UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460



  SEQ CHAPTER \h \r 1 OFFICE OF

PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM

SUBJECT:	Assessment of the Benefits of Soil Fumigation with Chloropicrin
in Tobacco Production (DP# 337490)

FROM:	Sunil Ratnayake, Biologist

		Biological Analysis Branch

		Elisa Rim, Economist	

Economic Analysis Branch

Biological and Economic Analysis Division (7503 P)

THRU:	Arnet Jones, Chief 	

Biological Analysis Branch

Timothy Kiely, Chief 	

Economic Analysis Branch

Biological and Economic Analysis Division (7503 P)

TO:		John Leahy, Senior Policy Advisor

		Special Review and Reregistration Division (7508 P)

PRODUCT REVIEW PANEL DATE:  April 11, 2007

Summary

This assessment measures the benefit of chloropicrin use in tobacco
production in the Southern U.S., which comprises about 94% of total U.S.
production acreage.  The request to use methyl bromide in tobacco was
denied in 2006 critical use exemption process.  However, there is some
small remaining use of methyl bromide from existing stocks.  Metam
(metam sodium or metam potassium), chloropicrin, 1,3-dichloropropene,
and their combinations, are available as fumigants for tobacco growers.
Currently, the usage of metam is less than 1%.  Application of metam
sodium is not acceptable for early transplanting of tobacco due to the
long period of aeration required to avoid phytotoxicity.  Nationally,
chloropicrin is used in approximately 15% of tobacco production, which
is typically applied in combination with 1,3-dichloropropene (13% of
crop treated).  

Fumigants are mainly used to control a mix of nematodes and plant
pathogens.  The fumigant 1,3-dichloropropene is effective on nematodes,
but it is less effective on soil pathogens.  In contrast, chloropicrin
is effective on soil pathogens and it is less effective on controlling
soil nematodes.  

This analysis focuses on the benefits of chloropicrin as an effective
pre-plant fumigant to control major soil pathogens for field grown
tobacco growers. Yield losses due to plant diseases are estimated to be
from 6 to 7%. This estimate may vary depending on the severity of the
diseases.  Although tobacco nursery seedling production also uses
fumigants, such as methyl bromide, chloropicrin, and
1,3-dichloropropene, there is limited information on usage, yield
effects, revenues, and production costs of using these fumigants.  Thus,
the benefits on nursery production was not analyzed.  In North Carolina
alone (the largest user of fumigants), total cost savings are nearly $9
million annually for producers.  On a national level, there are
approximately 300,000 acres of field grown tobacco in the U.S. annually
and chloropicrin is applied to about 14% or over 58,000 acres.  The
total benefits of fumigation could be as much as $12 million/year in
improved yields on treated acres.   A significant portion of these
benefits accrue to consumers in the form of a more abundant supply and
lower prices.

Statement of Purpose

As part of the Reregistration Eligibility Decision (RED) process, EPA is
assessing the risks and benefits of the use of several soil fumigants as
a group:  chloropicrin, metam-potassium, metam-sodium, and methyl
bromide.  This document presents the assessment of the benefits to field
grown tobacco production that is provided by the soil fumigants,
particularly chloropicrin, the most widely used of these chemicals. 
Conceptually, the benefits of a pesticide like a soil fumigant are
comprised of the improvements in production and/or reductions in cost
resulting from the pesticide use.  The social benefits of a pesticide
are divided between the users of the pesticide, e.g., tobacco producers,
and consumers of tobacco and tobacco-containing products.  Consumers
benefit because higher production and/or lower costs translate into a
cheaper and more abundant supply of tobacco. The impact of fumigant
regulation on this consumer benefit is not explicitly evaluated in this
document.

In evaluating the benefits of soil fumigants, this document compares the
current situation in which fumigants are available for use, subject to
existing label restrictions, to the situation that is estimated to occur
were the fumigants not available.  This is somewhat different from other
BEAD assessments of the impacts of regulation, in that no specific
regulatory scheme is considered.

