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

YEAR: CUN:

NOMINATING PARTY: The United States of America BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Peppers Grown in Open Fields on Plastic Tarpaulins ( Prepared in 2005)

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.

Yes

No Signature Name Date Title: U. S. Pepper ii CONTACT OR EXPERT( S) FOR FURTHER TECHNICAL DETAILS Contact/ Expert Person: Steve Knizner Title: Acting Division Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U. S. Environmental Protection Agency Mail Code 7503C Washington, DC 20460 U. S. A. Telephone: ( 703) 305 6903 Fax: ( 703) 308 8090 E mail: Knizner. steve@ 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 U. S. Pepper iii TABLE OF CONTENTS PART A: SUMMARY ____________________________________________________________ 9 1. Nominating Party _________________________________________________________ 9 2. Descriptive Title of Nomination______________________________________________ 9 3. Crop and Summary of Crop System___________________________________________ 9 4. Methyl Bromide Nominated _________________________________________________ 9 5. Brief Summary of the Need for Methyl Bromide as a Critical Use ___________________ 9 6. Summarize Why Key Alternatives Are Not Feasible_____________________________ 13 7. Proportion of Crops Grown Using Methyl Bromide _____________________________ 13 8. Amount of Methyl Bromide Requested for Critical Use __________________________ 14 9. Summarize Assumptions Used to Calculate Methyl Bromide Quantity Nominated for Each Region___________________________________________________________________ 15 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ______________ 15 Michigan  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 15 Michigan  11. Characteristics of Cropping System and Climate _____________________ 16 Michigan  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 17 MICHIGAN  PART C: TECHNICAL VALIDATION _____________________________________ 18 Michigan  13. Reason for Alternatives Not Being Feasible _________________________ 18 Michigan  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 22 Michigan  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 22 Michigan  16. State Relative Effectiveness of Relevant Alternatives Compared to Methyl Bromide for the Specific Key Target Pests and Weeds for which It Is Being Requested ___ 22 Michigan  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 24 Michigan  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 24 Michigan  Summary of Technical Feasibility ____________________________________ 25 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE_____________________________________ 26 Southeast U. S. Peppers Consortium excluding Florida and Georgia  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request____ 26 Southeast U. S. Peppers Consortium excluding Florida and Georgia  11. Characteristics of Cropping System and Climate ________________________________________________ 27 Southeast U. S. Peppers Consortium excluding Florida and Georgia  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested _____________________________________________________ 29 SOUTHEAST PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART C: TECHNICAL VALIDATION ________________________________________________________________ 30 U. S. Pepper iv Southeast U. S. Peppers Consortium excluding Florida and Georgia  13. Reason for Alternatives Not Being Feasible _______________________________________________ 30 Southeast U. S. Peppers Consortium excluding Florida and Georgia  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ______________________________________ 34 Southeast U. S. Peppers Consortium excluding Florida and Georgia  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _________ 35 Southeast U. S. Peppers Consortium excluding Florida and 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 ___________________________ 36 Southeast U. S. Peppers Consortium excluding Florida and Georgia  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide?_________________________________________________________________ 38 Southeast U. S. Peppers Consortium excluding Florida and Georgia  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? 39 Southeast U. S. Peppers Consortium excluding Florida and Georgia   Summary of Technical Feasibility ________________________________________________________________ 39 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _______________ 41 Georgia  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 41 Georgia  11. Characteristics of Cropping System and Climate_______________________ 41 Georgia  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested __________________________________ 44 GEORGIA  PART C: TECHNICAL VALIDATION_______________________________________ 45 Georgia  13. Reason for Alternatives Not Being Feasible __________________________ 45 Georgia  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 49 Georgia  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 50 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 ___ 50 Georgia  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 51 Georgia  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 52 Georgia  Summary of Technical Feasibility _____________________________________ 52 FLORIDA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE________________ 54 Florida  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request_____________________________________________________ 54 Florida  11. Characteristics of Cropping System and Climate _______________________ 54 Florida  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested __________________________________ 56 FLORIDA  PART C: TECHNICAL VALIDATION_______________________________________ 57 Florida  13. Reason for Alternatives Not Being Feasible ___________________________ 57 U. S. Pepper v Florida  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: _______________ 61 Florida  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 62 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 ___ 62 Florida  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 63 Florida  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide? _______________________________________________________ 64 Georgia  Summary of Technical Feasibility _____________________________________ 64 CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE _____________ 66 California  10. Key Diseases and Weeds for which Methyl Bromide Is Requested and Specific Reasons for this Request______________________________________________ 66 California  11. Characteristics of Cropping System and Climate _____________________ 66 California  12. Historic Pattern of Use of Methyl Bromide, and/ or Mixtures Containing Methyl Bromide, for which an Exemption Is Requested ____________________________ 67 CALIFORNIA  PART C: TECHNICAL VALIDATION ____________________________________ 69 California  13. Reason for Alternatives Not Being Feasible _________________________ 69 California  14. List and Discuss Why Registered ( and Potential) Pesticides and Herbicides Are Considered Not Effective as Technical Alternatives to Methyl Bromide: ___________ 71 California  15. List Present ( and Possible Future) Registration Status of Any Current and Potential Alternatives _______________________________________________________ 71 California  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 ___ 72 California  17. Are There Any Other Potential Alternatives Under Development which Are Being Considered to Replace Methyl Bromide? __________________________________ 73 California  18. Are There Technologies Being Used to Produce the Crop which Avoid the Need for Methyl Bromide?___________________________________________________ 73 California  Summary of Technical Feasibility ___________________________________ 73 PART D: EMISSION CONTROL ___________________________________________________ 74 19. Techniques That Have and Will Be Used to Minimize Methyl Bromide Use and Emissions in the Particular Use ________________________________________________________ 74 20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used, or Are Not Planned for the Circumstances of the Nomination, State Reasons_____________________ 75 PART E: ECONOMIC ASSESSMENT________________________________________________ 76 21. Operating Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period ___ 76 22. Gross and Net Revenue___________________________________________________ 78 Measures of Economic Impacts of Methyl Bromide Alternatives _____________________ 79 Summary of Economic Feasibility _____________________________________________ 81 PART F. FUTURE PLANS _______________________________________________________ 84 23. What Actions Will Be Taken to Rapidly Develop and Deploy Alternatives for This Crop? ________________________________________________________________________ 84 U. S. Pepper vi 24. How Do You Plan to Minimize the Use of Methyl Bromide for the Critical Use in the Future? __________________________________________________________________ 85 25. Additional Comments on the Nomination ____________________________________ 85 26. Citations ______________________________________________________________ 86 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI).________________ 91 APPENDIX B. 2006 Methyl Bromide Reconsideration for Peppers.___________________ 95 LIST OF TABLES PART A: SUMMARY _____________________________________________________________ 9 Table 4.1: Methyl Bromide Nominated ____________________________________________ 9 Table A. 1: Executive Summary _________________________________________________ 12 Table 7.1: Proportion of Crops Grown Using Methyl Bromide _________________________ 13 Table 8.1: Amount of Methyl Bromide Requested for Critical Use______________________ 14 MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE __________________ 15 Michigan  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request __ 15 Michigan  Table 11.1: Characteristics of Cropping System ___________________________ 16 Michigan  Table 11.2 Characteristics of Climate and Crop Schedule____________________ 16 Michigan  Table 12.1 Historic Pattern of Use of Methyl Bromide ______________________ 18 MICHIGAN  PART C: TECHNICAL VALIDATION________________________________________ 18 Michigan   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 19 Michigan   Table 15.1: Present Registration Status of Alternatives _____________________ 22 Michigan   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 24 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________________________ 26 Southeast U. S. Peppers Consortium excluding Florida and Georgia  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ____________________________ 26 Southeast U. S. Peppers Consortium excluding Florida and Georgia  Table 11.1: Characteristics of Cropping System ______________________________________________________ 27 Southeast U. S. Peppers Consortium excluding Florida and Georgia  Table 11.2 Characteristics of Climate and Crop Schedule   January Fumigation ( Spring, Early Summer Harvest) __ 27 Southeast U. S. Peppers Consortium excluding Florida and Georgia  Table 11.3 Characteristics of Climate and Crop Schedule   Spring Fumigation ( Fall Harvest)__________________ 27 Southeast U. S. Peppers Consortium excluding Florida and Georgia  Table 12.1 Historic Pattern of Use of Methyl Bromide _________________________________________________ 29 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART C: TECHNICAL VALIDATION _____________________________________________________________ 30 Southeast U. S. Peppers Consortium excluding Florida and Georgia   Table 13.1: Reason for Alternatives Not Being Feasible _____________________________________________ 30 Southeast U. S. Peppers Consortium excluding Florida and Georgia   Table 14.1: Technically Infeasible Alternatives Discussion ___________________________________________ 34 Southeast U. S. Peppers Consortium excluding Florida and Georgia   Table 15.1: Present Registration Status of Alternatives for Peppers _________________________________ 35 Southeast U. S. Peppers Consortium excluding Florida and Georgia Table 16.1. Fumigant Alternatives to Methyl Bromide for Polyethylene Mulched Tomato_________________ 36 U. S. Pepper vii Southeast U. S. Pepper Consortium   Table C. 1: Alternatives Yield Loss Data Summary ____ 37 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 41 Georgia  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ___ 41 Georgia  Table 11.1: Characteristics of Cropping System ____________________________ 41 Georgia  Table 11.2 Characteristics of Climate and Crop Schedule   July Fumigation Event, Pepper Crop is Harvested in Fall ____________________________________________ 42 Georgia  Table 11.3 Characteristics of Climate and Crop Schedule   Spring ( Late February   March) Fumigation Event, Pepper Crop is Harvested in Early Summer ______________ 42 Georgia  Table 12.1 Historic Pattern of Use of Methyl Bromide _______________________ 44 GEORGIA  PART C: TECHNICAL VALIDATION_________________________________________ 45 Georgia   Table 13.1: Reason for Alternatives Not Being Feasible______________________ 45 Georgia   Table 14.1: Technically Infeasible Alternatives Discussion ___________________ 49 Georgia   Table 15.1: Present Registration Status of Alternatives for Peppers _____________ 50 Georgia Table 16.1. Fumigant Alternatives to Methyl Bromide for Polyethylene Mulched Tomato ________________________________________________________________ 50 Georgia   Table C. 1: Alternatives Yield Loss Data Summary__________________________ 51 FLORIDA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ___________________ 54 Florida  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request ____ 54 Florida  Table 11.1: Characteristics of Cropping System _____________________________ 54 Florida  Table 11.2 Characteristics of Climate and Crop Schedule _____________________ 55 Florida  Table 11.3 Characteristics of Climate and Crop Schedule   Peppers Double Cropped with another Vegetable Crop ( usually Cucurbits) _______________________________ 55 Florida  Table 12.1 Historic Pattern of Use of Methyl Bromide________________________ 56 FLORIDA  PART C: TECHNICAL VALIDATION _________________________________________ 57 Florida   Table 13.1: Reason for Alternatives Not Being Feasible ______________________ 57 Florida   Table 14.1: Technically Infeasible Alternatives Discussion____________________ 61 Florida   Table 15.1: Present Registration Status of Alternatives _______________________ 62 Florida  Table 16.1. Fumigant Alternatives to Methyl Bromide for Polyethylene Mulched Tomato ________________________________________________________________ 62 Florida   Table C. 1: Alternatives Yield Loss Data Summary __________________________ 63 CALIFORNIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ________________ 66 California  Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request__ 66 California  Table 11.1: Characteristics of Cropping System___________________________ 66 California  Table 11.2 Characteristics of Climate and Crop Schedule ___________________ 67 California  Table 12.1 Historic Pattern of Use of Methyl Bromide _____________________ 68 CALIFORNIA  PART C: TECHNICAL VALIDATION ______________________________________ 69 California   Table 13.1: Reason for Alternatives Not Being Feasible ____________________ 69 California   Table 15.1: Present Registration Status of Alternatives _____________________ 72 California   Table C. 1: Alternatives Yield Loss Data Summary ________________________ 72 PART D: EMISSION CONTROL ____________________________________________________ 74 Table 19.1: Techniques to Minimize Methyl Bromide Use and Emissions ________________ 74 PART E: ECONOMIC ASSESSMENT _________________________________________________ 76 Table 21.1: Peppers   Operating Costs of Alternatives Compared to Methyl Bromide Over 3 Year Period _____________________________________________________________ 77 Table 22.1: Peppers  Year 1, 2, and 3 Gross and Net Revenues ________________________ 78 California Pepper  Table E. 1: Economic Impacts of Methyl Bromide Alternatives_________ 79 U. S. Pepper viii Florida Pepper  Table E. 2: Economic Impacts of Methyl Bromide Alternatives ___________ 79 Georgia Pepper   Table E. 3: Economic Impacts of Methyl Bromide Alternatives __________ 80 Michigan Pepper  Table E. 4: Economic Impacts of Methyl Bromide Alternatives _________ 80 Southeastern USA ( except Georgia) Pepper  Table E. 5: Economic Impacts of Methyl Bromide Alternatives _____________________________________________________________ 81 PART F. FUTURE PLANS ________________________________________________________ 84 APPENDIX A. 2007 Methyl Bromide Usage Numerical Index ( BUNI). __________________ 91 U. S. Pepper Page 9 PART A: SUMMARY 1. NOMINATING PARTY:

