Methyl Bromide Critical Use Nomination for Preplant Soil Use

For Forest Seedlings

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 Forest Seedlings (Submitted in 2006
for 2008 Use Season)

Nominating Party Contact Details

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

Title:	International Affairs Officer

Address:	Office of Environmental Policy

	U. S. Department of State

	2201 C Street N.W. Room 4325

	Washington, DC 20520

	U. S. A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail:	  HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>

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

( Yes                                  ( No

Signature

Name

Date

Title:

Contact or Expert(s) for Further Technical Details

Contact/Expert Person:	Richard Keigwin

Title:	Acting Director

Address:	Biological and Economic Analysis Division

	Office of Pesticide Programs

	U. S. Environmental Protection Agency

	Mail Code 7503C

	Washington, DC 20460

	U. S. A.

Telephone:<PHONE_NUMBER>

Fax:<PHONE_NUMBER>

E-mail<EMAIL_ADDRESS>

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

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

Paper Documents:

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

electronic copies of all paper documents:

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

Table of Contents

  TOC \f \h \z    HYPERLINK \l "_Toc125862830"  Part A: Summary
PAGEREF _Toc125862830 \h  9

  HYPERLINK \l "_Toc125862831"  1. Nominating Party	  PAGEREF
_Toc125862831 \h  9

  HYPERLINK \l "_Toc125862832"  2. Descriptive Title of Nomination
PAGEREF _Toc125862832 \h  9

  HYPERLINK \l "_Toc125862833"  3. Crop and Summary of Crop System
PAGEREF _Toc125862833 \h  9

  HYPERLINK \l "_Toc125862834"  4. Methyl Bromide Nominated	  PAGEREF
_Toc125862834 \h  10

  HYPERLINK \l "_Toc125862835"  5. Brief Summary of the Need for Methyl
Bromide as a Critical Use	  PAGEREF _Toc125862835 \h  10

  HYPERLINK \l "_Toc125862836"  6. Summarize Why Key Alternatives Are
Not Feasible	  PAGEREF _Toc125862836 \h  11

  HYPERLINK \l "_Toc125862837"  7. Proportion of Crops Grown Using
Methyl Bromide	  PAGEREF _Toc125862837 \h  12

  HYPERLINK \l "_Toc125862838"  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.	  PAGEREF _Toc125862838 \h  12

  HYPERLINK \l "_Toc125862839"  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?	  PAGEREF _Toc125862839 \h  12

  HYPERLINK \l "_Toc125862840"  8. Amount of Methyl Bromide Requested
for Critical Use	  PAGEREF _Toc125862840 \h  13

  HYPERLINK \l "_Toc125862841"  9. Summarize Assumptions Used to
Calculate Methyl Bromide Quantity Nominated for Each Region	  PAGEREF
_Toc125862841 \h  15

  HYPERLINK \l "_Toc125862842"  Region A – Southern Forest Nursery
Management Cooperative - Part B: Crop Characteristics and Methyl Bromide
Use	  PAGEREF _Toc125862842 \h  16

  HYPERLINK \l "_Toc125862843"  Region A. Southern Forest Nursery
Management Cooperative. 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request	  PAGEREF
_Toc125862843 \h  16

  HYPERLINK \l "_Toc125862844"  Region A – Southern Forest Nursery
Management Cooperative - 11. (i) Characteristics of Cropping System and
Climate	  PAGEREF _Toc125862844 \h  17

  HYPERLINK \l "_Toc125862845"  Region A – Southern Forest Nursery
Management Cooperative - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862845 \h  17

  HYPERLINK \l "_Toc125862846"  Region A – Southern Forest Nursery
Management Cooperative - 12. Historic Pattern of Use of Methyl Bromide,
and/or Mixtures Containing Methyl Bromide, for which an Exemption Is
Requested	  PAGEREF _Toc125862846 \h  18

  HYPERLINK \l "_Toc125862847"  Region B - International Paper - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862847 \h
19

  HYPERLINK \l "_Toc125862848"  Region B. International Paper. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862848 \h  19

  HYPERLINK \l "_Toc125862849"  Region B. International Paper. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862849
\h  19

  HYPERLINK \l "_Toc125862850"  Region B - International Paper - 11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862850 \h  20

  HYPERLINK \l "_Toc125862851"  Region B. International Paper. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862851 \h  21

  HYPERLINK \l "_Toc125862852"  Region C. Illinois Department of Natural
Resources. Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125862852 \h  22

  HYPERLINK \l "_Toc125862853"  Region C. Illinois Department of Natural
Resources. 10. Key Diseases and Weeds for which Methyl Bromide Is
Requested and Specific Reasons for this Request	  PAGEREF _Toc125862853
\h  22

  HYPERLINK \l "_Toc125862854"  Region C. Illinois Department of Natural
Resources. 11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125862854 \h  22

  HYPERLINK \l "_Toc125862855"  Region C - Illinois Department of
Natural Resources - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862855 \h  23

  HYPERLINK \l "_Toc125862856"  Region C. Illinois Department of Natural
Resources. 12. Historic Pattern of Use of Methyl Bromide, and/or
Mixtures Containing Methyl Bromide, for which an Exemption Is Requested
 PAGEREF _Toc125862856 \h  23

  HYPERLINK \l "_Toc125862857"  Region D. Weyerhaeuser-South. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862857 \h
24

  HYPERLINK \l "_Toc125862858"  Region D. Weyerhaeuser-South. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862858 \h  24

  HYPERLINK \l "_Toc125862859"  Region D. Weyerhaeuser-South. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862859
\h  24

  HYPERLINK \l "_Toc125862860"  Region D - Weyerhaeuser-South - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862860 \h  25

  HYPERLINK \l "_Toc125862861"  Region D. Weyerhaeuser-South. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862861 \h  25

  HYPERLINK \l "_Toc125862862"  Region E. Weyerhaeuser-West. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862862 \h
26

  HYPERLINK \l "_Toc125862863"  Region E. Weyerhaeuser-West. 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request	  PAGEREF _Toc125862863 \h  26

  HYPERLINK \l "_Toc125862864"  Region E. Weyerhaeuser-West. 11.
Characteristics of Cropping System and Climate	  PAGEREF _Toc125862864
\h  26

  HYPERLINK \l "_Toc125862865"  Region E - Weyerhaeuser-West - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?	  PAGEREF _Toc125862865 \h  27

  HYPERLINK \l "_Toc125862866"  Region E. Weyerhaeuser-West. 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862866 \h  27

  HYPERLINK \l "_Toc125862867"  Region F. Weyerhaeuser-South. Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862867 \h
28

  HYPERLINK \l "_Toc125862868"  Region F. Northeastern Forest and
Conservation Nursery Association. 10. Key Diseases and Weeds for which
Methyl Bromide Is Requested and Specific Reasons for this Request
PAGEREF _Toc125862868 \h  28

  HYPERLINK \l "_Toc125862869"  Region F. Northeastern Forest and
Conservation Nursery Association. 11. Characteristics of Cropping System
and Climate	  PAGEREF _Toc125862869 \h  28

  HYPERLINK \l "_Toc125862870"  Region F - Northeastern Forest &
Conservation Nursery Association - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?	  PAGEREF _Toc125862870 \h  29

  HYPERLINK \l "_Toc125862871"  Region F. Northeastern Forest and
Conservation Nursery Association. 12. Historic Pattern of Use of Methyl
Bromide, and/or Mixtures Containing Methyl Bromide, for which an
Exemption Is Requested	  PAGEREF _Toc125862871 \h  29

  HYPERLINK \l "_Toc125862872"  Region G. Michigan Seedling Association.
Part B: Crop Characteristics and Methyl Bromide Use	  PAGEREF
_Toc125862872 \h  30

  HYPERLINK \l "_Toc125862873"  Region G. Michigan Seedling Association.
10. Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request	  PAGEREF _Toc125862873 \h  30

  HYPERLINK \l "_Toc125862874"  Region G. Michigan Seedling Association.
11. Characteristics of Cropping System and Climate	  PAGEREF
_Toc125862874 \h  31

  HYPERLINK \l "_Toc125862875"  Region G - Michigan Seedling Association
- 11. (ii) Indicate if any of the above characteristics in 11. (i)
prevent the uptake of any relevant alternatives?	  PAGEREF _Toc125862875
\h  32

  HYPERLINK \l "_Toc125862876"  Region G. Michigan Seedling Association.
12. Historic Pattern of Use of Methyl Bromide, and/or Mixtures
Containing Methyl Bromide, for which an Exemption Is Requested	  PAGEREF
_Toc125862876 \h  32

  HYPERLINK \l "_Toc125862877"  Regions A-G. Forest Seedlings. Part C:
Technical Validation	  PAGEREF _Toc125862877 \h  33

  HYPERLINK \l "_Toc125862878"  Regions A-G. Forest Seedlings. 13.
Reason for Alternatives Not Being Feasible	  PAGEREF _Toc125862878 \h
33

  HYPERLINK \l "_Toc125862879"  Regions A-G. Forest Seedlings. 14. List
and Discuss Why Registered (and Potential) Pesticides and Herbicides Are
Considered Not Effective as Technical Alternatives to Methyl Bromide:
PAGEREF _Toc125862879 \h  37

  HYPERLINK \l "_Toc125862880"  Regions A-G. Forest Seedlings. 15. List
Present (and Possible Future) Registration Status of Any Current and
Potential Alternatives	  PAGEREF _Toc125862880 \h  37

  HYPERLINK \l "_Toc125862881"  Regions A-G. Forest Seedlings.16. State
Relative Effectiveness of Relevant Alternatives Compared to Methyl
Bromide for the Specific Key Target Pests and Weeds for which It Is
Being Requested	  PAGEREF _Toc125862881 \h  38

  HYPERLINK \l "_Toc125862882"  Regions A-G. Forest Seedlings. 17. Are
There Any Other Potential Alternatives Under Development which Are Being
Considered to Replace Methyl Bromide?	  PAGEREF _Toc125862882 \h  43

  HYPERLINK \l "_Toc125862883"  Regions A-G. Forest Seedlings. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?	  PAGEREF _Toc125862883 \h  45

  HYPERLINK \l "_Toc125862884"  Regions A-G. Forest Seedlings. Summary
of Technical Feasibility	  PAGEREF _Toc125862884 \h  46

  HYPERLINK \l "_Toc125862885"  Part D: Emission Control	  PAGEREF
_Toc125862885 \h  48

  HYPERLINK \l "_Toc125862886"  19. Techniques That Have and Will Be
Used to Minimize Methyl Bromide Use and Emissions in the Particular Use
 PAGEREF _Toc125862886 \h  48

  HYPERLINK \l "_Toc125862887"  20. If Methyl Bromide Emission Reduction
Techniques Are Not Being Used, or Are Not Planned for the Circumstances
of the Nomination, State Reasons	  PAGEREF _Toc125862887 \h  50

  HYPERLINK \l "_Toc125862888"  Part E: Economic Assessment	  PAGEREF
_Toc125862888 \h  51

  HYPERLINK \l "_Toc125862889"  21. Costs of Alternatives Compared to
Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125862889 \h  51

  HYPERLINK \l "_Toc125862890"  22. Gross and Net Revenue	  PAGEREF
_Toc125862890 \h  52

  HYPERLINK \l "_Toc125862891"  Measures of Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125862891 \h  53

  HYPERLINK \l "_Toc125862892"  Summary of Economic Feasibility
PAGEREF _Toc125862892 \h  58

  HYPERLINK \l "_Toc125862893"  Part F. Future Plans	  PAGEREF
_Toc125862893 \h  60

  HYPERLINK \l "_Toc125862894"  23. What Actions Will Be Taken to
Rapidly Develop and Deploy Alternatives for This Crop?	  PAGEREF
_Toc125862894 \h  60

  HYPERLINK \l "_Toc125862895"  24. How Do You Plan to Minimize the Use
of Methyl Bromide for the Critical Use in the Future?	  PAGEREF
_Toc125862895 \h  61

  HYPERLINK \l "_Toc125862896"  25. Additional Comments on the
Nomination	  PAGEREF _Toc125862896 \h  61

  HYPERLINK \l "_Toc125862897"  26. Citations	  PAGEREF _Toc125862897 \h
 62

  HYPERLINK \l "_Toc125862898"  APPENDIX B.  Estimated Costs Of
Converting A Loblolly Forest Tree Seedling Nursery From Soil-Based To
Containerized Soilless Culture1	  PAGEREF _Toc125862898 \h  67

List of Tables

  TOC \f F \h \z \c "Table"    HYPERLINK \l "_Toc125862900"  Part A:
Summary	  PAGEREF _Toc125862900 \h  9

  HYPERLINK \l "_Toc125862901"  Table 4.1: Methyl Bromide Nominated
PAGEREF _Toc125862901 \h  10

  HYPERLINK \l "_Toc125862902"  Table A.1: Executive Summary	  PAGEREF
_Toc125862902 \h  11

