Ornamentals - Summary of Technical Feasibility" \f C \l "2"

Without methyl bromide, certain growers will suffer both yield and
quality losses.  In addition growers who rotate several species of
ornamentals on a particular field, need to kill crop residue from
previous crops to eliminate contamination, as well as control other
weeds and pathogens.  Due to the diversity and complexity of the cut
flower and foliage industry, an additional 2 to 3 years are needed to
complete ongoing research into implementation of methyl bromide
alternatives.  Alternatives have not been found for all species.  Some
of the alternatives that have been found for other crops (such as 1,3-D
for Easter lilies in Oregon) may not be feasible for floriculture in
general because of high cost, difficulties with quickly treating and
replanting fields for multi-cropping, and buffer zone requirements.
Other alternatives provide inconsistent control or have restrictions
that limit their use at this time.  Growers also need time to transition
to the alternatives.

In this industry, the fumigation situation and need for methyl bromide
varies by species.  Although there are some potential alternatives,
there is not enough grower experience and research to justify to
switching to alternatives by the 2008 growing season.

Michigan Herbaceous Perennials - Part B: Crop Characteristics and Methyl
Bromide Use  TC "Michigan Herbaceous Perennials. Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"

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

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

Region where methyl bromide use is requested	Key Pests 	Specific reasons
why methyl bromide is needed

Michigan Herbaceous Perennials	Nematodes: Meloidogyne hapla,
Pratylenchus spp., Ditylenchus spp.;

Fungi: Pythium (damping-off, root rot), Fusarium (damping-off, root
rot), Phytophthora, Rhizoctonia; Weeds: Cyperus esculentus (yellow
nutsedge), Inula brittanica, Oxalis stricta, Cirsium arvense, Rorippa
sylvestris	Research for effective alternatives to MeBr is ongoing with
USDA supported research due to be analyzed and reported after 2006
studies end.  Until field-tested alternatives can be identified and
protocols developed for them, MeBr will be critical to pest management
for this industry.

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

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

Characteristics	Michigan Herbaceous Perennials

Crop Type: (e.g. transplants, bulbs, trees or cuttings)	Ornamental
herbaceous perennials (e.g., Delphinium, Hosta, Phlox)

Annual or Perennial Crop: (# of years between replanting) 	Perennial:
2-year seeded (6% of treated area) and 2-year transplants (29% of
treated area) are on a 2 year replant/fumigation cycle; 3-year
transplants (65% of treated area) are on a 3 year replant/fumigation
cycle

Typical Crop Rotation (if any) and use of methyl bromide for other crops
in the rotation: (if any)	None

Soil Types:  (Sand, loam, clay, etc.)	Various, light to heavy

Frequency of methyl bromide Fumigation:

(e.g. every two years)	Once in 2 to 3 years

Other relevant factors:	No other relevant factors identified.

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

Year 1 of two-year cycle.

Year 1	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	USDA zones 4a - 6a

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

	2-year transplants

	2-year seedlings; 3-year transplants

Planting Schedule

	2-year transplants

3-year transplants	3-year transplants

Year 2 of two-year cycle.

Year 1	Mar	Apr	May	Jun	Jul	Aug	Sept	Oct	Nov	Dec	Jan	Feb

Climatic Zone	USDA zones 4a - 6a

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

Planting Schedule

	2-year seedlings

Michigan Herbaceous Perennials - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?

Long term research results are to be compiled and analyzed in 2006-2007,
to assess the efficacy of alternatives.  In addition, the consortium is
developing timelines to determine a strategy to transition from MB.
Fumigation schedule with MeBr is based on the effectiveness in managing
the numerous pests.  With alternatives, fumigation will likely have to
be increased and timing of seedling and transplant production will be
affected.  Consequently, the ongoing research program must be completed
to address implementation of production processes with newly identified
alternatives.

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

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

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

Area Treated (hectares)	248	228	129	130	110	110

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	flat fumigation	flat fumigation	flat fumigation	flat
fumigation	flat fumigation	flat fumigation

Amount of methyl bromide active ingredient used (kg)	97,477	89,539
50,485	50,961	41,153	41,153

formulations of methyl bromide

(MB:PIC)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied 	injected	injected	injected
injected	injected	injected

Application rate [Active Ingredient] (kg/ha)	392	392	392	392	375	375

Actual dosage rate [active ingredient] (g/m2)	39.2	39.2	39.2	39.2	37.5
37.5

In 2002, 1,316.6 kg of methyl bromide applied to herbaceous perennials
in the program states (California, Florida, Michigan, Oregon,
Pennsylvania, and Texas).  In Michigan, the percent of herbaceous
perennials treated with methyl bromide was 1 percent (USDA Agricultural
Chemical Usage, 2004).

 Part C: Technical Validation  TC "Michigan Herbaceous Perennials -
Part C: Technical Validation" \f C \l "1"

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

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

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

Chemical Alternatives

1,3-Dichloropropene	1,3-D is not very efficacious on its own for weed
and disease control.  Some growers have found adequate control when
1,3-D is combined with other fumigants or herbicides.

	No.

Metam sodium	Performance with metam sodium is erratic and inconsistent,
depending on soil type, moisture content, and temperature. Many years of
research have indicated difficulty achieving consistent efficacy with
metam sodium on high value crops.  Also, pest populations tend to build
up over time with metam sodium.  Repeat use results in an increase in
the population of bio-degraders of the active ingredient.

Buffer zones make using this alternative difficult because ornamentals
are produced on small parcels of land.  This fumigant cannot be used in
urbanized areas.

	No

Dazomet	Appropriate aeration times, which are dependent on soil
temperature, are needed to avoid phytotoxicity (Semer, 1987).  In
addition, plant back restrictions may cause some growers to be able to
grow fewer crops in a year.	No.

Chloropicrin	Weed control is poorer than with methyl bromide (Ragsdale,
2004).  Nematodes and weeds are not controlled adequately. Adequate
efficacy for the pest complex cannot be achieved with lower use rates.
No.

MITC	Same issues described above for metam sodium and dazomet.	No.

Non Chemical Alternatives

Biofumigation	This is a process where mustard species (Brassica spp.)
are grown and ultimately disked into soils.  A bioactive breakdown
product of some of these species is MITC.  Biofumigation is still
largely in the experimental stages.  (Pizano, 2001).  Specific brassicas
as well as specific years yield variable amounts of activity.  While
this alternative may provide some control, the control of all target
pests is not sufficient.  Also, brassica waste must be available in huge
quantities to provide at best minor effects.  	No.

