	457

* Price per Unit (us$)	$16	$16	$16

= Gross Revenue per Hectare (us$)	$12,775	$9,070	$7,154

- Operating Costs per Hectare (us$)	$9,168	$9,076	$8,795

= Net Revenue per Hectare (us$)	$3,608	$(5)	$(1,640)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$3,613	$5,248

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$24	$35

3. Loss as a Percentage of Gross Revenue (%)	0%	28%	41%

4. Loss as a Percentage of Net Revenue (%)	0%	100%	145%

5. Operating Profit Margin (%)	28%	0%	-23%



Southeastern U.S. (except Georgia) Squash - Table E.8: Economic Impacts
of Methyl Bromide Alternatives  TC "Southeastern U.S. (except Georgia)
Squash - Table E.8: Economic Impacts of Methyl Bromide Alternatives" \f
F \l "1"  

Southeast U.S. (except Georgia) Squash	Methyl Bromide	1,3-D +
Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	311	221	174

* Price per Unit (us$)	$25	$25	$25

= Gross Revenue per Hectare (us$)	$7,628	$5,416	$4,272

- Operating Costs per Hectare (us$)	$5,851	$6,171	$6,025

= Net Revenue per Hectare (us$)	$1,777	$(755)	$(1,754)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$2,532	$3,531

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$17	$24

3. Loss as a Percentage of Gross Revenue (%)	0%	33%	46%

4. Loss as a Percentage of Net Revenue (%)	0%	142%	199%

5. Operating Profit Margin (%)	23%	-14%	-41%



All Southeastern U.S. (except Georgia) Cucurbits - Table E.9: Economic
Impacts of Methyl Bromide Alternatives  TC "Southeastern U.S. (except
Georgia) Cucurbits - Table E.9: Economic Impacts of Methyl Bromide
Alternatives" \f F \l "1"  

All Southeast U.S. (except Georgia) Cucurbits	Methyl Bromide	1,3-D +
Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	749	532	420

* Price per Unit (us$)	$16	$16	$16

= Gross Revenue per Hectare (us$)	$12,315	$8,744	$6,896

- Operating Costs per Hectare (us$)	$8,184	$7,495	$6,874

= Net Revenue per Hectare (us$)	$4,131	$1,249	$23

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$2,883	$4,108

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$19	$27

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

4. Loss as a Percentage of Net Revenue (%)	0%	70%	99%

5. Operating Profit Margin (%)	34%	14%	0%



Georgia Cucumber - Table E.10: Economic Impacts of Methyl Bromide
Alternatives  TC “Georgia Cucumber – Table E.10: Economic Impacts of
Methyl Bromide Alternatives” \f F \l “1”  

Georgia Cucumber	Methyl Bromide	1,3-D + Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	4,122	2,926	2,308

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

= Gross Revenue per Hectare (us$)	$34,491	$24,488	$19,315

- Operating Costs per Hectare (us$)	$27,926	$24,592	$22,307

= Net Revenue per Hectare (us$)	$6,565	$(103)	$(2,992)

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$6,668	$9,557

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$44	$64

3. Loss as a Percentage of Gross Revenue (%)	0%	19%	28%

4. Loss as a Percentage of Net Revenue (%)	0%	102%	146%

5. Operating Profit Margin (%)	19%	0%	-15%



Georgia Melon  - Table E.11: Economic Impacts of Methyl Bromide
Alternatives  TC "Georgia Melon - Table E.11: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"  

Georgia Melon	Methyl Bromide	1,3-D + Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	2,975	2,112	1,666

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

= Gross Revenue per Hectare (us$)	$27,915	$19,820	$15,633

- Operating Costs per Hectare (us$)	$18,714	$16,260	$14,965

= Net Revenue per Hectare (us$)	$9,201	$3,560	$668

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$5,641	$8,533

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$38	$57

3. Loss as a Percentage of Gross Revenue (%)	0%	20%	31%

4. Loss as a Percentage of Net Revenue (%)	0%	61%	93%

5. Operating Profit Margin (%)	33%	18%	4%



Georgia Squash - Table E.12: Economic Impacts of Methyl Bromide
Alternatives  TC "Georgia Squash - Table E.12: Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"  