The United States of America ( U. S.)

2. DESCRIPTIVE TITLE OF NOMINATION Methyl Bromide Critical Use Nomination for Preplant Soil Use for Peppers Grown in Open Fields on Plastic Tarpaulins ( Prepared in 2005)

3. CROP AND SUMMARY OF CROP SYSTEM Peppers grown in Alabama, Arkansas, California, Florida, Georgia, Kentucky, Louisiana, Michigan, North Carolina, South Carolina, Tennessee, and Virginia. These crops are grown in open fields on plastic tarps, often followed by various other crops. Harvest is destined for the fresh market.

4. METHYL BROMIDE NOMINATED TABLE 4.1: METHYL BROMIDE NOMINATED YEAR NOMINATION AMOUNT ( KG) NOMINATION AREA ( HA)

2007 1,151,751 7,343   This amount includes 2,844 kg for research.

5. BRIEF SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE:

The U. S. nomination is only for those areas where the alternatives are not suitable. In U. S. pepper 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 pepper production.  Geographic distribution of key target pests: i. e., some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure, and in such cases the U. S. is only nominating a CUE for peppers where the key pest pressure is moderate to high such as nutsedge in the Southeastern U. S..  Regulatory constraints: e. g., 1,3 D use is limited in Georgia and Florida due to the presence of karst geology.  Potential delay in planting and harvesting: e. g., the plant back interval for 1,3 D + Chloropicrin may be up to two weeks longer than methyl bromide + chloropicrin. In Michigan an additional delay would occur because soil temperature must be higher to fumigate with alternatives. Delays in planting and harvesting may result in users missing key market windows, and adversely affect revenues through lower prices. U. S. Pepper Page 10 Michigan, California, Florida, Southeastern U. S. ( except Georgia and Florida) are each presented as separate regions in this nomination to reflect the separate applications from growers in these areas. A brief description of their need for MB follows, also presented on a regional basis.

Michigan The key pest of peppers in Michigan is the soil fungi Phytophthora capsici, which 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 other vegetable crops in Michigan ( Hausbeck and Cortright 2003), the level of control was lower than that afforded by MB. P. capsici has recently been shown to also 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 research results accurately reflect efficacy of MB alternatives in pepper production. Furthermore, 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 MB alternative. Among the more important ones are a potential delay in planting as long as 28 days, ( which could lead to missing a key market window) due to label restrictions and low soil temperatures, and a mandatory 30 meter buffer for treated fields near inhabited structures.

Based on the 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) was estimated to be 6 %, based on plant loss. In a second trial undertaken by Hausbeck and Cortright ( 2004), yields from pepper plots treated with metam potassium, alone or in combination with chloropicrin, and from plots treated with 1,3 D + chloropicrin were comparable to yields from plots treated with MB + chloropicrin and yields from untreated ( control plots). These results Likely indicate a very low pest pressure in all treated and control plots.

Michigan pepper farmers requesting MB must plant by the first week of May to capture an early market window. Soil fumigation must therefore be completed by mid April to allow 14 21 days for aeration. However, 1,3 D and metam labels recommend that applications be made when soil temperatures ( at application depth) are above 4.4 ° C. Furthermore, optimum soil temperatures for 1,3 D are in the 10 ° C  25 ° C range ( University of California, Davis, undated). Since soil temperatures in Michigan do not climb over 10 ° C until after mid to late May ( Schaetzl and Tomczak, 2001), neither 1,3 D nor metam products can be used effectively for early pepper planting in Michigan. Metam products have the additional disadvantage that when the soil is wet and cold ( below 15 ° C), the minimum recommended plant back period is 30 days, which would push the crop beyond the early market window.

California The California peppers situation is similar to Michigan's in that the critical pest controlled by MB is P. capsici. The other important pest targeted by MB use in this region is the root knot nematode. California is requesting MB for about 10 % of its pepper area, mainly along the coast. As in Michigan, climatological conditions in these coastal areas  primarily long periods of rainy, cloudy weather   exacerbate problems involving the use of MB alternatives, particularly U. S. Pepper Page 11 formulations of 1,3 D, which cannot be used when soils are very wet. Growers are also reporting lack of efficacy against both of these pests at the maximum label rates for this alternative. In addition, California has township caps that limit the amount of 1,3 D that can be applied in a given area, as well as 100 meter buffer zones near inhabited structures. Urban encroachment is increasing dramatically in California coastal counties, making the buffer zone requirement more prevalent. These conditions are present in the 10% of California pepper production area that need MB.

Southeastern United States ( Including Florida and Georgia)

In the Southeastern United States, including Florida and Georgia, MB is requested primarily for control of moderate to severe infestations of nutsedge weeds. P. capsici is also an important pest targeted currently with MB in these regions. Many growers also use MB against root knot nematodes. Left uncontrolled, any of these pests could completely destroy the harvests from affected areas.

Of currently available MB alternatives, metam sodium offers inconsistent control of nutsedges and nematodes, while 1,3 D + chloropicrin provides adequate control of nematodes and disease ( Locascio et al. 1997, Eger 2000, Noling et al. 2000). However, metam sodium has yield losses of up to 44 % compared to MB where weed infestations are moderate to severe ( Locascio et al. 1997). Metam sodium also creates a planting delay as long as 30 days to avoid risk of phytotoxic injury to crops compared to a 14 day delay for MB. Furthermore, 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, and anywhere in Dade County, Florida, where the majority of that region's peppers are grown. There is also a 28 day planting delay due to regulatory restrictions for 1,3 D + chloropicrin. In Florida particularly, growers are on a tight production schedule and must place pepper transplants in fields at a certain time of the year ( see Table 11.2 in the Florida section for details). Relying only on metam sodium for preplant treatment would force growers to fumigate earlier in their season, which in turn would extend the fumigation schedule into rainy periods. Growers would have to fumigate earlier to avoid rain and lose a portion of the crop ( Aerts, 2004).

Furthermore, trials of metam sodium and 1,3 D + chloropicrin ( and various combinations thereof) are based on small plot research trials conducted in the Southeastern United States on crops other than peppers. For fungi and nutsedge, no on farm, large scale trials have yet been done. Some researchers have also reported that these MB alternatives degrade more rapidly in areas where they are applied repeatedly due to enhanced metabolism by soil microbes ( Dungan and Yates 2003, Gamliel et al. 2003). This may compromise long term efficacy of these compounds and appears to need further scientific scrutiny.

In a recent field study conducted in Tifton, Georgia by Culpepper and Langston ( 2004), 1,3 D + chloropicrin, followed by more chloropicrin, was more effective than MB against yellow nutsedge, but less effective against purple nutsedge. Although this treatment performed as well as MB in terms of spring pepper yield, its fall yield performance was inferior to that of MB.

In a second treatment, 1,3 D by itself, followed by chloropicrin, was significantly less effective U. S. Pepper Page 12 than methyl bromide for the control of both purple and yellow nutsedge, but as effective as MB for the control soil nematodes. In terms of spring and fall pepper yield, however, this treatment performed as well as MB.

In a third treatment, 1,3 D + chloropicrin, followed by metam sodium, was as effective as MB against yellow nutsedge, 36% less effective than MB against purple nutsedge, and as effective as MB for the control of soil nematodes. This treatment also performed as well as MB in terms of both spring and fall pepper yield.

Although these combinations are showing promise, they will require further testing and validation.

In sum, although promising, these MB alternatives require further testing and validation at the commercial level before being available for adoption by pepper growers. Threfore, MB remains a critical use for peppers in the United States.

TABLE A. 1: EXECUTIVE SUMMARY.

Region Michigan Southeastern U. S. except Georgia and Florida Georgia Florida California AMOUNT OF APPLICANT REQUEST 2007 Kilograms 15,195 240,086 347,183 1,415,207 136,078 AMOUNT OF NOMINATION*

2007 Kilograms 11,396 66,089 178,778 880,121 12,522 * See Appendix A for a complete description of how the nominated amount was calculated. U. S. Pepper Page 13 6. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

For Michigan pests 1,3 D + chloropicrin is the only key alternative with efficacy comparable to MB. Regulatory restrictions due to human exposure concerns, combined with technical limitations, reduce its use. Key among these factors are a potential delay in planting as long as 28 days, due both to label restrictions and low soil temperatures, and mandatory 30 to 100 meter buffers for treated fields near inhabited structures.

For the Southeastern United States, including Florida and Georgia, an application of 1,3 D + chloropicrin ( Telone C35), along with a herbicide mix ( e. g. clomazone + metolachlor) applied at bed formation, or Telone C35 followed by a chloropicrin or a metam application, may be the best available BM alternatives outside karst geology areas. In karst geology areas, including 31 counties in Florida, where Telone use is highly restricted, metam sodium or metam potassium remain at present the best alternatives. Although promising, these alternatives will require further testing and validation on commercial fields.

There is evidence that the efficacy of metam sodium declines in areas where it is repeatedly applied due to enhanced degradation of methyl isothiocyanate, the active ingredient, by soil microbes ( Ashley et al. 1963, Ou et al. 1995, Verhagen et al. 1996, Gamliel et al. 2003).

All other available MB alternatives are currently technically infeasible for U. S. peppers.

