Methyl Bromide Critical Use Nomination for Preplant Soil Use for 

Turfgrass Sod Farms

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 Turfgrass Sod Farms (Submitted in
2006 for 2008 Use Season)



Nominating Party Contact Details

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

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U.S.A.

Telephone:	(202) 647-9799

Fax:	(202) 647-5947

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



	

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

                

( Yes                                  ( No











Signature

Name

Date

Title:







Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwinr

Title:	Acting Division Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U.S.A.

Telephone:	(703) 308-8200

Fax:	(703) 308-8090

E-mail:	  HYPERLINK "mailto:keigwinr.richard@epa.gov" 
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 "_Toc125799914"  Part A: Summary	 
PAGEREF _Toc125799914 \h  6  

  HYPERLINK \l "_Toc125799915"  1. Nominating Party	  PAGEREF
_Toc125799915 \h  6  

  HYPERLINK \l "_Toc125799916"  2. Descriptive Title of Nomination	 
PAGEREF _Toc125799916 \h  6  

  HYPERLINK \l "_Toc125799917"  3. Crop and Summary of Crop System	 
PAGEREF _Toc125799917 \h  6  

  HYPERLINK \l "_Toc125799918"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125799918 \h  6  

  HYPERLINK \l "_Toc125799919"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125799919 \h  6  

  HYPERLINK \l "_Toc125799920"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125799920 \h  7  

  HYPERLINK \l "_Toc125799921"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125799921 \h  7  

  HYPERLINK \l "_Toc125799922"  7. (ii) If only part of the crop area is
treated with methyl bromide, indicate the reason why methyl bromide is
not used in the other area, and identify what alternative strategies are
used to control the target pathogens and weeds without methyl bromide
there.	  PAGEREF _Toc125799922 \h  7  

  HYPERLINK \l "_Toc125799923"  7. (iii) Would it be feasible to expand
the use of these methods to cover at least part of the crop that has
requested use of methyl bromide?  What changes would be necessary to
enable this?	  PAGEREF _Toc125799923 \h  8  

  HYPERLINK \l "_Toc125799924"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125799924 \h  8  

  HYPERLINK \l "_Toc125799925"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated	  PAGEREF _Toc125799925 \h 
8  

  HYPERLINK \l "_Toc125799926"  Part B: Crop Characteristics and Methyl
BRomide USe	  PAGEREF _Toc125799926 \h  9  

  HYPERLINK \l "_Toc125799927"  10. Sod—Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request	
 PAGEREF _Toc125799927 \h  9  

  HYPERLINK \l "_Toc125799928"  11. Sod—Characteristics of Cropping
System and Climate	  PAGEREF _Toc125799928 \h  9  

  HYPERLINK \l "_Toc125799929"  11. (ii) Sod—Indicate if any of the
above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125799929 \h  10  

  HYPERLINK \l "_Toc125799930"  12. Sod—Historic Pattern of Use of
Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125799930 \h  10  

  HYPERLINK \l "_Toc125799931"  Part C: Sod—Technical Validation	 
PAGEREF _Toc125799931 \h  10  

  HYPERLINK \l "_Toc125799932"  13. Sod—Reason for Alternatives Not
Being Feasible	  PAGEREF _Toc125799932 \h  10  

  HYPERLINK \l "_Toc125799933"  14. Sod—List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125799933 \h  11  

  HYPERLINK \l "_Toc125799934"  15. Sod—List Present (and Possible
Future) Registration Status of Any Current and Potential Alternatives	 
PAGEREF _Toc125799934 \h  11  

  HYPERLINK \l "_Toc125799935"  16. Sod—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
_Toc125799935 \h  12  

  HYPERLINK \l "_Toc125799936"  17. Are There Any Other Potential
Alternatives Under Development which Are Being Considered to Replace
Methyl Bromide?	  PAGEREF _Toc125799936 \h  14  

  HYPERLINK \l "_Toc125799937"  18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide	  PAGEREF
_Toc125799937 \h  14  

  HYPERLINK \l "_Toc125799938"  Summary of Technical Feasibility	 
PAGEREF _Toc125799938 \h  14  

