METHYL BROMIDE CRITICAL USE NOMINATION FOR PREPLANT SOIL USE FOR CUCURBITS GROWN IN OPEN FIELDS ON PLASTIC TARPAULINS FOR ADMINISTRATIVE PURPOSES ONLY: DATE RECEIVED BY OZONE SECRETARIAT:

YEAR: CUN:

NOMINATING PARTY: The United States of America BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Cucurbits Grown in Open Fields on Plastic Tarpaulins NOMINATING PARTY CONTACT DETAILS Contact Person: John E. Thompson, Ph. D. Title: International Affairs Officer Address: Office of Environmental Policy U. S. Department of State 2201 C Street N. W. Room 4325 Washington, DC 20520 U. S. A. Telephone: ( 202) 647 9799 Fax: ( 202) 647 5947 E mail: ThompsonJE2@ state. gov Following the requirements of Decision IX/ 6 paragraph ( a)( 1), the United States of America has determined that the specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption.

X Yes

No CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Tina E. Levine, Ph. D. Title: Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency ii Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 308 3099 Fax: ( 703) 308 8090 E mail: levine. tina@ epa. gov LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE List all paper and electronic documents submitted by the Nominating Party to the Ozone Secretariat 1. PAPER DOCUMENTS: Title of Paper Documents and Appendices Number of Pages Date Sent to Ozone Secretariat 2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: Title of Electronic Files Size of File ( kb) Date Sent to Ozone Secretariat iii TABLE OF CONTENTS PART A: SUMMARY ____________________________________________________________ 7 1. Nominating Party _________________________________________________________ 7 2. Descriptive Title of Nomination______________________________________________ 7 3. Crop and Summary of Crop System___________________________________________ 7 4. Methyl Bromide Nominated _________________________________________________ 7 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 7 6. Summarize Why Key Alternatives Are Not Feasible_____________________________ 10 7. Proportion of Crops Grown Using Methyl Bromide _____________________________ 10 8. Amount of Methyl Bromide Requested for Critical Use __________________________ 12 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 14 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ______________ 16 Michigan  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 16 Michigan  11. Characteristics of Cropping System and Climate _____________________ 16 Michigan  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 18 MICHIGAN  PART C: TECHNICAL VALIDATION _____________________________________ 19 Michigan  13. Reason for Alternatives Not Being Feasible _________________________ 19 Michigan  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 22 Michigan  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 22 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 ___ 23 Michigan  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 24 Michigan  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 24 Michigan  Summary of Technical Feasibility ____________________________________ 25 SOUTHEASTERN USA EXCEPT GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________________________________________________________ 26 Southeastern USA except Georgia  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request _______________________________ 26 Southeastern USA except Georgia  11. Characteristics of Cropping System and Climate__ 26 Southeastern USA except Georgia  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ___________ 28 SOUTHEASTERN USA EXCEPT GEORGIA  PART C: TECHNICAL VALIDATION_______________ 29 Southeastern USA except Georgia  13. Reason for Alternatives Not Being Feasible _____ 29 Southeastern USA except Georgia  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _________________________________________________________________ 32 iv Southeastern USA except Georgia  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________ 33 Southeastern USA except Georgia  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 ___________________________________________________________ 34 Southeastern USA except Georgia  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? ______________ 35 Southeastern USA except Georgia  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? ________________________________ 36 Southeastern USA except Georgia  Summary of Technical Feasibility ________________ 36 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 37 Georgia  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 37 Georgia  11. Characteristics of Cropping System and Climate_______________________ 37 Georgia  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested __________________________________ 39 GEORGIA  PART C: TECHNICAL VALIDATION_______________________________________ 40 Georgia  13. Reason for Alternatives Not Being Feasible __________________________ 40 Georgia  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 42 Georgia  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 43 Georgia  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 ___ 44 Georgia  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 45 Georgia  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 45 Georgia  Summary of Technical Feasibility _____________________________________ 46 PART D: EMISSION CONTROL ___________________________________________________ 47 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 47 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 48 PART E: ECONOMIC ASSESSMENT________________________________________________ 49 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 49 22. Gross and Net Revenue___________________________________________________ 51 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 53 Summary of Economic Feasibility _____________________________________________ 59 PART F. FUTURE PLANS _______________________________________________________ 63 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 63 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 64 v 25. Additional Comments on the Nomination ____________________________________ 64 26. Citations ______________________________________________________________ 65 APPENDIX B. SUMMARY OF NEW APPLICANTS __________________________________ 74 LIST OF TABLES PART A: SUMMARY _____________________________________________________________ 7 Table 4.1: Methyl Bromide Nominated ____________________________________________ 7 Table A. 1: Executive Summary __________________________________________________ 9 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 10 Michigan  Table 8.1: Amount of Methyl Bromide Requested for Critical Use ____________ 12 Southeastern USA except Georgia  Table 8.2: Amount of Methyl Bromide Requested for Critical Use _____________________________________________________________ 12 Georgia  Table 8.3: Amount of Methyl Bromide Requested for Critical Use______________ 13 Table A. 2: 2005 Sector Request Cucurbit ________________________________________ 14 Table A. 3: 2006 Sector Nomination Cucurbit _____________________________________ 15 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 16 Michigan  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 16 Michigan  Table 11.1: Characteristics of Cropping System ___________________________ 16 Michigan  Table 11.2 Characteristics of Climate and Crop Schedule____________________ 17 Michigan  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 18 MICHIGAN  PART C: TECHNICAL VALIDATION________________________________________ 19 Michigan   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 19 Michigan   Table 14.1: Technically Infeasible Alternatives Discussion __________________ 22 Michigan   Table 15.1: Present Registration Status of Alternatives _____________________ 22 Michigan   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 24 SOUTHEASTERN USA EXCEPT GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________________________________________________________ 26 Southeastern USA except Georgia  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request_________________________________________________________ 26 Southeastern USA except Georgia  Table 11.1: Characteristics of Cropping System _______ 26 Southeastern USA except Georgia  Table 11.2 Characteristics of Climate and Crop Schedule 27 Southeastern USA except Georgia  Table 12.1 Historic Pattern of Use of Methyl Bromide __ 28 SOUTHEASTERN USA EXCEPT GEORGIA  PART C: TECHNICAL VALIDATION __________________ 29 Southeastern USA except Georgia   Table 13.1: Reason for Alternatives Not Being Feasible 29 Southeastern USA except Georgia   Table 14.1: Technically Infeasible Alternatives Discussion _______________________________________________________________________ 32 Southeastern USA except Georgia   Table 15.1: Present Registration Status of Alternatives _ 33 Southeastern USA except Georgia   Table C. 1: Alternatives Yield Loss Data Summary_____ 35 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 37 Georgia  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ___ 37 Georgia  Table 11.1: Characteristics of Cropping System ____________________________ 37 Georgia  Table 11.2 Characteristics of Climate and Crop Schedule _____________________ 38 Georgia  Table 12.1 Historic Pattern of Use of Methyl Bromide _______________________ 39 GEORGIA  PART C: TECHNICAL VALIDATION_________________________________________ 40 Georgia   Table 13.1: Reason for Alternatives Not Being Feasible______________________ 40 vi Georgia   Table 14.1: Technically Infeasible Alternatives Discussion ___________________ 42 Georgia   Table 15.1: Present Registration Status of Alternatives_______________________ 43 Southeastern USA except Georgia   Table C. 1: Alternatives Yield Loss Data Summary_____ 44 PART D: EMISSION CONTROL ____________________________________________________ 47 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 47 PART E: ECONOMIC ASSESSMENT _________________________________________________ 49 Table 21.1: Michigan  Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______________________________________________________________________ 49 Table 21.2: Southeastern USA except Georgia  Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______________________________________________ 50 Table 21.3: Georgia  Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period 50 Table 22.1: Michigan  Year 1, 2, and 3 Gross and Net Revenues_______________________ 51 Table 22.2: Southeastern USA except Georgia  Year 1, 2, and 3 Gross and Net Revenues ___ 51 Table 22.3: Georgia  Year 1, 2, and 3 Gross and Net Revenues ________________________ 52 Michigan Cucumber Table E. 1: Economic Impacts of Methyl Bromide Alternatives _______ 53 Michigan Melon  Table E. 2: Economic Impacts of Methyl Bromide Alternatives _________ 53 Michigan Winter Squash  Table E. 3: Economic Impacts of Methyl Bromide Alternatives ___ 54 Michigan Zucchini  Table E. 4: Economic Impacts of Methyl Bromide Alternatives________ 54 Michigan Winter Squash  Table E. 3: Economic Impacts of Methyl Bromide Alternatives ___ 55 Southeastern USA except Georgia Cucumber  Table E. 5: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________________ 55 Southeastern USA except Georgia Melons  Table E. 6: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________________ 56 Southeastern USA except Georgia Squash  Table E. 7: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________________ 56 Southeastern USA except Georgia Squash  Table E. 7: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________________ 57 Georgia Cucumber   Table E. 8: Economic Impacts of Methyl Bromide Alternatives _______ 57 Georgia Melon  Table E. 9: Economic Impacts of Methyl Bromide Alternatives___________ 58 Georgia Squash  Table E. 10: Economic Impacts of Methyl Bromide Alternatives _________ 58 Georgia Squash  Table E. 10: Economic Impacts of Methyl Bromide Alternatives _________ 59 PART F. FUTURE PLANS ________________________________________________________ 63 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 69 Page 7 PART A: SUMMARY 1. NOMINATING PARTY:

The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Cucurbits Grown in Open Fields on Plastic Tarpaulins 3. CROP AND SUMMARY OF CROP SYSTEM Cucurbits ( squash, melons, and cucumber) grown in Alabama, Arkansas, Georgia, Kentucky, Louisiana, Michigan, North Carolina, South Carolina, Tennessee, and Virginia. These crops are grown in open fields on plastic tarps, often followed by various other crops. Harvest is destined for the fresh market.

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA) 2006 753,202 5,363 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE The U. S. nomination is only for those areas where the alternatives are not suitable. In U. S. cucurbit 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 U. S. is only nominating a CUE for curcurbits where the key pest pressure is moderate to high such as nutsedge in the Southeastern U. S..  regulatory constraints: e. g., telone use is limited in Georgia 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. Page 8 In Michigan cucurbits, the only currently available methyl bromide ( MB) alternative that is technically feasible for the control of the key target pests is 1,3 D + chloropicrin. These pests are the soil borne fungi Phytophthora capsici and Fusarium oxysporum, both of which can easily destroy the entire harvest from affected areas if left uncontrolled. At least one of these pests, P. capsici, has recently been shown to occur in irrigation water in Michigan ( Gevens and Hausbeck 2003). This has probably contributed to the spread of this pathogen. Due to widespread pest distribution, virtually all of the cucurbit acreage in Michigan currently uses MB ( plus chloropicrin) as a prophylactic control of fungal pests. While 1,3 D + chloropicrin provided some control of fungi in recent small plot trials with cucurbits in Michigan ( Hausbeck and Cortwright 2003), there were yield losses ( approximately 6 %) relative to the MB + chloropicrin standard.

