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

For Administrative Purposes Only:

Date received by Ozone Secretariat:

YEAR:                              CUN:

Nominating Party:	The United States of America

Brief Descriptive Title of Nomination:	Methyl Bromide Critical Use
Nomination for Pre-plant Soil Use for Tomato Grown in Open Fields
(Submitted in 2006 for 2008 Use Season)

Nominating Party Contact Details

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

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U.S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail:	  HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>

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

( Yes                                  ( No

Signature

Name

Date

Title:

Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting Division Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U.S.A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail:	  HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>

List of Documents Sent to the Ozone Secretariat in Official Nomination
Package

List all paper and electronic documents submitted by the Nominating
Party to the Ozone Secretariat

Paper Documents:

Title of Paper Documents and Appendices	Number of Pages	Date Sent to
Ozone Secretariat

electronic copies of all paper documents:

Title of Electronic Files	Size of File (kb)	Date Sent to Ozone
Secretariat

Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125796867"  Part A: Summary
PAGEREF _Toc125796867 \h  7

  HYPERLINK \l "_Toc125796868"  1. Nominating Party	  PAGEREF
_Toc125796868 \h  7

  HYPERLINK \l "_Toc125796869"  2. Descriptive Title of Nomination
PAGEREF _Toc125796869 \h  7

  HYPERLINK \l "_Toc125796870"  3. Crop and Summary of Crop System
PAGEREF _Toc125796870 \h  7

  HYPERLINK \l "_Toc125796871"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125796871 \h  7

  HYPERLINK \l "_Toc125796872"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125796872 \h  7

  HYPERLINK \l "_Toc125796873"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125796873 \h  8

  HYPERLINK \l "_Toc125796874"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125796874 \h  8

  HYPERLINK \l "_Toc125796875"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125796875 \h  9

  HYPERLINK \l "_Toc125796876"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125796876 \h  10

  HYPERLINK \l "_Toc125796877"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125796877 \h  11

  HYPERLINK \l "_Toc125796878"  Michigan - 10. Key Diseases and Weeds
for which Methyl Bromide Is Requested and Specific Reasons for this
Request	  PAGEREF _Toc125796878 \h  11

  HYPERLINK \l "_Toc125796879"  Michigan - 11. Characteristics of
Cropping System and Climate	  PAGEREF _Toc125796879 \h  11

  HYPERLINK \l "_Toc125796880"  Michigan - 12. Historic Pattern of Use
of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for which
an Exemption Is Requested	  PAGEREF _Toc125796880 \h  12

  HYPERLINK \l "_Toc125796881"  Michigan - Part C: Technical Validation
 PAGEREF _Toc125796881 \h  13

  HYPERLINK \l "_Toc125796882"  Michigan - 13. Reason for Alternatives
Not Being Feasible	  PAGEREF _Toc125796882 \h  13

  HYPERLINK \l "_Toc125796883"  Michigan - 14. List and Discuss Why
Registered (and Potential) Pesticides and Herbicides Are Considered Not
Effective as Technical Alternatives to Methyl Bromide:	  PAGEREF
_Toc125796883 \h  15

  HYPERLINK \l "_Toc125796884"  Michigan - 15. List Present (and
Possible Future) Registration Status of Any Current and Potential
Alternatives	  PAGEREF _Toc125796884 \h  16

  HYPERLINK \l "_Toc125796885"  Michigan - 16. State Relative
Effectiveness of Relevant Alternatives Compared to Methyl Bromide for
the Specific Key Target Pests and Weeds for which It Is Being Requested
 PAGEREF _Toc125796885 \h  16

  HYPERLINK \l "_Toc125796886"  Michigan - 17. Are There Any Other
Potential Alternatives Under Development which Are Being Considered to
Replace Methyl Bromide?	  PAGEREF _Toc125796886 \h  17

  HYPERLINK \l "_Toc125796887"  Michigan - 18. Are There Technologies
Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?
 PAGEREF _Toc125796887 \h  18

  HYPERLINK \l "_Toc125796888"  Michigan - Summary of Technical
Feasibility	  PAGEREF _Toc125796888 \h  18

  HYPERLINK \l "_Toc125796889"  South-Eastern United States - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796889 \h
18

  HYPERLINK \l "_Toc125796890"  South-Eastern United States - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125796890 \h  18

  HYPERLINK \l "_Toc125796891"  South-Eastern United States - 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125796891
\h  18

  HYPERLINK \l "_Toc125796892"  South-Eastern United States - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125796892 \h  19

  HYPERLINK \l "_Toc125796893"  South-Eastern United States - Part C:
Technical Validation	  PAGEREF _Toc125796893 \h  23

  HYPERLINK \l "_Toc125796894"  South-Eastern United States - 13. Reason
for Alternatives Not Being Feasible	  PAGEREF _Toc125796894 \h  23

  HYPERLINK \l "_Toc125796895"  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:
PAGEREF _Toc125796895 \h  25

  HYPERLINK \l "_Toc125796896"  South-Eastern United States - 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125796896 \h  26

  HYPERLINK \l "_Toc125796897"  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	  PAGEREF _Toc125796897 \h  28

  HYPERLINK \l "_Toc125796898"  South-Eastern United States - 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125796898 \h  31

  HYPERLINK \l "_Toc125796899"  South-Eastern United States - 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125796899 \h  31

  HYPERLINK \l "_Toc125796900"  South-Eastern United States - Summary of
Technical Feasibility	  PAGEREF _Toc125796900 \h  31

  HYPERLINK \l "_Toc125796901"  Part D: Emission Control	  PAGEREF
_Toc125796901 \h  32

  HYPERLINK \l "_Toc125796902"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use
 PAGEREF _Toc125796902 \h  32

  HYPERLINK \l "_Toc125796903"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125796903 \h  33

  HYPERLINK \l "_Toc125796904"  Part E: Economic Assessment	  PAGEREF
_Toc125796904 \h  34

  HYPERLINK \l "_Toc125796905"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125796905 \h  34

  HYPERLINK \l "_Toc125796906"  22. Gross and Net Revenue	  PAGEREF
_Toc125796906 \h  35

  HYPERLINK \l "_Toc125796907"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125796907 \h  36

  HYPERLINK \l "_Toc125796908"  Summary of Economic Feasibility
PAGEREF _Toc125796908 \h  37

  HYPERLINK \l "_Toc125796909"  Part F. Future Plans	  PAGEREF
_Toc125796909 \h  39

  HYPERLINK \l "_Toc125796910"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125796910 \h  39

  HYPERLINK \l "_Toc125796911"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125796911 \h  41

  HYPERLINK \l "_Toc125796912"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125796912 \h  41

  HYPERLINK \l "_Toc125796913"  26. Citations	  PAGEREF _Toc125796913 \h
 42

  HYPERLINK \l "_Toc125796914"  APPENDIX B. List of Treatments in MBTOC
Final Databases.	  PAGEREF _Toc125796914 \h  45

 List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125796235"  Part A:
Summary	  PAGEREF _Toc125796235 \h  7