  HYPERLINK \l "_Toc125862903"  Table 7.1: Proportion of Crops Grown
Using Methyl Bromide	  PAGEREF _Toc125862903 \h  12

  HYPERLINK \l "_Toc125862904"  Table 8.1. Region A - Southern Forest
Nursery Management Cooperative:  Amount of Methyl Bromide Requested for
Critical Use	  PAGEREF _Toc125862904 \h  13

  HYPERLINK \l "_Toc125862905"  Table 8.2. Region B - International
Paper: Amount of Methyl Bromide Requested for Critical Use	  PAGEREF
_Toc125862905 \h  13

  HYPERLINK \l "_Toc125862906"  Table 8.3. Region C - Illinois
Department of Natural Resources:  Amount of Methyl Bromide Requested for
Critical Use	  PAGEREF _Toc125862906 \h  14

  HYPERLINK \l "_Toc125862907"  Table 8.4. Region D -
Weyerhaeuser-South:  Amount of Methyl Bromide Requested for Critical Use
  PAGEREF _Toc125862907 \h  14

  HYPERLINK \l "_Toc125862908"  Table 8.5. Region E - Weyerhaeuser-West:
 Amount of Methyl Bromide Requested for Critical Use	  PAGEREF
_Toc125862908 \h  14

  HYPERLINK \l "_Toc125862909"  Table 8.6. Region F - Northeastern
Forest and Conservation Nursery Association:  Amount of Methyl Bromide
Requested for Critical Use	  PAGEREF _Toc125862909 \h  15

  HYPERLINK \l "_Toc125862910"  Table 8.7. Region G - Michigan Seedling
Association:  Amount of Methyl Bromide Requested for Critical Use
PAGEREF _Toc125862910 \h  15

  HYPERLINK \l "_Toc125862911"  Region A – Southern Forest Nursery
Management Cooperative - Part B: Crop Characteristics and Methyl Bromide
Use	  PAGEREF _Toc125862911 \h  16

  HYPERLINK \l "_Toc125862912"  Region A – Southern Forest Nursery
Management Cooperative - Table 10.1: Key Diseases and Weeds and Reason
for Methyl Bromide Request	  PAGEREF _Toc125862912 \h  16

  HYPERLINK \l "_Toc125862913"  Region A – Southern Forest Nursery
Management Cooperative - Table 11.1: Characteristics of Cropping System
 PAGEREF _Toc125862913 \h  17

  HYPERLINK \l "_Toc125862914"  Region A – Southern Forest Nursery
Management Cooperative - Table 11.2 Characteristics of Climate and Crop
Schedule	  PAGEREF _Toc125862914 \h  17

  HYPERLINK \l "_Toc125862915"  Region A – Southern Forest Nursery
Management Cooperative - Table 12.1 Historic Pattern of Use of Methyl
Bromide	  PAGEREF _Toc125862915 \h  18

  HYPERLINK \l "_Toc125862916"  Region B - International Paper - Part B:
Crop Characteristics and Methyl Bromide Use	  PAGEREF _Toc125862916 \h
19

  HYPERLINK \l "_Toc125862917"  Region B. International Paper. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
PAGEREF _Toc125862917 \h  19

  HYPERLINK \l "_Toc125862918"  Region B. International Paper. Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125862918 \h  19

  HYPERLINK \l "_Toc125862919"  Region B. International Paper. Table
11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125862919 \h  20

  HYPERLINK \l "_Toc125862920"  Region B. International Paper. Table
12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862920
\h  21

  HYPERLINK \l "_Toc125862921"  Region C. Illinois Department of Natural
Resources. Table 10.1: Key Diseases and Weeds and Reason for Methyl
Bromide Request	  PAGEREF _Toc125862921 \h  22

  HYPERLINK \l "_Toc125862922"  Region C. Illinois Department of Natural
Resources. Table 11.1: Characteristics of Cropping System	  PAGEREF
_Toc125862922 \h  22

  HYPERLINK \l "_Toc125862923"  Region C. Illinois Department of Natural
Resources. Table 11.2 Characteristics of Climate and Crop Schedule
PAGEREF _Toc125862923 \h  22

  HYPERLINK \l "_Toc125862924"  Region C. Illinois Department of Natural
Resources. Table 12.1 Historic Pattern of Use of Methyl Bromide
PAGEREF _Toc125862924 \h  23

  HYPERLINK \l "_Toc125862925"  Region D. Weyerhaeuser-South. Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
PAGEREF _Toc125862925 \h  24

  HYPERLINK \l "_Toc125862926"  Region D. Weyerhaeuser-South. Table
11.1: Characteristics of Cropping System	  PAGEREF _Toc125862926 \h  24

  HYPERLINK \l "_Toc125862927"  Region D. Weyerhaeuser-South. Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125862927 \h
24

  HYPERLINK \l "_Toc125862928"  Region D. Weyerhaeuser-South. Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862928 \h  25

  HYPERLINK \l "_Toc125862929"  Region E. Weyerhaeuser-West. Table 10.1:
Key Diseases and Weeds and Reason for Methyl Bromide Request	  PAGEREF
_Toc125862929 \h  26

  HYPERLINK \l "_Toc125862930"  Region E. Weyerhaeuser-West. Table 11.1:
Characteristics of Cropping System	  PAGEREF _Toc125862930 \h  26

  HYPERLINK \l "_Toc125862931"  Region E. Weyerhaeuser-West. Table 11.2
Characteristics of Climate and Crop Schedule	  PAGEREF _Toc125862931 \h
26

  HYPERLINK \l "_Toc125862932"  Region E. Weyerhaeuser-West. Table 12.1
Historic Pattern of Use of Methyl Bromide	  PAGEREF _Toc125862932 \h  27

  HYPERLINK \l "_Toc125862933"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request	  PAGEREF _Toc125862933 \h  28

  HYPERLINK \l "_Toc125862934"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 11.1: Characteristics of
Cropping System	  PAGEREF _Toc125862934 \h  28

  HYPERLINK \l "_Toc125862935"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 11.2 Characteristics of Climate
and Crop Schedule	  PAGEREF _Toc125862935 \h  28

  HYPERLINK \l "_Toc125862936"  Region F. Northeastern Forest and
Conservation Nursery Association. Table 12.1 Historic Pattern of Use of
Methyl Bromide	  PAGEREF _Toc125862936 \h  30

  HYPERLINK \l "_Toc125862937"  Region G. Michigan Seedling Association.
Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
  PAGEREF _Toc125862937 \h  30

  HYPERLINK \l "_Toc125862938"  Region G. Michigan Seedling Association.
Table 11.1: Characteristics of Cropping System	  PAGEREF _Toc125862938
\h  31

  HYPERLINK \l "_Toc125862939"  Region G. Michigan Seedling Association.
Table 11.2 Characteristics of Climate and Crop Schedule	  PAGEREF
_Toc125862939 \h  31

  HYPERLINK \l "_Toc125862940"  Region G. Michigan Seedling Association.
Table 12.1 Historic Pattern of Use of Methyl Bromide	  PAGEREF
_Toc125862940 \h  32

  HYPERLINK \l "_Toc125862941"  Regions A-G. Table 13.1: Reason for
Alternatives Not Being Feasible	  PAGEREF _Toc125862941 \h  33

  HYPERLINK \l "_Toc125862942"  Regions A-G. Forest Seedlings. Table
14.1: Technically Infeasible Alternatives Discussion	  PAGEREF
_Toc125862942 \h  37

  HYPERLINK \l "_Toc125862943"  Regions A-G. Forest Seedlings. Table
15.1: Present Registration Status of Alternatives	  PAGEREF
_Toc125862943 \h  37

  HYPERLINK \l "_Toc125862944"  Regions A-G. Forest Seedlings. Table
16.1.A: Effectiveness of Alternatives–Weeds	  PAGEREF _Toc125862944 \h
 38

  HYPERLINK \l "_Toc125862945"  Regions A-G. Forest Seedlings. Table
C.1: Alternatives Yield Loss Data Summary	  PAGEREF _Toc125862945 \h  43

  HYPERLINK \l "_Toc125862946"  Part D: Emission Control	  PAGEREF
_Toc125862946 \h  48

  HYPERLINK \l "_Toc125862947"  Table 19.1: Techniques to Minimize
Methyl Bromide Use and Emissions	  PAGEREF _Toc125862947 \h  49

  HYPERLINK \l "_Toc125862948"  Part E: Economic Assessment	  PAGEREF
_Toc125862948 \h  51

  HYPERLINK \l "_Toc125862949"  Table 21.1: Costs of Alternatives
Compared to Methyl Bromide Over 3-Year Period	  PAGEREF _Toc125862949 \h
 51

  HYPERLINK \l "_Toc125862950"  Table 22.1: Year 1 Gross and Net Revenue
  PAGEREF _Toc125862950 \h  52

  HYPERLINK \l "_Toc125862951"  Region A - Table E.1: Economic Impacts
of Methyl Bromide Alternatives	  PAGEREF _Toc125862951 \h  53

  HYPERLINK \l "_Toc125862952"  Region B - International Paper - Table
E.2: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862952 \h  54

  HYPERLINK \l "_Toc125862953"  Region C - Illinois Department of
Natural Resources - Table E.3: Economic Impacts of Methyl Bromide
Alternatives	  PAGEREF _Toc125862953 \h  55

  HYPERLINK \l "_Toc125862954"  Region d - Weyerhaeuser South - Table
E.4: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862954 \h  56

  HYPERLINK \l "_Toc125862955"  Region E - Weyerhaeuser West - Table
E.5: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862955 \h  56

  HYPERLINK \l "_Toc125862956"  Region F - Northeastern Forest &
Conservation Nursery Association - Table E.6: Economic Impacts of Methyl
Bromide Alternatives	  PAGEREF _Toc125862956 \h  57

  HYPERLINK \l "_Toc125862957"  Region G - Michigan Seedling Association
- Table E.7: Economic Impacts of Methyl Bromide Alternatives	  PAGEREF
_Toc125862957 \h  58

  HYPERLINK \l "_Toc125862958"  Part F. Future Plans	  PAGEREF
_Toc125862958 \h  60

  HYPERLINK \l "_Toc125862959"  APPENDIX A.  2008 Methyl Bromide Usage
Newer Numerical Index (BUNNI).	  PAGEREF _Toc125862959 \h  66

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

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

The United States of America (U.S.)

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

Methyl Bromide (MB) Critical Use Nomination for Preplant Soil Use for
Forest Seedlings (Submitted in 2006 for 2008 Use Season)

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

Forest seedling nurseries in the U.S. supply conifer and hardwood
seedlings that are used for reforestation, forest establishment, fiber
production, and wildlife and conservation uses.  In a survey conducted
in 2001-2002 (Southern Forest Nursery Management Cooperative, Appendix 1
of their request), there were approximately 1.7 billion pine seedlings
produced in the southern region of the U.S., which accounted for 80% of
U. S. pine seedling production.  Nurseries in the U.S. are located in
eight climate zones (Zones 3 to 10) and have mostly light or medium
soils.  The majority of seedlings are species of conifers, especially
pine.  In addition, 30-60 species of hardwoods, such as oaks, hickory,
poplars, and ash, are produced.  Nurseries produce seedlings adapted to
their respective regional conditions, with variables such as climate and
soil type.  Forest seedling nurseries requesting critical use of MB
include both public and private nursery operations.

Nurseries of this sector produce mostly conifer seedlings, which are
typically grown for one or two years in seedling beds.  After harvest,
beds have one or two years of fallow or cover crops.  Managers typically
fumigate a particular conifer seedling bed with MB once every 3-4 years,
i.e., one-quarter to one-third of the total nursery land is fumigated
each year to produce two or three harvestable forest seedling crops per
single bed fumigation.  Effective fumigants, such as MB, permit less
frequent bed fumigation per harvestable seedling crop.  For hardwood
seedlings, fumigation is usually provided prior to each seedling crop,
as hardwood species are generally more prone to root rots and
damping-off diseases than conifers, although the production volume of
hardwoods is smaller than overall conifer production.

At the appropriate stage of maturity, forest seedlings are harvested in
the nursery, packaged, and transported to the planting site.  Seedlings
are usually culled or sized during the harvesting process, with culled
trees discarded.  Nurseries that grade their seedlings may sell lower
grade seedlings at a reduced price, or discard all but the highest grade
seedlings.  The impact of seedling quality, particularly seedling size,
on the success of plantation establishment cannot be overstated.  The
production of large and healthy planting stock is essential to the
economic viability of reforestation processes.  These typically include
soil preparation at the planting site, transportation to the planting
site, planting, and weed control after planting.  The quality of
seedlings is highly correlated with the success of the regeneration
process and corresponding long-term economic and use benefits, where
seedling quality results in greater survival rates and faster growth.
Maintaining pest-free nursery soils is the backbone of an integrated
pest management approach to producing healthy seedlings and the
foundation for establishing economically viable forests.