It is also not yet clear whether these small scale results accurately reflect efficacy of MB alternatives in commercial cucurbit production. Furthermore, regulatory restrictions due to concerns over human exposure and ground water contamination, along with the lower yields, result in potential economic infeasibility of this formulation as a practical MB alternative. Key among these factors are a delay in planting up to 14 days relative to MB, due to a combination label restrictions and the low soil temperatures typical of Michigan, as well as a mandatory 30 m buffer for treated fields with 1,3 D + chloropicrin near inhabited structures. Delays in planting may result in growers missing key market windows and premium harvest prices, and buffer zones will result in some areas remaining vulnerable to pests in the absence of MB.

In the Southeastern USA ( including Georgia), nutsedges are the primary target pest of concern. Some growers in this region also face root knot nematodes and the soil borne fungal pathogens ( described above) as key pests. Left uncontrolled, any of these pests could completely destroy the harvests from affected areas. Metam sodium offers some control of nutsedges and nematodes, while 1,3 D + chloropicrin provides good control of nematodes ( e. g., Eger 2000, Noling et al. 2000). However, in areas where nutsedge infestations are moderate to severe and fungal pathogens are present, metam sodium results in an estimated 44 % yield loss relative to MB. In such areas, use of 1, 3 D + chloropicrin is likely to lead to allow an estimated 29 % yield loss relative to MB. In addition to these estimated losses, it must be noted that 1,3 D + chloropicrin cannot be used in large portions of the southeastern USA ( primarily Kentucky and Georgia as regards this nomination) due to the presence of karst geology. 1,3 D cannot be used on such soil due to label restrictions created in response to concerns over groundwater contamination. Together, these yield losses and regulatory restrictions render these promising MB alternatives technologically and economically infeasible.

It should be noted also that all studies of yield losses for metam sodium and 1,3 D + chloropicrin relative to methyl bromide are based on small plot research trials done on non cucurbit crops. Large scale on farm trials will need to be conducted in cucurbits with high fungal and nutsedge pest pressure to determine the long term potential for these alternatives.

Some researchers have also reported that these MB alternatives are degraded more rapidly in areas where they are applied repeatedly, due to enhanced metabolism by soil microbes. This phenomenon may compromise long term efficacy of these compounds and appears to need further scientific scrutiny. Page 9 In sum, neither of these promising MB alternatives is presently adequate for control of key pests, and MB remains a critical use for cucurbits. in the southeastern USA also.

Michigan, Southeastern USA ( except Georgia), and Georgia are presented as separate regions in this nomination to reflect the separate applications from growers in these areas.

TABLE A. 1: EXECUTIVE SUMMARY*

Region Michigan Southeastern USA except Georgia Georgia AMOUNT OF NOMINATION 2006 Kilograms 27,656 461,257 257,985 Application Rate ( kg/ ha) 48 150 150 Area ( ha) 574 3,071 1,718 AMOUNT OF APPLICANT REQUEST 2006 Kilograms 27,656 928,739 405,837 Application Rate ( kg/ ha) 48 150 150 Area ( ha) 574 6,184 2,702 ECONOMICS FOR NEXT BEST ALTERNATIVE Technically Feasible Alternative( s) Best Alternative Best Alternative Best Alternative Yield Loss (%) 6% 29% 29%

Loss per hectare ( US$/ ha) $ 2,232 $ 2,883 $ 7,230 Loss per kg Methyl Bromide ( US$/ kg) $ 46 $ 19 $ 48 Loss as % of Gross Revenue (%) 12% 23% 21% Loss as % of Net Revenue (%) 55% 70% 52%

* See Appendix A for complete description of how the nominated amount was calculated Page 10 6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

Our review of available research on all other MB alternatives discussed by MBTOC for cucurbits suggests that, of registered ( i. e., legally available) chemistries only metam sodium and 1,3 D + chloropicrin have shown potential as commercially viable replacement to MB. Non chemical alternatives are either unviable for U. S. cucurbits or require more research and commercial development before they can be technically and economically feasible.

For Michigan pests 1,3 D + chloropicrin is the only key alternative with efficacy comparable to MB. However, it has regulatory restrictions due to human exposure concerns, along with technical limitations, that result in economic infeasibility of this formulation as a practical MB alternative. Key among these factors are a delay in planting as long as 30 days, due both to label restrictions and low soil temperatures, and a mandatory 30 m buffer for treated fields near inhabited structures.

For Southeastern USA and Georgia, metam sodium and 1,3 D + chloropicrin are the most promising alternatives for nutsedges and nematodes, respectively, which are the key target pests in these regions. However, where nutsedges are moderate to severe, metam sodium is technically and economically infeasible due to planting delays and yield losses, while 1,3 D + chloropicrin is infeasible due to ( 1) its use being prohibited on Karst geology, which are widespread in these regions, ( 2) a 21 day planting delay, and ( 3) yield losses. These effects have been discussed in Section 5 ( above).

There is also evidence that the pesticidal efficacy of both 1,3 D and metam sodium declines in areas where it is repeatedly applied, due to enhanced degradation of methyl isothiocyanate by soil microbes ( Ou et al. 1995, Verhagen et al. 1996, Dungan and Yates 2003, Gamliel et al. 2003).

All other potential or available MB alternatives are also technically infeasible for U. S. cucurbits ( see Section 13 of each region for further details).

7. ( i) PROPORTION OF CROPS GROWN USING METHYL BROMIDE TABLE 7.1: PROPORTION OF CROPS GROWN USING METHYL BROMIDE REGION WHERE METHYL BROMIDE USE IS REQUESTED TOTAL CROP AREA AVERAGE OF 2001 AND 2002 ( HA) PROPORTION OF TOTAL CROP AREA TREATED WITH METHYL BROMIDE (%) Michigan 8,114 7%

Southeastern USA except Georgia 21,489 24%

Georgia 25,191 11%

NATIONAL TOTAL*: 181,552 5% * Includes additional states not requesting methyl bromide. Page 11 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.

In Michigan, only acreage that has pest pressure is treated with MB.

In Southeastern USA and Georgia, areas not treated do not have nutsedges, or nematodes naturally present in cucurbit fields. Simple absence of all pests is the only reason these areas are not presently treated with MB.

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?

The primary reason that some cucurbits may be grown without methyl bromide in all three regions is the absence of key target pests ( i. e., nutsedge in the Southeast, and Georgia, soil pathogens and cold soil temperatures in Michigan, and karst topography in Georgia. Page 12 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE MICHIGAN  TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Michigan YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 27,656 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Strip/ Bed FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 574 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 71.6 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 48 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE Information not available.

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

SOUTHEASTERN USA EXCEPT GEORGIA  TABLE 8.2: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Southeastern USA except Georgia YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 928,739 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Strip/ Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 6184 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 223.9 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 150 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE Information not available * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 13 GEORGIA  TABLE 8.3: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Georgia YEAR OF EXEMPTION REQUEST 2006 KILOGRAMS OF METHYL BROMIDE 405,837 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Strip/ Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 2,702 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 223.9 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 150 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE Information not available.

* For Flat Fumigation treatment application rate and dosage rate may be the same. Page 14 9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION The amount of methyl bromide nominated by the U. S. 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 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, karst topography, unsuitable terrain, and cold soil temperatures.

TABLE A. 2: 2005 SECTOR REQUEST CUCURBIT*

2005 Cucurbit Sector Request Michigan Southeastern USA except Georgia Georgia Requested Hectares ( ha) 585 6,022 2,702 Requested Application Rate ( kg/ ha) 48 150 150 Applicant Request for 2005 Requested Kilograms ( kg) 28,187 904,426 405,837 * See Appendix A for complete description of how the nominated amount was calculated. Page 15 TABLE A. 3: 2006 SECTOR NOMINATION CUCURBIT*

2006 Cucurbit Sector Nomination Michigan Southeastern USA except Georgia Georgia Requested Hectares ( ha) 574 6,184 2,702 Requested Application Rate ( kg/ ha) 48 150 150 Applicant Request for 2006 Requested Kilograms ( kg) 27,656 928,739 405,837 Nominated Hectares ( ha) 574 3,071 1,718 Nominated Application Rate ( kg/ ha) 48 150 150 CUE Nominated for 2006 Nominated Kilograms ( kg) 27,656 461,257 257,985 Overall Reduction (%) 45 2006 U. S. CUE Nomination ( kg) 752,261 Research amount ( kg) 941 2006 Sector Nomination Totals Total 2006 U. S. Sector Nominated Kilograms ( kg) 753,202 * See Appendix A for complete description of how the nominated amount was calculated. Page 16 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE MICHIGAN  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST MICHIGAN  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Michigan Soilborne fungal diseases: Phytophthora capsici and Fusarium oxysporum No effective post emergence control available; 1,3 D + chloropicrin is technically but not economically feasible as a MB alternative due to regulatory and technical restrictions on use. Low soil temperatures and regulatory restriction also means that use of 1,3 D will delay planting and prevent growers from obtaining premium harvest prices in a narrow market window.

MICHIGAN  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE MICHIGAN  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS MICHIGAN CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplants grown for curcubit 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) Corn, soybeans, tomatoes, strawberries, other cucurbit crops. MB is not used for the other crops if applied once already in a given year.

