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

YEAR: CUN:

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

X Yes

No CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Tina E. Levine, Ph. D. Title: Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency 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 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 8 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___________________________________________________________________ 13 Florida  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE_________________ 15 Florida  11. Characteristics of Cropping System and Climate _______________________ 15 Florida  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested __________________________________ 16 FLORIDA  PART C: TECHNICAL VALIDATION_______________________________________ 17 Florida  13. Reason for Alternatives Not Being Feasible ___________________________ 17 Florida  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 18 Florida  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 18 Florida  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 19 Florida  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 21 Florida  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 21 Florida  Summary of Technical Feasibility______________________________________ 21 Georgia  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ________________ 23 Georgia  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 23 Georgia  11. Characteristics of Cropping System and Climate_______________________ 23 Region A  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 25 GEORGIA  PART C: TECHNICAL VALIDATION_______________________________________ 26 Georgia  13. Reason for Alternatives Not Being Feasible __________________________ 26 Georgia  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 27 Georgia  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 28 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 ___ 29 iv Georgia  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 30 Georgia  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 30 Michigan  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 32 Michigan  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 32 Michigan  11. Characteristics of Cropping System and Climate _____________________ 32 Michigan  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 33 MICHIGAN  PART C: TECHNICAL VALIDATION _____________________________________ 35 Michigan  13. Reason for Alternatives Not Being Feasible _________________________ 35 Michigan  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 36 Michigan  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 37 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 ___ 37 Michigan  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 39 Michigan  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 39 Michigan  Summary of Technical Feasibility ____________________________________ 39 PART D: EMISSION CONTROL ___________________________________________________ 41 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 41 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 42 PART E: ECONOMIC ASSESSMENT________________________________________________ 43 21. Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period____________ 43 22. Gross and Net Revenue___________________________________________________ 44 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 44 Summary of Economic Feasibility _____________________________________________ 46 PART F. FUTURE PLANS _______________________________________________________ 48 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 48 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 49 25. Additional Comments on the Nomination ____________________________________ 49 26. Citations ______________________________________________________________ 49 Citations Reviewed but Not Applicable _________________________________________ 51 APPENDIX B. SUMMARY OF NEW APPLICANTS ___________ Error! Bookmark not defined. v LIST OF TABLES PART A: SUMMARY _____________________________________________________________ 7 Table 4.1: Methyl Bromide Nominated ____________________________________________ 7 Table A. 1: Executive Summary _________________________________________________ 10 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 10 Florida  Table 8.1: Amount of Methyl Bromide Requested for Critical Use ______________ 12 Georgia  Table 8.2: Amount of Methyl Bromide Requested for Critical Use______________ 12 Michigan  Table 8.3: Amount of Methyl Bromide Requested for Critical Use ____________ 13 Table A. 2: 2005 Sector Request _________________________________________________ 14 Table A. 3: 2006 Sector Nomination ______________________________________________ 14 FLORIDA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 15 Florida  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ____ 15 Florida  Table 11.1: Characteristics of Cropping System _____________________________ 15 Region B  Table 11.2 Characteristics of Climate and Crop Schedule____________________ 16 Florida  Table 12.1 Historic Pattern of Use of Methyl Bromide________________________ 16 FLORIDA  PART C: TECHNICAL VALIDATION _________________________________________ 17 Florida   Table 13.1: Reason for Alternatives Not Being Feasible ______________________ 17 Florida   Table 14.1: Technically Infeasible Alternatives Discussion____________________ 18 Florida   Table 15.1: Present Registration Status of Alternatives _______________________ 18 Southeastern USA except Georgia   Table C. 1: Alternatives Yield Loss Data Summary_____ 19 Table 5. Fumigant Alternatives to Methyl Bromide for Polyethylene Mulched Tomato ( Locascio et al., 1997______________________________________________________________ 19 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 23 Georgia  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ___ 23 Georgia  Table 11.1: Characteristics of Cropping System ____________________________ 23 Region A  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 24 Region A  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 25 GEORGIA  PART C: TECHNICAL VALIDATION_________________________________________ 26 Region A   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 26 Georgia   Table 14.1: Technically Infeasible Alternatives Discussion ___________________ 27 Georgia   Table 15.1: Present Registration Status of Alternatives_______________________ 28 Southeastern USA except Georgia   Table C. 1: Alternatives Yield Loss Data Summary_____ 29 Table 5. Fumigant Alternatives to Methyl Bromide for Polyethylene Mulched Tomato ( Locascio et al., 1997______________________________________________________________ 29 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 32 Michigan  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 32 Michigan  Table 11.1: Characteristics of Cropping System ___________________________ 32 Region A  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 33 Michigan  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 34 MICHIGAN  PART C: TECHNICAL VALIDATION________________________________________ 35 Michigan   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 35 Michigan   Table 15.1: Present Registration Status of Alternatives _____________________ 37 Michigan   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 37 PART D: EMISSION CONTROL ____________________________________________________ 41 vi Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 41 PART E: ECONOMIC ASSESSMENT _________________________________________________ 43 Table 21.1: Michigan  Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _______________________________________________________________________ 43 Table 22.1: Michigan  Year 1, 2, and 3 Gross and Net Revenues_______________________ 44 Georgia Melon  Table E. 9: Economic Impacts of Methyl Bromide Alternatives___________ 44 Georgia Cucumber   Table E. 8: Economic Impacts of Methyl Bromide Alternatives _______ 45 Southeastern U. S. A. except Georgia Cucumber  Table E. 5: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________ 45 PART F. FUTURE PLANS ________________________________________________________ 48 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI)._________________ 52 7 PART A: SUMMARY 1. NOMINATING PARTY: The United States of America 2. DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Eggplant Grown in Open Fields 3. CROP AND SUMMARY OF CROP SYSTEM:

This is a request for eggplant grown in the States of Florida, Georgia, and Michigan. In Florida, eggplant can be grown year round, and are often double cropped with pepper or cucumber following eggplant harvest. The vegetable crop that follows eggplant in a double cropping production system depends upon prevailing environmental and economic factors. Growers in Florida often put eggplant in as an extra crop, and grow okra, squash, or cucumbers after the eggplant has been harvested. A spring crop of eggplant may follow as a second crop after a fall crop of pepper or tomato. Eggplant does best on well drained, fertile, sandy loam soils at a pH of 6.0 6.5. Poorly drained soils may result in slow plant growth, reduced root systems, and low yields. Eggplant requires a long, warm, frost free growing season, usually of 14 16 weeks. Cold temperatures below 50oC injure this crop. The best temperatures are 27 32oC during the day and 21 32oC during the night. Plant growth is curtailed at temperatures below 16oC. Additionally, soil temperature below 16oC restricts germination. However, most eggplant is started in the field from transplants. Methyl bromide ( MB) is always used in the full bed mulch process. Until 1999, the chemical formulation primarily used was 98 percent methyl bromide and two percent chloropicrin. Since then, growers have shifted to formulations with lower concentrations of methyl bromide and higher amounts of chloropicrin due to the phase out schedule of methyl bromide ( USDA, 2002).

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA) 2005 2006 106,193 758 8 5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE:

The US nomination is only for those areas where the alternatives are not suitable. In US eggplant 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 eggplant production.  geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the US is only nominating a CUE for eggplants where the key pest pressure is moderate to high such as nutsedge in the Southeastern US.  regulatory constraints: e. g., telone use is limited in 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.

Methyl bromide is the only fumigant that consistently provides reliable control of target weeds, nematodes, and pathogens. There are no technically or economically feasible alternatives. The best alternatives ( e. g. 1,3 D + chloropicrin, metam sodium) are not as effective in controlling nutsedge and have a long waiting period for planting that would disrupt planting schedules and cause growers to miss key market windows. Furthermore, regulatory restrictions due to concerns over human exposure and ground water contamination, along with technical limitations, result in potential economic infeasibility of 1,3 D alone or in combination as a practical MB alternative. Key among these factors are a 28 day planting delay due both to label restrictions and low soil temperatures and a mandatory 30.4 m buffer for treated fields near inhabited structures.

5.1 Michigan In Michigan eggplant, no currently available methyl bromide ( MB) alternative exists that is technically feasible for the control of the key target pathogen, Phytophthora capsici except 1,3 D + chloropicrin. These soil fungi can easily destroy the entire harvest from affected areas if left uncontrolled. While 1,3 D + chloropicrin provided some control in small plot trials with peppers and cucurbits in Michigan ( Hausbeck and Cortright 2003), the level of control was lower than that afforded by MB. It is also noteworthy that at least one of the pests in question, P. capsici, has recently been shown to occur in irrigation water in Michigan ( Gevens and Hausbeck 2003). This will increase the likelihood of spread of this pathogen. It is also not yet clear whether these small scale results accurately reflect efficacy of MB alternatives in commercial fresh vegetable ( peppers, eggplant, cucurbit) production. Furthermore, regulatory restrictions ( e. g., mandatory 30 m buffer zone for treated fields near inhabited structures) due to concerns over human exposure and ground water contamination, along with technical and economic limitations, result in potential infeasibility of this formulation as a practical MB alternative. Also, planting delays restrictions ( 21 to 30 days) or variations in soil temperatures or rainfall could cause delays in fumigation events, since all fumigations must be completed by the first week of May.

Based on a small plot trial conducted on Michigan peppers cited above, the best case yield loss estimate for Michigan using the best available MB alternative ( 1,3 D + chloropicrin) is estimated to be 6%. In untreated buffer areas, losses could approach 100 % in the worst case scenario. There may also be unpredictable but potentially significant economic effects created by the planting delays ( described above), which will disrupt the schedule of delivery of fresh pepper harvest to wholesale buyers. 9 Florida and Georgia Nutsedges, when present at moderate to severe infestations, are key pests which require MB for control in the Southeastern United States, including Florida and Georgia. Phytophthora is also a key pest. Of MB alternatives, only 1,3 D + chloropicrin has some efficacy against Phytophthora. However, 1,3 D cannot be applied in areas overlying karst geology which is common throughout the Southeast.