Georgia Squash	Methyl Bromide	1,3-D + Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	4,448	3,158	2,491

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

= Gross Revenue per Hectare (us$)	$32,603	$23,148	$18,258

- Operating Costs per Hectare (us$)	$21,081	$17,708	$16,007

= Net Revenue per Hectare (us$)	$11,522	$5,440	$2,251

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$6,082	$9,271

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$41	$62

3. Loss as a Percentage of Gross Revenue (%)	0%	19%	28%

4. Loss as a Percentage of Net Revenue (%)	0%	53%	80%

5. Operating Profit Margin (%)	35%	24%	12%



All Georgia Cucurbits - Table E.13: Economic Impacts of Methyl Bromide
Alternatives  TC "Georgia Cucurbits - Table E.13: Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"  

All Georgia Cucurbits	Methyl Bromide	1,3-D + Chloropicrin	Metam-sodium

Yield Loss (%) 	0%	29%	44%

   Yield per Hectare 	3,502	2,486	1,961

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

= Gross Revenue per Hectare (us$)	$34,621	$24,581	$19,388

- Operating Costs per Hectare (us$)	$20,781	$17,971	$16,419

= Net Revenue per Hectare (us$)	$13,840	$6,610	$2,968

Five Loss Measures *

1. Loss per Hectare (us$)	$0	$7,230	$10,871

2. Loss per Kilogram of Methyl Bromide (us$)	$0	$48	$72

3. Loss as a Percentage of Gross Revenue (%)	0%	21%	31%

4. Loss as a Percentage of Net Revenue (%)	0%	52%	79%

5. Operating Profit Margin (%)	40%	27%	15%



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

There are currently few alternatives to methyl bromide for use in
cucurbits.  Furthermore, there are several factors that limit possible
alternatives’ usability and efficacy from place to place.  These
include pest complex, climate, and regulatory restrictions.  The two
most promising alternatives to methyl bromide in Georgia and the
Southeastern USA for control of nut-sedge in cucurbits (1,3-D +
chloropicrin and metam-sodium) are considered not technically feasible.
This derives from regulatory restrictions and the magnitude of resulting
expected yield losses.  Economic data representing Georgia and
Southeastern USA cucurbit growing conditions are thus included in the
economic assessment as a supplement to the biological review to
illustrate the impacts of using MeBr alternatives, not to gauge them
with respect to economic feasibility.  In Michigan 1,3-D + chloropicrin
is considered technically feasible.

Michigan

The US concludes that, at present, no economically feasible alternatives
to MeBr exist for use in Michigan cucurbit production.  The US has
arrived at this conclusion by examining the individual crops within the
Michigan cucurbit sector and then examining the sector as a whole. Yield
loss and missed market windows, which are discussed individually below,
have proven most important in reaching this conclusion.

1. Yield Loss

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

2. Missed Market Windows

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

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

To describe economic conditions in Michigan, EPA used weekly and monthly
cucurbit sales and production data from the U.S. Department of
Agriculture for the previous three years to gauge the impact of early
season price fluctuations on gross revenues.  Though data availability
was limiting, analysts assumed that if cucurbit growers adjust the
timing of their production system, as required when using 1,3-D +
Chloropicrin, gross revenues will decline by approximately 5% over the
course of the growing season, due solely to price effects.  The season
average price was reduced by 5% in the analysis of the alternatives to
reflect this effect.  Based on currently available information, the U.S.
believes this reduction in price serves as a reasonable indicator of the
typical effect of planting delays resulting when MB alternatives are
used in Michigan.

Southeastern U.S. (Except Georgia)

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

The applicant provided no data on the operating costs of alternatives. 
Analysts assumed, however, that these costs were similar to those of
methyl bromide with slight upward adjustments for the costs of applying
the alternatives and a slight downward adjustment for the cost of the
alternative product.  In addition, the applicant did not provide data
for second crops (including revenues and operating costs).  Analysts
assumed that Southeastern cucurbits are grown in a single crop
production system.  However, if double cropping is practiced in the
actual production system, this assumption could make the critical need
for MB appear smaller than it actually is, because the value the second
crop derives from methyl bromide is not included in the analysis

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

Georgia

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

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

Economic analysis of Georgia growing conditions included cost and
production data representing a second cucurbits or peppers crop.