  HYPERLINK \l "_Toc125799939"  Part D: Emission Control	  PAGEREF
_Toc125799939 \h  15  

  HYPERLINK \l "_Toc125799940"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use	
 PAGEREF _Toc125799940 \h  15  

  HYPERLINK \l "_Toc125799941"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125799941 \h  15  

  HYPERLINK \l "_Toc125799942"  Part E: Economic Assessment	  PAGEREF
_Toc125799942 \h  16  

  HYPERLINK \l "_Toc125799943"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125799943 \h  16  

  HYPERLINK \l "_Toc125799944"  22. Gross and Net Revenue	  PAGEREF
_Toc125799944 \h  16  

  HYPERLINK \l "_Toc125799945"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125799945 \h  17  

  HYPERLINK \l "_Toc125799946"  Summary of Economic Feasibility	 
PAGEREF _Toc125799946 \h  17  

  HYPERLINK \l "_Toc125799947"  Part F. Future Plans	  PAGEREF
_Toc125799947 \h  18  

  HYPERLINK \l "_Toc125799948"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125799948 \h  18  

  HYPERLINK \l "_Toc125799949"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125799949 \h  18  

  HYPERLINK \l "_Toc125799950"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125799950 \h  18  

  HYPERLINK \l "_Toc125799951"  26. Citations	  PAGEREF _Toc125799951 \h
 19  

 

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125799952"  Part A:
Summary	  PAGEREF _Toc125799952 \h  6  

  HYPERLINK \l "_Toc125799953"  Table 4.1: Methyl Bromide Nominated	 
PAGEREF _Toc125799953 \h  6  

  HYPERLINK \l "_Toc125799954"  Table A.1: Executive Summary	  PAGEREF
_Toc125799954 \h  7  

  HYPERLINK \l "_Toc125799955"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125799955 \h  7  

  HYPERLINK \l "_Toc125799956"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125799956 \h  8  

  HYPERLINK \l "_Toc125799957"  Part B: Crop Characteristics and Methyl
Bromide Use	  PAGEREF _Toc125799957 \h  9  

  HYPERLINK \l "_Toc125799958"  Table 10.1: Sod—Key Diseases and Weeds
and Reason for Methyl Bromide Request	  PAGEREF _Toc125799958 \h  9  

  HYPERLINK \l "_Toc125799959"  Table 11.1: Sod—Characteristics of
Cropping System	  PAGEREF _Toc125799959 \h  9  

  HYPERLINK \l "_Toc125799960"  Table 11.2 Sod—Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125799960 \h  10  

  HYPERLINK \l "_Toc125799961"  Table 12.1: Sod—Historic Pattern of
Use of Methyl Bromide	  PAGEREF _Toc125799961 \h  10  

  HYPERLINK \l "_Toc125799962"  Part C: Sod—Technical Validation	 
PAGEREF _Toc125799962 \h  10  

  HYPERLINK \l "_Toc125799963"  Table 13.1: Sod—Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125799963 \h  11  

  HYPERLINK \l "_Toc125799964"  Table 14.1: Sod—Technically Infeasible
Alternatives Discussion	  PAGEREF _Toc125799964 \h  11  

  HYPERLINK \l "_Toc125799965"  Table 15.1: Sod—Present Registration
Status of Alternatives	  PAGEREF _Toc125799965 \h  11  

  HYPERLINK \l "_Toc125799966"  Table 16.1: Sod—Effectiveness of
Alternatives – Nutsedge (Cyperus spp.) in Florida	  PAGEREF
_Toc125799966 \h  12  

  HYPERLINK \l "_Toc125799967"  Table 16.2: Sod—Effectiveness of
Alternatives – Weedy Grasses in Florida	  PAGEREF _Toc125799967 \h  13
 

  HYPERLINK \l "_Toc125799968"  Table C.1: Sod—Alternatives Yield Loss
Data Summary	  PAGEREF _Toc125799968 \h  13  

  HYPERLINK \l "_Toc125799969"  Part D: Emission Control	  PAGEREF
_Toc125799969 \h  15  