  HYPERLINK \l "_Toc125796236"  Table 4.1: Methyl Bromide Nominated
PAGEREF _Toc125796236 \h  7

  HYPERLINK \l "_Toc125796237"  Table A.1: Executive Summary for
Tomatoes	  PAGEREF _Toc125796237 \h  8

  HYPERLINK \l "_Toc125796238"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125796238 \h  8

  HYPERLINK \l "_Toc125796239"  Table 8.1: Amount of Methyl Bromide
Requested for Critical Use – Michigan, Southeast U.S., and Georgia
PAGEREF _Toc125796239 \h  9

  HYPERLINK \l "_Toc125796240"  Table 8.2: Amount of Methyl Bromide
Requested for Critical Use – Florida	  PAGEREF _Toc125796240 \h  10

  HYPERLINK \l "_Toc125796241"  Michigan - Part B: Crop Characteristics
and Methyl Bromide Use	  PAGEREF _Toc125796241 \h  11

  HYPERLINK \l "_Toc125796242"  Michigan - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request	  PAGEREF _Toc125796242 \h
11

  HYPERLINK \l "_Toc125796243"  Michigan - Table 11.1: Characteristics
of Cropping System	  PAGEREF _Toc125796243 \h  11

  HYPERLINK \l "_Toc125796244"  Michigan - Table 11.2 Characteristics of
Climate and Crop Schedule	  PAGEREF _Toc125796244 \h  12

  HYPERLINK \l "_Toc125796245"  Michigan - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125796245 \h  13

  HYPERLINK \l "_Toc125796246"  Michigan - Part C: Technical Validation
 PAGEREF _Toc125796246 \h  13

  HYPERLINK \l "_Toc125796247"  Michigan – Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125796247 \h  13

  HYPERLINK \l "_Toc125796248"  Michigan – Table 14.1: Technically
Infeasible Alternatives Discussion	  PAGEREF _Toc125796248 \h  15

  HYPERLINK \l "_Toc125796249"  Michigan – Table 15.1: Present
Registration Status of Alternatives	  PAGEREF _Toc125796249 \h  16

  HYPERLINK \l "_Toc125796250"  Michigan Region – Table #?: Evaluation
pf Fumigants for managing Phytophthora	  PAGEREF _Toc125796250 \h  17

  HYPERLINK \l "_Toc125796251"  Michigan – Table 16.1: Effectiveness
of Alternatives – Key Pest 1	  PAGEREF _Toc125796251 \h  17

  HYPERLINK \l "_Toc125796252"  Michigan – Table C.1: Alternatives
Yield Loss Data Summary	  PAGEREF _Toc125796252 \h  17

  HYPERLINK \l "_Toc125796253"  South-Eastern United States  - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125796253 \h
18

  HYPERLINK \l "_Toc125796254"  South-Eastern United States - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
PAGEREF _Toc125796254 \h  18

  HYPERLINK \l "_Toc125796255"  South-Eastern United States - Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125796255 \h  19

  HYPERLINK \l "_Toc125796256"  South-Eastern United States - Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125796256 \h
19

  HYPERLINK \l "_Toc125796257"  Virginia  - Table 12.1 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125796257 \h  19

  HYPERLINK \l "_Toc125796258"  Southeast U.S. * - Table 12.2 Historic
Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796258 \h  20

  HYPERLINK \l "_Toc125796259"  Georgia  - Table 12.3 Historic Pattern
of Use of Methyl Bromide	  PAGEREF _Toc125796259 \h  20

  HYPERLINK \l "_Toc125796260"  Florida – North Florida - Table 12.4
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796260 \h  21

  HYPERLINK \l "_Toc125796261"  Florida – Ruskin / Palmetto - Table
12.5 Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796261
\h  21

  HYPERLINK \l "_Toc125796262"  Florida – palm Beach - Table 12.6
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796262 \h  22

  HYPERLINK \l "_Toc125796263"  Florida – Southwest - Table 12.7
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796263 \h  22

  HYPERLINK \l "_Toc125796264"  Florida – Dade County - Table 12.8
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125796264 \h  22

  HYPERLINK \l "_Toc125796265"  South-Eastern United States - Part C:
Technical Validation	  PAGEREF _Toc125796265 \h  23

  HYPERLINK \l "_Toc125796266"  South-Eastern United States – Table
13.1: Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125796266
\h  23

  HYPERLINK \l "_Toc125796267"  South-Eastern United States – Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125796267 \h  25

  HYPERLINK \l "_Toc125796268"  South-Eastern United States – Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125796268 \h  26

  HYPERLINK \l "_Toc125796269"  South-Eastern United States – Table
16.1: Effectiveness of Alternatives – Key Pest 1	  PAGEREF
_Toc125796269 \h  28

  HYPERLINK \l "_Toc125796270"  South-Eastern U.S. Alternatives –
Table 16.1: South-Eastern US Trellis Tomato Fumigation Trial	  PAGEREF
_Toc125796270 \h  28

  HYPERLINK \l "_Toc125796271"  South-Eastern U.S. Alternatives –
Table 16.2: South-Eastern US Fumigants and Varieties to Manage Southern
Bacterial Wilt of Tomato	  PAGEREF _Toc125796271 \h  28

  HYPERLINK \l "_Toc125796272"  South-Eastern U.S. Alternatives –
Table 16.3: Efficacy of Methyl Bromide Alternatives for Verticilllium
and Weed Management in Tomatoes	  PAGEREF _Toc125796272 \h  29

  HYPERLINK \l "_Toc125796273"  South-Eastern U.S. Alternatives –
Table 16.4: Methyl Bromide Alternatives in Tomato Production Systems in
North Carolina	  PAGEREF _Toc125796273 \h  29

  HYPERLINK \l "_Toc125796274"  South-Eastern U.S. Alternatives –
Table 16.5: Tomato Yields Are Not Significantly Different But Percent
Yield Loss Can Be Large	  PAGEREF _Toc125796274 \h  29

  HYPERLINK \l "_Toc125796275"  South-Eastern U.S. Alternatives –
Table 16.6: Pepper Yields Are Not Significantly Different But Percent
Yield Loss Can Be Large	  PAGEREF _Toc125796275 \h  30

  HYPERLINK \l "_Toc125796276"  South-Eastern United States – Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125796276 \h  31

  HYPERLINK \l "_Toc125796277"  Part D: Emission Control	  PAGEREF
_Toc125796277 \h  32

  HYPERLINK \l "_Toc125796278"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125796278 \h  33

  HYPERLINK \l "_Toc125796279"  Part E: Economic Assessment	  PAGEREF
_Toc125796279 \h  35

  HYPERLINK \l "_Toc125796280"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125796280 \h
 35

  HYPERLINK \l "_Toc125796281"  Table 22.1: Year 1 Gross and Net Revenue
  PAGEREF _Toc125796281 \h  35

  HYPERLINK \l "_Toc125796282"  Table 22.2: Year 2 Gross and Net Revenue
  PAGEREF _Toc125796282 \h  36

  HYPERLINK \l "_Toc125796283"  Table 22.3: Year 3 Gross and Net Revenue
  PAGEREF _Toc125796283 \h  36

  HYPERLINK \l "_Toc125796284"  Michigan - Table E.1: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc125796284 \h  36

  HYPERLINK \l "_Toc125796285"  Southeastern US - Table E.2: Economic
Impacts of Methyl Bromide Alternatives	  PAGEREF _Toc125796285 \h  37

  HYPERLINK \l "_Toc125796286"  Part F. Future Plans	  PAGEREF
_Toc125796286 \h  40

  HYPERLINK \l "_Toc125796287"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125796287 \h  44

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

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

The United States of America (U.S.)