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 IN 2003 ( HA) PROPORTION OF REQUEST FOR METHYL BROMIDE (%) Michigan 816 16 Southeastern U. S. except Georgia and Florida 5806 16 Georgia 2889 79 Florida 7893 100 California 10659 7 NATIONAL TOTAL* 24954 50 * Includes States not requesting MB. U. S. Pepper Page 14 7. ( ii) IF ONLY PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE THERE.

In Michigan, areas not treated apparently do not have any infestation ( i. e., zero oospores per unit soil) of the key fungal pests. Applicant states that soil infestation is spreading in the region annually. In California, areas where MB is not used rely on 1,3D + chloropicrin and post emergence fungicides to control the same pests.

In southeastern U. S., Florida, and Georgia, areas not treated do not have nutsedges or nematodes naturally present in pepper fields. Simple absence of all pests is the only reason these areas are not presently treated with MB.

7. ( iii) WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE THIS?

No. For further discussion of limitations please see Part 5 ( above), and the region specific discussions below.

8. AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE TABLE 8.1: AMOUNT OF METHYL BROMIDE REQUESTED FOR CRITICAL USE REGION: Michigan Southeastern U. S. except Georgia and Florida Georgia Florida California YEAR OF EXEMPTION REQUEST 2007 2007 2007 2007 2007 KILOGRAMS OF METHYL BROMIDE 15,195 240,086 347,183 1,415,207 136,078 USE: FLAT FUMIGATION OR STRIP/ BED TREATMENT Strip/ Bed Strip/ Bed Strip/ Bed Strip/ Bed Flat FORMULATION ( ratio of methyl bromide/ chloropicrin mixture) TO BE USED FOR THE CUE 67: 33 or 50: 50 67: 33 67: 33 Mostly 67: 33 67: 33 TOTAL AREA TO BE TREATED WITH THE METHYL BROMIDE OR METHYL BROMIDE/ CHLOROPICRIN FORMULATION ( ha) 127 1,599 2,312 8,417 759 DOSAGE RATE* ( g/ m2) OF ACTIVE INGREDIENT USED TO CALCULATE REQUESTED KILOGRAMS OF METHYL BROMIDE 12.0 15.0 15.0 16.8 17.9 . U. S. Pepper Page 15 9. SUMMARIZE ASSUMPTIONS USED TO CALCULATE METHYL BROMIDE QUANTITY NOMINATED FOR EACH REGION:

The amount of methyl bromide nominated by the U. S. was calculated as follows:

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

MICHIGAN  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE MICHIGAN  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST MICHIGAN  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST REGION WHERE METHYL BROMIDE USE IS REQUESTED KEY DISEASE( S) AND WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Michigan Crown and root rots caused by soilborne fungus Phytophthora capsici. Fumigation operations need to be completed by the first week of May to allow growers to plant early and capture the early market for premium prices, as well as ensuring demand for their crop during the entire growing season ( especially during the mid and late season). U. S. Pepper Page 16 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) Pepper transplants for fruit production 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) Pepper   usually followed by an eggplant or pepper crop SOIL TYPES: ( Sand, loam, clay, etc.) Sandy loam; clay loam FREQUENCY OF METHYL BROMIDE FUMIGATION: ( e. g. every two years) 1 time every 2 years OTHER RELEVANT FACTORS: Key marketing opportunities have been established with Michigan's vegetable crop diversification and aims toward stable demands in the late spring and through the summer for Midwestern markets.

MICHIGAN  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE FOR PEPPERS MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE USDA Plant Hardiness zone 5b SOIL TEMP. ( ° C) < 10 10  15 15 20 20 25 20 25 20 25 20 10 15 < 10 < 10 < 10 < 10 RAINFALL ( mm) 40 72 101 48 47 32 17 31 36 20 6 8 OUTSIDE TEMP. ( ° C) 0.2 7.4 12.1 17.5 20.6 20.9 18.1 8 2.4  2.9  8  7 FUMIGATION SCHEDULE X PLANTING SCHEDULE X KEY MARKET WINDOW X X X X U. S. Pepper Page 17 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 P. capsici via irrigation sources ( Gevens and Hausbeck 2003). Generally, there is no difference in the amount of infection depending on soil type. The pathogen is widespread and indigenous on almost all soil types in Michigan ( Cortright 2003, Gevens and Hausbeck 2003).

Significant rainfall events (> 25 mm) or cold soil temperatures (< 4.4 ° C) delay fumigation and planting with the MB alternatives 1, 3 D + chloropicrin and metam sodium. Also, 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).

MICHIGAN  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED Growers are using anti drip valves to eliminate loss of MB at the end of rows when the machinery is removed from the ground. Michigan's use of MB 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 % MB to 67 % MB). Currently, all MB is applied to tarped beds, with 100% of low density polyethylene sheeting and 95% of the acreage was treated with the 67: 33 formulation. Since 2000, about 5% of the acreage has been treated with the 50: 50 formulation of methyl bromide and chloropicrin.

Please see Table 12.1 for further information. U. S. Pepper Page 18 MICHIGAN  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE ON PEPPERS FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 96 98 117 126 135 128 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED No pepper area in Michigan uses flat fumigation application.

AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 11,482 11,747 14,001 15,618 16,230 15,391 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) A 67: 33 67: 33 67: 33 or 50: 50 67: 33 or 50: 50 67: 33 or 50: 50 67: 33 or 50: 50 METHODS BY WHICH METHYL BROMIDE APPLIED Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm Injected 20 25 cm DOSAGE RATE* ( KG/ HA) FOR THE ACTIVE INGREDIENT 12.0 12.0 12.0 or 8.9 12.0 or 8.9 12.0 or 8.9 12.0 or 8.9 A Growers have just started switching to the 50/ 50 formulation of MB/ Chloropicrin since 2000 ( about 5% of production acreage) to reduce cost per acre.

MICHIGAN   PART C: TECHNICAL VALIDATION  PEPPERS MICHIGAN  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE U. S. Pepper Page 19 MICHIGAN   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE CHEMICAL ALTERNATIVES Metam sodium or Metam potassium Pepper farmers requesting MB must plant by the first week of May to capture an early market window. Soil fumigation must therefore be completed by mid April to allow 14 21 days for aeration. However, metam labels recommend that applications be made when soil temperatures ( at application depth) are above 4.4 ° C. Since soil temperatures in Michigan do not climb over 10 ° C until after mid to late May ( Schaetzl and Tomczak, 2001), metam products cannot be used effectively for early pepper planting in Michigan. Metam products have the additional disadvantage that when the soil is wet and cold ( below 15 ° C), the minimum recommended plant back period is 30 days, which would further move the crop beyond the early market window.

In addition, control of the key pest is inconsistent ( Locascio et al. 1997, Martin 2003). Gilreath et al. ( 1994) found that metam sodium treatments did not match MB in terms of plant vigor at the end of the season; P. capsici was, however, not present. In the cool conditions of Michigan, metam sodium is likely to be slow to transform into the active ingredient ( methyl isothiocyanate), which also suggests that pest control will not be as effective as with MB ( Ashley et al. 1963). In a recent study conducted in Oceana County, Michigan by Hausbeck and Cortright ( 2004), yields from pepper plots treated with metam potassium ( K Pam) were comparable to yields from control plots and plots treated with MB + chloropicrin, indicating e a very low pest ( P. capsici) pressure at the test site. No NON CHEMICAL ALTERNATIVES Soil solarization Michigan's climate is typically cool ( often less than 11 oC through May) and cloudy, particularly early in the growing season when control of the key pests is especially important. In Michigan, the growing season is short ( May to September), and the time needed to utilize solarization is likely to render the subsequent growing of crops impossible, even if it did somehow eliminate all fungal pathogens. Since solarization has shown promise in other crops and regions ( e. g., tomatoes in Florida), the potential for adoption exists ( Schneider et al. 2003). However, because of climate, solarization is not feasible in Michigan. No Steam While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in open field pepper crops in Michigan. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize soil down to the rooting depth of field crops ( at least 20 50 cm). No U. S. Pepper Page 20 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE Biological Control Biological control agents are not technically feasible alternatives to MB because they alone cannot control the soil pathogens that afflict peppers in Michigan. The bacterium Burkholderiaia cepacia and the fungus Gliocladium virens have shown some potential in controlling some fungal plant pathogens ( Larkin and Fravel 1998). However, in a test conducted by the Michigan applicants, P. capsici was not controlled adequately in summer squash by either of these beneficial microorganisms. No Cover crops and mulching There is no evidence these practices effectively substitute for the control MB provides against P. capsici. Control of P. capsici is imperative for pepper production in Michigan. Plastic mulch is already in widespread use in Michigan vegetables, and regional crop experts state that it is not an adequate protectant when used without MB. The longevity and resistance of P. capsici oospores renders cover crops ineffective as a management alternative to MB. No Crop rotation and fallow land The crop rotations available to growers in Michigan region are also susceptible to these fungi, particularly to P. capsici. Fallow land can still harbor P. capsici oospores ( Lamour and Hausbeck 2003). Thus fungi would persist and attack peppers if crop rotation/ fallow land was the main management regime. No Endophytes Though these organisms ( bacteria and fungi that grow symbiotically or as parasites within plants) have been shown to suppress some plant pathogens in cucumber, there is no such information for the other pepper crops grown in Michigan. Furthermore, the pathogens involved did not include Phytophthora species, which are arguably the greatest single threat to Michigan peppers. No Flooding/ Water management Flooding is not technically feasible as an alternative because it does not have any suppressive effect on P. capsici ( Allen et al. 1999), and is likely to be impractical for Michigan pepper growers. It is unclear whether irrigation methods in this region could be adapted to incorporate flooding or alter water management for pepper fields. In any case, there appears to be no supporting evidence for its use against the hardy oospores of P. capsici. No Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrate s/ plug plants. Due to the paucity of scientific information on the utility of these alternatives as MB replacements in peppers, they have been grouped together for discussion in this document. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major pepper pests. Grafting and plant breeding are thus also rendered technically infeasible as MB alternatives for control of Phytophthora fungi. Soilless culture, organic production, and substrates/ plug plants are also not technically viable alternatives to MB for fungi. One of the fungal pests listed by Michigan can spread through water ( Gevens and Hausbeck 2003), making it difficult to keep any sort of area ( with or without soil) disease free. Various aspects of organic production  e. g., cover crops, fallow land, and steam sterilization  have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES U. S. Pepper Page 21 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE Metam sodium or metam potassium + Chloropicrin Pepper farmers requesting MB must plant by the first week of May to capture an early market window. Soil fumigation must therefore be completed by mid April to allow 14 21 days for aeration. However, metam labels recommend that applications be made when soil temperatures ( at application depth) are above 4.4 ° C. Since soil temperatures in Michigan do not climb over 10 ° C until after mid to late May ( Schaetzl and Tomczak, 2001), metam products cannot be used effectively for early pepper planting in Michigan. Metam products have the additional disadvantage that when the soil is wet and cold ( below 15 ° C), the minimum recommended plant back period is 30 days, which would further move the crop beyond the early market window.