  HYPERLINK \l "_Toc125799970"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125799970 \h  15  

  HYPERLINK \l "_Toc125799971"  Part E: Economic Assessment	  PAGEREF
_Toc125799971 \h  16  

  HYPERLINK \l "_Toc125799972"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125799972 \h
 16  

  HYPERLINK \l "_Toc125799973"  Table 22.1: Year 1 Gross and Net Revenue
  PAGEREF _Toc125799973 \h  16  

  HYPERLINK \l "_Toc125799974"  Table 22.2: Year 2 Gross and Net Revenue
  PAGEREF _Toc125799974 \h  16  

  HYPERLINK \l "_Toc125799975"  Table 22.3: Year 3 Gross and Net Revenue
  PAGEREF _Toc125799975 \h  16  

  HYPERLINK \l "_Toc125799976"  Table E.1: Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125799976 \h  17  

  HYPERLINK \l "_Toc125799977"  Part F. Future Plans	  PAGEREF
_Toc125799977 \h  18  

  HYPERLINK \l "_Toc125799978"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125799978 \h  20  

 

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
Turfgrass Sod Farms (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"   



The Turfgrass Producers International has requested methyl bromide (MB)
as a critical use.  

This nomination includes use of MB in the production of turfgrass sod,
grown primarily in California, Florida, Georgia, Alabama, and Texas. 
There are at least 1,143 turfgrass sod producers across the U.S. who
farm approximately 132,000 hectares, with a wholesale product value of
U.S. $670 million.  On average, fumigation of the affected soil occurs
once every three years.  Sod fields have been flat fumigated with MB
when first establishing new sod fields and as a pre-plant fumigation
when pest pressures become so severe that effective pest management with
alternatives is particularly difficult.  Turfgrass yields average
between 6,400 and 8,700 square meters per hectare per cutting.  From
planting to harvest, a sod crop takes between 9-12 months to reach
maturity.

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

	52,189	168

	*Includes research amount of 1,928 kg.

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 effective against key pests when pressure is moderate to high.  The
use of MB is also considered critical only where alternatives are not
suitable because of regulatory, economic, or technical constraints. 
Although alternative treatments can be foreseen as long-term solutions
to MB use, transition from MB will depend on the development of
application technologies to better deliver these alternatives to soils
containing target pests.  Alternative treatments may require more
frequent applications and increase costs and environmental pesticide
burden.  Research is ongoing to develop protocols for likely
alternatives.  

A small percentage of total hectares for sod farms currently use MB. 
The use is primarily for approximately 1% of sod farm hectares that face
pests that are difficult to manage.  The little research that has been
conducted to identify MB alternatives has found that metam-sodium and
dazomet may be acceptable replacements for MB for many farms that
currently use MB.  This sector is still developing methods of
applications that can make these alternatives more effective. 

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

Turf	Turfgrass Producers

International

Amount of Request* (kg)

2008	680,388

Amount of Nomination (kg)

2008	52,189

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

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



Primary MeBr alternatives for sod production are metam-sodium and
dazomet, often in combination with chloropicrin and in some cases,
depending on pests, 1,3-D.  Research results (Unruh and Brecke, 2001;
Unruh et al., 2002) suggest that these alternatives have the potential
to be as effective as MB, although research in application technologies
will continue and will permit development of more effective pest control
methodologies.

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



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

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

Turfgrass Producers	1206	1 %



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



Approximately 1% of the total land planted for turfgrass is treated with
MeBr each year; the affected area averages one treatment every three
years.  MeBr is used only in the portion of the turfgrass area where
pest problems cannot be acceptably controlled using alternative methods.
 For instance, some broadleaf weeds, such as ragweed, pigweed, and
morning glory, may be controlled through continuous mowing to reduce
seed production.  Spot treatment with a nonselective herbicide, such as
glyphosate, may be used to control competitive grasses that can be
easily distinguished from the turfgrass crop.  Relatively low pest
pressures in most of the turfgrass sod production area make it possible
for producers to use alternative pesticides (herbicides, fungicides,
nematicides, and insecticides) and cultural practices.