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

Methyl Bromide Critical Use Nomination for Pre-plant Soil Use for Tomato
Grown in Open Fields (Submitted in 2006 for 2008 Use Season).

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

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

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

Year	Nomination Amount (kg)*	Nomination Area (ha)

2008	1,840,100	14,131

* Includes research amount

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

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.

Table A.1: Executive Summary for tomatoes *  TC "Table A.1: Executive
Summary for Tomatoes" \f F \l "1"

Region	Michigan 	Virginia	Southeast U.S**	Georgia	Florida – North
Florida	Florida – Ruskin / Palmetto	Florida – Palm Beach	Florida -
Southwest	Florida – Dade County

Amount of Applicant Request

2008 Kilograms	30,391	453,592	1,038,145	353,443	253,717	845,654	392,652
1,212,587	221,058

Amount of Nomination*

2008 Kilograms	30,310	91,628	377,955	147,366	98,222	327,373	152,396
473,253	136,097

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

**Includes Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South
Carolina, and Tennessee.

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

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 geology in the South-Eastern United States, including Florida.  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.

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

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

Region where Methyl Bromide use is requested	Total crop area

Average of 2001 and 2003 (ha)	Proportion of Request for methyl bromide
in 2003 (%)

Michigan Region	769	33

South-Eastern United States	28,646	100

National Total : *	51,506	57

* National total includes other regions not requesting methyl bromide

**Includes Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South
Carolina, Tennessee, and Virginia.

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.

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

Table 8.1: Amount of Methyl Bromide Requested for Critical Use –
Michigan, Southeast U.S., and Georgia  TC "Table 8.1: Amount of Methyl
Bromide Requested for Critical Use – Michigan, Southeast U.S., and
Georgia" \f F \l "1"

Region: 	Michigan 	Southeast U.S**	Georgia

Year of Exemption Request

Kilograms of Methyl Bromide	30,391	1,491,737	353,443

Use: Broadcast or Strip/Bed Treatment	Strip/Bed	Mostly Strip/Bed	Mostly
Strip/Bed

Formulation (ratio of methyl bromide/chloropicrin mixture) to be used
for the CUE	67/33	Mostly 67/33	Mostly 67/33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	253	9,534	2,353

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of methyl bromide	12.0	16.2	15.0

*Only 36.7% percent of an hectare receives this amount of methyl bromide
formulation

**Includes Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South
Carolina, Tennessee, and Virginia.

Table 8.2: Amount of Methyl Bromide Requested for Critical Use –
Florida  TC "Table 8.2: Amount of Methyl Bromide Requested for Critical
Use – Florida" \f F \l "1"

Region: 	Florida – North Florida	Florida – Ruskin / Palmetto	Florida
– Palm Beach	Florida - Southwest	Florida – Dade County

Year of Exemption Request	2008

Kilograms of Methyl Bromide	253,717	845,654	392,652	1,212,587	221,058

Use: Broadcast or Strip/Bed Treatment	Mostly Strip/Bed	Mostly Strip/Bed
Mostly Strip/Bed	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	Mostly 67/33	Mostly 67/33	Mostly
67/33

Total Area to be treated with the methyl bromide or methyl
bromide/Chloropicrin formulation (m2 or ha)	1,509	5,030	2,335	7,212
1,315

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of methyl bromide	16.8	16.8	16.8	16.8	16.8

*Only 36.7% percent of a hectare receives this amount of methyl bromide
formulation

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

The amount of methyl bromide nominated by the 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 geology, buffer zones, unsuitable terrain, and
cold soil temperatures.

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

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

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

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

Michigan Region	1. Crown, root and fruit rot caused by Phytophthora
capsici

2. Fusarium oxysporum wilt	MB 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.

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

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

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

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

Climatic Zone

(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?

In Michigan, low soil temperatures during late March to early April make
the use of in-kind (metam-sodium, 1,3-D + chloropicrin) fumigants
impractical because soil temperatures may be below the labeled minimums
or plant back restrictions may be too long (14 to 30 days) to allow
April transplanting of tomato seedlings in the field.

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

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

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

Area Treated (hectares)	195	233	260	270	256	278

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)	23,493	28,003	31,235	32,461	30,781	33,430

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	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*	120	120	120	120	120	120

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

*Only 36.7 percent land area is treated in the form of beds and
therefore dosage rate (g/m2) is higher.

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

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

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

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

Chemical Alternatives

1,3-D	It is not effective against fungal plant pathogens.  	No

Metam sodium	Metam sodium is effective against soil fungi.  However,
Michigan soil temperatures during April are too low to use this fumigant
for an early fresh market tomato crop.  Product label states that
tomatoes cannot be transplanted to the field for up to 21 days after
fumigation.  Technically, it is MB alternative, but economically it is
not a viable alternative.	No

Chloropicrin	Chloropicrin is ineffective as a 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 MB 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 MB 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

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 MB 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.  See paragraph below.  	No

Metam sodium + crop rotation	Same as for metam sodium.	No

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

The proposal by MBTOC to obviate the use of methyl bromide in Michigan
by applying some alternative (specifically a combination of 1,3-D and
chloropicrin) in the autumn preceeding crop planting will not work on
tomatoes.  In Michigan, the predominant agricultural treatment that uses
methyl bromide is one where methyl bromide is applied in strips of
raised beds.  Areas between the raised beds are not treated.  In
addition to the risk that the harsh winter conditions (prolonged periods
of below freezing weather with snow, sleet, and high winds) will tear
the plastic barrier, there is significant risk of flooding and
concomitant recontamination of the treated areas.  The length and
severity of the winter means 4-5 months of precipitation is ‘stored’
in frozen form and released over the short period of thaw in the spring.
 This thaw-based flooding can be exacerbated by heavy rainfalls (in
excess of 25 mm/event) that occur throughout the spring and summer in
Michigan.  Because phytophthora and verticillium are endemic in the
areas of Michigan for which methyl bromide is being requested, flooding
will transfer spores from the untreated to treated areas, resulting in
additional infected plants and severe crop losses.

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

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

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 crown 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*)

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

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

Name of Alternative	Present Registration Status

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

Methyl Iodide	Not registered.  	Yes	Unknown

Sodium azide	Not registered.  No registration package has been received.
No	Unknown

Furfural	Not registered.  Registration package has been received.	Yes
Unknown

Propargyl Bromide	Not registered.  No registration package has been
received.	No	Unknown

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

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

In 2003, the applicant submitted the results of one small scale field
trial on the efficacy of methyl bromide alternatives in controlling
Phytophthora capsici and its 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.  Results were inconclusive.  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 if fields are fumigated in early May
instead of April (using methyl bromide + chloropicrin).  In addition,
growers may also experience revenue losses if they miss early tomato
market when prices are higher.