Growers in this region also face root knot nematodes and the fungal pathogens described above as key pests. Left uncontrolled, any of these pests could completely destroy the harvests from affected areas. Halosulfuron, which is effective against nutsedges, can be applied only in row middles, but cannot be applied in raised beds, where nutsedge competition is critical ( Florida CUE # 03 0054).

Metam sodium offers erratic, inconsistent control of nutsedges and nematodes, while 1,3 D + chloropicrin provides adequate control of nematodes ( Eger 2000, Noling et al. 2000). However, metamsodium has yield losses of up to 44 percent compared to MB where weed infestations are moderate to severe ( Locascio et al. 1997). Metam sodium also creates a planting delay as long as 28 days to avoid risk of phytotoxic injury o crops compared to a 14 day delay for MB. Further, due to regulatory restrictions resulting from groundwater contamination concerns, 1,3 D + chloropicrin cannot be used in large portions of the southeastern United States due to the presence of karst geology. There is a 21 day planting delay ( vs. 14 days for MB) due to regulatory restrictions for 1,3 D + chloropicrin also. Any apparent technical feasibility of metam sodium and 1,3 D + chloropicrin ( and various combinations thereof) are based on small plot research trials that done on crops other than eggplant. For fungi and nutsedge pests at least, no on farm, large scale trials have yet been done. 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 microorganisms. This phenomenon may compromise long term efficacy of these compounds and appears to need further scientific scrutiny.

In sum, neither of these MB alternatives is presently adequate for control of key pests, and MB remains a critical use for eggplant in the Southeastern United States.

Implications of MB loss for individual growers If MB were to be removed as a pest control option for U. S. eggplant, the particular growers in each region cited in this nomination would have to stop crop production or suffer substantial losses. These growers would either leave agriculture entirely or switch to other crops that do not rely on pre plant fumigation for soil pest control. The extent of this impact on the affected growers is debatable, but given the current embryonic state of commercial deployment of MB alternatives, it is possible that growers who currently treat their land routinely with MB would face this outcome. 10 TABLE A. 1: EXECUTIVE SUMMARY FOR EGGPLANT* Region Florida Georgia Michigan AMOUNT OF NOMINATION 2006 Kilograms 73,716 27,769 3,951 Application Rate ( kg/ ha) 150 150 48 Area ( ha) 491 185 82 AMOUNT OF APPLICANT REQUEST 2005 Kilograms 97,250 48,868 4,027 Application Rate ( kg/ ha) 150 150 120 Area ( ha) 647 325 36 2006 Kilograms 97,250 48,868 3,951 Application Rate ( kg/ ha) 150 150 48 Area ( ha) 647 325 82 ECONOMICS FOR NEXT BEST ALTERNATIVE Marginal Strategy 1,3 D + Pic 1,3 D + Pic 1,3 D + Pic Yield Loss (%) 29 % 29 % 6% Loss per hectare ( US$/ ha) $ 5,252 $ 7,593 $ 4,076 Loss per kg Methyl Bromide ( US$/ kg) $ 35 $ 51 $ 84 Loss as % of Gross Revenue (%) 24% 18% 12% Loss as % of Net Revenue (%) 82% 72% 44%

6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

In Florida and Georgia, where weeds, especially nutsedge, are the main methyl bromide target pests neither 1,3 D nor metam sodium, alone or in combination with chloropicrin, adequately control moderate to high nutsedge populations. In Florida and, to a lesser extent in Georgia, the use of 1,3 D is prohibited in areas overlying karst geology because of groundwater contamination concerns. It is estimated that 40% of the Florida's production area overlies karst geology. The 1,3 D label prohibits its use in Dade County, Florida. Moreover, for Florida and Georgia farmers, using products containing 1,3 D and metam sodium in the fall may be impractical because of the required longer waiting periods for planting following application, 28 days for 1,3 D and 21 days for metam sodium, compared to 14 days for methyl bromide. Such delays could cause Florida and Georgia growers to miss part of the key market windows.

In Michigan, where soil borne pathogens are the key methyl bromide target pests, neither 1,3 D nor metam sodium is effective against soil borne fungi. Furthermore, the 28 and 21 day planting delays for 1,3 D and metam sodium, respectively, might disrupt this state's carefully timed planting and harvesting schedules, causing growers to miss part of the market windows. The 1,3 D + chloropicrin combination may be as effective as methyl bromide against soil borne pathogens. However, the 21 day planting delay would hinder grower adoption of this alternative.

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 2001 2002 AVERAGE ( HA) PROPORTION OF TOTAL CROP AREA TREATED WITH METHYL BROMIDE (%) Florida 647 100 Georgia 497 64%

Michigan Not available Not available NATIONAL TOTAL: 2197 51 * See Appendix A for a complete description of how the nominated amount was calculated. 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 Georgia, areas not treated with MB do not have nutsedges or nematodes naturally present in eggplant fields. Simple absence of all pests is the only reason these areas are not presently treated with MB. In Michigan, areas not treated apparently do not have any infestation ( i. e., zero oospores or chlamydospores per unit soil) of the key fungal pests. The applicant states that soil infestation is spreading in the region annually.

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?

Growers have the option to use halosulfuron only in row middles. 12 8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE FLORIDA  TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: FLORIDA YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 97,250 97,250 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Strip Bed FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 or 98: 2 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 647 ha 647ha APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 150 150 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 224 224 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 15 15 * For Flat Fumigation treatment application rate and dosage rate may be the same.

GEORGIA  TABLE 8.2: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: GEORGIA YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 48,868 48,868 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Predominantly 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) 325 325 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION 224 224 APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 150 150 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 22 22 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 15 15 * For Flat Fumigation treatment application rate and dosage rate may be the same. 13 MICHIGAN  TABLE 8.3: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: MICHIGAN YEAR OF EXEMPTION REQUEST 2005 2006 KILOGRAMS OF METHYL BROMIDE 4,027 3,951 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Predominantly Strip Bed FORMULATION ( ratio of methyl bromide/ Chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 or 50: 50 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( m2 or ha) 83 82 APPLICATION RATE* ( kg/ ha) FOR THE FORMULATION APPLICATION RATE* ( kg/ ha) FOR THE ACTIVE INGREDIENT 48 48 DOSAGE RATE* ( g/ m2) OF FORMULATION USED TO CALCULATE REQUESTED KG OF METHYL BROMIDE 17.9 17.9 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 32.2 Strip treatment 32.2 Strip treatment * For Flat Fumigation treatment application rate and dosage rate may be the same.

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

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

  The percent of regional hectares in the applicant's request was divided by the total area planted in that crop in the region covered by the request. Values greater than 100 percent are due to the inclusion of additional varieties in the applicant's request that were not included in the USDA National Agricultural Statistics Service surveys of the crop.   Hectares counted in more than one application or rotated within one year of an application to a crop that also uses methyl bromide were subtracted. There was no double counting in this sector.   Growth or increasing production ( the amount of area requested by the applicant that is greater than that historically treated) was subtracted. The applicant that included growth in their request had the growth amount removed.   Quarantine and pre shipment ( QPS) hectares is the area in the applicant's request subject to QPS treatments. Not applicable in this sector.   Only the acreage experiencing one or more of the following impacts were included in the nominated amount: moderate to heavy key pest pressure, regulatory impacts, karst topography, buffer zones, unsuitable terrain, and cold soil temperatures. 14 TABLE A. 2: 2005 SECTOR REQUEST  EGGPLANT*

2005 Eggplant Sector Request Florida Georgia Michigan Requested Hectares ( ha) 647 325 83 Requested Application Rate ( kg/ ha) 150 150 48 Applicant Request for 2005 Requested Kilograms ( kg) 97,250 48,868 4,027 TABLE A. 3: 2006 SECTOR NOMINATION  EGGPLANT 2006 Eggplant Sector Nomination Florida Georgia Michigan Requested Hectares ( ha) 647 325 82 Requested Application Rate ( kg/ ha) 150 150 48 Applicant Request for 2006 Requested Kilograms ( kg) 97,250 48,868 3,951 Nominated Hectares ( ha) 491 185 82 Nominated Application Rate ( kg/ ha) 150 150 48 CUE Nominated for 2006 Nominated Kilograms ( kg) 73,716 27,769 3,951 Overall Reduction (%) 29 2006 U. S. CUE Nomination ( kg) 106,193 Research Amount ( kg) 433 2006 Sector Nomination Totals Total 2006 U. S. Sector Nominated Kilograms ( kg) 106,626 * See Appendix A for a complete description of how the nominated amount was calculated. 15 FLORIDA PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE FLORIDA  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST FLORIDA  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED TARGET PESTS ( WEEDS, PLANTPARASITIC NEMATODES) AND PATHOGENS SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Florida Purple and Yellow Nutsedge ( Cyperus rotundus & C. esculentus), Root knot nematodes ( Meloidogyne spp.), Nightshade ( Solanum spp.), Morningglory ( Ipomoea spp.), Southern blight ( Sclerotium rolfsii) Methyl bromide is the only fumigant that consistently controls key target weeds affecting eggplant in Florida. Neither 1,3 D nor metam sodium is effective under high nutsedge population pressures. 1,3 D cannot be applied in areas overlying karst geology ( about 40% of the production area in Florida).

FLORIDA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE FLORIDA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS FLORIDA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Vegetable crop for fresh market 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) Peppers, cucurbits SOIL TYPES: ( Sand, loam, clay, etc.) Sandy and sandy loam soils FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) Annually OTHER RELEVANT FACTORS: Double cropped with cucurbit; may be preceded by pepper.