Solarization	Solarization is not feasible under Michigan field
conditions.  Not able to generate acceptable heat to allow spring
planting; most effective time for solarization is not compatible with
timing for production; uses solar radiation to heat soil under clear
plastic, and under certain conditions in some locations in the summer,
soil can be heated to as high as 60 C to a depth of 7.5 cm.  Effective
solarization would likely require several months of covered bed
treatments, to heat soil to a sufficient depth (25-30 cm) in order to
affect soil-borne pathogens.  Seeds of some weed species are resistant
even to higher temperatures obtained with solarization.  Nutsedges,
Fusarium spp., Macrophomina spp. are not controlled, or unpredictably
controlled, by solarization (Elmore et al., 1997).  Therefore, this
alternative is not considered technically feasible.  	No.

Steam	Steam can be a technically effective alternative in some cases.
Reasons cited for not using steam for this crop system are high initial
cost and high application costs limit widespread use, it is slow, best
suited to small acreages, and continuous cropping.  Some greenhouse
growers have adapted this approach already in crops where it works
better (such as Freesia).  In-field steaming is not a feasible
alternative due to lack of machinery that can deliver the steam,
differences in soil type, and environmental impact of fuel use.	No.

Biological control 	No biological controls are developed to cover all of
the pests.  Results with biological control agents may vary with field
or environmental conditions (Pizano, 2001).  Even in small containers,
biological control is not reliable for soil-borne pathogens.	No.

Crop residue compost/Crop rotation/fallow	Crop rotation/fallow does not
adequately control the target pests.  Rotation would be to other
ornamental crops.  In addition, crop rotation is not really a solution
to pest problems in floriculture because either the crop cycle is too
long (perennials) or the pests persist in the soil for a long time
(Pizano, 2001).  Rotations are generally not a true rotation in the pest
control sense.   	No.

Flooding and water management	Beds are generally designed and graded for
good drainage to prevent standing water.  Flooding could increase the
incidence of certain diseases and is also time restrictive.	No.

General IPM	Although IPM is currently practiced, this alone will not
control weed and disease pests.	No.

Grafting/resistant rootstock/plant breeding	Grafting/resistant
rootstock/plant breeding are not feasible alternatives.  None of the
herbaceous perennials grown are grafted and very few are resistant.
Given the thousands of varieties of ornamentals, plant breeding for the
variety of pests is not practical.	No.

Organic amendments/compost	Not effective alone in weed or pest
management; may be incorporated as part of an IPM program.  Does not
provide adequate weed and disease control.	No.

Physical removal/sanitation	Appropriate sanitation practices are already
used extensively.  	No.

Resistant cultivars	Given the thousands of varieties of ornamentals,
developing resistant cultivars for each variety, each with unique pest
problems, is not practical.  Choices are often market driven.	No.

Soilless culture / Substrates /plug plants	Container production may be
possible in higher value cut flower crops but it is not generally
feasible, especially for deeper rooted crops and on large acreage.  	No.

Combinations of Alternatives

1,3-Dichloropropene + chloropicrin	This combination provides poorer weed
control than methyl bromide.

	No.

Dazomet + chloropicrin	Appropriate aeration times, which are dependent
on soil temperature, are needed to avoid phytotoxicity (Semer, 1987).
In addition, plant back restrictions may cause some growers to be able
to grow fewer crops in a year.

Weed control is poorer than with methyl bromide (Ragsdale, 2004).
Nematodes and weeds are not controlled adequately. Adequate efficacy for
the pest complex cannot be achieved with lower use rates.  	No.

Metam sodium + chloropicrin	Many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops.

Good disease control can be provided by chloropicrin.  However,
chloropicrin provides poorer weed control than methyl bromide.

In general, weed and nematode control is not adequate with this
combination.  In addition, these chemicals would have to be applied
separately, requiring two applications.

	No.

Metam sodium + crop rotation	Many years of research have indicated
difficulty achieving consistent efficacy with metam sodium on high value
crops.

Rotation would be to other ornamental crops.  In addition, crop rotation
is not really a solution to pest problems in floriculture because either
the crop cycle is too long (perennials) or the pests persist in the soil
for a long time (Pizano, 2001).  ).  Rotations are generally not a true
rotation in the pest control sense.	No.

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

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

Name of Alternative	Discussion

Herbicides and fumigation with methyl bromide, 1,3-D and chloropicrin,
metam sodium and chloropicrin	Herbicides are more feasible for
perennials if they are registered.  Herbicides are often selective and
there are a limited number registered.  There are liability concerns due
to phytotoxicity concerns on ornamentals.

Sodium azide	Preliminary results in a calla trial suggest that sodium
azide may not be a feasible alternative in this crop due to reduced crop
vigor and increased mortality (Gerik, 2003).

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

Table 15.1: Present Registration Status of Alternatives  TC "Michigan
Herbaceous Perennials. Table 15.1: Present Registration Status of
Alternatives" \f F \l "1"

Name of Alternative	Present Registration Status

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

Sodium Azide	Not registered in U. S.  No registration package has been
received.	No	Unknown

Propargyl bromide	Not registered in U. S.  No registration package has
been received.	No	Unknown

Iodomethane	Not registered in U. S.	Yes	Unknown

Furfural	Not registered	Yes	Unknown

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

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

Currently, limited research is available for herbaceous perennials
because long term research with USDA is ongoing.  This research is due
to be analyzed and reported after 2006 studies end.  However, some
preliminary research is available and is described below.  For
additional studies on ornamentals, see data included for California and
Florida.  These studies are separated by location of the study, but some
of the crop species, pests, and other issues are the same.

Michigan Herbaceous Perennials – Hosta – Table 16.1: Effectiveness
of Alternatives – Inula brittannica  TC "Michigan Herbaceous
Perennials –Hosta– Table 16.1: Effectiveness of Alternatives –
Inula brittannica" \f F \l "1"

Key Pest: Inula Brittannica	Average Percent weed control and Average
Percent Crop Injury

Methyl Bromide formulations and Alternatives

	# of Reps	October 15, 2001	June 20, 2002

Percent Weed Control	Percent Crop Injury	Percent Weed Control	Percent
Crop Injury

Triclopyr + clopyralid (1.68 kg ai/ha)	n/a	100	19	89	89

Dicamba (2.24 kg ai/ha)	n/a	100	41	67	78

Clopyralid (0.28 kg ai/ha)	n/a	100	19	67	26

Clopyralid (0.56 kg ai/ha)	n/a	100	22	81	33

2,4-D + clopyralid (1.5 kg ai/ha)	n/a	100	22	78	37

2,4-D (3.36 kg ai/ha)	n/a	97	37	74	56

Triclopyr (2.24 kg ai/ha)	n/a	89	3	70	81

Glyphosate (4.48 kg ai/ha)	n/a	48	41	26	89

Diquat (1.5 kg ai/ha)	n/a	52	97	26	14

Dicamba + diflufenzopyr (0.196 kg ai/ha)	n/a	89	26	8	78

LSD

10	23	30	16

(Richardson, Zandstra, and Dudek)

These herbicides are currently not registered for control of this weed.
Some limitations to this study include no methyl bromide control
treatment and no data from an untreated control.

