Nominating Party: 	The United States of America

FILE NAME: USA CUN13 Soil ORNAMENTALS Open Field and Protected
Environments

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for
Ornamentals in Open Fields and Protection Environments (Submitted in
2011 for 2013 Use Season)

Crop name (open field or protected): Ornamentals – Open Fields and
Protected

Quantity of methyl bromide Nominated:

Table 1: Quantity of Methyl Bromide Nominated

Year	Nomination Amount

2013	48,164 kg 



NOMINATING PARTY CONTACT DETAILS:

Contact Person:	John Thompson

Title:	Division Director

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street, N.W. Room 2658

	Washington, D.C. 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:      			

(Details on this page are requested under Decision Ex. I/4(7), for
posting on the Ozone Secretariat website under Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will
also refer to the original nomination on which the Party’s first-year
exemption was approved, as well as any supplementary information
provided by the Party in relation to that original nomination.  As this
earlier information is retained by MBTOC, a Party need not re-submit
that earlier information.   

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person:	Jack Housenger	

Title:	Director	

Address:	Biological and Economic Analysis Division			

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	1200 Pennsylvania Avenue, N.W. Mailcode 7503P

	Washington, D.C. 20460

	U.S.A.	

Telephone:	(703) 308-8200		

Fax:	(703) 308-7042	

E-mail:	  HYPERLINK "mailto:Housenger.Jack@epa.gov" 
Housenger.Jack@epa.gov 

		

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION
PACKAGE:

1.  PAPER DOCUMENTS:  

Title of paper documents and appendices	No. of pages	Date sent to Ozone
Secretariat

















2.  ELECTRONIC COPIES OF ALL PAPER DOCUMENTS:  

*Title of each electronic file (for naming convention see notes above)
No. of kilobytes 	Date sent to Ozone Secretariat

USA CUN13 Soil ORNAMENTALS Open Field and Protected Environments















* Identical to paper documents



METHYL BROMIDE CRITICAL USE RENOMINATION FOR Preplant Soil Use (OPEN
FIELD OR PROTECTED ENVIRONMENT)

ORNAMENTALS

SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE:

This re-nomination is for methyl bromide for the production of
ornamentals.  The ornamental sector consists of cut flowers, cut greens,
and bulbs in California and floriculture in Florida.  All data comes
from the applicants’ requests unless otherwise cited.

California

Ornamental growers in California have a demonstrated critical need for
methyl bromide in 2013.  Alternatives are not available due to
regulatory constraints.   Iodomethane (methyl iodide)  was registered in
December of 2010 in California, but its future registration status is
uncertain because of lawsuit that was filed to stop its registration. 
Many alternative fumigants contain 1,3-dichloropropene and/or
chloropicrin; these active ingredients are severely restricted by
California state and local laws which effectively prevent their use as
methyl bromide alternatives for ornamental cultivation.  Restrictions on
chloropicrin also means the lowest formulation of methyl bromide used in
California is 67:33 (methyl bromide: chloropicrin), as rates of
chloropicrin higher than 225 kg/ha are prevented by law and lower rates
are ineffective for pest control.  A single grower may grow dozens of
types of species and cultivars, each of which may experience different
pest pressures and may result in varying cultivar and species reactions
to pest control measures, impacting an alternative’s ability to
control the entire pest spectrum.

Florida

Iodomethane has been a registered pesticide in Florida since early 2009.
Thus far, research results indicate that it is as efficacious as methyl
bromide, facilitating a transition away from methyl bromide.  However,
few long-term trials have been conducted and concerns have been raised
about application techniques and species-specific interactions.  For
instance, there have been no iodomethane trials to treat permanent
post-rows using the “hot gas” method, which is a common management
practice for Florida ornamental growers.  Until more studies have been
done to address these concerns and growers have more time to adapt their
production practices, there is a critical need for methyl bromide in
2013 as part of a multi-year transition to alternatives. Some
alternatives that appear effective in research trials are not currently
registered, including acrolein and dimethyl disulfide (DMDS).  