In addition, trials in tomato have shown inconsistent efficacy of this formulation against fungal pests, though it is generally better than metam sodium alone ( Locascio and Dickson 1998, Csinos et al. 1999). These studies apparently did not measure yield impacts, and did not involve peppers. Hausbeck and Cortright ( 2004) evaluated several soil fumigants for control of P. capsici on several vegetable crops, including peppers, in Michigan. Results show that yields from pepper plots treated with metam potassium + chloropicrin were comparable to yields from control plots and from plots treated with MB + chloropicrin. These results point to a very low pest pressure in the study area. Further studies are necessary to clearly identify MB alternatives. No 1,3 dichloropropene + chloropicrin Regulatory restrictions and Michigan's cool and wet soils may result in a delay of up to 28 days in planting after treatment with this combination. This delay could result in growers missing key market windows, with consequent negative economic impacts ( detailed in other sections below). In a small plot study conducted in Michigan by Hausbeck and Cortright ( 2004) pepper yields from plots treated with 1,3 D + chloropicrin were comparable to yields from control plots and plots treated with MB + chloropicrin. These results seem to indicate a very low pest ( P. capsici) pressure at the test site. Further studies are necessary to clearly identify MB alternatives. No 1,3 dichloropropene + Metam sodium Trials in tomato have shown inconsistent efficacy of this combination against fungal pests, though it is generally better than metam sodium alone ( Csinos et al. 1999). Low efficacy in even small plot trials indicates that this is not a technically feasible alternative for commercially produced peppers in Michigan at this time. These studies apparently did not measure yield impacts, and did not involve peppers. No * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. U. S. Pepper Page 22 MICHIGAN  14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

Table 14.1 Technically Infeasible Alternatives Discussion.

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

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

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

Methyl iodide Not registered in the U. S. for peppers, although registration is being pursued for tomatoes, strawberries, peppers, and ornamental crops. Yes Unknown Furfural Not registered in the U. S. for peppers. Registration is currently being pursued only for non food greenhouse uses. No ( for peppers) Unknown Sodium azide Not registered. No registration requests submitted to U. S. No ( for any crop/ commodity) Unknown Propargyl bromide Not registered. No registration requests submitted to U. S. No ( for any crop/ commodity) 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 pepper farmers requesting MB must plant by the first week of May to capture an early market window. Soil fumigation must therefore be completed by mid April to allow 14 21 days for aeration. However, 1,3 D and metam labels recommend that applications be made when soil temperatures ( at application depth) are above 4.4 ° C. Furthermore, optimum soil temperatures for 1,3 D are in the 10 ° C  25 ° C range ( University of California, Davis, undated). Since soil temperatures in Michigan do not climb over 10 ° C until after mid to late May ( Schaetzl and Tomczak, 2001), neither 1,3 D nor metam products can be used effectively for early pepper planting in Michigan. Metam products have the additional disadvantage that when the soil is wet and cold ( below 15 ° C), the minimum recommended plant back period is 30 days, which would push the crop beyond the early market window. U. S. Pepper Page 23 Few studies have focused on peppers in Michigan's growing conditions. A recent study, conducted in Oceana County, Michigan by Hausbeck and Cortright ( 2004), was undertaken to evaluate soil fumigants for managing P. capsici on several solanaceous and cruciferous crops. Results, however, show that yields from pepper plots treated with metam potassium ( K Pam), alone or in combination with chloropicrin, and from plots treated with 1,3 D + chloropicrin ( Telone C35) were comparable to yields from plots treated with MB + chloropicrin and to yields from control plots. These results seem to indicate a very low pest pressure in treated and control plots. However, with the best available MB alternative, revenue losses would be possible from planting delays and missing of key market windows.

In studies with other vegetable crops, 1,3 D + chloropicrin has generally shown better control of fungi than metam sodium formulations, although still not as good as control with MB. For example, in a study using a bell pepper/ squash rotation in small plots  conducted in the much warmer conditions of Georgia and without P. capsici as a component of the pest complex  Webster et al. ( 2001) found significantly lower fungal populations with 1,3 D + 35 % chloropicrin ( drip irrigated or chisel injected, 146 kg/ ha of 1,3 D), as compared to the untreated control. However, MB ( 440 kg/ ha, shank injected) lowered fungal populations even more. Methyl iodide had no significant suppressive effect, as compared to the untreated control. In another study, conducted on tomatoes in Florida, Gilreath et al. ( 1994) found that metam sodium treatments did not match MB in terms of plant vigor at the end of the season. P. capsici was not present. U. S. Pepper Page 24 MICHIGAN   TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 dichloropropene + Chloropicrin P. capsici 0   6 % PLUS loss of revenue due to planting delays 6 % loss of revenue due to planting delays OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 6 % likely with the best alternative ( 1,3 D + chloropicrin)

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

The critical use exemption applicant states that 1,3 D + chloropicrin, metam sodium, methyl iodide, chloropicrin, and chloropicrin/ metam sodium will continue to be subjects of field studies of utilization and efficacy enhancement where P. capsici fungi are the target pests. Most of these alternatives are not currently registered for peppers, and there are presently no commercial entities pursuing registration in the United States. The regulatory restrictions on 1,3 D discussed elsewhere will adversely influences the economics of this MB alternative. The timeline for developing the above mentioned MB alternatives in Michigan is as follows: 2003   2005: Test for efficacy of identified alternatives. 2005   2007: Establish on farm demonstration plots for effective MB alternatives. 2008   2010: Work with growers to implement widespread commercial use of effective alternatives.

Research is also under way to optimize the use of a 50 % MB: 50 % chloropicrin formulation to replace the currently used 67: 33 formulation. In addition, field research is being conducted to optimize a combination of crop rotation, raised crop beds, black plastic, and foliar fungicides. Use of virtually impermeable film ( VIF) will also be investigated as a replacement for the currently used low density polyethylene ( LDPE).

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

No. Soilless systems and greenhouse production are not in use for peppers in this region, and quick adoption is probably economically infeasible. Growers apply MB on fields with a history of fungal contamination, but it appears that most growing acreage in this region has moderate to severe infestations of P. capsici and other soil borne fungi, which thrive in cool and moist climates. U. S. Pepper Page 25 MICHIGAN  SUMMARY OF TECHNICAL FEASIBILITY Based on the new trials conducted in vegetable crops in Michigan in 2003 ( described above in Section 16), EPA has determined that only 1,3 D + chloropicrin has some technical feasibility against the key pest of peppers in this region.

Available studies in vegetable crops in the U. S. indicate that 1,3 D + chloropicrin has some technical feasibility against the key pest of peppers in this region. However, no large plot studies have yet been performed to show commercial feasibility. Demonstration studies are planned ( see Section 17 above). Important regulatory constraints on 1,3 D must also be kept in mind: a 7 28 day planting delay, mandatory 30 m buffers near inhabited structures   both of which will cause negative economic impacts that make the use of these MB alternatives infeasible. There is also potentially lower dissipation ( and thus efficacy) of these compounds in the cool, wet soils of this region. These planting restrictions may thus be important factors inhibiting widespread grower adoption of this MB alternative. Potential yield losses associated with plant restrictions could be exacerbated because 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). Key marketing opportunities have been established with Michigan's vegetable crop diversification and aims toward stable demands in the late spring and through the summer for Midwestern markets.

Currently unregistered alternatives, such as furfural and sodium azide, have shown good efficacy against the key pests involved ( Cortright, personal communication). However, even if registration is pursued soon, these options would require additional research focusing on their adaptation to commercial pepper production in Michigan.

There are also no non chemical alternatives that are currently viable for MB replacement for commercial pepper growers. In sum, while the potential exists for a combination of chemical and non chemical alternatives to replace MB use in Michigan pepper, this goal appears be at least a few years away. U. S. Pepper Page 26 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ON PEPPERS SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA [ U. S. States of Alabama, Arkansas, Kentucky*, Louisiana*, North Carolina, South Carolina, Tennessee and Virginia; * States added for 2005 2007]  10. KEY DISEASES AND WEEDS FOR WHICH METHYL BROMIDE IS REQUESTED AND SPECIFIC REASONS FOR THIS REQUEST SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 10.1: KEY DISEASES AND WEEDS AND REASON FOR METHYL BROMIDE REQUEST FOR PEPPERS REGION WHERE METHYL BROMIDE USE IS REQUESTED TARGET PESTS ( WEED & PLANT PARASITIC NEMATODES) PATHOGENS, AND [% DEGREE OF INFESTATION, IF REPORTED ] SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Southeast U. S. Peppers Consortium excluding Florida and Georgia Yellow and purple nutsedge ( Cyperus esculentus, C. rotundus), [ 30%]; plant parasitic nematodes ( Meloidogyne incognita; Pratylenchus sp.); pythium root and collar rots ( P. irregulare, P. myriotylum, P. ultimum, P. aphanidermatum); crown and root rot ( Phytophthora capsici) Only MB can effectively control the target pests found in the southeastern United States where pest pressures commonly exist at moderate to severe levels. Most, if not all of these states, are limited in the use of the alternative 1,3 D because of underlying karst topography throughout the region. Halosulfuron, while effective against nutsedge, is only registered for use on row middles in peppers. Metam sodium has limited pest control capabilities and should never be used as a stand alone fumigant ( Noling, 2003). U. S. Pepper Page 27 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE FOR PEPPERS SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Pepper transplants for fruit production 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) Pepper   usually double cropped with a highvalue cucurbit crop ( muskmelon, cucumber, or squash).

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: There are two distinct pepper growing systems: 1) a spring crop ( fumigation cycle begins in January) and a fall crop ( fumigation cycle begins in May). Methyl bromide is applied 1 time per year on an individual field. Pepper does not follow pepper in this rotation; peppers are rotated with another crop, often a high value cucurbit, which also depends on MB fumigation.

SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE   JANUARY FUMIGATION ( SPRING, EARLY SUMMER HARVEST) JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC CLIMATIC ZONE U. S. Plant Hardiness Zones 6b, 7a, 7b, 8a, 8b FUMIGATION SCHEDULE X X X PLANTING SCHEDULE X X X KEY HARVEST WINDOW X X X X SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 11.3 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE   SPRING FUMIGATION ( FALL HARVEST) JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC CLIMATIC ZONE U. S. Plant Hardiness Zones 6b, 7a, 7b, 8a, 8b FUMIGATION SCHEDULE X X PLANTING SCHEDULE X X KEY HARVEST WINDOW X X X X U. S. Pepper Page 28 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Peppers are generally produced using mechanized practices that involve deep soil injection ( 20   25 cm) of methyl bromide. Weeds, especially nutsedge, are the most serious concern precipitating MB use in both transplant beds and the field. Nutsedge species grow even under adverse conditions, resist traditional and modern methods of weed control, and are endemic to large tracts of pepper producing area in the Southeastern United States. Although herbicides are applied to the row middles between raised production beds to manage grass and broadleaf weeds, there are no registered herbicides that can be used to control nutsedges on the beds. In addition to weeds, 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 broad spectrum soil fumigant.