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"   

Consortia will develop timelines describing the transition from MB.  In
addition, ongoing research is examining alternative technologies to
develop protocols for maximizing the efficacy of alternatives.

24. How Do You Plan to Minimize the Use of Methyl Bromide for the
Critical Use in the Future?  TC "24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?" \f C \l "2"   



Consortia will develop timelines describing the transition from MB.  In
addition, ongoing research is examining alternative technologies to
develop protocols for maximizing the efficacy of alternatives. 

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

The MB critical use exemption nomination for cucurbits 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 only for those fields where sufficient pest control can
not be achieved otherwise.  The loss of MB 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"  



Allen, L.H., S.J. Locascio, D.W. Dickson, D.J. Mitchell, and S.D.
Nelson. 1999. Flooding (soil anoxia) for control of pests of vegetables.
Research Summary, USDA Specific Cooperative Agreement 58-6617-6-013.

Ashley, M.G., B.L. Leigh, and L.S. Lloyd. 1963. The action of
metham-sodium in soil II. Factors affecting removal of methyl
isothiocyanate residues. J. Sci. Food Agric. 14: 153-161.

Burgos, N. R. and R. E. Talbert. 1996. Weed control and sweet corn (Zea
mays var. rugosa) response in a no-till system with cover crops. Weed
Sci. 44 (2): 355 – 361.

Chase, C.A., T.R. Sinclair, D.G. Shilling, J.P. Gilreath, and S.J.
Locascio. 1998. Light effects on rhizome morphogenesis in nutsedges
(Cyperus spp): Implications for control by soil solarization. Weed Sci.
46:575-580.

Culpepper, S. and D. Langston 2001. Fumigant/herbicide combinations in
tomato. Unpublished study conducted by researchers at the University of
Georgia, Athens, GA. Included in CUE package 03-0042.

Culpepper, S. and D. Langston. 2004. Fumigant/herbicide combinations.
Unpublished study conducted by researchers at the University of Georgia,
Athens, GA. Included in CUE package 2004.

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

Dowler, C. C. 1999. Herbicide activity of metham, methyl iodide, and
methyl bromide applied through irrigation systems. Proc. Southern Weed
Sci. Soc. 52: 77 – 78.

Dungan, R.S. and S.R. Yates. 2003. Degradation of fumigant Pesticides.
1,3-Dichloropropene, methyl isothiocyanate, and methyl bromide. Vodose
Zone Jour. 2: 279-286.

Eger, J. E. 2000. Efficacy of Telone products in Florida crops: a seven
year summary. Proc. Annual Int. Res. Conf. on Methyl Bromide
Alternatives and Emissions Reductions. Available on the web at  
HYPERLINK "http://www.mbao.org/mbrpro00.html" 
http://www.mbao.org/mbrpro00.html .

Galloway, B. A. and L. A. Weston. 1996. Influence of cover crop and
herbicide treatment on weed control and yield in no-till sweet corn (Zea
mays L.) and pumpkin (Cucurbita maxima Duch.). Weed Technol. 10 (2): 341
– 346.

Gamliel, A., S. Triki, M. Austerweil, P. DiPrimo, I. Peretz-Alon, O.
Heiman, M. Beniches, B. Steiner, and J. Katan. 2003. Aceelerated
degradation of metam sodium in the field and its management. Proc.
Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions
Reductions. Available on the web at http://www.mbao.org/mbrpro03.html.

Gevens, A., and M. K. Hausbeck. 2003. Phytophthora capsici in irrigation
water and isolation of P. capsici from snap beans in Michigan. Michigan
State Univ. Vegetable Crop Advisory Team Alert Vol. 18 (19). Available
on the Web at www.ipm.msu.edu/CAT03_veg/V09-24-03.htm.