This study was repeated during the 2004 growing season.  However, this
study does not represent the typical Michigan conditions because due to
the cool wet weather the plots were not treated until June 8 when the
soil was warm enough for the alternatives to be effective.  Results show
that yields from tomato plots treated with metam potassium (K-Pam),
alone or in combination with chloropicrin, and from plots treated with
1,3-D + chloropicrin (Telone C35) are not significantly different from
yields from plots treated with MB + chloropicrin or from yields from
untreated control plots (Hausbeck and Cartright, 2004).  As for the 2003
trial discussed above, results of the 2004 study are still inconclusive,
probably because of the occurrence of low pest pressure in the study
area.

Michigan Region – Table #? .  Evaluation of Fumigants for Managing
Phytophthora Crown and Fruit Rot of Solanaceous and Cucurbit Crops 2004
  TC "Michigan Region – Table #?: Evaluation pf Fumigants for managing
Phytophthora " \f F \l "1"

Alternative & Rate 	Plant Loss (%)	Marketable Yield Loss

MeBr  67:33 350 lb/A)	4.6 %	0%

Telone C-35 shank (392 gal/A)	15.3 % 	30%

Chloropicrin shank (344 lb/A) plus Metam potassium drip (174 lb/A)	0.60%
-23%

Chloropicrin shank (344 lb/A) plus Metam potassium drip (348 lb/A)	0.40%
-12%

Chloropicrin 99% shank (25 gal)	24.30%	11%

Metam potassium drip (348 lb/A)	1.70%	-17%

Metam potassium drip (174 lb/A)	2.10%	7%

Footnote.  Due to a wet spring the treatments were applied later than
typical for Michigan on June 8, 2004.

From Hausbeck and Cortright, 2004.

Michigan Region – Table 16.1: Effectiveness of Alternatives – Key
Pest 1  TC "Michigan – Table 16.1: Effectiveness of Alternatives –
Key Pest 1" \f F \l "1"

No additional information is available.

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

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

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 delays; Most likely losses are 6 % using
1,3 D + chloropicrin (the best alternative)

Reference: Alternatives for methyl bromide on cucurbit and Solanaceous
crops, 2003.  M.K. Hausbeck, B.D. Cortright.  2003.  Unpublished.

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

In Michigan the critical use exemption application states that 1,3-D +
chloropicrin, metam-sodium, 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).

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

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

Although metam sodium and a combination of 1,3-D + chloropicrin can
control the key target pest, Phytophthora, the resulting planting and
harvesting delays 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 that delay tomato harvest by 14-28 days, resulting 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  TC "South-Eastern United States  - Part B: Crop
Characteristics and Methyl Bromide Use" \f F \l "1"    TC "South-Eastern
United States - Part B: Crop Characteristics and Methyl Bromide Use" \f
C \l "1"

SOUTH-EASTERN UNITED STATES - 10. Key Diseases and Weeds for which
Methyl Bromide Is Requested and Specific Reasons for this Request  TC
"South-Eastern United States - 10. Key Diseases and Weeds for which
Methyl Bromide Is Requested and Specific Reasons for this Request" \f C
\l "2"

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

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

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 alternatives is effective in controlling the
key pests in the South-Eastern United States.

South-Eastern United States - 11. (i) Characteristics of Cropping System
and Climate  TC "South-Eastern United States - 11. Characteristics of
Cropping System and Climate" \f C \l "2"

SOUTH-EASTERN UNITED STATES - Table 11.1: Characteristics of Cropping
System  TC " South-Eastern United States - Table 11.1: Characteristics
of Cropping System" \f F \l "1"

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  TC "South-Eastern United States - Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone

(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

South-Eastern United States – 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?

In the Southeastern U.S., karst geology inhibits the use of all
fumigants that contain 1,3-D in a significant portion of the tomato
production areas.

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

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

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

Area Treated (hectares)	    1,439 	  1,719 	 2,038 	  2,102 	   1,983
Not Available

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)	242,014 	288,961 	342,711 	353,325 	333,390 	Not Available

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	16.8	16.8	16.8	16.8	16.8
16.8

Southeast U.S. * - Table 12.2 Historic Pattern of Use of Methyl Bromide
TC "Southeast U.S. * - Table 12.2 Historic Pattern of Use of Methyl
Bromide" \f F \l "1"

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

Area Treated (hectares)	5,564 	5,816 	   6,052 	 5,947 	6,131 	6,252

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)	835,014 	870,340 	 907,927 	891,844 	919,621 	937,856

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	15.0	15.0	15.0	15.0	15.0
15.0

*Includes Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South
Carolina, and Tennessee

Georgia  - Table 12.3 Historic Pattern of Use of Methyl Bromide  TC
"Georgia  - Table 12.3 Historic Pattern of Use of Methyl Bromide" \f F
\l "1"

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

Area Treated (hectares)	2,686	2,307	2,216	2,353	2,341	2,688

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)	512,423	354,727	332,778	353,443	351,620	403,710

formulations of methyl bromide (methyl bromide /Chloropicrin)	67/33
67/33	67/33	67/33	67/33	67/33

Method by which methyl bromide 	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

Actual dosage rate of Active Ingredient (g/m2)*	19.1	15.4	15.0	15.0	15.0
15.0

Florida – North Florida - Table 12.4 Historic Pattern of Use of Methyl
Bromide  TC "Florida – North Florida - Table 12.4 Historic Pattern of
Use of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	1,032	1,376	1,376	1,942	1,700	1,509

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)	199,690	246,754	246,754	348,359	335,295	291,740

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	19.4	17.9	17.9	17.9	19.7
19.3

Florida – Ruskin / Palmetto - Table 12.5 Historic Pattern of Use of
Methyl Bromide  TC "Florida – Ruskin / Palmetto - Table 12.5 Historic
Pattern of Use of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	5,443	5,261	6,313	6,313	6,313	5,030

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)	1,009,806	887,226	990,645	948,189	1,089,709	850,841

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	18.6	16.9	15.7	15.0	17.3
16.9

Florida – palm Beach - Table 12.6 Historic Pattern of Use of Methyl
Bromide  TC "Florida – palm Beach - Table 12.6 Historic Pattern of Use
of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	2,044	2,843	2,843	2,843	2,843	2,335

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)	329,852	471,600	446,108	426,989	490,719	395,060

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	16.1	16.6	15.7	15.0	17.3
16.9

Florida – Southwest - Table 12.7 Historic Pattern of Use of Methyl
Bromide  TC "Florida – Southwest - Table 12.7 Historic Pattern of Use
of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	7,345	8,529	8,529	8,529	8,529	7,212

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)	1,320,936	1,347,883	1,338,323	1,280,966	1,472,156	1,220,025

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

Actual dosage rate of Active Ingredient (g/m2)*	18.0	15.8	15.7	15.0	17.3
16.9

Florida – Dade County - Table 12.8 Historic Pattern of Use of Methyl
Bromide  TC "Florida – Dade County - Table 12.8 Historic Pattern of
Use of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	1,700	1,700	1,603	1,481	1,481	1,315