General background

This assessment focuses on field grown tobacco grown in the Southern
U.S. (North Carolina, Kentucky, Tennessee, South Carolina, Virginia, and
Georgia). Tobacco is the seventh largest cash crop in the United States.
 North Carolina, Kentucky, Tennessee, South Carolina, Virginia, and
Georgia are the major tobacco growing States (Table 1).  Tobacco
averages $1.6 billion in total value per year.  About 94% of production
is from the six major tobacco producing Southern States and these states
contribute about 91% of the value.  Tobacco in this region is grown in
open fields on plastic tarps.  A more detailed discussion of key
fumigant usage, key target pests, and impacts of changes in fumigant
availability is presented below.  Because of the small amount of
fumigant use in nursery tobacco production and limited data on that use,
this document does not evaluate nursery tobacco production systems. 

Field grown tobacco production in the U.S has been reduced due to the
legislative termination of the tobacco marketing quota and price
support.  According to a survey conducted by the USDA Economic Research
Service, the number of farms growing tobacco in the United States has
dropped from 512,000 in 1954 to 56,977 in 2002.  The average farm size
producing tobacco was  7.5 acres in 2002, compared with 9 acres in 1997
(1). Also, nationally, harvested tobacco acreage has dropped from
432,290 acres in 2001 to 298,080 acres in 2005 (Table 1).  

The key tobacco production areas based on data from the National
Agricultural Statistics Service (NASS), are described in Table 1. 
According to the 2005 figures, there are approximately 298,000 acres of
tobacco grown in the U.S.  Typical U.S. tobacco production is described
in Table 2.  Harvested acreage, yield per acre, total production,
percent of U.S. production, price, and value of production are given by
selected states and for the U.S.  The table covers more than 94% of U.S.
tobacco production. 

Table 1. Field Tobacco Acreage Grown by Selected State and U.S. Total, 
2001 – 2005

STATE	2001	2002	2003	2004	2005	Average

Georgia	26,100	26,500	27,000	23,000	16,000	23,720

Kentucky	115,700	111,100	111,650	114,950	79,700	106,620

North Carolina	161,700	168,300	159,700	156,100	126,000	154,360

South Carolina	32,000	30,500	30,000	27,000	20,000	27,900

Tennessee	39,690	35,900	31,140	30,260	22,950	31,988

Virginia	29,500	30,000	25,110	29,680	17,040	26,266

US TOTAL*	432,310	428,710	411,150	408,050	298,020	395,648

* Includes other field grown tobacco producing states which account for
6% of total tobacco acreage in the U.S.: Connecticut, Florida, Indiana,
Maryland, Massachusetts, Missouri, Ohio, Pennsylvania, West Virginia,
and  Wisconsin.

Source: USDA/NASS Crop Production 2003 and 2005 Summary, January, 2004
and 2006 (7). Available at:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPr
odSu-01-12-2006.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPro
dSu-01-12-2006.pdf  and
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2004/CropPro
dSu-01-12-2004.pdf

Table 2. Field Tobacco Harvested acreage, yield, production, percent of
U.S. production, price, and value of production by Selected State,
2001~2005 Average

STATE	Harvested Acreage	Average

Yield/Acre	Production	% of US Production	Price Per Pound	Value of
Production

	(Acres)	(Pounds)	(1,000 pounds)	(%)	($/Pound)	($1,000 dollars)

Georgia	23,720	2,105	50,741	6%	$    1.765	$       91,495

Kentucky	106,620	2,073	220,990	26%	$    1.954	$    435,098

North Carolina	154,360	2,159	332,859	40%	$    1.770	$    593,281

South Carolina	27,900	2,190	61,265	7%	$    1.744	$    108,250

Tennessee	31,988	2,161	68,967	8%	$    2.039	$    141,014

Virginia	26,266	2,090	54,753	7%	$    1.791	$       99,401

US TOTAL*	395,648	2,120	838,811	100%	$    1.899	$ 1,604,963

* Includes other field grown tobacco producing states which account for
9% of total tobacco value of production in the U.S.: Connecticut,
Florida, Indiana, Maryland, Massachusetts, Missouri, Ohio, Pennsylvania,
West Virginia, and  Wisconsin.