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

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

Year

	Nomination Amount (kg)	Nomination Area (ha)

2008	133,140	527

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

The U.S. nomination is for those areas where the alternatives are not
effective against key pests when pressure is moderate to high.  The use
of MB is considered critical where alternatives are not suitable because
of regulatory, economic, or technical constraints.  Although alternative
treatments can be foreseen as long-term solutions to MB use, transition
from MB will depend on the development of application technologies to
better deliver these alternatives to soils containing target pests.  In
addition, because of MB efficacy, two or three seedling crops can be
grown with each MB application—generally applied once in three or four
years.  Alternative treatments are likely to be a combination of
treatments, both chemical and non-chemical, which may involve increased
costs and environmental pesticide burdens.

Forest nurseries throughout the U. S. contend with a variety of pests.
Effective fumigation is relied on to manage fungal pathogens (e.g.,
Fusarium, Alternaria, Phytophthora, Pythium, Rhizoctonia,
Cylindrocladium spp., Cylindrocarpon, and Macrophomina), nematodes
(e.g., Circonemoides, Helicotylenchus), and yellow and purple nutsedges
(species of Cyperus) (Cram and Fraedrich, 1997).  Nutsedges are
generally considered among the major pests of forest seedling nurseries
in the southeastern U.S. and the pests most difficult to manage.

Concerns for crop damage and worker exposure of some alternatives have
been expressed by nursery growers after a significant outgassing
incident from metam-sodium, in 1999, resulted in destruction of millions
of nursery seedlings (described in the request by International Paper).
Because of the importance placed on seedling quality, failure to achieve
consistently healthy seedlings in even a fraction of the production beds
can have a devastating effect on this sector's ability to provide
acceptable seedlings.

Inconsistency in pest management performance by alternatives has been
the primary concern for this sector, and the reason that MB is currently
critical for maintaining high quality seedlings.  While direct yield
losses, in terms of seedlings/hectare, were not large on average,
intensive seedling production relies on the ability of nursery managers
to meet quality, as well as yield, goals.  In addition, economic issues
such as increased application costs (e.g., costs associated with
application of metam-sodium and a separate chloropicrin application) may
have an impact on overall feasibility of these alternatives for the
forest seedlings sector.

As research identifies the most effective alternatives and application
methodologies with alternative treatments, industry transition to these
alternatives will accelerate.  Research is ongoing to develop protocols
for likely alternatives, such as 1,3-D and metam-sodium, and integrated
methods with chemicals and non-chemicals.  The requesting consortia are
developing timelines that will help determine how the transition from MB
will be achieved, most likely by implementing an integrated management
strategy with a combination of chemical and non-chemical treatments.
While field trials proceed, however, there is a critical need for MB for
this sector for the 2008 use season.

Table A.1: Executive Summary for forest seedlings*  TC "Table A.1:
Executive Summary" \f F \l "1"

Region	SOUTHERN FOREST NURSERY MANAGEMENT COOPERATIVE	International
Paper	Illinois Department of Natural Resources	Weyerhaeuser South
Weyerhaeuser West	Northeastern Forest & Conservation Nursery Assoc
Michigan Seedling Association

Kilograms (kg)	246,032	15,728	4,264	17,962	16,506	29,276	7,050

Amount of Applicant Request

2008 Kilograms (kg)	246,032	15,714	4,264	17,962	16,491	29,250	6,908

Amount of Nomination *

2008 Kilograms (kg)	60,764	10,627	3,819	13,889	16,491	20,946	6,604

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

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

Alternatives to MB are currently problematic for optimal seedling
production because of their inconsistent performance from season to
season, for nurseries with moderate to high pest (especially weed)
pressure (e.g., Fraedrich and Dwinell, 2003a, 2003b, 2003c; Carey, 2000;
Carey, 1996; Carey, 1994; Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10,
1994-96).  While chemicals such as chloropicrin, metam-sodium, dazomet,
herbicides, or 1,3-D can be effective in some situations in reducing
pest infestations, including weed problems, inconsistency in pest
management by chemical alternatives is the primary concern for this
sector, and the reason that MB is currently critical for maintaining
high quality seedlings.  For example, Fraedrich and Dwinell (2003b)
found that dazomet had some efficacy against nutsedge in field trials
one year in two southern nurseries.  But in one of the nurseries in
Georgia, nutsedge plant populations increased over the course of the
summer.  They cautioned that “…[i]f dazomet is to be used for
nutsedge control, additional efforts will be necessary to better define
the optimal use conditions”.  Fraedrich and Dwinell (2003c) also
conducted studies with glyphosate as a possible control for nutsedge.
Two years of study suggested that glyphosate in broadcast treatments
might be a feasible treatment.  However, an integrated system of pest
management must first be developed to achieve acceptable levels of
control.

Research studies with organic and inorganic soil amendments (Fraedrich
and Dwinell, 1998; James et al., 1997; James et al., 2001; Lantz, 1997;
Stone et al., 1998) resulted in reduction in populations of certain
pathogens, but the effects were variable depending on the nursery
locations and species of seedlings.  Furthermore, it was unclear if
pathogen population size was correlated with disease incidence.  More
research is required before there can be commercial application of these
methods as independent treatments.

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

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

Region where Methyl Bromide use is requested	Total crop area in 2002
(ha)	Proportion of total crop area treated with methyl bromide in 2002
(%)

A. Southern Forest Nursery Management Cooperative 	Not available	Not
available

B. International Paper 	Not available	Not available

C. Illinois Dept of Natural Resources 	Not available	Not available

D. Weyerhaeuser-South 	Not available	Not available

E. Weyerhaeuser-West 	Not available	Not available

F. Northeastern Forest and Conservation Nursery Association 	Not
available	Not available

G. Michigan Seedling Association 	Not available	Not available

National Total**:	51,506	2%

*Typically, only a fraction of a nursery’s beds are fumigated in a
given year.

**National average may include states not requesting methyl bromide.

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

Alternatives such as metam-sodium, chloropicrin, dazomet are used in
approximately half of nursery hectares, especially those without severe
nutsedge problems.  Where soil types and temperatures are conducive, and
especially where pest pressure is not high, these alternatives can be
effective.  This nomination, however, applies to those nurseries where
alternatives are not effective.  MB allows conifer seedling beds to be
fumigated after two or three crops (as opposed to after every crop)
because of the effectiveness of MB, which usually makes a second-year
treatment unnecessary.  Moreover, during the subsequent two years, beds
are fallowed or an unfumigated cover crop is planted.  With severe
infestations of pests alternative products usually are applied more
often, or several treatments with more than one alternative are used.
Higher costs can be incurred if appropriate pest management strategies
have not been properly designed.

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?  TC "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?" \f C \l "2"

Nurseries of this sector have been implementing some methods (cover crop
or fallow) that can reduce pest infestations.  Strategies to replace MB
are being studied by all of the nurseries involved.  Within the next few
years there will be considerable empirical data to identify the
effectiveness of MB alternatives feasible for this sector, probably by
implementing an integrated management strategy with a combination of
chemical and non-chemical treatments.  Until this time, however, there
is a critical need for MB for this sector.

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

Table 8.1. Region A – Southern Forest Nursery Management Cooperative:
Amount of Methyl Bromide Requested for Critical Use  TC "Table 8.1.
Region A - Southern Forest Nursery Management Cooperative:  Amount of
Methyl Bromide Requested for Critical Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	246,032

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	656

Application rate* (kg/ha) for the Active Ingredient	375

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	37.5

Table 8.2. Region B - International Paper: Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.2. Region B - International
Paper: Amount of Methyl Bromide Requested for Critical Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	15,714

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	41

Application rate* (kg/ha) for the Active Ingredient	386

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	30.4

Table 8.3. Region C - Illinois Department of Natural Resources:  Amount
of Methyl Bromide Requested for Critical Use  TC "Table 8.3. Region C -
Illinois Department of Natural Resources:  Amount of Methyl Bromide
Requested for Critical Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	4264

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	16

Application rate* (kg/ha) for the Active Ingredient	263

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	26.3

Table 8.4. Region D - Weyerhaeuser-South:  Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.4. Region D -
Weyerhaeuser-South:  Amount of Methyl Bromide Requested for Critical
Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	17,962

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	53

Application rate* (kg/ha) for the Active Ingredient	336

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	33.6

Table 8.5. Region E - Weyerhaeuser-West:  Amount of Methyl Bromide
Requested for Critical Use  TC "Table 8.5. Region E - Weyerhaeuser-West:
 Amount of Methyl Bromide Requested for Critical Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	16,491

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	69

Application rate* (kg/ha) for the Active Ingredient	239

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	23.9

Table 8.6. Region F - Northeastern forest and Conservation Nursery
Association:  Amount of Methyl Bromide Requested for Critical Use  TC
"Table 8.6. Region F - Northeastern Forest and Conservation Nursery
Association:  Amount of Methyl Bromide Requested for Critical Use" \f F
\l "1"

Year of Exemption Request	2008

Kilograms of MB	29,250

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	98:2

Total Area to be treated with the MB or MB/Pic formulation (ha)	81

Application rate* (kg/ha) for the Active Ingredient	363

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	36.3

Table 8.7. Region G - Michigan Seedling Association:  Amount of Methyl
Bromide Requested for Critical Use  TC "Table 8.7. Region G - Michigan
Seedling Association:  Amount of Methyl Bromide Requested for Critical
Use" \f F \l "1"

Year of Exemption Request	2008

Kilograms of MB	6,908

Use: flat fumigation or Strip/Bed Treatment	flat fumigation

Formulation (ratio of MB/Pic mixture) to be used for the CUE	67:33

Total Area to be treated with the MB or MB/Pic formulation (ha)	26

Application rate* (kg/ha) for the Active Ingredient	266

Dosage rate* (g/m2) of active ingredient used to calculate requested
kilograms of MB	26.6

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

The amount of MB 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.  No adjustment was made for this sector.

Hectares counted in more than one application, or rotated within one
year of an application to a crop that also uses MB, were subtracted.
The double counted hectares were removed.

Growth or increasing production (the amount of area requested by the
applicant that is greater than that historically treated) was
subtracted.  The five applicants that included growth in their request
had the growth amount removed.

Quarantine and pre-shipment (QPS) hectares were removed from each
applicant’s request.

Only the hectares with moderate to heavy key pest pressure were included
in the nominated amount.

Region A – Southern Forest Nursery Management Cooperative - Part B:
Crop Characteristics and Methyl Bromide Use  TC "Region A – Southern
Forest Nursery Management Cooperative - Part B: Crop Characteristics and
Methyl Bromide Use" \f F \l "1"    TC "Region A – Southern Forest
Nursery Management Cooperative - Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"

Region A – Southern Forest Nursery Management Cooperative - 10. Key
Diseases and Weeds for which Methyl Bromide Is Requested and Specific
Reasons for this Request  TC "Region A. Southern Forest Nursery
Management Cooperative. 10. Key Diseases and Weeds for which Methyl
Bromide Is Requested and Specific Reasons for this Request" \f C \l "2"

Region A – Southern Forest Nursery Management Cooperative - Table
10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request  TC
"Region A – Southern Forest Nursery Management Cooperative - 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

Southern Forest Nursery Management Cooperative	Fungi [100% at times]:
Fusarium, Macrophomina, Rhizoctonia, Pythium, Phytophthora;	For areas
where pest pressure is high, MB provides sufficient protection for three
successive seedling crops, with one fumigation treatment (one treatment
every four years). Until protocols are developed to improve efficacy of
alternative treatments, there may be a need to provide additional
fumigation treatments, or use a combination of chemicals and other
effective treatments that may increase costs, beyond what is feasible.

	Weeds [100% at times]: broadleaf, grasses, sedges

Nematodes [100% at times]: Circonemoides, Helicotylenchus

Region A – Southern Forest Nursery Management Cooperative - 11. (i)
Characteristics of Cropping System and Climate  TC "Region A –
Southern Forest Nursery Management Cooperative - 11. (i) Characteristics
of Cropping System and Climate" \f C \l "2"

Region A – Southern Forest Nursery Management Cooperative - Table
11.1: Characteristics of Cropping System  TC " Region A – Southern
Forest Nursery Management Cooperative - Table 11.1: Characteristics of
Cropping System" \f F \l "1"

Characteristics	Southern Forest Nursery Management Cooperative

Crop Type: 	Bareroot forest seedlings (91-96% pine, 4-9% hardwood
species)

Annual or Perennial Crop: 	Conifers: Typically grown for 1 year for each
of two or three crops before fumigation on fourth year;

Hardwoods: Prior to each crop

Typical Crop Rotation  and use of methyl bromide for other crops in the
rotation: 	Cover crops are used to reduce pest pressure on target crops;
cover crops used include sorghum and corn

Soil Types: 	Light (85%); medium (15%)

Frequency of methyl bromide Fumigation: 	Typically, fumigated once in
3-4 years

Other relevant factors:	No other relevant factors were identified.