7. (iii) Would it be feasible to expand the use of these methods to
cover at least part of the crop that has requested use of methyl
bromide?  What changes would be necessary to enable this?  TC "7. (iii)
Would it be feasible to expand the use of these methods to cover at
least part of the crop that has requested use of methyl bromide?  What
changes would be necessary to enable this?" \f C \l "2"  



Advances in technologies that will improve efficacy (e.g., application
methods, use of VIF) and may increase the area of production where
alternatives can be used effectively.  Research (e.g., Unruh and Brecke,
2001; Unruh et al, 2002) in turfgrass production indicates that fumigant
efficacy (even MB) varies depending on location and pest pressure.  It
is likely that farms where nutsedge is a major pest will have the most
difficult task finding an alternative.

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: 	Turfgrass Producers

Year of Exemption Request	2008

Kilograms of Methyl Bromide	680,388

Use: Flat Fumigation or Strip/Bed Treatment	Flat fumigation

Formulation (ratio of methyl bromide/chloropicrin mixture) to be used
for the Critical Use Exemption (CUE)	98:2

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (ha)	1416

Application rate* (kg/ha) for the active ingredient	300

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of methyl bromide	30.0

* For Flat Fumigation treatment application rate and dosage rate may be
the same.

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



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

Hectares counted in more than one application or rotated within one year
of an application to a crop that also uses MeBr were subtracted. 

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

Use rate was adjusted.  

Transition adjustment was calculated.  

Only the areas with moderate to heavy key pest pressure were included in
the nomination. 

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



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



Table 10.1: Sod—Key Pests and Reason for Methyl Bromide Request  TC
"Table 10.1: Sod—Key Diseases and Weeds and Reason for Methyl Bromide
Request" \f F \l "1"  

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



Throughout the United States	Weeds: nutsedge (Cyperus spp. ); mainly
off-type perennial grasses, crabgrass (Digitaria spp.); goosegrass
(Eleusine indica); common bermudagrass (Cynodon dactylon) and turfgrass
from the previous crop cycle.

Nematodes:  over 15 genera of parasitic nematodes, such as lance
nematodes (Hoplolaimus spp. ) and sting nematodes (Belonolaimus
longicaudatus)

Insects: white grubs (several species of soil-inhabiting scarabaeid
beetle larvae)	Producers of turfgrass need to produce sod that is free
of contamination with off-type perennial grasses, other weeds, pests,
and diseases.  For approximately 1% of the turfgrass sod growing area,
this degree of pest control has been achieved through MeBr fumigation. 
However, dazomet and metam sodium with chloropicrin have looked as good
(statistically) and nearly as good (numerically) in control of nutsedge
and weedy grasses as MeBr at the high use rates for turf  (560 kg/ha)
(e.g., Unruh and Brecke, 2001; Unruh et al., 2002). 



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



Table 11.1: Sod—Characteristics of Cropping System  TC "Table 11.1:
Sod—Characteristics of Cropping System" \f F \l "1"  

Characteristics	U.S.

Crop Type: 	Turfgrass sod grown from seeds or rhizomes

Annual or Perennial Crop: 	Harvested annually

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

Soil Types:  	Varies from clayish-loam to sandy-loam

Frequency of methyl bromide Fumigation: 

	The area is treated with methyl bromide approximately once every 3
years.  On average, 1% of the total turfgrass crop production area in
the U.S. is fumigated in any one year. 

Other relevant factors:	None identified.



Table 11.2 Sod—Characteristics of Climate and Crop Schedule

  TC "Table 11.2 Sod—Characteristics of Climate and Crop Schedule" \f
F \l "1"  

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

Climatic Zone	Range from temperate to subtropical (USDA Plant Hardiness
Zones 5b through  11) 

Soil Temp. ((C)	Variable throughout the United States.

Rainfall (mm)

	Outside Temp. ((C)

	Fumigation Schedule1





X	X





	Planting 

Schedule





X	X





	Key Market Window	Variable

1 On average, 1% of the area is fumigated once every three years.

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



None were identified as being relevant factors.

