USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 1 of 17



### NOMINATING PARTY: The United States of America

FILE NAME: USA CUN11 SOIL FOREST SEEDLING NURSERIES Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Forest Seedling Nurseries in Open Fields (Submitted in 2009 for 2011 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Forest Seedling Nurseries Open Field

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION



### Year N OMINATION 

### A MOUNT 

### 2011 106,043 kilograms

NOMINATING PARTY CONTACT DETAILS: Contact Person: Hodayah Finman Title: Foreign Affairs Officer Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2658 Washington, D.C. 20520
U.S.A. Telephone: (202) 647-1123 Fax: (202) 647-5947
E-mail: finmanhh@state.gov

Following the requirements of Decision IX/6 paragra ph (a)(1) The United States of America has determin ed that the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for
this use would result in a significant market disru ption. 

## ■ Yes  No

Signature Name Date

Title:

(Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat we bsite under Decision Ex. I/4(8).)

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation on which the Party’s first-year exemption was approved , as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Pa rty need not re-submit that earlier information.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 2 of 17



### CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: Contact/Expert Person: Jack Housenger Title: Director (Acting) Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460
U.S.A. Telephone: (703) 308-8200 Fax: (703) 308-7042
E-mail: Housenger.Jack@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:
1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozone
Secretariat
USA CUN11 SOIL FOREST SEEDLING NURSERIES Open Field 17

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat
USA CUN11 SOIL FOREST SEEDLING NURSERIES Open Field

* Identical to paper documentsUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 3 of 17



## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE (OPEN FIELD OR PROTECTED ENVIRONM ENT)

FOREST SEEDLING NURSERIES

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICA L USE

Forests are increasingly important as challenges to the environment have global implications. The first step in forest establishment is the produ ction of tree seedlings by forest tree nurseries. These nurseries provide healthy starting material f or newly planted forests. The U.S. nomination is for those nurseries where registered alternative s are not effective or sufficiently tested to enable commercial use. This comprises much of fore st seedling nursery production land. The use of methyl bromide is considered critical where alternatives are not suitable because of regulatory, economic, or technical constraints.

Of the registered alternatives, iodomethane may off er forest seedling nurseries (except in Washington where it is not registered) the most imm ediate hope as a replacement of methyl bromide. The main concern regarding adopting this newly registered product is the lack of testing that has been done for this sector. Uncert ain use rates, formulation type, application techniques, certification questions, and only now, the beginning of technology to allow gluing high barrier films has impeded a wholesale move to iodomethane for the short-term. The U.S. believes a transition period is necessary to resolv e these issues.

Inconsistency in overall pest management performanc e by some alternatives (e.g. metam-sodium and dazomet) has been the primary concern for this sector, and the reason that methyl bromide
continues to have some critical use. While direct yield losses, in terms of seedlings/hectare, may not be large on average, intensive seedling product ion relies on the ability of nursery managers to meet quality and yield goals as well as certificati on that plants are essentially pest-free.

Effective fumigation can 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 ). Nutsedge species are generally considered among the major pests of forest seedling nurseries in the eastern U.S. and the pests most difficult to ma nage.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

For the 2011 use season, methyl bromide remains a c ritical need for forest seedling nurseries to produce plants free of pests in order to meet state certification standards, as well as customer expectations. The use protocols for the effective alternatives have not been developed sufficiently to provide effective control of the ke y pests to depths of 1 m. In addition, there are few, if any, markets for plants that do not meet th e certification standards, which mean thatUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 4 of 17



### losses up to 100% are possible when inadequate pest control occurs. Failure to adequately manage pests in transplants will jeopardize the via bility of the planted forests.

A new registration for iodomethane presents an addi tional alternative (it is currently registered in all states except California, New York, and Washing ton). Before iodomethane replaces methyl bromide for forest seedling production it will have to be accepted as an appropriate treatment for pest-free certification. Iodomethane use rates and formulations (98:2 or 50:50) are being tested by seedling nurseries to determine what rates are t he most effective and cost-feasible. Chloropicrin appears to be a possible alternative, but strict regulations make its future uncertain when used at the high rates that have been shown to be effective (South, 2007; Enebak, 2007).