Region A - Southern Forest Nursery Management Cooperative - Table 11.2
Characteristics of Climate and Crop Schedule  TC "Region A – Southern
Forest Nursery Management Cooperative - Table 11.2 Characteristics of
Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 7a, 7b, 8a, 8b (nurseries in: Alabama,
Arkansas, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma,
South Carolina, Tennessee, Texas, Virginia)

Rainfalla (mm)	125	128	155	135	91	100	141	118	76	52	87	131

Outside Temp. ((C)	7.7	10.0	13.9	18.3	22.2	26.1	27.2	27.2	25.0	18.9	13.9
10.0

Fumigation Schedule	1st year

	Planting  Scheduleb

2nd 3rd 4th years

aThe rainfall and temperature data are for Alabama, which may be
considered typical of the region.

bFumigation generally occurs once in three or four years.  According to
this consortium, “The typical crop cycle would include a period of
cover crop and fallow, nine to 24 months, after the second harvest
(months 25-48).  After the cover crop and/or fallow period, the area
would be fumigated again and the crop cycle would continue.”

Region A - Southern Forest Nursery Management Cooperative - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?  TC "Region A – Southern Forest
Nursery Management Cooperative - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?" \f C \l "2"

Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden.

Region A – Southern Forest Nursery Management Cooperative - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested  TC "Region A –
Southern Forest Nursery Management Cooperative - 12. Historic Pattern of
Use of Methyl Bromide, and/or Mixtures Containing Methyl Bromide, for
which an Exemption Is Requested" \f C \l "2"

Region A - Southern Forest Nursery Management Cooperative - Table 12.1
Historic Pattern of Use of Methyl Bromide  TC "Region A – Southern
Forest Nursery Management Cooperative - Table 12.1 Historic Pattern of
Use of Methyl Bromide" \f F \l "1"

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

Area Treated (hectares)	656	656	656	656	656	656

ratio of flat fumigation methyl bromide use to strip/bed use if strip
treatment is used	not available	flat fumigation	flat fumigation	flat
fumigation	flat fumigation	flat fumigation

Amount of methyl bromide active ingredient used

(total kilograms)	246,032	246,032	246,032	246,032	246,032	246,032

formulations of methyl bromide

(methyl bromide:chloropicrin)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied )	shank injected w/tarp	shank
injected w/tarp 	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

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

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

* For flat fumigation treatment application rate and dosage rate may be
the same.

aData are based on a survey of consortium members in 2000.  Consortium
does not keep records of seedling production data but assumes that use
rates and production information do not vary significantly from year to
year.

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

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

Region B - International Paper - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region B. International Paper.
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

International Paper	Fungi: Rhizoctonia (root rot);	For areas where pest
pressure is high, MB allows two successive seedling crops with one
fumigation treatment (one treatment every four years).  Alternative
treatments will require more frequent fumigation due to reduced efficacy
until protocols are developed to improve efficacy.

	Weeds: Cyperus esculentus/rotundus (purple/yellow nutsedge)

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

Region B – International Paper - Table 11.1: Characteristics of
Cropping System  TC " Region B. International Paper. Table 11.1:
Characteristics of Cropping System" \f F \l "1"

Characteristics	International Paper

Crop Type: 	Forest seedlings (all pine species) and some hardwoods

Annual or Perennial Crop:	Typically grown for each of two years followed
by two years of unfumigated cover crops before fumigation in the fourth
year just before sowing the first seedling crop

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

Soil Types: 	Light, medium, heavy

Frequency of methyl bromide Fumigation: 	Fumigation once in four years

Other relevant factors:	No other relevant factors were identified.

Region B – International Paper - Table 11.2 Characteristics of Climate
and Crop Schedule  TC "Region B. International Paper. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 6b, 7a, 7b, 8a, 8b (Alabama, Arkansas, Georgia,
South Carolina, Texas)

Rainfall (mm)	Not available, but varies with diverse climates

Outside Temp. ((C)	Not available, but varies with diverse climates

Fumigation Schedule

1st year

Planting  Schedulea

2nd 3rd 4th years

aFumigation occurs once in four years for conifers after two or three
crops are harvested.

Region B - International Paper - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region B - International Paper - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"

Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden.   International Paper
estimated in 2003 (Dr. George Lowerts, personal communication), that
typically, a 10-day delay would be incurred with alternative treatments
such as 1,3-D to avoid phytotoxic effects.

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

Region B - International Paper - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region B. International Paper. 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)	185	121	115	101	130	131

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 	68,975	43,646	38,666
34,853	49942	50253

formulations of methyl bromide

(methyl bromide:chloropicrin)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied 	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	374	362	338	344	384	384

Actual dosage rate [active ingredient] (g/m2)*	37.4	36.2	33.8	34.4	38.4
38.4

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region C - Illinois Department of Natural Resources - Part B: Crop
Characteristics and Methyl Bromide Use  TC "Region C. Illinois
Department of Natural Resources. Part B: Crop Characteristics and Methyl
Bromide Use" \f C \l "1"

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

Region C - Illinois Department of Natural Resources - Table 10.1: Key
Diseases and Weeds and Reason for Methyl Bromide Request  TC "Region C.
Illinois Department of Natural Resources. 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

Illinois Department of Natural Resources	Fusarium spp.	Consistency in
production for the variety of nursery plants grown in small public
nursery.

	weeds

nematodes

Region C - Illinois Department of Natural Resources - 11. (i)
Characteristics of Cropping System and Climate  TC " Region C. Illinois
Department of Natural Resources. 11. Characteristics of Cropping System
and Climate" \f C \l "2"

Region C - Illinois Department of Natural Resources - Table 11.1:
Characteristics of Cropping System  TC " Region C. Illinois Department
of Natural Resources. Table 11.1: Characteristics of Cropping System" \f
F \l "1"

Characteristics	Illinois Department of Natural Resources

Crop Type: 	Hardwood seedlings (13 ha); shrubs (2 ha); prairie forbs (1
ha)

Annual or Perennial Crop: 	Typically grown for 1 or 2 years

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

Soil Types:  	Light

Frequency of methyl bromide Fumigation: 	Fumigation every year

Other relevant factors:	No other relevant factors were identified.

Region C - Illinois Department of Natural Resources - Table 11.2
Characteristics of Climate and Crop Schedule  TC " Region C. Illinois
Department of Natural Resources. Table 11.2 Characteristics of Climate
and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 5b, 6b

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedule

X

Planting

Schedule

X

Region C - Illinois Department of Natural Resources - 11. (ii) Indicate
if any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?  TC "Region C - Illinois Department of Natural
Resources - 11. (ii) Indicate if any of the above characteristics in 11.
(i) prevent the uptake of any relevant alternatives?" \f C \l "2"

For this small, public consortium, fumigation in the fall followed by
planting is the most effective means of meeting production goals.
Alternatives will require delays due to increased labor costs for hand
weeding, and potential outgassing damage to already planted beds.

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

Region C - Illinois Department of Natural Resources - Table 12.1
Historic Pattern of Use of Methyl Bromide  TC "Region C. Illinois
Department of Natural Resources. 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)	17	16	13	16	15	15

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

(total kilograms)	4,370	4,211	3,411	4,232	3,869	3,869

formulations of methyl bromide (methyl bromide:chloropicrin)	67:33	67:33
67:33	67:33	67:33	67:33

Method by which methyl bromide applied 	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	263	263	263	263	263	263

Actual dosage rate [active ingredient] (g/m2)*	26.3	26.3	26.3	26.3	26.3
26.3

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region D - Weyerhaeuser-South - Part B: Crop Characteristics and Methyl
Bromide Use  TC "Region D. Weyerhaeuser-South. Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"

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

Region D - Weyerhaeuser-South - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region D. Weyerhaeuser-South.
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

Weyerhaeuser-South	Fungi: Fusarium, Pythium, Rhizoctonia;	Only #1 grade
seedlings are sold; grade #2 and culls are discarded.  To economically
manage the range of pests (where infestation of fungal pathogens and
nutsedges is severe), MB is necessary since no alternatives currently
provide both reliable control and economic sustainability for #1 grade
seedlings.

	Weeds: Cyperus (nutsedges)

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

Region D - Weyerhaeuser-South - Table 11.1: Characteristics of Cropping
System  TC " Region D. Weyerhaeuser-South. Table 11.1: Characteristics
of Cropping System" \f F \l "1"

Characteristics	Weyerhaeuser-South

Crop Type: 	Primarily loblolly pine; some hardwood species

Annual or Perennial Crop:	Typically grown for 1 year

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

Soil Types: 	Light (62%); Medium (22%)

Frequency of methyl bromide Fumigation: 	Fumigation once in four years
(conifers)

Other relevant factors:	No other relevant factors were identified.

Region D - Weyerhaeuser-South - Table 11.2 Characteristics of Climate
and Crop Schedule  TC " Region D. Weyerhaeuser-South. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA 7b, 8a (includes Alabama, Arkansas, North Carolina,
and South Carolina)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedule

1st year

Planting  Schedulea

2nd 3rd 4th years

aFumigation occurs once in four years, one year old conifer seedlings
are harvested.

Region D - Weyerhaeuser-South - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region D - Weyerhaeuser-South - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"

Fumigation for conifer crops typically occurs once in a four-year cycle.
 Therefore, typically, two or three successive annual seedling crops are
produced for each fumigation event.  Alternatives may require fumigation
(with 1,3-D + chloropicrin, for example) prior to each crop, which may
increase the costs and environmental burden.

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

Region D - Weyerhaeuser-South - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region D. Weyerhaeuser-South. 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)	72	66	61	64	66	72

73

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)	29,649	21,516
21,709	24,231	26,079	29803

formulations of methyl bromide (methyl bromide:chloropicrin)	98:2	90:10
90:10	90:10	98:2	98:2

Method by which methyl bromide applied )	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	412	327	355	379	398	406

Actual dosage rate [active ingredient] (g/m2)*	41.2	32.7	35.5	37.9	39.8
40.6

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region E - Weyerhaeuser-West - Part B: Crop Characteristics and Methyl
Bromide Use  TC "Region E. Weyerhaeuser-West. Part B: Crop
Characteristics and Methyl Bromide Use" \f C \l "1"

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

Region E - Weyerhaeuser-West - Table 10.1: Key Diseases and Weeds and
Reason for Methyl Bromide Request  TC "Region E. Weyerhaeuser-West.
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

Weyerhaeuser-West	Fungi [100% at times]: Cylindrocarpon (root rot);
Pythium (damping-off, root rot), Fusarium (damping-off, root rot),
Phoma, Fusarium, Botrytis (stem cankers);	Cylindrocarpon root rot is an
increasingly important disease, with no registered chemicals.  Applicant
states that increased area reflects increased losses to the disease and
necessity of continued production numbers.  High pathogen populations
and potential for contamination with Phytophthora ramorum (sudden oak
death) leave little room for production variability.

	Weeds: Cyperus (yellow nutsedge) [100% at times]

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

Region E - Weyerhaeuser-West - Table 11.1: Characteristics of Cropping
System  TC " Region E. Weyerhaeuser-West. Table 11.1: Characteristics of
Cropping System" \f F \l "1"

Characteristics	Weyerhaeuser-West

Crop Type: 	Pine, Christmas trees, some hardwoods

Annual or Perennial Crop: 	Typically one year seedling bed, one year
transplant bed; transplants can be grown for 2, 3, or 4 years

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

Soil Types: 	Light (60%), Medium (40%)

Frequency of methyl bromide Fumigation: 	Fumigation once in 3 years

Other relevant factors:	No other relevant factors were identified.

Region E - Weyerhaeuser-West - Table 11.2 Characteristics of Climate and
Crop Schedule  TC " Region E. Weyerhaeuser-West. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 8a, 8b (includes Washington and western Oregon)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

1st year

Planting Schedule

2nd

3rd

aTypically fumigation occurs once in three years, one year old seedlings
are harvested.

Region E - Weyerhaeuser-West - 11. (ii) Indicate if any of the above
characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region E - Weyerhaeuser-West - 11. (ii) Indicate if
any of the above characteristics in 11. (i) prevent the uptake of any
relevant alternatives?" \f C \l "2"

Fumigation occurs once in a three year cycle.  Typically, two successive
annual seedling crops are produced for each fumigation event.
Alternatives may require more frequent fumigation (with 1,3-D +
chloropicrin, for example) or a combination of treatments that could
significantly increase the costs and environmental burden.