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)	283,858	283,858	251,471	222,460	255,663	226,121

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 	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

Actual dosage rate of Active Ingredient (g/m2)*	16.7	16.7	15.7	15.0	17.3
17.2

SOUTH-EASTERN UNITED STATES - Part C: Technical Validation  TC
"South-Eastern United States - Part C: Technical Validation" \f F \l "1"
   TC "South-Eastern United States - Part C: Technical Validation" \f C
\l "1"

SOUTH-EASTERN UNITED STATES - 13. Reason for Alternatives Not Being
Feasible  TC "South-Eastern United States - 13. Reason for Alternatives
Not Being Feasible" \f C \l "2"

SOUTH-EASTERN UNITED STATES – Table 13.1: Reason for Alternatives Not
Being Feasible  TC "South-Eastern United States – Table 13.1: Reason
for Alternatives Not Being Feasible" \f F \l "1"

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

Chemical Alternatives

1,3 dichloropropene (Telone)	Effective against nematodes, but not
against fungal plant pathogens and nutsedge weeds.  Approximately 40% of
tomato land has Karst geology.  Growers with Karst geology cannot use
1,3-D because of underground water contamination.  	No

Metam sodium/potassium	Metam (sodium or potassium) will control many
weeds, but control of nutsedge is very inconsistent, and this fumigant
is not very effective against soil nematodes. 	No

Chloropicrin	Chloropicrin controls soil fungi, but may also stimulate
nutsedge weed growth, and therefore it is not a viable option.  It
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 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

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
(cannot afford to take land out of production) feasible alternative to
MB because it does not, by itself, provide adequate control of fungi
and/or nutsedges.  Crops available for rotation to growers are also
susceptible to fungi, while fallow land can still harbor fungal
oospores.  The nutsedge tubers 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	This 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+ a herbicide (such as napropamide + s-metolachlor +
halosulfuron)	A combination of fumigants and herbicide partners 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 nearly equal to
yields obtained using MB and chloropicrin.  With this combination, in
areas where it can be used, growers may lose an average of 6.2% yield
(Chellemi et al., 2001).  	Some combinations are promising

Metam sodium + Chloropicrin	Although this combination may be more
effective than metam sodium alone in controlling fungal pests, it 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 MB alternative in the South-Eastern
United States, where growers cannot use telone due to karst geology.
Further studies need to be undertaken to ascertain whether or not it is
technically and economically viable.  	It shows promise

Telone + Chloropicrin	This combination 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 in these areas cannot use
telone because of state regulations and underground water contamination
issues.  	No

Telone + metam sodium + herbicide (such as napropamide + s-metolachlor +
halosulfuron)	This mixture could provide reasonable control of pests
when weed pressure is low to moderate and land does not have Karst
geology.  Growers will need to use one of the newly registered
herbicides if they use this combination, although they will be
constrained by certain limitations (described below). 	No

Metam sodium + Crop rotation	Same as metam sodium.

	Fumigant combination + herbicide partners	Current research suggests
that in areas of low pest pressure this combination may be suitable for
some growers as an alternative for methyl bromide.  In these situations
growers may employ a marginal strategy without major economic
dislocation if given a reasonable time frame for the transition.	Yes

* 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:  TC "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:" \f C \l "2"

SOUTH-EASTERN UNITED STATES – Table 14.1: Technically Infeasible
Alternatives Discussion  TC "South-Eastern United States – Table 14.1:
Technically Infeasible Alternatives Discussion" \f F \l "1"

Name of Alternative	Discussion

Glyphosate	It is a non-selective herbicide that can be applied to row
middles only, since direct application to the rows would  cause injury
to the tomato crop.  It does not provide residual control.  As a
post-emergence treatment, glyphosate will not provide season long
control of yellow and/or purple nutsedge in tomatoes.

Paraquat	It is a non-selective herbicide that will not control nutsedge
in the plant rows.  It does not provide residual control.  Repetitive
applications are required to achieve fair control of annual weeds in the
row middle (Culpepper, 2003).  It may also be applied prior to crop
emergence.  Direct 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 would not affect tuber viability,
allowing the weed to grow again.  Thus, paraquat cannot provide season
long.

SOUTH-EASTERN UNITED STATES - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives  TC
"South-Eastern United States - 15. List Present (and Possible Future)
Registration Status of Any Current and Potential Alternatives" \f C \l
"2"  :

SOUTH-EASTERN UNITED STATES – Table 15.1: Present Registration Status
of Alternatives  TC "South-Eastern United States – Table 15.1: Present
Registration Status of Alternatives" \f F \l "1"

Name of Alternative	Present Registration Status

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

Halosulfuron-methyl	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, but its
registration expired in December, 2002 (the manufacturer went out of
business)	No	No longer registered

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	Unlikely due to
phytotoxicity

Rimsulfuron	Registered for use on 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  postemergence 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.  No registration package has been received.
No	Unknown

Furfural	Not registered.  Registration package has been received.	Yes
Unknown

Propargyl Bromide	Not registered.  No registration package has been
received.	No	Unknown

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

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 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 halosulfuron-methyl, 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 post-emergence 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
rotational interval needed for second crop production and IPM programs.

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  TC
"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" \f C \l "2"

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 show that growers may harvest tomato yields that
are nearly equal to yields 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 crop experts maintain that tomato 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.  However, in areas of low to moderate pest
pressure, information suggests that some growers may employ a marginal
strategy without major economic dislocation if given a reasonable time
frame for the transition.  The assessment of need was adjusted to
account for this.  The crop experts were unable to provide yield loss
estimate without 2-3 years of field trials and maintain that more time
is needed to evaluate various MB 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  TC "South-Eastern United States – Table
16.1: Effectiveness of Alternatives – Key Pest 1" \f F \l "1"

South-Eastern US Alternatives Yield Loss Data Summary 2005

SOUTH-EASTERN U.S. Alternatives – Table 16.1: South-Eastern US Trellis
Tomato Fumigation Trial  TC "South-Eastern U.S. Alternatives – Table
16.1: South-Eastern US Trellis Tomato Fumigation Trial" \f F \l "1"

Treatment	Fusarium  infected stems	Dead Plants (%)	Marketable Yield Loss
(%)

Terrogas 98:2 (245 MeBr + 5 Pic lb ai/A)	1.5	10.8	0

Terrogas 80:20 (200 + 50 lb ai/A)	2.0	2.2	25

Telone C-17 (35 gal/A)	3.0	9.8	14

Metam sodium (50 gal/A)	1.8	3.3	15

Footnote:  Baldwin, R.E. &  C.M. Waldenmaier.  1991.