According to nursery specialists from requesting co nsortia (Enebak, 2008; Lowerts, 2008; Talbert, 2008; Overton, 2008), iodomethane holds pr omise as an effective alternative to methyl bromide. However, the following comments highlight concerns by nursery experts of potential problems with a transition to iodomethane for the f orest seedling nursery industry:

• Research has been scant for testing the efficacy of iodomethane in forest seedling nurseries. One two-year study conducted in the sou theast U.S. (Starkey et al., 2007) indicated that the size of pine seedlings with iodo methane were similar to that with methyl bromide for both years. Weed populations we re significantly greater in one of the two years of the study. There is a need to val idate the studies to determine if iodomethane manages weed populations sufficiently f or commercial production.

• The limited number of field studies that have been conducted is not sufficient to
confirm that iodomethane is a suitable alternative to methyl bromide; the industry cannot afford to risk production until the new prod uct is rigorously tested. One
consortium stated that “most researchers consider 3 years of trials over several locations are needed to develop reliable data for p esticide guidelines.” Trials for this sector have not been completed or reported. Trials conducted in the northeast are limited to a few vegetable crops with custom applic ators from outside the region.

• Research trials with iodomethane conducted in Washi ngton (where iodomethane is not currently registered for commercial use) have f ound encouraging results.

• Cost estimates for the southeast for application an d tarp removal of 350 lb/acre [392 kg/ha] of 98:2 methyl bromide was approximately $4, 450 per hectare. The cost of 175 lb/acre [196 kg/ha] of 98:2 iodomethane was app roximately $6,280 per hectare. Cost in the northeast for iodomethane products rang e from $15 per kg (50:50) to $20 per kg (98:2). This compares to $7 per kg for meth yl bromide (98:2). Estimated costs of fumigation per hectare for northeastern nu rseries average $8,300 for iodomethane (98:2), $10,500 for iodomethane (50:50) , and $4,820 for methyl bromide (98:2). If these cost differences are main tained the industry would find iodomethane to be economically infeasible.

• Regional fumigation contractors do not currently ha ve the equipment to broadcast iodomethane. According to the iodomethane label, “The treated ground must beUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 5 of 17 

### sealed using closing shoes, roller, compaction roll er, cultipacker or other equivalent equipment that will sufficiently cover chisel marks left after soil injection. The equipment shall cover the chisel marks with soil im mediately prior to the placement of the tarpaulin being laid down (with fumigant inj ection) by tarpaulin-laying equipment mounted on the application tractor.” Demand for the product may change this situation, but the industry is not able curren tly to broadcast iodomethane.

• Use of iodomethane resulted in a reduction of benef icial Trichoderma fungi populations in soil 12 and 18 months following trea tment in both years of a two-year study (Starkey et al., 2007). This effect will hav e to be confirmed by additional studies, but would result in long-term reduced prod uction quality.

• Methyl bromide is accepted by state control boards as meeting phytosanitary requirements for nursery shipments. Iodomethane wi ll require the same acceptance, but as yet, this certification standard has not bee n addressed by the registrant of iodomethane or state regulators.

• According to the consortium representing northeast nurseries, Arysta (manufacturer of MIDAS iodomethane) has no representatives or dea lers of the iodomethane product in northeastern states.

• The iodomethane label (MIDAS) does not make clear i f use is allowed for production of deciduous tree seedlings (“ strawberries, stone fruits, tree nuts, and conifer trees ”). Deciduous seedlings are generally more valuable tha n conifer seedlings and have greater pest management requirements.

3. IS THE USE OF METHYL BROMIDE COVERED BY A CERTIF ICATION
STANDARD?

This sector is covered by certification requirement s. All states have certification standards and all nurseries have additional internal quality cont rol standards as well (NPB, 2008 for summaries of nursery plant regulations for all states). USDA -APHIS has guidelines for containment of sudden oak death through movement of nursery materi al (USDA-APHIS, 2004). An example from Mississippi, “All nursery stock shipped into M ississippi must carry on each container or bundle a valid nursery inspection tag (inspection c ertificate) of the State of origin. Containers should also be plainly marked with the names and ad dresses of shipper and consignee” (MDAC, 2003). Similarly from Alabama, “Nursery stock ente ring the State of Alabama must be certified as being apparently free from plant pests. Certifi cate tags issued by the official certifying agency of the state of origin stating such must be firmly attached to each box, bundle or package of nursery stock moved into the state” (ADAI, 2004). In addition, “No inspection certificate shall be issued for the sale, offering for sale, or movem ent of any nursery stock until the stock in question shall have been inspected by the Commissio ner and found to be apparently free from seriously injurious plant pests” (ADAI, 2004). Oth er states have similar regulations (NPB, 2008).USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 6 of 17



### 4. IF 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 W HAT ALTERNATIVE STRATEGIES ARE USED TO
CONTROL THE TARGET PATHOGENS AND WEEDS W ITHOUT METHYL
BROMIDE THERE.