Gilreath, J., J. P. Jones, and A. J. Overman. 1994. Soil-borne pest
control in mulched tomato with alternatives to methyl bromide. Proc.
Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions
Reductions. Available on the web at http://www.mbao.org/mbrpro94.html.

Hausbeck, M. K. and B. D. Cortwright. 2003. Evaluation of fumigants for
managing Phytophthora crown and fruit rot of solanaceous and cucurbit
crops, plot two, 2003. Unpublished study supplied with CUE package
03-0005.	

Horowitz, M. 1972. Effects of desiccation and submergence on the
viability of rhizome fragments of bermudagrass, johnsongrass, and tubers
of nutsedge.  Israel J. Agric. Res. 22(4):215-220.

Kadir, J. B., R. Charudattan, W. M. Stall, and B. J. Brecke. 2000. Field
efficacy of Dactylaria higginsii as a bioherbicide for the control of
purple nutsedge (Cyperus rotundus). Weed Technol. 14 (1): 1 – 6.

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

Larkin, R. P., and Fravel, D. R. 1998.   Efficacy of various fungal and
bacterial biocontrol organisms for control of Fusarium wilt of tomato.
Plant Dis. 82:1022 -1028.

Locascio. S. J., and D. W. Dickson. 1998. Metam sodium combined with
chloropicrin as an alternative to methyl bromide. Proc. Annual Int. Res.
Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available
on the web at   HYPERLINK "http://www.mbao.org/mbrpro98.html" 
http://www.mbao.org/mbrpro98.html .

Locascio, S.J., J.P. Gilreath, D.W. Dickson, T.A. Kucharek, J.P. Jones,
and J.W. Noling. 1997. Fumigant alternatives to methyl bromide for
polyethylene mulched tomato. HortSci. 32: 1208-1211. 

Martin, F. N. 2003. Development of alternative strategies for management
of soilborne pathogens currently controlled with methyl bromide. Ann.
Rev. Phytopathol. 41: 325 - 350. 

MBTOC (1994): 1994 Report of the Methyl Bromide Technical Options
Committee for the 1995 Assessment of the UNEP Montreal Protocol on
Substances that Deplete the Ozone Layer. Nairobi

Munn. D.A. 1992. “Comparison of shredded newspaper and wheat straw as
crop mulches.” Hort technol. 2: 361 - 366.

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

Ou, L.-T., K.Y.Chung, J.E. Thomas, T.A. Obreza, and D.W. Dickson.1995.
Degradation of 1,3-dichloropropene (1,3-D) in soils with different
histories of field applications of 1,3-D. J. Nematol. 25: 249–257.

Phatak, S. C., D. R. Sumner, H. D. Wells, D. K. Bell, and N. C. Glaze.
1983. Biological control of yellow nutsedge, Cyperus esculentus, with
the indigenous rust fungus Puccinia canaliculata. Science. 219: 1446 –
1448.

Patterson, D.T. 1998.  Suppression of purple nutsedge (Cyperus rotundus)
with polyethylene film mulch. Weed Technology, 12:275-280.

Schneider S. M., E.N. Rosskopf, J.G. Leesch, D.O. Chellemi, C. T. Bull,
and M. Mazzola. 2003. United States Department of Agriculture –
Agricultural Research Service research on alternatives to methyl
bromide: pre-plant and post-harvest. Pest Manag Sci. 59: 814-826.

Thullen, R.J. and P.E. Keeley. 1975. Yellow nutsedge sprouting and
resprouting potential. Weed Sci. 23:333-337.

Smelt, J.H., S.J.H. Crum, and W. Teinissen. 1989. Accelerated
transformation of the fumigant methyl isocyanate in soil after repeated
application of metam sodium. J. Environ. Sci. Health B24: 437-455.

UNEP (United Nations Environment Programme). 1998. Methyl Bromide
Technical Options Committee (MBTOC) 1998 assessment of alternatives to
methyl bromide. p.49.

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

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

Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner,
and R. L. Fery. 2001. Methyl bromide alternatives in a bell pepper –
squash rotation. Crop Prot. 20 (7): 605 – 614.

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

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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U.S. Cucurbits

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U.S. Cucurbits