Source: USDA/NASS Crop Values Annual Summary 2003 and 2005, February
2006 and March 2004.  Available at:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/CropValuSu//2000s/2006/CropVa
luSu-02-15-2006.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/CropValuSu//2000s/2006/CropVal
uSu-02-15-2006.pdf  and
http://usda.mannlib.cornell.edu/usda/nass/CropValuSu//2000s/2004/CropVal
uSu-03-31-2004.pdf

Use of Fumigants

The following section provides a summary of our understanding of the use
of fumigants in field grown tobacco production.  In preparing this
summary, we referred to all available pesticide use data for the period
2001 to 2005.  These included data from the U.S. Department of
Agriculture, National Agricultural Statistics Service (NASS),
information provided in methyl bromide critical use nomination packages,
and proprietary pesticide use data.  It is worth noting that these
sources are frequently divergent.  For this reason, we have reviewed
each of the sources carefully and have used what we concluded to be the
most appropriate and accurate information.  Thus, the data provided
below reflects an element of professional judgment.  It may therefore be
difficult to independently calculate the same estimates of fumigant use.
 Nonetheless, the following data provides insight into the extent and
general importance of fumigants in tobacco production.

State	Active Ingredient	% Acres Treated	Acres Treated	Pounds Applied

North Carolina	Chloropicrin	28%	              42,900 	         1,185,400


	1,3 Dichloropropene	20%	              30,600 	         2,441,900 

	Methyl Bromide	5%	                7,100 	            347,900 

Kentucky	Chloropicrin	Less than 1%	                    100 	            
   1,900 

	Methyl Bromide	Less than 1%	                     100 	               
3,900 

Tennessee	Chloropicrin	5%	                1,654 	            132,900 

	Dichloropropene	Less than 1%	Less than 100	                2,900 

South Carolina	Chloropicrin	34%	                9,500 	           
269,400 

	1,3Dichloropropene	31%	                8,600 	            601,100 

	Methyl Bromide	1%	                   300 	              16,500 

	Metam	2%	                   600 	              36,600 

Virginia	Chloropicrin	9%	                2,400 	              53,600 

	1,3Dichloropropene	6%	                1,600 	            119,800 

	Methyl Bromide	2%	                   500 	              18,300 

	Metam	2%	                   600 	              43,700 

Georgia	Chloropicrin	3%	                   800 	              10,600 

	1,3 Dichloropropene 	31%	                7,500 	            511,700 

	Methyl Bromide	1%	                   400 	                5,100 

United States	Chloropicrin	15%	              58,600 	         3,700,000 

	1,3Dichloropropene	13%	              50,900 	         1,400,000 

	Methyl Bromide	Less than 1%	                2,800 	            200,000 

	Metam	Less than 1%	                   600 	              40,000 

	US TOTAL1	15%	58,600	         5,340,000

Table 3 provides an overview of fumigants used on tobacco.  Over 5
million pounds of fumigants are used on tobacco per year in the U.S. 
Metam sodium and methyl bromide each have less than 1% of the acres
treated in the U.S.  1,3-dichloropropene is applied to approximately 13%
of the tobacco acreage. Nationally, chloropicrin, which is often used in
combination with methyl bromide, metam-sodium, or 1,3-dichloropropene,
is applied to 15% of the tobacco crop acreage.  In total, approximately
15% of the U.S. tobacco crop is treated with one or more fumigants.  