SOIL TYPES: ( Sand, loam, clay, etc.) Light to medium loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once every year for a given field OTHER RELEVANT FACTORS: Soil temperatures are low relative to the rest of the U. S. cucurbit growing regions ( see below) Page 17 MICHIGAN  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) Temperate USDA 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 17.5 20.6 20.9 18.1 8 2.4  2.9  8  7 FUMIGATION SCHEDULE X PLANTING SCHEDULE X X X X KEY MARKET WINDOW X MICHIGAN   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Low soil temperatures ( often below 10 oC) prior to the typical planting window inhibit dissipation of 1,3 D + chloropicrin ( Martin 2003), which can delay planting due to phytotoxicity to crop plants. There is also a 21 day planting delay as per registration label language. Combined, this results in a delay as long as 30 days in planting crops, which may negatively affect the economics of cucurbit production in this region. Metam sodium transformation into the active ingredient, methyl isothiocyanate, is also slowed by low soil temperatures ( Ashley et al. 1963). Page 18 MICHIGAN  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED MICHIGAN  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 381 417 427 508 567 589 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 kilograms) 18736 20093 20556 24502 27331 28403 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) Shank injected Shank injected Shank injected Shank injected Shank injected Shank injected APPLICATION RATE OF FORMULATIONS IN kg/ ha* 71.6 71.6 71.6 71.6 71.6 71.6 APPLICATION RATE OF ACTIVE INGREDIENT IN kg/ ha* 48 48 48 48 48 48 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 29.1 29.1 29.1 29.1 29.1 29.1 ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* 19.5 19.5 19.5 19.5 19.5 19.5 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 19 MICHIGAN  PART C: TECHNICAL VALIDATION MICHIGAN  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE MICHIGAN   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D + chloropicrin In small plot trials conducted in Michigan, this formulation showed some efficacy against the key pests. It should be noted that these trials had not been completed at the time results were submitted to the U. S. EPA. Plant loss was about 6 % as compared to 0 % with MB ( Hausbeck and Cortwright 2003). While this suggests that it may be technically feasible, large scale trials have not been conducted to confirm the results. Furthermore, regulatory restrictions and Michigan's cool and wet soils result in a delay of up to 30 days in planting after treatment with this formulation. This results in growers missing key harvest windows, with consequent negative economic impacts ( detailed in other sections below). No Metam sodium Control of the key pests is inconsistent at best. A small plot trial in progress on cucurbits in Michigan indicates that plots with metam sodium had higher plant loss than the untreated check plots ( Hausbeck and Cortwright 2003). It should be noted that these trials had not been completed at the time results were submitted to the U. S. EPA. Another trial showed control of Fusarium in tomato, but this was performed in the much warmer conditions of southwest Florida ( Webster et al. 2001). In the cool conditions of Michigan, metam sodium is likely to be slow to transform into the active ingredient ( methyl isothiocyanate), which suggests that pest control will not be as effective as in the more favorable Florida conditions. No NON CHEMICAL ALTERNATIVES Soil solarization Michigan's climate is typically cool ( less than 11 oC frequently through May) and cloudy, particularly early in the growing season when control of the key pests is particularly important. In Michigan, the growing season is particularly short ( May to September), so the time needed to utilize solarization is likely to render the subsequent growing of crops impossible, even if it did somehow eliminate all fungal pathogens. No Page 20 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

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 cucurbit crops in Michigan. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize 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 that afflict cucurbits in Michigan. The bacterium Burkholder cepacia and the fungus Gliocladium virens have shown some potential in controlling some fungal plant pathogens ( Larkin and Fravel 1998). However, in a test conducted by the Michigan applicants ( included in the 2002 application from this region), P. capsici was not controlled adequately in summer squash, a cucurbit crop, by either of these beneficial microorganisms. No Cover crops and mulching There is no evidence these practices effectively substitute for the control methyl bromide provides against P. capsici. Control of P. capsici is imperative for cucurbit production in Michigan. Plastic mulch is already in widespread use in Michigan vegetables, and regional crop experts state that it is not an adequate protectant when used without methyl bromide. The longevity and resistance of P. capsici oospores renders cover crops ineffective as a stand alone management alternative to methyl bromide. No Crop rotation and fallow land The crop rotations available to growers in Michigan region are also susceptible to these fungi, particularly to P. capsici. Fallow land can still harbor P. capsici oospores ( Lamour and Hausbeck 2003). Thus fungi would persist and attack cucurbits if crop rotation/ fallow land was the main management regime. No Endophytes Though these organisms ( bacteria and fungi that grow symbiotically or as parasites within plants) apparently suppress some plant pathogens in cucumber ( MBTOC 1994), there is no such information for the other cucurbit crops grown in Michigan. Furthermore, the pathogens involved did not include P. capsici, arguably the greatest single threat to Michigan cucurbits. No Flooding/ Water management Flooding is not technically feasible as an alternative because it does not have any suppressive effect on P. capsici ( Allen et al. 1999), and is likely to be impractical for Michigan cucurbit growers. It is unclear whether irrigation methods in this region could be adapted to incorporate flooding or alter water management for cucurbit fields. In any case, there appears to be no supporting evidence for its use against the hardy oospores of P. capsici. No Page 21 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. Due to the paucity of scientific information on the utility of these alternatives as methyl bromide replacements in cucurbits, they have been grouped together for discussion in this document. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major cucurbit pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of Phytophthora and Fusarium fungi. Soilless culture, organic production, and substrates/ plug plants are also not technically viable alternatives to methyl bromide for fungi. One of the fungal pests listed by Michigan can spread through water ( Gevens and Hausbeck 2003), making it difficult to keep any sort of area ( with or without soil) disease free. Various aspects of organic production   e. g., cover crops, fallow land, and steam sterilization  have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Trials in tomato have shown inconsistent efficacy of this formulation against fungal pests, though it is generally better than metam sodium alone ( Locascio and Dickson 1998, Csinos et al. 1999). Low efficacy in even small plot trials indicates that this is not a technically feasible alternative for commercially produced cucurbits at this time. These studies apparently did not measure yield impacts, and did not involve cucurbits. No 1,3 D + Metam sodium Trials in tomato have shown inconsistent efficacy of this formulation against fungal pests, though it is generally better than metam sodium alone ( Csinos et al. 1999). Low efficacy in even small plot trials indicates that this is not a technically feasible alternative for commercially produced cucurbits in Michigan at this time. These studies apparently did not measure yield impacts, and did not involve cucurbits. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. Page 22 MICHIGAN  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

MICHIGAN   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION None Other than those options discussed elsewhere, no alternatives exist for the control of the key pests when they are present in the soil and/ or afflict the belowground portions of cucurbit plants. A number of effective fungicides are available for treatment of these fungi when they infect aerial portions of crops. However, these infections are not the focus of MB use, which is meant to keep newly planted transplants free of these fungi.

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

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

Methyl iodide Not registered in the USA for cucurbits. Registration is currently being pursued only for tomatoes, strawberries, peppers, and ornamental crops. No ( for cucurbits) Unknown Furfural Not registered in the USA for cucurbits. Registration is currently being pursued only for non food greenhouse uses. No ( for cucurbits) Unknown Sodium azide Not registered; no registration requests submitted to USA No ( for any crop/ commodity) Unknown Propargyl bromide Not registered; no registration requests submitted to USA No ( for any crop/ commodity) Unknown Page 23 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 As far as the U. S. can ascertain, virtually none of the studies on key MB alternatives has focused on cucurbits as the crop system. One exception to this situation can be summarized first, although this study was ongoing at the time it was submitted to U. S. EPA. This study is a field trial, conducted in small plots in 2003 in Michigan by M. K. Hausbeck and B. D. Cortwright of Michigan State University. This study focused on a number of vegetable crops including the cucurbits zucchini, winter squash, and melons. As of July 31, 2003, results indicated that 1,3 D + 35 % chloropicrin treatments ( shank injected at 56.7 liters/ ha) showed approximately 6 % plant loss ( due to both Phytophthora and Fusarium combined)   less than the 7 % loss seen in the untreated control plots. Metam sodium ( drip applied at 58.7 kg/ ha) showed a 13 % loss ( MB showed no loss). Methyl iodide ( currently unregistered for cucurbits) with either 50 % or 33 % chloropicrin ( shank injected, at either 46.1 or 36.8 kg/ ha, respectively) showed only 2 % plant loss. It should be noted that ( 1) since the trial had not yet ended, statistical analysis on these figures was not conducted, and ( 2) plant loss figures are for all vegetable crops combined.

In studies with other vegetable crops, 1,3 D + chloropicrin has generally shown better control of fungi than metam sodium formulations ( though still not as good as control with MB). For example, in a study using a bell pepper/ squash rotation in small plots, Webster et al. ( 2001) found significantly lower fungal populations with 1,3 D + 35 % chloropicrin ( drip applied, 146 kg/ ha of 1,3 D), as compared to the untreated control. However, MB ( 440 kg/ ha, shank injected) lowered fungal populations even more. It should be noted that P. capsici was not present in test plots, though Fusarium spp. were. Methyl iodide had no significant suppressive effect, as compared to the untreated control. However, neither of these MB alternatives increased squash fruit weight significantly over the untreated control. Indeed, as compared to the MB standard treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots, and 41 % lower in the methyl iodide plots. The proportion of marketable squash fruit ( defined only as those fruit so bad as to have to be discarded) in the 1,3 D plots was 30 % lower than that in the MB plots, though in the methyl iodide plots it was equivalent to MB. In another study, conducted in tomatoes, Gilreath et al. ( 1994) found that metam sodium treatments did not match MB in terms of plant vigor at the end of the season; again, Fusarium ( but not P. capsici) was one of several pests present. Page 24 MICHIGAN   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D + Chloropicrin Soil borne fungal diseases 0  30 % PLUS loss of revenue due to planting delays ( Note: 0 % is plausible only in cases where the initial infestation of Fusarium is very low, and P. capsici is absent) 6 % PLUS loss of revenue due to planting delays ( Hausbeck and Cortwright, 2003)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 6 % likely with the best alternative ( 1,3 D + chloropicrin)

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

The critical use exemption applicant states that 1,3 D + chloropicrin, metam sodium, furfural, propylene oxide, and sodium azide will continue to be the subjects of field studies of utilization and efficacy enhancement where Phytophthora and Fusarium fungi are the target pests. It should be kept in mind that furfural, propylene oxide, and sodium azide are currently unregistered for use on cucurbits, and there are presently no commercial entities pursuing registration in the USA. The regulatory restrictions on 1,3 D discussed elsewhere will also remain as negative influences on the economics of this MB alternative. 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 fungi) 2005   2007: Establish on farm demonstration plots for effective MB alternatives 2008   2010: Work with growers to implement widespread commercial use of effective alternatives.

Research is also under way to optimize the use of a 50 % MB: 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). All research is to be conducted by Michigan State University staff in collaboration with commercial cucurbit growers.

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

No. Page 25 MICHIGAN  SUMMARY OF TECHNICAL FEASIBILITY The U. S. EPA has determined that only 1,3 D + chloropicrin has some technical feasibility against the key pests of cucurbits in this region. Metam sodium alone has little efficacy against these pests; when combined with chloropicrin, it has shown better efficacy in trials with other vegetable crops ( e. g, peppers), but results have been inconsistent across different studies, and no large plot studies have been performed to show commercial feasibility in cucurbits ( e. g., Martin 2003, Hausbeck and Cortwright 2003, Csinos et al. 1999). Important technical constraints on both 1,3 D and metam sodium formulations must also be kept in mind: a 21   30 day planting delay, mandatory 100 foot buffers ( for 1,3 D) near inhabited structures   both of which will cause negative economic impacts, and potentially lower dissipation ( and thus efficacy) in the cool soils of this region.

Currently unregistered alternatives, such as furfural and sodium azide, have shown good efficacy against the key pests involved in small plot tests. However, even if registration is pursued soon ( and the U. S. EPA has no indications of any commercial venture planning to do so), these options will need more research on how to adapt them to commercial cucurbit production in Michigan. There are also no non chemical alternatives that are currently viable for MB replacement for commercial cucurbit growers. In sum, while the potential exists for a combination of chemical and non chemical alternatives to replace MB use in Michigan cucurbits, this appears to be at least a few years away. Page 26 SOUTHEASTERN USA EXCEPT GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE SOUTHEASTERN USA EXCEPT GEORGIA  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST SOUTHEASTERN USA EXCEPT GEORGIA  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE NEEDED " Southeastern USA except Georgia". A consortium of cucurbit growers in Alabama, Arkansas, Kentucky, Louisiana, North Carolina, South Carolina, Tennessee, and Virginia is included here Nutsedges: yellow ( Cyperus esculentum), and purple ( Cyperus rotundus); to a lesser extent: fungal diseases ( Phytophthora, Fusarium spp.) and root knot nematodes ( Meloidogyne incognita) No effective alternatives exist for control of the nutsedge, due to either lack of registration, planting delays ( due to regulatory restriction or phytotoxicity) or low efficacy, or lack of registration of potentially effective herbicides, all of which result in significant economic loss. In part of this region, fungal diseases may also have no effective control in the absence of MB, due to regulatory restrictions and planting delays associated with 1,3 D + chloropicrin use.