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

Region E - Weyerhaeuser-West - Table 12.1 Historic Pattern of Use of
Methyl Bromide  TC "Region E. Weyerhaeuser-West. 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)	43	70	65	70	76	95

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

(total kilograms)	11,360	17,864	17,125	14,647	16,935	19,122

formulations of methyl bromide

(methyl bromide:chloropicrin)	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied

(e.g. injected at 25cm depth, hot gas)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	262	255	263	210	224	201

Actual dosage rate [active ingredient] (g/m2)*	26.2	25.5	26.3	21.0	22.4
20.1

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region F - Northeastern Forest & Conservation Nursery Association - Part
B: Crop Characteristics and Methyl Bromide Use  TC "Region F.
Weyerhaeuser-South. Part B: Crop Characteristics and Methyl Bromide Use"
\f C \l "1"

Region F - Northeastern Forest & Conservation Nursery Association - 10.
Key Diseases and Weeds for which Methyl Bromide Is Requested and
Specific Reasons for this Request  TC " Region F. Northeastern Forest
and Conservation Nursery Association. 10. Key Diseases and Weeds for
which Methyl Bromide Is Requested and Specific Reasons for this Request"
\f C \l "2"

Region F - Northeastern Forest & Conservation Nursery Association -
Table 10.1: Key Diseases and Weeds and Reason for Methyl Bromide Request
 TC "Region F. Northeastern Forest and Conservation Nursery Association.
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

Northeastern Forest & Conservation Nursery Association	Fungi:
Phytophthora (damping-off, root rot) [80%], Fusarium (damping-off, root
rot) [80%], Cylindrocladium [50%];	In humid, warm conditions damping-off
is a significant problem; as with much of industry, weed problems,
especially nutsedge and Canada thistle, are difficult to manage without
MB.

	Weeds: Cyperus (yellow nutsedge) [40%], Cirsium (Canada thistle) [70%]

Region F - Northeastern Forest & Conservation Nursery Association - 11.
(i) Characteristics of Cropping System and Climate  TC " Region F.
Northeastern Forest and Conservation Nursery Association. 11.
Characteristics of Cropping System and Climate" \f C \l "2"

Region F - Northeastern Forest & Conservation Nursery Association -
Table 11.1: Characteristics of Cropping System  TC " Region F.
Northeastern Forest and Conservation Nursery Association. Table 11.1:
Characteristics of Cropping System" \f F \l "1"

Characteristics	Northeastern Forest and Conservation Nursery Association

Crop Type: 	Conifers (10-15 spp.)= 1-yr, 8%; 2-yr, 4%; 3-yr, 14%;
hardwoods (30-50 spp.)= 1-yr, 55%; 2-yr, 9%; shrubs and forbs (>75
spp.)= 10%

Annual or Perennial Crop: 	Bareroot cuttings, and transplants, typically
grown 1-3 years

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

Soil Types: 	Light, Medium

Frequency of methyl bromide Fumigation: 	Fumigation minimum, once in two
years; depending on species, can be once in two to four years

Other relevant factors:	No other relevant factors were identified.

Region F - Northeastern Forest & Conservation Nursery Association -
Table 11.2 Characteristics of Climate and Crop Schedule  TC " Region F.
Northeastern Forest and Conservation Nursery Association. Table 11.2
Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 3a, 4b, 5a, 5b, 6a, 6b, 7a (includes
state-owned nurseries in Illinois, Indiana, Kentucky, Maryland,
Missouri, New Jersey, Ohio, Pennsylvania, West Virginia, and Wisconsin)

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

	X

	Planting  Schedulea	X	X	X

	X	X	X

aDue to the large number of species and wide geographical area
represented in this consortium, seedlings can be planted at various
times in the fall or spring.  Generally, fumigation occurs once in two
or three years, but beds for certain hardwood species may be treated
every year.

Region F - Northeastern Forest & Conservation Nursery Association - 11.
(ii) Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?  TC "Region F - Northeastern Forest
& Conservation Nursery Association - 11. (ii) Indicate if any of the
above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?" \f C \l "1"

Fumigation occurs once in a two to three year cycle.  Numerous species
are grown by nurseries in this consortium, but typically, two successive
annual seedling crops are produced for each fumigation event.  Until
effective combination treatments can be devised, alternatives (e.g.,
dazomet) may require application to each crop, or application of several
different treatments, which could increase significantly the costs and
environmental burden.

Region F - Northeastern Forest & Conservation Nursery Association - 12.
Historic Pattern of Use of Methyl Bromide, and/or Mixtures Containing
Methyl Bromide, for which an Exemption Is Requested  TC "Region F.
Northeastern Forest and Conservation Nursery Association. 12. Historic
Pattern of Use of Methyl Bromide, and/or Mixtures Containing Methyl
Bromide, for which an Exemption Is Requested" \f C \l "2"

Variation in MB use is due to changes in products, and may be determined
by market demand and/or availability of seed.  Changes in product will
affect area planted (and therefore treated).  For example, hardwoods are
grown at densities of 65-130 seedlings/m2, while conifer seedlings are
grown at densities of 215-320 seedlings/m2.  Changes in the proportion
of hardwood and pine seedlings, therefore, will affect the area
requiring fumigation.

Region F - Northeastern Forest & Conservation Nursery Association -
Table 12.1 Historic Pattern of Use of Methyl Bromide  TC "Region F.
Northeastern Forest and Conservation Nursery Association. 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)	91	87	80	72	87	78

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

(total kilograms)	31,961	28,308	26,844	26,273	30,798	29,027

formulations of methyl bromide

(methyl bromide:chloropicrin)	98:2	98:2	98:2	98:2	98:2	98:2

Method by which methyl bromide applied

(e.g. injected at 25cm depth, hot gas)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	352	326	337	363	359	372

Actual dosage rate [active ingredient] (g/m2)*	35.2	32.6	33.7	36.3	35.9
37.2

* For flat fumigation treatment application rate and dosage rate may be
the same.

Region G - Michigan Seedling Association - Part B: Crop Characteristics
and Methyl Bromide Use  TC "Region G. Michigan Seedling Association.
Part B: Crop Characteristics and Methyl Bromide Use" \f C \l "1"

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

Region G - Michigan Seedling Association - Table 10.1: Key Diseases and
Weeds and Reason for Methyl Bromide Request  TC "Region G. Michigan
Seedling Association. 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 Seedling Association	Primarily annual and perennial weeds
(e.g., nutsedge, Canada thistle); also, fungal pathogens; nematodes
Nutsedge (50% of area), common groundsel (95% of area), hairy
bittercress (60% of area), Canada thistle (25% of area), and mugwort
(20% of area); Soil-borne diseases are also of concern; dazomet and
metam-sodium are not reliable in this region because of cooler soil
temperatures.

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

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

Characteristics	Michigan Seedling Association

Crop Type: 	Conifers, hardwoods

Annual or Perennial Crop: 	Conifers: bareroot and transplants, typically
1, 2, or 3 years growth; Hardwood: 1-year (80%) and 2-year (20%)

Typical Crop Rotation and use of methyl bromide for other crops in the
rotation: 	Crop grown on half the area.  Land not in production are left
fallow for 1-2 years, and planted with rye in Oct-Nov and Sudex in
March-April.

Soil Types:  	Light

Frequency of methyl bromide Fumigation: 	Fumigation every year on land
in production (approximately half the land).  Therefore, an average area
of nursery is fumigated once in two years.

Other relevant factors:	No other relevant factors were identified.

Region G - Michigan Seedling Association - Table 11.2 Characteristics of
Climate and Crop Schedule  TC " Region G. Michigan Seedling Association.
Table 11.2 Characteristics of Climate and Crop Schedule" \f F \l "1"

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

Climatic Zone	USDA zones 4b, 5a, 5b

Rainfall (mm)	Not available

Outside Temp. ((C)	Not available

Fumigation Schedulea

	(sometimes) Spring

	(usually) Fall	(usually) Fall

	Planting Schedule

	for conifers, after Fall fumigation

	for hardwoods, after Fall fumigation

	aFumigation schedules depend on growth as annual seedlings or
additional bed requirements as transplants.  Generally, fumigation
occurs each year on the production land (half of the total nursery
land)—therefore a particular parcel of land will receive fumigation
once in two years.

Region G - Michigan Seedling Association - 11. (ii) Indicate if any of
the above characteristics in 11. (i) prevent the uptake of any relevant
alternatives?  TC "Region G - Michigan Seedling Association - 11. (ii)
Indicate if any of the above characteristics in 11. (i) prevent the
uptake of any relevant alternatives?" \f C \l "2"

Michigan Seedling Association working with Michigan State University is
in the midst of conducting research (with grants from USDA MB
Alternatives program) to assess the efficacy of alternatives with an
economic survey conducted to define costs associated with alternatives.
Results of this research that will be available in 2006-2007, should
help identify true alternatives to MB.  Feasible alternatives should be
identified and available by 2007-2008 growing season, according to the
requesting consortium.  Until this time, MB is critical for the
continuation of this industry.  The consortium has stated that growers
have been transitioning to use of 1,3-D for pest problems that can be
effectively managed by this treatment.  Tarp studies and studies of
various herbicides are being conducted and hold promise to manage key
weed problems.

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

Region G - Michigan Seedling Association - Table 12.1 Historic Pattern
of Use of Methyl Bromide  TC "Region G. Michigan Seedling Association.
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)	46	51	34	35	26	26

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

(total kilograms)	13,825	9,144	9689	9493	9420	9420

formulations of methyl bromide

(methyl bromide:chloropicrin)	67:33	67:33	67:33	67:33	67:33	67:33

Method by which methyl bromide applied

(e.g. injected at 25cm depth, hot gas)	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp	shank injected w/tarp	shank
injected w/tarp	shank injected w/tarp

Application rate [Active Ingredient] (kg/ha*)	302	178	285	270	364	364

Actual dosage rate [active ingredient] (g/m2)*	30.2	17.8	28.5	27.0	36.4
36.4

* For flat fumigation treatment application rate and dosage rate may be
the same.

 Part C: Technical Validation  TC "Regions A-G. Forest Seedlings. Part
C: Technical Validation" \f C \l "1"

13. Reason for Alternatives Not Being Feasible  TC "Regions A-G. Forest
Seedlings. 13. Reason for Alternatives Not Being Feasible" \f C \l "2"

Table 13.1: Reason for Alternatives Not Being Feasible  TC "Regions A-G.
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:

Also, see Section 14 for additional chemicals not listed by MBTOC.

Dazomet

(400 kg/ha)	Inconsistent results with weeds, especially w/moderate to
high weed pressure.  Does not consistently provide acceptable levels of
nutsedge control, nor does it manage some diseases associated with
fungal pathogens (root rot and damping-off pathogens).  Most effective
use will probably be incorporated with other methods, but protocols must
be developed (Fraedrich and Dwinell, 2003b).  Field trials show that
seedling size (diameter and height) and root volume were inconsistent,
non-uniform, and reduced with dazomet, leading to higher counts of Grade
#2 seedlings and culls compared to greater numbers of Grade #1 seedlings
with MB.  Reduced efficacy requires production cycle compensation by
increasing the frequency of fumigation or lengthening the fallow period
in order to obtain better control of weeds and other pests.  These
strategies result in reduced seedling production.  Damage to seedlings
growing adjacent to beds being fumigated with dazomet has resulted in
significant loss of seedlings due to fumigant drift.  Soil temperature
requirements (above 6° C/ optimal 12-18° C) of dazomet, due to vapor
pressure properties, constrains use in some areas (north and west)
(Landis and Campbell, 1989); (Fraedrich and Dwinell, 2003b; Campbell and
Kelpsas, 1988; Carey, 1996; Carey, 1994; Enebak et al., 1990;
Weyerhaeuser, #3, 1984-87; Weyerhaeuser, #4, 1985-87; Weyerhaeuser, #6,
1992; Weyerhaeuser, #7, 1994-96; Weyerhaeuser, #8, 1992-95;
Weyerhaeuser, #9, 1994-95; Weyerhaeuser, #10, 1994-96) 	No

Metam-sodium

(485 kg/ha)	Inconsistent results with weeds, especially w/high weed
pressure.  Average yield losses are estimated to be approximately 5%
with metam-sodium, although the addition of other pesticides to provide
broader control could reduce losses.  As with dazomet, reduced efficacy
requires production cycle compensation by increasing the frequency of
fumigation or lengthening the fallow period in order to obtain better
control of weeds and other pests.  These strategies result in reduced
seedling production.  As with dazomet, seedling quality is inconsistent
resulting in less predictable seedling production factors.  Damage to
seedlings growing adjacent to beds being fumigated with metam-sodium has
resulted in significant loss of seedlings due to fumigant drift.
Fumigant drift may result in issues related to human safety and legal
liability.  Soil temperature requirements (above 4° C) of metam-sodium,
due to vapor pressure properties, can constrain use in some areas (north
and west) (Landis and Campbell, 1989); (Campbell and Kelpsas, 1988;
Carey, 1996; Carey, 1994, Darrow, 2002; Weyerhaeuser, #4, 1985-87;
Weyerhaeuser, #6, 1992)	No

Non Chemical Alternatives

Containerized production	Containerization of nursery production would
(1) require a large capital investment by all participants in the
sector, (2) increase seedling production costs by 300 to 600%, (3)
reduce reforestation rates as public nurseries opt out of reforestation
as expenditures go up.  (see Section 18 and Appendix B.).  Some
nurseries with specialized markets have a portion of their production in
containers (Barnett and McGilvrary, 1997; Darrow, 2002; Lowerts, 2003).
For seedling production goals, is not cost effective for the complex
production system. [see Section 18 and Appendix B.]