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

Alternative	List Type of Pest	Range of Yield Loss (compared to MB)	Best
Estimate of Yield Loss

Chloropicrin	Fungi	+3% to –13%	5% loss

Metam-sodium	Weeds	+3% to –13%	5% loss

Dazomet	Weeds	+3% to –13%	5% loss

1,3-D	Nematodes, Weeds	+3% to –13%	5% loss

Metam-sodium + chloropicrin	Weeds, Fungi	+5% to –8%	0-3% loss

1,3-D + chloropicrin	Weeds, Fungi	+5% to –8%	0-3% loss

Overall Loss Estimate for All Alternatives to Pests	3-5%

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

Research is currently being conducted to identify potential
alternatives.  Please refer to Section 16 and Section 23.

The use of 1,3-D or 1,3-D/chloropicrin under tarp combined with
post-emergence herbicides is considered a potential alternative.  Some
growers have already made the transition to 1,3-D.  However, increased
research on herbicides, including the evaluation of carryover and
phytotoxicity, is needed.  In addition, some herbicides may need
expanded labeling, which could take time.  Iodomethane is also expected
to help growers transition away from methyl bromide, although it is
unknown when registration might occur.  This region expects to have
workable alternatives by 2007 or 2008.

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

A number of technologies are currently being used in this sector,
including integrated pest management, crop rotation, fallow periods,
hand weeding, etc.  However, these practices are still not sufficient to
control the key target pests without the use of methyl bromide.

Summary of Technical Feasibility  TC "Michigan Herbaceous Perennials.
Summary of Technical Feasibility" \f C \l "2"

This nomination includes requests for MeBr only for those nurseries
where sufficient pest control can not be achieved otherwise.  While
combinations of chemicals, such as 1,3-D + chloropicrin + herbicides
appear to be effective for some growers, currently all growers can not
rely solely on alternatives.

For example, 1,3-D is an effective nematicide that may have some
efficacy against plant pathogens, but for efficacy for weed management
additional inputs will be required, such as the use of herbicides.  In
addition, these alternatives may not be economically feasible.

The industry is continuing to sponsor research on alternatives and to
test improved chemical application technologies to increase the efficacy
of some of the most viable alternatives.  MeBr is considered to be
critical in the short-term, with chemical alternatives the likely
long-term solution.  Non-chemical and biological control methodologies
are not adequate to control the key pests.  Integration of several
alternative treatments is the most likely alternative to MB.

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

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

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

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

What use/emission reduction methods are presently adopted?	Currently
some growers use HDPE tarps.	Some growers have switched from a 98% MeBr
formulation to a 67 % formulation.	Unknown.	Unknown

What further use/emission reduction steps will be taken for the methyl
bromide used for critical uses?	The U.S. anticipates that the decreasing
supply of methyl bromide will motivate growers to try high density
films.	The U.S. anticipates that the decreasing supply of methyl bromide
will motivate growers to try lowering methyl bromide dosages.	The U.S.
anticipates that the decreasing supply of methyl bromide will motivate
growers to try increasing the chloropicrin percentage.	The U.S.
anticipates that the decreasing supply of methyl bromide will motivate
growers to try less frequent applications.  However, limited grower
experience and scientific data suggest current applications are critical
for production.

Other measures (please describe)	Water seals of newer products	Unknown
Unknown	Unknown

20. If Methyl Bromide Emission Reduction Techniques Are Not Being Used

or Are Not Planned for the Circumstances of the Nomination

State Reasons  TC "20. If Methyl Bromide Emission Reduction Techniques
Are Not Being Used, or Are Not Planned for the Circumstances of the
Nomination, State Reasons" \f C \l "2"

  SEQ CHAPTER \h \r 1 In accordance with the criteria of the critical
use exemption, each party is required to describe ways in which it
strives to minimize use and emissions of methyl bromide.   The use of
methyl bromide in ornamental production in the United States is
minimized in several ways.  First, because of its toxicity, methyl
bromide has, for the last 40 years, been regulated as a restricted use
pesticide in the United States.  As a consequence, methyl bromide can
only be used by certified applicators that are trained at handling these
hazardous pesticides.  In practice, this means that methyl bromide is
applied by a limited number of very experienced applicators with the
knowledge and expertise to minimize dosage to the lowest level possible
to achieve the needed results.  In keeping with both local requirements
to avoid “drift” of methyl bromide into inhabited areas, as well as
to preserve methyl bromide and keep related emissions to the lowest
level possible, methyl bromide application is most often machine
injected into soil to specific depths.

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

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

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

Part E: Economic Assessment  TC "Part E: Economic Assessment" \f F \l
"1"    TC "Part E: Economic Assessment" \f C \l "1"

(Pull Economics from previous Forest Seedling CUNs?)

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

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

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

REGION	Alternative	Yield*	Cost in year 1 (U.S.$/ha)	Cost in year 2
(U.S.$/ha)	Cost in year 3 (U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	100	$5,421
$5,421	$5,421

	Dazomet	75	$5,421	$5,421	$5,421

	1,3-d + pic	75	$5,421	$5,421	$5,421

	Metam Sodium	80	$5,421	$5,421	$5,421

Florida Cut Flowers - Lilies	Methyl Bromide	100	$14,085	$14,085	$14,085

	Dazomet	75	$14,085	$14,085	$14,085

	1,3-d + pic	75	$14,085	$14,085	$14,085

	Metam Sodium	80	$14,085	$14,085	$14,085

Florida Cut Flowers - Caladium	Methyl Bromide	100	$7,660	$7,660	$7,660

	Dazomet	75	$7,660	$7,660	$7,660

	1,3-d + pic	75	$7,660	$7,660	$7,660

	Metam Sodium	80	$7,660	$7,660	$7,660

region h - Michigan Herbaceous Perennials	Methyl Bromide	100	 $
37,311 	 $    37,311 	 $    37,311

	Various Alternatives*	95	 $    58,414 	 $    58,414 	 $    58,414

*As percentage of typical or 3-year average yield, compared to methyl
bromide.