Table 3.  Fumigants Usage on Field Tobacco (2001-2005)

1% US total takes into consideration the overlapping of fumigants used
on acres.

Source: EPA Proprietary Data (5), NASS Pesticide Use Reports (8)
USDA/NASS Crop Production 2003 and 2005 Summary, January, 2004 and 2006.
Available at:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPr
odSu-01-12-2006.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPro
dSu-01-12-2006.pdf  and   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2004/CropPr
odSu-01-12-2004.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2004/CropPro
dSu-01-12-2004.pdf  

Tobacco is very sensitive to pathogenic interactions and as such, yields
can be reduced by minor interactions.  Leaf aesthetics are very
important in the values of the crop since the sale of the crop is
dependant upon the visual appearance at tobacco auctions.  Fumigants are
applied at two occasions and in two places during tobacco production. 
First, fumigants are applied in nursery seedling beds and second in the
fields, where transplants are to be planted.  

Nursery Production

About 85% of field grown tobacco is transplanted into the field as
seedlings produced in greenhouses or in plastic-covered outdoor plant
beds (2).  Most transplant production has switched to a float system for
tobacco seedlings which has reduced the use of soil fumigants in tobacco
production.  Methyl bromide is the only fumigant used in float systems. 
The use of methyl bromide as a soil fumigant was phased out in the U.S.
in 2005 except for critical use exemption holders.  Furthermore, the
requests to use methyl bromide in nursery tobacco for float systems and
nursery beds were not allowed since the 2006 methyl bromide critical use
exemption.   Therefore, methyl bromide will not be available for the
nursery seedling tobacco growers, although there is no data on current
fumigation practices or alternative fumigation practices.  Seed bed
seedling production occurs on relatively small areas of land.  In a farm
with 4 acres of tobacco production, about 0.06 acres of land is
allocated for the seedling production (6).  Approximately, 60 square
feet of greenhouse space produce enough plants for transplanting a one
acre area in the field.  However, an area of 720 square feet of outdoor
plant beds is needed to produce plants for planting of one acre area in
the field (2).  Since, usage and production information on nursery
seedbeds is difficult to differentiate from normal field production, an
analysis was not performed.

Field Production

Tobacco is grown on a wide variety of soils, from very sandy to clay.
However, the maximum yields are obtained in sandy loam soils with high
organic content (2).  Nitrogen content in soil must be low after
flowering, for a successful, high quality tobacco production. 
Approximately 90 percent of the crop is grown at least with a two-year
crop rotation (2).  Flue-cured tobacco is grown on a high, wide row beds
to allow good drainage and aeration and most of the burley tobacco is
grown on leveled fields.  

In tobacco field production, fumigants are applied in the fields to
control nematodes, weeds, and soil pathogens.  Soil pathogens cause
major diseases such as black rot, black shank, fusarium, and grainville
wilt (2).  Once the planting beds are prepared in the Spring, soil
fumigants are shank injected to the soil at recommended rates and beds
are covered with polyethylene to increase the efficacy and to reduce the
emission to the environment.  Fumigants are shank injected into soil.
Generally, seedlings are transplanted in the field in April to May and
once the seedlings are transplanted in the field developing flower heads
are removed (topped) to increase yield and leaf quality. This may be
done by hand or mechanically. Since tobacco is a terminally dominant
plant, removal of flower heads induces growth of lateral shoots
(suckers). Mostly, sucker production is controlled chemically, but some
manual clean-up is usually required. Harvest of flue-cured tobacco is
accomplished 2 to 3 times per crop cycle. The ripest (lowest) leaves are
removed mechanically or by hand.