2.	reasons why alternatives to methyl bromide are not feasible

The adoption of alternatives to methyl bromide by the ornamentals sector
is constrained by regulatory prohibitions, yield losses, and higher
costs which vary greatly by state.  Additionally, some constraints apply
to the entire ornamentals industry.  A single grower may grow dozens of
types of species and cultivars, each of which may experience different
pest pressures.  For example, a 2008 study in Florida found a
significant difference between the pests of two cultivars of Delphinium
and their pest loads (Rosskopf et al 2008). These differences may result
in varying cultivar and species reactions to pest control measures,
impacting an alternative’s ability to control the entire pest
spectrum.  Methyl bromide is requested for ornamentals to allow time to
test the alternatives for all the different crops and growing
conditions. 

California

In addition to federal regulations, the California Department of
Pesticide Regulation (DPR) has implemented severe restrictions for soil
fumigants, including larger buffer zone requirements and township caps,
which limit the amount of each fumigant can be applied within a 36-mile
area (Segawa et al 2005).  If these restrictions were not in place, the
best methyl bromide alternative for ornamental growers in California
would be 1,3-D plus chloropicrin followed by metam sodium (James Gerik,
personal communication). A recent study found that this fumigant
combination was at least as efficacious as methyl bromide (Klose et al
2008).  The state buffer and township cap regulations currently prevent
the use of this alternative.  Moreover, another recent study found that
the most effective alternative treatments contain chloropicrin (Gerik et
al 2002). However, any pesticide combinations including either 1,3-D or
chloropicrin are subject to prohibitory regulations and can only be
considered as  alternatives in areas where regulatory constraints do not
restrict their use.  Iodomethane received a registration in California
in December of 2010.  The rates registered in California are lower than
those registered in the rest of the U.S. and the buffer distances to
habited structures are up to 10X larger than in the rest of the U.S. 
Research will need to be conducted on the efficacy of these lower use
rates. 

Some alternatives that appear effective in research trials are not
currently registered, including acrolein, and DMDS. The future
registration status of these products and other alternatives is unknown.

Florida

Iodomethane is now fully registered in Florida and recent research
results showed it is at least as effective as methyl bromide for pest
control in Florida ornamentals (Rosskopf et al 2006, Rosskopf et al
2007a, Rosskopf et al 2007b, Kokalis-Burelle et al 2006). However, no
studies have been conducted on the same fields for more than two years,
so long-term efficacy and application issues have yet to be fully
identified and understood.   Moreover, efficacy has varied between the
species and cultivars tested in research trials; it is impossible to
predict how each of the many species and cultivars of ornamentals would
respond to iodomethane.  Additionally, research is needed on the
compatibility of iodomethane with ‘hot gas’ fumigant application
currently used for methyl bromide; it is a common management method for
ornamental growers. 

More studies are needed in order to understand the climate-specific
constraints faced by Florida ornamental growers. The applicants continue
to apply for grants and conduct research to this end in collaboration
with California ornamental growers.  DMDS was registered in 2010 for
ornamentals but not in Florida (registered states currently include:
Georgia, Ohio, North and South Carolina, Michigan, New Mexico,
Tennessee, Texas, and Virginia).  If DMDS is registered in Florida
additional time will be needed because there are very few long term DMDS
efficacy studies on ornamentals. 

3.	is the use covered by A certification STANDARD?

Methyl bromide is not used to meet a certification standard for
ornamental production.

4.	If 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. 

Methyl bromide is only being requested for ornamental crop acreage with
demonstrated critical need and is not being requested for acreage that
has had success with alternatives, such as caladiums in Florida. 

Enclosures

Some ornamental growers using greenhouses have had success controlling
pests with substrates.  Crops successfully grown in soilless media
include roses, gerbera, lilies, and tulips.  However, even substrates
are fumigated after multiple cropping seasons to control diseases such
as Pythium and continue using the substrate, which must be reused in
order for the cropping system to be cost effective.  Certain crops
actually experience yield or quality gains when grown in substrates,
such as roses; however, for most crops there is not such a gain to
offset the increased costs associated with substrate production. 
Soilless media systems also require altered watering and fertilization
management practices, which may incur additional costs.  Ultimately, the
use of substrates requires greenhouses with benches, as opposed to
growing crops in enclosures with open bottoms to the soil.  