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



Table 12.1: Sod—Historic Pattern of Use of Methyl Bromide  TC "Table
12.1: Sod—Historic Pattern of Use of Methyl Bromide" \f F \l "1"  

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

Area Treated (hectares)	1,874	1,563	1,029	1381	647	398

Amount of MeBr active ingredient used 

(total kilograms)	913,557	762,021	501,568	619,244	312,071	189,269

formulations of MeBr (MB /chloropicrin)	According to the applicant, the
typical formulation used on turfgrass sod is 98:2.  

Method by which MeBr applied  	Liquid MeBr is shank injected into soil
at a depth of 20-80 cm and covered with polyethylene tarpaulin. 

Application rate for the active ingredient in kg/ha*	488	488	488	448	482
475

Actual dosage rate for the active ingredient (g/m2)*	48.8	48.8	48.8	44.8
48.2

	

 Part C: Sod—Technical Validation  TC "Part C: Sod—Technical
Validation" \f F \l "1"    TC "Part C: Sod—Technical Validation" \f C
\l "1"  



13. Sod—Reason for Alternatives Not Being Feasible  TC "13.
Sod—Reason for Alternatives Not Being Feasible" \f C \l "2"   



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

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

Chemical Alternatives

Dazomet	Research results indicated that most treatments (including MB)
differed in efficacy depending on site location and specific weed pests
that were evaluated (e.g., Unruh et al., 2002).  In research trials,
dazomet provided poor control of nutsedge in Jay, Florida, 44 weeks
after treatment, compared to MeBr (89% vs. 57%, respectively).  At the
same site, dazomet provided equal control of weedy grasses and slightly
better control of broadleaf weeds compared to MB, 44 weeks after
treatment and 32 weeks after treatment, respectively (Unruh et al.,
2002). MeBr fields may be planted within 48 hours after the plastic
cover is removed, while, depending on soil temperature, a period of 14
to 21 days may be required for effective fumigation when dazomet is used
to treat the soil.

In situations of low pest pressure golfcourses may employ a marginal
strategy without major economic dislocation if given a reasonable time
frame for the transition.	Possibly

1,3-D and 1,3-D + Chloropicrin	Might be used if nematodes are a primary
pest, or possibly in conjunction with dazomet or metam-sodium.  Unruh
and Brecke (2001) did not observe sufficient efficacy for managing weed
pests.	Possibly

Metam-Sodium / Chloropicrin	Unruh and Brecke (2001) found that
metam-sodium with chloropicrin provided comparable control (vs. MB) of
weedy grasses and nutsedge at some locations in Florida but not in all. 
Efficacy varied for all treatments, including MB, depending on location.
Possibly

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

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



Table 14.1: Sod—Technically Infeasible Alternatives Discussion  TC
"Table 14.1: Sod—Technically Infeasible Alternatives Discussion" \f F
\l "1"   

Name of Alternative	Discussion

Selective Pre- or Post-Emergent Herbicides	Please refer to Item 13
above.



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



Table 15.1: Sod—Present Registration Status of Alternatives  TC "Table
15.1: Sod—Present Registration Status of Alternatives" \f F \l "1"  

Name of Alternative	Present Registration Status

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

Iodomethane (Methyl Iodide)	Iodomethane is undergoing registration
reviews in the U.S., but not for use on turfgrass	Yes	Unknown

Sodium Azide	The manufacturer has not requested registration in the U.S.
No	Unknown

Propargyl Bromide	Not registered in U.S., no registration package has
been received.	No	Unknown

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



16. Sod—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 "16. Sod—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"  



Table 16.1: Sod—Effectiveness of Alternatives – Nutsedge (Cyperus
spp.) in Florida1  TC "Table 16.1: Sod—Effectiveness of Alternatives
– Nutsedge (Cyperus spp.) in Florida" \f F \l "1"  

Treatment	Rates	Application Methods	% NusedgeControl2



	Site 1	Site 2



	6

WAT3	44 WAT3	3 WAT3	15 WAT3

Methyl Bromide + Chloropicrin	549 kg/ha  + 11 kg/ha	Shank injected	100a
89a	100a	83a