Regions described

This assessment will assess the benefit of fumigant use on field grown
tobacco in the Southern U.S. (Georgia, Kentucky, North Carolina, South
Carolina, Tennessee, and Virginia).  Although tobacco nursery seedling
production also uses fumigants, such as methyl bromide, chloropicrin,
and 1,3-dichloropropene, there is limited information on usage and yield
effects using these fumigants, as well as revenue and production cost
information, thus the benefits on nursery production will not be
analyzed.  

fumigation characteristics

Target Pests 

Fumigants are used alone or in combination in the Southern U.S. to
control mainly, the following diseases and nematodes in field grown
tobacco production (Table 4).  

Table 4. Key diseases and Pests

Region 	Key diseases, and Pests  

Southeast U.S. 

(North Carolina, Kentucky, Tennessee, South Carolina, Virginia, and
Georgia)	

Soil Pathogens:  Rhizoctonia spp., Phythium spp., Phytophthora
parasitica nicotianae 

Soil Nematodes: M. incognita, M. Javainca. M. arenaria



Source (2, 3, 4)

Use Characteristics

Table 5 provides information on the general pests controlled by
fumigants and fumigant combinations.  Table 6 provides information
characterizing typical fumigant use in field grown tobacco production. 
Currently, 1, 3 dichloropropene, chloropicrin, metam sodium and their
combinations are available for tobacco growers. Chloropicrin is
generally not used alone it is mixed with other fumigants such as
1,3-dichloropropene.  In the southern U.S. the primary fumigant is
1,3-dichloropropene mixed with chloropicrin (Table 3).   

Table 5. Characteristics of Fumigants and Fumigant Combinations 

Chemical	Characteristics

1, 3 dichloropropene 	Effective against nematodes less effective against
fungal plant pathogens. 

Metam sodium	Effective against fungal pathogens, but needs a longer
aeration period.

Chloropicrin	Effective against many soil pathogens, not effective
against nematodes when applied alone.

1,3 dichloropropene + Chloropicrin	Effective against nematodes and
fungal pathogens.

Source (6)

Table 6.  Fumigant Application In Field Grown Tobacco Production

Application Rate 

(lb ai/acre)	Chloropicrin 	102 pounds  per acre 

	1,3 – Dichloropropene 	89.5 pounds per acre

	Metam Sodium	90 to  252 pounds per acre

Acres Treated per Day	 10 to  40 acres per tractor

Time of Fumigation	 Oct – Dec

Application Method	Primarily shank injected under tarp

Method of Application	Primarily strip 

Tarps or Water Caps	HDPE tarp

Source (6, 8)

Chemical Control Alternatives

Chemical Control Practices

In the Southern U.S., the chemical alternatives to chloropicrin would be
1,3-dichloropropene or metam sodium.  Application of metam sodium is not
acceptable for early transplanting of tobacco due to the long period of
aeration required to avoid phytotoxicity.  This could lead to a late
planting of seedlings in the field exposing the crop for diseases.
Generally, 1,3-dichloropropene is effective on nematodes, but it is less
effective on soil pathogens. In contrast, chloropicrin is effective on
soil pathogens and it is less effective in controlling soil nematodes.
Therefore, if chloropicrin were unavailable, an effective pre-plant
fumigant to control major soil pathogens would not be available for
tobacco growers.  

Cultural Control Practices

Solarization of soil: Consistent effectiveness is not achieved by this
method and effectiveness depends upon meteorological conditions. 
Generally, an adequate sunlight condition does not exist prior to
seedbed preparation. Therefore, solarization must be done in the
previous summer or fall.

Steam sterilization of soil: Not readily available for farm use and the
equipment is expensive.

Crop rotation/fallow:   Strongly recommended and usually practiced.
However, crop rotation alone is not adequate to control the fungal
pathogens Pythium and Rhizoctonia spp.  Rotated sites also can be
recontaminated.  

Physical removal/sanitation: Not effective and completely disease free
beds are required for a successful crop production

Resistant cultivars:  Already used but not sufficient enough to control
all the soil pathogens found in field conditions. 