Steam sterilization has been adopted by some shade house and greenhouse
growers to produce lilies. While steam is considered effective in
controlling pests, there are many costs required to set up a steaming
system within an existing enclosure structure.  The cost of fuel
required to heat soil beds uniformly also impacts the feasibility of
steam sterilization.  Some growers who attempted transitioning to steam
sterilization switched back to fumigation due to application issues and
additional costs.  Researchers in California and Florida have looked a
steam sterilization for ornamental production systems (Rosskopf 2010,
and Hanson 2010).  This work suggests with some additional testing that
field applied steam could become a technically and economically feasible
alternative.  

Open Field

The U.S. does not have information about the proportion of ornamental or
floriculture crops using alternatives to methyl bromide.  It can be
presumed that acreage not requesting methyl bromide has either
transitioned to an alternative pesticide or does not have the same
cropping practices or pest pressure as the applicants with critical use
requests.  For example, Easter lily growers in California now use 1,3-D
and metam sodium applied sequentially instead of methyl bromide. 
However, these crops allow fallow periods between crops of more than 10
years, which is not feasible for other specialty growers due to limited
land resources.   Additionally, some growers have reduced their planted
acreage due to economic hardship in recent years but intend to expand
plantings and thereby fumigated acres when the economy improves.

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

No, it is not currently feasible to expand the use of alternative pest
control measures to address the demonstrated critical needs of the
ornamentals sector requesting methyl bromide for the 2013 growing
season.   Regulatory, technical, and economic barriers prevent their
adoption and generally vary by state.  Research to find efficacious,
safe, and cost effective alternatives is ongoing, and applicants have a
long history of successfully applying for grants and carrying out
research on alternatives.

California

State and local regulations would have to change in order for fumigants
such as 1,3-D and chloropicrin to be adopted as methyl bromide
alternatives.  Other fumigants currently being tested may prove
effective in research trials but lack registration in the state of
California, such as DMDS ).  Furthermore, some fumigants considered
effective in research trials for use in California lack both federal and
state registration, including dimethyl disulfide and acrolein (Gerik and
Wong 2008).  

Florida

Research is needed in order to determine the long-term efficacy and cost
issues associated with iodomethane adoption as a methyl bromide
alternative.  More research is also needed on nonfumigant alternatives
such as steam.  Critical use of methyl bromide could be further reduced
by changing the label to allow concentrations lower than 98:2 (methyl
bromide: chloropicrin) to be applied using the ‘hot gas’ method,
which is a common management practice.  Concentrations as low as 50:50
(methyl bromide: chloropicrin) have been found to achieved comparable
control of nematodes and nutsedge as with the 98:2 formula (Noling et al
2001).

6.	summary of recent research

CALIFORNIA

Hanson, B.  2010.    HYPERLINK "85Hanson.pdf"  Steam Disinfestation as a
Methyl Bromide Alternative in California Cut Flower Nurseries.  
Proceedings of the Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/085HansonBSteamflowernursery.pdf" 
http://mbao.org/2010/085HansonBSteamflowernursery.pdf 

Steam treatments were compared to methyl bromide for the production of
snapdragon, and Asiatic lily in California.  There were no difference
between MeBr and steam for weed or Fusarium control at the snapdragon
site.  At the Asiatic lily site there were no difference in Fusarium or
Pythium control, weed control or lily plant emergence.  

FLORIDA

Rosskopf, E.N., N. Kokalis-Burelle, E. Nissen, O. Nissen, R. Hartman, R.
McSorley, E. Skvarch, T.J. Swaford, C. Owens, S. Brooks, and K.
Register. 2010.  Evaluation of currently available alternatives to
methyl bromide for ornamental crop production in Florida.  Proceedings
of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/082RosskopfAreawideOrnamental..pdf" 
http://mbao.org/2010/082RosskopfAreawideOrnamental..pdf 

The 2010 results were different than the 2008 results above.  No
significant difference between methyl bromide, DMDS, or iodomethane in
terms of soil borne fungi.,  However, none of the alternatives were as
consistent as methyl bromide for weed control and there was a fungal
plant pathogen with nematode interaction for the different fumigants
that will need to be resolved..   