SOUTHEASTERN USA EXCEPT GEORGIA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE SOUTHEASTERN USA EXCEPT GEORGIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS SOUTHEASTERN USA EXCEPT GEORGIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplants grown for cucurbit 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) Other cucurbits, tobacco, grains, cotton SOIL TYPES: ( Sand, loam, clay, etc.) Low organic content, light to medium loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once every year OTHER RELEVANT FACTORS: Page 27 SOUTHEASTERN USA EXCEPT GEORGIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) Temperate USDA Plant Hardiness Zones 6b   8b SOIL TEMP. ( ° C) Not available.

RAINFALL ( mm) 163 124 109 87 78 146 113 202 109 116 54 76 OUTSIDE TEMP. ( ° C) 9.4 14.5 17.7 23.4 26 25.9 22.6 14.9 7.7 3.4 2.9 4.2 FUMIGATION SCHEDULE X X X PLANTING SCHEDULE X X X X X KEY MARKET WINDOW X SOUTHEASTERN USA EXCEPT GEORGIA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

In some areas of the southeast, alternatives are not effective against the key pests in this sector. Page 28 SOUTHEASTERN USA EXCEPT GEORGIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED SOUTHEASTERN USA EXCEPT GEORGIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 3,237 3,541 3,976 4,532 5,034 5,253 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED Not applicable AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 711,414 777,910 597,177 680,751 756,120 788,942 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 67: 33 67: 33 67: 33 67: 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shank injected Shank injected Shank injected Shank injected Shank injected Shank injected APPLICATION RATE OF FORMULATION IN kg/ ha* 224.5 224.5 223.9 223.9 223.9 223.9 APPLICATION RATE OF ACTIVE INGREDIENT IN kg/ ha* 220 220 150 150 150 150 ACTUAL DOSAGE RATE OF FORMULATION ( g/ m2)*

ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* Information not available.

* For Flat Fumigation treatment application rate and dosage rate may be the same. Page 29 SOUTHEASTERN USA EXCEPT GEORGIA  PART C: TECHNICAL VALIDATION SOUTHEASTERN USA EXCEPT GEORGIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE SOUTHEASTERN USA EXCEPT GEORGIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D + chloropicrin Effective ( in small plot studies) in controlling disease and nematode pests, but not nutsedges ( Locascio et al. 1997, Csinos et al. 1999, Noling et al. 2000). Subject to regulatory restrictions in some areas ( where Karst geology exist). No Metam sodium Provides control of nutsedges only close to application site ( Dowler 1999, Locascio and Dickson 1998). Surviving nutsedge tubers can potentially recolonize the crop field ( Webster 2002). Not effective against the disease or nematode pests in this region. Approximate yield losses due to nutsedge are 3   25 %; losses would be higher in areas facing the other key pests along with nutsedges. Technically and economically infeasible due to these yield losses ( see economic analyses in Part E) 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 50 oC or higher ( Chase et al. 1999). While this may be achieved for some portion of the autumn cropping in southern cucurbit growing regions, it is very unlikely for any portion of the spring crops. Trials conducted in mid summer in Georgia resulted in maximal soil temperatures of 43 oC at 5 cm depth. Thus, solarization, even in the warmer months in southern states, did not result in temperatures reliably 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 cucurbit 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 open cucurbit crops. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize soil down to the rooting depth of field crops ( at least 20 50 cm). No Page 30 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Biological Control Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens and/ or nutsedges that afflict cucurbits. While some fungal pathogens showed potential as control agents ( Phatak 1983), no work has yet been done on using these pathogens as reliable pest management tools in open field cucurbit crops. Season long field tests have shown low levels of pest control or lack of persistence of the control agents ( Kadir et al. 2000) No Cover crops and mulching Cover crops and mulches appear to control many weeds, but not nutsedges ( Burgos and Talbert 1996). The effect of cover crops on cucurbit crop growth and yield remains unknown; this contributes to the technical obstacles this strategy faces as a methyl bromide alternative. In some studies cover crops have delayed crop maturity and reduced height and yield of plants ( Burgos and Talbert 1996, Galloway and Weston 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 Crop rotation/ fallow is not a technically feasible alternative to methyl bromide because it does not, by itself, provide adequate control of fungi or nutsedges. The crop rotations available to growers are also susceptible to fungi; fallow land can still harbor fungal oospores ( Lamour and Hausbeck 2003). As regards nutsedges, tubers of these perennial species provide new plants with larger energy reserves than the annual weeds that can be frequently controlled by crop rotations and fallow land ( Thullen and Keeley 1975). Furthermore, nutsedge plants can produce tubers within 2 weeks after emergence ( Wilen et al. 2003). 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 Though these organisms ( bacteria and fungi that grow symbiotically or as parasites within plants) have shown potential against some pathogens in cucumber ( MBTOC 1994), there is no such information for the other cucurbit crops. Similarly, the USA found no evidence that endophytes control nutsedges No Page 31 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Flooding/ Water management As with many of the other alternatives to methyl bromide, flooding has been shown to control a number of weeds, but not nutsedge species. Nutsedge is 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. Another practical obstacle to implementing flood management approaches in cucurbit production in the southern and southeastern U. S. states is that the soil composition may not support flooding and still remain productive. No Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. The USA was unable to locate any studies showing any potential for grafting, resistant rootstock or plant breeding as technically feasible alternatives to methyl bromide control of nutsedges in cucurbits. While in theory plant breeding may improve the ability of cucurbits to compete with these weeds for nutrients, light, etc., it would certainly not provide alternatives within the time span considered in this critical use exemption nomination. The effect on the quality of the crops involved is unknown also. For resistant rootstock at least, there are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major cucurbit pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives. U. S. EPA found no evidence that soilless culture or substrates/ plug plants can be used to produce cucurbit crops on a large scale, or that they will control nutsedges, which like soil fungi are particularly hardy. Various aspects of organic production   organic mulches, cover crops, fallow land, steam sterilization have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Would possibly be more effective than metam sodium alone where fungal pests are the only concern ( see Michigan sections for more discussion), but this combination may not prevent yield losses due to nutsedges, particularly where the weed pressure is high. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). No 1,3 D + Metam sodium Controls nematodes but not nutsedges. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). Inconsistently effective against fungal pests ( see Michigan sections for more discussion). 1,3 D also subject to regulatory prohibition of use on Karst geology ( prevalent in Kentucky). No Page 32 * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

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

SOUTHEASTERN USA EXCEPT GEORGIA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Halosulfuron methyl Herbicide: causes potential crop injury; has plant back restrictions. Efficacy is lowered in rainy conditions ( common during the period of initial planting of these crops). Also, a 24 month plant back restriction may cause significant economic disruption if growers must rely on this control option. Halosulfuron is only allowed for the row middles for cucurbits, due to its phytotoxicity. This would result in nutsedges surviving close to crop plants. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

Glyphosate Herbicide: Is non selective; like halosulfuron, it will not control nutsedge within the plant rows; does not provide residual control. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

Paraquat Herbicide: Is non selective; will not control nutsedge in the plant rows; does not provide residual control. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated. Page 33 SOUTHEASTERN USA EXCEPT GEORGIA  15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

SOUTHEASTERN USA EXCEPT GEORGIA   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION: Methyl iodide For nutsedges and fungi: Not registered in the USA for cucurbits. Registration is currently being pursued only for tomatoes, strawberries, peppers, and ornamental crops No ( for cucurbits) Not applicable Pebulate For nutsedges: Was registered for use in tomatoes only, but even this registration lapsed December 31, 2002 ( registrant corporation went out of business) No ( for cucurbits) Not applicable S metolachlor For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Terbacil For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Rimsulfuron For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Trifloxysulfuron For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Page 34 SOUTHEASTERN USA EXCEPT GEORGIA  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 For a discussion of relative effectiveness of MB alternatives against fungal pests, please see Section 16 for the Michigan region. A brief discussion of this topic as regards the other key pests in southeastern USA except Georgia follows below. As with fungal pests, virtually all research on this topic has been conducted with other vegetable crops in the USA.

For root knot nematodes, both metam sodium and 1,3 D + 35 % chloropicrin have shown good efficacy in trials with tomato and pepper. For example, Locascio and Dickson ( 1998) reported that metam sodium + 35 % chloropicrin ( 295 l/ ha of metam sodium, shankinjected reduced nematode galls significantly over untreated control plots, though not as much as did MB + 35 % chloropicrin treatments ( 500kg MB/ ha, shank injected), in Florida tomatoes. Analysis of 35 tomato and 5 pepper trials conducted from 1993   1995 indicated that 1,3 D ( with either 17 % or 35 % chloropicrin) provided control of nematodes that was equal or superior to that seen with MB, in 95 % of the tomato and 100 % of pepper trials ( Eger 2000). However, it is not clear whether yields were also comparable to those obtained with MB. Noling et al ( 2000) also studied the effects of metam sodium ( 115 l/ ha, syringe injected), 1,3 D + 17 % chloropicrin ( 53.6 l/ ha, soil injected), and 1,3 D + 35 % chloropicrin ( 39.8 l/ ha), among other treatments, in tomato plots. Galls inflicted by root knot nematodes were reduced significantly by all these MB alternatives, as compared to untreated control plots. Yields were also significantly higher as compared to the control plots; all MB alternatives resulted in similar high yields. However, the effects of MB formulations were not reported in this study. Further, it is the opinion of some U. S. crop experts that metam sodium, in particular, is very inconsistent in its beneficial effects as a nematode control agent ( Dr. S. Culpeper, University of Georgia, personal communication).

