METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE FOR TOMATO GROWN IN OPEN FIELDS NOMINATING PARTY: The United States of America BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Pre plant Soil Use for Tomato Grown in Open Fields 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: 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.

X Yes

No CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Tina E. Levine, Ph. D. Title: Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 FOR ADMINISTRATIVE PURPOSES ONLY: DATE RECEIVED BY OZONE SECRETARIAT:

YEAR: CUN: ii U. S. A. Telephone: ( 703) 308 3099 Fax: ( 703) 308 8090 E mail: levine. tina@ 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 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat iii TABLE OF CONTENTS PART A: SUMMARY ____________________________________________________________ 7 1. Nominating Party _________________________________________________________ 7 2. Descriptive Title of Nomination______________________________________________ 7 3. Crop and Summary of Crop System___________________________________________ 7 4. Methyl Bromide Nominated _________________________________________________ 7 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 8 6. Summarize Why Key Alternatives Are Not Feasible______________________________ 9 7. Proportion of Crops Grown Using Methyl Bromide _____________________________ 10 8. Amount of Methyl Bromide Requested for Critical Use __________________________ 11 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 12 Region A  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 13 Region A  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 13 Region A  11. Characteristics of Cropping System and Climate _____________________ 14 Region A  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 16 REGION A  PART C: TECHNICAL VALIDATION ______________________________________ 17 Region A  13. Reason for Alternatives Not Being Feasible _________________________ 17 Region A  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 19 Region A  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 19 Region A  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 19 Region A  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 20 Region A  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 20 Region A  Summary of Technical Feasibility ____________________________________ 21 Region B  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 21 Region B  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 21 Region B  11. Characteristics of Cropping System and Climate______________________ 22 Region B  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 23 REGION B  PART C: TECHNICAL VALIDATION ______________________________________ 24 Region B  13. Reason for Alternatives Not Being Feasible _________________________ 24 Region B  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 25 Region B  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 26 iv Region B  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 26 Region B  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 27 Region B  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 28 Region B  Summary of Technical Feasibility ____________________________________ 28 Region C  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 28 Region C  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 28 Region C  11. Characteristics of Cropping System and Climate______________________ 29 Region C  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 30 REGION C  PART C: TECHNICAL VALIDATION ______________________________________ 31 Region C  13. Reason for Alternatives Not Being Feasible _________________________ 31 Region C  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 33 Region C  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 34 Region C  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 36 Region C  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 36 Region C  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 37 Region C  Summary of Technical Feasibility ____________________________________ 38 PART D: EMISSION CONTROL ___________________________________________________ 39 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 39 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 39 PART E: ECONOMIC ASSESSMENT________________________________________________ 40 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 40 22. Gross and Net Revenue___________________________________________________ 41 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 42 Summary of Economic Feasibility _____________________________________________ 43 PART F. FUTURE PLANS _______________________________________________________ 47 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 47 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 48 25. Additional Comments on the Nomination ____________________________________ 49 26. Citations ______________________________________________________________ 50 APPENDIX B. SUMMARY OF NEW APPLICANTS ___________ Error! Bookmark not defined. v LIST OF TABLES PART A: SUMMARY _____________________________________________________________ 7 Table 4.1: Methyl Bromide Nominated ____________________________________________ 7 Table A. 1: Executive Summary for Tomatoes _______________________________________ 9 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 10 Region A  Table 8.1: Amount of Methyl Bromide Requested for Critical Use ____________ 11 Region B  Table 8.2: Amount of Methyl Bromide Requested for Critical Use ____________ 11 Region C  Table 8.3: Amount of Methyl Bromide Requested for Critical Use ____________ 12 Table A. 2: 2006 Sector Nomination ______________________________________________ 13 REGION A  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 13 Region A  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 13 Region A  Table 11.1: Characteristics of Cropping System ___________________________ 14 Region A  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 14 Region A  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 16 REGION A  PART C: TECHNICAL VALIDATION ________________________________________ 17 Region A   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 17 Region A   Table 14.1: Technically Infeasible Alternatives Discussion __________________ 19 Region A   Table 15.1: Present Registration Status of Alternatives _____________________ 19 Region A   Table 16.1: Effectiveness of Alternatives   Key Pest 1 _____________________ 20 Region A   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 20 REGION B  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 21 Region B  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 21 Region B  Table 11.1: Characteristics of Cropping System ___________________________ 22 Region B  Table 11.2 Characteristics of Climate and Crop Schedule____________________ 22 Region B  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 23 REGION B  PART C: TECHNICAL VALIDATION ________________________________________ 24 Region B   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 24 Region B   Table 14.1: Technically Infeasible Alternatives Discussion __________________ 25 Region B   Table 15.1: Present Registration Status of Alternatives _____________________ 26 Region B   Table 16.1: Effectiveness of Alternatives   Key Pest 1 _____________________ 26 Region B   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 27 REGION C  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 28 Region C  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 28 Region C  Table 11.1: Characteristics of Cropping System ___________________________ 29 Region C  Table 11.2 Characteristics of Climate and Crop Schedule____________________ 29 Region C  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 30 REGION C  PART C: TECHNICAL VALIDATION ________________________________________ 31 Region C   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 31 Region C   Table 14.1: Technically Infeasible Alternatives Discussion __________________ 33 Region C   Table 15.1: Present Registration Status of Alternatives _____________________ 34 Region C   Table 16.1: Effectiveness of Alternatives   Key Pest 1 _____________________ 36 Region C   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 36 PART D: EMISSION CONTROL ____________________________________________________ 39 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 39 PART E: ECONOMIC ASSESSMENT _________________________________________________ 40 vi Table 21.1: Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______ 40 Table 22.1: Year 1 Gross and Net Revenue ________________________________________ 41 Table 22.2: Year 2 Gross and Net Revenue ________________________________________ 41 Table 22.3: Year 3 Gross and Net Revenue ________________________________________ 41 California  Table E. 1: Economic Impacts of Methyl Bromide Alternatives _______________ 42 Michigan  Table E. 2: Economic Impacts of Methyl Bromide Alternatives _______________ 42 Southeastern US  Table E. 3: Economic Impacts of Methyl Bromide Alternatives _________ 43 PART F. FUTURE PLANS ________________________________________________________ 47 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 52 Page 7 PART A: SUMMARY 1. NOMINATING PARTY:

The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Pre plant Soil Use for Tomato Grown in Open Fields 3. CROP AND SUMMARY OF CROP SYSTEM Tomato Crops Grown in Open Fields for Fruit. In California, Michigan and South Eastern United States ( Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, North Carolina, South Carolina, Tennessee). These crops are grown in open fields on plastic tarps, often followed by various other crops. Harvested fruit is destined for the fresh market.

4. METHYL BROMIDE NOMINATED:

TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA) 2006 2,931,879 19,839 Page 8 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE Currently registered alternatives to methyl bromide do not consistently provide effective control of nutsedge weed species and more time is needed to evaluate relationship between fumigant alternatives, various mulches, and herbicide systems under different growing conditions.

The US nomination is only for those areas where the alternatives are not suitable. In US tomato production there are several factors that make the potential alternatives to methyl bromide unsuitable. These include:  pest control efficacy of alternatives: the efficacy of alternatives may not be comparable to methyl bromide in some areas, making these alternatives technically and/ or economically infeasible for use in tomato production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for tomato where the key pest pressure is moderate to high such as nutsedge in the Southeastern US.  regulatory constraints: e. g., telone use is limited in California due to townships caps and in Florida due to the presence of karst geology.  delay in planting and harvesting: e. g., the plant back interval for telone+ chloropicrin is two weeks longer than methyl bromide+ chloropicrin, and in Michigan an additional delay would occur because soil temperature must be higher to fumigate with alternatives. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices.  unsuitable topography: e. g., alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant. Page 9 TABLE A. 1: EXECUTIVE SUMMARY FOR TOMATOES *

Region California Region Michigan Region South Eastern United States AMOUNT OF NOMINATION 2006 Kilograms 102,058 10,745 2,799,236 Application Rate ( kg/ ha) 105 48 150 Area ( ha) 971 223 18,645 AMOUNT OF APPLICANT REQUEST 2005 Kilograms 102,058 32,214 4,640,896 Application Rate ( kg/ ha) 105 48 155 Area ( ha) 971 668 29,959 2006 Kilograms 102,058 31,606 4,519,689 Application Rate ( kg/ ha) 105 48 150 Area ( ha) 971 656 30,104 ECONOMICS FOR NEXT BEST ALTERNATIVE Technically Feasible Alternative ( s) METAM SODIUM 1,3 D + PIC 1,3 D + PIC Production Loss (%) 15% 6% 6%

Loss per hectare ( US$/ ha) $ 8,618 $ 6,113 $ 5,708 Loss per kg Methyl Bromide ( US$/ kg) $ 82 $ 127 $ 38 Loss as % of Gross Revenue (%) 10% 15% 14%

Loss as % of Net Revenue (%) 26% 65% 39% * See Appendix A for complete description of how the nominated amount was calculated.

6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

Research results confirm that methyl bromide alternatives options provide inconsistent control of nutsedge weed species. Nutsedge is an extremely competitive weed in tomato and can cause significant yield losses in the Southeast. Methyl bromide alternatives also provide incomplete control of soil pathogens in Michigan.

In addition, there is a regulatory prohibition on the use of 1,3 D on karst topography in the South Eastern United States. In Michigan, 1,3 D can only be used when soil temperature are higher than required for using methyl bromide, and this results in a planting/ harvesting/ marketing delay. In California, alternatives that must be applied with drip irrigation may not be suitable in areas with rolling or sloped topography due to uneven distribution of the fumigant. Page 10 7. ( i) PROPORTION OF CROPS GROWN USING METHYL BROMIDE TABLE 7.1: PROPORTION OF CROPS GROWN USING METHYL BROMIDE REGION WHERE METHYL BROMIDE USE IS REQUESTED TOTAL CROP AREA AVERAGE OF 2001 AND 2002 ( HA) PROPORTION OF TOTAL CROP AREA TREATED WITH METHYL BROMIDE IN 2002 (%) California Region 15,479 6 Michigan Region 749 88 South Eastern United States 31,270 99 NATIONAL TOTAL : * 51,506 63 * National total includes other regions not requesting methyl bromide 7. ( ii) IF ONLY PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE THERE.