SOUTH-EASTERN U.S. Alternatives – Table 16.2: South-Eastern US
Fumigants and Varieties to Manage Southern Bacterial Wilt of Tomato  TC
"South-Eastern U.S. Alternatives – Table 16.2: South-Eastern US
Fumigants and Varieties to Manage Southern Bacterial Wilt of Tomato" \f
F \l "1"

Treatment	Diseased Plants (%)

Ralstonia solanacearum 	Marketable Yield

MeBr  98:2 (292 + 8 lb/A)	59% 	0%

Telone C-35 (35 gal/A)	84% 	23%

Chlor-O Pic (10.5 gal)	81% 	28%

Telone C-35 (30 gal/A)	84% 	35%

Footnote:  A Ralstonia solanacearum resistant variety BHN 446 was tried
with low disease incidence but commercially undesireable because fruit
was small and late maturing.

Driver , J.G.,& F.J. Louws.  2000

SOUTH-EASTERN U.S. Alternatives – Table 16.3: Efficacy of Methyl
Bromide Alternatives for Verticillium and Weed Management in Tomatoes
TC "South-Eastern U.S. Alternatives – Table 16.3: Efficacy of Methyl
Bromide Alternatives for Verticilllium and Weed Management in Tomatoes"
\f F \l "1"

Treatment	Verticillium dahliae Infected (%) 2004	Weeds per meter2

(Aug 19, 2004)	Marketable Yield Loss 2003

MeBr  67:33 (268 + 132 lb/A)	29	0	0%

Telone C-35 shank (35 gal/A)	17.4	5.8	4%

Telone InLine C-35 drip (35 gal/A)	-	-	13%

Chloropicrin 99% (150 gal)	24.2	26.5	14%

Metam sodium drip (75 gal/A)	-	-	8%

Metam sodium spray/till (75 gal/A)	-	-	15%

Tri chlor EC (200 lb/A)

-	22%

Footnote:  Louws, F.J., L.M. Ferguson, K. Ivors, J. Driver, K. Jennings,
D. Milks, P.B. Shoemaker & D.W. Monks.  2004

SOUTH-EASTERN U.S. Alternatives – Table 16.4: Methyl Bromide
Alternatives in Tomato Production Systems in North Carolina    TC
"South-Eastern U.S. Alternatives – Table 16.4: Methyl Bromide
Alternatives in Tomato Production Systems in North Carolina" \f F \l "1"

Treatment	Verticillium dahliae Rating (July 7, 2002)	Marketable Yield
Loss

MeBr  67:33 (268 + 132 lb/A)	4.9bc 	0%

Telone C-35 shank (35 gal/A)	10.6 bc	-3%

Telone InLine C-35 drip (35 gal/A)	24.6 ab	5%

Chloropicrin shank (15 gal)	0 c	-4%

Metam sodium drip (75 gal/A)	13.4 abc	2%

Metam sodium spray/till (75 gal/A)	9.3 bc	5%

Tri chlor EC (200 lb/A)	17.6 abc	9%

Tri chlor EC (200 lb/A) 1 week delay Metam (75 gal/A)	15.1	7%

Footnote:  Louws, F.J., L.M. Ferguson, N.P. Lynch, & P. B. Shoemaker.
2002

In Florida Gilreath et al 2003 looked at methyl bromide plus
chloropicrin (350 lb per acre of 67:33) versus
1,3-D-35%Pic/trifluralin/napropamide/chloropicrin (28 gal/0.5 lb/2
lb/125 lb) for pepper yield.  While the yields were not significantly
different there was a 14 to 13 percent yield loss compared to methyl
bromide plus chloropicrin.  In addition this alternative treatment with
additional chemicals willl require extra time to apply the other
pesticides and allow the second application of chloropicrin to off gas
so that the transplants are not killed.  This additional time delay
would lead to impacts in terms of the key market windows.

SOUTH-EASTERN U.S. Alternatives – Table 16.5: Tomato Yields Are Not
Significantly Different But Percent Yield Loss Can Be Large    TC
"South-Eastern U.S. Alternatives – Table 16.5: Tomato Yields Are Not
Significantly Different But Percent Yield Loss Can Be Large " \f F \l
"1"

	Bradenton FL	Immokalee FL

Treatment	Marketable Yield

(kg per 10 plants)	% Yield Change versus MeBr	Marketable Yield

(kg per 10 plants)	% Yield Change versus MeBr

Untreated	23	-56%	49	-16%

Methyl bromide:chloropicrin (350 lb of 67:33)	53	0%	58	0%

1,3-D-35%Pic + trifluralin + napropamide + chloropicrin

(28 gal/0.5 lb/2 lb/125 lb)	46	-14%	51	-13%

Footnote:  From Gilreath et al. 2003.  Proc. Fla. State Hort. Soc.

Recent research on have suggested that metham sodium, with and without
chloropicrin can provide yields that are not significantly different
than  methyl bromide plus chloropicrin treated fields.  However, under
heavy rainfall years (in June through July of 2004 in North Carolina
rain fell for 41 of 61 days) 1,3 D/Pic combinations have not shown
effective control in fields where heavy nutsedge pressure is present.
Combinations including trifluralin have shown stunting in tomato
especially during years of above average rainfall on the production
areas of the Southeastern US.

In other Florida research (Gilreath et al 2005) looked at methyl bromide
in combination with high barrier films for pepper production.  In that
study which had a high Cyperus spp. pressure there were no significant
difference in yield between any of the rates of methyl bromide with the
different types of films.  However, the non-significant difference
between treatment 2 and 3 is a 22% reduction in yield.  And while not
significant the difference between treatment 2 and 5 and 6 are equal to
17 and 14 yield losses respectively.  The data does go on to show that
there are virtually no difference in yield between treatment 2 and 4
(LDPE versus VIFP at one quarter the rate).  This type of inconsistency
suggests that even for very adept researchers there appear to be other
factors at play that can impact plant yield.  It also helps to reinforce
the fact that statistical significance may not always be the appropriate
benchmark when talking about yield loss.

SOUTH-EASTERN U.S. Alternatives – Table 16.6: Pepper Yields Are Not
Significantly Different But Percent Yield Loss Can Be Large    TC
"South-Eastern U.S. Alternatives – Table 16.6: Pepper Yields Are Not
Significantly Different But Percent Yield Loss Can Be Large " \f F \l
"1"

	Treatment	Use Rate

kg/ha	Yield

t/ha	% Change

1	Untreated

9.5	-31%

2	MeBr + Pic LDPE	392	13.8	0%

3	MeBr + Pic VIFP	196	10.8	-22%

4	MeBr + Pic VIFP	98	13.6	1%

5	MeBr + Pic VIFV	196	11.4	-17%

6	MeBr + Pic VIFV	98	11.9	-14%

Footnote:  From Gilreath et al. 2005.  Crop Protection 24: 285-287.

LDPE is low density polyethylene, VIFP and VIFV are virtually
impermeable film by Plastopil and Vikase respectively.

Another study by Gilreath, Santos, Motis, Noling and Mirusso (2005)
looks at nematode and Cyperus control in bell pepper (Capsicum annum).
In that study the authors state “For bell pepper yield, the
application of metam sodium and metam sodium + chloropicrin provided
similar fruit weight as for methy bromide + chloropicrin in two of the
three seasons.”  However, in that one year (Fall 2002) the yields went
from 18.8 t/ha for methyl bromide + chloropicrin to 13.7 t/ha for metam
sodium + chloropicrin or a 27% drop in yield.  This level of yield loss
could have severe economic impacts for a grower.  Because of the
inconsistency of some of the alternative treatments the U.S. does not
consider them to be a replacement for methyl bromide.