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

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

Year 1

Region	Alternatives

(as shown in question 21)	Gross revenue for last reported year

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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

Year 1

Region	Alternatives

(as shown in question 21)	Gross revenue for last reported year

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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

Year 3

Region	Alternatives

(as shown in question 21)	Gross revenue for last reported year

(U.S.$/ha)	Net Revenue for last reported year

(U.S.$/ha)

California Cut Flowers – Calla Lily & Bulbs	Methyl Bromide	$171,286
$22,251

	Dazomet	$128,465	($20,570)

	1,3-d + pic	$128,465	($20,570)

	Metam Sodium	$137,029	($12,006)

Florida Cut Flowers - Lilies	Methyl Bromide	$231,043	$71,537

	Dazomet	$173,283	$13,776

	1,3-d + pic	$173,283	$13,776

	Metam Sodium	$184,835	$25,328

Florida Cut Flowers - Caladium	Methyl Bromide	$27,799	$3,459

	Dazomet	$20,850	($3,490)

	1,3-d + pic	$20,850	($3,490)

	Metam Sodium	$22,239	($2,100)

region h - Michigan Herbaceous Perennials	Methyl Bromide	$  140,956	$
103,645

	Various Alternatives*	$  133,908	$      75,494

* The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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

Table E.1: California Calla Lily & Bulbs - Economic Impacts of Methyl
Bromide Alternatives  TC "Table E.1: California Calla Lily & Bulbs -
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"

California Cut Flowers –

Calla Lily & Bulbs	Methyl Bromide	Dazomet	1,3-D + Pic	Metam Sodium

Yield Loss (%) 	0	25 %	25%	20%

   Yield per Hectare 	236,630	177,473	177,473	189,304

* Price per Unit (U.S.$)	$0.72	$0.72	$0.72	$0.72

= Gross Revenue per Hectare (U.S.$)	$171,286	$128,465	$128,465	$137,029

- Operating Costs per Hectare (U.S.$)	$149,035	$149,035	$149,035
$149,035

= Net Revenue per Hectare (U.S.$)	$22,251	($20,570)	($20,570)	($12,006)

1. Loss per Hectare (U.S.$)	$0	$42,822	$42,822	$34,257

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$170	$170	$136

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	192%	192%	154%

Table E.2: Florida Cut Flowers - Lilies - Economic Impacts of Methyl
Bromide Alternatives  TC "Table E.2: Florida Cut Flowers - Lilies -
Economic Impacts of Methyl Bromide Alternatives" \f F \l "1"

Florida Cut Flowers - Lilies	Methyl Bromide	Dazomet	1,3-D + Pic	Metam
Sodium

Yield Loss (%) 	0	25 %	25%	20%

   Yield per Hectare 	30,806	23,104	23,104	24,645

* Price per Unit (U.S.$)	$7.50	$7.50	$7.50	$7.50

= Gross Revenue per Hectare (U.S.$)	$231,043	$173,283	$173,283	$184835

- Operating Costs per Hectare (U.S.$)	$159,506	$159,506	$159,506
$159,506

= Net Revenue per Hectare (U.S.$)	$71,537	$13,776	$13,776	$25,328

1. Loss per Hectare (U.S.$)	$0	$57,761	$57,761	$46,209

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$131	$131	$105

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	81%	81%	65%

Table E.3: Florida - Caladium - Economic Impacts of Methyl Bromide
Alternatives  TC " Table E.3: Florida - Caladium - Economic Impacts of
Methyl Bromide Alternatives" \f F \l "1"

Florida - Caladium	Methyl Bromide	Dazomet	1,3-D + Pic	Metam Sodium

Yield Loss (%) 	0	25 %	25 %	25 %

   Yield per Hectare 	111,197	83,398	83,398	88,958

* Price per Unit (U.S.$)	$0.25	$0.25	$0.25	$0.25

= Gross Revenue per Hectare (U.S.$)	$27,799	$20,850	$20,850	$22,239

- Operating Costs per Hectare (U.S.$)	$24,340	$24,340	$24,340	$24,340

= Net Revenue per Hectare (U.S.$)	$3,459	($3,490)	($3,490)	($2,100)

1. Loss per Hectare (U.S.$)	$0	$6,950	$6,950	$5,560

2. Loss per Kilogram of Methyl Bromide (U.S.$)	$0	$23	$23	$19

3. Loss as a Percentage of Gross Revenue (%)	0%	25%	25%	20%

4. Loss as a Percentage of Net Revenue (%)	0%	201%	201%	161%

Table E.4: Economic Impacts of Methyl Bromide Alternatives  TC "Region H
- Michigan Herbaceous Perennials - Table E.4: Economic Impacts of Methyl
Bromide Alternatives" \f F \l "1"

Michigan Herbaceous Perennials	Methyl Bromide	Various Alternatives**

Yield Loss (%) 	0%	5%

   Yield per Hectare Conifer Seedlings	144,920	137,674

* Price per Unit (U.S. $/seedling)	 $        0.97 	 $         0.97

= Gross Revenue per Proportion  (60%)	 $   140,956 	 $   133,908

-  Operating Cost per Hectare (U.S. $)	 $     37,311 	 $     58,414

= Net Revenue per Hectare (U.S. $)	 $   103,645 	 $     75,494

Loss Measures

1. Loss per Hectare (U.S. $)	$0	 $     28,151

2. Loss per Kilogram of Methyl Bromide (U.S. $)	$0	 $     143.52

3. Loss as a Percentage of Gross Revenue (%)	0%	21%

4. Loss as a Percentage of Net Revenue (%)	0%	37%

** The category Various Alternatives includes physical removal and
sanitation, the use of artificial media, and soil treatment with 1,3-D
+chloropicrin.

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

The economic analysis evaluated methyl bromide alternative control
scenarios for cut flower production for Florida, California, and
Michigan by comparing the economic outcomes of methyl bromide oriented
production systems to those using alternatives.  However, due to the
fact that there are over 100 species of ornamentals grown in all regions
of the country, the data from these xamples are used to derive a proxy
estimate for the entire industry.

The economic factors that most influence the feasibility of methyl
bromide alternatives for fresh cut flower production are: (1) yield
losses, referring to reductions in the quantity produced, (2) increased
production costs, which may be due to the higher-cost of using an
alternative, additional pest control requirements, and/or resulting
shifts in other production or harvesting practices, and (3) missed
market windows due to plant back time restrictions, which also affect
the quantity and price received for the goods.

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

(1) Loss per Hectare.  For crops, this measure is closely tied to
income.  It is relatively easy to measure, but may be difficult to
interpret in isolation.

(2) Loss per Kilogram of Methyl Bromide.  This measure indicates the
nominal marginal value of methyl bromide to crop production.

(3) Loss as a Percentage of Gross Revenue.  This measure has the
advantage that gross revenues are usually easy to measure, at least over
some unit, e.g., a hectare of land or a storage operation.  However,
high value commodities or crops may provide high revenues but may also
entail high costs.  Losses of even a small percentage of gross revenues
could have important impacts on the profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue.  We define net cash
revenues as gross revenues minus operating costs.  This is a very good
indicator as to the direct losses of income that may be suffered by the
owners or operators of an enterprise.  However, operating costs can
often be difficult to measure and verify.

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

These measures represent different ways to assess the economic
feasibility of methyl bromide alternatives for methyl bromide users, who
are producers in this case.  Because producers (suppliers) represent an
integral part of any definition of a market, we interpret the threshold
of significant market disruption to be met if there is a significant
impact on commodity suppliers using methyl bromide.  The economic
measures provide the basis for making that determination.