All nurseries currently treat production beds with methyl bromide due to certification and production requirements. Where weeds are of primar y pests, methyl bromide has been the most effective treatment and accepted by state inspector s. Methyl bromide allows conifer seedling beds to be fumigated after two or three crops (as o pposed to after every crop) because of the effectiveness of methyl bromide, which usually make s a second-year treatment unnecessary. Iodomethane is a new fumigant and may be an effecti ve alternative, but multi-season information on its use for forest nurseries is lacking.

5. 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?

Preliminary results of research suggest iodomethane has value as a replacement for methyl bromide, but it first must be tested to prove effic acy and acceptability for certification. In addition, as with all new products, adjustment of u se rates and application experience with iodomethane will require a few seasons where nurser ies can transition from methyl bromide, assuming costs do not limit the use of iodomethane.

6. SUMMARY OF RECENT RESEARCH

The amount of methyl bromide nominated for 2011 has been reduced from the previous
nomination. This is due to a reduction in rates or a change in the proportion of methyl bromide in the formulation by some nurseries. Impacts for nurseries that have a critical need for methyl bromide would be significant without the fumigant f or 2011. Research is ongoing to develop commercially feasible protocols for likely alternat ives, such as iodomethane, 1,3-D and chloropicrin, chloropicrin, and/or metam-sodium.

Research with low permeability films and methods to glue them for broadcast fumigation appears to be progressing towards resolving technic al problems. The feasibility for commercial broadcast with high barrier films is still question able. The standard width of film used in the nursery industry (400 cm) is not available for the film that currently can be glued, which may slow adoption, according to a representative of Pli ant Corporation, a major manufacturer of high
barrier films in the U.S. Research trials with VIF have primarily been conducted with bed, rather than the standard broadcast fumigation due to probl ems gluing film. Glues are apparently proprietary and manufacturing information is diffic ult to attain. Ajwa (2008) reported some preliminary successes in strawberry research trials gluing VIF and totally impermeable film (TIF). He cited reports that researchers in Florid a had had difficulty gluing TIF.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 7 of 17



### In 2008, iodomethane was registered in all states r equesting a critical use of methyl bromide, except Washington, for use in forest seedling nurse ries. Unfortunately, research on iodomethane use for this industry is minimal and rates, formula tion, and application techniques will have to be optimized for commercial applications. The registr ant, Arysta, has not yet completed work to support pest-free certification with the product. Fumigant trials have been conducted with conifers, not hardwoods, which constitute a valuabl e portion of many nurseries.

• In a two-year study conducted in Georgia, Starkey e t al. (2007) found that iodomethane:chloropicrin (168 kg/ha of 98:2) produc ed seedlings with characteristics (density, diameter, height, root and shoot biomass) comparable to methyl bromide-treated beds. Methyl bromide and chloropicrin (168 kg/ha o f 98:2) with VIF produced seedlings comparable to methyl bromide:chloropicrin (336 kg/h a of 98:2) with standard films. Weeds in iodomethane-treated beds were comparable t o methyl bromide in a 2006 trial and more than in methyl-bromide-treated beds in a 2 005 trial. This was attributed to the rate of iodomethane that was used. The regeneratio n of the beneficial fungus
Trichoderma was reduced under VIF and with iodomethane treatme nts compared to methyl bromide.

• Quicke et al. (2008) studied two nursery sites in S outh Carolina. Randomized blocks were treated with one of seven fumigants (98:2 meth yl bromide at both 450 kg/ha and 264 kg/ha; 70:30 methyl bromide at 450 kg/ha; Pic+ at 336 kg/ha; chloropicrin at 336 kg/ha; Chlor60 at 450 kg/ha; DMDS/Pic at ~820 kg/ha ). At both sites, all treatments provided comparable seedling densities. No nematod es were detected in any fumigated
soil. Trichoderma populations were greatest in soil that had been tr eated with a high rate of chloropicrin.