Rosskopf, E.N., N. Kokalis-Burelle, D.M. Butler, J. Holzinger, S.
Fennimore.  2010.  Evalution of steam for nematode and weed control in
cut flower production inFlorida.  Proceedings of the Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/083RosskopfSteam.pdf" 
http://mbao.org/2010/083RosskopfSteam.pdf 

The results of the 2010 study suggests that steam sterilization can
control weeds, reduce root gall ratings compared to MeBr on snapdragon,
larkspur, and delphinium.  The production of snapdragon, larkspur, and
delphinium appeared similar between MeBr and steam treatments.  

7.  ECONOMIC FEASIBILITY OF ALTERNATIVES 

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

Table 2: California cut flowers - Calla Lily & Ranunculus - Economic
Impacts of Methyl Bromide Alternatives

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

Yield Loss (%) 	0	25 	25	20

   Yield per Hectare 	55,937	41,952	41,952	44,749

* Price per Unit (U.S.$)	2.59	2.59	2.59	2.59

= Gross Revenue per Hectare (U.S.$)	145,107	108,830	108,830	116,086

- Operating Costs per Hectare (U.S.$)	160,030	160,030	160,030	160,030

= Net Operating Revenue per Hectare (U.S.$)	-14,923	-51,200	-51,200
-43,945

1. Loss per Hectare (U.S.$)	0	36,277	36,277	29,021

2. Loss per Kilogram of Methyl Bromide (U.S.$)	0	137	137	110

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

4. Loss as a Percentage of Net Operating Revenue (%)	0	-243	-243	-194



Table 3: Florida Cut Flowers - Lilies - Economic Impacts of Methyl
Bromide Alternatives 

Florida Cut Flowers – Lilies	Methyl Bromide	IODOMETHANE + PIC (98:2) 

Yield Loss (%) 	0	0 

   Yield per Hectare 	31,135	31,135

* Price per Unit (U.S.$)	10	10

= Gross Revenue per Hectare (U.S.$)	311,353	311,353

- Operating Costs per Hectare (U.S.$)	262,715	262,715

= Net Operating Revenue per Hectare (U.S.$)	48,638	46,908

1. Loss per Hectare (U.S.$)	0	1,730

2. Loss per Kilogram of Methyl Bromide (U.S.$)	0	4

3. Loss as a Percentage of Gross Revenue (%)	0	1

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



Summary of Economic Feasibility

The economic analysis evaluated methyl bromide alternative control
scenarios for cut flower production for California and Florida by
comparing the economic outcomes of methyl bromide oriented production
systems to those using alternatives.  However, due to the fact that
there are over 100 species of ornamentals grown in all regions of the
country, the data from these examples are used to derive a proxy
estimate for the entire industry.  A major factor that affected this
economic analysis as compared to the past economic analyses was the
availability of iodomethane (registered in 2008) in Florida, but not in
California for use in ornamentals.  

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

	

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

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

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

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

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

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

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

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

Loss per hectare measures the value of methyl bromide based on changes
in operating costs and/or changes in yield.  Loss expressed as a
percentage of the gross revenue is based on the ratio of the revenue
loss to the gross revenue, likewise for the loss as a percentage of net
revenue.  Yield loss estimates were based on data from the CUE
applications and U.S. EPA data, as well as expert opinion.

Regulatory constraints

California restricts total use of 1,3-D at the local level (township
cap).  Nematodes and weeds and pathogens are key pests in Florida and
California bulb grower and are controlled with methyl bromide. 
Chloropicrin is not as effective in controlling weeds as methyl bromide.
 Using chloropicrin adds to production costs through increased chemical,
weeding and labor costs.

Tables 2 though 4 provide a summary of the estimated economic losses.  A
measure of net revenue loss may not be completely accurate partly
because some nurseries are publicly owned and seedling prices or
production costs are subsidized.  Indirect losses arising from shifts in
the production cycle were not quantified.  Changes in production costs
arise due to differences between the costs of methyl bromide and the
alternatives, shifts in the production cycle (increasing the frequency
of fumigation or lengthening the fallow period) and additional expenses
such as supplementary irrigation.  These costs vary across regions.  