Several methodological approaches will help interpret the findings.
Economic estimates were first calculated in pounds and acres and then
converted to kilograms and hectares.  Costs for alternatives are based
on market prices for the control products multiplied by the number of
pounds of active ingredient that would be applied.  Baseline costs were
based on the average number of annual applications necessary to treat
cut flowers with methyl bromide.

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

Loss per hectare measures the value of methyl bromide based on changes
in operating costs and/or changes in yield.  Loss expressed as a
percentage of the gross revenue is based on the ratio of the revenue
loss to the gross revenue.  Likewise for the loss as a percentage of net
revenue.  The profit margin percentage is the ratio of net revenue to
gross revenue per hectare.   The values to estimate gross revenue and
the operating costs for each alternative were derived for three
alternative control scenarios for Florida and California, relative to
methyl bromide: 1) Dazomet; 2) 1,3-d + chloropicrin; and 3) metam
sodium.  Yield loss estimates were based on data from the CUE’s and
U.S. EPA data, as well as expert opinion.

Regulatory constraints.

In California, 1,3-d plus chloropicrin would also be the primary
replacement for methyl bromide.  California restricts total use of
1,3-d, at the local level (township cap).  In Florida, the use of 1,3-d
also requires a 100-foot buffer around inhabited structures.  This would
reduce the production acreage an estimated 10%.  Nematodes and weeds and
pathogens are key pests in Florida and California bulb grower and are
controlled with methyl bromide.  Chloropicrin is not as effective in
controlling weeds as methyl bromide.  Using chloropicrin adds to
production costs through increased chemical, weeding and labor costs.

Tables E.1 - E.4 provides a summary of the estimated economic losses.  A
measure of net revenue loss may not be completely accurate partly
because some nurseries are publicly owned and seedling prices or
production costs are subsidized.  The range of losses in the studies is
rather large because both dazomet and metam-sodium provide inconsistent
pest control.  Indirect losses arising from shifts in the production
cycle were not quantified.  Changes in production costs arise due to
differences between the costs of methyl bromide and the alternatives,
shifts in the production cycle (increasing the frequency of fumigation
or lengthening the fallow period) and additional expenses such as
supplementary irrigation.  These costs vary across regions

Michigan Herbaceous Perennials

Michigan herbaceous perennials, labeled Region H above, comprise three
categories of production systems with numerous plant varieties grown
within each category.  These categories are 2-year seeded (6% of
plants), 2-year transplanted (29% of plants), and 3-year transplanted
(65% of plants).  To represent growing conditions on a typical hectare
of production, and to account for the fact that each category has
different revenues and costs of production, the above measures were
calculated using representative revenues and costs for each category;
these were weighted by the proportion of total production.  In addition,
various combinations of alternative pest control measures would need to
be employed to accomplish the most effective and lowest cost pest
control without MB.  These various alternative pest control measures
include physical removal and sanitation, the use of artificial media,
and soil treatment with 1,3-D +chloropicrin.

Note: Market price data was not available for the United States cut
flower industry but it is assumed that the net effect of shifting from
methyl bromide to any of the alternatives other than metam sodium would
result in additional revenue reductions due to fluctuations in market
price due to changes in production and harvesting times.

It should be noted that the applicants do not consider any alternative
to be feasible and that these estimates are an attempt to measure
potential impacts.

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

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

Between 1992 and 2003, the California Cut Flower Commission has spent
$260,000 in research related to methyl bromide alternatives in addition
to hundreds of thousands of dollars spent by individual growers trying
to find workable alternatives.  In 2004, $90,000 was spent on research
and $100,000 was spent in 2005.  One researcher was recently warded
$322,000 to continue research on methyl bromide alternatives in the
California ornamentals industry.  Future research will focus on the
following pests:  weeds, Fusarium oxysporum, Pythium spp., Meloidogyne
spp., and previous crop debris, such as bulblets, cormlets, etc. from
crops such as callas, caladiums, and gladiolus.  1,3-D, metam sodium,
dazomet, chloropicrin, sodium azide, and iodomethane have already been
tested.  Future research will focus on iodomethane, combinations of
1,3-D, metam sodium, and chloropicrin.

In Florida, research trials for 2003 are in place for caladiums in muck,
aster, and snapdragons, and caladiums in sand are planned for 2004.
Several alternatives will be tested, including metam sodium,
1,3-D/chloropicrin, iodomethane/chloropicrin, and sodium azide.
Research, including projects on Celosia and DMDS, is ongoing.

The Michigan Field Grown Herbaceous Perennial Growers Association is
currently assisting in field trials with Michigan State University in
research supported in part by the USDA MeBr Alternatives Grant Program.
For 2002-2004, $68,979 has been allocated and $370,701 has been granted
for a study that runs from 2003-2006.  This work is a large investment
in identifying alternatives for Michigan growers.

The Agricultural Research Service (United States Department of
Agriculture) has two full time employees (since 2000) working on methyl
bromide alternatives for flowers and ornamentals.  This represents about
a $600,000 annual investment.  In addition, a recent grant and other
money, about $100,000 has provided two CCC grants for flower
alternatives.

The amount of methyl bromide requested for research purposes is
considered critical for the development of effective alternatives.
Without methyl bromide for use as a standard treatment, the research
studies can never address the comparative performance of alternatives.
This would be a serious impediment to the development of alternative
strategies.  The U.S. government estimates that ornamentals research
will require ??? kg per year of methyl bromide for 2008?.  This amount
of methyl bromide is necessary to conduct research on alternatives and
is in addition to the amounts requested in the submitted CUE
applications.  One example of the research is a five year field study
testing the comparative performance of methyl bromide, 1,3-D, metam
sodium, and new reduced risk chemicals for control of soilborne pests
with emphasis on nematodes and weeds.

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

See Section 23 above.

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

The MeBr critical use exemption nomination for Ornamentals Seedlings has
been reviewed by the U. S. Environmental Protection Agency and the U. S.
Department of Agriculture and meets the guidelines of The Montreal
Protocol on Substances That Deplete the Ozone Layer.  This nomination
includes requests for MeBr only for those ornamental operations where
sufficient pest control can not be achieved otherwise.

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

2002 Census of Agriculture, State and County Profiles.  Web address:
HYPERLINK "http://www.nass.usda.gov/fl/rtoc0ho.htm"
http://www.nass.usda.gov/fl/rtoc0ho.htm

Ajwa, H.  Preliminary Weeding Data from Ajwa MBr Alts Experiment at
Silverlake Ranch in

Soledad CA. see CUE-0018 request California Floriculture 2005 submission

Ajwa, H. and Elmore, C.  2005.  Methyl Bromide Alternatives Research and
Education for 	California Cut Flowers.  Annual Report – California Cut
Flower Commission.  see CUE-	0018 request California Floriculture 2005
submission

Charron, C. S. and Sams, C. E.  Macerated Brassica leaves suppress
Pythium ultimum and Rhizoctonia solani mycelial growth.  see CUE-0066
request Michigan Field Grown Herbaceous Perennial Growers consortium in
2003 submission.