• Results from experiment-sized plots conducted in Mt . Vernon Research Center, Washington (Talbert, 2008) in 2007 in cooperation w ith USDA, found that iodomethane treatments generally provided acceptable weed and p athogen control. Concerns were raised about the effectiveness of spring fumigation with iodomethane and consistency throughout different locations. Additional testing is planned for western nurseries and two to three seasons is considered necessary to gau ge efficacy and feasibility.

• Research (Weiland et al., 2008) to study the effica cy of reduced doses of fumigants (methyl bromide, iodomethane, and DMDS) under VIF a nd their effects on soil pathogens and weeds is underway in Oregon and Washi ngton. Trials will be analyzed in
the fall of 2009.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

Please note that in this study net revenue is calcu lated as gross revenue minus operating costs. This is a good measure as to the direct losses of i ncome that may be suffered by the users. It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability of an operation for an ente rprise, is gross revenue minus the sum ofUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 8 of 17



### operating and fixed costs. Net income is smaller t han the net revenue measured in this study, often substantially so. We did not include fixed c osts because they are difficult to measure and verify.

The economic analysis of the tomato application com pared data on yields, crop prices, revenues and costs using methyl bromide and using alternativ e pest control regimens in order to estimate the loss of methyl bromide availability. The alter natives identified as technically feasible - in cases of low pest infestation 1 

### – for different regions by the U.S. are: (a) Iodom ethane and (b) 1,3- Dichloropropene and Chloropicrin followed by Metam sodium (otherwise referred to as the Georgia 3-Way).

The economic factors that really drives the feasibi lity analysis for nursery stock production uses of methyl bromide are: (1) yield losses, referring to reductions in the quantity produced, (2) increased production costs, which may be due to the higher-cost of using an alternative, additional pest control requirements, and/or result ing shifts in other production or harvesting practices (3) quality losses, which generally affec t the quantity and price received for the goods, and (4) missed market windows due to plant back tim e restrictions, which also affect the quantity and price received for the goods.

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

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

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

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

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

(5) Operating Profit Margin . We define operating profit margin to be net oper ating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an en terprise. Again, operating costs may be

1 

### It should be noted that the USG does not request m ethyl bromide for use in areas of low to moderate pest pressure. Only cases where key pests are present at moderate to high levels require methyl bromide for pest pressure.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 9 of 17



### difficult to measure and fixed costs even more diff icult, therefore fixed costs were not included in the analysis.

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

The economic analysis of the forest seedling applic ation compared data on costs using methyl bromide and using the next best alternative pest co ntrol regimen, iodomethane, in order to estimate the loss of methyl bromide availability.

The economic reviewers then analyzed crop budgets f or forest seedlings to determine the likely economic impact if methyl bromide were unavailable. Various measures were used to quantify the impacts, including the following:

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

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

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

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

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

These measures represent different ways to assess t he economic feasibility of methyl bromide alternatives for methyl bromide users, who are fore st seedling producers in this case. Because producers (suppliers) represent an integral part of any definition of a market, we interpret the threshold of significant market disruption to be me t if there is a significant impact on commodity suppliers using methyl bromide. The economic measu res provide the basis for making that
determination.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 10 of 17



### The results of the analysis of methyl bromide compa red to iodomethane are shown in Tables 2 - 6 below. Iodomethane, is assumed to provide the sa me yields as methyl bromide. Therefore, the only losses shown in the tables below as a result o f methyl bromide not being available are increased fumigation and hand weeding costs. Since one study (Starkey et al., 2007) indicated increased weed pressure with iodomethane compared t o methyl bromide, almost $800 per hectare per year was added for hand weeding costs w ith the use of iodomethane.

Please note, that the yields, revenues, and costs i n Tables 2-6 below are averages per year over fumigation cycles of 2 – 4 years. Most of the yiel ds, revenues, and costs occur 1 – 2 years out of 2 – 4 fumigation cycles, while fumigations are usua lly done once during the fumigation cycle and sometimes twice for certain species. Since the costs are average annual costs, the increased
costs will be less than the full increased cost of a single iodomethane fumigation compared to methyl bromide.

Also, revenues and costs will vary between regions due to different yields, species, and cultural and fumigation practices.