SOUTH-EASTERN UNITED STATES – Table C.1: Alternatives Yield Loss Data
Summary  TC "South-Eastern United States – Table C.1: Alternatives
Yield Loss Data Summary" \f F \l "1"

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

1,3 D + chloropicrin + herbicide 	Fungi, Nematodes and Nutsedges	–
10.1

(Chellemi et al., 2001)	6.2

Telone C-35 shank (35 gal/A + herbicide	Verticillium	3.0 better to 4%
worse.

Loews et al 2002 & 2004	0 (+/- 3.5%)

Chloropicrin followed by metam sodium	Verticillium	7% loss

Loews et al 2002	7%

	Range 3.0 to 10.1%

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?  TC "South-eastern United States – 17.  Are There Any
Other Potential Alternatives Under Development Which Are Being
Considered To Replace Methyl Bromide?" \f C \l "2"

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 for postemergence application, 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 crop 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 - 18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide?  TC
"South-Eastern United States - 18. Are There Technologies Being Used to
Produce the Crop which Avoid the Need for Methyl Bromide?" \f C \l "2"

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

South-Eastern United States - Summary of Technical Feasibility  TC
"South-Eastern United States - Summary of Technical Feasibility" \f C \l
"2"

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 for postmergence application 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 experts 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.

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

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

Several members of MBTOC and the USG were recently able to tour field
research sites in Florida and Georgia including the plots of Dr.
Gilreath.  During those discussions and in his recent research
publications (Gilreath et al 2005, Gilreath et al in press, and Gilreath
& Gilreath 2005) the improved pest control when using Virtually
Impermeable Film (VIF) or metalized films (using an aluminum layer such
as Canslit) was described (see also Table 16.5).  Dr. Gilreath and other
researchers were contacted on the topics of low permeability barrier
films, and newer application techniques.  Based on their input it
appears that VIF films have still not been widely adopted because of
problems in: laying the films, inelasticity and the resultant difficulty
in conforming to the bed shape, problems with linear shear, and the fact
that embossed films are not available.  The current versions of
metalized films are being widely tested by several researchers and
growers and they have the potential to reduce fumigant use rates with
better laying and bedshape conforming characteristics.  It is
anticipated that the results of many of these research plots and growers
field tests will be available next year.  These metalized films pose
several questions for adoption: the fate of the aluminum coating if it
“flakes off” on the soil during removal and the photostability of
the coating during multiple crop cycles as is common in the southeastern
U.S.  An additional concern with all of the low permeability films and
reduced use rates is poor uniformity of treatment unless the application
equipment must be redesigned to accommodate reduced flow rates and
pressure (Gilreath and Gilreath 2005).  While all of these results are
promising there are only a few researchers that have multi-year trials
with these films and new or modified application equipment.  Many
growers are said to be testing the new films, reduced rates of methyl
bromide, and other alternatives.  Without multi-year trials under a
range of environmental conditions the consistency, feasibility, and
adaptability cannot be assessed.

When evaluating research that MBTOC cites (Gilreath et al 2003) at the
Bradenton site the untreated control has 53 nutsedge (Cyperus rotundus)
plants per square yard while the Immokalee site has less than one plant
per square yard.  The current standard that the US recommends for
moderate nutsedge pressure is 5 to 30 plants per square yard.  At the
Bradenton site the nutsedge control was not significantly different
between MeBr:Pic (350 lb per acre) versus
1,3-D-35%Pic/trifluralin/napropamide/chloropicrin (28 gal/0.5 lb/2
lb/125 lb) but had 39% more nutsedge plants and a 17% reduction in
yield.  When comparing the same treatments at the second site at
Immokalee which had low nutsedge pressure (< 1 plant per square yard)
and no significant difference in Fusarium, or nematodes such as
Meloidogyne spp, Belonolainus spp. and Tylenchorhynchus spp. still had a
12.5% reduction in yield compared to methyl bromide.

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

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

What use/emission reduction methods are presently adopted?	Began
research during 2003	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?	Began research during 2003	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  TC "20. If Methyl Bromide Emission Reduction Techniques Are Not
Being Used, or Are Not Planned for the Circumstances of the Nomination,
State Reasons" \f C \l "2"  :

  SEQ CHAPTER \h \r 1 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 tomato 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 tomatoes 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 98% methyl bromide and 2% 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 tomato 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  TC "Part E: Economic Assessment" \f F \l
"1"    TC "Part E: Economic Assessment" \f C \l "1"

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

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

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

Michigan	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

	Chloropicrin	78	$    29,555	$    29,555	$    29,555

Southeastern US	Methyl Bromide	100	$     26,380	$     26,380	$
26,380

	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.

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

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

Year 1

Region	Alternatives

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

Michigan	Methyl Bromide	$    39,996	$      9,438

	1,3–D + Chloropicrin	 $    32,880 	 $      3,325

	Metam Sodium	 $    34,931 	 $      5,192

	Chloropicrin	$    32,880	 $      3,325

Southeastern US	Methyl Bromide	$     40,914	$     14,533

	1,3–D + Chloropicrin 	$    33,772	$      8,825

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

Year 2

Region	Alternatives

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

Michigan	Methyl Bromide	$    39,996	$      9,438

	1,3–D + Chloropicrin	 $    32,880 	 $      3,325

	Metam Sodium	 $    34,931 	 $      5,192

	Chloropicrin	$    32,880	 $      3,325

Southeastern US	Methyl Bromide	$     40,914	$     14,533

	1,3–D + Chloropicrin 	$    33,772	$      8,825

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

Year 3

Region	Alternatives

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

Michigan	Methyl Bromide	$    39,996	$      9,438

	1,3–D + Chloropicrin	 $    32,880 	 $      3,325

	Metam Sodium	 $    34,931 	 $      5,192

	Chloropicrin	$    32,880	 $      3,325

Southeastern US	Methyl Bromide	$     40,914	$     14,533

	1,3–D + Chloropicrin 	$    33,772	$      8,825

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

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

Michigan	Methyl Bromide	1,3-D + Pic	Metam Sodium	Chloropicrin

Production Loss (%) 	0%	6%	13%	6%

   Production per Hectare 	4,414	         4,132 	3,845 	4,132

* Price per Unit (us$)	$            9.44	 $            9.44 	 $
  9.44 	 $             9.448

= Gross Revenue per Hectare (us$)	$    41,652	 $    38986 	 $    36,279
 $      38986

- Operating Costs per Hectare (us$)**	$    37,055	 $    32453 	 $
31,170 	 $      32,453

= Net Revenue per Hectare (us$)	$      4596	 $      6,533 	 $      5,109
	 $        6,533

Five Loss Measures *

1. Loss per Hectare (us$)	$           -	$      1,937	$      512	$
1,937

2. Loss per Kilogram of Methyl Bromide (us$)	$           -	$         16
$          4	$           16

3. Loss as a Percentage of Gross Revenue (%)	0%	5%	1%	5%

4. Loss as a Percentage of Net Operating Revenue (%)	0%	42%	11%	42%

5. Operating Profit Margin (%)	11%	17%	14%	17%

**Note that the measures in the tables below must be interpreted
carefully.  Operating costs do not include fixed costs and net revenue
equals gross revenue minus operating costs.