The primary reason that some tomatoes may be grown without methyl bromide in all three regions is the absence of key target pests ( i. e., nutsedge in the Southeast, soil pathogens in Michigan, and pathogens and nematodes in California).

In Florida, areas without karst geology and having low nutsedge pressure can successfully employ a fumigation system relying on 1,3 D and chloropicrin.

In Michigan, the majority of tomato producing acres do not have Phytopthora spp., and do not use methyl bromide.

In California, areas with flat terrain successfully employ 1,3 D with chloropicrin as a fumigant.

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?

No, areas that use methyl bromide do so because hilly terrain, cold soil temperatures, and heavy pest pressure preclude the use of fumigants that are employed when these conditions are not present. Page 11 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE CALIFORNIA REGION  TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: California Region YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 102,058 102,058 USE: BROAD ACRE OR STRIP/ BED TREATMENT FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67/ 33 67/ 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 971 971 APPLICATION RATE ( kg/ ha) FOR THE ACTIVE INGREDIENT 105 105 APPLICATION RATE ( kg/ ha) FOR THE FORMULATION 157 157 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 10.5 10.5 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 15.7 15.7 MICHIGAN REGION  TABLE 8.2: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Michigan Region YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 32,214 31,606 USE: BROAD ACRE OR STRIP/ BED TREATMENT Strip/ Bed Strip/ Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE 67/ 33 67/ 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 668 656 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 48* 48*

APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 71.6* 71.6*

DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 13.1 13.1 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 19.5 19.5 * Only 36.7% percent of an hectare receives this amount of methyl bromide formulation. Page 12 SOUTH EASTERN UNITED STATES*  TABLE 8.3: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: South Eastern United States YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 4,640,896 4,519,689 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Mostly Strip/ Bed Mostly Strip/ Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE Mostly 67/ 33 Mostly 67/ 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 29,959 30,104 APPLICATION RATE ( kg/ ha) FOR THE ACTIVE INGREDIENT 155 150 APPLICATION RATE ( kg/ ha) FOR THE FORMULATION 231 224 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 15.5 15.0 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 23.1 22.4 * Includes Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, North Carolina, South Carolina, and Tennessee.

9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION:

The amount of methyl bromide nominated by the US was calculated as follows:

  The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request. Values greater than 100 percent are due to the inclusion of additional varieties in the applicant's request that were not included in the USDA National Agricultural Statistics Service surveys of the crop.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses methyl bromide were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted. The three applicants that included growth in their request had the growth amount removed.   Quarantine and pre shipment ( QPS) hectares is the area in the applicant's request subject to QPS treatments. Not applicable in this sector.   Only the acreage experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure, regulatory impacts, karst topography, buffer zones, unsuitable terrain, and cold soil temperatures. Page 13 TABLE A. 2: 2006 SECTOR NOMINATION *

2006 ( Sector) Nomination California Region Michigan Region South Eastern United States Requested Hectares ( ha) 971 656 31,104 Requested Application Rate ( kg/ ha) 105 48 150 Applicant Request for 2006 Requested Kilograms ( kg) 102,058 31,606 4,519,688 Nominated Hectares ( ha) 971 223 18,645 Nominated Application Rate ( kg/ ha) 105 48 150 CUE Nominated for 2006 Nominated Kilograms ( kg) 102,058 10,745 2,799,236 Overall Reduction (%) 37 Total 2006 U. S. CUE Nominated Kilograms ( kg) 2,931,879 Research Amount ( kg) 5,501 2006 Sector Nomination Totals Total 2006 U. S. Sector Nominated Kilograms ( kg) 2,937,380 * See Appendix A for complete description of how the nominated amount was calculated.

CALIFORNIA REGION  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE CALIFORNIA REGION  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST CALIFORNIA REGION  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED California Fusarium wilt Verticillium wilt Root Knot nematodes Pythium spp. Registered alternatives do not provide consistent, efficient and economical control of listed pests. Page 14 CALIFORNIA REGION  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE CALIFORNIA REGION  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS CALIFORNIA REGION CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplants for tomato fruit production ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Tomato   Strawberry or Barley or fallow SOIL TYPES: ( Sand, loam, clay, etc.) Sandy to Loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Annual OTHER RELEVANT FACTORS: No additional information was provided CALIFORNIA REGION  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( Plant Hardiness Zone) 9A, 9B, 10A RAINFALL ( mm) 0.25 0.00 0.25 3.05 51.8 2.29 OUTSIDE TEMP. ( ° C)* 17.8 20.5 22.2 20.0 14.4 11.7 FUMIGATION SCHEDULE ( DATES) X X X X X PLANTING SCHEDULE ( DATES) X X X X KEY MARKET WINDOW ( DATES) X X X X X X * Norton et al., 2000. Page 15 CALIFORNIA REGION   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Telone fumigation controls nematodes. Chloropicrin controls fungal pathogens. A combination of telone and chloropicrin may be a technically feasible alternative for methyl bromide on flat terrain. However, this CUE is only for hilly, rolling terrain where these alternatives would not be uniformly distributed by the irrigation systems.

Metam sodium alone or metam sodium plus chloropicrin will not control root knot nematodes. In addition, rolling field topography having varied soil textures does not allow uniform application of metam sodium. This may result in pockets of high and low concentrations of metam sodium. High concentrations of metam sodium can be phytotoxic to the tomatoes, limiting its usefulness as an alternative in areas of hilly or rolling terrain. The surviving fungal pathogen populations can build up quickly to kill tomato plants ( Burnette, 2003). Page 16 CALIFORNIA REGION  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED CALIFORNIA REGION  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 994 1,039 1,087 1,089 1,080 900 RATIO OF FLAT FUMIGATION USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED 100% flat fumigation 100% flat fumigation 100% flat fumigation 100% flat fumigation 100% flat fumigation 100% flat fumigation AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 125,359 125,318 125,964 126,236 123,783 97,775 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Mostly Shank at 25 30 cm depth Mostly Shank at 25 30 cm depth Mostly Shank at 25 30 cm depth Mostly Shank at 25 30 cm depth Mostly Shank at 25 30 cm depth Mostly Shank at 25 30 cm depth APPLICATION RATE OF ACTIVE INGREDIENT IN kg/ ha* 126 121 116 116 115 109 APPLICATION RATE OF FORMULATIONS IN kg/ ha* 188 181 173 173 172 163 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2) 12.6 12.1 11.6 11.6 11.5 10.9 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 18.8 18.1 17.3 17.3 17.2 16.3 * It is based on formulation containing 67% methyl bromide. Page 17 CALIFORNIA REGION  PART C: TECHNICAL VALIDATION CALIFORNIA REGION  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE CALIFORNIA REGION   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Telone Effective against nematodes but not against fungal plant pathogens. Not effective on hilly, rolling terrain. No Metam sodium Effective against fungal plant pathogen if applied uniformly. The petitioner states that metam sodium cannot be applied uniformly because uneven land topography and soil texture. This results in pockets of very high and very low concentration of metam sodium. The surviving fungal pathogen populations can build up quickly to kill tomato plants ( Burnette, 2003). In addition, the applicant claims that high concentration can be phytotoxic and low concentration does not control fungal pathogens ( data not submitted). No Chloropicrin Chloropicrin is not effective when it is applied alone. No NON CHEMICAL ALTERNATIVES Soil solarization The CUE is for tomatoes grown in the coastal areas of California, which have mild weather conditions ( 15  25 C temperatures). The weather conditions restrict soil solarization as alternative to methyl bromide. No Steam While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in open tomato fields. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to pasteurize soil down to the rooting depth of field crops ( at least 20 50 cm). No Biological Control Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens and/ or nematodes. While biological control may have utility as part of plant pathogen management strategy, it can not be a methyl bromide alternative No Cover crops and mulching There is no evidence that these practices effectively substitute for the control methyl bromide provides against fungal pathogens and nematodes. No Page 18 Crop rotation and fallow land The land is very expensive and there are not enough hectares in tomato growing areas to rotate. The fungal pathogen survive for many years in soil and therefore it is not a viable option. No Endophytes No information is available on tomato endophytes that will control fungal and plant pathogens. No Flooding/ Water management Flooding is not technically feasible as an alternative because it does not have any suppressive effect on fungal plant pathogens and nematodes. In addition, it is prohibitively expensive and there are water management restrictions. No Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as target pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of fungal pathogens and nematodes. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Undulating land topography and variable soil texture will result in uneven concentration of metam sodium through drip irrigation that may affect field performance and can result in phytotoxicity to tomato transplants. This mixture will not control nematodes. No Metam sodium + Crop rotation Same as metam sodium No 1,3 D + Metam sodium This mixture may control fungi and nematodes, but undulating land topography will result in uneven concentration of metam sodium through drip irrigation that may result in phytotoxicity to tomato transplants. No 1,3 D + Chloropicrin Telone is effective against nematodes. Chloropicrin is effective against fungal plant pathogens. The combination is a technically feasible alternative to methyl bromide, but undulating topography can reduce its uniformity of application and, hence, its effectiveness. No 1,3 D + metam sodium + pebulate This mixture cannot be used as a methyl bromide alternative because pebulate is no longer registered in the United States ( during 2002 its registration expired and the manufacturer went out of business). No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. Page 19 CALIFORNIA REGION  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

CALIFORNIA REGION   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION None Foliar fungicides are not suitable because the key pests are soil borne and afflict the belowground portion of the tomato plant. There are no other alternatives that exist for the control of these key pests on hilly or rolling terrain when they are present in the soil. A number of fungicides are available that may control fungal pathogenss when they attach aerial plant parts. Fusarium spp. results in plant wilting and there is no remedy once plant is systemically infected.