For nutsedges, metam sodium and 1,3 D ( with and without chloropicrin) have shown inconsistent efficacy that is often inferior to that of MB formulations. For example, Locascio et al. ( 1997) studied MB alternatives on tomatoes grown in small plots in Florida. Various treatments were tested on plots that had multiple pests. At the Bradenton site there was moderate to heavy Fusarium infestation; heavy purple nutsedge infestation and light root knot nematode pressure. At Gainesville there was heavy infestation of yellow and purple nutsedge and moderate infestation of root knot nematode. The treatments at both locations included MB ( 67%) + chloropicrin ( 33%) chisel injected at 390 kg/ ha; metam sodium ( chisel injected) at 300L/ ha; metam sodium drip irrigated at 300L/ ha; and 1,3 D + 17% chloropicrin chisel injected at 327L/ ha. In pair wise statistical comparisons, the yield was significantly lower in metamsodium treatments compared to MB at both sites. At Bradenton, the average yield from both metam sodium treatments was 33% of the MB yields, suggesting a 67% yield loss from not using MB. At Gainesville, the average yield of the two metam sodium treatments was 56% of the MB yield, suggesting a 44% yield loss from not using MB. The yield of the 1,3 D treatment at Gainesville was 71% of the MB standard suggesting a 29% loss by not using MB ( yield data for 1,3 D were not reported for Bradenton). In considering 1,3 D results, the reader must keep in mind that this MB alternative cannot be used in areas where karst geology exists. No farm scale trials appear to have been done to validate these results as yet. Page 35 SOUTHEASTERN USA EXCEPT GEORGIA   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D + chloropicrin Nutsedges 0 40 % ( 0 % would be possible only in lightly infested areas; these areas are not included in this request for MB) 29 % ( Locascio, et al., 1997)

Metam sodium ( with or without chloropicrin) Nutsedges 0 66 % ( 0 % would be possible only in lightly infested areas; these areas are not included in this request for MB) 44 % ( Locascio, et al., 1997)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 29 % where 1,3 D can be used; 44 % where only metam sodium can be used SOUTHEASTERN USA EXCEPT GEORGIA  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

The applicant states that research has been conducted on nutsedge control with halosulfuron, 1,3 D + chloropicrin, and metam sodium. Future research will focus on halosulfuron and crop rotation for control of nutsedges. Approximately 3 to 5 years are expected as a timeframe for developing effective MB alternatives for nutsedge control in cucurbits produced in this region. Research will be conducted in cooperation with commercial cucurbit growers, by faculty and extension staff at various land grant universities in the states encompassed by this region. Also, it is reasonable to expect that the results from Michigan research on fungicidal alternatives to MB will be used to develop options for fungal pests of southeastern U. S. cucurbits.

Future plans to minimize MB use also include:

( 1) Using research and on farm evaluations optimize a combination of nutsedge control in fallow fields, crop rotation, and use of post emergent herbicide in crops. Herbicides will include halosulfuron, sulfentrazone, and glyphosate. ( 2) Optimize the combined use of plastic ( LDPE) tarps and drip irrigation equipment for applying at plant herbicides. Page 36 SOUTHEASTERN USA EXCEPT GEORGIA  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

No. Areas where MB is not used in this region do not face moderate to severe populations of the key pests.

SOUTHEASTERN USA EXCEPT GEORGIA  SUMMARY OF TECHNICAL FEASIBILITY As regards the key pests cited by the applicants from this region, technically feasible alternatives appear to exist for root knot nematodes, namely 1,3 D + chloropicrin and metamsodium ( by itself or with chloropicrin). 1, 3 D + chloropicrin also shows efficacy against the fungal pests in this region. However, this MB alternative has significant regulatory and technical limitations that are likely to result in negative economic impacts ( please see the summary of technical feasibility for Michigan for a discussion of these limitations). In addition to the limitations faced by Michigan growers, farmers in the southeastern USA who farm on Karst geology are prohibited from even considering this option due to regulatory restrictions intended to mitigate groundwater contamination. When 1,3 D cannot be used, growers in this region will have no technically feasible control option where fungi are the major pests.

For nutsedge pests, which are widespread in this region, cucurbit growers do not currently have technically feasible alternatives to MB use at planting. Metam sodium and 1,3 D + chloropicrin have shown some efficacy in small plot trials in other vegetable crops ( e. g, tomato). However, at best, metam sodium may allow at least 44 % yield loss, while 1,3 D may allow at least 29 % loss. Both often show less control than MB ( in terms of population suppression) of nutsedges. These factors suggest that even this alternative will not be economically feasible even in the best case technical scenario. It should be noted that there is evidence that both 1,3 D and methyl isothiocynate levels decline more rapidly, thus further compromising efficacy, in areas where these are repeatedly applied ( Smelt et al. 1989, Ou et al. 1995, Gamliel et al. 2003). This is due to enhanced degradation of these chemicals by soil microbes ( Dungan and Yates 2003). Other chemical alternatives to MB that have shown promise against nutsedges ( e. g, pebulate) are currently unregistered for cucurbits, and are often not being developed for registration by any commercial entity.

Large scale, on farm demonstrations of optimal application methodology in a commercial setting are lacking for cucurbit crops, adding to the current lack of viability of MB alternatives in this crop system. While a combination of alternatives may replace MB in future cucurbit production in this region, it remains some years away from technical feasibility. Page 37 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE GEORGIA   10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST GEORGIA  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE NEEDED Georgia Nutsedges: yellow ( Cyperus esculentum), and purple ( Cyperus rotundus); fungal diseases ( mainly Pythium spp.); to a lesser extent: root knot nematodes ( Meloidogyne incognita) No effective alternatives exist for control of the nutsedge, due to either lack of registration, planting delays ( due to regulatory restriction or phytotoxicity) or low efficacy, both of result in significant economic loss, or lack of registration of potentially effective herbicides. In part of this region, fungal diseases may also have no effective control in the absence of MB, due to regulatory restrictions on the only effective alternative ( 1,3 D + chloropicrin). Georgia may have a higher level of nematode pressure than the other southeastern states.

GEORGIA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE GEORGIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS GEORGIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Transplants grown for cucurbit fruit production.

ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual ( one)

TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Other cucurbits, bell pepper, squash, eggplant SOIL TYPES: ( Sand, loam, clay, etc.) Light to medium loam, low organic matter FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Once every year OTHER RELEVANT FACTORS: Karst geology are widespread in Georgia. Page 38 GEORGIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) Temperate USDA Plant Hardiness Zones 7a   8b SOIL TEMP. ( ° C) Not available RAINFALL ( mm) 206 108 148 248 0 158 84 122 109 137 37 131 OUTSIDE TEMP. ( ° C) 15 17.7 22.9 25.6 27.2 27.5 25.1 20 11.4 7.5 6.2 9.7 FUMIGATION SCHEDULE X X*

PLANTING SCHEDULE X X X KEY MARKET WINDOW X** X**

Notes: ( 1) * = This fumigation period is for a cantaloupe typically double cropped with squash, which is typically a spring application cycle; the other fumigation period shown is for cucumber usually double cropped with bell peer and squash usually double cropped with cabbage, both typically a fall cycle. ( 2) ** = U. S. EPA assumes these are the key market windows based on harvest schedule supplied by the applicant. According to the applicant, harvests for fall cycle crops occur in October & November, those for spring cycle crops occur in May through July. ( 3) Planting schedule is July and August for crops with a fall application cycle; March for those with a spring cycle.

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

Karst geology prevent widespread application of 1,3 D + chloropicrin as an alternative for disease and nematode control, because regulatory restrictions prohibit use of this chemical on the overlying soils. Page 39 GEORGIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED GEORGIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 1345 1873 2408 2062 2872 Not available.

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) 344859 462779 449691 317177 431487 Not available.

FORMULATIONS OF METHYL BROMIDE ( methyl bromide/ chloropicrin) 98: 2 98: 2 67: 33 67: 33 67: 33 67: 33 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Shank injected Shank injected Shank injected Shank injected Shank injected Shank injected APPLICATION RATE OF FORMULATION IN kg/ ha* 252 252 285.1 230 223.9 Not available.

APPLICATION RATE OF ACTIVE INGREDIENT IN kg/ ha* 247 247 191 154 150 Not available.

ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)*

ACTUAL DOSAGE RATE OF ACTIVE INGREDIENT ( g/ m2)* Information not available.

* For Flat Fumigation treatment application rate and dosage rate may be the same. Page 40 GEORGIA  PART C: TECHNICAL VALIDATION GEORGIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE GEORGIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 D + chloropicrin Effective ( in small plot studies) in controlling disease and nematode pests, but not nutsedges ( Locascio et al. 1997, Csinos et al. 1999, Noling et al. 2000). Subject to regulatory restrictions in some areas ( where Karst geology exist). No Metam sodium Provides control of nutsedges only close to application site ( Dowler 1999, Locascio and Dickson 1998). Surviving nutsedge tubers can recolonize the crop field ( Webster 2002). Not effective against the disease or nematode pests in this region. Approximate yield losses due to nutsedge are 3 66%; losses would be higher in areas facing the other key pests along with nutsedges. This alternative is both technically and economically infeasible due to these yield losses ( see economic analyses in Part E) 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 50 oC or higher ( Chase et al. 1999). While this may be achieved for some portion of the autumn cropping in southern cucurbit growing regions, it is very unlikely for any portion of the spring crops. Trials conducted in mid summer in Georgia resulted in maximal soil temperatures of 43 oC at 5 cm depth. Thus, solarization, even in the warmer months in southern states, did not result in temperatures reliably 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 cucurbit 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 open cucurbit crops. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize soil down to the rooting depth of field crops ( at least 20 50 cm). No Page 41 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Biological Control Biological control agents are not technically feasible alternatives to methyl bromide because they alone cannot control the soil pathogens and/ or nutsedges that afflict cucurbits. While some fungal pathogens showed potential as control agents ( Phatak 1983), no work has yet been done on using these pathogens as reliable pest management tools in open field cucurbit crops. Season long field tests have shown low levels of pest control or lack of persistence of the control agents ( Kadir et al. 2000) No Cover crops and mulching Cover crops and mulches appear to control many weeds, but not nutsedges ( Burgos and Talbert 1996). The effect of cover crops on cucurbit crop growth and yield remains unknown; this contributes to the technical obstacles this strategy faces as a methyl bromide alternative. In some studies cover crops have delayed crop maturity and reduced height and yield of plants ( Burgos and Talbert 1996, Galloway and Weston 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 Crop rotation/ fallow is not a technically feasible alternative to methyl bromide because it does not, by itself, provide adequate control of fungi or nutsedges. The crop rotations available to growers are also susceptible to fungi; fallow land can still harbor fungal oospores. As regards nutsedges, tubers of these perennial species provide new plants with larger energy reserves than the annual weeds that can be frequently controlled by crop rotations and fallow land. Furthermore, nutsedge plants can produce tubers within 8 weeks after emergence. This enhances their survival across different cropping regimes that can disrupt other plants that rely on a longer undisturbed growing period to produce seeds to propagate the next generation. No Endophytes Though these organisms ( fungi that grow symbiotically or as parasites within plants) have been shown to suppress some plant pathogens in cucumber, there is no such information for the other cucurbit crops. Similarly, the USA found no evidence that endophytes control nutsedges No Flooding/ Water management As with many of the other alternatives to methyl bromide, flooding has been shown to control a number of weeds, but not nutsedge species. Nutsedge is 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. Another practical obstacle to implementing flood management approaches in cucurbit production in the southern and southeastern U. S. states is that the soil composition may not support flooding and still remain productive. No Page 42 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates/ plug plants. The USA was unable to locate any studies showing any potential for grafting, resistant rootstock or plant breeding as technically feasible alternatives to methyl bromide control of nutsedges in cucurbits. While in theory plant breeding may improve the ability of cucurbits to compete with these weeds for nutrients, light, etc., it would certainly not provide alternatives within the time span considered in this critical use exemption nomination. The effect on the quality of the crops involved is unknown also. For resistant rootstock at least, there are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major cucurbit pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives. The USA found no evidence that soilless culture or substrates/ plug plants can be used to produce cucurbit crops on a large scale, or that they will control nutsedges, which like soil fungi are particularly hardy. Various aspects of organic production   organic mulches, cover crops, fallow land, steam sterilization have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Would be more effective than metam sodium alone where fungal pests are the only concern ( see Michigan sections for more discussion), but this combination may not prevent yield losses due to nutsedges, particularly where the weed pressure is high. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). Technically but not economically feasible due to these yield losses ( see economic analyses elsewhere) No 1,3 D + Metam sodium Controls nematodes but not nutsedges. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). Inconsistently effective against fungal pests ( see Michigan sections for more discussion). 1,3 D also subject to regulatory prohibition of use on Karst geology ( prevalent in Kentucky). No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration.