Church, G. T. and Rosskopf, E. N., Evaluation of DMDS for Production of
Ornamental Cockscomb (Celosia argentea), USDA, ARS, U.S. Horticultural
Research Laboratory, Fort Pierce, FL.

Elmore, C. L., Stapleton, J. J., Bell, C. E., DeVay, J. E. 1997.  Soil
Solarization.  Univ. California, Div. Agriculture and Natural Resources,
Publ. 21377.  Oakland, CA. pp. 13.

Elmore, C., J. MacDonald, H. Ferris, I. Zasada, S. Tsjvold, K. Robb, C.
Wilen, L. Bolkin, L. Yahaba, J. Roncoroni, 2003a, Alternatives to Methyl
Bromide for Control of Weeds, Nematodes, and Soil-Borne Fungi, Bacteria
in Coastal Ornamental Crops – Draft.

Elmore, C., J. Roncoroni, K. Robb, C. Wilen, and H. Ajwa, 2003b,
Preplant Pest Production in Ranunculus Production, Proceeding from the
2003 Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions, Web address:  www.mbao.org

Foliage, Floriculture, and Cut Greens.  May 2003.  Florida Agricultural
Statistics Service.  Web address:  http://www.nass.usda.gov/fl

Foliage, Floriculture, and Cut Greens.  July 2004.  Florida Agricultural
Statistics Service.  Web address:  http://www.nass.usda.gov/fl

Gerik, J., 2003, Evaluation of Alternatives to Methyl Bromide for
Floriculture Crop – Progress Report submitted by USDA-ARS.

Gerik, J., 2004.Final report submitted by USDA-ARS for cooperative
agreement number 58-5302-3-104.

Gerik, J. S. 2005a, Evaluation of Soil Fumigants Applied by Drip
Irrigation for Liatris Production, Plant Dis. 89: 883-887.

Gerik, J., 2005b.Evaluation of Alternatives to Methyl Bromide for
Floriculture Crops.  CCFC Agreement No. 58-5302-4-455.

Gilreath, J.P., R. McSorley, and R.J. McGovern, 1999, Soil Fumigant and
Herbicide Combinations for Soilborne Pest Control in Caladium, Proc Fla
State Hort Soc 112: 285-290.

Gilreath, J., 2004, University of Florida – IFAS, Personal
communication.

McSorley, R. and K.-H. Wang., 2003, Fumigant Alternatives to Methyl
Bromide for Managing Nematodes and Weeds in Snapdragon, Proc Fla State
Hort Soc.

McSorley, R. and K.-H. Wang, 2004, Impact of Soilborne Pest Problems on
Field-Grown Snapdragons, Proc Fla State Hort Soc.

Mellano, M, Mellano and Company, 2003, Personal communication.

Overman, A.J. and B. K. Harbaugh, 1983, Soil Fumigation Increases
Caladium Tuber Production on Sandy Soil, Proc Fla State Hort Soc 96:
248-250.

Pizano, M., 2001, Floriculture and the Environment:  Growing Flowers
without Methyl Bromide, United Nations Environment Programme.

Prince & Prince, Inc. Survey, 2003.  Conducted for California Cut Flower
Commission.

Ragsdale, N., USDA-ARS National Program Staff, 2004, Personal
communication.

Richardson, R., B. Zandstra, and T. Dudek.  Evaluation of Herbicidal
Controls for Inula brittannica. ee CUE-0066 request Michigan Field Grown
Herbaceous Perennial Growers consortium in 2004 submission

Rosskopf, E. N., W. Basinger, Screening Reduced Risk Compounds for
Fungicidal and Herbicidal Activity.  USDA, ARS, Fort Pierce, FL and Ajay
North America, LLC, Powder Springs, GA.

Rosskopf, E., C. Yandoc, J. Albano, and E. Lamb, Report for IR-4
Advanced Stage Biopesticide Program 2002-03, United States Horticultural
Research Laboratory, USDA, ARS, Fort Pierce, FL and Indian River
Research and Education Center, University of Florida, Fort Pierce, FL.

Schneider, S., E. Rosskopf, J. Leesch, D. Chellemi, C. Bull, and M.
Mazzola, 2003, United States Department of Agriculture – Agricultural
Research Service Research on Alternatives to Methyl Bromide: Pre-plant
and Post-harvest, Pest Manag Sci 59: 814-826.

Semer, C. R. IV, 1987, Basamid and Methyl Bromide Compounds as Fumigants
in Carnation and Chrysanthemum Production in Selected Propagation Media,
Proc Fla State Hort Soc 100: 330-334.

Trout, T., 2001, Impact of Township Caps on Telone Use in California.

Trout, T., 2003, Impact of Township Caps on Telone Use in California,
Proc. Annual International Research Conference on MB Alternatives and
Emission Reductions, p. 109.

USDA Agricultural Chemical Usage, Nursery and Floriculture, 2004, Web
address:    HYPERLINK
"http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcn0904.pdf
"
http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcn0904.pdf

USDA ERS, 1999, Table 30—Cut gladioli: Growers, production, and value
of sales, major States, 1991-98,   Web address:    HYPERLINK
"http://usda2.mannlib.cornell.edu/data-sets/specialty/99003/"
http://usda2.mannlib.cornell.edu/data-sets/specialty/99003/

APPENDIX A.  2008 Methyl Bromide Usage Numerical Index (BUNI).  TC
"APPENDIX A.  2008 Methyl Bromide Usage Numerical Index (BUNI)" \f C \l
"1"

Footnotes for Appendix A:

		Values may not sum exactly due to rounding.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Appendix B – Key Pests of Select Cut Flower Species  TC "Appendix B
– Key Pests of Select Cut Flower Species" \f C \l "1"

The following list is not comprehensive, but is intended to demonstrate
the complexity of the industry. In addition to the diseases and
nematodes listed below, there are numerous weed species that are major
problems in cut flower production.  These species include the bulbs,
tubers, or cormlets from a previous crop, yellow nutsedge (Cyperus
esculentus), little mallow (Malva parviflora), and common sow thistle
(Sonchus oleracea).

 Diseases and Nematodes of cut flower crops currently controlled with
Methyl Bromide.

Crop	Key Pests	Scientific name

Antirrhinum	Nematodes

	 Belanolaimus longidorus, Criconomella spp., Dolichodorus
heterocephalus

	Pythium root rot	Pythium irregulare (documented resistance to mefenoxam
is 25-50%)

Calla lily	Erwinia soft rot	Erwinia carotovora

	Pythium root rot	Pythium spp. (resistance to mefenoxam suspected to be
widespread

Delphinium	Sclerotinia stem rot	Sclerotinia spp.