Virtually Impermeable Film (VIF)	Current technology does not allow the
gluing together of overlapping sheets and therefore makes this product
non-functional for flat fumigation treatments, and currently available
products are relatively weak and torn by wind or pressure. However,
manufacturers believe problems can be resolved (Rimini and Wigley,
2004).  Both factors combine to make VIF film impractical using current
technology.  In the future, VIF might have a role in reducing MB use
rates while maintaining efficacy, due to reduced emissions.  Ongoing
studies may help assess value of VIF with MB and chemical alternatives.
(Carey and Godbehere, 2004; Guillino et al., 2002; Martin, 2003).  	Not
currently cost effective; not allowed in California

 Solarization	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.  Conceivably,
solarization could be optimized for efficacy and incorporated into an
integrated pest management (IPM) program that would help reduce chemical
use for bed preparation, but because of intensive scheduling of seedling
production, solarization is inadequate as a sole replacement for MB in
the forest seedling industry even in the southern U. S. (Weyerhaeuser,
#8, 1992-95)	Not cost effective as drop-in replacement

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.  However, this alternative is
not considered feasible due to the difficulty in obtaining sufficient
biomass to produce effective amounts of MITC to manage diseases and
weeds under nursery conditions.  11,500 kg per ha of Brassica
plants—an amount that is considered very high production—is
equivalent to approximately 25 kg dazomet, an amount significantly less
than effective fumigation rates.  In addition, increased Fusarium
populations due to favorable conditions provided by Brassica plants have
been reported to increase seedling diseases after biofumigation
treatments.  While some Petri dish studies (e.g., Charron and Sams) have
indicated a reduction in growth of some fungal pathogens limited field
studies have been conducted to verify effects. 	Not able to provide
sufficient biomass

Flooding/Water management	Nursery beds generally are designed and graded
for good drainage to prevent standing water.  Flooding could increase
incidence of Phytophthora and Pythium, which cause important damping-off
and root rot diseases.  Therefore, this alternative is not considered
technically feasible.	No

General Integrated Pest Management (IPM)	Nurseries currently use IPM
techniques, but these measures do not provide adequate weed and disease
control.  Therefore, this alternative is not considered technically
feasible.	Not as drop-in replacement

Plowing/Tillage	Nursery beds, especially medium type soils with higher
clay or organic matter than light soil beds, are susceptible to damage
to soil structure and development of an impermeable "plow pan" layer.
Increased plowing can result in less productive seedling beds,
therefore, this alternative is not considered feasible.	No

Physical Removal/ Sanitation	Appropriate sanitation practices are
already followed by nurseries, as this improves productivity.  Weed
control by mechanical means would not be technically feasible for
large-scale nursery seedling production.  	No

Organic Amendments/ Compost	Not acceptably effective alone in weed
management; often cover crops are already used for beds not in current
production, as part of general IPM program; can be issue with weed
introduction by plant-based mulches (James et al., 1997; James et al.,
2001; Stone et al., 1998).  Most nurseries employ various soil
amendments to enhance seedling growth and quality, but these measures do
not provide adequate weed and disease control, therefore, this
alternative is not considered feasible.	No

Combinations of ALTERNATIVES

 See Section 14 for non-MBTOC alternatives

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

14. List and Discuss Why Registered (and Potential) Pesticides and
Herbicides Are Considered Not Effective as Technical Alternatives to
Methyl Bromide:  TC "Regions A-G. Forest Seedlings. 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"

Chloropicrin and 1,3-D were not listed as one of the MB alternatives by
MBTOC.  These have been investigated by the industry as potential
alternatives, and in certain circumstances (e.g., low weed pressure),
can be effective in reducing weed, fungi and nematode populations.

Table 14.1: Technically Infeasible Alternatives Discussion  TC "Regions
A-G. Forest Seedlings. Table 14.1: Technically Infeasible Alternatives
Discussion" \f F \l "1"

Name of Alternative	Discussion

Chloropicrin

(340 kg/ha)	A good fungicide, but not acceptably effective with moderate
or high weed pressure, some reports of enhanced weed seed germination
(Carey, 2000; Carey, 1996; Enebak et al., 1990; Weyerhaeuser, #7,
1994-96; Weyerhaeuser, #10, 1994-96).  Weed pressure will likely
increase overtime.

Metam-sodium (485 kg/ha) + chloropicrin (115 kg/ha)	Can be effective
against weeds and fungi, especially with low to moderate pressure and
light soils (Carey, 2000; Carey, 1996; Carey, 1994; Weyerhaeuser, #10,
1994-96).  There is a history of outgassing problems and significant
seedling damage.

1,3-D (260 kg/ha) + chloropicrin (140 kg/ha)	A good nematicide, requires
light soils with optimal moisture content.  Not sufficiently effective
against weeds, especially with even moderate weed pressure; may have
legal restrictions on use (Carey, 1996; Carey, 1994; Weyerhaeuser, #7,
1994-96; Weyerhaeuser, #10, 1994-96)

Herbicides	Research will help to identify herbicides (e.g., glyphosate)
that can effectively reduce high populations of nutsedge with consistent
and reliable activity, most likely as part of an integrated program of
alternatives (e.g., Fraedrich and Dwinell, 2003c).

15. List Present (and Possible Future) Registration Status of Any
Current and Potential Alternatives  TC "Regions A-G. Forest Seedlings.
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 "Regions
A-G. Forest Seedlings. 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

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

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 "Regions A-G. Forest Seedlings.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"  .

16.1.A: Effectiveness of Alternatives – Weeds  TC " Regions A-G.
Forest Seedlings. Table 16.1.A: Effectiveness of Alternatives–Weeds"
\f F \l "1"

Research Results for Weed Management with Methyl Bromide (MB) and/or
Alternatives

Treatment	# Trials	Yield	Quality	Relative Quality	Weed Severity	Weed
Incidence	Citation

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 193b

[2] 236a

[3] 236a	Average Grade #1 Yield (per m2)

[1] 6b

[2] 19ab

[3] 45a	Quality (% Grade #1 compared to total)

[1] 3%

[2] 8%

[3] 19%	(# Nutsedge rhizomes per m2)

[1] 91a

[2] 43b

[3] 5b	No MB trt	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (285 kg/ha)

[3] Chloropicrin (285 kg/ha) + metam sodium (240 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 150b

[2] 214ab

[3] 246a	Average Grade #1 Yield (per m2)

[1] 8b

[2] 15ab

[3] 53a	Quality (% Grade #1 compared to total)

[1] 5%

[2] 7%

[3] 22%	(Nutsedge dry wt, kg/ha)

[1] 551a

[2] 40b

[3] 11b	No MB trt	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)

[4] MB (385 kg/ha) + Pic (8 kg/ha)	1

(W/

Loblolly pine)	Average Total Yield (per m2)

[1] 150b

[2] 193a

[3] 204a

[4] 204a	Average Grade #1 Yield (per m2)

[1] 27b

[2] 114ab

[3] 150a

[4] 131a	Quality (% Grade #1 compared to total)

[1] 18%

[2] 59%

[3] 74%

[4] 64%	Not reported	Not reported	Carey, 2000

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (340 kg/ha)

[3] Chloropicrin (340 kg/ha) + metam sodium (320 kg/ha)

[4] MB (385 kg/ha) + Pic (8 kg/ha)	1

(W/

Slash pine)	Average Total Yield (per m2)

[1] 107a

[2] 150a

[3] 150a

[4] 129a	Average Grade #1 Yield (per m2)

[1] 63b

[2] 109ab

[3] 136a

[4] 109ab	Quality (% Grade #1 compared to total)

[1] 59%

[2] 73%

[3] 91%

[4] 84%	Not reported	Not reported	Carey, 2000

“Heavy” soil (57% silt, 14% clay, 29% sand) [Chem. trts w/tarp]

[1] Control (no fumigation)

[2] Chloropicrin (285 kg/ha)

[3] Metam sodium (455 kg/ha)

[4] Chloropicrin (130 kg/ha) + metam sodium (455 kg/ha)

[5] 1,3-D (240 kg/ha) + Pic (100 kg/ha)

[6] Dazomet (285 kg/ha)

[7] MB (265 kg/ha)+Pic(130kg/ha)	1 (w/

Loblolly pine

Average Total Yield (per m2)

[1] 194

[2] 181

[3] 204

[4] 192

[5] 238

[6] 214

[7] 188

[LSD, 0.05=20]

Average Grade #1 Yield (per m2)

[1] 41

[2] 31

[3] 35

[4] 31

[5] 28

[6] 25

[7] 23

[LSD, 0.05=40]

Quality (% Grade #1 compared to total)

[1] 21%

[2] 17%

[3] 17%

[4] 16%

[5] 12%

[6] 12%

[7] 12%

(# Total weeds/ m2; 53 days after treatment)

[1] 37

[2] 16

[3] 25

[4] 7

[5] 12

[6] 12

[7] 6

[LSD, 0.05=14]	(% Coverage of weeds per plot (30 m2); 53 days after
treatment)

[1] 39%a

[2] 14%bc

[3] 25%ab

[4] 11%bc

[5] 21%bc

[6] 22%bc

[7] 6%c

	Carey, 1996

[Chem. trts w/tarp]

[1] Control (no fumigation)

[2] 1,3-D (240 kg/ha) + chloropicrin (100 kg/ha)

[3] Metam sodium (455 kg/ha)

[4] Chloropicrin (130 kg/ha) + metam sodium (455 kg/ha)

[5] Dazomet (340 kg/ha)

[6] Dazomet (170 kg/ha) +Pic (130kg/ha)

[7] MB (265 kg/ha)+Pic(130kg/ha)	Not reported	Not reported	Not reported
Not reported	(# Nutsedge /m2; 7 months after treatment)

[1] 85abc

[2] 5c

[3] 27bc

[4] 15bc

[5] 98abc

[6] 127abc

[7] 1c

[LSD, 0.05=38]	(% Coverage of weeds per plot (175 m2)7 months after
treatment)

[1] 100%a

[2] 35%c

[3] 36%c

[4] 38%c

[5] 95%a

[6] 46%c

[7] 29%c

[LSD, 0.05=16]	Carey, 1994

[1] Metam-sodium (485 kg/ha)

[2] MB (235 kg/ha) + chloropicrin (115 kg/ha) [spring trt]

[3] MB (235 kg/ha) + chloropicrin (115 kg/ha) [fall trt]	1

(1st year Ponderosa pine)	Average Total Yield (per m2)

[1] 245/m2

[2] 221/m2

[3] 208/m2	Not reported	Not reported	Not reported	Not reported
Weyer-haeuser #2, 1980

[1] MB (235 kg/ha) + chloropicrin (115 kg/ha)

[2] Metam-sodium (485 kg/ha)

[3] Dazomet (400 kg/ha)	1

(2nd year crop Douglas fir)	(# Of packable seedlings relative to MB trt)

[2] –54/m2

[3] –5/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 11%

[3] 1%	Consortium (CUE 03-0021) Comment: “Height, caliper, shoot
weight were greater w/ MBC treated soil”	Not reported	Not reported
Weyer-haeuser #4, 1985-1987

[1] MB (235 kg/ha) + chloropicrin (115 kg/ha)

[2] Dazomet (285 kg/ha)

[3] Dazomet (400 kg/ha)

[4] Control	1 (2nd year crop w/ Douglas fir)	(# Of packable seedlings
relative to MB trt)

[2] –88/m2

[3] –13/m2

[4] –75/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 18%

[3] 3%

[4] 16%	Consortium (CUE 03-0021) Comment: “Seedling size not
significantly different between MBC and dazomet at 285 kg/ha; size
reduced w/ dazomet at 400 kg/ha (toxicity?”)	Not reported	Not reported
Weyer-haeuser #5, 1985-1987

[1] MB (400 kg/ha) + chloropicrin (10 kg/ha)

[2] Metam sodium (485 kg/ha)

[3] Dazomet (400 kg/ha)

[4] Control	1 (1st year crop w/ loblolly pine)	(# Of packable seedlings
relative to MB trt)

[2] –27/m2

[3] –13/m2

[4] –27/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 6%

[3] 3%

[4] 6%	Consortium (CUE 03-0021) Comment:

“Seedling height averaged 5 cm shorter for dazomet and 10 cm shorter
for metam sodium and control.”  “Caliper (diameter) was reduced by 1
mm in metam sodium and control seedlings.”	Not reported	Not reported
Weyer-haeuser #6, 1992

[1] MB (390 kg/ha) + chloropicrin (8 kg/ha) [tarped]

[2] MB (300 kg/ha) + chloropicrin (100 kg/ha) ) [tarped]

[3] Dazomet (400 kg/ha) [tarped]

[4] Dazomet (400 kg/ha) [un-tarped]

[5] Pic-chlor (400 kg/ha) [tarped]

[6] Chloropicrin (340 kg/ha) [tarped]

[7] Control	1 (1st and 2nd year crops w/loblolly pine)	(# Of packable
seedlings relative to MB trt)

1st year crop:

[1] =[2]

[3] –64/m2

[4] –99/m2

[5] +11/m2

[6] +19/m2

[7] –88/m2

2nd year crop:

[1] =[2]

[3] –83/m2

[4] –59/m2

[5] –59/m2

[6] –19/m2

[7] Not reported	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[1] =[2]

[3] 13%

[4] 21%

[5] 2% gain

[6] 4% gain

[7] 18%

2nd year crop:

[1] =[2]

[3] 17%

[4] 12%

[5] 12%

[6] 4%

[7] Not reported	Consortium (CUE 03-0021) Comment:

[1st year crop reduction with dazomet due to stunting, and reduced root
volume]

[2nd year crop yield reduction due to stunting, and reduced root volume]
Not reported	Not reported	Weyer-haeuser #7, 1994-1996

[1] MB (390 kg/ha) + chloropicrin (8 kg/ha) [tarped]

[2] Dazomet (400 kg/ha) [tarped]

[3] Dazomet (400 kg/ha) [tarped & solarized 3 mo.]