Alternatives like 1,3 dichloropropene and metam sodium require, respectively, a 7 28 day interval and a 14 30 day interval before planting, compared to 14 days for MB. This interval may cause delays and adjustments in production schedules that could lead to missing specific market windows, thus reducing profits for pepper growers ( Kelley, 2003). U. S. Pepper Page 29 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE ON PEPPERS, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE ON PEPPERS FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) A 830 880 809 809 991 1,153 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED Not available AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED A ( total kilograms) 182,253 132,199 121,563 121,563 148,914 173,227 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) No definitive/ substantiated information available 67: 33 67: 33 67: 33 METHODS BY WHICH METHYL BROMIDE APPLIED No information available Injected 15 to 25 cm deep Injected 15 to 25 cm deep Injected 15 to 25 cm deep APPLICATION RATE ( KG/ HA) FOR THE FORMULATION No information available DOSAGE RATE* ( G/ HA) FOR THE ACTIVE INGREDIENT 22.0 15.0 15.0 1.50 15.0 15.0 A An increase in the acreage of peppers produced in the Southeastern U. S. is projected from 2003 through 2007. Although reasons vary from state to state; they include shifts in acreage from tobacco and peanut production to the production of peppers and other high value vegetable crops. This nomination package also includes two new states ( added since 2001): Kentucky and Louisiana. B Based on estimated area: 2,023 to 2,415 m2 ( Lewis, 2003, personal communication). U. S. Pepper Page 30 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  PART C: TECHNICAL VALIDATION FOR PEPPERS SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Metam Sodium Metam sodium provides limited and erratic performance at suppressing all major pepper pathogens and pests. In addition, there is a 14 30 day waiting period at the time of application until planting, compared to 14 days for MB. Such a delay could cause the higherend market windows to be missed, particularly for the spring plantings ( i. e., fall harvests). Beginning the application cycle earlier is not an option since crops from the previous fumigation cycle must be 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 and reduce efficacy as a result of increased populations of adapted microorganisms ( Dungan and Yates, 2003). No NON CHEMICAL ALTERNATIVES Soil solarization For nutsedge control in the southeastern United States, solarization is not technically feasible as a methyl bromide alternative. Response of Cyperus species to solarization is sporadic and not well understood; data show solarization to provide, at best, suppression of nutsedge populations ( Chase et al. 1999). Research indicates that the lethal temperature for nutsedge tubers is 50oC or higher. Trials conducted in mid summer in Georgia resulted in maximum soil temperatures of 43 oC at 5 cm depth ( Chase et al. 1999). Thus, solarization, even in the warmer months in southern states, did not result in temperatures high enough to destroy nutsedge tubers. Also, tubers lodged deeper in the soil would be completely unaffected. In addition, solarization would take fields out of production since it would be needed during the spring and into the summer months, which are optimal for pepper production. No Steam Steam is not a technically feasible alternative for open field pepper production because it requires sustained heat over a required period of time ( UNEP 1998). While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in open field pepper crops. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize soil down to the rooting depth of field crops ( at least 20 50 cm). No U. S. Pepper Page 31 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Biological Control Biological control agents alone cannot control nutsedge and/ or the soil pathogens that afflict peppers. The bacterium Burkholderia cepacia and the fungus Gliocladium virens have shown some potential in controlling some fungal plant pathogens ( Larkin and Fravel 1998). However, no biological control agent has been identified to effectively control nutsedge or Phytophthora. Therefore, biological control is not a stand along replacement for methyl bromide in pepper crops. Only a limited number of biological organisms are effectively used to manage soil borne diseases and pests. Biocontrol agents are usually very specific regarding the organisms they control and their successful establishment is highly dependent on environmental conditions. No Cover crops and mulching Cover crops and mulches have been integrated into solanaceous crop production systems. However there is no evidence these practices effectively substitute for the control methyl bromide provides against nutsedges ( Burgos and Talbert 1996). Some cover crops that have been shown to reduce weed populations also reduced or delayed crop maturity and/ or emergence, as well as yields ( Burgos and Talbert 1996, Galloway and Weston 1996). Mulching has also been shown to be ineffective in controlling nutsedges, which are able to penetrate through both organic and plastic mulches ( Munn 1992, Patterson 1998). No Crop rotation and fallow land Crop rotation/ fallow is not a technically feasible alternative to methyl bromide because it does not provide adequate control of nutsedges or fungal pathogens. The crop rotations available to growers are also susceptible to fungi; fallow land can still harbor fungal oospores ( Lamour and Hausbeck 2003). Tubers of the perennial nutsedges provide new plants with larger energy reserves than annual weeds that can be more easily controlled by crop rotations and fallow. ( Thullen and Keeley 1975). Furthermore, nutsedge plants can produce tubers within 2 weeks after emergence ( Wilen et al. 2003). This enhances their survival across different cropping regimes that can disrupt other plants that rely on a longer undisturbed growing period to produce seeds to propagate the next generation. No Flooding/ Water management Flooding has been used effectively to manage various soil borne pest and diseases, especially nematodes and some weeds. However, nutsedges have shown tolerance to this treatment. Submerging nutsedge tubers for 8 days to 4 weeks showed no effect on the sprouting capabilities of the tubers ( Horowitz, 1972). Studies in Florida showed ineffective nematode, disease, and nutsedge control after flooding ( Allen, 1999). Regulatory issues concerning water management, as well as economic feasibility, also preclude its viability as an alternative to methyl bromide. Land structure, frequent and severe droughts, and the economics of developing and managing flood capabilities prevent flooding from being a viable, cost effective alternative in the Southeastern United States. No U. S. Pepper Page 32 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrat es/ plug plants. Due to the paucity of scientific information on the utility of these alternatives as methyl bromide replacements in peppers, they have been grouped together for discussion in this document. The U. S. EPA was unable to locate any studies showing any potential for grafting, resistant rootstock or plant breeding as technically feasible alternatives to methyl bromide control of nutsedges. Plug plants are extensively used on high value vegetable crops like pepper but they do not control competition from nutsedges. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major pepper pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of Phytophthora and Fusarium fungi. Soilless culture, organic production, and substrates/ plug plants are also not technically viable alternatives to methyl bromide for fungi. Various aspects of organic production   e. g., cover crops, fallow land, and steam sterilization  have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Although this combination would likely be more effective than metam sodium alone where fungal pests are the only concern, it may not prevent yield losses due to nutsedges, particularly where weed pressure is high. In a study with vegetables it provided control of yellow nutsedge, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). No 1,3 dichloropropene ( Telone II) + metam sodium This combination controls nematodes but not nutsedges. In a study with vegetables, it provided control of yellow nutsedge, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). It is inconsistently effective against fungal pests ( see Michigan sections for more discussion). 1,3 D is also subject to regulatory prohibition of use on Karst geology. No 1,3 dichloropropene ( Telone II) followed by chloropicrin Culpepper and Langston ( 2004) tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. Results show that 1,3 D, followed by chloropicrin, was significantly less effective than MB for the control of both purple and yellow nutsedge, but as effective as MB for the control soil nematodes. In terms of spring and fall crop yield, however, this combination performed as well as MB. This treatment is promising and will require further testing and validation in commercial fields. No, but shows promise U. S. Pepper Page 33 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

1,3 dichloropropene + chloropicrin This combination does not adequately control nutsedge. Because of ground water contamination concerns, 1,3 D cannot be used in pepper growing areas of the U. S. where karst topography exists. Where 1,3 D use is allowed, set back restrictions (~ 100 meters from occupied structures; ~ 30 meters for emulsified formulations applied via chemigation) may limit the portion of a field that can be treated. In addition, because of a 28 day waiting period between application and planting ( compared to 14 days for MB), growers could lose half of the harvest season and miss higher end market windows, mainly for spring fumigations ( i. e., fall harvests). No 1,3 dichloropropene + chloropicrin ( Telone C35) followed by chloropicrin Culpepper and Langston ( 2004) have tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. In this study, 1,3 D + chloropicrin, followed by more chloropicrin, was more effective than MB for the control of yellow nutsedge, but less effective against purple nutsedge. This treatment performed as well as MB in terms of spring crop yield, but poorly in terms of fall yield. This combination does not appear to show promise as a MB alternative. No 1,3 dichloropropene + chloropicrin ( Telone C35) followed by metam sodium Culpepper and Langston ( 2004) have tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. In this study, 1,3 D + chloropicrin, followed by metam sodium was 36% less effective than MB for the control of purple nutsedge, but as effective as MB for the control of yellow nutsedge and soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. This combination is promising and will require further testing and validation in commercial fields. No, but shows promise Fumigant combination + herbicide partners Current research suggests that in areas of low pest pressure this combination may be suitable for some growers as an alternative for methyl bromide. In these situations growers may employ a marginal strategy without major economic dislocation if given a reasonable time frame for the transition. Yes * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. U. S. Pepper Page 34 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA 14. LIST AND DISCUSS WHY REGISTERED ( and Potential) PESTICIDES AND HERBICIDES ARE CONSIDERED NOT EFFECTIVE AS TECHNICAL ALTERNATIVES TO METHYL BROMIDE:

SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   TABLE 14.1: TECHNICALLY INFEASIBLE ALTERNATIVES DISCUSSION NAME OF ALTERNATIVE DISCUSSION Halosulfuron methyl Is a non selective herbicide. Causes potential crop injury; has plant back restrictions. Efficacy is lowered in rainy conditions ( common during the period of initial planting of these crops). Also, a 24 month plant back restriction may cause significant economic disruption if growers must rely on this option. Since halosulfuron can only be applied to the row middles, nutsedges would survive on the pepper beds, close to crop plants. Thus this herbicide is not technically feasible as a stand alone replacement for MB, and its use in conjunction with other pest management methods has not yet been investigated.

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

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

Other than those options discussed elsewhere, no alternative exists for the control of the key weeds, nematodes, and pathogens affecting pepper production. Non chemical alternatives and chemical alternatives to methyl bromide have been or are being investigated and when suitable, are incorporated into current pepper production practices.

Nutsedge management has proven to be difficult due to the perennial growth habit of nutsedge and tubers as primary means of propagation. 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.) Research suggests that metam sodium can, in some situations, provide effective pest management for certain diseases and weeds. However, even though there have been nearly 50 years experience with metam sodium, ( which breaks down to methyl isothiocyanate) nutsedge control results have been unpredictable.

Since methyl bromide has been used effectively to manage minor crop production, there are limited pesticide alternatives due primarily to the small market share and the high cost associated with pesticide registration. Labeling of these products in minor crops could be more expensive than returns from potential sales, and therefore pesticide manufacturers have been reluctant to register pesticides for minor crop uses. Methyl bromide will be needed until a cost effective alternative regimen is in place. U. S. Pepper Page 35 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   TABLE 15.1: PRESENT REGISTRATION STATUS OF ALTERNATIVES FOR PEPPERS NAME OF ALTERNATIVE PRESENT REGISTRATION STATUS REGISTRATION BEING CONSIDERED BY NATIONAL AUTHORITIES? ( Y/ N) DATE OF POSSIBLE FUTURE REGISTRATION:

Methyl iodide Not registered Yes Unknown Furfural Not registered. No Unknown Sodium azide Not registered. No registration application received. No Unknown Propargyl bromide Not registered. No registration application received. No Unknown U. S. Pepper Page 36 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND 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:

SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  TABLE 16.1. FUMIGANT ALTERNATIVES TO METHYL BROMIDE FOR POLYETHYLENE MULCHED TOMATO ( LOCASCIO ET AL. 1997)

Chemicals Rate ( kg/ 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 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.