As shown in Table 2, the alternatives to methyl bromide for California
cut flower production impose significant economic impacts on the
growers.  However, in Florida where iodomethane is available for use in
ornamentals, economic impacts of using iodomethane as an alternative to
methyl bromide are small.  

8.  RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

Table 4. Nomination Amount.

CITATIONS

Rosskopf, E.N., N. Kokalis-Burelle, E. Nissen, O. Nissen, R. Hartman, R.
McSorley, E. Skvarch, T.J. Swaford, C. Owens, S. Brooks, and K.
Register. 2010.  Evaluation of currently available alternatives to
methyl bromide for ornamental crop production in Florida.  Proceedings
of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/082RosskopfAreawideOrnamenta.pdf" 
http://mbao.org/2010/082RosskopfAreawideOrnamenta.pdf 

Rosskopf, E.N., N. Kokalis-Burelle, D.M. Butler, J. Holzinger, S.
Fennimore.  2010.  Evalution of steam for nematode and weed control in
cut flower production inFlorida.  Proceedings of the Annual
International Research Conference on Methyl Bromide Alternatives and
Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/083RosskopfSteam.pdf" 
http://mbao.org/2010/083RosskopfSteam.pdf 

Gerik, JS; CL Elmore, ID Greene. 2002. Alternative soil treatments for
field grown ornamentals. Proceedings of the Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions.     HYPERLINK
"http://mbao.org/2002proc/093gerikj%20mbao_2002.pdf" 
http://mbao.org/2002proc/093gerikj%20mbao_2002.pdf 

Gerik, James and Dong Wang. 2008. Control of Agrobacterium tumafaciens
with soil fumigants. Proceedings of the Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.    
HYPERLINK "http://mbao.org/2008/110Gerik.pdf" 
http://mbao.org/2008/110Gerik.pdf 

Gerik, James. Personal communication via telephone. October 28, 2008.

Hanson, B.  2010.    HYPERLINK "85Hanson.pdf"  Steam Disinfestation as a
Methyl Bromide Alternative in California Cut Flower Nurseries.  
Proceedings of the Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2010/085HansonBSteamflowernursery.pdf" 
http://mbao.org/2010/085HansonBSteamflowernursery.pdf 

Klose, Susanne; Jim Gerik, Hussein Ajwa, Cheryl Wilen, Mike Mellano.
2008. Proceedings of the Annual International Research Conference on
Methyl Bromide Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2008/029Klose.pdf"  http://mbao.org/2008/029Klose.pdf 

Kokalis-Burelle, Nancy; Erin Rosskopf, Randy Driggers. 2006. Efficacy of
Midas for control of Meloidognye incognita on Celosia in Florida.
Proceedings of the Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2006/06Proceedings/112BurelleNMBAOAbstractBurelleetal20
06.pdf" 
http://mbao.org/2006/06Proceedings/112BurelleNMBAOAbstractBurelleetal200
6.pdf 

McSorley, R., Wang, K.H., Church, G. 2004. Fumigant alternatives to
methyl bromide for managing nematodes and weeds in snapdragon.
Proceedings of Florida State Horticulture Society. 117:334-337.

National Agricultural Statistics Service (NASS). 2008. Floriculture
Crops 2007 Summary. USDA Sp Cr 6-1 (08)

http://usda.mannlib.cornell.edu/usda/current/FlorCrop/FlorCrop-04-24-200
8.pdf

Noling, J.W; J.P. Gilreath, E.R. Rosskopf. 2001. Alternatives to methyl
bromide field research efforts for nematode control in Florida.
Proceedings of the Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.  
http://mbao.org/2001proc/014%20Noling%20JW%20MBAO2-2001.pdf

Rosskopf, Erin; D.O. Chellemi, N. Kokalis-Burelle, G.T. Church. 2005.
Alternatives to methyl bromide: a Florida perspective.  APSnet Feature
June 2005:   HYPERLINK
"http://www.apsnet.org/online/feature/methylbromide/" 
http://www.apsnet.org/online/feature/methylbromide/ 

Rosskopf, Erin; Nancy Kokalis-Burelle, Randy Driggers. 2006. Evaluation
of Midas for production of ornamental cockscomb in Florida. Proceedings
of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions.     HYPERLINK
"http://mbao.org/2006/06Proceedings/037Rosskopfetalcelosia2006.pdf" 
http://mbao.org/2006/06Proceedings/037Rosskopfetalcelosia2006.pdf 