TABLE 11.2: CHARACTERISTICS OF CLIMATE AND EGGPLANT CROP SCHEDULE: NOT DOUBLE CROPPED MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) Zones: 9a, 10a, 10b  In 1997, 80% of the state's eggplant production was in the southeast; remainder of about 20% distributed in the rest of the state, mostly in the central and northern regions. RAINFALL ( mm) 65.5 50.0 72.5 134.1 175.8 193.3 152.7 65.0 42.7 158.8 62.0 66.8 OUTSIDE TEMP.( ° C) 19.4 22.1 25.3 27.6 28.2 28.2 27.3 24.1 19.2 17.3 16.0 16.9 FUMIGATION SCHEDULE; A X X X X X X X X PLANTING SCHEDULE B E E E E E E E E KEY HARVEST WINDOW; C E E E E E E E E E ANon double cropped.: earliest start date: June 15; shaded cells represent variation in fumigation initiation amongst eggplant growers. C For Non Double cropped eggplant production, planting eggplants is usually initiated around July 1; shaded cells represent variation in transplanting dates EFor Non Double Cropped Eggplants; Harvest Period usually begins as early as Nov. 1, may continue until July 31, depending on when planted and weather conditions. 16 TABLE 11.3: CHARACTERISTICS OF CLIMATE AND EGGPLANT CROP SCHEDULE; DOUBLE CROPPED MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE ( e. g. temperate, tropical) Zones 9a, 10a, 10b  In 1997, 80% of the state's eggplant production was in the southeast; remainder of about 20% distributed in the rest of the state, mostly in the central and northern regions. RAINFALL ( mm) 65.5 50.0 72.5 134.1 175.8 193.3 152.7 65.0 42.7 158.8 62.0 66.8 OUTSIDE TEMP.( ° C) 19.4 22.1 25.3 27.6 28.2 28.2 27.3 24.1 19.2 17.3 16.0 16.9 FUMIGATION SCHEDULE A X X X X PLANTING SCHEDULE B E E E E 2C KEY HARVEST WINDOW F E E 2C 2C 2C E E E E A Double cropped; assumed to be with cucurbits; earliest start date is June 15; shaded cells represent variation in fumigation initiation among eggplant growers who double crop. B For Double Cropped eggplant production, planting ( E) is typically initiated on July 1; variance can be until October 1, as represented by the shaded cells. The second crop of cucurbits transplants would typically be initiated around Feb 1, and may vary until end of Feb, or 1st part of March. C For Double Cropped Eggplants, Harvest Period usually begins as early as Nov. 15 ( E), may continue until April 15, depending on when planted and weather conditions; Harvesting of second crop ( 2C) may start around May 1 and continue until mid July FLORIDA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

The karst geology prevalent in Florida and, to a lesser extent, Georgia severely limits the use of I, 3 D in those States. There are no atypical characteristics identified in the nomination which might prevent the utility of Devrinol   ( napromide) and trifluralin for nutsedge control and for control of broad leaved weed species, such as morningglory. Halosulfuron, however has several label limitations ( e. g., reduced effectiveness if rain events follow within 4 hours of application), and plant back restrictions ( 0 to 36 months) ( U. S. EPA, CUN 2003/ 050).

FLORIDA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED FLORIDA  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) 971 890 809 728 728 728 AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 63,335 149,723 127,384 114,646 114,623 114,623 FORMULATIONS OF METHYL BROMIDE MB / chloropicrin) 98: 2 98: 2 67: 33 or 98: 2 67: 33 or 98: 2 67: 33 or 98: 2 67: 33 or 98: 2 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Sweptback chisel shank, 25 30.5 cm deep APPLICATION RATE OF FORMULATIONS IN kg/ ha* 159 182 159 182 159 182 159 182 159 182 159 182 DOSAGE RATE*( G/ M 2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 251 251 235 235 235 235 APPLICATION RATE FOR THE ACTIVE INGREDIENT IN kg/ ha* 168 168 157 157 157 157 ACTUAL DOSAGE RATE FOR THE ACTIVE INGREDIENT ( g/ m2)* 16.8 16.8 15.7 15.7 15.7 15.7 APPLICATION RATE OF STRIP/ BED ( g/ m2) * For Flat Fumigation treatment application rate and dosage rate may be the same. 17 FLORIDA  PART C: TECHNICAL VALIDATION FLORIDA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE FLORIDA   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 ( Telone   ) Limestone solution channels potentially leading to groundwater (" karst geology) underlies a portion of FL production area; estimated to be about 40% in 2002 for eggplant area; Telone is not labeled for use in Dade County. No Halosulfuron Registered for use on eggplant ( Dec. 2002, US EPA, Aug. 2003); use restricted to the middle row only; potential crop injury; severe plant back restrictions from 3 to 36 months for most vegetables; severe restrictions when used in pest management strategy that includes soil applied organophosphates. No Metam sodium ( Vapam   ) Does not work under high pest pressure. Limited niche as a complementary treatment with other fumigants and herbicides, never stand alone ( Noling, 2003). Considered as best available alternative for Dade County only ( Aerts, 2003) No Napromide ( Devrinol   ) Weak in terms of nutsedge efficacy; does not control established weeds ( CUE 03 0017); waste of money ( Noling, 2003) No Trifluralin Aids in control of annual grasses; does not manage broadleaf weeds. May cause excessive crop stress leading to reductions in stands and yields. No NON CHEMICAL ALTERNATIVES Solarization Weed density ( yellow and purple nutsedge was greater in the solarized treatments compared to the methyl bromide treatment. Worked for the 1st year in FL peppers; if pest threshold is low ( Chellemi, et al., 1997) No Myrothecium verrucaria( Ditera   ) Biological nematicide; registered on broad range of crops, field efficacy is untested No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin ( Telone II or Telone C 35) + Devrinol + trifluralin Strategy involves applying 1,3 D Flat Fumigation, followed by chloropicrin 3 4 wks post fumigation + both herbicides before laying plastic. Chloropicrin may not be efficacious in managing white mold ( Sclerotium rolfsii). Producers in Dade County are prohibited from using Telone products. Yes, except for areas with underlying karst geology.

Solarization + 1,3 D May work in areas with low weed, pest or disease pressure. Eliminated root galling and high density of root knot nematodes. ( Chellemi, D. O., et al. 1997. Application of soil solarization to Fall Production of cucurbits and pepper. Proc. Fla. State Hort. 110: 333 336.) No Solarization + biocontrol fungus, Gliocladium virens Ristaino, J. B., Perry, K. B. and R. D. Lumsden. 1996. Soil solarization and Gliocladium virens reduce the incidence of southern blight ( Sclerotium rolfsii) in bell pepper in the field. Biocon. Sci. and Tech. 6: 583 593. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. 18 FLORIDA  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

FLORIDA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION None Other than options discussed elsewhere, no alternatives exist for the control of the key pests when they are present in the soil and/ or afflict the below ground portions of eggplants.

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

FLORIDA   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: Iodomethane Pre plant soil fumigant. Not registered yet. Yes Unknown Trifloxysulfuron sodium Herbicide. Registration pending ONLY in tomato, FL only. Crop Injury issues exist. Yes Unknown Fosthiazate OP nematicide. Not registered. Yes Unknown Furfural ( Multigard

) Not registered. Yes Unknown Sodium azide Not registered. Registration application not yet submitted. No Unknown Propargyl bromide Not registered. Registration application not yet submitted. No Unknown Paecilomyces lilacinus Biological nematicide. Registration pending. Yes Unknown 19 FLORIDA  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:

FLORIDA   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, fungal pathogens 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, fungal pathogens 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 Data ( narrative only) and information are bridged for eggplants from the best available information ( Locascio et al. 1997).

Locascio et al. ( 1997) studied MB alternatives on tomatoes grown in small plots at two Florida locations. 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%) chiselinjected 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 pairwise statistical comparisons, the yield was significantly lower in metam sodium 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, one must keep in mind that this MB alternative cannot be used in areas where karst geology exists.

TABLE 16.1. FUMIGANT ALTERNATIVES TO METHYL BROMIDE FOR POLYETHYLENE MULCHED TOMATO ( LOCASCIO ET AL. 1997)

Chemicals Rate (/ ha) Average Nutsedge Density (#/ m2) Average Marketable Yield ( ton/ ha) % Yield Loss ( compared to MB)

Untreated ( control)  300 ab 20.1 a 59.1 MB + Pic ( 67 33), chisel injected 390 kg 90 c 49.1 b  1,3 D + Pic ( 83 17), chisel injected 327 l 340 a 34.6 c 29.5 Metam Na, Flat Fumigation 300 l 320 a 22.6 a 54.0 Metam Na, drip irrigated 300 l 220 b 32.3 c 34.2 20 Notes: ( 1) Numbers followed by the same letter ( within a column) are not significantly different at the 0.05 level of probability, using Duncan's multiple range test. ( 2) Data shown are from the Gainesville/ Horticultural Unit site, 1994 season ( this was one of three sites included in this study). This site had relatively high nutsedge pressure, and data for both pest pressure and marketable yields for all treatments shown.

Yield loss estimates could likely be lower for growers who can legally use 1,3 D products. For example, evidence from one tomato and bell pepper grower using Telone II on 30 percent of his total area suggests that average yields declined 6.16 % across all fields, while average yield declines were 15.77 % in sideby side plantings ( FFVA, 2002). The standard deviation on these yields did not change, which resulted in an increase in the coefficient of variation from 32.7 percent on fields planted to methyl bromide to 38.3 percent on fields planted to Telone II. These results suggest that alternatives to methyl bromide reduce yields by as much as 15.7 % and that risk associated with yield variability would likewise increase. Page 21 FLORIDA  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?:

Iodomethane is under consideration for potential methyl bromide replacement. Although it is currently being considered for registration by regulatory authorities, it is unknown when it will be registered. Please refer to Table 15.1 for detailed information.

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

The U. S. Government is presently unaware of large scale, commercial greenhouse operations for eggplants. It might be expected, however that there are local ( or small community) operations of organic eggplant production that target fresh market and/ or temporal ( seasonal) sectors.