CALIFORNIA REGION  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

CALIFORNIA REGION   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Methyl Iodide Application submitted to the US EPA during February 2002. Not registered Yes Unknown Sodium azide No application submitted to the US EPA till date. Not registered No Unknown Propargyl bromide No application submitted to the US EPA till date. Not registered No Unknown CALIFORNIA REGION  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED:

The applicant submitted the results of two field trials conducted in San Diego and Ventura counties on the efficacy of methyl bromide and its alternatives in controlling listed pests ( Fusarium wilt, Verticillium wilt, Root knot nematode, and Pythium spp.). Metam sodium and 1,3 D are both not viable options because of hilly, rolling terrain. Varied soil texture and undulating land topography can create high and low concentration spots of metam sodium and 1,3 D, affecting its efficacy in controlling the pests ( Burnette, 2003). Low concentrations may results in lower efficacy and high concentration in phytotoxicity. The growers may suffer 15 20% yield losses. The applicant did not submit any document on the effect of low and high concentration spots of metam sodium on tomato yield. Therefore, we are unable to validate whether or not these losses are reasonable. Page 20 CALIFORNIA REGION   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   KEY PEST 1 No additional information is available to present.

CALIFORNIA REGION   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS Metam sodium Fusarium wilt Verticillium wilt Root Knot nematodes Pythium spp. 15 20%, based on professional opinion 15 20%

1,3 D As above Not a viable option because of hilly, rolling terrain. 1,3 D + Chloropicrin As above Not a viable option because of hilly, rolling terrain. 1,3 D + metam sodium + Chloropicrin As above Not a viable option because of hilly, rolling terrain.

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 15 20%

CALIFORNIA REGION  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?: ( If so, please specify.)

Methyl Iodide, Sodium Azide and Propargyl Bromide These have not been widely tested in the fields or registered for use in any crop by the United States Environmental Protection Agency. The above fumigants are potential alternatives to methyl bromide that could be used in California to control fungal pathogens and nematodes.

CALIFORNIA REGION  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

Tomatoes are grown in fields. It is neither technically feasible nor economically viable to grow tomatoes in soil less culture or in containers. Page 21 CALIFORNIA REGION  SUMMARY OF TECHNICAL FEASIBILITY The US EPA has determined that in flat terrain, only 1,3 D + chloropicrin and metam sodium + chloropicrin can be technically feasible against the key pests of tomatoes grown in California. Metam sodium alone will not control nematodes and may be phytotoxic to plants because of undulating land topography of tomato fields. A mixture of metam sodium and chloropicrin will not control nematodes. In addition, this mixture may also be phytotoxic due to undulating land topography. A mixture of 1,3 D and chloropicrin is unreliable in undulating topography because of uneven distribution of the fumigant through drip irrigation systems. Currently unregistered alternatives, such as methyl iodide, sodium azide or propargyl bromide have shown good efficacy against the key pests. However, even if registration is pursued soon the commercial tomato growers will need transition period for adoption in California.

There are also no non chemical alternatives that are currently viable for MB replacement for commercial tomato growers.

MICHIGAN REGION  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE MICHIGAN REGION  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST MICHIGAN REGION  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE NEEDED Michigan Region 1. Crown, root and fruit rot caused by Phytophthora capsici 2. Fusarium oxysporum wilt Methyl bromide is currently the only product that can control these soil borne pathogens and allow MI growers to deliver their produce during premium priced early market windows. Other control measures have plant back restrictions that put MI tomatoes outside the premium priced fresh market. Resistant varieties have not been identified. Page 22 MICHIGAN REGION  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE MICHIGAN REGION  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS MICHIGAN REGION CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplant tomatoes to produce fruit ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Squash, cucumber, eggplant and melons. All are susceptible to Phytpphthora capsici.

SOIL TYPES: ( Sand, loam, clay, etc.) Sandy to Loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Annual OTHER RELEVANT FACTORS: Low soil temperatures during late March do not allow effective soil fumigation with telone, telone+ chloropicrin or metam sodium for tomato planting in April.

MICHIGAN REGION  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( Plant Hardiness Zone) 5B SOIL TEMP. ( ° C)* < 10 10 15 15 20 20 25 20 25 20 25 20 10 15 10 < 10 < 10 < 10 RAINFALL ( mm)* * 40 72 101 48 47 32 17 31 36 20 6 8 OUTSIDE TEMP. ( ° C) * * 0.2 7.4 12.1 17.7 20.6 20.9 18.1 8.0 2.4  2.9  8.0  7.0 FUMIGATION SCHEDULE X PLANTING SCHEDULE X X KEY MARKET WINDOW X X X * HAUSBECK AND CORTRIGHT ( 2003). ** DATA SOURCE " http:// www. crh. noaa. gov/ grr/ climate/ f6/ preliminary. php? site= LAN"

MICHIGAN REGION   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Low soil temperatures during late March to early April make the use of in kind ( metamsodium 1,3 D + chloropicrin) fumigants impractical because soil temperatures may be below the labeled minimums or plant back restrictions are too long ( 15 to 30 days) to allow April transplanting of tomato seedlings in the field. Page 23 MICHIGAN REGION  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED MICHIGAN REGION  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 435 476 487 581 648 673 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED 100% strip 100% strip 100% strip 100% strip 100% strip 100% strip AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 21,001 22,964 23,493 28,003 31,235 32,461 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm APPLICATION RATE OF ACTIVE INGREDIENT IN kg/ ha* 48 48 48 48 48 48 APPLICATION RATE OF FORMULATIONS IN kg/ ha* 71.6* 71.6 71.6 71.6 71.6 71.6 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 13.1 13.1 13.1 13.1 13.1 13.1 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 19.5 19.5 19.5 19.5 19.5 19.5 * Only 36.7 percent land area is treated in the form of beds and therefore dosage rate ( g/ m2) is higher. Page 24 MICHIGAN REGION  PART C: TECHNICAL VALIDATION MICHIGAN REGION  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE ( Give list of all relevant chemical and non chemical alternatives, and their combinations)

MICHIGAN REGION   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE + CITATIONS** IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D It is not effective against fungal plant pathogens. No Metam sodium Metam sodium is effective against soil fungi. Michigan soil temperature during April are too low to use this fumigant for an early fresh market tomato crop. Product label states that transplant cannot be planted in the field up to 21 days after fumigation. Technically, it is methyl bromide alternative but economically it is not a viable alternative. No Chloropicrin Chloropicrin is ineffective as soil fumigant when applied alone. No NON CHEMICAL ALTERNATIVES Soil solarization Michigan is a northern state with cold weather conditions and therefore it is not a viable option. No Steam While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in the open tomato fields. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to pasteurize soil down to the rooting depth of field crops ( at least 20 50 cm). No Biological Control Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens and/ or nematodes. While biological control may have utility as part of plant pathogen management strategy, it can not be a methyl bromide alternative No Cover crops and mulching There is no evidence that these practices effectively substitute for the control methyl bromide provides against fungal pathogens and nematodes. No Crop rotation and fallow land The land is very expensive and there are not enough hectares in tomato growing areas to rotate. The fungal pathogen survive for many years in soil and therefore crop rotation and fallow are not a viable options ( Lamour and Hausbeck, 2003*) No Page 25 Endophytes No information is available on tomato endophytes that will control fungal and plant pathogens. No Flooding/ Water management Flooding is not technically feasible because it does not suppress fungal plant pathogens and nematodes. No Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as target pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of fungal pathogens and nematodes. No COMBINATIONS OF ALTERNATIVES Telone + Chloropicrin Telone is effective against nematodes. Chloropicrin is effective against fungal plant pathogens. Their combination is a technically feasible alternative, but Michigan's low soil temperature does not allow soil fumigation during April months for early fresh market tomato crop. No Metam sodium + Crop rotation Same as metam sodium No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

MICHIGAN REGION  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

MICHIGAN REGION   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION None Other than those options discussed above, there are no alternatives that may control the key pest. Registered fungicides ( such as azoxystrobin, mefenoxam and mancozeb) may control aerial infections of Phytophthora capsici, but are not effective against collar and root rot phase of this pathogen. Soil fumigation with methyl bromide kills soil borne primary inoculum of this pest and therefore fungicide use is also reduced ( Lamour and Hausbeck, 2003*) Page 26 MICHIGAN REGION  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

MICHIGAN REGION   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Methyl Iodide Not registered. Yes Unknown Sodium azide Not registered. No registration package has been received. No Unknown Furfural Not registered No Unknown Propargyl Bromide Not registered. No registration package has been received. No Unknown MICHIGAN REGION  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED:

The applicant submitted the results of one small scale field trial on the efficacy of methyl bromide alternatives in controlling the pest and their effect on tomato yield ( Hausbeck and Cortwright, 2003). This study focused on tomato and a number of vegetable crops ( cucurbits, winter squash, and melons). As of July 2003, results showed that methyl bromide+ chloropicrin ( 67/ 33, shank injected @ 390 Kg/ Hectare), metam sodium ( drip applied) @ 355 KG ai/ ha), 1, 3 D+ chloropicrin ( 65/ 35, shank injected @ 150 liters/ ha) resulted in 0, 12.9, 6.4 percent plant loss. Untreated control suffered 7.1% plant loss.

The fields were treated on May 15 and 16, 2003, and the weather was unusually cooler than normal during May and early June of the year 2003. The results are inconclusive. This study may be repeated during 2004 growing season. The state expert claims that the growers may suffer 6.4 and 12.9 percent yield losses using 1, 3 D + chloropicrin and metam sodium. The expert claims that these losses are expected if the grower fumigate their fields in early May instead of April ( using methyl bromide + chloropicrin). In addition, the growers may also suffer revenue losses if they miss early tomato market when prices are higher.

MICHIGAN REGION   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   KEY PEST 1 No additional information is available. Page 27 MICHIGAN REGION   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS methyl bromide+ chloropicrin Phytophthora capsici 0.0   0.0 0.0 metam sodium Phytophthora capsici 0.0   12.9 12.9 1, 3 D+ chloropicrin Phytophthora capsici 0.0   6.4 6.4 chloropicrin Phytophthora capsici 0.0   6.4 6.4 OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 0  13 % plus revenue losses due to planting; Most likely losses are 6 % using 1,3 D + chloropicrin ( the best alternative)

MICHIGAN REGION  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

In Michigan the critical use exemption application states that telone + chloropicrin, metamsodium methyl iodide, sodium azide, and furfural will continue to be under investigation as methyl bromide alternatives. Most of these alternatives are currently unregistered for use on tomato, and there are presently no commercial entities pursuing registration in the United States. The timeline for developing the above mentioned MB alternatives in Michigan is as follows: 2003   2005: Test for efficacy ( particularly against the more prevalent Phytophthora) 2005   2007: Establish on farm demonstration plots for effective MB alternatives 2008   2010: Work with growers to implement commercial use of effective alternatives.