Benefits of Fumigaton 

Yield and Quality 

Yield loss information due to soil pathogens in the field production of
tobacco is limited in the literature. In North Carolina, diseases caused
an average yield loss of 6 to 7 % in 1996 and 1997 (2).  Depending on
the environmental conditions and disease pressure this estimate can vary
significantly and may not represent the yield losses due to soil
pathogens in other tobacco producing areas. 

Economic Benefits

In the following section we evaluate the benefits of chloropicrin on the
economic viability of tobacco producers.  BEAD uses a partial budget
analysis to estimate the impacts of changes in production.  That is, we
evaluate the consequences on a typical acre of the crop grown, rather
than attempt to assess the impacts in the context of a whole enterprise,
which could include multiple crops under cultivation.  This approach
allows the Agency to compare losses to net operating revenue, which is
defined as the difference between gross revenue and variable operating
costs, on a per-acre basis.  The analysis ignores fixed costs, which are
highly dependent on land ownership and the size and diversity of the
grower’s operation, and therefore difficult to define on a per-acre
basis.  As such, this analysis may understate the impacts as a
percentage of the grower’s income.  BEAD used North Carolina as a
representation of all areas that grow tobacco because it is the largest
producer of field grown tobacco.

Benefits of chloropicrin in North Carolina tobacco production are
summarized in Table 7.

Table 7.  Economic Analysis of North Carolina Tobacco Production

	1,3-Dichloropropene + chloropicrin	1,3-Dichloropropene 

Estimated Yield Loss	0%	7%

Yield (pounds)	2,159	2,008

Price per pound	$2	$2

Gross Revenue  	$4,102	$3,815

Total Operating Costs  	$2,687	$2,687

Net Operating Revenue  	$1,415	$1,215

Percentage Change in Net Operating Revenue	0%	-14%

Source:  NC State University: Flue-Cured Tobacco – Machine Harvest
East - 2006. Available at:
http://www.ces.ncsu.edu/depts/agecon/tobacco_econ/budgets/Tobmach-2006.p
df

Without the use of chloropicrin, North Carolina tobacco producers may
experience the losses presented in Table 7.  This would apply to that
part of the North Carolina tobacco acreage that is treated with one or
more fumigants, about 28% or 42,900 acres (Table 3).  Chloropicrin use
on these areas represents benefits of about $9 million
($200/acre*42,900acres) or over 6 million pounds (151*42,900 acres) of
tobacco production annually (Table 2).  Given that tobacco acreage can
be put to a different use, such as producing a different crop, these
benefits may ultimately be somewhat less.

National Benefits

There are approximately 300,000 acres of tobacco grown in the U.S.
annually.  Approximately 15% of tobacco producing acres uses
chloropicrin.  Chloropicrin use on these areas represents benefits of
almost $12 million ($200/acre*58,600acres) in total value of production
or over 9 million pounds (151 lbs/acre*58,600acres) of field grown
tobacco.  Again, tobacco acreage could be put to a different use, such
as producing a different crop; these benefits could be somewhat less on
a national scale as well.

CONCLUSIONS

There are over 300,000 acres of tobacco harvested in the U.S. annually. 
From these acres, over 800 million pounds of tobacco are harvested,
worth approximately $1.6 billion.  Tobacco producers rely on fumigants,
or in this case chloropicrin, for disease control.  These pests can be
very damaging, and fumigation prevents yield losses from these pests. 
Approximately 15% of tobacco producing acreage relies on fumigants to
maintain current yield levels.  The annual value of fumigant use in U.S.
tobacco production is estimated to be $12 million, which is the
resulting increase in total value of production from fumigant use in
tobacco production.  This benefit is shared by tobacco producers and
consumers.  Again, since tobacco acreage could be put to a different
use, such as producing a different crop, these benefits could be
somewhat less. 