Locascio et al. ( 1997) studied MB alternatives on tomatoes grown in small plots at two Florida locations with high nutsedge infestation. The data from this tomato study are being cited because comparable pepper data are not available. 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 considering1,3 D results, one must keep in mind that this MB alternative cannot be used in areas where karst geology exists which is approximately 40% of the Florida pepper production area. U. S. Pepper Page 37 For root knot nematodes, both metam sodium and 1,3 D + 35 % chloropicrin have shown good efficacy in trials with tomato and pepper. For example, Locascio and Dickson ( 1998) reported that metam sodium + 35 % chloropicrin ( 295 l/ ha of metam sodium, shank injected) reduced nematode galls significantly over untreated control plots, though not as much as did MB + 35 % chloropicrin treatments ( 500kg MB/ ha, shank injected), in Florida tomatoes. Analysis of 35 tomato and 5 pepper trials conducted from 1993   1995 indicated that 1,3 D ( with either 17 % or 35 % chloropicrin) provided control of nematodes that was equal or superior to that seen with MB, in 95 % of the tomato and 100 % of pepper trials ( Eger 2000). However, it is not clear whether yields were also comparable to those obtained with MB. Noling et al ( 2000) also studied the effects of metam sodium ( 115 l/ ha, syringe injected), 1,3 D + 17 % chloropicrin ( 53.6 l/ ha, soil injected), and 1,3 D + 35 % chloropicrin ( 39.8 l/ ha), among other treatments, in tomato plots. Galls inflicted by root knot nematodes were reduced significantly by all these MB alternatives, as compared to untreated control plots. Yields were also significantly higher as compared to the control plots; all MB alternatives resulted in similar high yields. However, the effects of MB formulations were not reported in this study. Further, it is the opinion of some U. S. crop experts that metam sodium, in particular, is inconsistent as a nematode control agent ( Dr. S. Culpeper, University of Georgia, personal communication).

SOUTHEAST U. S. PEPPER CONSORTIUM  TABLE C. 1: ALTERNATIVES YIELD LOSS DATA SUMMARY ALTERNATIVE LIST TYPE OF PEST RANGE OF YIELD LOSS BEST ESTIMATE OF YIELD LOSS 1,3 dichloropropene + chloropicrin Nutsedges, fungal pathogens 20  100 29%

Metam sodium ( with or without chloropicrin) Nutsedges, fungal pathogens 30  55 44%

OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 29 % if 1,3 D + pic is used; 44 % if metamsodium is used U. S. Pepper Page 38 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?:

Future plans to minimize MB use include:

1) Optimizing use of plastic ( VIF) tarps and drip irrigation equipment for applying at plant herbicides. 2) Conducting studies on tomato, pepper, and cucurbit crops with combinations of fumigants and herbicides including halosulfuron, metolachlor, rimsulfuron, and dimethenamid. Telone C 35 will be used as a fumigant because of nematode and disease problems. 3) Changing MB: chloropicrin formulations from 98: 2 to 67: 33 Trials using the alternative fumigants Telone C 35, iodomethane, metam sodium, chloropicrin, and at least two reduced risk products ( Propozone, PlantPro45, DiTera, Deny) are also planned. These trials will incorporate screening of pepper varieties for tolerance/ resistance to Phytophthora capsici. The applicant noted that a program to evaluate host resistance to Phytophthora root and crown rot has been implemented. Growers are starting to deploy lines identified with genetic resistance and acceptable horticultural qualities.

In addition, the following new long term studies have been initiated at the Coastal Plain Experiment Station in Tifton, Georgia, with funding provided by USDA CSREES, Methyl Bromide Transitions Grant:

 Evaluation of the effects of soil conditions, particularly soil temperature and moisture, on nutsedge species efficacy from several fumigants.

 Investigation of the impact of multiple season adoption of methyl bromide alternatives in terms of pest species composition, including weeds, diseases, and nematodes.

 Integration of multiple tactics as alternatives to methyl bromide for management of weeds, diseases, and nematodes in pepper and eggplant.

 Evaluation of vegetable crop response to herbicides applied under plastic prior to crop transplants and characterize herbicide fate when applied in a plasticulture system between summer and fall crops. U. S. Pepper Page 39 SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA  18. ARE THERE TECHNOLOGIES BEING USED TO PRODUCE THE CROP WHICH AVOID THE NEED FOR METHYL BROMIDE?:

No. Soilless systems and greenhouse production are not in use for peppers and quick adoption is probably economically infeasible. Grafting has not been evaluated for vegetable production due to the high cost and the large number of plants that would be needed. In addition this alternative is primarily used for nematode and disease management, but there is no evidence that it applies to competition from weeds. Plug plants are extensively used on high value vegetable crops like pepper but they do not control competition from nutsedges.

SOUTHEAST U. S. PEPPERS CONSORTIUM EXCLUDING FLORIDA AND GEORGIA   SUMMARY OF TECHNICAL FEASIBILITY There has been extensive research on alternatives for solanaceous crops, and methyl bromide minimizing practices have been incorporated into pepper production systems where possible. However, the effectiveness of chemical and non chemical alternatives designed to fully replace methyl bromide must still be characterized as preliminary. These alternatives have not been shown to be stand alone replacements for methyl bromide, and no combination has been shown to provide effective, economical pest control. Methyl bromide is believed to be the only treatment currently available that consistently provides reliable control of nutsedge species and the disease complex affecting pepper production. ( Locascio et al., 1997) Nutsedges resist traditional and modern methods of weed control and are endemic to large tracts of pepper producing area in the Southeastern United States. Herbicides are applied to the row middles between raised production beds to manage grass and broadleaf weeds, but there are no currently registered herbicides to address sedge weed pests. Nematodes, especially root knot nematodes ( Meloidogyne spp.), and fungal diseases ( such as Phytophthora blight) are also of concern. Fungal pests are expected to become serious problems for pepper production if MB were not available for pre plant fumigation.

The 1,3 dichloropropene and chloropicrin combination does not effectively control nutsedges. Lack of an effective registered herbicide for control of nutsedge impairs adoption of methyl bromide alternatives in pepper ( Banks, 2002). In addition, labeling of 1,3 dichloropropene products restricts its use in key pepper growing areas of the United States where karst topography exists due to ground water contamination concerns. In areas where 1,3 dichloropropene use is allowed, set back restrictions and 7 28 day waiting periods between application and planting cause delays/ adjustments in production schedules that could lead to missing specific market windows, thus reducing profits on pepper crops. For example, peppers produced during the winter return a higher price than peppers produced during warmer months, and many growers rely on this price premium to maintain profitability.

Metam sodium provides limited and erratic performance at suppressing all major solanaceous pathogens and pests. Data indicate that metam sodium is not an effective alternative to methyl U. S. Pepper Page 40 bromide for nutsedge control in bell pepper fields Webster et al., ( 2002). A 14 30 day planting delay is also recommended for this chemical. In addition there is evidence that both 1,3 dichloropropene and methyl isothiocyanate ( the breakdown product of metam sodium) levels decline more rapidly, thus further compromising efficacy, in areas where these are repeatedly applied ( Smelt et al. 1989, Ou et al. 1995, Gamliel et al. 2003). This is due to enhanced degradation of these chemicals by soil microbes ( Dungan and Yates 2003).

Culpepper and Langston ( 2004) recently compared the effectiveness of several soil fumigants in managing soil pests affecting peppers in Tifton, Georgia. Results show that 1,3 D followed by chloropicrin was significantly less effective than methyl bromide for the control of both purple and yellow nutsedge, but as effective as MB for the control soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. 1,3 D + chloropicrin, followed by more chloropicrin was more effective than MB for the control of yellow nutsedge, but less effective against purple nutsedge. This treatment performed as well as MB in terms of spring crop yield, but poorly in terms of fall yield. 1,3 D + chloropicrin, followed by metam sodium was 36% less effective than methyl bromide for the control of purple nutsedge, but as effective as MB for the control of yellow nutsedge. This combination was as effective as MB against soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. These treatments are showing promise and will require further testing and validation in commercial fields.

Research on the effectiveness of non chemical alternatives to methyl bromide is still in a preliminary stage, particularly for high value, minor use crops such as peppers. U. S. Pepper Page 41 GEORGIA  PART B: CROP CHARACTERISTICS AND METHYL BROMIDE USE ON PEPPERS 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 FOR PEPPERS REGION WHERE METHYL BROMIDE USE IS REQUESTED TARGET PESTS ( WEED & PLANT PARASITIC NEMATODES) PATHOGENS, AND [% DEGREE OF INFESTATION, IF REPORTED ] SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Georgia Yellow and purple nutsedge ( Cyperus esculentus, C. rotundus) [ 100%]; crown and Root rot ( Phytophthora capsici) [ 40%]; plant parasitic nematodes ( Meloidogyne incognita; Pratylenchus sp) [ 70%]; southern blight ( Sclerotium rolfsii) [ 70%]; Pythium root and collar rots ( P. irregulare, P. myriotylum, P. ultimum, P. aphanidermatum) [ 100%] Only MB can effectively control the target pests found in the southeast U. S. where pest pressures commonly exist at moderate to severe levels. Most, if not all of these states are limited in the use of the alternative 1,3 D because of underlying karst geology throughout the region. Halosulfuron, which is registered only for middle of row use, does not control nutsedge near pepper plants where most competition occurs. Metam sodium has limited pest control capabilities and should never be used as a stand alone fumigant ( Noling, 2003). Refer to Item 13 for additional detail.

GEORGIA  11. ( i) CHARACTERISTICS OF CROPPING SYSTEM AND CLIMATE FOR PEPPERS GEORGIA  TABLE 11.1: CHARACTERISTICS OF CROPPING SYSTEM CHARACTERISTICS GEORGIA CROP TYPE: ( e. g. transplants, bulbs, trees or cuttings) Pepper transplants for fruit production 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) Pepper   usually followed by a cucurbit crop ( cucumbers or squash). Occasionally eggplants follow pepper crops.

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: Actual frequency may be between 12 and 15 months depending on the number of crops grown per fumigation cycle. U. S. Pepper Page 42 GEORGIA  TABLE 11.2 CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE   JULY FUMIGATION EVENT, PEPPER CROP IS HARVESTED IN FALL. MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN FEB CLIMATIC ZONE U. S. Plant Hardiness Zones 7a, 7b, 8a, 8b SOIL TEMP. ( ° F) 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 ( inches) 5.0 3.8 3.5 4.5 5.6 4.8 3.4 2.3 2.3 4.5 4.5 4.2 AVERAGE AIR 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 X PLANTING SCHEDULE 2C P KEY HARVEST WINDOWS 2C 2C 2C P P P Methyl bromide applied in July allows the grower to economically produce at least two crops from one annual fumigation event. P = planting or harvest of pepper crop; 2C = planting and/ or harvest of 2nd crop.

GEORGIA  TABLE 11.3. CHARACTERISTICS OF CLIMATE AND CROP SCHEDULE   SPRING ( LATE FEBRUARY  MARCH) FUMIGATION EVENT, PEPPER CROP IS HARVESTED IN EARLY SUMMER FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC JAN CLIMATIC ZONE U. S. Plant Hardiness Zones 7a, 7b, 8a, 8b SOIL TEMP. ( ° C) Same as above Table 11.2 RAINFALL ( mm) Same as above Table 11.2 AIR TEMP. ( ° C) Same as above Table 11.2 FUMIGATION SCHEDULE A X PLANTING SCHEDULE A, P 2C KEY HARVEST WINDOW A, P P P 2C 2C 2C AFumigation is an early spring event. Two crops are shown as being produced from one fumigation event. P = planting and/ or harvest of pepper crop; 2C = planting and/ or harvest of second crop. U. S. Pepper Page 43 GEORGIA   11. ( ii) INDICATE IF ANY OF THE ABOVE CHARACTERISTICS IN 11. ( i) PREVENT THE UPTAKE OF ANY RELEVANT ALTERNATIVES?