Research is also under way to optimize the use of a 50 % methyl bromide: 50 % chloropicrin formulation to replace the currently used 67: 33 formulation. In addition, field research is being conducted to optimize a combination of crop rotation, raised crop beds, black plastic, and foliar fungicides. Use of virtually impermeable film ( VIF) will also be investigated as a replacement for the currently used low density polyethylene ( LDPE). Page 28 MICHIGAN REGION  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?: ( e. g. soilless systems, plug plants, containerized plants. State proportion of crop already grown in such systems nationally and if any constraints exist to adoption of these systems to replace methyl bromide use. State whether such technologies could replace a portion of proposed methyl bromide use.)

Tomatoes are grown in fields. In michigan, it is neither technically feasible nor economically viable to grow tomatoes in soil less culture or in containers.

MICHIGAN REGION  SUMMARY OF TECHNICAL FEASIBILITY Although the U. S. E. P. A. determined that metam sodium and a combination of telone + chloropicrin can control the key pest, Phytophthora, the planting and harvesting delay due to cold soil temperatures and longer plant back interval lead to a shorter growing season and missing key market windows when commodity prices are most favorable. These alternatives have plant back restriction of 14 28 days. The plant back restriction delays tomato harvest by 14 28 days. The delayed harvest results in lower net revenues per acre because tomato prices decline as season progresses.

Currently unregistered alternatives, such as methyl iodide, sodium azide, propargyl bromide and furfural have good efficacy against the key pests involved. However, even if registration is pursued, the growers will need transition time to adopt them.

SOUTH EASTERN UNITED STATES  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE SOUTH EASTERN UNITED STATES  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST SOUTH EASTERN UNITED STATES  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE NEEDED South Eastern United States Nutsedges ( Cyperus rotundus and C. esculentus)

Root Knot nematodes Phytophthora Crown and Root Rot. Fusarium Wilt ( F. oxysporum) None of the listed MBTOC alternative is effective in controlling the key pests in the South Eastern United States. Page 29 SOUTH EASTERN UNITED STATES  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE ( Place major attention on the key characteristics that affect the uptake of alternatives):

SOUTH EASTERN UNITED STATES  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS SOUTH EASTERN UNITED STATES CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplant for tomato fruit production ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Tomato. Tomato Cucumber or Squash or Watermelon or Cantaloupe. Tomato Cucurbits.

SOIL TYPES: ( Sand, loam, clay, etc.) Sandy to loam, over karst geology in many areas FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Annual OTHER RELEVANT FACTORS: No other information provided.

SOUTH EASTERN UNITED STATES  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( Plant Hardiness Zone) 6b, 7a, 7b, 8a, 8b, 9b, 10a, 10b SOIL TEMP. ( ° C) ** 17 20 17 21 21 24 22 26 25 29 26 29 27 30 28 32 27 29 25 27 21 23 19 21 RAINFALL ( mm)* 51 203 51 203 51 203 51 203 102 203 102 203 51 203 51 203 25 102 25 102 25 102 25 102 OUTSIDE TEMP. ( ° C)* 11 22 16 23 21 25 25 28 26 28 25 28 23 25 17 25 10 22 7 19 7 19 8 19 FUMIGATION SCHEDULE X X X X X X X X PLANTING SCHEDULE X X X X X X X KEY MARKET WINDOW X X X X X X X X * JACOB ( 1977). ** FLORIDA SOIL TEMPERATUTES SOURCE IS WWW. IMOK. UFL/ EDU/ WEATHER/ ARCHIVES/ 200/ CLIM00 Page 30 SOUTH EASTERN UNITED STATES   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Karst geology inhibits the use of all fumigants that contain 1,3 D.

SOUTH EASTERN UNITED STATES  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED SOUTH EASTERN UNITED STATES  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 22,269 24,002 25,814 27,831 28,931 28,572 RATIO OF FLAT FUMIGATION USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Approx. 50% strip Approx. 50% strip Approx. 50% strip Approx. 50% strip Approx. 50% strip Approx. 50% strip AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 4,484,413 4,747,976 4,491,580 4,462,390 4,514,006 4,370,645 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / Chloropicrin) 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 67/ 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Mostly Injected at 25 30 cm depth Mostly Injected at 25 30 cm depth Mostly Injected at 25 30 cm depth Mostly Injected at 25 30 cm depth Mostly Injected at 25 30 cm depth Mostly Injected at 25 30 cm depth APPLICATION RATE OF FORMULATIONS IN kg/ ha* 201 196 175 163 158 154 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 20.1 19.6 17.5 16.3 15.8 15.4 Page 31 SOUTH EASTERN UNITED STATES  PART C: TECHNICAL VALIDATION SOUTH EASTERN UNITED STATES  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE SOUTH EASTERN UNITED STATES   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Telone Effective against nematodes, but not against fungal plant pathogens and nutsedge weeds. Approximately 40% of tomato land has Karst geology. Growers with Karst topography can not use telone because of underground water contamination. No Metam sodium It will control many weeds but control of nutsedge is very inconsistent. It is not very effective against nematode population. No Chloropicrin Chloropicrin controls soil fungi only. It also stimulates nutsedge weed growth and therefore it is not a viable option. It occasionally stimulates nutsedge emergence but also occasionally controls nutsedge as noted in the literature. Again the issue is its inability to get consistent control ( Culpepper, 2004). No NON CHEMICAL ALTERNATIVES Soil solarization For nutsedge control in the southeastern U. S. states, solarization is unlikely to be technically feasible as a methyl bromide alternative. Research indicates that the lethal temperature for nutsedge tubers is 50oC or higher ( Chase et al. 1999). While this may be achieved for some portion of the autumn cropping in southern cucurbit growing regions, it is very unlikely for any portion of the spring crops. Trials conducted in mid summer in Georgia resulted in maximal soil temperatures of 43oC at 5 cm depth, not high enough to destroy nutsedge tubers, and tubers lodged deeper in the soil would be completely unaffected. No Steam Steam is not a technically feasible alternative for open field tomato production because it requires sustained heat over a required period of time ( UNEP 1998). While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in tomato fields. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to pasteurize soil down to the rooting depth of field crops ( at least 20 50 cm). No Biological Control Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens, nematodes and nutsedges. No Page 32 Cover crops and mulching Cover crops and mulches appear to reduce weed population, but not nutsedges ( Burgos and Talbert 1996). Mulching has also been shown to be ineffective in controlling nutsedges, since these plants are able to penetrate through both organic and plastic mulches ( Munn 1992, Patterson 1998). No Crop rotation and fallow land It is not a technically or economically ( can not afford to take land out of production) feasible alternative to methyl bromide because it does not, by itself, provide adequate control of fungi and/ or nutsedges. The crop rotations available to growers are also susceptible to fungi; fallow land can still harbor fungal oospores. As regards nutsedges, tubers of these perennial species provide new plants with larger energy reserves than the annual weeds that can be frequently controlled by crop rotations and fallow land. Furthermore, nutsedge plants can produce tubers within 8 weeks after emergence. This enhances their survival across different cropping regimes that can disrupt other plants that rely on a longer undisturbed growing period to produce seeds to propagate the next generation. No Endophytes It is not a technically viable option because it has never been shown to work against the key pests in tomato or similar crops. No Flooding/ Water management Flooding has never been shown to control nutsedge species. Nutsedges are much more tolerant of watery conditions than many other weed pests. For example, Horowitz ( 1972) showed that submerging nutsedge in flowing or stagnant water ( for 8 days and 4 weeks, respectively) did not affect the sprouting capacity of tubers. There are also serious practical obstacles to implementing flood management approaches in cucurbit production in the southern and southeastern U. S. states. Droughts are common in many parts of these regions, and the soil composition may not support flooding and still remain productive. No Grafting/ resistant rootstock/ plant breeding/ soil less culture/ organic production/ substrates/ plug plants. These technologies have never been shown to control listed key pests under field conditions. Resistant root stock or cultivars may control one pest, but not the other. It is almost impossible to breed or genetically engineer tomato cultivars that has all agronomic characters and is resistant to all key pests. This has no effect on managing nutsedge weeds. No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin+ herbicide ( such as pebulate) This combination is the most promising alternative for the control of all key pests in southeastern region. The executive summary of dozens of research trials show that the growers may harvest tomato yield that is near equal to the yield obtained using methyl bromide and chloropicrin. Using this combination the growers may lose an average of 6.2% yield in areas where this combination can be used ( Chellemi et al., 2001). May be Page 33 Metam sodium + Chloropicrin This mixture may be more effective than metam sodium alone in controlling fungal pests, but this combination would not prevent yield losses caused by nutsedges and some species of nematodes. This mixture along with a herbicide ( for controlling nutsedge weeds) may be a viable methyl bromide alternative in the South Eastern United States where the growers can not use telone due to karst topography. Further experiments need to be done on this mixture to find out whether or not it is technically and economically viable. May be Telone + Chloropicrin It is effective against nematodes and fungal plant pathogens, but not against nutsedge and other weeds. Approximately 40 and 8.0% of tomato land in Florida and Georgia, respectively, has Karst geology. Growers with Karst topography can not use telone because of state regulations and underground water contamination issues. No Telone + metam sodium + herbicide ( such as pebulate) This mixture could provide reasonable control of pests if weed pressure is low to moderate and land does not have Karst geology. Pebulate is no longer registered because the manufacturer went out of business during 2002. Growers will need to use one of the newly registered herbicides if they use this combination, and will be constrained by certain limitations ( described below). No Metam sodium + Crop rotation Same as metam sodium.