FLORIDA  SUMMARY OF TECHNICAL FEASIBILITY In Florida neither 1,3 D nor metam sodium, alone or in combination with chloropicrin, adequately control moderate to high nutsedge populations. In addition, 1,3 D cannot be applied in areas overlying karst geology, estimated to be 40% of the production area in the State. Furthermore, using products containing 1,3 D and metam sodium in the fall would mean longer waiting periods for planting following application, 28 days for 1,3 D and 21 days for metam sodium, compared to 14 days for methyl bromide. Such delays may cause Florida growers to miss part of the key market windows.

The top priority of control associated with each major segment of pest management across Florida eggplant production regions remained weeds, especially the nutsedges, because of the lack of registered herbicides that do not cause crop injury, or have severe plant back restrictions. When nutsedge pressure is moderate to severe, the 1,3 D + chloropicrin combination is not technically feasible because it needs to be coupled with an effective herbicide to provide control for the entire growing season ( U. S. EPA, 2002). There are no herbicides which control nutsedge in the crop row. Paraquat and glyphosate will suppress emerged nutsedge, but cannot be used in the crop row because of potential crop injury ( SE Pepper Consortium CUE 02 0041).

In the study reported in Item 16 ( Table 16.1 ), 1,3 D + chloropicrin treatments did not adequately control moderate to high nutsedge populations, and yield losses occurred when compared to MB plus chloropicrin treatments. Additional research on this alternative to improve efficacy against nutsedge is needed in areas with moderate to high nutsedge pressure. Lack of an effective, registered herbicide impairs adoption in crops such as eggplant ( Banks, 2002).

Diseases caused by soil borne plant pathogenic fungi, ( e. g., Phytophthora spp., Verticillium spp., Pythium spp. and Rhizoctonia solani) may be curtailed if weather conditions are detrimental for disease development. These pathogens commonly reside in many production areas, since many eggplant production areas are old tomato production fields. Fungicides such as chlorothalonil, and azoxystrobilurin are considered to be only prophylactic, and may not offer sufficient pest management. Resistance of Phytophthora spp. to metalaxyl and mefanoxem ( Ridomil and Ridomil Gold, respectively) has been reported in tomato crop areas, and most recently pepper ( Lamour and Hausbeck, 2003).

Nematode pests, such as the root knot nematode species of Meloidogyne, were third to weed pests in terms of priority of pest management strategies in Florida eggplant production. Pre plant control of Page 22 nematodes is critical since nematode root feeding and damage may predispose plant tissues to invasion by fungal pathogens, potentially leading to wilt, loss of plant vigor, and significant yield losses. Fumigant alternatives such as metam sodium have proven inconsistent ( Noling, 2003; FFVA, 2002).

Approximately 40 percent of the eggplant production area in Florida has karst geology. Because it is illegal for producers to use 1,3 D products ( Telone II, Telone C 35) on these soils, growers would likely use a combination of metam sodium + a herbicide, such as halosulfuron or napropamide. Page 23 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 TARGET PESTS ( WEEDS, PLANT PARASITIC NEMATODES) AND PATHOGENS SPECIFIC REASONS WHY METHYL BROMIDE NEEDED Georgia 1. Yellow and Purple Nutsedge ( Cyperus esculentus, C. rotundus) [ 100%] 2. Crown and Root rot ( Phytophthora capsici) [ 40%] 3. Plant parasitic nematodes ( Meloidogyne incognita; Pratylenchus sp) [ 70%] 4. Southern Blight ( Sclerotium rolfsii) [ 70%] 5. Pythium root and collar rots ( P. irregulare, P. myriotylum, P. ultimum, P. aphanidermatum) [ 100%] Registered alternatives are not as effective as methyl bromide. Methyl bromide is needed for timely management of targeted pests and pathogens. Using products containing 1,3 D and metam sodium in the fall is impractical because of the long waiting periods for planting following application under plastic mulch. For 1,3 D there is a 28 day waiting period; for metam sodium, there is a 21 day waiting period. Such delays could cause growers to miss part of the higher market windows.

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) Vegetable crop for the fresh market ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual; generally 1 year TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Eggplants, followed by a cucurbit crop ( cucumbers, or squash) or pepper.

SOIL TYPES: ( Sand, loam, clay, etc.) Sandy loam; clay loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) 1 time per year; ( either in spring or fall)

OTHER RELEVANT FACTORS: The grower may complete two, three or even four crops in one fumigation cycle. Page 24 GEORGIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE " PLANT HARDINESS ZONE" ( e. g. temperate, tropical) Climate zones 7a, 7b, 8a, and 8b noted in the application. Zone 7a:  15.0 to   17.7 ° C ( 0 to 5 ° F): Oklahoma City, OK; South Boston, VA Zone 7b:  12.3 to 14.9 ° C ( 5 to 10 ° F); Griffin, GA Zone 8a:  9.5 to  12.2 ° C ( 10 to 15 ° F); Tifton, GA Zone 8b:  6.7 to   9.4 ° C ( 15 to 20 ° F); Austin, TX; Gainesville, FL Portions of GA fall into all four of these zones.

SOIL TEMP. ( ° C) 64.1 72.5 80.8 85.9 87.8 86.8 82.2 73.9 34.0 54.0 51.1 55.5 RAINFALL ( mm) 5.0 3.8 3.5 4.5 5.6 4.8 3.4 2.3 2.3 4.5 4.5 4.2 AMBIENT TEMP. ( ° C) ) 69.8 77.7 84.7 89.4 90.7 90.5 87.3 79.3 69.8 63.1 61.5 64.0 FUMIGATION SCHEDULE A

 PLANTING SCHEDULE A, B

 KEY HARVEST ( MARKET) WINDOW A, B

 Shaded areas represent typical duration of activity . Darker shaded areas represent duration of activities for the second crop. AFumigation, a fall application only. Methyl bromide applied either in the spring or fall allows the grower to economically produce at least two crops ( sometimes 3 or 4), the second crop usually cucumbers, from one fumigation event. BTwo crops are represented from one fumigation event.

= initiation of planting and/ or harvest of first crop;  = termination of planting and/ or harvest of first crop.  = initiation of planting and/ or harvest of second crop;  = termination of planting and/ or harvest of second crop.

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

Nearly all of the vegetable production occurs on Coastal Plain Soils are subject to high temperatures and excess heat. In addition to weed pests, soil borne fungal pathogens and plant parasitic nematodes are endemic to the region and nearly all production areas have severe infestations, thereby necessitating annual treatment with a soil fumigant. Page 25 GEORGIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE ON EGGPLANTS, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED GEORGIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE ON EGGPLANTS FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1997 1998 1999 2000 2001 2002 AREA TREATED ( hectares) 284 168 251 333 315 321 AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 70312 41,407 47,723 50,023 47,288 48,139 FORMULATIONS OF METHYL BROMIDE ( e. g. methyl bromide 98: 2; methyl bromide / chloropicrin 70: 30) 98: 2 98: 2 98: 2 ( 15% of area ) 67: 33 ( 85% of area) 67: 33 67: 33 67: 33 METHODS BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Injected, 20.3 to 30.5 cm, under tarp Injected, 20.3 to 30.5 cm, under tarp Injected, 20.3 to 30.5 cm, under tarp Injected, 20.3 to 30.5 cm, under tarp Injected, 20.3 to 30.5 cm, under tarp Injected, 20.3 to 30.5 cm, under tarp APPLICATION RATE ( KG/ HA) FOR THE FORMULATION 252 252 194/ 283 224 224 224 APPLICATION RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 247 247 191 150 150 150 DOSAGE RATE*( G/ M 2) OF FORMULATION USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 25.2 25.2 19.4/ 28.3 22.4 22.4 22.4 ACTUAL DOSAGE RATE FOR THE ACTIVE INGREDIENT ( g/ m2)* 24.7 24.7 19.1 15.0 15.0 15.0 APPLICATION RATE OF STRIP/ BED, G MB/ M 2 Approximately 58% of the total area is covered with plastic mulch and treated with methyl bromide in each acre.

For Flat Fumigation treatment application rate and dosage rate may be the same Page 26 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 + CITATIONS** IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE? CHEMICAL ALTERNATIVES 1,3 D products ( includes Telone II, Telone EC, & Telone C 35) Products will not adequately control nutsedge. Label restriction states that these products cannot be used where karst geology exists (~ 8% of the production area). Up to 2 applications of Telone II, in line, or EC formulations may be needed to manage moderate to severe pest population levels. Also, there is a 28 day waiting period at the time of application until planting, which could cause loss of over half of the harvest season and the higher end market windows to be missed. These are plantings made in July and harvested in the fall ( Georgia CUE # 03 0049; Kelley, 2003). This only applies to light to moderate infestations and only with Telone C 35. No Metam sodium Product does not adequately control nutsedge. Also, there is a 21 day waiting period at the time of application until planting ( 40% of harvest season missed), which may cause part of the higher end market windows to be missed. These are plantings made in July and harvested in the fall. Beginning the application cycle earlier is not an option, since crops from the previous fumigation cycle must be terminated and cleaned up prior to metam application ( Georgia CUE # 03 0049; Kelley, 2003). Repeated applications of MITC ( the breakdown product of metam sodium) are known to enhance its biodegradation as a result of adapted microorganisms ( Duncan and Yates, 2003). No Page 27 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE + CITATIONS** IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Halosulfuron Registered for specific uses in eggplant ( Dec. 2002, US EPA, Aug. 2003); application for eggplant is for ROW MIDDLE application and would not provide control of nutsedge in the eggplant bed; potential crop injury; severe plant back restrictions from 3 to 36 months for most vegetables. No COMBINATIONS OF ALTERNATIVES

1. 1,3 D products and a herbicide, e. g. napropamide 2. Metam sodium and a herbicide, e. g. napropamide 3. Iodomethane and a herbicide, e. g. napropamide 4. Glyphosate treatment of plots between the first and second crops ( Webster, et al. 2001)

5. Pest resistant cultivars combined with alternative fumigant strategies 1, 2, and 3 Currently, there are no data to substantiate transition toward a suitable alternative to annual methyl bromide fumigation. Alternative chemicals and cultural practices that are under consideration include various combinations of currently registered and unregistered fumigants and/ or herbicides.