1,3-D + oxadiazon	140 L/ha + 168 kg/ha	Shank injected + surface
broadcast	0f	86ab	0c	74ab

Dazomet	392 kg/ha	Surface broadcast followed by rototill followed by
soil seal	80abc	57de	78b	58bcd

Dazomet + Chloropicrin	392 +168 kg/ha	Surface broadcast followed by
rototill followed by soil seal + shank injected	81ab	63bcd	81b	48cd

Dazomet +

1,3-D	392 kg/ha + 140 L/ha	Surface broadcast followed by rototill
followed by soil seal + shank injected	51de	31f	76b	41d

Metam-sodium	748 L/ha	Surface spray followed by rototill followed by
soil seal	43e	26f	71b	73ab

Metam-sodium + Chloropicrin	748 L/ha + 168 kg/ha	Surface spray followed
by rototill followed by soil seal + shank injected	55cde	38ef	72b	76ab

Metam-sodium + Chloropicrin tarped	748 L/ha + 168 kg/ha	Surface spray
followed by rototill + shank injected	64b-e	56de	100a	79ab

Metam-sodium + 1,3-D	748 + 140 L/ha	Surface spray followed by rototill +
shank injected	69bcd	50def	87ab	70abc

Untreated Control

	0f	0g	0c	0e

LSD (0.05)

	25	24	17	23

1 Modified from Unruh and Brecke (2001) and Unruh et al. (2002) 

2 Numbers followed by the same letter(s) are not significantly
different.  

3 Number of weeks after treatment 

Table 16.2: Sod—Effectiveness of Alternatives – Weedy Grasses1 in
Florida 2  TC "Table 16.2: Sod—Effectiveness of Alternatives – Weedy
Grasses in Florida" \f F \l "1"  

Treatment	Rates	Application Methods	% Weed Control3



	Site 1	Site 2



	6

WAT3	44 WAT3	3 WAT3	15 WAT3

Methyl Bromide + Chloropicrin	549 kg/ha  + 11 kg/ha	Shank injected	100a
98a	100a	74ab

1,3-D + oxadiazon	140 L/ha + 168 kg/ha	Shank injected + surface
broadcast	0b	53b	13c	71ab

Dazomet	392 kg/ha	Surface broadcast followed by rototill followed by
soil seal	98a	93a	83b	44cd

Dazomet + Chloropicrin	392 +168 kg/ha	Surface broadcast followed by
rototill followed by soil seal + shank injected	96a	93a	91ab	38d

Dazomet +

1,3-D	392 kg/ha + 140 L/ha	Surface broadcast followed by rototill
followed by soil seal + shank injected	100a	95a	90ab	54bcd

Metam-sodium	748 L/ha	Surface spray followed by rototill followed by
soil seal	98a	88a	87b	65abc

Metam-sodium + Chloropicrin	748 L/ha + 168 kg/ha	Surface spray followed
by rototill followed by soil seal + shank injected	100a	89a	92a	69abc

Metam-sodium + Chloropicrin tarped	748 L/ha + 168 kg/ha	Surface spray
followed by rototill + shank injected	100a	94a	100a	70abc

Metam-sodium + 1,3-D	748 + 140 L/ha	Surface spray followed by rototill +
shank injected	96a	94a	95ab	59a-d

Untreated Control

	0b	0c	0c	0d

LSD (0.05)

	35	13	13	27

1 Grass species include coastal bermudagrass at Site 1 and
alexandergrass, broadleaf signalgrass, and common bermudagrass at Site
2.  