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

SOUTH EASTERN UNITED STATES  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

SOUTH EASTERN UNITED STATES   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Glyphosate For nutsedges: Non selective herbicide that will not control nutsedge. It is not labeled for row middle application. In addition, it does not provide residual control. It is a non selective herbicide used to control weeds in row middles. Application to the rows would cause injury to the tomato crop. As a preplant treatment glyphosate will not provide season long control of yellow and/ or purple nutsedge in tomatoes.

Paraquat Non selective; will not control nutsedge in the plant rows; does not provide residual control. Its repetitive applications are required to achieve fair control in the row middle ( Culpepper, 2003). Paraquat is a non selective herbicide that controls annual weeds in row middles. It may also be applied preemergence to the crop. Application to the rows would cause injury to the tomato crop. For perennial weeds, such as nutsedge, it will burn down the top portion of the plant but the tubers remain viable, allowing the weed to grow again. Therefore, paraquat will not provide season long control because the weed can regrow during the growing season. Page 34 SOUTH EASTERN UNITED STATES  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

SOUTH EASTERN UNITED STATES   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Halosulfuronmethyl There are a number of restrictions limiting the potential to use this herbicide in tomatoes in the Southeast ( see additional notes below). Among these are potential crop injury and plant back restrictions for rotational crops. Efficacy is lowered in rainy conditions ( which are common in this region). Need more time to experiment under field conditions. Yes Recently registered Pebulate For nutsedges: Was registered for use in tomatoes only, its registration expired during December, 2002 ( the manufacturer went out of business) No Unknown S metolachlor For nutsedges: Not registered in some states of concern. It is effective against yellow nutsedge and not effective against purple nutsedge ( Culpepper, 2004). Yes Already registered Terbacil For nutsedges: Registered ONLY in strawberries. The manufacturer claims that it is partially effective against yellow nutsedge and does not control purple nutsedge. No Unknown Rimsulfuron Registered for the control of nutsedge weeds in tomatoes. The product label states that it is partially effective against nutsedges. Y Already registered Trifloxysulfuron For nutsedges: Newly Registrated for use in tomato. Efficacy needs to be tested under large scale field trials. Labeled for use in Florida only. It provides good control of nutsedge but rotational restrictions may limit its large scale adoption. Y Already registered Methyl Iodide Not yet registered in the United States Y unknown Sodium azide Not registered in the United States No unknown Sulfuryl Floride It is not registered for preplant soil treatment. It is registered for postharvest treatment of agricultural produce ( tomato not included) The registrant has not contacted USEPA for its use as a preplant soil fumigant. unknown Additional notes on specific herbicides listed: Halosulfuron methyl In December 2002, halosulfuron methyl ( Sandea ® ) was registered for weed control ( including nutsedge) in tomatoes, peppers, eggplant, and cucurbits. This recent registration was not on the list of alternatives from Page 35 MBTOC and several years are needed to see if it will be adopted. Historically, in the United States it has taken three to five years for an herbicide to be adopted by a significant number of vegetable crop growers.

Halosulfuron methyl has a number of limitations which may affect its widespread adoption, that include: ( 1) phyto toxicity with moderate rainfall immediately after application; ( 2) cool temperatures, ( 3) susceptible varieties, and ( 4) plant back restrictions. Specifically:   Rainfall or sprinkler irrigation greater than 2.5 cm, soon after a pre emergent application of halosulfuronmethyl may cause crop injury. Sudden storms with greater than 2.5 cm of rainfall are common in Florida and other areas of the southeastern United States. In addition, rainfall within four hours after a postemergence application of halosulfuron methyl may reduce effectiveness and cause crop injury.   Under cool temperatures that can delay early seedling emergence or growth, halosulfuron methyl can cause injury or crop failure. This is especially likely to occur during the first planting of the season. In addition, not all hybrids/ varieties of tomatoes have been tested for sensitivity to halosulfuron methyl. Halosulfuron may also delay maturity of treated crops.   Halosulfuron methyl plant back restrictions are up to 36 months. Many of the vegetable crops fall within the 4 to 12 month range, although some are longer. There are label limitations for halosulfuron methyl. As per product label, halosulfuron methyl should not be applied if the crop or target weeds are under stress due to drought, water saturated soils, low fertility, or other poor growing conditions. This herbicide can not be applied to soil that has been treated with organophosphate insecticides. Foliar applications of organophosphate insecticides may not be made within 21 days before or 7 days after halosulfuron methyl application. Note: All the limitations above are listed in the US registration label for halosulfuron, which in turn is based on proprietary data submitted to EPA by the registrant company.

S metolachlor It was registered for use in tomatoes in April 2003. However, it is not registered in states of concern, and does not control purple nutsedge or nightshade species. Further, it does not provide commercially acceptable weed control in plasticulture systems. Rimsulfuron There is evidence that rimsulfuron only provides suppressive control of yellow nutsedge ( 40 to 70 percent control) ( Nelson et al, 2002). In addition, the label warns against tank mixing with organophosphate insecticides because injury to the crop may occur. Also, for most of the vegetable crops besides tomatoes there is a 12 month plant back restriction. This plant back restriction can seriously compromise the needed rotational interval needed for IPM programs. Page 36 SOUTH EASTERN UNITED STATES  16. STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED Telone C35 ( 1,3 D + 35 % chloropicrin) plus pebulate herbicide has been found to be the best alternative to methyl bromide in controlling listed key pests under Florida growing conditions ( Chellemi et al., 2001). Pebulate is no longer registered in the U. S., however, so another herbicide would have to be substituted into the fumigation mixture. The results of many trials showed that growers may harvest tomato yield that is near equal to the yield obtained using methyl bromide and chloropicrin. Assuming that an herbicide is used that is as effective as pebulate, growers using a 1,3 D + chloropicrin + herbicide mixture may suffer an average of 6.2 percent yield losses ( Chellemi et al., 2001). Florida and Georgia experts claim the yield losses using a combination of 1,3 D + chloropicrin + herbicides will be higher than 6.2 percent because pebulate is no longer registered and other herbicides have limitations. The experts were unable to provide yield loss estimate without 2 3 years of field trials. The experts claim that more time is needed to evaluate various methyl bromide fumigant alternatives, mulches and herbicides systems to study their effects on tomato yields.

SOUTH EASTERN UNITED STATES   TABLE 16.1: EFFECTIVENESS OF ALTERNATIVES   KEY PEST 1 No additional information is available.

SOUTH EASTERN UNITED STATES   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D + chloropicrin + herbicide Fungi, Nematodes and Nutsedges 2.3   10.1 ( Chellemi et al., 2001) 6.2 OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 6.2%

SOUTH EASTERN UNITED STATES  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?: ( If so, please specify.)

A combination of 1,3 D + chloropicrin + pebulate appeared to be the best alternative in controlling key pests in tomato fields. Since pebulate herbicide is no longer available then the growers will have to substitute another herbicide, listed in table 14.1 and 15.1 ( such as halosulfuron, rimsulfuron or trifloxysulfuron to achieve similar pest control). Florida and Georgia state expert claim the yield losses using a combination of 1,3 D + chloropicrin + herbicides will be higher than 6.2 losses because pebulate is no longer registered and other herbicides have limitations. The experts were unable to provide yield loss estimate without 2 3 years of field trials. The experts claim that more time is needed to evaluate various methyl bromide fumigant alternatives, mulches and herbicides systems to study their effects on tomato yields. Page 37 SOUTH EASTERN UNITED STATES  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE? ( e. g. soilless systems, plug plants, containerized plants. State proportion of crop already grown in such systems nationally and if any constraints exist to adoption of these systems to replace methyl bromide use. State whether such technologies could replace a portion of proposed methyl bromide use.)

Tomatoes are grown in fields. In South eastern united states, it is neither technically feasible nor economically viable to grow tomatoes in soil less culture or in containers. Page 38 SOUTH EASTERN UNITED STATES  SUMMARY OF TECHNICAL FEASIBILITY The submitted data showed that using the above best alternative the growers are expected to suffer 6.2% yield losses ( Chellemi, Botts and Noling. 2001). A combination of 1,3 D + chloropicrin + pebulate appeared to be the best alternative in controlling key pests in tomato fields. Since pebulate is no longer available then the growers will need to substitute another herbicides such as halosulfuron, rimsulfuron or trifloxysulfuron to control nutsedge weeds. But, these herbicides have significant limitations, as described in the notes to Table 15.1. In addition, losses will be higher in areas of Karst geology, where 1,3 D may not be used.

Florida and Georgia state expert claim that the yield losses using a combination of 1,3 D + chloropicrin + other herbicides will be higher than 6.2 losses because of limitations of other herbicides ( see table 14.1 and 15.1). The experts were unable to provide yield loss estimate without 2 3 years of field trials. The experts claim that more time is needed to evaluate various methyl bromide fumigant alternatives, mulches and herbicides systems to study their effects on tomato yields. Page 39 PART D: EMISSION CONTROL 19. TECHNIQUES THAT HAVE AND WILL BE USED TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS IN THE PARTICULAR USE: ( State % adoption or describe change)

TABLE 19.1: TECHNIQUES TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS 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? Start research during 2004 Already using 67: 33 with the potential to use lower ratios in the future. Between 1997 and 2002, the US has achieved a 27 % reduction in use rates. Already using 67: 33 with the potential to use lower ratios in the future The US anticipates that the decreasing supply of methyl bromide will motivate growers to try less frequent applications.

WHAT FURTHER USE/ EMISSION REDUCTION STEPS WILL BE TAKEN FOR THE METHYL BROMIDE USED FOR CRITICAL USES? Start research during 2004 Already using 67: 33 with the potential to use lower ratios in the future Already using 67: 33 with the potential to use lower ratios in the future Not applicable OTHER MEASURES ( please describe) Not applicable Not applicable Not applicable Not applicable 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED, OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS:

In accordance with the criteria of the critical use exemption, each party is required to describe ways in which it strives to minimize use and emissions of methyl bromide. The use of methyl bromide in the growing of cucurbit nurseries in the United States is minimized in several ways. First, because of its toxicity, methyl bromide has, for the last 40 years, been regulated as a restricted use pesticide in the United States. As a consequence, methyl bromide can only be used by certified applicators who are trained at handling these hazardous pesticides. In practice, this means that methyl bromide is applied by a limited number of very experienced applicators with the knowledge and expertise to minimize dosage to the lowest level possible to achieve the needed results. In keeping with both local requirements to avoid " drift" of methyl bromide into inhabited areas, as well as to preserve methyl bromide and keep related emissions to the lowest level possible, methyl bromide application for cucurbits is most often machine injected into soil to specific depths.