Peppers are generally produced using mechanized practices that involve deep injection of methyl bromide. Methyl bromide is being requested only for moderate to severe pest infestations. Approximately 81% of the Georgia pepper area is considered to have moderate to severe infestations of nutsedge ( Culpepper, 2004).

Weeds, especially nutsedge, are the most serious concern precipitating methyl bromide use in both transplant beds and in the field. Nutsedge species grow even under adverse conditions, resist traditional and modern methods of weed control, and are endemic to large tracts of pepper producing area in the Southeastern United States. Herbicides are applied to the row middles between raised production beds to manage grass and broadleaf weeds  but there are no currently registered herbicides that control nutsedges near pepper plants. Weeds, when present in crops such as pepper, tomato, and cucurbits for 40 to 60 days may reduce yields by 10 to 50%. In addition to weeds, soil borne fungal pathogens and plant parasitic nematodes are endemic to the region and nearly all production areas have severe infestations, thus necessitating annual treatment with a broad spectrum soil fumigant.

Alternatives like 1,3 dichloropropene and metam sodium require, respectively, a 14 28 day interval and a 14 30 day interval before planting, compared to 14 days for MB. This interval can cause delays/ adjustments in production schedules that could lead to missing specific market windows, thus reducing profits on pepper crops ( Kelley, 2003). U. S. Pepper Page 44 GEORGIA  12. HISTORIC PATTERN OF USE OF METHYL BROMIDE ON PEPPERS, AND/ OR MIXTURES CONTAINING METHYL BROMIDE, FOR WHICH AN EXEMPTION IS REQUESTED GEORGIA  TABLE 12.1 HISTORIC PATTERN OF USE OF METHYL BROMIDE ON PEPPERS FOR AS MANY YEARS AS POSSIBLE AS SHOWN SPECIFY: 1998 1999 2000 2001 2002 2003 AREA TREATED ( hectares) 1,267 1,767 2,263 2,252 2,312 2,117 RATIO OF FLAT FUMIGATION METHYL BROMIDE USE TO STRIP/ BED USE IF STRIP TREATMENT IS USED All production acreage is strip/ bed fumigation and tarped with LDPE films. Approximately 58% of the field is treated with MB and covered with plastic mulch.

AMOUNT OF METHYL BROMIDE ACTIVE INGREDIENT USED ( total kilograms) 313,053 337,163 347,944 338,248 347,183 317,886 FORMULATIONS OF METHYL BROMIDE ( methyl bromide / chloropicrin) 98: 2 98: 2 ( 15% acreage) 67: 33 ( 85% Of acreage) 67: 33 67: 33 67: 33 67: 33 METHODS BY WHICH METHYL BROMIDE APPLIED 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 DOSAGE RATE*( G/ M 2) OF ACTIVE INGREDIENT 24.7 18.1 15.0 15.0 15.0 15.0 U. S. Pepper Page 45 GEORGIA  PART C: TECHNICAL VALIDATION FOR PEPPERS GEORGIA  13. REASON FOR ALTERNATIVES NOT BEING FEASIBLE GEORGIA   TABLE 13.1: REASON FOR ALTERNATIVES NOT BEING FEASIBLE NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

CHEMICAL ALTERNATIVES Metam Sodium Metam sodium provides limited and erratic performance at suppressing all nutsedge weed species and pepper pathogens. Also, there is a 14 30 day waiting period at the time of application until planting compared to 14 days for MB. Such a delay may cause the higher end market windows to be missed   particularly for the spring plantings ( i. e., fall harvests). Beginning the application cycle earlier is not an option since crops from the previous fumigation cycle must be 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 ( and reduce efficacy) as a result of increased populations of adapted microorganisms ( Dungan and Yates, 2003). No NON CHEMICAL ALTERNATIVES Soil solarization For nutsedge control in the southeastern United States, solarization is not technically feasible as a methyl bromide alternative. Response of Cyperus species to solarization is sporadic and not well understood; data show solarization to provide, at best, suppression of nutsedge populations ( Chase et al. 1999). Research indicates that the lethal temperature for nutsedge tubers is 50 oC or higher ( Chase et al. 1999). Trials conducted in mid summer in Georgia resulted in maximum soil temperatures of 43 oC at 5 cm depth. Thus, solarization, even in the warmer months in southern states, did not result in temperatures high enough to destroy nutsedge tubers. Also, tubers lodged deeper in the soil would be completely unaffected. In addition, solarization would take fields out of production since it would be needed during the spring and into the summer months, which are optimal for pepper production. No Steam Steam is not a technically feasible alternative for open field pepper production because it requires sustained heat over a required period of time ( UNEP 1998). While steam has been used effectively against fungal pests in protected production systems, such as greenhouses, there is no evidence that it would be effective in open field pepper crops. Any such system would also require large amounts of energy and water to provide sufficient steam necessary to sterilize soil down to the rooting depth of field crops ( at least 20 50 cm). No U. S. Pepper Page 46 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Biological Control Biological control agents alone cannot control nutsedge and/ or the soil pathogens that afflict peppers. The bacterium Burkholderia cepacia and the fungus Gliocladium virens have shown some potential in controlling some fungal plant pathogens ( Larkin and Fravel 1998). However, no biological control agent has been identified to effectively control nutsedge or Phytophthora. Therefore, biological control is not a stand along replacement for methyl bromide in pepper crops. Only a limited number of biological organisms are effectively used to manage soil borne plant pathogens and pests. Biocontrol agents are usually very specific regarding the organisms they control and their successful establishment is highly dependent on environmental conditions. No Cover crops and mulching Cover crops and mulches have been integrated into solanaceous crop production systems. However there is no evidence these practices effectively substitute for the control methyl bromide provides against nutsedges ( Burgos and Talbert 1996). Some cover crops that have been shown to reduce weed populations also reduced or delayed crop maturity and/ or emergence, as well as yields ( Burgos and Talbert 1996, Galloway and Weston 1996). Mulching has also been shown to be ineffective in controlling nutsedges, which are able to penetrate through both organic and plastic mulches ( Munn 1992, Patterson 1998). No Crop rotation and fallow land Crop rotation/ fallow is not a technically feasible alternative to methyl bromide because it does not provide adequate control of nutsedges or fungal pathogens. The crop rotations available to growers are also susceptible to fungi; fallow land can still harbor fungal oospores ( Lamour and Hausbeck 2003). Tubers of the perennial nutsedges provide new plants with larger energy reserves than annual weeds that can be more easily controlled by crop rotations and fallow. ( Thullen and Keeley 1975). Furthermore, nutsedge plants can produce tubers within 2 weeks after emergence ( Wilen et al. 2003). This enhances their survival across different cropping regimes that can disrupt other plants that rely on a longer undisturbed growing period to produce seeds to propagate the next generation. No Flooding/ Water management Flooding has been used effectively to manage various soil borne pest and plant pathogens, especially nematodes and some weeds. However, nutsedges have shown tolerance to this treatment. Submerging nutsedge tubers for 8 days to 4 weeks showed no effect on the sprouting capabilities of the tubers ( Horowitz, 1972). Studies in Florida showed ineffective nematode, plant pathogen, and nutsedge control after flooding ( Allen, 1999). Regulatory issues concerning water management, as well as economic feasibility, also preclude its viability as an alternative to methyl bromide. Land structure, frequent and severe droughts, and the economics of developing and managing flood capabilities prevent flooding from being a viable, cost effective alternative in the Southeastern United States. No U. S. Pepper Page 47 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

Grafting/ resistant rootstock/ plant breeding/ soilless culture/ organic production/ substrates / plug plants. Due to the paucity of scientific information on the utility of these alternatives as methyl bromide replacements in peppers, they have been grouped together for discussion in this document. The United States was unable to locate any studies showing any potential for grafting, resistant rootstock or plant breeding as technically feasible alternatives to methyl bromide control of nutsedges. Plug plants are extensively used on high value vegetable crops like pepper but they do not control competition from nutsedges. There are no studies documenting the commercial availability of resistant rootstock immune to the fungal pathogens listed as major pepper pests. Grafting and plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of Phytophthora and Fusarium fungi. Soilless culture, organic production, and substrates/ plug plants are also not technically viable alternatives to methyl bromide for fungi. Various aspects of organic production   e. g., cover crops, fallow land, and steam sterilization  have already been addressed in this document and assessed to be technically infeasible methyl bromide alternatives. No COMBINATIONS OF ALTERNATIVES Metam sodium + Chloropicrin Would possibly be more effective than metam sodium alone where fungal pests are the only concern ( see Michigan sections for more discussion), but this combination may not prevent yield losses due to nutsedges, particularly where the weed pressure is high. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). No 1,3 dichloropropene + Metam sodium Controls nematodes but not nutsedges. U. S. EPA is aware of one vegetable study that showed control of yellow nutsedge with this chemical combination, but weed pressure in that small plot test was low, according to the authors ( Csinos et al. 1999). Inconsistently effective against fungal pests ( see Michigan sections for more discussion). 1,3 D also subject to regulatory prohibition of use on Karst geology. No 1,3 dichloropropene ( Telone II) followed by chloropicrin Culpepper and Langston ( 2004) have tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. Results show that 1,3 D followed by chloropicrin was significantly less effective than MB for the control of both purple and yellow nutsedge, but as effective as MB for the control soil nematodes. In terms of spring and fall crop yield, however, this combination performed as well as MB. This treatment is promising and will require further testing and validation in commercial fields. No, but shows some promise U. S. Pepper Page 48 NAME OF ALTERNATIVE TECHNICAL AND REGULATORY* REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR AVAILABLE IS THE ALTERNATIVE CONSIDERED COST EFFECTIVE?

1,3 dichloropropene + chloropicrin This combination does not adequately control nutsedge. Due to ground water contamination concerns, 1,3 D cannot be used in pepper growing areas of the U. S. where karst topography exists. Where 1,3 dichloropropene use is allowed, set back restrictions (~ 100 meters from occupied structures; ~ 30 meters for emulsified formulations applied via chemigation) may limit the proportion of the field that can be treated. In addition, because of a 28 day waiting period between application and planting ( compared to 14 days for MB), growers could lose half of the harvest season and miss higher end market windows, mainly for spring fumigations ( i. e., fall harvests). ( SE Pepper Consortium, CUE # 03 0041). No 1,3 dichloropropene + chloropicrin ( Telone C35) followed by chloropicrin Culpepper and Langston ( 2004) have tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. In this study, 1,3 D + chloropicrin, followed by more chloropicrin was more effective than MB for the control of yellow nutsedge, but less effective against purple nutsedge. This treatment performed as well as MB in terms of spring crop yield, but poorly in terms of fall yield. This combination does not appear to show promise as a MB alternative. No 1,3 dichloropropene + chloropicrin ( Telone C35) followed by metam sodium Culpepper and Langston ( 2004) have tested the effectiveness of several soil fumigant combinations for the management of nutsedges and nematodes affecting peppers in Tifton, Georgia. In this study, 1,3 D + chloropicrin, followed by metam sodium was 36% less effective than MB for the control of purple nutsedge, but as effective as MB for the control of yellow nutsedge and soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. This combination is promising and will require further testing and validation in commercial fields. No, but shows promise Fumigant combination + herbicide partners Current research suggests that in areas of low pest pressure this combination may be suitable for some growers as an alternative for methyl bromide. In these situations growers may employ a marginal strategy without major economic dislocation if given a reasonable time frame for the transition. Yes * Regulatory reasons include local restrictions ( e. g. occupational health and safety, local environmental regulations) and lack of registration. U. S. Pepper Page 49 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 Halosulfuron methyl For nutsedges: potential crop injury; plant back restrictions. Efficacy is lowered in rainy conditions ( which are common in this region). Also, a 24 month plant back restriction may cause significant economic disruption if growers must rely on this control option.