2Modified from Unruh and Brecke (2001) and Unruh et al. (2002)

3 Numbers followed by the same letter(s) are not significantly
different.  

4 Number of weeks after treatment 

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

Alternative	List Type of Pest	Range of Quality Loss	Best Estimate of
Quality Loss1

Dazomet, alone or in combination with chloropicrin	Weeds, primarily
off-type perennial grasses; secondarily, nutsedge, nematodes and insects
Unable to determine since research shows variability even among MeBr
treatments, depending on location of trials and pest type	Unable to
determine since research shows variability even among MeBr treatments,
depending on location of trials and pest type

Metam sodium, alone or in combination with chloropicrin 



	Overall Loss Estimate for All Alternatives to Pests	Unable to determine
since research shows variability even among MeBr treatments, depending
on location of trials and pest type



However, in areas of low to moderate pest pressure, information suggests
that some growers may employ a marginal strategy without major economic
dislocation if given a reasonable time frame for the transition.  The
assessment of need was adjusted to account for this.  

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



Metam-sodium and dazomet, possibly in conjunction with chloropicrin, are
likely effective alternatives to MeBr for turfgrass sod production. 
Covering plots treated with metam sodium + chloropicrin with plastic
tarpaulin increased the nutsedge control effectiveness of this
combination in southern Florida, although not in a western Florida site
(Unruh et al., 2002).  However, MeBr was also variable in its efficacy
depending on the location and specific pests.

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



The turfgrass producers claim that the reduction in MB, for 2003, was a
result of increased use of metam-sodium.  However, they claim a loss of
quality as a result.  Research indicates that metam-sodium and dazomet,
and chloropicrin combinations have the potential to reduce the use of
MeBr in many situations.

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



Research indicates that metam sodium and dazomet are the best available
alternatives for MeBr in turfgrass sod production.  Metam sodium and
dazomet applied alone, or in conjunction with chloropicrin, can provide
good control of wild and off-type perennial grasses and broad leaf
weeds, but typically, fair to poor control of nutsedge (Unruh and
Brecke, 2001).  In research trials (e.g., Unruh and Brecke, 2001; Unruh
et al., 2002) all of the fumigants that were tested, including MB, had
variable efficacy depending on the location of the field trials.  These
studies indicated that in some locations metam-sodium + chloropicrin,
under polyvinyl tarp, can be as effective as MeBr for controlling some
target weeds.  For areas with nutsedge infestations, efficacy of MeBr
varied depending on location, and was superior in one trial in Florida
and comparable to metam-sodium in another (Unruh et al., 2002).  Farms
with severe nutsedge infestations are most at risk for pest management
problems when using dazomet or metam-sodium.

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?	Research to
examine tarps is ongoing and appears to improve efficacy (e.g.,
Landschoot and Park, 2004; Park and Landschoot, 2003)	None identified;
industry traditionally has had a high use rate of MB	None identified;
industry traditionally has had a high use rate of MB	For sod farms, used
once in 3 years.

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	Research to examine tarps is ongoing and
appears to improve efficacy (e.g., Landschoot and Park, 2004; Park and
Landschoot, 2003)	None identified; industry traditionally has had a high
use rate of MB	None identified; industry traditionally has had a high
use rate of MB	For sod farms, used once in 3 years.

Other measures 







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"  

The requesting consortia identified future plans for examining high
density polyethylene as a means to minimize MeBr emissions.

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



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



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

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

Methyl Bromide	100%	$1,235	$1,235	$1,235

Dazomet	75%	$2,964	$2,964	$2,964

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

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



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

Year 1

Alternatives 

(as shown in question 21)	Gross revenue for last reported year
(U.S.$/ha)	Net Revenue for last reported year (U.S.$/ha)

Methyl Bromide	$19,619	$10,327

Dazomet	$14,714	$3,693



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

Year 2

Alternatives 

(as shown in question 21)	Gross revenue for last reported year
(U.S.$/ha)	Net Revenue for last reported year  (U.S.$/ha)

Methyl Bromide	$19,619	$10,327

Dazomet	$14,714	$3,693



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

Year 3

Alternatives 

(as shown in question 21)	Gross revenue for last reported year
(U.S.$/ha)	Net Revenue for last reported year  (U.S.$/ha)