As methyl bromide has become more scarce, users in the United States have, where possible, experimented with different mixes of methyl bromide and chloropicrin. Specifically, in the early 1990s, methyl bromide was typically sold and used in methyl bromide mixtures made up of 95% Page 40 methyl bromide and 5% chloropicrin, with the chloropicrin being included solely to give the chemical a smell enabling those in the area to be alerted if there was a risk. However, with the outset of very significant controls on methyl bromide, users have been experimenting with significant increases in the level of chloropicrin and reductions in the level of methyl bromide. While these new mixtures have generally been effective at controlling target pests, at low to moderate levels of infestation, it must be stressed that the long term efficacy of these mixtures is unknown.

Tarpaulin ( high density polyethylene) is also used to minimize use and emissions of methyl bromide. In addition, cultural practices are utilized by cucurbit growers.

Reduced methyl bromide concentrations in mixtures, cultural practices, and the extensive use of tarpaulins to cover land treated with methyl bromide has resulted in reduced emissions and an application rate that we believe is among the lowest in the world for the uses described in this nomination.

PART E: ECONOMIC ASSESSMENT The following economic analysis is organized by MeBr critical use application. Cost of MeBr and alternatives are given first in table 21.1. This is followed in table 22.1 by a listing of net and gross revenues by applicant. Expected losses when using MeBr alternatives are then decomposed in tables E1 through E3.

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

21. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD:

TABLE 21.1: COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD REGION ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Methyl Bromide 100 $ 50,240 $ 50,240 $ 50,240 Metam Sodium 85 $ 46,353 $ 46,353 $ 46,353 CALIFORNIA Metam Sodium 80 $ 44,626 $ 44,626 $ 44,626 Methyl Bromide 100 $ 30,559 $ 30,559 $ 30,559 1,3   D + Chloropicrin 78 $ 29,555 $ 29,555 $ 29,555 Metam Sodium 78 $ 29,739 $ 29,739 $ 29,739 MICHIGAN Chloropicrin 78 $ 29,555 $ 29,555 $ 29,555 Methyl Bromide 100 $ 26,380 $ 26,380 $ 26,380 SOUTHEASTERN US 1,3   D + Chloropicrin 83 $ 24,946 $ 24,946 $ 24,946 * As percentage of typical or 3 year average yield, compared to methyl bromide e. g. 10% more yield, write 110. Page 41 22. GROSS AND NET REVENUE:

TABLE 22.1: YEAR 1 GROSS AND NET REVENUE YEAR 1 REGION ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 83,367 $ 33,127 Metam Sodium ( 15% loss) $ 70,862 $ 24,509 CALIFORNIA Metam Sodium ( loss 20%) $ 66,694 $ 22,068 Methyl Bromide $ 39,996 $ 9,438 1,3   D + Chloropicrin $ 32,880 $ 3,325 Metam Sodium $ 34,931 $ 5,192 MICHIGAN Chloropicrin $ 32,880 $ 3,325 Methyl Bromide $ 40,914 $ 14,533 SOUTHEASTERN US 1,3   D + Chloropicrin $ 33,772 $ 8,825 TABLE 22.2: YEAR 2 GROSS AND NET REVENUE YEAR 2 REGION ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 83,367 $ 33,127 Metam Sodium ( 15% loss) $ 70,862 $ 24,509 CALIFORNIA Metam Sodium ( loss 20%) $ 66,694 $ 22,068 Methyl Bromide $ 39,996 $ 9,438 1,3   D + Chloropicrin $ 32,880 $ 3,325 Metam Sodium $ 34,931 $ 5,192 MICHIGAN Chloropicrin $ 32,880 $ 3,325 Methyl Bromide $ 40,914 $ 14,533 SOUTHEASTERN US 1,3   D + Chloropicrin $ 33,772 $ 8,825 TABLE 22.3: YEAR 3 GROSS AND NET REVENUE YEAR 3 REGION ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Methyl Bromide $ 83,367 $ 33,127 Metam Sodium ( 15% loss) $ 70,862 $ 24,509 CALIFORNIA Metam Sodium ( loss 20%) $ 66,694 $ 22,068 Methyl Bromide $ 39,996 $ 9,438 1,3   D + Chloropicrin $ 32,880 $ 3,325 Metam Sodium $ 34,931 $ 5,192 MICHIGAN Chloropicrin $ 32,880 $ 3,325 Methyl Bromide $ 40,914 $ 14,533 SOUTHEASTERN US 1,3   D + Chloropicrin $ 33,772 $ 8,825 Page 42 MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES CALIFORNIA METHYL BROMIDE METAM SODIUM PRODUCTION LOSS (%) 0% 15% 20%

PRODUCTION PER HECTARE 11,106 9,440 8,885 * PRICE PER UNIT ( US$) $ 8 $ 8 $ 8 = GROSS REVENUE PER HECTARE ( US$) $ 83,367 $ 70,862 $ 66,694  OPERATING COSTS PER HECTARE ( US$)** $ 50,240 $ 46,353 $ 44,626 = NET REVENUE PER HECTARE ( US$) $ 33,127 $ 24,509 $ 22,068 LOSS MEASURES * 1. LOSS PER HECTARE ( US$) $  $ 8,618 $ 11,059 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 82 $ 105 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 10% 13%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 26% 33%

MICHIGAN  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN METHYL BROMIDE 1,3 D + PIC METAM SODIUM CHLOROPICRIN PRODUCTION LOSS (%) 0% 6% 6% 6% PRODUCTION PER HECTARE 4,248 3,976 3,976 3,976 * PRICE PER UNIT ( US$) $ 9 $ 8 $ 9 $ 8 = GROSS REVENUE PER HECTARE ( US$) $ 39,996 $ 32,880 $ 34,931 $ 32,880  OPERATING COSTS PER HECTARE ( US$)** $ 30,559 $ 29,555 $ 29,739 $ 29,555 = NET REVENUE PER HECTARE ( US$) $ 9,438 $ 3,325 $ 5,192 $ 3,325 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $  $ 6,113 $ 4,246 $ 6,113 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 127 $ 88 $ 127 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 15% 11% 15%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 65% 45% 65% Page 43 SOUTHEASTERN US  TABLE E. 3: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEASTERN US METHYL BROMIDE 1,3 D + PIC PRODUCTION LOSS (%) 0% 6% PRODUCTION PER HECTARE 4,382 4,110 * PRICE PER UNIT ( US$) $ 9 $ 8 = GROSS REVENUE PER HECTARE ( US$) $ 40,914 $ 33,772  OPERATING COSTS PER HECTARE ( US$)** $ 26,380 $ 24,946 = NET REVENUE PER HECTARE ( US$) $ 14,533 $ 8,825 LOSS MEASURES *

1. LOSS PER HECTARE ( US$) $  $ 5,708 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $  $ 38 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 14%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 39%

SUMMARY OF ECONOMIC FEASIBILITY The economic analysis of the tomato application compared data on yields, crop prices, revenues and costs using methyl bromide and using alternative pest control regimens in order to estimate the loss of methyl bromide availability. The alternatives identified as technically feasible  in cases of low pest infestation  by the U. S. are: ( a) 1,3 Dichloropropene + Chloropicrin; ( b) Metam sodium; and ( c) Chloropicrin. Changes in pest control costs for tomatoes are less than 4 percent of total variable costs therefore they would have little impact on any of the economic measures used in the analysis.

The economic factors that really drives the feasibility analysis for fresh market tomato uses of methyl bromide are: ( 1) yield losses, referring to reductions in the quantity 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 ( 3) quality losses, which generally affect the quantity and price received for the goods, and ( 4) missed market windows due to plant back time restrictions, which also affect the quantity and price received for the goods.

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

( 1) 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. Page 44 ( 2) Loss per Kilogram of Methyl Bromide. This measure indicates the 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.

( 5) Operating Profit Margin. We define operating profit margin to be net operating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more difficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to assess the economic feasibility of methyl bromide alternatives for methyl bromide users, who are tomato 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.

California We conclude that, at present, no economically feasible alternatives to MeBr exist for use in California tomato production. Yield loss in California tomato production is expected to be 15~ 20% when using MeBr alternatives. Growers will experience loss on a per hectare basis of approximately US$ 8,618 to US$ 11,059 and approximately 10% and 35% losses in gross and net operating revenues, respectively. These measures clearly indicate that Metam Sodium is not an economically feasible alternative to MeBr.

We have quantified the economic conditions of tomato growers as best as possible but, primarily due to limited data availability, are unable to capture every aspect of the economic picture in our numeric analysis. Factors not accounted for in this analysis are distribution of yield loss across individual growers and the yield risk associated with using MeBr alternatives.

Michigan We conclude that, at present, no economically feasible alternatives to MeBr exist for use in Michigan tomato production. Three factors have proven most important in our conclusion. These are yield loss, quality loss, and missed market windows, which are discussed individually below. Page 45 1. Yield Loss  Expected yield losses of 6% are anticipated throughout Michigan tomato production.

2. Quality Loss   Expected quality losses of 7% are anticipated throughout Michigan tomato production. The quality losses are translated into a reduction in the season average price by 1~ 3%.

3. Missed Market Windows  We agree with Michigan's assertion that growers will likely receive significantly lower prices for their produce if they switch to 1,3 D + chloropicrin or Metam Sodium or Chloropicrin. This is due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals when using these alternatives.

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

To describe these conditions in Michigan tomato production, we used daily tomato sales data from the U. S. Department of Agriculture for the previous year to gauge the impact of early season price fluctuations on gross revenues. Though data availability is limiting, we assume that if tomato growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin or Metam Sodium or Chloropicrin, that they will, over the course of the growing season, accumulate gross revenues reduced by approximately 4~ 11%. We reduced the season average price by 4~ 11% in our analysis of the alternatives to reflect this. Based on currently available information, we believe this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MeBr alternatives are used in Michigan.