Dianthus	Fusarium wilt	Fusarium oxysporum fsp. dianthii

Eustoma	Fusarium wilt, root rot, and stem rot	Fusarium oxysporum, F.
solani, and F. avenaceaum

Freesia	Fusarium wilt	Fusarium spp.

Gladiolus	Fusarium wilt	Fusarium oxysporum fsp. gladioli

	Stromatinia neck rot	Stromatinia gladioli

Helianthus	Downy mildew	Plasmopara halstedii (this is a soil-borne
pathogen)

Hypericum 	Root knot nematode	Meloidogyne spp.

	Pythium root rot	Pythium spp.

Iris	Fusarium wilt	Fusarium oxysporum fsp. iridis

Larkspur	Sclerotinia stem rot	Sclerotinia sclerotiorum

Liatris spicata	Sclerotinia stem rot	Sclerotinia sclerotiorum

Lilium	Pythium root rot	Pythium spp.

Matthiola	Sclerotinia stem rot	Sclerotinia sclerotiorum

	Xanthomonas leaf spot	Xanthomonas campestris pv. campestris

Ranunculus	Pythium root rot	Pythium spp.

	Xanthomonas leaf spot	Xanthomonas campestris

 PAGE

U.S. Ornamentals

 PAGE   vi

Page  PAGE   51

U.S. Ornamentals

Page  PAGE   71

Page  PAGE   75


[Federal Register Volume 80, Number 194 (Wednesday, October 7, 2015)]
[Notices]
[Pages 60668-60669]
[FR Doc No: 2015-25528]

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ENVIRONMENTAL PROTECTION AGENCY

[FRL-9926-03-OEI]

Cross-Media Electronic Reporting: Authorized Program Revision
Approval, Commonwealth of Virginia

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: This notice announces EPA's approval of the Commonwealth of

Virginia's request to revise/modify its EPA Administered Permit
Programs: The National Pollutant Discharge Elimination System EPA-
authorized program to allow electronic reporting.

DATES: EPA's approval is effective October 7, 2015.

FOR FURTHER INFORMATION CONTACT:  Karen Seeh, U.S. Environmental
Protection Agency, Office of Environmental Information, Mail Stop
2823T, 1200 Pennsylvania Avenue NW., Washington, DC 20460, (202) 566-
1175<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION: On October 13, 2005, the final Cross-Media
Electronic Reporting Rule (CROMERR) was published in the Federal
Register (70 FR 59848) and codified as part 3 of title 40 of the CFR.
CROMERR establishes electronic reporting as an acceptable regulatory
alternative to paper reporting and establishes requirements to assure
that electronic documents are as legally dependable as their paper
counterparts. Subpart D of CROMERR requires that state, tribal or local
government agencies that receive, or wish to begin receiving,
electronic reports under their EPA-authorized programs must apply to
EPA for a revision or modification of those programs and obtain EPA
approval. Subpart D provides standards for such approvals based on
consideration of the electronic document receiving systems that the
state, tribe, or local government will use to implement the electronic
reporting. Additionally, Sec.  3.1000(b) through (e) of 40 CFR part 3,
subpart D provides special procedures for program revisions and
modifications to allow electronic reporting, to be used at the option
of the state, tribe or local government in place of procedures
available under existing program-specific authorization regulations. An
application submitted under the subpart D procedures must show that the
state, tribe or local government has sufficient legal authority to
implement the electronic reporting components of the programs covered
by the application and will use electronic document receiving systems
that meet the applicable subpart D requirements.
    On January 13, 2010, the Virginia Department of Environmental
Quality (VA DEQ) submitted an application titled ``Electronic
Environmental Data Exchange Reporting System'' for revision/
modification to its EPA-approved stormwater program under title 40 CFR
to allow new electronic reporting. EPA reviewed VA DEQ's request to
revise/modify its EPA-authorized Part 123--EPA Administered Permit
Programs: The National Pollutant Discharge Elimination System program
and, based on this review, EPA determined that the application met the
standards for approval of authorized program revision/modification set
out in 40 CFR part 3, subpart D. In accordance with 40 CFR 3.1000(d),
this notice of EPA's decision to approve Virginia's request to revise/
modify its Part 123--EPA Administered Permit Programs: The National
Pollutant Discharge Elimination System program to allow electronic
reporting under 40 CFR part 122 is being published in the Federal
Register.
    VA DEQ was notified of EPA's determination to approve its
application with respect to the authorized program listed above.

Matthew Leopard,
Director, Office of Information Collection.
[FR Doc. 2015-25528 Filed 10-6-15; 8:45 am]
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[Federal Register Volume 84, Number 108 (Wednesday, June 5, 2019)]
[Notices]
[Pages 26157-26159]
[FR Doc No: 2019-11740]

=======================================================================
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DEPARTMENT OF LABOR

Occupational Safety and Health Administration

[Docket No. OSHA-2007-0042]

TUV Rheinland of North America, Inc.: Application for Expansion
of Recognition

AGENCY: Occupational Safety and Health Administration (OSHA), Labor.

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: In this notice, OSHA announces the application of TUV
Rheinland of North America, Inc., for expansion of the scope of
recognition as a Nationally Recognized Testing Laboratory (NRTL) and
presents the agency's preliminary finding to grant the application.

DATES: Submit comments, information, and documents in response to this
notice, or requests for an extension of time to make a submission, on
or before June 20, 2019.

ADDRESSES: Submit comments by any of the following methods:
    Electronically: You may submit comments and attachments
electronically at: https://www.regulations.gov, which is the Federal
eRulemaking Portal. Follow the instructions online for submitting
comments.
    Facsimile: If your comments, including attachments, are not longer
than 10 pages, you may fax them to the OSHA Docket Office at (202) 693-
1648.
    Mail, hand delivery, express mail, messenger, or courier service:
When using this method, you must submit a copy of your comments and
attachments to the OSHA Docket Office, Docket No. OSHA-2007-0042,
Occupational Safety and Health Administration, U.S. Department of
Labor, Room N-3653, 200 Constitution Avenue NW, Washington, DC 20210.
Deliveries (hand, express mail, messenger, and courier service) are
accepted during the Docket Office's normal business hours, 10:00 a.m.
to 3:00 p.m., ET.
    Instructions: All submissions must include the agency name and OSHA
docket number (OSHA-2007-0042). OSHA places comments and other
materials, including any personal information, in the public docket
without revision, and these materials will be available online at
http://www.regulations.gov. Therefore, the agency cautions commenters
about submitting statements they do not want made available to the
public, or submitting comments that contain personal information
(either about

themselves or others) such as Social Security Numbers, birth dates, and
medical data.
    Docket: To read or download comments or other material in the
docket, go to https://www.regulations.gov or the OSHA Docket Office at
the above address. All documents in the docket (including this Federal
Register notice) are listed in the https://www.regulations.gov index;
however, some information (e.g., copyrighted material) is not publicly
available to read or download through the website. All submissions,
including copyrighted material, are available for inspection at the
OSHA Docket Office.
    Extension of comment period: Submit requests for an extension of
the comment period on or before June 20, 2019 to the Office of
Technical Programs and Coordination Activities, Directorate of
Technical Support and Emergency Management, Occupational Safety and
Health Administration, U.S. Department of Labor, 200 Constitution
Avenue NW, Room N-3653, Washington, DC 20210, or by fax to (202) 693-
1644.