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

GEORGIA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION Page 43 NAME OF ALTERNATIVE DISCUSSION Halosulfuron methyl For nutsedges: potential crop injury; plant back restrictions. Efficacy is lowered in rainy conditions ( common during the period of initial planting of these crops). Also, a 24 month plant back restriction may cause significant economic disruption if growers must rely on this control option. Halosulfuron is only allowed on the row middles for cucurbits, due to its phytotoxicity. This would result in weeds surviving close to crop plants. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

Glyphosate For nutsedges: Non selective; will not control nutsedge in the plant rows; does not provide residual control. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

Paraquat For nutsedges: Non selective; will not control nutsedge in the plant rows; does not provide residual control. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

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

GEORGIA   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION: Methyl iodide For nutsedges: Not registered in the USA for cucurbits. Registration is currently being pursued only for tomatoes, strawberries, peppers, and ornamental crops No ( for cucurbits) Not applicable Pebulate For nutsedges: Was registered for use in tomatoes only, but even this registration lapsed December 31, 2002 ( registrant corporation went out of business) No ( for cucurbits) Not applicable S metolachlor For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Terbacil For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Rimsulfuron For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Trifloxysulfuron For nutsedges: registered for crops other than cucurbits No ( for cucurbits) Not applicable Page 44 GEORGIA  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 For a discussion of relative effectiveness of MB alternatives against fungal pests, please see Section 16 for the Michigan region. Though the fungal pest cited by Georgia growers is in a different genus ( Pythium), the relative effectiveness of relevant MB alternatives is likely to be similar to that where the other soil borne fungal pests are concerned. For a discussion of relative effectiveness of MB alternatives against root knot nematodes and nutsedges, please see Section 16 for the Southeastern USA region.

G EORGIA   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 D + chloropicrin Nutsedges 0 40 % ( 0 % would be possible only in lightly infested areas; these areas are not included in this request for MB) 29 % ( Locascio et al., 1997)

Metam sodium ( with or without chloropicrin) Nutsedges 0 66 % ( 0 % would be possible only in lightly infested areas; these areas are not included in this request for MB) 44 % ( Locascio et al., 1997)

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 29 % where 1,3 D can be used; 44 % where only metam sodium can be used Page 45 GEORGIA  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

For Georgia cucurbits, research focusing on the deployment of MB alternatives for control of nutsedges and Phytophthora fungi is planned. Field trials will include treatments with methyl iodide in combination with halosulfuron, 1,3 D in combination with chloropicrin and halosulfuron, and a combination of metam potassium, 1,3 D, and halosulfuron. The Georgia applicants provided no specific timeline for development and deployment, but it is reasonable to expect that the 3 5 year timeframe cited by cucurbit growers in the other southeastern U. S. states will probably apply. University of Georgia research and extension staff will conduct trials, presumably in collaboration with cooperating growers.

Future plans to minimize MB use also include:

( 3) Using research and on farm evaluations optimize a combination of nutsedge control in fallow fields, crop rotation, and use of post emergent herbicides in crops. Herbicides will include halosulfuron, sulfentrazone, and glyphosate. ( 4) Optimize the combined use of plastic ( LDPE) tarps and drip irrigation equipment for applying at plant herbicides.

It is also reasonable to expect that growers in this region will adopt measure shown in Michigan to be successful in minimizing MB use where fungal pests are the only key pests involved.

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

No. Areas where MB is not used in this region do not face moderate to severe populations of the key pests. Page 46 GEORGIA  SUMMARY OF TECHNICAL FEASIBILITY As regards the key pests cited by the applicants from this region, technically feasible alternatives appear to exist for root knot nematodes, namely 1,3 D + chloropicrin and metamsodium ( by itself or with chloropicrin). 1, 3 D + chloropicrin also shows efficacy against the fungal pests in this region. However, this MB alternative has significant regulatory and technical limitations that are likely to result in negative economic impacts ( please see the summary of technical feasibility for Michigan for a discussion of these limitations). In addition to the limitations faced by Michigan growers, farmers in Georgia who farm on Karst geology are prohibited from even considering this option due to regulatory restrictions intended to mitigate groundwater contamination. When 1,3 D cannot be used, growers in this region will have no technically feasible control option where fungi are the major pests.

For nutsedge pests, which are widespread in this region, cucurbit growers do not currently have technically feasible alternatives to MB use at planting. Metam sodium and 1,3 D + chloropicrin have shown some efficacy in small plot trials in other vegetable crops ( e. g, tomato). However, at best, metam sodium may allow at least 44 % yield loss, while 1,3 D may allow at least 29 % loss. Both often show less control than MB ( in terms of population suppression) of nutsedges. These factors suggest that even this alternative will not be economically feasible even in the best case technical scenario. It should be noted that there is evidence that both 1,3 D and methyl isothiocynate levels decline more rapidly, thus further compromising efficacy, in areas where these are repeatedly applied ( Smelt et al. 1989, Ou et al. 1995, Gamliel et al. 2003). This is due to enhanced degradation of these chemicals by soil microbes ( Dungan and Yates 2003). Other chemical alternatives to MB that have shown promise against nutsedges ( e. g, pebulate) are currently unregistered for cucurbits, and are often not being developed for registration by any commercial entity.

Large scale, on farm demonstrations of optimal application methodology in a commercial setting are lacking for cucurbit crops, adding to the current lack of viability of MB alternatives in this crop system. While a combination of alternatives may replace MB in future cucurbit production in this region, it remains some years away from technical feasibility. Page 47 PART D: EMISSION CONTROL 19. TECHNIQUES THAT HAVE AND WILL BE USED TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS IN THE PARTICULAR USE TABLE 19.1: TECHNIQUES TO MINIMIZE METHYL BROMIDE USE AND EMISSIONS TECHNIQUE OR STEP TAKEN VIF OR HIGH BARRIER FILMS METHYL BROMIDE DOSAGE REDUCTION INCREASED % CHLOROPICRIN IN METHYL BROMIDE FORMULATION LESS FREQUENT APPLICATION WHAT USE/ EMISSION REDUCTION METHODS ARE PRESENTLY ADOPTED? Currently some growers use HDPE tarps. Growers have switched from a 98% MB formulation to a 67 % formulation. Between 1997 and 2001, the U. S. has achieved a 36 % reduction in use rates. From 2 % to 33 % No WHAT FURTHER USE/ EMISSION REDUCTION STEPS WILL BE TAKEN FOR THE METHYL BROMIDE USED FOR CRITICAL USES? Research is underway to develop use in commercial production systems Research is underway to develop use of a 50 % MB formulation in Michigan commercial production systems. Not known if other regions are planning similar work. Research is underway to develop use of a 50 % MB formulation in Michigan commercial production systems. Not known if other regions are planning similar work. The U. S. anticipates that the decreasing supply of methyl bromide will motivate growers to try less frequent applications.

OTHER MEASURES ( please describe) Examination of promising but presently unregistered alternative fumigants and herbicides, alone or in combination with nonchemical methods, is planned in all regions ( Please see Section 17 for each region for details) Measures adopted in Michigan will likely be used in the other regions when fungi are the only key pests involved Measures adopted in Michigan will likely be used in the other regions when fungi are the only key pests involved Unknown Page 48 20. IF METHYL BROMIDE EMISSION REDUCTION TECHNIQUES ARE NOT BEING USED, OR ARE NOT PLANNED FOR THE CIRCUMSTANCES OF THE NOMINATION, STATE REASONS In accordance with the criteria of the critical use exemption, each party is required to describe ways in which it strives to minimize use and emissions of methyl bromide. The use of methyl bromide in the growing of cucurbit nurseries in the United States is minimized in several ways. First, because of its toxicity, methyl bromide has, for the last 40 years, been regulated as a restricted use pesticide in the United States. As a consequence, methyl bromide can only be used by certified applicators who are trained at handling these hazardous pesticides. In practice, this means that methyl bromide is applied by a limited number of very experienced applicators with the knowledge and expertise to minimize dosage to the lowest level possible to achieve the needed results. In keeping with both local requirements to avoid " drift" of methyl bromide into inhabited areas, as well as to preserve methyl bromide and keep related emissions to the lowest level possible, methyl bromide application for cucurbits is most often machine injected into soil to specific depths.

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

Tarpaulin ( high density polyethylene) is also used to minimize use and emissions of methyl bromide. 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. Page 49 PART E: ECONOMIC ASSESSMENT The following economic assessment is organized by MB critical use application. Individual crops within each application are examined first and are followed by aggregate measures for each application. Cost of MB and alternatives are given in table 21.1. Table 22.1 lists net and gross revenues. Expected losses when using MB alternatives are further decomposed in tables E1 through E13.

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

21. COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD TABLE 21.1: MICHIGAN CUCURBITS  COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Cucumber Methyl Bromide 100% $ 3,385 $ 3,385 $ 3,385 1,3 D + Chloropicrin 94% $ 3,422 $ 3,422 $ 3,422 Melon Methyl Bromide 100% $ 1,342 $ 1,342 $ 1,342 1,3 D + Chloropicrin 94% $ 1,354 $ 1,354 $ 1,354 Winter Squash Methyl Bromide 100% $ 3,385 $ 3,385 $ 3,385 1,3 D + Chloropicrin 94% $ 3,422 $ 3,422 $ 3,422 Zucchini Methyl Bromide 100% $ 1,342 $ 1,342 $ 1,342 1,3 D + Chloropicrin 94% $ 1,354 $ 1,354 $ 1,354 * As percentage of typical or 3 year average yield, compared to methyl bromide. Page 50 TABLE 21.2 : SOUTHEASTERN USA ( EXCEPT GEORGIA) CUCURBITS  COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Cucumber Methyl Bromide 100% $ 2,214 $ 2,214 $ 2,214 1,3 D + Chloropicrin 71% $ 2,585 $ 2,585 $ 2,585 Metam sodium 54% $ 2,585 $ 2,585 $ 2,585 Melons Methyl Bromide 100% $ 2,214 $ 2,214 $ 2,214 1,3 D + Chloropicrin 71% $ 2,585 $ 2,585 $ 2,585 Metam sodium 54% $ 2,585 $ 2,585 $ 2,585 Squash Methyl Bromide 100% $ 2,214 $ 2,214 $ 2,214 1,3 D + Chloropicrin 71% $ 2,585 $ 2,585 $ 2,585 Metam sodium 54% $ 2,585 $ 2,585 $ 2,585 * As percentage of typical or 3 year average yield, compared to methyl bromide.