Southeastern US We conclude that, at present, no economically feasible alternatives to MeBr exist for use in Southeastern US tomato production. Two factors have proven most important in our conclusion. These are yield loss and missed market windows, which are discussed individually below.

1. Yield Loss  Expected yield losses of 6% are anticipated throughout Michigan tomato production.

2. Missed Market Windows  We agree with Southeastern US's assertion that growers will likely receive significantly lower prices for their produce if they switch to 1,3 D + chloropicrin. This is Page 46 due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals when using these alternatives.

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

To describe these conditions in Southeastern US tomato production, we used weekly tomato sales data from the U. S. Department of Agriculture for the previous three years to gauge the impact of early season price fluctuations on gross revenues. Though data availability is limiting, we assume that if tomato growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin, that they will, over the course of the growing season, accumulate gross revenues reduced by approximately 12%. We reduced the season average price by 12% in our analysis of the alternatives to reflect this. Based on currently available information, we believe this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MeBr alternatives are used in Southeastern US. Page 47 PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP? ( Based on responses to Question 13, the answer should include activities that would be undertaken to overcome the difficulties that resulted in the alternatives being considered unsuitable. Include a timetable for completion of key activities.):

Since 1997, the United States EPA has made the registration of alternatives to methyl bromide a high registration priority. Because the EPA currently has more applications pending in its registration review queue than the resources to evaluate them, EPA prioritizes the applications. By virtue of being a top registration priority, methyl bromide alternatives enter the science review process as soon as U. S. EPA receives the application and supporting data rather than waiting in turn for the EPA to initiate its review.

As one incentive for the pesticide industry to develop alternatives to methyl bromide, the Agency has worked to reduce the burdens on data generation, to the extent feasible while still ensuring that the Agency's registration decisions meet the Federal statutory safety standards. Where appropriate from a scientific standpoint, the Agency has refined the data requirements for a given pesticide application, allowing a shortening of the research and development process for the methyl bromide alternative. Furthermore, Agency scientists routinely meet with prospective methyl bromide alternative applicants, counseling them through the preregistration process to increase the probability that the data is done right the first time and rework delays are minimized The U. S. EPA has also co chaired the U. S. DA/ EPA Methyl Bromide Alternatives Work Group since 1993 to help coordinate research, development and the registration of viable alternatives. This coordination has resulted in key registration issues ( such as worker and bystander exposure through volatilization, township caps and drinking water concerns) being directly addressed through USDA's Agricultural Research Service's U. S.$ 15 million per year research program conducted at more than 20 field evaluation facilities across the country. Also EPA's participation in the evaluation of research grant proposals each year for USDA's U. S.$ 2.5 million per year methyl bromide alternatives research has further ensured close coordination between the U. S. government and the research community.

As per Culpepper ( 2004), over 50 vegetable trials, focusing on weed management, were conducted by the University of Georgia. Four of these trials compared methyl bromide alternatives and another 30 trials searched for the development and labeling of new herbicides for vegetables. During 2004, these experiments will be continued to find methyl bromide alternatives.

The amount of methyl bromide requested for research purposes is considered critical for the development of effective alternatives. Without methyl bromide for use as a standard treatment, the research studies can never address the comparative performance of alternatives. This would be a serious impediment to the development of alternative strategies. The U. S. government estimates that tomatoes research will require 5501 kg per year of methyl bromide for 2005 and 2006. This research request also includes the amounts for asparagus, cabbage, ginseng, and Page 48 nutsedge for 74 kg per year. This amount of methyl bromide is necessary to conduct research on alternatives and is in addition to the amounts requested in the submitted CUE applications. One example of the research is a field study testing the comparative performance of methyl bromide, host resistance, cultural practices, pest management approaches for control of root knot nematodes. Another example is a five year field study comparing methyl bromide to 1,3 D combined with biologically based materials including transplant treatments for control of weeds, root knot nematodes and soil borne fungal pathogens.

24. HOW DO YOU PLAN TO MINIMIZE THE USE OF METHYL BROMIDE FOR THE CRITICAL USE IN THE FUTURE? ( Include a plan of the stepwise reduction schedule for methyl bromide as alternatives are phased in and/ or additional emission controls are implemented):

The U. S. wants to note that our usage rate is among the lowest in the world in requested sectors and represents efforts of both the government and the user community over many years to reduce use rates and emissions. We will continue to work with the user community in each sector to identify further opportunities to reduce methyl bromide use and emissions. Georgia experts ( Culpepper, 2004) note that the ability to reduce the use of methyl bromide will rely on the interaction of fumigant alternatives, plastic mulches and herbicide systems under specific growing conditions. More time is needed to develop these systems. Page 49 25. ADDITIONAL COMMENTS ON THE NOMINATION?)

Research efforts began in the early 1990' s to find out methyl bromide alternatives in various crops including tomato. With each year of experimentation the researchers became more familiar and efficient with methyl bromide fumigant alternatives for nutsedge management. The researchers learned strengths and weakness of each fumigant system, plastic film types, herbicide system, and various production environments. The researchers need more time to evaluate and refine these systems in large scale trials prior to large scale implementation at growers field level. Page 50 26. CITATIONS Chellemi, D., Botts, D. A. and Noling, J. W. 2001. Field scale demonstration/ validation studies of methyl bromide in plastic mulch culture in Florida, USDA ARS specific co operative agreement SCA # 58 6617 6 013, Executive Summary ( 1996 2001) submitted to the USEPA

Burnette, G. 2003. Personal communication, November 25, 2003.

Culpepper, Stanley. 2004. Faculty, University of Georgia, Athens, GA. Comments on methyl bromide Critical use nomination for preplant soil use for tomato grown in open fields.

Florida. 2000. Florida soil temperatures. Web address: www. imok. ufl/ edu/ weather/ archive/ 200/ clim00 Hausbeck, M. and Cortright, B. 2003. Soil temperature data submitted to BEAD ( OPP, US EPA) in support of methyl bromide critical use exemption application.

Jacob, W. C. 1977. Range of mean outside temperature and rainfall in South Eastern United States. Climatic Atlas of the United States. Published by the US Department of Commerce.

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

Locasio, S. J., Gilreath, J. P., Dickson, D. W., Kucharek, T. A., Jones, J. P. and Noling, J. W. 1997. Fumigant alternatives to methyl bromide for polyethylene mulched tomato. HortScience 32( 7) 1208 1211.

Morales, J. P., Santos, B. M., Stall, W. M. and Bewick. T. A. 1997. Effects of purple nutsedge ( Cyprus rotundus) on tomato and bell pepper vegetative growth and fruit yield. Weed Science Technology 11: 672 676.

Nelson, K. A. and Renner, K. A. 2002. Yellow nutsedge ( Cyprus esculentus) control and tuber production with glyphosate and ALS inhibiting herbicides. Weed Technology 16( 3): 512 519.

Norton, J., Nelson, R. D., Nelson, M. D., Olson, B. O., Mey, B. V. and Lepez, G. 2000. Field evaluation of alternatives to methyl bromide for pre plant soil fumigant in California tomatoes. USDA IR 4 methyl bromide alternatives program for minor crop. Report submitted to the US EPA during 2003 in support of methyl bromide critical use exemption.

Stall, W. M. and Morales Payan, J. P. 2003. The critical period of nutsedge interference in tomato, Florida. Web address: http:// www. imok. ufl. edu/ liv/ groups/ ipm/ weed_ con/ nutsedge. htm Page 51 U. S. Environmental Protection Agency. 1998. Re registration Eligibility Decision ( RED) 1,3 dichloroprppene. Available at http:// www. epa. gov/ REDs/ 0328red. pdf U. S. Environmental Protection Agency. 1998. Feasibility of using gas permeable tarps to reduce methyl bromide emissions associated with soil fumigation in the United States. Page 52 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI).

Date: Sector: 2001 & 2002 Average % of 2001 & 2002 Average % of Request 749 88% 88%

15,479 6% 6%

29,672 97% 101%

45,900 67% 69%

Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) % Reduction 10,745 223 48 66%

102,058 971 105 0%

2,799,236 18,645 150 38%

2,931,879 19,839 101 37%

37% 37%

2006 Low High Low High Low High Low High Low High Low High Low HIGH LOW 48 48 0% 0% 0% 0% 34% 34% 0% 0% 0% 0% 34% 34% 34% 34%

105 105 0% 0% 0% 0% 0% 0% 9% 1% 100% 100% 0% 0% 100% 100%

150 150 32% 32% 0% 0% 50% 29% 0% 0% 0% 0% 0% 0% 66% 53%

Strip Bed Treatment Currently Use Alternatives? Research /

Transition Plans Tarps /

Deep Injection Used Pest

free Cert.

Requirement Change from Prior CUE Request (+/) Verified Historic MeBr Use /

State Frequency of Treatment Loss per Hectare (

US$/

ha) Loss per Kilogram of MeBr (

US$/

kg) Loss as a %

of Gross Revenue Loss as a %

of Net Revenue Yes Yes Yes Tarp No  Yes 4,730 $ 98 $ 12% 50%

Yes Yes Yes Tarp No  Yes 8,618 $ 82 $ 10% 26%

Yes Yes Yes Tarp No  Yes 5,708 $ 38 $ 14% 39%

Conversion Units: 1 Pound = Kilograms Hectare Methyl Bromide Critical Use Exemption Process 2006 Methyl Bromide Usage Numerical Index ( BUNI) 1 Acre = Combined Impacts Adjustment ( kgs)

HIGH LOW 2006 Amount of Request 2001 & 2002 Average Use* Quarantine and Pre Shipment Kilograms ( kgs) Use Rate ( kg/ ha)

31,606 656 48 31,848 Hectares ( ha) Use Rate ( kg/ ha) Kilograms ( kgs) Hectares ( ha)

102,058 971 105 110,779 28,887 154 0%

661 48 0%

990 112 0%

4,519,688 30,104 150 4,442,326 TOTAL OR AVERAGE 4,653,353 31,731 101 2,079,698 30,537 105 0%

2006 Nomination Options Subtractions from Requested Amounts ( kgs) () QPS 31,606   2 2006 Request () Double Counting () Growth or 2002 CUE Comparison () Use Rate Difference 102,058     2,910,861  10,745  102,058 4,519,688  137,191