Iodomethane is not registered in the U. S. Please refer to question 15 for detailed and specific information regarding the alternatives. 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 NAME OF ALTERNATIVE DISCUSSION none Other than options discussed elsewhere, no alternatives exist for the control of the key pests when they are present in the soil and/ or afflict the below ground portions of eggplants. Page 28 The U. S. EPA only considered those technically feasible registered alternatives which are relevant for managing severe pathogen and pest pressures. Therefore research or data presented in the CUN2003/ 050   Eggplant Grown Outdoors on Plastic Mulch are not included in the present eggplant sector analysis are irrelevant. For example, Table 2 ( page 4) represented data extracted from a field study conducted under low nutsedge pressure.

Paraquat and glyphosate will suppress emerged nutsedge, but cannot be used in the crop row because of potential crop injury ( SE Pepper Consortium CUE 02 0041).

Fumigation of products containing 1,3 D and metam sodium ( Vapam and/ or K pam) in the summer or fall is practically impossible because of the waiting periods for planting following application under plastic mulch. For 1,3 D there is a 28 day waiting period; for metam sodium, there is a 21 day waiting period. Such delays may cause reduction in yields and market windows missed. Thus, since the fall crop is dependent upon timely planting, a long waiting period ( e. g., 28 days) would cost growers at least half of the harvest season, thereby missing the higher market windows ( Kelley, 2003).

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: Iodomethane Not registered Yes Unknown Fosthiazate Not registered. Yes Unknown Furfural ( Multigard

) Not registered Yes Unknown Sodium azide Not registered. Registration application not yet submitted. No Unknown Propargyl bromide Not registered. Registration application not yet submitted. No Unknown Paecilomyces lilacinus Not registered. Registration pending. Yes Unknown Page 29 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: ( Use same groups as in Question 10 and provide a separate table for each target group for which methyl bromide is considered essential. Omit pathogen and/ or weed tables if these are not the reason why critical use is requested.) 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 Data ( narrative only) and information are bridged for eggplants from the best available information.

Locascio et al. ( 1997) studied MB alternatives on tomatoes grown in small plots at two Florida locations. Various treatments were tested on plots that had multiple pests ( Table 16.1). 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; metamsodium drip irrigated at 300L/ ha; and 1,3 D + 17% chloropicrin chisel injected at 327L/ ha. In pairwise statistical comparisons, the yield was significantly lower in metam sodium 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, one must keep in mind that this MB alternative cannot be used in areas where karst geology exists.

TABLE 16.1. FUMIGANT ALTERNATIVES TO METHYL BROMIDE FOR POLYETHYLENE MULCHED TOMATO ( LOCASCIO ET AL. 1997)

Chemicals Rate (/ ha) Average Nutsedge Density (#/ m2) Average Marketable Yield ( ton/ ha) % Yield Loss ( compared to MB)

Untreated ( control)  300 ab 20.1 a 59.1 MB + Pic ( 67 33), chisel injected 390 kg 90 c 49.1 b

1,3 D + Pic ( 83 17), chisel injected 327 l 340 a 34.6 c 29.5 Metam Na, Flat Fumigation 300 l 320 a 22.6 a 54.0 Metam Na, drip irrigated 300 l 220 b 32.3 c 34.2 Notes: ( 1) Numbers followed by the same letter ( within a column) are not significantly different at the 0.05 level of probability, using Duncan's multiple range test. ( 2) Data shown are from the Gainesville/ Horticultural Unit site, 1994 season ( this was one of three Page 30 sites included in this study). This site had relatively high nutsedge pressure, and data for both pest pressure and marketable yields for all treatments shown.

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

Iodomethane is under consideration for potential methyl bromide replacement. Although it is currently being considered for registration by regulatory authorities, it is currently unknown when it will be registered. Please refer to Table 15.1 for detailed information.

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

No. Any organic production of eggplants is presumed insignificant and probably not cost effective because of the intensive management of pests ( for organic production) and the long growing season. Page 31 GEORGIA  SUMMARY OF TECHNICAL FEASIBILITY Neither 1,3 D nor metam sodium, alone or in combination with chloropicrin, adequately control moderate to high nutsedge populations in Georgia. In addition, 1,3 D cannot be applied in areas overlying karst geology (~ 8 % of the eggplant area; CUE # 03 0050). Furthermore, using products containing 1,3 D and metam sodium in the fall is impractical because of the required long waiting periods for planting following application, 28 days for 1,3 D and 21 days for metam sodium. Such delays would cost Georgia farmers at least half of the harvest season, thereby missing key market windows.

In studies on peppers ( Csinos et al. 1999, Noling et al. 2000), 1,3 D + chloropicrin treatments did not adequately control moderate to high nutsedge populations, and yield losses occurred when compared to MB plus chloropicrin treatments. Additional research on this alternative to demonstrate efficacy against nutsedge is needed in areas with moderate to high nutsedge pressure, considered to be approximately 58% of the current eggplant production area ( Culpepper, 2004). Lack of an effective, registered herbicide impairs adoption in crops such as pepper ( Banks, 2002), and probably other high value vegetable crops for the fresh market ( Monks, Southeast Peppers Consortium, CUE 03 0041).

Nematode pests, such as the root knot nematode species of Meloidogyne, were third to nutsedge in terms of priority of pest management strategies in Georgia eggplant production. Pre plant control of nematodes is critical since nematode root feeding and damage may predispose plant tissues to invasion by fungal pathogens, potentially leading to wilt, loss of plant vigor, and significant yield losses. Fumigant alternatives such as metam sodium have proven inconsistent ( Noling, 2003; FFVA, 2002).

Diseases caused by soil borne plant pathogenic fungi, ( e. g., Phytophthora spp., Pythium spp. and Sclerotium rolfsii) may be curtailed if weather conditions are detrimental for disease development. These pathogens are endemic in many vegetable production areas in Georgia. Fungicides such as chlorothalonil, and azoxystrobilurin are considered to be only prophylactic, and may not offer sufficient pest management. Resistance of Phytophthora spp to metalaxyl and mefanoxem ( Ridomil and Ridomil Gold, respectively) has been reported in tomato crop areas, and most recently pepper ( Lamour and Hausbeck, 2003)

The use of products containing 1,3 D and metam sodium in the fall is impractical because of the long waiting periods for planting following application under plastic mulch. For 1,3 D there is a 28 day waiting period; for metam sodium, there is a 21 day waiting period. Such delays would cost growers at least half of the harvest season, thereby missing the higher market windows. Thus, since the fall crop is dependent upon timely planting, the required waiting period would cost growers at least half of the harvest season, thereby missing the higher market windows ( Kelley, 2003). Page 32 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 TARGET PESTS ( WEEDS, PLANTPARASITIC NEMATODES) AND PATHOGENS SPECIFIC REASONS WHY METHYL BROMIDE NEEDED Michigan Crown and root rots caused by Soilborne Fungus  Phytophthora capsici.

Wilts caused by Soil borne Fungi  Verticillium spp. Methyl bromide alone allows growers to fumigate and plant early in order to capture the key market window ( July  September) and have their product available for premium prices, as well as ensuring demand for their crop during the entire growing season, especially during the mid and late season. The fumigation and planting schedule allow growers to maintain market diversity, as well.

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) Vegetable crop for the fresh market ANNUAL OR PERENNIAL CROP: (# of years between replanting) Annual  generally 1 year TYPICAL CROP ROTATION ( if any) AND USE OF METHYL BROMIDE FOR OTHER CROPS IN THE ROTATION: ( if any) Rotation sequence commonly followed by a pepper or cucurbit crop SOIL TYPES: ( Sand, loam, clay, etc.) Sandy loam, clayish loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) 1 time every 2 years OTHER RELEVANT FACTORS: Michigan's diversified vegetable crop production is designed to meet key late spring and summer market demands in Midwestern states. Page 33 MICHIGAN  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE FOR EGGPLANTS MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE " PLANT HARDINESS ZONE" ( e. g. temperate, tropical) Generally characterized as 5b according to the USDA Hardiness Zone Map, with annual minimum temperature ranges ( average) as   23.4 to   26.1 ° C ( 15 to   10 ° F). Example cities: Columbia, Missouri and Mansfield, Pennsylvania.

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

  PLANTING SCHEDULE

  KEY HARVEST ( MARKET) WINDOW

 Shaded areas represent typical duration of activity;

= typical initiation of activity,  = typical termination of activity MICHIGAN   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Michigan experiences heavy rainfall events across the entire state at any given moment of the growing season. Heavy rain events ( over 25 mm) can trigger rapid root and crown rot development, and promote dissemination of Phytophthora capsici via irrigation sources. Generally, there is no difference in the amount of infection depending on soil type or production area. The pathogen is widespread and indigenous on almost all soil types in Michigan ( Cortwright, 2003; Gevens and Hausbeck, 2003).

All fumigation practices need to be completed by the first week of May to allow growers to plant early and capture the early market ( July September).

Significant rainfall events (> 25.4 mm) or cold soil temperatures (< 4.4 ° C) could delay fumigation and planting.

Lighter soil types may make drip application difficult ( Cortwright, 2003).

MICHIGAN  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED Michigan's use of methyl bromide for vegetable production has declined steadily since the mid 1990s, when growers switched to different application methods ( i. e. from Flat Fumigation to tarped beds) and formulations, from 98: 2 to 67: 33 ( methyl bromide: chloropicrin). Since 1997, all methyl bromide is applied to tarped beds, with 100% of low density polyethylene sheeting and 95% of the area was treated Page 34 with the 67: 33 formulation. Since 2000, about 5% of the area used the 50: 50 methyl bromide: chloropicrin formulation. Growers are using anti drip valves to eliminate loss of MB at the end of rows when the machinery is removed from the ground.

Please see Table 12.1 for further information.