TABLE 21.3 : GEORGIA CUCURBITS  COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( US$/ ha) COST IN YEAR 2 ( US$/ ha) COST IN YEAR 3 ( US$/ ha) Cucumber Methyl Bromide 100% $ 3,642 $ 3,642 $ 3,642 1,3 D + Chloropicrin 71% $ 3,242 $ 3,242 $ 3,242 Metam sodium 54% $ 3,027 $ 3,027 $ 3,027 Melon Methyl Bromide 100% $ 3,642 $ 3,642 $ 3,642 1,3 D + Chloropicrin 71% $ 3,242 $ 3,242 $ 3,242 Metam sodium 54% $ 3,027 $ 3,027 $ 3,027 Squash Methyl Bromide 100% $ 3,642 $ 3,642 $ 3,642 1,3 D + Chloropicrin 71% $ 3,242 $ 3,242 $ 3,242 Metam sodium 54% $ 3,027 $ 3,027 $ 3,027 * As percentage of typical or 3 year average yield, compared to methyl bromide. Page 51 22. GROSS AND NET REVENUE TABLE 22.1: MICHIGAN CUCURBITS   YEAR 1, 2, AND 3 GROSS AND NET REVENUES YEAR 1, 2, AND 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Cucumber Methyl Bromide $ 25,656 $ 7,926 1,3 D + Chloropicrin $ 24,116 $ 5,797 Melon Methyl Bromide $ 14,069 $ 6,150 1,3 D + Chloropicrin $ 13,224 $ 4,570 Winter Squash Methyl Bromide $ 13,282 $ 1,970 1,3 D + Chloropicrin $ 12,485 $ 227 Zucchini Methyl Bromide $ 13,484  $ 2,880 1,3 D + Chloropicrin $ 12,675  $ 3,423 All Michigan Cucurbits Methyl Bromide $ 19,149 $ 17,100 1,3 D + Chloropicrin $ 17,100 $ 1,825 NOTE: Year 1 equals year 2 and 3.

TABLE 22.2: SOUTHEASTERN USA ( EXCEPT GEORGIA) CUCURBITS   YEAR 1, 2, AND 3 GROSS AND NET REVENUES YEAR 1, 2, AND 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Cucumber Methyl Bromide $ 11,589 $ 1,468 1,3 D + Chloropicrin $ 8,228 $ 1,581 Metam sodium  $ 6,490  $ 2,848 Melon Methyl Bromide $ 12,775 $ 3,608 1,3 D + Chloropicrin $ 9,070  $ 5 Metam sodium $ 7,154  $ 1,640 Squash Methyl Bromide $ 7,628 $ 1,777 1,3 D + Chloropicrin $ 5,416  $ 755 Metam sodium $ 4,272  $ 1,754 All Southeastern USA Cucurbits Methyl Bromide $ 12,315 $ 4,131 1,3 D + Chloropicrin $ 8,744 $ 1,249 Metam sodium $ 6,896 $ 23 NOTE: Year 1 equals year 2 and 3. Page 52 TABLE 22.3: GEORGIA CUCURBITS   YEAR 1, 2, AND 3 GROSS AND NET REVENUES YEAR 1, 2, AND 3 ALTERNATIVES ( as shown in question 21) GROSS REVENUE FOR LAST REPORTED YEAR ( US$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( US$/ ha) Cucumber Methyl Bromide $ 34,491 $ 6,565 1,3 D + Chloropicrin $ 24,488  $ 103 Metam sodium $ 19,315  $ 2,992 Melon Methyl Bromide $ 27,915 $ 9,201 1,3 D + Chloropicrin $ 19,820 $ 3,560 Metam sodium $ 15,633 $ 668 Squash Methyl Bromide $ 32,603 $ 11,522 1,3 D + Chloropicrin $ 23,148 $ 5,440 Metam sodium $ 18,258 $ 2,251 All Georgia Cucurbits Methyl Bromide $ 34,621 $ 13,840 1,3 D + Chloropicrin $ 24,581 $ 6,610 Metam sodium $ 19,388 $ 2,969 NOTE: Year 1 equals year 2 and 3. Page 53 MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN CUCUMBER  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN CUCUMBER METHYL BROMIDE 1,3 D + CHLOROPICRIN YIELD LOSS (%) 0% 6%

YIELD PER HECTARE 2,018 1,897 * PRICE PER UNIT ( US$) $ 13 $ 12 = GROSS REVENUE PER HECTARE ( US$) $ 25,656 $ 22,911  OPERATING COSTS PER HECTARE ( US$) $ 17,730 $ 17,113 = NET REVENUE PER HECTARE ( US$) $ 7,926 $ 5,797 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 2,128 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 44 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 8%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 27%

MICHIGAN MELON  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN MELON METHYL BROMIDE 1,3 D + CHLOROPICRIN YIELD LOSS (%) 0% 6%

YIELD PER HECTARE 145 136 * PRICE PER UNIT ( US$) $ 97 $ 92 = GROSS REVENUE PER HECTARE ( US$) $ 14,069 $ 12,563  OPERATING COSTS PER HECTARE ( US$) $ 7,919 $ 7,994 = NET REVENUE PER HECTARE ( US$) $ 6,150 $ 4,570 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 1,580 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 33 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 11%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 26% Page 54 MICHIGAN WINTER SQUASH TABLE E. 3: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN WINTER SQUASH METHYL BROMIDE 1,3 D + CHLOROPICRIN YIELD LOSS (%) 0% 6%

YIELD PER HECTARE 1,063 999 * PRICE PER UNIT ( US$) $ 13 $ 12 = GROSS REVENUE PER HECTARE ( US$) $ 13,282 $ 11,861  OPERATING COSTS PER HECTARE ( US$) $ 11,312 $ 11,634 = NET REVENUE PER HECTARE ( US$) $ 1,970 $ 227 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 1,743 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 36 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 13%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 89%

MICHIGAN ZUCCHINI  TABLE E. 4: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES MICHIGAN ZUCCHINI METHYL BROMIDE 1,3 D + CHLOROPICRIN YIELD LOSS (%) 0% 6%

YIELD PER HECTARE 2,368 2,226 * PRICE PER UNIT ( US$) $ 6 $ 5 = GROSS REVENUE PER HECTARE ( US$) $ 13,484 $ 12,041  OPERATING COSTS PER HECTARE ( US$) $ 16,364 $ 15,464 = NET REVENUE PER HECTARE ( US$)  $ 2,880  $ 3,423 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 543 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 11 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 4%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 19% Page 55 ALL MICHIGAN CUCURBITS  TABLE E. 5: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES ALL MICHIGAN CUCURBITS METHYL BROMIDE 1,3 D + CHLOROPICRIN YIELD LOSS (%) 0% 6%

YIELD PER HECTARE 1,708 1,606 * PRICE PER UNIT ( US$) $ 11 $ 11 = GROSS REVENUE PER HECTARE ( US$) $ 19,149 $ 17,100  OPERATING COSTS PER HECTARE ( US$) $ 15,091 $ 15,275 = NET REVENUE PER HECTARE ( US$) $ 4,058 $ 1,825 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 2,232 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 46 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 12%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 55%

SOUTHEASTERN USA ( EXCEPT GEORGIA) CUCUMBER  TABLE E. 6: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEAST USA ( EXCEPT GEORGIA) CUCUMBER METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 828 588 464 * PRICE PER UNIT ( US$) $ 14 $ 14 $ 14 = GROSS REVENUE PER HECTARE ( US$) $ 11,589 $ 8,228 $ 6,490  OPERATING COSTS PER HECTARE ( US$) $ 10,121 $ 9,809 $ 9,338 = NET REVENUE PER HECTARE ( US$) $ 1,468  $ 1,581  $ 2,848 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 3,049 $ 4,316 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 20 $ 29 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 26% 37%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 208% 294% Page 56 SOUTHEASTERN USA ( EXCEPT GEORGIA) MELONS  TABLE E. 7: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEAST USA ( EXCEPT GEORGIA) MELON METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 815 579 457 * PRICE PER UNIT ( US$) $ 16 $ 16 $ 16 = GROSS REVENUE PER HECTARE ( US$) $ 12,775 $ 9,070 $ 7,154  OPERATING COSTS PER HECTARE ( US$) $ 9,168 $ 9,076 $ 8,795 = NET REVENUE PER HECTARE ( US$) $ 3,608  $ 5  $ 1,640 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 3,613 $ 5,248 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 24 $ 35 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 28% 41%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 100% 145%

SOUTHEASTERN USA ( EXCEPT GEORGIA) SQUASH  TABLE E. 8: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES SOUTHEAST USA ( EXCEPT GEORGIA) SQUASH METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 311 221 174 * PRICE PER UNIT ( US$) $ 25 $ 25 $ 25 = GROSS REVENUE PER HECTARE ( US$) $ 7,628 $ 5,416 $ 4,272  OPERATING COSTS PER HECTARE ( US$) $ 5,851 $ 6,171 $ 6,025 = NET REVENUE PER HECTARE ( US$) $ 1,777  $ 755  $ 1,754 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 2,532 $ 3,531 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 17 $ 24 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 33% 46%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 142% 199% Page 57 ALL SOUTHEASTERN USA ( EXCEPT GEORGIA) CUCURBITS  TABLE E. 9: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES ALL SOUTHEAST USA ( EXCEPT GEORGIA) CUCURBITS METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 749 532 420 * PRICE PER UNIT ( US$) $ 16 $ 16 $ 16 = GROSS REVENUE PER HECTARE ( US$) $ 12,315 $ 8,744 $ 6,896  OPERATING COSTS PER HECTARE ( US$) $ 8,184 $ 7,495 $ 6,874 = NET REVENUE PER HECTARE ( US$) $ 4,131 $ 1,249 $ 23 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 2,883 $ 4,108 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 19 $ 27 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 23% 33%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 70% 99%