FOR FURTHER INFORMATION CONTACT: Information regarding this notice is
available from the following sources:
    Press inquiries: Contact Mr. Frank Meilinger, Director, OSHA Office
of Communications, U.S. Department of Labor, telephone:<PHONE_NUMBER>;
email<EMAIL_ADDRESS>    General and technical information: Contact Mr. Kevin Robinson,
Director, Office of Technical Programs and Coordination Activities,
Directorate of Technical Support and Emergency Management, Occupational
Safety and Health Administration, U.S. Department of Labor, phone:
(202) 693-2110 or email<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

I. Notice of the Application for Expansion

    OSHA is providing notice that TUV Rheinland of North America, Inc.
(TUVRNA), is applying for expansion of the current recognition as a
NRTL. TUVRNA requests the addition of three (3) test standards to the
NRTL scope of recognition.
    OSHA recognition of a NRTL signifies that the organization meets
the requirements specified in 29 CFR 1910.7. Recognition is an
acknowledgment that the organization can perform independent safety
testing and certification of the specific products covered within its
scope of recognition. Each NRTL's scope of recognition includes (1) the
type of products the NRTL may test, with each type specified by the
applicable test standard and (2) the recognized site(s) that has/have
the technical capability to perform the product-testing and product-
certification activities for test standards within the NRTL's scope.
Recognition is not a delegation or grant of government authority;
however, recognition enables employers to use products approved by the
NRTL to meet OSHA standards that require product testing and
certification.
    The agency processes applications by a NRTL for initial recognition
and for an expansion or renewal of this recognition, following
requirements in Appendix A to 29 CFR 1910.7. This appendix requires
that the agency publish two notices in the Federal Register in
processing an application. In the first notice, OSHA announces the
application and provides its preliminary finding. In the second notice,
the agency provides the final decision on the application. These
notices set forth the NRTL's scope of recognition or modifications of
that scope. OSHA maintains an informational web page for each NRTL,
including TUVRNA, which details the NRTL's scope of recognition. These
pages are available from the OSHA website at http://www.osha.gov/dts/otpca/nrtl/index.html.
    TUVRNA currently has five facilities (sites) recognized by OSHA for
product testing and certification, with headquarters located at: TUV
Rheinland of North America, Inc., 12 Commerce Road, Newtown,
Connecticut 06470. A complete list of TUVRNA sites recognized by OSHA
is available at https://www.osha.gov/dts/otpca/nrtl/tuv.html.

II. General Background on the Application

    TUVRNA submitted an application, dated August 7, 2018 (OSHA-2007-
0042-0033), to expand recognition to include the addition of three test
standards. OSHA staff performed a detailed analysis of the application
packet and reviewed other pertinent information. OSHA did not perform
any on-site reviews in relation to these applications.
    Table 1 lists the appropriate test standards found in TUVRNA's
application for expansion for testing and certification of products
under the NRTL Program.

  Table 1--Proposed List of Appropriate Test Standards for Inclusion in
                   TUVRNA's NRTL Scope of Recognition
------------------------------------------------------------------------
         Test standard                     Test standard title
------------------------------------------------------------------------
UL 61010-2-010................  Safety Requirements for Electrical
                                 Equipment for Measurement, Control and
                                 Laboratory Use--Part 2-010: Particular
                                 Requirements for Laboratory Equipment
                                 for the Heating of Materials.
UL 61010-2-020................  Standard for Safety Requirements for
                                 Electrical Equipment for Measurement,
                                 Control and Laboratory Use--Part 2-020:
                                 Particular Requirements for Laboratory
                                 Centrifuges.
UL 61010-2-101................  Safety Requirement for Electrical
                                 Equipment for Measurement, Control and
                                 Laboratory Use--Part 2-101: Particular
                                 Requirements for In Vitro Diagnostic
                                 (IVD) Medical Equipment.
------------------------------------------------------------------------

III. Preliminary Finding on the Application

    TUVRNA submitted an acceptable application for expansion of the
scope of recognition. OSHA's review of the application files indicate
that TUVRNA can meet the requirements prescribed by 29 CFR 1910.7 for
expanding recognition to include the addition of these three test
standards for NRTL testing and certification. This preliminary finding
does not constitute an interim or temporary approval of TUVRNA's
application.
    OSHA welcomes public comment as to whether TUVRNA meets the
requirements of 29 CFR 1910.7 for expansion of recognition as a NRTL.
Comments should consist of pertinent written documents and exhibits.
Commenters needing more time to comment must submit a request in
writing, stating the reasons for the request by the due date for
comments. OSHA will limit any extension to 10 days unless the requester
justifies a longer time period. OSHA may deny a request for an
extension if it is not adequately justified. To obtain or review copies
of the exhibits identified in this notice, as well as comments
submitted to the docket, contact the Docket Office, Occupational Safety
and Health Administration, U.S. Department of Labor, listed in
ADDRESSES. These

materials also are available online at https://www.regulations.gov
under Docket No. OSHA-2007-0042.
    OSHA staff will review all comments to the docket submitted in a
timely manner. After addressing the issues raised by these comments,
staff will make a recommendation to the Assistant Secretary of Labor
for Occupational Safety and Health on whether to grant TUVRNA's
application for expansion of its scope of recognition. The Assistant
Secretary will make the final decision on granting the application. In
making this decision, the Assistant Secretary may undertake other
proceedings prescribed in Appendix A to 29 CFR 1910.7.
    OSHA will publish a public notice of this final decision in the
Federal Register.

Authority and Signature

    Loren Sweatt, Acting Assistant Secretary of Labor for Occupational
Safety and Health, authorized the preparation of this notice.
Accordingly, the agency is issuing this notice pursuant to 29 U.S.C.
657(g)(2), Secretary of Labor's Order No. 1-2012 (77 FR 3912, Jan. 25,
2012), and 29 CFR 1910.7.

    Signed at Washington, DC, on May 30, 2019.
Loren Sweatt,
Acting Assistant Secretary of Labor for Occupational Safety and Health.
[FR Doc. 2019-11740 Filed 6-4-19; 8:45 am]
 BILLING CODE 4510-26-P