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

Southeastern US	Methyl Bromide	 1,3-D + Pic

Production  Loss (%) 	0%	6%

   Production per Hectare 	4,551	         4,269

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

= Gross Revenue per Hectare (us$)	$     46,986	 $    44,073

- Operating Costs per Hectare (us$)**	$     26,660	 $    29,860

= Net Revenue per Hectare (us$)	$     20,326	 14,212

Five Loss Measures *

1. Loss per Hectare (us$)	$           -	$      6,113

2. Loss per Kilogram of Methyl Bromide (us$)	$           -	$          36

3. Loss as a Percentage of Gross Revenue (%)	0%	13%

4. Loss as a Percentage of Net Operating Revenue (%)	0%	30%

5. Operating Profit Margin (%)	43%	32%

**Note that the measures in the tables below must be interpreted
carefully.  Operating costs do not include fixed costs and net revenue
equals gross revenue minus operating costs.

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

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 and 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.

(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.

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.

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.

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.

Part F. Future Plans  TC "Part F. Future Plans" \f F \l "1"    TC "Part
F. Future Plans" \f C \l "1"

23. What Actions Will Be Taken to Rapidly Develop and Deploy
Alternatives for This Crop?  TC "23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?" \f C \l "2"

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 USDA/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 2007.  This
research request also includes the amounts for asparagus, cabbage,
ginseng, and 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.

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

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

Georgia experts (Culpepper, 2004) claims 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.

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

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 a few more years to evaluate and
refine these systems in large scale trials prior to large scale
implementation at growers’ field level.

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

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 US-EPA.

Baldwin, R.E. &  C.M. Waldenmaier.  1991. Trellis Tomato Fumigation
Trial 1991.  Eastern Shore Agricultural Experiment Station.  VA

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.

Driver , J.G.,& F.J. Louws.  2000.  Fumigants and varieties to manage
southern bacterial wilt of tomato.  North Carolina State University.

Florida. 2000. Florida soil temperatures. Web address:   HYPERLINK
"http://www.imok.ufl/edu/weather/archive/200/clim00"
www.imok.ufl/edu/weather/archive/200/clim00

Gilreath, J.P., J.P. Jones, T.N. Motis, B.M. Santos, J.W. Noling, and
E.R. Rosskopp.  2003. Evaluation of various chemical treatment for
potential as methyl bromide replacemnts for disinfetation of soilborne
pests in polyethylene-mulched tomato.  Proc. Fla. State Hort. Soc. 116:
151-158.

Gilreath, J.P., T.N. Motis, and B.M. Santos.  2005.  Cyperus spp.
Control with reduced methyl bromide plus chloropicrin doeses under
virtually impermeable films in pepper.  Crop Prot.  24: 285-287.

Gilreath, J.P. B.M. Santos, T.M. Motis, J.W. Noling, and J.M. Mirusso.
(2005) Methyl bromide alternatives for nematode and Cyperus control in
bell pepper (Capsicum annuum).  Crop Prot. 24: in press.

Hausbeck, M. and Cortright, B. 2003. Soil temperature data submitted to
BEAD (OPP, US-EPA) in support of methyl bromide critical use exemption
application.

Hausbeck, M.K. & B.D. Cortright. 2003.  Alternatives for methyl bromide
on cucurbit and Solanaceous crops.  Unpublished.

Hausbeck, M.K. & B.D. Cortright. 2004.  Evaluation of Fumigants for
Managing Phytophthora Crown and Fruit Rot of Solanaceous and Cucurbit
Crops; 2004.  .  Unpublished.

IR-4.  2003.  IR-4 Project Annual Report 2003.  Available online at
http://ir4.rutgers.edu/annreport/report2003.pdf

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.

Louws, F.J., L.M. Ferguson, K. Ivors, J. Driver, K. Jennings, D. Milks,
P.B. Shoemaker & D.W. Monks.  2004.  Efficacy of methyl bromide
alternatives for Verticillium and weed management in tomatoes.  North
Carolina State University.

Louws, F.J., L.M. Ferguson, N.P. Lynch, & P. B. Shoemaker.  2002.
Methyl bromide alternatives in tomato production systems in North
Carolina.  North Carolina State University.

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:   HYPERLINK
"http://www.imok.ufl.edu/liv/groups/ipm/weed_con/nutsedge.htm"
http://www.imok.ufl.edu/liv/groups/ipm/weed_con/nutsedge.htm

U.S. Environmental Protection Agency. 1998. Re-registration Eligibility
Decision (RED) 1,3 dichloroprppene. Available at   HYPERLINK
"http://www.epa.gov/REDs/0328red.pdf"
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.

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

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

APPENDIX B.  List of Treatments in MBTOC Final Databases.  TC "APPENDIX
B. List of Treatments in MBTOC Final Databases." \f C \l "1"

E-Mail Message from Ian Porter dated December 23, 2005

As discussed during the bilaterals in Senegal, we undertook to provide
you with a list of treatments that MBTOC would like some evaluation on
as possible alternatives to replace methyl bromide in future CUN's.
Allthough the list appears extensive often treatments are very similar
and could be discussed this way if necessary although the more detail we
get on individual treatments the better!!  The treatments in bold are
the highest priority (ie have shown good results in international
studies) but I have indicated against the crop type other treatments for
which we are aware of studies that shows their performance relative to
MB.

_

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ਁ氃愀϶_؀ralin (Treflan™)	Yes	Refer to # 11.

59	TC35MNa	TC35, Metam Sodium	 	Referred to in Tomato CUN as components
of multiple chemical mixtures (South-Eastern United States – Part C
Technical Validation).

60	TC35Nap	TC35; Napropamide (Devrinol™)	 	Referred to in Tomato CUN
as components of multiple chemical mixtures (South-Eastern United States
– Part C Technical Validation).

61	TC35Pic	TC35; Chloropicrin	 	Referred to in Tomato CUN as components
of multiple chemical mixtures (South-Eastern United States – Part C
Technical Validation).

62	TC35PicTrefDev	TC35; Treflan; Napropamide (Devrinol™); Chloropicrin
Yes	Referred to in Tomato CUN as components of multiple chemical
mixtures (South-Eastern United States – Part C Technical Validation).

63	TC35Sol	Solarization; TC35	 	See #3.

64	Vrlx	Vorlex CP	 	Registered cancelled in the United States.

Footnote:  TC17 and TC17 are considered to be Telone™
(1,3-dichloropicrin) with 17% chloropicrin or Telone™ with 35%
chloropicrin.

 PAGE

 PAGE   iii

U.S. Tomatoes

Page  PAGE   11

U. S. Tomatoes

Page  PAGE   47