GEORGIA CUCUMBER  TABLE E. 10: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES GEORGIA CUCUMBER METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 4,122 2,926 2,308 * PRICE PER UNIT ( US$) $ 8 $ 8 $ 8 = GROSS REVENUE PER HECTARE ( US$) $ 34,491 $ 24,488 $ 19,315  OPERATING COSTS PER HECTARE ( US$) $ 27,926 $ 24,592 $ 22,307 = NET REVENUE PER HECTARE ( US$) $ 6,565  $ 103  $ 2,992 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 6,668 $ 9,557 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 44 $ 64 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 19% 28%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 102% 146% Page 58 GEORGIA MELON  TABLE E. 11: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES GEORGIA MELON METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 2,975 2,112 1,666 * PRICE PER UNIT ( US$) $ 9 $ 9 $ 9 = GROSS REVENUE PER HECTARE ( US$) $ 27,915 $ 19,820 $ 15,633  OPERATING COSTS PER HECTARE ( US$) $ 18,714 $ 16,260 $ 14,965 = NET REVENUE PER HECTARE ( US$) $ 9,201 $ 3,560 $ 668 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 5,641 $ 8,533 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 38 $ 57 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 20% 31%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 61% 93%

GEORGIA SQUASH  TABLE E. 12: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES GEORGIA SQUASH METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 4,448 3,158 2,491 * PRICE PER UNIT ( US$) $ 7 $ 7 $ 7 = GROSS REVENUE PER HECTARE ( US$) $ 32,603 $ 23,148 $ 18,258  OPERATING COSTS PER HECTARE ( US$) $ 21,081 $ 17,708 $ 16,007 = NET REVENUE PER HECTARE ( US$) $ 11,522 $ 5,440 $ 2,251 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 6,082 $ 9,271 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 41 $ 62 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 19% 28%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 53% 80% Page 59 ALL GEORGIA CUCURBITS  TABLE E. 13: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES ALL GEORGIA CUCURBITS METHYL BROMIDE 1,3 D + CHLOROPICRIN METAM SODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 3,502 2,486 1,961 * PRICE PER UNIT ( US$) $ 10 $ 10 $ 10 = GROSS REVENUE PER HECTARE ( US$) $ 34,621 $ 24,581 $ 19,388  OPERATING COSTS PER HECTARE ( US$) $ 20,781 $ 17,971 $ 16,419 = NET REVENUE PER HECTARE ( US$) $ 13,840 $ 6,610 $ 2,968 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 7,230 $ 10,871 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 48 $ 72 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 21% 31%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 52% 79%

SUMMARY OF ECONOMIC FEASIBILITY There are currently few alternatives to methyl bromide for use in cucurbits. Furthermore, there are several factors that limit possible alternatives' usability and efficacy from place to place. These include pest complex, climate, and regulatory restrictions. The two most promising alternatives to methyl bromide in Georgia and the Southeastern USA for control of nut sedge in cucurbits ( 1,3 D + chloropicrin and metam sodium) are considered not technically feasible. This derives from regulatory restrictions and the magnitude of resulting expected yield losses. Economic data representing Georgia and Southeastern USA cucurbit growing conditions are thus included in the economic assessment as a supplement to the biological review to illustrate the impacts of using MB alternatives, not to gauge them with respect to economic feasibility. In Michigan 1,3 D + chloropicrin is considered technically feasible.

Michigan The U. S. concludes that, at present, no economically feasible alternatives to MB exist for use in Michigan cucurbit production. The U. S. has arrived at this conclusion by examining the individual crops within the Michigan cucurbit sector and then examining the sector as a whole. Two factors have proven most important in reaching that conclusion:. These are yield loss and missed market windows, which are discussed individually below.

1. Yield Loss Expected yield losses of 6% are anticipated throughout Michigan cucurbit production. Page 60 2. Missed Market Windows The U. S. agrees with Michigan's assertion that growers will likely receive significantly lower prices for their produce if they switch to 1,3 D + chloropicrin. This is due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals when using 1,3 D + chloropicrin.

The analysis of this effect is based on the fact that prices farmers receive for their cucurbits 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 cucurbits are harvested, the supply is at its lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenues, cucurbit growers manage their production systems with the goal of harvesting the largest possible quantity of cucurbits when the prices are at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profitability of cucurbit operations.

To describe economic conditions in Michigan, U. S. EPA used weekly and monthly cucurbit sales and production 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 was limiting, analysts assumed that if cucurbit growers adjust the timing of their production system, as required when using 1,3 D + Chloropicrin, gross revenues will decline by approximately 5% over the course of the growing season, due solely to price effects. The season average price was reduced by 5% in the analysis of the alternatives to reflect this effect. Based on currently available information, the U. S. believes this reduction in price serves as a reasonable indicator of the typical effect of planting delays resulting when MB alternatives are used in Michigan.

Southeastern USA Except Georgia No technically ( and thus economically) feasible alternatives to MB are presently available to the effected cucurbit growers. As such, the U. S. concludes that use of MB is critical in Southeastern USA cucurbit production.

Analytical Notes The applicant provided no data on the operating costs of alternatives. Analysts assumed, however, that these costs were similar to those of methyl bromide with slight upward adjustments for the costs of applying the alternatives and a slight downward adjustment for the cost of the alternative product. In addition, the applicant did not provide data for second crops ( including revenues and operating costs). Analysts assumed that Southeastern cucurbits are grown in a single crop production system. However, if double cropping is practiced in the actual production system, this assumption could make the critical need for MB appear smaller than it actually is, because the value the second crop derives from methyl bromide is not included in the analysis Page 61 Other potentially significant economic factors, such as price reductions due to missed market windows, were not analyzed for this region, as the case for critical use of MB is sufficiently strong based solely on yield loss.

Georgia No technically ( and thus economically) feasible alternatives to MB are presently available to the effected cucurbit growers. As such, the U. S. concludes that use of MB is critical in Georgia cucurbit production.

Analytical Notes Other potentially significant economic factors, such as price reductions due to missed market windows, were not analyzed for this region, as the case for critical use of MB is sufficiently strong based solely on yield loss.

Economic analysis of Georgia growing conditions included cost and production data representing a second cucurbits or peppers crop. Page 62 Page 63 PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP?

Registration Since 1997, the United States EPA has made the registration of alternatives to methyl bromide a high registration priority. Because the U. S. EPA currently has more applications pending in its registration review queue than the resources to evaluate them, U. S. 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 U. S. 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 U. S. 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.

Research 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 cucurbits research will require 941 kg per year of methyl bromide for 2005 and 2006. 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 rootknot nematodes. Another example is a five year field study comparing methyl bromide to 1,3 Page 64 D combined with biologically based materials including transplant treatments for control of weeds, root knot nematodes and soil borne fungal pathogens.

24. HOW DO YOU PLAN TO MINIMIZE THE USE OF METHYL BROMIDE FOR THE CRITICAL USE IN THE FUTURE?

The U. S. wants to note that our usage rate is among the lowest in the world in requested sectors and represents efforts of both the government and the user community over many years to reduce use rates and emissions. We will continue to work with the user community in each sector to identify further opportunities to reduce methyl bromide use and emissions.

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Ashley, M. G., B. L. Leigh, and L. S. Lloyd. 1963. The action of metham sodium in soil II. Factors affecting removal of methyl isothiocyanate residues. J. Sci. Food Agric. 14: 153 161.

Burgos, N. R. and R. E. Talbert. 1996. Weed control and sweet corn ( Zea mays var. rugosa) response in a no till system with cover crops. Weed Sci. 44 ( 2): 355   361.

Chase, C. A., T. R. Sinclair, D. G. Shilling, J. P. Gilreath, and S. J. Locascio. 1998. Light effects on rhizome morphogenesis in nutsedges ( Cyperus spp): Implications for control by soil solarization. Weed Sci. 46: 575 580.

Culpepper, S. and Langston 2001. Fumigant/ herbicide combinations in tomato. Unpublished study conducted by researchers at the University of Georgia, Atehns, GA. Included in CUE package 03 0042.

Csinos, A. S., D. R. Sumner, R. M. McPherson, C. Dowler, C. W. Johnson, and A. W. Johnson. 1999. Alternatives for methyl bromide fumigation of tobacco seed beds, pepper, and tomato seedlings. Proc. Georgia Veg. Conf. Available on the Web at http:// www. tifton. uga. edu/ veg/ Publications/ Gfvga99. pdf Dowler, C. C. 1999. Herbicide activity of metham, methyl iodide, and methyl bromide applied through irrigation systems. Proc. Southern Weed Sci. Soc. 52: 77   78.

Dungan, R. S. and S. R. Yates. 2003. Degradation of fumigant Pesticides. 1,3 Dichloropropene, methyl isothiocyanate, and methyl bromide. Vodose Zone Jour. 2: 279 286.

Eger, J. E. 2000. Efficacy of Telone products in Florida crops: a seven year summary. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro00. html.

Galloway, B. A. and L. A. Weston. 1996. Influence of cover crop and herbicide treatment on weed control and yield in no till sweet corn ( Zea mays L.) and pumpkin ( Cucurbita maxima Duch.). Weed Technol. 10 ( 2): 341   346.

Gamliel, A., S. Triki, M. Austerweil, P. DiPrimo, I. Peretz Alon, O. Heiman, M. Beniches, B. Steiner, and J. Katan. 2003. Aceelerated degradation of metam sodium in the field and its management. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro03. html. Page 66 Gevens, A., and M. K. Hausbeck. 2003. Phytophthora capsici in irrigation water and isolation of P. capsici from snap beans in Michigan. Michigan State Univ. Vegetable Crop Advisory Team Alert Vol. 18 ( 19). Available on the Web at www. ipm. msu. edu/ CAT03_ veg/ V09 24 03. htm.

Gilreath, J., J. P. Jones, and A. J. Overman. 1994. Soil borne pest control in mulched tomato with alternatives to methyl bromide. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro94. html.

Hausbeck, M. K. and B. D. Cortwright. 2003. Evaluation of fumigants for managing Phytophthora crown and fruit rot of solanaceous and cucurbit crops, plot two, 2003. Unpublished study supplied with CUE package 03 0005.

Horowitz, M. 1972. Effects of desiccation and submergence on the viability of rhizome fragments of bermudagrass, johnsongrass, and tubers of nutsedge. Israel J. Agric. Res. 22( 4): 215 220.

Kadir, J. B., R. Charudattan, W. M. Stall, and B. J. Brecke. 2000. Field efficacy of Dactylaria higginsii as a bioherbicide for the control of purple nutsedge ( Cyperus rotundus). Weed Technol. 14 ( 1): 1   6.

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

Larkin, R. P., and Fravel, D. R. 1998. Efficacy of various fungal and bacterial biocontrol organisms for control of Fusarium wilt of tomato. Plant Dis. 82: 1022  1028.

Locascio. S. J., and D. W. Dickson. 1998. Metam sodium combined with chloropicrin as an alternative to methyl bromide. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro98. html.

Locascio, S. J., J. P. Gilreath, D. W. Dickson, T. A. Kucharek, J. P. Jones, and J. W. Noling. 1997. Fumigant alternatives to methyl bromide for polyethylene mulched tomato. HortSci. 32: 1208 1211.