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) 22 24 25 29 33 34 AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kg) 2,625 2,870 2,937 3,500 3,905 4,057 FORMULATIONS OF METHYL BROMIDE ( e. g. methyl bromide 98: 2; methyl bromide/ Chloropicrin 70: 30) 67: 33 67: 33 67: 33 67: 33 or 50: 50 67: 33 or 50: 50 67: 33 or 50: 50 METHOD BY WHICH METHYL BROMIDE APPLIED ( e. g. injected at 25cm depth, hot gas) Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm APPLICATION RATE OF FORMULATIONS IN kg/ ha* 180 180 180 180 180 180 ACTUAL DOSAGE RATE OF FORMULATIONS ( g/ m2)* 17.9 17.9 17.9 17.9 17.9 17.9 APPLICATION RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 120 120 120 120 or 90 120 or 90 120 or 90 ACTUAL DOSAGE RATE FOR THE ACTIVE INGREDIENT ( g/ m2)* 12 12 12 12 or 9 12 or 9 12 or 9 APPLICATION RATE OF STRIP/ BED, G MB/ M 2 32.2 32.2 32.2 32.2 or 27.0 32.2 or 27.0 32.2 or 27.0 * For Flat Fumigation treatment application rate and dosage rate may be the same. Page 35 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 + CITATIONS** IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES 1,3 Dichloropropene ( 1,3 D) Not effective against soil borne fungi. Several bacteria genera appear to be capable of degrading 1,3 D ( Duncan and Yates, 2003). There is a Federal label restriction of a 30.4 m buffer zone between treated fields and inhabited structures. 28 day waiting period for planting may be disruptive to timely eggplant production and marketing. No Chloropicrin Does not distribute evenly throughout the soil profile when used by itself, resulting in poor efficacy. Does not control Phytophthora capsici when used at maximum label rates. ( California Pepper Commission, CUE 02 0017; CUE03 0017) No Metam Sodium Poor fumigant with erratic results and inconsistent distribution in soil profiles; does not control Phytophthora capsici nor Verticillium spp. ( California Pepper Commission, CUE 02 0017; CUE03 0017). Repeated applications of MITC ( the breakdown product of metam sodium) are known to enhance its biodegradation as a result of adapted microorganisms ( Duncan and Yates, 2003). Phytotoxicity has been reported with this fumigant. 21 day day waiting period for planting may be disruptive to timely eggplant production and marketing. No COMBINATIONS OF ALTERNATIVES 1,3 D + chloropicrin ( Telone C 35) The 28 day waiting period for planting could disrupt the eggplant production and marketing timing. Regulatory restrictions due to concerns over human exposure and ground water contamination, along with technical limitations, result in potential economic infeasibility of this formulation as a practical MB alternative. No Metam Sodium/ Crop Rotation Metam sodium is a poor fumigant that provides erratic control. Repeated applications of MITC ( the breakdown product of metam sodium) are known to enhance its biodegradation as a result of adapted microorganisms ( Duncan and Yates, 2003). Because of high land costs, very few crops are of high enough economic value to be rotated with eggplants. A 4 5 year rotation is necessary to reduce inoculum levels. The economic threshold of Phytophthora capsici is presumed to be 1 oospore/ ft2 ( Michigan CUE 03 0061). 21 day day waiting period for planting may be disruptive to timely eggplant production and marketing. No Page 36 Metam Sodium/ Furfural ( Multigard

) Results of a 2003 small plot field study demonstrated practically equivalent soil pest control of targeted pests ( plot vigor) and slightly lesser yields than methyl bromide. ( Cortwright and Hausbeck, 2003). Please refer to Table 16.2 (??). Although furfural is not yet registered by the U. S. EPA, it is under consideration by federal authorities. Insufficient data and trials to estimate cost effectiveness at this time.

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

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

Potential yield losses to Phytophthora capsici could be up to 10% of the production area, especially if the plants are affected early in the growing season. This is explained by the widespread occurrence of indigenous populations of P. capsici, ( Michigan CUE # 03 0061; Gevens and Hausbeck., 2003), significant rainfall events ( greater than 254 mm) which trigger rapid disease development ( Cortwright, 2003), metalaxyl and mefanoxem insensitivity reported among Phytophthora spp. populations in several vegetable production areas ( Lamour and Hausebeck, 2003; Parra and Ristaino, 1998), and planting restrictions of registered alternative fumigants ( e. g. 1,3 D + chloropicrin and metam sodium).

Wilts caused by species of soil borne fungi such as Verticillium are endemic to many vegetable producing areas of Michigan. These fungi have an extensive plant host range, typically forming survival structures ( microsclerotia) which are resistant to fungicides and periods of drought, overwintering in colonized plant tissue.

Planting restrictions on 1,3 D and metam sodium labels, rather than lack of effectiveness, curtail Michigan grower use of these fumigants. Potential yield losses associated with regulatory restrictions could be higher because fumigation needs to be completed by the first week of May to allow growers to plant early and capture the early market ( July  September) and have their product available for premium prices, as well as ensuring demand for their crop during the entire growing season ( especially during the mid and late season). According to the applicant, Michigan's diversified vegetable crop industry, designed to meet market demands in the late spring and through the summer for Midwestern markets, require carefully timed planting and harvesting schedules. The fumigation with methyl bromide and planting schedule allow growers to maintain market diversity, as well. Fumigation with 1,3 D + chloropicrin might be an effective alternative, except in certain years when climatic conditions ( e. g., wet soils) may delay planting schedules. Page 37 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:

Iodomethane Not registered. Yes unknown Fosthiazate OP nematicide. Under review. Yes Unknown Furfural ( Multigard

) Not registered. Yes Unknown Sodium azide Not registered. Yes Unknown Diallyl sulfide Registered to control Sclerotinia spp. ( plant pathogenic fungi). Very limited and narrow spectrum of uses. Uses may be expanded Unknown Metam sodium Registered Yes Reregistration scheduled for 2005 06 Propargyl bromide Not registered. Yes Unknown Paecilomyces lilacinus Not registered. Registration pending. Yes Unknown 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:

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 5 95 % PLUS loss of revenue due to planting delays 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) Page 38 Small plot field trial conducted in summer, 2003: Evaluation of fumigants for managing Phytophthora crown and fruit rot of solanaceous and cucurbit crops. The following are the results of the eggplant trials ( Cortrwright and Hausbeck, 2003).

In a randomized complete block design with 4 replicates per treatment, no significant differences were noted for eggplant yields for plots treated with metam sodium ( Vapam), methyl bromide + chloropicrin, 1,3 D + chloropicrin or Iodomethane ( Midas   ) + chloropicrin. Eggplant yields obtained from plots treated with the 50% formulation of iodomethane + chloropicrin were practically equivalent, whereas eggplant yields from plots treated with the 33% formulation of iodomethane + pic were appreciably higher than yields from plots treated with MB. The vegetable plots ( portion of relevant results in Table 16.2) were constructed on a sandy loam soil ( 72.4% sand, 14.2% silt, 13.4% clay) with a known history of Phytophthora, and pumpkin planting in 2002, followed by a rye cover crop. Fumigant treatments were injected at 80 psi; all treatment beds were covered with 1.25 mil black plastic embossed mulch. Beds were 6 in. high and spaced 5 ft apart. Two drip tubes were installed just under the plastic during bed formation and mulch laying, dividing the bed into thirds. During the first week of August, 2003, several heavy rain events saturated the soil ( 101 262 mm during a span of 3 days, Oceana, MI). There was a quick disease epidemic which spread rapidly and uniformly across the replicates with significant differences in plant death noted for the tested Curcurbitacae. There was no plant death, and no difference in plant vigor for the eggplant plots. There were no significant weed rating differences for the tested treatments.

Table 16.2 Summary of field trials conducted by Cortrwright and Hausbeck ( 2003)

ALTERNATIVE APPLICATION RATE, METHOD TARGET PEST( S) A YIELDS OF EGGPLANTS ( numbers of fruit)

Untreated 14.3 Multigard   Protect + metam sodium HL Multigard   37 gal + 20 gal Preplant Drip 5.8 gal Postplant Drip 14.4 Multigard   Protect + metam sodium HL Multigard   56 gal + 30 gal Preplant Drip 5.8 gal Postplant Drip 13.1 Metam sodium HL 75 gal; Preplant Drip 10.5 MB + chloropicrin ( 67: 33) 350 lb; Preplant Shank 16.2 1,3 D + chloropicrin C35 35 gal; Preplant Shank 17.0 Iodomethane/ chloropicrin ( 50: 50) 250 lb; Preplant Shank 13.3 Iodomethane/ chloropicrin ( 33/ 67) 200 lb; Preplant Shank Phytophthora capsici Verticillium spp.

23.9 AOther pests ( e. g., weeds and nematodes) were most likely present; however population densities were not determined in this study. Ratings of plant health and severe disease pressure were based on typical symptoms of Phytopthora crown and fruit rots on peppers From these small plot studies, the yield results indicate that 1,3 D + chloropicrin ( 65: 35 formulation) and methyl bromide ( 67: 33) were very effective in managing pest populations for eggplants. Yields of eggplants were appreciably higher in the plots treated with the 33/ 67 iodomethane/ chloropicrin (~ 66 lbs iodomethane formulation, however eggplant yields were practically equivalent in the higher rate of iodomethane ( 50: 50 formulation; 125 lbs iodomethane). However, yields of eggplants from the metam sodium treated plots were somewhat lower than for the plots treated with Page 39 methyl bromide, demonstrating the inconsistency of metam sodium in pesticidal efficacy. Multigard   ( furfural) applied post plant seemed to slightly improve eggplant yield compared to metam sodium alone. Yields were lower than those obtained with methyl bromide, however. Soils treated with repeated applications of metam sodium ( or metam potassium) are known to enhance its biodegradation through adapted microorganisms. Preliminary evidence suggests that the microorganisms responsible for enhanced degradation of MITC specifically target the isothiocyanate functional group ( Duncan and Yates, 2003). Other field researchers have alluded to metam sodium's limited niche as a complementary treatment with other fumigants and herbicides, indicating that this chemical should not be used as a standalone treatment ( Noling, 2003).