[4] Solarization [tarped, solar. 3 mo]

[5] Control	1 (1st and 2nd year crops w/loblolly pine) (bare fallow from
harvest Feb., 1992 through fumigation and tarp (3 mo.) summer 1992	(# Of
packable seedlings relative to MB trt)

1st year crop:

[2] –8/m2

[3] –5/m2

[4] –11/m2

[5] = [1]

2nd year crop:

[2] –8/m2

[3] –5/m2

[4] –11/m2

[5] +19/m2	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[2] 2%

[3] 1%

[4] 2%

[5] no loss

2nd year crop:

[2] 2%

[3] 1%

[4] 2%

[5] 4% gain	[# weeds/m2 May, 1993; dominant species: Amaranthaceae spp.,
Mollugo verticillata, Euphorbia supine]

[1] 31b

[2] 25b

[3] 35b

[4] 54ab

[5] 104a	[# weeds/m2 June, 1993;

dominant species: Euphorbia supine, Digitaria ciliaris, Digitaria
ischaemun]

[1] 13b

[2] 10b

[3] 17b

[4] 28a

[5] 36a	Not reported	Weyer-haeuser #8, 1992-1995

[1] MB (400 kg/ha) + chloropicrin (8 kg/ha) [tarped]

[2] Dazomet (400 kg/ha) [tarped]

[3] Dazomet (400 kg/ha) [un-tarped]

[4] Control	1 (1st year crop w/loblolly pine)	(# Of packable seedlings
relative to MB trt)

[2] –19/m2

[3] –35/m2

[4] –5/m2	Loss (based on 480 seedlings/m2 w/MB):

[2] 4%

[3] 7%

[4] 1%	Consortium (CUE 03-0021)Comment: Short trees and poor root
structure were main cull factors	Not reported	Not reported	Weyer-haeuser
#9, 1994-1995

[1] MB (400 kg/ha) + chloropicrin (8 kg/ha)

[2] 1,3-D (260 kg/ha) + chloropicrin (140 kg/ha)

[3] Chloropicrin (130 kg/ha) + metam sodium (240 kg/ha) [tarped]

[4] Dazomet (400 kg/ha)[tarped]

[5] Dazomet (400 kg/ha)[untarped]

[6] Chloropicrin (340 kg/ha) [tarped]

[7] Control	1 (1st and 2nd year crops w/loblolly pine)	(# Of packable
seedlings relative to MB trt [1])

1st year crop:

[2] –40/m2

[3] –8/m2

[4] +3/m2

[5] –29/m2

[6] –13/m2

[7] –46/m2

2nd year crop:

[2] –3/m2

[3] –3/m2

[4] +3/m2

[5] Not reported

[6] +3/m2

[7] Not reported	Loss (based on 480 seedlings/m2 w/MB):

1st year crop:

[2] 8%

[3] 2%

[4] no loss

[5] 6%

[6] 3%

[7] 10%

2nd year crop:

[2] No loss

[3] No loss

[4] No loss

[5] Not reported

[6] No loss

[7] Not reported	1st year crop:

Culls were short with small diameters

2nd year crop:

Study was suspended due to high nutsedge populations

	Not reported	Not reported	Weyer-haeuser #10, 1994-1996

Table 16.1.B: Effectiveness of Alternatives – Disease

Research Results for Disease (Fusarium, Pythium, Rhizoctonia) Management
with Methyl Bromide (MB) and/or Alternatives

Treatment	# Trials	Yield	Percent Survival	Average Yield Post Emergence

(per m2)	Percent Healthy Root Tips (1 year old seedlings)	Stand density,
seedlings/m2 (fumigation Sept. 1986, seeding Oct., 1986)	Citation Number

May 1987	Sept 1987

	[1] Control (no fumigation)

[2] Chloropicrin (196 kg/ha)

[3] MB (392 kg/ha]

[4] MB (263 kg/ha) + chloropicrin (65 kg/ha)

[5] MB (130 kg/ha) + chloropicrin (131 kg/ha)

[6] Dazomet (280 kg/ha)

[7] Captan (6 kg/ha) [soil drench]

[8] Thiram (38 g/kg seed) [seed trt.]

[9] Captan (6 kg/ha) [soil drench] + thiram (38 g/kg seed) [seed trt.]

[10] Silica sand (overlay seeds)	6 reps (w/white pine in WI)	[Yield per
m2 at seedling emergence, based on survival from damping-off diseases,
calculated rate of 720 seedlings/ m2 at seeding rate of 14 g seed/ m2]

[1] 496b

[2] 550a

[3] 570a

[4] 566a

[5] 564a

[6] 522ab

[7] 474b

[8] 404c

[9] 408c

[10] 366c

Percent survival from damping-off at seedling emergence

[1] 69%ab

[2] 76%a

[3] 79%a

[4] 79%a

[5] 78%a

[6] 73%a

[7] 66%ab

[8] 57%c

[9] 57%c

[10] 51%c	[Yield per m2 after seedling emergence based on survival from
damping-off diseases at cotyledon or primary needle stage]

[1] 592d

[2] 702a

[3] 694ab

[4] 710a

[5] 682abc

[6] 686ab

[7] 580d

[8] 646c

[9] 670abc

[10] 662bc

[1] 20%c

[2] 55%ab

[3] 68%a

[4] 72%a

[5] 76%a

[6] 31%bc

[7] 8%c

[8] 18%c

[9] 16%c

[10] 38%bc

[1] 464

[2] 464

[3] 464

[4] 464

[5] 464

[6] 464

[7] 320

[8] 360

[9] 360

[10] 320

[1] 110

[2] 464

[3] 464

[4] 464

[5] 464

[6] 250

[7] 106

[8] 106

[9] 106

[10] 80	Enebak et al., 1990

[1] Control (no fumigation)

[2] MB (266 kg/ha) + chloropicrin (130 kg/ha)

[3] Metam sodium (485 kg/ha)

[4] Dazomet (400 kg/ha)	4 reps (w/

pon- derosa  pine in Pacific NW)	[% Mortality due to Pythium, and
Fusarium, during 1st growing season]

[1] 25%a

[2] 12%b

[3] 8%b

[4] 10%b	[# Of seedlings after 1st growing season] (per m2)

[1] 150a

[2] 300b

[3] 343b

[4] 300b

	Campbell and Kelpsas, 1988

[1] Control (no fumigation)

[2] MB (266 kg/ha) + chloropicrin (130 kg/ha)

[3] MB (580 kg/ha) + chloropicrin (285 kg/ha)

[4] Dazomet (400 kg/ha)	1 (with Douglas fir)	1st crop year:

Seedlings/m2

[1] 429

[2] 482

[3] 455

[4] 469

Weyer-haeuser #3, 1984-1987

Table C.1: Alternatives Yielda Loss Data Summary  TC "Regions A-G.
Forest Seedlings. 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	Nematodes, Weeds, Fungi	+5% to –8%	0-3% loss

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

aYield loss estimates for the forest nursery sector do not adequately
address the greater effect of seedling quality for forest plantings.
Forests planted with undersized seedlings will have reduced survival and
slowed growth if initial seedling health is compromised.  No
alternatives have been sufficiently tested to currently be substituted
for MB.

17. Are There Any Other Potential Alternatives Under Development which
Are Being Considered to Replace Methyl Bromide?  TC "Regions A-G. Forest
Seedlings. 17. Are There Any Other Potential Alternatives Under
Development which Are Being Considered to Replace Methyl Bromide?" \f C
\l "2"

According to one applicant (CUE 05-0007), “an IPM system using true
fallow, pathogen resistant cover crops, increased supplemental organic
matter applications, increased herbicide and insecticide use, and annual
chloropicrin and Telone fumigation for bareroot pine production” are
the likely alternatives that could replace MB.  Combinations of
chemicals, such as chloropicrin, metam-sodium, or 1,3-D appear to be
effective for some nurseries in reducing pest infestations, including
some weed problems (e.g., Carey, 2000; Carey, 1996; Carey, 1994;
Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10, 1994-96).  Combinations of
these compounds and application techniques (such as deep injection) to
achieve the same pest control efficiencies as MB are being studied along
with integrating non-chemical treatments, such as bed-fallow or cover
crops.  So far, none have proven cost effective and have generally
resulted in an increased input of pesticides.  Because of their physical
limitations (e.g., low vapor pressure of metam-sodium), these products
are frequently not used by nursery managers due to their lack of
consistency.  Conclusions based on individual research trials may be
skewed since large-scale production may result in greater differences
between treatments due to scale-up and different pest pressure.  In
addition, economic issues may have an impact on overall acceptability of
these alternatives for the forest seedling nursery sector.  Tests are
being conducted with methyl iodide, which has potential as a MB
replacement, although it is unknown when, or if, registration might
occur.

As MBTOC has stated in questions to the U.S. in summer, 2005, the use of
metam without tarping is not feasible due to crop injury and worker
exposure issues.  It might appear appropriate, then, to tarp the
material to prevent out-gassing problems.  However, the application of
metam followed by chloropicrin under flat-tarping, considering the large
number of hectares treated each year, is not practical or cost
effective, and currently, not technically feasible (personal
communication, International Paper [Region B]; Southern Forest Nursery
Management Cooperative [Region A]).  A three-step process would be
required, first application of metam, then chloropicrin, and finally,
application of the tarp.  Incorporation of metam using a rotovator is an
extremely slow process, and the area to be treated within a given
treatment window (determined by weather: temperature, moisture, wind) is
limited.  This window of application is generally 4-6 weeks, and even
under the best application methods, this treatment takes four times as
long to apply as the typical MB treatment.  Therefore, to treat the
necessary hectares each year would require a four-fold increase in labor
and additional available equipment in order to apply metam, chloropicrin
and cover with tarp.  According to the label, and depending on soil and
weather conditions, there would be a two to six week delay before
planting after application of metam, chloropicrin and tarp-covering.
This would affect market production costs.

The equipment needed to treat the area in spring and fall would not be
available without the purchase of four additional applicator units and
would greatly increase the cost to growers, as would the “set-up”
time for the treatment with additional machinery.  In order for tarps to
be placed on the treated metam areas, workers must return into the
treated area to lay down tarps after chloropicrin has been injected into
the soil.  In this case, out-gassing occurs, and workers must wear
personal protection equipment that is not practical given the
temperatures that normally occur at the time of application.  Nursery
growers of these regions are currently using high density films to
decrease emissions of MB, but have found that for current production VIF
is not an option due to excessive costs and technical difficulties of
gluing during application.  Nursery members of the Southern Forest
Nursery Cooperative, among others, are experimenting with VIF, but are
not able to adopt this technology for the 2008 season.

The use of virtually impermeable film (VIF) may offer a means of
reducing MB use rates while maintaining efficacy and production goals
(Carey and Godbehere, 2004).  However, in the U.S. availability of VIF
is limited and nursery applicators do not currently have experience
laying this material.  Research is being conducted to determine if this
type of film is feasible in the U. S. (e.g., does it hold up physically
in field conditions? can it be glued to acceptable specifications?, is
the cost acceptable?).  VIF manufacturers believe that technical
problems will be solved (Rimini and Wigley, 2004).  However, the
efficacy of VIF for U. S. agriculture may be different than that for
Europe (Federal Register, 1998); California does not permit the use of
VIF and costs are higher in the U.S. due to transportation and greater
areas treated.  There has been research examining the effects of certain
fertilizer salts (e.g., ammonium thiosulfate, see Gan and Yates, 1998),
which may act as barriers to volatile compounds (e.g., 1,3-D, MB) when
applied to the soil surface, thus reducing emissions and improving
efficacy, although this method is in the beginning stages of testing.