TOTAL 4,653,353 4,653,353 4,516,161 4,516,159 4,516,159 3,023,665 3% 3% 35%

REGION Michigan California Southeastern US % Reduction from Initial Request 0% 0% Regulatory Issues (%)

3%

Use Rate ( kg/ ha) (%) Karst Topography (%) 100 ft Buffer Zones (%) Key Pest Distribution REGION Michigan Unsuitable Terrain (%)

Other Considerations Dichotomous Variables ( Y/ N) Other Issues Economic Analysis California Southeastern US Adjustments to Requested Amounts 47% 1,3 D + Pic Combined Impacts (%)

15% Yield Loss, Range 15 to 20%

Cold Soil Temp (%) 10,745 102,058 2,352,736 2,465,540 0.453592 0.404686 REGION Michigan California Southeastern US California Southeastern US REGION Michigan MOST LIKELY IMPACT VALUE Regional Hectares**

2/ 26/ 2004 TOMATOES Average Hectares in the US:

% of Average Hectares Requested: 51,506 62%

21%, 6.2% Yield Loss + 14.8% delay Quality/ Time/ Market Window/ Yield Loss (%) Marginal Strategy 22%, 6% Yield Loss + 16% delay 1,3 D+ Pic+ herbicide Metam Sodium Page 53 Footnotes for Appendix A: Values may not sum exactly due to rounding. 1. Average Hectares in the US   Average Hectares in the US is the average of 2001 and 2002 total hectares in the US in this crop when available. These figures were obtained from the USDA National Agricultural Statistics Service. 2. % of Average Hectares Requested  Percent (%) of Average Hectares Requested is the total area in the sector's request divided by the Average Hectares in the US. Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 3. 2006 Amount of Request   The 2006 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. 4. 2001 & 2002 Average Use   The 2001 & 2002 Average Use is the average of the 2001 and 2002 historical usage figures provided by the 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. Adjustments are made when necessary due in part to unavailable 2002 estimates in which case only the 2001 average use figure is used. 5. Quarantine and Pre Shipment   Quarantine and pre shipment ( QPS) hectares is the percentage (%) of the applicant's request subject to QPS treatments. 6. Regional Hectares, 2001 & 2002 Average Hectares   Regional Hectares, 2001 & 2002 Average Hectares is the 2001 and 2002 average estimate of hectares within the defined region. These figures are taken from various sources to ensure an accurate estimate. The sources are from the USDA National Agricultural Statistics Service and from other governmental sources such as the Georgia Acreage estimates. 7. Regional Hectares, Requested Acreage %  Regional Hectares, Requested Acreage % is the area in the applicant's request divided by the total area planted in that crop in the region covered by the request as found in the USDA National Agricultural Statistics Service ( NASS). Note, however, that the NASS categories do not always correspond one to one with the sector nominations in the U. S. CUE nomination ( e. g., roma and cherry tomatoes were included in the applicant's request, but were not included in NASS surveys). Values greater than 100 percent are due to the inclusion of these varieties in the U. S. CUE request that were not included in the USDA NASS: nevertheless, these numbers are often instructive in assessing the requested coverage of applications received from growers. 8. 2006 Nomination Options   2006 Nomination Options are the options of the inclusion of various factors used to adjust the initial applicant request into the nomination figure. 9. Subtractions from Requested Amounts   Subtractions from Requested Amounts are the elements that were subtracted from the initial request amount. 10. Subtractions from Requested Amounts, 2006 Request   Subtractions from Requested Amounts, 2006 Request is the starting point for all calculations. This is the amount of the applicant request in kilograms. 11. Subtractions from Requested Amounts, Double Counting  Subtractions from Requested Amounts, Double Counting is the estimate measured in kilograms in situations where an applicant has made a request for a CUE with an individual application while their consortium has also made a request for a CUE on their behalf in the consortium application. In these cases the double counting is removed from the consortium application and the individual application takes precedence. 12. Subtractions from Requested Amounts, Growth or 2002 CUE Comparison  Subtractions from Requested Amounts, Growth or 2002 CUE Comparison is the greatest reduction of the estimate measured in kilograms of either the difference in the amount of methyl bromide requested by the applicant that is greater than that historically used or treated at a higher use rate or the difference in the 2006 request from an applicant's 2002 CUE application compared with the 2006 request from the applicant's 2003 CUE application. 13. Subtractions from Requested Amounts, QPS  Subtractions from Requested Amounts, QPS is the estimate measured in kilograms of the request subject to QPS treatments. This subtraction estimate is calculated as the 2006 Request minus Double Counting, minus Growth or 2002 CUE Comparison then Page 54 multiplied by the percentage subject to QPS treatments. Subtraction from Requested Amounts, QPS = ( 2006 Request   Double Counting   Growth)*( QPS %) 14. Subtraction from Requested Amounts, Use Rate Difference   Subtractions from requested amounts, use rate difference is the estimate measured in kilograms of the lower of the historic use rate or the requested use rate. The subtraction estimate is calculated as the 2006 Request minus Double Counting, minus Growth or 2002 CUE Comparison, minus the QPS amount, if applicable, minus the difference between the requested use rate and the lowest use rate applied to the remaining hectares. 15. Adjustments to Requested Amounts   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. 16. (%) Karst topography   Percent karst topography 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 topography. 17. (%) 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. 18. (%) 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. 19. 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. 20. 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. 21. 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. 22. 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 topography, 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 topography. 23. Qualifying Area  Qualifying area ( ha) is calculated by multiplying the adjusted hectares by the combined impacts. 24. Use Rate  Use rate is the lower of requested use rate for 2006 or the historic average use rate. 25. CUE Nominated amount  CUE nominated amount is calculated by multiplying the qualifying area by the use rate. 26. Percent Reduction  Percent reduction from initial request is the percentage of the initial request that did not qualify for the CUE nomination. 27. Sum of CUE Nominations in Sector  Self explanatory. 28. Total US Sector Nomination  Total U. S. sector nomination is the most likely estimate of the amount needed in that sector. 29. 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. 30. Strip Bed Treatment   Strip bed treatment is ` yes' if the applicant uses such treatment, no otherwise. 31. 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. Page 55 32. Research/ Transition Plans   Research/ Transition Plans is ` yes' when the applicant has indicated that there is research underway to test alternatives or if applicant has a plan to transition to alternatives. 33. 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. 34. Pest free cert. Required  This variable is a ` yes' when the product must be certified as ` pest free' in order to be sold 35. Other Issues. Other issues is a short reminder of other elements of an application that were checked 36. Change from Prior CUE Request This variable takes a `+' if the current request is larger than the previous request, a ` 0' if the current request is equal to the previous request, and a `` if the current request is smaller that the previous request. 37. Verified Historic Use/ State This item indicates whether the amounts requested by administrative area have been compared to records of historic use in that area. 38. 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. 39. Economic Analysis   provides summary economic information for the applications. 40. Loss per Hectare   This measures the total loss per hectare when a specific alternative is used in place of methyl bromide. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 41. Loss per Kilogram of Methyl Bromide   This measures the total loss per kilogram of methyl bromide when it is replaced with an alternative. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 42. Loss as a % of Gross revenue   This measures the loss as a proportion of gross ( total) revenue. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. 43. Loss as a % of Net Operating Revenue  This measures loss as a proportion of total revenue minus operating costs. Loss comprises both the monetized value of yield loss ( relative to yields obtained with methyl bromide) and any additional costs incurred through use of the alternative. It is measured in current US dollars. This item is also called net cash returns. 44. Quality/ Time/ Market Window/ Yield Loss (%)   When this measure is available it measures the sum of losses including quality losses, non productive time, missed market windows and other yield losses when using the marginal strategy. 45. Marginal Strategy  This is the strategy that a particular methyl bromide user would use if not permitted to use methyl bromide. Page 56 APPENDIX B. SUMMARY OF NEW APPLICANTS A number of new groups applied for methyl bromide for 2005 during this application cycle, as shown in the table below. Although in most cases they represent additional amounts for sectors that were already well characterized sectors, in a few cases they comprised new sectors. Examples of the former include significant additional country ( cured, uncooked) ham production; some additional request for tobacco transplant trays, and very minor amounts for pepper and eggplant production in lieu of tomato production in Michigan.

For the latter, there are two large requests: cut flower and foliage production in Florida and California (` Ornamentals') and a group of structures and process foods that we have termed ` Post Harvest NPMA' which includes processed ( generally wheat based foods), spices and herbs, cocoa, dried milk, cheeses and small amounts of other commodities. There was also a small amount requested for field grown tobacco.

The details of the case that there are no alternatives which are both technically and economically feasible are presented in the appropriate sector chapters, as are the requested amounts, suitably adjusted to ensure that no double counting, growth, etc. were included and that the amount was only sufficient to cover situations ( key pests, regulatory requirements, etc.) where alternatives could not be used.

The amount requested by new applicants is approximately 2.5% of the 1991 U. S. baseline, or about 1,400,000 pounds of methyl bromide, divided 40% for pre plant uses and 60% for postharvest needs.

The methodology for deriving the nominated amount used estimates that would result in the lowest amount of methyl bromide requested from the range produced by the analysis to ensure that adequate amounts of methyl bromide were available for critical needs. We are requesting additional methyl bromide in the amount of about 500,000 Kg, or 2% or the 1991 U. S. baseline, to provide for the additional critical needs in the pre plant and post harvest sector.

Applicant Name 2005 U. S. CUE Nomination ( lbs)

California Cut Flower Commission 400,000 National Country Ham Association 1,172 Wayco Ham Company 39 California Date Commission 5,319 National Pest Management Association 319,369 Michigan Pepper Growers 20,904 Michigan Eggplant Growers 6,968 Burley & Dark Tobacco Growers USA  Transplant Trays 2,254 Burley & Dark Tobacco Growers USA  Field Grown 28,980 Virginia Tobacco Growers  Transplant Trays 941 Page 57 Michigan Herbaceous Perennials 4,200 Ozark Country Hams 240 Nahunta Pork Center 248 American Association of Meat Processors 296,800 Total lbs 1,087,434 Total kgs 493,252 .