Methyl Bromide	$19,619	$10,327

Dazomet	$14,714	$3,693



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



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

U.S.	Methyl Bromide	Dazomet

Yield/Quality Loss (%) 	0	 25%

   Yield per Hectare (in ha/ha)  	1	Not Available

* Price per Unit (u.s.$)	$19,619	Not Available

= Gross Revenue per Hectare (u.s.$)	$19,619	$14,714 

- Operating Costs per Hectare (u.s.$)	$9,292	$11,021

= Net Revenue per Hectare (u.s.$)	$10,327	$3,693

Loss Measures

1. Loss per Hectare (u.s.$)	$0	$6,634

2. Loss per Kilogram of Methyl Bromide (u.s.$)	$0	$13.82

3. Loss as a Percentage of Gross Revenue (%)	0%	33.81% 

4. Loss as a Percentage of Net Revenue (%)	0%	64.24% 



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



The primary economic loss that would be expected in sod turfgrass is
price reduction associated with the inability to market sod as
certified, which results in up to a 75% reduction in gross revenue.  The
small proportion of turf production represented by this nomination is
intended for sod growers producing certified sod.

In addition to price reductions from downgraded quality, there are also
expected to be some losses from off-type grasses rendering some areas
simply unharvestable, either from the presence of off-type grasses, or
the required destruction of all grass in a particular area (to prevent
the spreading of off-types).  The losses are much smaller than the
impact of not being able to certify the sod.

The CUE reviewers analyzed crop budgets data for sod turfgrass to
determine the likely economic impact if methyl bromide were not
available. The four economic measures in Table E.1 were used to quantify
the economic impacts to pre-plant uses for sod turfgrass. The four
economic measures are not independent in such a way that they can be
calculated from the same crop budget data. The measures are, however,
supplementary to each other in evaluating the CUE applicant’s economic
viability.  These measures represent different ways to assess the
economic feasibility of methyl bromide alternatives for methyl bromide
users.

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.

As stated earlier in the application, the price of non-certified sod is
75% lower than the price of certified sod.  For production areas that
would otherwise fumigate with methyl bromide, it is possible that some
areas will be able to continue producing certified seed for a limited
time, as long as they do not attempt to change variety or species.  But,
as mentioned earlier in the application, changing variety or species is
one primary reason for needed to control off-types of grass.

To reflect a lower bound on impacts, under the assumption that some
areas covered by the nomination would delay their shift in grass type,
or delay their control of other key pests, the economic analysis used
25% as the yield/price effect.  It is important to recognize that in
some areas, the loss could be as high as 75%.  Using the lower bound, we
estimate that a representative grower would suffer $6,634 loss per
hectare per year due to inferior product and a lower proportion of
harvestable acreage, and an increase of fumigation costs with dazomet
(TPI, 2003).  The loss as a percentage of gross revenue was estimated at
33.81% and the loss as a percentage of net revenue at 64.24%. These
changes are estimated to have a significant economic impact to the sod
industry. The results suggest that dazomet is not economically viable as
an alternative for methyl bromide.  

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"   



Metam-sodium and dazomet already are used in the sod turfgrass
production industry.  It has not been determined how the 1% of total sod
farm hectares that use MeBr can further reduce its use.

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"   



According to the Critical Use Exemption request, studies of high density
polyethylene will be evaluated.  The consortium will create a timeline
for a transition from MeBr to alternatives.

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

 

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

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



Dunn, R. A. and Crow, W. T. 2001.  Soil fumigation before planting turf.
 University of Florida IFAS Extension Publication ENY-26.   HYPERLINK
"http://edis.ifas.ufl.edu/IN095"  http://edis.ifas.ufl.edu/IN095 .

Unruh, J. B. and B. J. Brecke.  2001.  Seeking Alternatives for Methyl
Bromide.  Golf Course Management.  69(3): 65-72. 
http://www.gcsaa.org/gcm/2001/mar01/pdfs/03seeking.pdf

Unruh, J. B., B. J. Brecke, J. A. Dusky and J. S. Godbehere.  2002. 
Fumigant Alternatives for Replacement of Methyl Bromide in Turfgrass. 
Weed Technology, 16:379-387, pp 379-387. 
http://www.pw.ucr.edu/textfiles/methyl%20bromide-1.pdf

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.  

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 PAGE   

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