Rosskopf, Erin; Nancy Kokalis-Burelle, and Randy Driggers. 2007a.
Reduced rates and alternatives to methyl bromide for snapdragon
production in Florida. Proceedings of the Annual International Research
Conference on Methyl Bromide Alternatives and Emissions Reductions.    
HYPERLINK
"http://mbao.org/2007/Proceedings/106RosskopfEMBAOsnapdragon2007.pdf" 
http://mbao.org/2007/Proceedings/106RosskopfEMBAOsnapdragon2007.pdf 

Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley. 2007b. Status
of methyl bromide alternatives for ornamental crop production in Florida
and California. American Phytopathological Society Annual Meeting.

Rosskopf, Erin and Nancy Kokalis-Burelle. 2008. Area-wide demonstration
of chemical alternatives to methyl bromide for Florida ornamentals.
Proceedings of the Annual International Research Conference on Methyl
Bromide Alternatives and Emissions Reductions.    HYPERLINK
"http://mbao.org/2008/028Rosskopf.pdf" 
http://mbao.org/2008/028Rosskopf.pdf 

Segawa, Randy. 2005. Methods for developing fumigant regulatory
requirements in California. Proceedings of the Annual International
Research Conference on Methyl Bromide Alternatives and Emissions
Reductions.   HYPERLINK
"http://mbao.org/2005/05Proceedings/001%20SegawaR%20mbao_2005_conf_segaw
a_summary.pdf" 
http://mbao.org/2005/05Proceedings/001%20SegawaR%20mbao_2005_conf_segawa
_summary.pdf 

Zinati, Gladis; Herbert Bryan and Merlyn Codallo. 2002. Solarization as
a potential approach for recycling wastes for potting media and as an
alternative to methyl bromide for field-grown bedding plants.
Proceedings of Florida State Horticulture Society. 115: 123 – 127.

APPENDIX A: ORNAMENTAL SPECIES GROWN   TC "APPENDIX B  ORNAMENTAL
SPECIES GROWN AND TARGET PESTS" \f C \l "1"  

The very large and constantly changing number of species and cultivars
grown in the ornamentals sector means that compiling a complete list of
species and acreage grown is not possible.  There are hundreds of types
of cut flower, foliage, and bulb crops grown each year and often several
species are grown in the same field simultaneously. However, the U.S.
has tried to describe the major crops below.  Additional information is
not available from public or private sources.

California

APPENDIX B -Table 1:  California Ornamentals - Production of Major
Species

Species	# Flower Bunches in 2003

Alstroemeria	892,789

Carnations	1,694,870

Delphinium	3,617,186

Gladiolus	Data not released

Gerbera	62,638,650

Iris	5,823,242

Lilium	6,247,027

Chrysanthemums	1,273,742

Pompons	6,350,127

Roses	7,360,729

Snapdragons	2,976,219



Appendix B - Table 2: California Ornamentals - Partial Listing and
Estimate of Cut Flower and Foliage Area Produced in California in 2002

Crop	Area (usually field) - ha	Area (usually greenhouse) - HA

Alstroemeria	8	 5

Antirrhinum (snapdragon)	126	 17

Aster

6

Calla lily	16

	Carnation	30	2

Chrysanthemum	88	28

Delphinium	22

	Eucalyptus	54

	Gerbera

21

Gypsophila	55

	Iris (Dutch)	18

	Larkspur	6

	Lilium	32	21

Limonium spp.	13

	Lisianthus	13

	Protea	190

	Rose	41	12

Stock (Matthiola)	26

	Wax flower	317

	Other	791	6

Greenhouse misc.	70	28

Field misc.	303

	Cut greens misc.	389

	Total	2609	145 ha

1  Total does not add due to rounding.  

Florida 

The only three cut flower species identified by the Florida Agricultural
Statistics Service are gladioli, lilies and snapdragon.  These are
assumed to have the highest acreage and they have been identified by the
applicant as using methyl bromide. 