Glyphosate For nutsedges: Non selective; will not control nutsedge in the plant rows; does not provide residual control. Repeated applications are required for control even in row middles.

Paraquat For nutsedges: Non selective; will not control nutsedge in the plant rows; does not provide residual control Other than those options discussed in Table 13.1 and elsewhere in this document, no alternative exists for the control of the key pests and fungi affecting pepper production. Non chemical alternatives and chemical alternatives to methyl bromide have been or are being investigated and when suitable, are incorporated into current pepper production practices.

Nutsedge management has proven to be difficult due to the perennial growth habit of nutsedge and tubers as primary means of propagation. 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). Research suggests that metam sodium can, in some situations, provide effective pest management for certain plant pathogens and weeds. However, even though there have been nearly 50 years experience with metam sodium, ( which breaks down to methyl isothiocyanate) nutsedge control results have been unpredictable.

Since methyl bromide has been used effectively to manage minor crop production, there are limited pesticide alternatives due primarily to the small market share and the high cost associated with pesticide registration. Labeling of these products in minor crops could be more expensive than returns from potential sales, and therefore pesticide manufacturers have been reluctant to register pesticides for minor crop uses. Methyl bromide will be needed until a cost effective alternative regimen is in place.

The applicant supplied information indicating pepper yield in fields treated with 1,3 D was 43% below MB treated fields, though these results are as yet unpublished. U. S. Pepper Page 50 GEORGIA 15. LIST PRESENT ( and Possible Future) REGISTRATION STATUS OF ANY CURRENT AND POTENTIAL ALTERNATIVES:

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

Iodomethane Not registered Yes Unknown Furfural ( Multigard

) Not registered No Unknown Sodium azide Not registered. No registration application received. No Unknown Propargyl bromide Not registered. No registration application received. No Unknown 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:

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

Chemicals Rate ( kg/ 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 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.

Locascio et al. ( 1997) studied MB alternatives on tomatoes grown in small plots at two Florida locations with high nutsedge infestation. The data from the tomato study are being cited because pepper data are not available.

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 U. S. Pepper Page 51 nematode pressure. At Gainesville there was heavy infestation of yellow and purple nutsedge and moderate infestation of root knot nematode. The treatments at both locations included MB ( 67%) + chloropicrin ( 33%) chisel injected at 390 kg/ ha; metam sodium ( chisel injected) at 300L/ ha; metam sodium drip irrigated at 300L/ ha; and 1,3 D + 17% chloropicrin chisel injected at 327L/ ha. In pairwise statistical comparisons, the yield was significantly lower in metamsodium treatments compared to MB at both sites. At Bradenton, the average yield from both metam sodium treatments was 33% of the MB yields, suggesting a 67% yield loss from not using MB. At Gainesville, the average yield of the two metam sodium treatments was 56% of the MB yield, suggesting a 44% yield loss from not using MB. The yield of the 1,3 D treatment at Gainesville was 71% of the MB standard suggesting a 29% loss by not using MB ( yield data for 1,3 D were not reported for Bradenton). { In considering 1,3 D results, one must keep in mind that this MB alternative cannot be used in areas where karst geology exists.}

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, fungal pathogens 20   100 29 Metam sodium ( with or without chloropicrin) Nutsedges, fungal pathogens 30   55 44 OVERALL LOSS ESTIMATE FOR ALL ALTERNATIVES TO PESTS 29 % if 1,3 D + pic is used; 44 % if metamsodium is used GEORGIA  17. ARE THERE ANY OTHER POTENTIAL ALTERNATIVES UNDER DEVELOPMENT WHICH ARE BEING CONSIDERED TO REPLACE METHYL BROMIDE?

There are plans to conduct studies on tomato, pepper, and cucurbit crops with combinations of fumigants and herbicides including halosulfuron, metolachlor, rimsulfuron, and dimethenamid. Telone C 35 will be used as a fumigant because of nematode and plant pathogen problems.

Trials using the alternative fumigants Telone C 35, iodomethane, metam sodium, chloropicrin, and at least two low risk products ( Propozone, PlantPro45, DiTera, Deny) are also planned. These trials will incorporate screening of pepper varieties for tolerance/ resistance to P. capsici. The applicant noted that a program to evaluate host resistance to Phytophthora root and crown rot has been implemented. Growers are starting to deploy lines identified with genetic resistance and acceptable horticultural qualities.

In addition, the following new long term studies have been initiated at the Coastal Plain Experiment Station in Tifton, Georgia, with funding provided by USDA CSREES, Methyl Bromide Transitions Grant:

 Evaluation of the effects of soil conditions, particularly soil temperature and moisture, on nutsedge species efficacy from several fumigants.

 Investigation of the impact of multiple season adoption of methyl bromide alternatives in terms of pest species composition, including weeds, diseases, and nematodes. U. S. Pepper Page 52  Integration of multiple tactics as alternatives to methyl bromide for management of weeds, diseases, and nematodes in pepper and eggplant.

Evaluation of vegetable crop response to herbicides applied under plastic prior to crop transplants and characterize herbicide fate when applied in a plasticulture system between summer and fall crops.

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

No. Soilless systems and greenhouse production are not in use for peppers and quick adoption is probably economically infeasible. Grafting has not been evaluated for vegetable production due to the high cost and the large number of plants that would be needed. In addition this alternative is primarily used for nematode and plant pathogen management, but there is no evidence that it applies to competition from weeds. Plug plants are extensively used on high value vegetable crops like pepper but they do not control competition from nutsedges.

GEORGIA  SUMMARY OF TECHNICAL FEASIBILITY There has been extensive research on alternatives for solanaceous crops, and methyl bromide minimizing practices have been incorporated into pepper production systems where possible. However, the effectiveness of chemical and non chemical alternatives designed to fully replace methyl bromide must still be characterized as preliminary. These alternatives have not been shown to be stand alone replacements for methyl bromide, and no combination has been shown to provide effective, economical pest control. Methyl bromide is believed to be the only treatment currently available that consistently provides reliable control of nutsedge species and the plant pathogen complex affecting pepper production. Nutsedges resist traditional and modern methods of weed control and are endemic to large tracts of pepper producing area in the Southeastern United States. Herbicides are applied to the row middles between raised production beds to manage grass and broadleaf weeds, but there are no currently registered herbicides to address nutsedges in the row. Nematodes, especially root knot nematodes ( Meloidogyne spp.), and fungal diseases ( such as Phytophthora blight) are also of concern. These pests are expected to become serious problems for pepper production if methyl bromide were not available for pre plant fumigation.

The 1,3 dichloropropene and chloropicrin combination does not effectively control nutsedges. Lack of an effective registered herbicide for control of nutsedge impairs adoption of methyl bromide alternatives in pepper ( Banks, 2002). In addition, labeling of 1,3 dichloropropene products restricts its use in key pepper growing areas of the U. S. where karst topography exists, due to ground water contamination concerns. In areas where 1,3 dichloropropene use is allowed, set back restrictions, and 7 28 day waiting periods between application and planting cause delays/ adjustments in production schedules that could lead to missing specific market windows, thus reducing profits on pepper crops. For example, peppers produced during the winter fetch a higher price than peppers produced during warmer months, and many growers rely on this price premium to maintain profitability. U. S. Pepper Page 53 Metam sodium provides limited and erratic performance at suppressing all major solanaceous pathogens and pests. Data indicate that metam sodium is not an effective alternative to methyl bromide for nutsedge control in bell pepper fields Webster et al., ( 2002 a). A 14 30 day planting delay is also recommended for this chemical. In addition there is evidence that both 1,3 dichloropropene and methyl isothiocyanate ( the breakdown product of metam sodium) levels decline more rapidly, thus further compromising efficacy, in areas where these are repeatedly applied ( Smelt et al. 1989, Ou et al. 1995, Gamliel et al. 2003). This is due to enhanced degradation of these chemicals by soil microbes ( Dungan and Yates 2003).

Culpepper and Langston ( 2004) recently compared the effectiveness of several soil fumigants in managing soil pests affecting peppers in Tifton, Georgia. Results show that 1,3 D followed by chloropicrin was significantly less effective than methyl bromide for the control of both purple and yellow nutsedge, but as effective as MB for the control soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. 1,3 D + chloropicrin, followed by more chloropicrin was more effective than MB for the control of yellow nutsedge, but less effective against purple nutsedge. This treatment performed as well as MB in terms of spring crop yield, but poorly in terms of fall yield. 1,3 D + chloropicrin, followed by metam sodium was 36% less effective than methyl bromide for the control of purple nutsedge, but as effective as MB for the control of yellow nutsedge. This combination was as effective as MB against soil nematodes. In terms of spring and fall crop yield, this treatment performed as well as MB. These treatments are showing promise and will require further testing and validation in commercial fields.

Research on the effectiveness of non chemical alternatives to methyl bromide is still in a preliminary stage, particularly for high value, minor use crops. U. S. Pepper Page 54 PART B: FLORIDA  CROP CHARACTERISTICS AND METHYL BROMIDE USE ON PEPPERS 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 PATHOGENS, NEMATODES AND/ OR WEED( S) TO GENUS AND, IF KNOWN, TO SPECIES LEVEL SPECIFIC REASONS WHY METHYL BROMIDE IS NEEDED Florida Weeds: yellow & purple nutsedges ( Cyperus rotundus & C. esculentus), nightshade ( Solanum spp.), white clover ( Trifollium repens), ragweed ( Ambrosia artemisifolia)

Plant diseases: phytophthora blight ( Phytophthora spp.), damping off ( Rhizoctonia solani, Pythium spp.), white mold ( Sclerotinia sclerotiorum)

Nematodes: root knot nematodes ( Meloidogyne spp.), Only MB can effectively control the target pests found in Florida, where pest pressures commonly exist at moderate to severe levels. Use of 1,3 D is restricted in key pepper growing areas of Florida underlain by karst geology and sandy ( porous) subsoils geological features that could lead to groundwater contamination. Approximately 40% of Florida's pepper production land has these soil constraints. For instance, 1,3 D is prohibited in Dade County, where 100% of the pepper growing area is affected ( U. S. EPA, 2002, Noling, 2003). Metam sodium has limited pest control capabilities and is not useful as a stand alone fumigant ( Noling, 2003). Halosulfuron, which is effective against nutsedge, is only registered for use in row middles in peppers.