Limitations to this assessment

This document presents the assessment of the benefits provided by
chloropicrin in the production of tobacco.  The following are
limitations of this analysis:

Compared with other tobacco producing States, North Carolina has the
highest tobacco production acreage treated with soil fumigants. In this
assessment, due to lack of information form other states, potential
yield loss estimates of using 1,3-dichloropropene alone collected from
North Carolina were used to assess the yield losses of other states.
These estimates may not be precise enough for the yield loss estimates
in other States. Pest problems and pest pressure found in North Carolina
may not be exactly similar to other states. Therefore, BEAD is
requesting the information listed in the Appendix 1 during the comment
period.  

  

Social benefits of pesticide use accrue to several groups, e.g., tobacco
producers and consumers of tobacco.  This document considers the
benefits of fumigant use from the perspective of tobacco producers, and
does not account for benefits accrued to other parties.

The assessment does not account for transition to new agronomic
practices such as a conversion to float tray system production,
introduction of new growing areas, or the introduction of newer as yet
unregistered fumigants.  

The assessment is based on partial budget analysis and does not account
for price or income distribution effects resulting from changes in
supply. 

REFERENCES

1)  Capheart, 2004. Trends in U.S. Tobacco Farming.  Out Look, United
States Department of Agriculture.  Accessible at:   HYPERLINK
"http://www.ers.usda.gov/publications/tbs/nov04/tbs25702/tbs25702.pdf" 
http://www.ers.usda.gov/publications/tbs/nov04/tbs25702/tbs25702.pdf  .

2)  Crop profile for tobacco in North Carolina.  1999.   HYPERLINK
"http://www.ipmcenters.org/CropProfiles/docs/nctobacco.html" 
http://www.ipmcenters.org/CropProfiles/docs/nctobacco.html .

3)  Crop profiles for tobacco in Virginia 2001.    HYPERLINK
"http://cipm.ncsu.edu/cropprofiles/docs/vatobacco.html" 
http://cipm.ncsu.edu/cropprofiles/docs/vatobacco.html .

4)  Crop profile for tobacco in Kentucky.  2003.    HYPERLINK
"http://www.ipmcenters.org/CropProfiles/docs/KYtobacco.html" 
http://www.ipmcenters.org/CropProfiles/docs/KYtobacco.html .

5)  EPA Proprietary Data (2001-2005)

6)   Methyl Bromide Critical Use Exemption. 2005. United States
Environment  Protection Agency.

7)  USDA NASS.  2002-2006. Crop Production, Summary.  National
Agricultural Statistics Service, U.S. Department of Agriculture,
January, Available at:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPr
odSu-01-12-2006.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2006/CropPro
dSu-01-12-2006.pdf  and
http://usda.mannlib.cornell.edu/usda/nass/CropProdSu//2000s/2004/CropPro
dSu-01-12-2004.pdf.

8)  USDA NASS.  2005.  Agricultural Chemical Usage. 2004.  Field Crops
Summary.  National Agricultural Statistics Service, U.S. Department of
Agriculture, May, at   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/nass/AgriChemUsFC//2000s/2005/Agri
ChemUsFC-05-18-2005.pdf" 
http://usda.mannlib.cornell.edu/usda/nass/AgriChemUsFC//2000s/2005/AgriC
hemUsFC-05-18-2005.pdf . 

APPENDIX I.  Information BEAD Expects to Collect During the Comment
Period.

1) 	Information on tobacco yield losses with or without fumigants due to
soil pathogens, nematodes, or weeds from tobacco producing States.

 

2) 	Information on severity of soil pathogens and nematodes in tobacco
producing states.

3)      	Percentage of growers using floating and seed bed seedling
production systems and the information on the effectiveness and problems
involved with alternative fumigation methods such as use of steam, dry
heat, and other disinfectants.

 

4)      	Research information on the use of metam-sodium and other
chemicals as potential soil fumigants from major tobacco producing
States.

 

5)       	Research information on aeration time and best application
timing of metam to avoid phytotoxicity and residual effects in soilbed
tobacco seedling production. 

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