At present, no data directly attribute yield losses to alternative management of pest pressures. Results of the above small study also suggest that yield losses can be mitigated if careful attention is given to preplant fumigation methods and bed preparation. Efficacy depends on proper application and can vary from site to site. In a similar trial, conducted in another Michigan location, with a lighter soil type, lower disease pressure was reported. However the lighter soil type reportedly made drip application difficult. ( Cortwright, 2003).

Expert opinion in the production area, U. S. EPA analyses ( August, 2003), and nomination packages ( CUE# s 02 0017 California & 03 0017 Florida) provide a yield loss range of 8 to 15%, depending on the extent of pathogen infestation, location of the fields and weather or climatic conditions that favor disease development. In some years, yield losses can be much greater.

An upper bound of 6% yield loss ( for high pest pressures only) is estimated because of 100% field infestation with the soil borne fungus, Phytophthora capsici. Chloropicrin does not provide control of Phytophthora capsici or other soil pathogens, such as Verticillium spp. Since metalaxyl resistant strains of Phytophthora capsici have been documented on solanaceous crops ( Lamour and Hausbeck, 2003; Parra and Ristaino, 1998), growers do not rely on Ridomil   , Ridomil Gold   , or Quadric   .

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

The Agency is presently unaware of large scale, commercial greenhouse operations for eggplants. It might be expected, however that there are local ( or small community) operations of both organic and hothouse eggplant production that target fresh market, and/ or temporal ( seasonal) sectors, e. g., farmers' markets. Large scale production is probably not cost effective, because of the intensive management of pests and the long growing season for eggplants.

MICHIGAN  SUMMARY OF TECHNICAL FEASIBILITY MICHIGAN  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?:

Iodomethane is under consideration for potential methyl bromide replacement. Date of registration is not known.

Please refer to Table 15.1 for a listing of other alternatives, currently under consideration and/ or registration status, as of December, 2003. Page 40 Results depicted in Table 16.1 suggest practically equivalent pest management at the pre plant stage ( plant vigor ratings) and harvestable eggplant yields from plots treated with 1,3 D + chloropicrin. However, yields of eggplants from the metam sodium treated plots were somewhat lower than for the plots treated with methyl bromide, demonstrating the inconsistency of metam sodium in pesticidal efficacy. Multigard   ( furfural) applied post plant seemed to slightly improve eggplant yield, than with metam sodium alone. Yields were lower than those obtained with methyl bromide, however. Soils treated with repeated applications of metam sodium ( or metam potassium) are known to enhance their biodegradation as a result of adapted microorganisms. Preliminary evidence suggests that the microorganisms responsible for enhanced degradation of MITC specifically target the isothiocyanate functional group ( Duncan and Yates, 2003). Other field researchers have alluded to metam sodium's limited niche as a complementary treatment with other fumigants and herbicides, and this chemical should never be used as a stand alone treatment ( Noling, 2003).

It should be noted that, these plots were carefully monitored and managed; post plant prophylactic foliar fungicide ( chlorothalonil, myclobutanil, Cabrio   ) and herbicide treatments were necessary to manage and prevent seasonal fluctuations of pest pressures.

Diseases caused by soil borne plant pathogenic fungi, ( e. g., Phytophthora spp., Verticillium spp., Pythium spp. and Rhizoctonia solani ) may be curtailed if weather conditions are detrimental for disease development. These pathogens are indigenous in many vegetable production areas in Michigan. Fungicides such as chlorothalonil, and azoxystrobilurin are considered to be only prophylactic, and may not offer sufficient pest management. Resistance of Phytophthora spp to metalaxyl and mefanoxem ( Ridomil and Ridomil Gold, respectively) has been reported in tomato crop areas, and most recently pepper ( Lamour and Hausbeck, 2003).

Rather than lack of effective alternative fumigants, planting restrictions on the labels of 1,3 D and metamsodium prevent their adoption by Michigan growers. Michigan's diversified vegetable crop production practices are designed to meet key late spring and summer market demands in Midwestern states in a timely fashion. Fumigation practices need to be completed by the first week of May to allow growers to plant early and capture the early market ( July  September) and have their product available for premium prices, as well as ensuring demand for their crop during the entire growing season ( especially during the mid and late season). The fumigation with methyl bromide and planting schedule allow growers to maintain market diversity, as well. Fumigation with 1,3 D + chloropicrin might be an effective alternative, except in certain years or climatic conditions ( e. g., wet soils) which may delay planting schedules. Page 41 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 US 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 US 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 non chemical 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 42 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. In addition, cultural practices are utilized by cucurbit growers.

Reduced methyl bromide concentrations in mixtures, cultural practices, and the extensive use of tarpaulins to cover land treated with methyl bromide has resulted in reduced emissions and an application rate that we believe is among the lowest in the world for the uses described in this nomination. Page 43 PART E: ECONOMIC ASSESSMENT The economic assessment is organized by MB critical use application. Cost of MB and alternatives are given first in table 21.1. This is followed in table 22.1 by a listing of net and gross revenues by applicant. Expected losses when using MB alternatives are then further decomposed in tables E1 through E3.

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: EGGPLANTS  COSTS OF ALTERNATIVES COMPARED TO METHYL BROMIDE OVER 3 YEAR PERIOD ALTERNATIVE YIELD* COST IN YEAR 1 ( U. S.$/ ha) COST IN YEAR 2 ( U. S.$/ ha) COST IN YEAR 3 ( U. S.$/ ha) Florida Methyl Bromide 100% $ 3,010 $ 3,010 $ 3,010 1,3 D + Chloropicrin 71% $ 3,719 $ 3,719 $ 3,719 Metam Sodium 56% $ 3,519 $ 3,519 $ 3,519 Georgia Methyl Bromide 100% $ 3,642 $ 3,642 $ 3,642 1,3 D + Chloropicrin 71% $ 3,242 $ 3,242 $ 3,242 Metam Sodium 56% $ 3,027 $ 3,027 $ 3,027 Michigan Methyl Bromide 100% $ 1,475 $ 1,475 $ 1,475 1,3 D + Chloropicrin 94% $ 1,772 $ 1,772 $ 1,772 * As percentage of typical or 3 year average yield, compared to methyl bromide e. g. 10% more yield, write 110. Page 44 22. GROSS AND NET REVENUE:

TABLE 22.1: EGGPLANT   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 ( U. S.$/ ha) NET REVENUE FOR LAST REPORTED YEAR ( U. S.$/ ha) Florida Methyl Bromide $ 21,730 $ 6,408 1,3 D + Chloropicrin $ 15,428 $ 1,156 Metam Sodium $ 12,169  $ 1,388 Georgia Methyl Bromide $ 42,857 $ 10,491 1,3 D + Chloropicrin $ 30,428 $ 2,899 Metam Sodium $ 24,000  $ 493 Michigan Methyl Bromide $ 34,074 $ 9,344 1,3 D + Chloropicrin $ 29,627 $ 5,268 NOTE: Year 1 equals year 2 and 3.

MEASURES OF ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FLORIDA EGGPLANT  TABLE E. 1: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES FLORIDA EGGPLANT METHYL BROMIDE 1,3 D + CHLOROPICRIN METAMSODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 1,893 1,344 1,060 * PRICE PER UNIT ( US$) $ 11 $ 11 $ 11 = GROSS REVENUE PER HECTARE ( US$) $ 21,730 $ 15,428 $ 12,169  OPERATING COSTS PER HECTARE ( US$) $ 15,322 $ 14,272 $ 13,557 = NET REVENUE PER HECTARE ( US$) $ 6,408 $ 1,156  $ 1,388 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 5,252 $ 7,796 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 35 $ 52 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 24% 36%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 82% 122% Page 45 GEORGIA EGGPLANT  TABLE E. 2: ECONOMIC IMPACTS OF METHYL BROMIDE ALTERNATIVES GEORGIA EGGPLANT METHYL BROMIDE 1,3 D + CHLOROPICRIN METAMSODIUM YIELD LOSS (%) 0% 29% 44%

YIELD PER HECTARE 6,326 4,491 3,542 * PRICE PER UNIT ( US$) $ 7 $ 7 $ 7 = GROSS REVENUE PER HECTARE ( US$) $ 42,857 $ 30,428 $ 24,000  OPERATING COSTS PER HECTARE ( US$) $ 32,365 $ 27,530 $ 24,493 = NET REVENUE PER HECTARE ( US$) $ 10,491 $ 2,899  $ 493 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 7,593 $ 10,985 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 51 $ 73 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 18% 26%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 72% 105%

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

YIELD PER HECTARE 3,665 3,445 * PRICE PER UNIT ( US$) $ 9.30 $ 8.60 = GROSS REVENUE PER HECTARE ( US$) $ 34,074 $ 29,627  OPERATING COSTS PER HECTARE ( US$) $ 24,730 $ 24,359 = NET REVENUE PER HECTARE ( US$) $ 9,344 $ 5,268 LOSS MEASURES 1. LOSS PER HECTARE ( US$) $ 0 $ 4,076 2. LOSS PER KILOGRAM OF METHYL BROMIDE ( US$) $ 0 $ 84 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 12%

4. LOSS AS A PERCENTAGE OF NET REVENUE (%) 0% 44% Page 46 SUMMARY OF ECONOMIC FEASIBILITY There are currently few alternatives to methyl bromide for use in eggplant. Furthermore, there are factors that limit existing alternatives' usability and efficacy from place to place. These include pest complex, climate, and regulatory restrictions. As described above, the two most promising alternatives to methyl bromide in Florida and Georgia for control of nutsedge in eggplant ( 1,3 D + chloropicrin and metam sodium) are considered not technically feasible. This derives from regulatory restrictions and the magnitude of expected yield losses when they are used. Economic data representing the Florida and Georgia eggplant growing conditions are thus included in this section as a supplement to the biological review to illustrate the impacts of using MB alternatives, not to gauge them with respect to economic feasibility. However, in Michigan 1,3 D + chloropicrin is considered technically feasible.