Appendix B Table 3.  Florida Ornamentals - Crop Production for Certain
Cut Flower Species2 

	2001	2002	2003

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

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

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

Lilies	4	3,031	3	2,257	-	-

1 Quantity of lilies sold 1000 stems.

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



APPENDIX B: KEY TARGET PESTS

The ornamentals industry is complex; therefore, the following list is
not comprehensive but is intended to demonstrate the large number of
pests affecting ornamental production and creating a critical need for
methyl bromide in the U.S. for the 2013 growing season.

TABLE C 1.  KEY PESTS  TC "Table 1.  KEY PESTS" \f F \l "1"   

Region where methyl bromide use is requested	Key disease(s) and weed(s)
to species and, if known, to level of race	Specific reasons why methyl
bromide needed (e.g. Effective herbicide available, but not registered
for this crop; mandatory requirement to meet certification for disease
tolerance; no host resistance for a specific race)

A:  California Cut Flowers, Cut Greens and Perennials	Verticillium spp.,
Fusarium spp., Pythium spp., Meloidogyne spp., Nutsedge (Cyperus spp.),
Malva spp., Poa spp., and previous crop propagules.  Specific pest
problems vary by individual crop and variety.  	The diversity and
complexity of the industry, makes it difficult to control all root
pathogens and weeds with currently available pest control methods. Some
methyl bromide alternatives used for other sectors are not feasible for
floriculture due to high costs, difficulty timing applications to allow
intercropping, and regulatory restrictions including township caps and
buffer zone requirements. 

B:  Florida Floriculture	Soilborne diseases, weeds, and nematodes
including Fusarium spp., Rhizoctonia spp., Phytoplithora, Stromatinia,
Pythium spp., Erwinia, and most soil nematodes e.g. Meliodogyne spp.,
and previous crop propagules. Specific pest problems vary by individual
crop and variety.  	These diseases are common, abundant, and spread via
water, exacerbated by Florida’s regions of tropical and sub-tropical
climates. Due to the complexity of the ornamentals sector, alternative
pest control measures have not been found for all species but research
efforts are ongoing.  Iodomethane is now registered; however, other
methyl bromide alternatives preliminarily considered effective, such as
dimethyl disulfide, are not currently registered for use.  





APPENDIX C: STATUS OF METHYL BROMIDE ALTERNATIVES

Table C 1.  Reason for alternatives n ot being feasible  TC "Table C 1. 
Reason for alternatives n ot being feasible" \f F \l "1"  

Name of alternative	Technical and regulatory* reasons for the
alternative not being feasible or available

1,3-Dichloropropene (1,3-D) 	Technical

Controls nematodes but will not provide adequate control of diseases and
weeds at label rates.  

Regulatory

Buffer zones limit its use and township caps in Florida and California
further restrict its use in those states.  Mandated plant-back times can
be 1 to 2 weeks longer with 1,3-D than with other fumigants.  1,3-D is
not registered for use in greenhouses.

Chloropicrin	Technical 

Weed control is poorer than with methyl bromide Control of the entire
pest spectrum cannot be achieved with lower use rates, but there are
concerns about phytotoxicity to nearby plantings if greater than 2%
chloropicrin is used in a fumigant combination 

Regulatory 

There is concern over the real or perceived public exposure to higher
rates of  chloropicrin, especially in highly populated urban areas,  due
to increased worker exposure, offsite movement, and smells.

Metam sodium	Technical

Efficacy data is inconsistent, depending on soil type, moisture content,
and temperature.  

Regulatory

Metam sodium is not registered for use in greenhouses.

Iodomethane	Technical

More research needs to be done to understand application and long-term
efficacy issues.

Regulatory

Iodomethane is not registered for use in California.  Large buffer zones
and lower use rates may also prevent widespread adoption.

1,3-D + chloropicrin	Technical 

This alternative does not control the entire pest spectrum.

Regulatory

In California, 1,3-D + chloropicrin is considered one of tthe best
currently available alternatives, if label application rates were
increased Township caps and buffer zones that exist for the individual
chemicals also apply for the combination.  

Metam sodium + chloropicrin	Technical

This combination does not adequately control nematodes and weeds, and
performance is inconsistent.  

Regulatory

Restrictions and concerns existing for the individual chemicals also
apply for the combination.