A major limitation with respect to ongoing research is the general lack
of information to accurately assess pest control in large scale,
compared to small research trials.  Topics, such as outgassing damage as
a result of metam-sodium applications and application of VIF and
associated costs, are being studied.  Technical difficulties in
extrapolating research scale plots to “real world” applications make
it difficult to transition away from MB and calculate implementation
timelines, since production consistency is frequently compromised.  As
discussed in Section 23 below, considerable research dollars have been
spent on research of MB alternatives.  However, phasing out MB for many
current uses may be foreseeable.  A combination of methods can
conceivably be used to reduce MB, but this will require several seasons
of testing and analyses.

In research plots, the reduction of MB from 98:2 to 65:35 or 50:50,
increased periods of cover crop growth, use of herbicides glyphosate
(Fraedrich and Dwinell, 2003c), and an increased use of mechanical
cultivation might reduce pest populations, and the overall use of MB.
However, nursery managers are unlikely to adopt the use of glyphosate
immediately, since it kills both hardwoods and conifers.  More research
will be necessary to devise special application technology if the use of
glyphosate is to be employed.  Experiments have indicated that some soil
amendments can reduce possible adverse growth effects of some
alternatives (e.g., dazomet).  Work in Wisconsin (Enebak et al., 1990;
Iver, undated) suggested that white pine seedlings subjected to dazomet,
but supplied with various nutrients, could reduce chlorosis sometimes
observed in dazomet treated beds.  Large scale trials will be necessary
to confirm this effect.  For disease control, studies (James et al.,
1997) comparing cultivation practices, such as till vs. no-till and
organic amendments indicate that effects vary according to the species
grown, thus each nursery may have to consider alternatives with species
and local environment in mind, unlike the more consistent effects of MB
fumigation.  Promising results in disease management have been observed
(Lantz, 1997; Stone et al., 1998) with organic amendments, but
successful weed management has not been adequately achieved.

18. Are There Technologies Being Used to Produce the Crop which Avoid
the Need for Methyl Bromide?  TC "Regions A-G. Forest Seedlings. 18. Are
There Technologies Being Used to Produce the Crop which Avoid the Need
for Methyl Bromide?" \f C \l "2"

Containerization is used for seedling production in a limited capacity
throughout the forest nursery sector.  One Michigan grower (CUE 04-0039)
produces greenhouse-grown plug plants, which are grown for 1-2 years,
then planted in beds for an additional 1-3 years.  Containers can also
be for special circumstances where species survival or an genetic value
of the planting stock make them economically feasible.  Recent surveys
indicate that of the 1.2 billion seedlings grown in the southeastern U.
S. in the 2002-2003 season, fewer than 5% were produced in containers
(McNabb and VandersSchaaf, 2003).  An estimate can be made that less
than 10% of the national forest seedling production is containerized.
Container production is used for specialty purposes, for example, to
reforest mine-spoil sites which are extremely harsh edaphic environments
requiring a soil plug system to obtain adequate seedling survival
(Lowerts, 2003).

A large investment would be necessary to shift the national production
to containerization, as well as a shift for many nurseries in the well
established protocols of growing seedlings.  According to Darrow (2002)
(also see Appendix B) the transition from bed to container production
would require additional capital and operating costs.  Investment would
be necessary for the purchases of greenhouses, container filling and
sowing machines, containers, outdoor holding areas, fertigation systems,
and new seedling transport systems both in the nursery and in the field.
 Not all sectors of seedling production would have this capital
available to them.  It is likely that smaller bareroot operations would
close and many state-run nurseries would opt to close rather than budget
state funds for such a significant capital outlay.  There is little
doubt that seedling prices could increase by up to six times current
prices.  A typical one year old bareroot seedling currently sells for
$0.04 each, while the typical container seedling of the same species
begins at $0.12 each.  In addition to an increase in seedling costs,
there are significant cost increases associated with transportation and
planting container stock.  Fewer container plants can be transported per
truck and fewer seedlings can be carried by individual tree planters.
More trucks and more fuel are needed to get seedlings to the planting
site and more labor and time are needed to plant a given area.  One
study found that daily production decreased from 9.7 ha per day with
bareroot seedlings to 7.3 ha per day with containerized seedlings, a
decrease of 25%, without increasing planting crew size (Lowerts, 2003).

The inevitable result of containerization would be a significant
increase in reforestation costs and a decrease in the rate of
reforestation.  According to the U. S. Forest Service, 48% of all
reforestation in the U. S. is done on non-industrial private lands, an
additional 42% is done on industrial lands, and 10% on government lands
(Moulton and Hernandez, 2000).  It is well established that
non-industrial forest owners are very sensitive to reforestation costs,
decreasing their investment in direct proportion to increasing costs
(Hardie and Parks, 1991; Royer, 1987).  Given the importance of
non-industrial owners on the general timber supply, a reduction in
reforestation efforts by this group may have serious long-term negative
impacts on the sustainability of the forest economy.  Industrial owners
will also be negatively impacted by increased reforestation costs as raw
material costs will increase (typically about 40-60% of the cost of
final fiber products), impacting the competitiveness of their industry.

Conclusion:  The infrastructure investment necessary for
containerization is enormous and would probably force many nurseries out
of business.  Seedling production costs would increase, resulting in
seedling price increases of over 250%.  New transportation and planting
systems would have to be adopted.  Reforestation costs would go up
significantly and probably result in fewer non-industrial forest owners
reforesting after harvest.  The potential long-term effect of these
changes on the forestry economy is enormous.  Overall, containerization
would result in a significant increase in seedling production,
transportation, and planting costs and would most likely decrease
reforestation rates.

Summary of Technical Feasibility  TC "Regions A-G. Forest Seedlings.
Summary of Technical Feasibility" \f C \l "2"

This nomination includes requests for MB for those nurseries where
sufficient pest control can not be achieved otherwise.  While
combinations of chemicals, such as chloropicrin, metam-sodium, and 1,3-D
appear to be effective for some nurseries in reducing pest infestations,
including some weed problems (e.g., Carey, 2000; Carey, 1996; Carey,
1994; Weyerhaeuser, #8, 1992-95; Weyerhaeuser, #10, 1994-96), currently
all nurseries 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 use of a formulation with
chloropicrin and use of VIF).  Its overall use may be limited by local
legal restrictions and pest-free permit requirements, and VIF has
technical problems and is restricted in California (e.g., Carey, 1996;
Carey, 1994; Weyerhaeuser #10, 1994-96).  In addition, economic issues
such as application costs may have an impact on overall acceptability of
these alternatives for the forest seedling nursery sector.

Recent studies with dazomet in Georgia and North Carolina nurseries
(Fraedrich and Dwinell, 2003b) and glyphosate (Fraedrich and Dwinell,
2003c) suggest that both might have potential as nutsedge treatments,
but will be used in seedling production after research can “…better
define the optimal use conditions”.  However issues remaining
preventing immediate implementation.  For example, seedling nurseries
have stated that forest tree seedlings cannot be exposed to glyphosate
as the herbicide kills both hardwood and conifer species (personal
communication, International Paper [Region B]; Southern Forest Nursery
Management Cooperative [Region A]).  While ‘shielded sprayers’ with
glyphosate have been tested in small trials, seedling mortality from
over-spray does occur.  An International Paper nursery, for example,
will typically produce 300 million seedlings per year, and so, even 1%
mortality due to herbicide sprays could result in significant seedling
loss.  Consequently, glyphosate would not be an option to control
nutsedge in nursery beds.

Statistically analyzed trials measuring quantity and quality losses due
to specific pests (e.g., weeds or pathogens) are not readily available.
More commonly found are trials indicating overall yield (and sometimes
quality assessments), allowing a comparison of treatments based on
yield, but making it difficult to ascribe losses to particular pests.
This is particularly a problem since the numerous forest seedling
nurseries can experience various problems unique to the combination of
climate, soil, seedling species, market forces, and customer base (e.g.,
public vs. private nursery, or commercial vs. recreational end uses).
Overall yield losses with the best alternatives, compared to MB, were
estimated at 0-3% based on research data.  In estimating the yield of
alternatives in comparison to MB, it should be remembered that these
figures are for the general case, and individual nurseries will likely
experience greater or lesser efficacy with a given treatment, depending
on soil, climate, production practices, market requirements, species of
seedling, etc.  The yield estimates listed in Table C.1 are based on
research results described in Section 16.  Quality factors are as
important in this industry as yield, and may affect the efficacy of a
given alternative beyond considerations of yield alone (e.g., “Percent
‘Healthy Root Tips’” in Table 16.1B, Enebak et al., 1990).

Larger seedling size and improved seedling vigor translate to improved
reforestation success and increased growth rate of young plantations.
This positive contribution to reforestation is well documented for
seedlings produced in MB fumigated soil.  Increases in seedling size and
quality resulting from fumigation with MB alternatives have been
variable.  The long-term impact on reforestation success with
alternatives is not known.  An important factor is the long-term
implication associated with forest growth and health over a 20-40 year
period of forest life.  Seedling quality has been highly correlated with
productive and healthy forests impacting both commercial and public
interests.

The industry is continuing to sponsor research alternatives and test
improved chemical application technologies to increase the efficacy of
some of the most viable alternatives.  The use of metam without tarping
is not feasible due to crop injury and worker exposure issues.  However,
the application of metam followed by chloropicrin under flat-tarping,
considering the large number of hectares treated each year, is not
practical or cost effective either, and currently, not technically
feasible (personal communication, International Paper [Region B];
Southern Forest Nursery Management Cooperative [Region A]).  A
three-step process would be required—first, application of metam, then
chloropicrin, and finally, application of the tarp.  Incorporation of
metam using a rotovator is an extremely slow process, and the area to be
treated within a given treatment window (determined by weather:
temperature, moisture, wind) is limited.  This window of application is
generally 4-6 weeks, and even under the best application methods, this
treatment takes four times as long to apply as the typical MB treatment.
 Therefore, to treat the necessary hectares each year would require a
four-fold increase in labor and additional available equipment in order
to apply metam, chloropicrin and cover with tarp.  According to the
label, and depending on soil and weather conditions, there would be a
two to six week delay before planting after application of metam,
chloropicrin and tarp-covering.  This would affect market production
costs.

The equipment needed to treat the area in spring and fall would not be
available without the purchase of four additional applicator units and
would greatly increase the cost to growers, as would the “set-up”
time for the treatment with additional machinery.  In order for tarps to
be placed on the treated metam areas, workers must return into the
treated area to lay down tarps after chloropicrin has been injected into
the soil.  In this case, out-gassing occurs, and workers must wear
personal protection equipment that is not practical given the
temperatures that normally occur at the time of application.  Nursery
growers of these regions are currently using high density films to
decrease emissions of MB, but have found that for current production VIF
is not an option due to excessive costs and technical difficulties of
gluing during application.  Nursery members of the Southern Forest
Nursery Cooperative, among others, are experimenting with VIF, but are
not able to adopt this technology for their 2007 production.

MB 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 advanced enough to rely on in the
foreseeable future.  Research with organic and inorganic soil amendments
(Fraedrich and Dwinell, 1998; James et al., 1997; James et al., 2001;
Lantz, 1997; Stone et al., 1998) have had some successes under certain
conditions, but the effects appear to be variable depending on the
nursery locations and species of seedlings.  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"

The Forest Seedlings sector has reduced its MB consumption through
several techniques developed over the past several years.  First, the
sector has incorporated the use of high-density polyethylene (HDPE) tarp
material that has helped increase fumigation efficiencies and reduced
application rates.  HDPE increases MB soil residence time, increasing
efficiency and reducing application rates.  VIF is likely to be an
important means of further reducing emissions if a method can be
developed to efficiently glue overlapping sheets of VIF film (e.g.,
Carey and Godbehere, 2004).  VIF film becomes impractical if adjacent
overlapping sheets cannot be glued.  In addition, there is a problem
with film breakage during application.  Suppliers believe technical
problems can be fixed (Rimini and Wigley, 2004), however, currently
regulations prevent the use of VIF in California.

Second, MB fumigation in the forest seedlings sector increasingly has
been made using deep injection that places the material deeper into the
soil than previously.  Deeper placement contributes to longer residence
time in the soil and greater application efficiency.  This has been
accomplished at considerable capital investment on the part of
applicators.

Third, forest seedlings nurseries have increased the percentage of
chloropicrin in fumigation mixtures.  While 98% MB and 2% chloropicrin
was the most widely used compound a few years ago, a 66:33 formulation
is now more common, especially in areas without heavy nutsedge
infestations.  Growers still applying 98:2 formulations, such as
International Paper, are currently examining the effects of 66:33 in
their nursery trials.  Some efficiency in weed control has been
sacrificed by this change in procedure, however, and higher
concentrations of chloropicrin become increasingly less satisfactory as
weed pressure, particularly nutsedge, increases.  Some nurseries are
investigating use of herbicides as an economic means of weed control
(e.g., Fraedrich and Dwinell, 2003c; Northeastern Consortium request,
Worksheet 4).