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

Analytical Notes Florida's application for MB critical use indicated that more than one crop is typically grown per growing season but did not provide specific production and sales data for this crop. As and result of this gap in data, economic assessment of Florida eggplant production was based on a single crop production system. This characterization of growing conditions could result in the critical need for MB appearing smaller than it actually is, because the value the second crop derives from methyl bromide is not included in the analysis.

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 eggplant growers. As such, the U. S. concludes that use of MB is critical in Georgia eggplant 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.

Michigan The U. S. concludes that, at present, no economically feasible alternatives to MB exist for use in Michigan eggplant production. Two factors have proven most important in this conclusion. These are yield loss and missed market windows, which are discussed individually below. Page 47 1. Yield Loss The U. S. anticipates yield losses of 6% throughout Michigan eggplant production.

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 eggplants 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 eggplants are harvested, the supply is at is lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenues, eggplant growers manage their production systems with the goal of harvesting the largest possible quantity of eggplants when the prices are at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profitability of eggplant operations.

Specific data representing these market fluctuations are not available for Michigan eggplant. However, because of the similar production system and growing conditions, Michigan pepper price data were used to represent price fluctuations in Michigan eggplant and their impact on growers' gross revenues. Though data availability is limiting, it was assumed that if eggplant growers adjust the timing of their production system, as required when using 1,3 D + chloropicrin, they will, over the course of the growing season, receive gross revenues reduced by approximately 7.5%. The season average price was reduced by 7.5% in analysis of the alternatives to reflect this. Based on currently available information, the U. S. believes this reduction in gross revenues serves as a reasonable indicator of the typical effect of planting delays resulting when MB alternatives are used in Michigan eggplant production. Page 48 PART F. FUTURE PLANS 23. WHAT ACTIONS WILL BE TAKEN TO RAPIDLY DEVELOP AND DEPLOY ALTERNATIVES FOR THIS CROP?

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

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

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 eggplant research will require 433 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 root knot nematodes. Another example is a five year field study comparing methyl bromide to 1,3 D combined with biologically based materials including transplant treatments for control of weeds, root knot nematodes and soil borne fungal pathogens. Page 49 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.

25. ADDITIONAL COMMENTS ON THE NOMINATION?

Aerts, M. 2003. Asst. Director, Environmental and Pest Management Division, Florida Fruit and Vegetable Association. Personal Communication with G. Tomimatsu, December 2, 2003.

Banks, H. J. 2002. 2002 Report of the Methyl Bromide Technical Options Committee, 2002 Assessment. Pg 46.

Chellemi, D. O., R. C. Hochmuth, T. Winsberg, W. Guetler, K. D. Shuler, L. E. Datnoff, D. T.

Kaplan, R. McSorley, R. A. Dunn, and S. M. Olson. 1997. Application of soil 26. CITATIONS Page 50 solarization to fall production of cucurbits and pepper. Proc. Fla. State Hort. Soc. 10: 333 336.

Cortwright, B. 2003. Field Research Associate University of Michigan. Personal Communication with G. Tomimatsu, November 24, 2003.

Cortwright, B. D. and M. K. Hausbeck. 2003. Evaluation of fumigants for managing Phytophthora crown and fruit rot of solanaceous and cucurbit crops, plot two, 2003. Unpublished study ( MI CUE # 03 0061).

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 Duncan, R. S. and S. R. Yates. 2003. Degradation of fumigant pesticides: 1,3 Dichloropropene, Methyl isothiocyanate, chloropicrin, and methyl bromide. Vadose Zone Journal 2: 279 286.

Florida Fruit and Vegetable Association ( FFVA). 2002. Application for the Methyl Bromide Critical Use Exemption on Solanaceous Crops ( other than tomato). September 9, 2002.

Frank, J. R., P. H. Schwartz and W. E. Potts. 1992. Modeling the effects of weed interference periods and insects on bell peppers ( Capsicum annuum). Weed Sci. 40: 308 312.

Gevens, A. J. and M. K. Hausbeck. 2003. A first report of Phytophthora capsici in irrigating water near cucurbit fields in Michigan ( Abstr).

Kelley, W. T. 2003, Professor, University of Georgia. Personal communication with G. Tomimatsu, November 24, 2003.

Lamour, K. H. and M. Hausbeck. 2003. Effect of Crop Rotation on the survival of Phytophthora capsici in Michigan. Plant Dis. 87: 841 845.

Lewis, C. 2003 ( President, Hy Yield Bromine). Personal communication through S. A. Toth ( steve_ toth@ ncsu. edu) , Extension Entomologist & Pest Management Information Specialist, North Carolina State University; message forwarded electronically to G. Tomimatsu, December 29, 2003.

Melban, K. 2003. California Pepper Commission. Personal Communication with G. Tomimatsu. Kenny@ tabcomp. com. 11/ 26/ 2003.

Noling, J. W. 2003. University of Florida Lake Alfred. Personal Communication with G. Tomimatsu. Jwn@ lal. ufl. edu. 11/ 25/ 2003. Page 51 Noling, J. W., E. Rosskopf, and D. L. Chellemi. 2000. Impacts of alternative fumigants on soil pest control and tomato yield. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http:// www. mbao. org/ mbrpro00. html.

Stall, W. M. and J. Morales Payan. 2000. The critical period of nutsedge interference in tomato. S. W. Florida Research & Education Center. www. imok. ufl. edu/ liv/ groups/ IPM/ weed_ con/ nutsedge. htm USDA. 2002. Crop Profiles: Florida Eggplant. http:// pestdata. ncsu. edu/ cropprofiles/ docs/ FLeggplant_. html U. S. EPA. 2002. Peppers Field. Peppers Grown Outdoors on Plastic Mulch. CUN2003/ 058 Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, R. L. Fery. 2001. Methyl bromide alternatives in a bell pepper squash rotation. Crop Protection 20: 605 614.

CITATIONS REVIEWED BUT NOT APPLICABLE Jones, J. 2003. Regulatory Status of Soil Fumigants. Plenary Session 1. Presentation at the 2003 Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions, San Diego, CA.

Webster, T. M., A. S. Csinos, A. W. Johnson, C. C. Dowler, D. R. Sumner, R. L. Fery. 2001. Methyl bromide alternatives in a bell pepper squash rotation. Crop Protection 20: 605 14. Page 52 APPENDIX A. 2006 Methyl Bromide Usage Numerical Index ( BUNI). 2,197 48%

2001 & 2002 Average % of 2001 &

2002 Average 497 64%

not available not available 647 113%

1,145 99%

Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) % Reduction 27,769 185 150 43%

3,951 82 48 0%

73,716 491 150 24%

106,193 758 116 29%

29% 28%

2006 Low High Low High Low High Low High Low High Low High Low HIGH LOW 150 150 8 8 0 0 58 39 0 0 0 0 0 0 62% 43%

48 48 0 0 0 0 75 75 0 0 0 0 100 100 100% 100%

150 150 40 40 1 1 58 39 0 0 0 0 0 0 80% 59%

Strip Bed Treatment Currently Use Alternatives? Research /

Transition Plans Tarps /

Deep Injection Used Pest

free Cert.

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

State Frequency of Treatment Loss per Hectare (

US$/

ha) Loss per Kilogram of MeBr (

US$/

kg) Loss as a %

of Gross Revenue Loss as a %

of Net Revenue Yes Yes Yes Tarp No 0 Yes 1/ year 7,593 $ 51 $ 18% 72%

Yes Yes Yes Tarp No 0 Yes 1/ year 1,674 $ 35 $ 5% 18%

Yes Yes Yes Tarp No  Yes 1/ year 5,252 $ 35 $ 24% 82%

Conversion Units: 1 Pound = Kilograms Hectare 2006 Methyl Bromide Usage Numerical Index ( BUNI) Sector: EGGPLANT % of Average Hectares Requested:

Methyl Bromide Critical Use Exemption Process Date: 2/ 26/ 04 Average Hectares in the US:

2001 & 2002 Average Use* Quarantine and Pre Shipment Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha) Kilograms ( kgs) Hectares ( ha) Use Rate ( kg/ ha)

2006 Amount of Request REGION 48,868 325 150 47,713 318 150 0%

3,951 82 48 3,981 83 48 0%

97,250 647 150 114,623 728 157 0%

TOTAL OR AVERAGE 150,069 1,055 116 166,317 1,129 119 0%

Subtractions from Requested Amounts ( kgs) Combined Impacts Adjustment ( kgs)

2006 Request () Double Counting () Growth or 2002 CUE Comparison () Use Rate Difference () QPS HIGH LOW 48,868  1,155   29,582 20,517 3,951     3,951 3,951 97,250

148,914  77,800 57,378 148,914 111,333 81,845 1% 26% 45%

% Reduction from Initial Request 0% 0% 1% 1% Unsuitable Terrain (%) Cold Soil Temp (%)

Adjustments to Requested Amounts Use Rate ( kg/ ha) (%) Karst Topography (%) 100 ft Buffer Zones MICHIGAN FLORIDA (%) Key Pest Distribution Regulatory Issues (%) Combined Impacts (%)

Other Considerations Dichotomous Variables ( Y/ N) Other Issues Economic Analysis Quality/ Time/ Market Window/ Yield Loss (%)

29% yield loss + planting delay 44% yield loss + planting delay Marginal Strategy 1,3 D + Pic Metam Sodium + Pic 29% yield loss + planting delay 44% yield loss + planting delay 6% Yield Loss 1,3 D+ Pic 0.404686 1,3 D + Pic Metam Sodium + Pic REGION REGION REGION GEORGIA MICHIGAN FLORIDA GEORGIA MICHIGAN FLORIDA 2006 Nomination Options 0.453592 1 Acre = 148,914 GEORGIA MICHIGAN FLORIDA GEORGIA Nomination Amount 150,069 150,069 MOST LIKELY IMPACT VALUE % of Requested Hectares Regional Hectares** 65%

not available 100%