1,3-D + metam sodium	Technical

Efficacy data is inconsistent. 

Regulatory

Restrictions for the individual chemicals also apply for the
combinations.

1,3-D + chloropicrin + metam sodium	Technical

Weed control is incomplete.

Regulatory

In California, 1,3-D + chloropicrin is considered the best currently
available alternative, if use restrictions, such as township caps, were
removed.  Restrictions existing for the individual chemicals also apply
for the combinations.

1,3-D + chloropicrin + herbicides	Technical

None.

Regulatory

Restrictions existing for the individual chemicals also apply for
combinations.

Dazomet	Technical:

Dazomet does not control the entire pest spectrum unless in combination
with 1,3-D, chloropicrin, and/or herbicides.

Regulatory:

Restrictions on 1,3-D and chloropicrin prevent the use of Dazomet as a
methyl bromide alternative.

Metam sodium + crop rotation	Technical

Treatment does not control the entire pest spectrum.

Regulatory 

Restrictions existing for metam sodium also apply to its use in
combination with other pest control measures.  

Steam

	Technical

Steam sterilization is not feasible in open field production due to the
need to remove the steam piping after application in order to
accommodate cultural management practices.  In greenhouses, steam has
been successfully used in previous decades as a pest control method.

 

Regulatory

None.  

Biological control agents	Technical

No biological controls have been developed to cover all of the pests.  

Regulatory

None.

Crop rotation	Technical:

Previous crops’ bulbs and corms often contaminate the following crop
as volunteer weeds or reservoirs for pathogens.  

Regulatory

None.

Herbicides	Technical:

Crop damage may occur from contact with certain herbicides or in the
following crop if soil residues remain.  

Regulatory

Restrictions for registered pesticides vary depending on the active
ingredient(s) and individual product labels.

Biofumigation	Technica:l

Biofumigation is still largely in the experimental stages.  Specific
brassicas as well as specific years yield variable amounts of activity. 
While this alternative may provide some control, the control of all
target pests is not sufficient.  

Regulatory:

None.  

Substrates	Technical:

The use of substrates is only technically feasible in greenhouses using
benches,

Regulatory

None. 

Dimethyl disulfide (DMDS)	Technical:

Studies are currently being conducted to test the efficacy of DMDS in
ornamentals under an Experimental Use Permit.

Regulatory:

DMDS is not currently registered in Florida or California, and its
future registration status is not known.

Acrolein	Technical:

Studies are currently being conducted to determine the efficacy of
acrolein for ornamentals.

Regulatory:

Acrolein is currently only registered as an aquatic herbicide and cannot
be used on soil for this use. Its future registration status is unknown.

Propargyl bromide	Technical:

More research is needed to understand its efficacy as a methyl bromide
alternative.

Regulatory:

This alternative is not currently registered and its future regulatory
status is unknown. 

Sodium azide	Technical:

More research is needed to understand its efficacy.

Regulatory:

This alternative is not currently registered and its future regulatory
status is unknown.

Muscador albus Strain QST 20779	Technical:

No commercially available formulation.

Regulatory:

None.

Ethane dinitrile (Cyanogen)	Technical:

Considered a viable alternative in Australia, no studies have been
conducted in the U.S. comparing efficacy with methyl bromide and other
alternatives.

Regulatory:

This product is not currently registered in the U.S. and its future
registration status is unknown.

Acidic electrolyzed oxidizing (EO) water	Technical:

EO water only controls foliar fungal diseases in greenhouse ornamentals.
No research has been conducted on this product as a pre-plant pesticide
in at least 6 years.

Regulatory:

There is no commercial development or planned registration of this
product currently.

Solarization	Technical:

Efficacy data is inconsistent between research trials. Regional
subclimates with significant cloud cover or cooler annual temperatures
will not receive enough degrees for solarization to be a feasible pest
control option. 

Regulatory:

None.

Furfural	Technical:

It does not control the entire pest spectrum.

Regulatory:

Furfural has a federal registration for ornamentals and non-food
commodities for greenhouse soil use only. However, it does not have
state registrations currently, and its future registration status is
unknown..



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

USA CUN13 SOIL Ornamentals Open Field and Protected Environments