Furthermore, these tables do not show other possibl e losses discussed earlier in this nomination and summarized below, which include:

• Efficacy . While the analysis of economic feasibility assum ed equal yields, the limited
number of field studies that have been conducted is not sufficient to confirm that iodomethane has equal efficacy as methyl bromide. If efficacy is not equal there could be impacts on seedling quality and forest health.

• Forest Health. Seedlings free of pathogens and other pests help es tablish forests with less pest pressure, thus resulting in faster growth and less use of pesticides.

• Certification . Methyl bromide is accepted by state control boar ds as meeting phytosanitary requirements for nursery shipments. Iodomethane will require the same acceptance, but as yet, with limited efficacy studi es, this certification standard has not been established. There are few, if any, markets f or plants that do not meet the certification standards, which mean that losses up to 100% are possible when inadequate pest control occurs.

• Equipment

. Regional fumigation contractors and nurseries do no t currently have the equipment to broadcast iodomethane. Demand for the product may change this situation, but the industry is not able currently to broadcast iodomethane.

• Deciduous trees . The iodomethane label (MIDAS) does not make clear if use is allowed for production of deciduous tree seedlings, which a re generally more valuable than conifer seedlings and have greater pest management requirements.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 11 of 17

T ABLE 2 S OUTHERN F OREST N URSERY M ANAGEMENT C OOPERATIVE : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

S OUTHERN F OREST N URSERY M ANAGEMENT C OOPERATIVE M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%
Yield (seedling) per Hectare Pine 779,617 779,617 * Price per Unit (U.S. $/seedling) $0.05 $0.05
Gross Revenue per Proportion (88% of seedlings; 72% of acres) $25,234 $25,234
Yield (seedling) per Hectare Longleaf Pine 423,785 423,785 * Price per Unit (U.S. $/seedling) $0.09 $0.09
Gross Revenue per Proportion (3% of seedlings; 5% of acres) $1,759 $1,759
Yield (seedling) per Hectare Hardwood 243,399 243,399 * Price per Unit (U.S. $/seedling) $0.25 $0.25
Gross Revenue per Proportion (9% of seedlings; 24% of acres) $14,337 $14,337

= G ROSS R EVENUE PER H ECTARE ( US $) $41,330 $41,330

− O PERATING C OSTS PER H ECTARE ( US $)** $23,401 $24,648

= N ET R EVENUE PER H ECTARE ( US $) $17,929 $16,682

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,248

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $15

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 3%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 7%

5. O PERATING P ROFIT M ARGIN (%) 43% 40%

** Note that the measures in this table must be int erpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating co sts.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 12 of 17

T ABLE 3. A RBORGEN : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

ARBORGEN M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%

Y IELD (S EEDLINGS ) PER H ECTARE 741,315 741,315

* P RICE PER U NIT ( US $) $0 $0.05

= G ROSS R EVENUE PER H ECTARE ( US $) $33,997 $33,997

− O PERATING C OSTS PER H ECTARE ( US $)** $20,946 $22,250

= N ET R EVENUE PER H ECTARE ( US $) $13,051 $11,747

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,304

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $20

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 4%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 10%

5. O PERATING P ROFIT M ARGIN (%) 38% 35%

** Note that the measures in this table must be int erpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating co sts.

T ABLE 4. W EYERHAEUSER : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

WEYERHAEUSER M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%

Y IELD (S EEDLINGS ) PER H ECTARE 55,006 55,006

* P RICE PER U NIT ( US $) $0 $0

= G ROSS R EVENUE PER H ECTARE ( US $) $17,932 $17,932

− O PERATING C OSTS PER H ECTARE ( US $)** $12,131 $13,155

= N ET R EVENUE PER H ECTARE ( US $) $5,801 $4,777

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,024

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $22

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 6%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 18%

5. O PERATING P ROFIT M ARGIN (%) 32% 27%

** Note that the measures in this table must be int erpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating co sts.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 13 of 17

T ABLE 5. N ORTHEASTERN F OREST AND C ONSERVATION : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

N ORTHEASTERN F OREST AND C ONSERVATION M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%
Yield (seedling) per Hectare Conifer (1-0) 247,105 247,105 * Price per Unit (U.S. $/seedling) $0.26 $0.26
Gross Revenue per Proportion (8% of acres) $5,140 $5,140
Yield (seedling) per Hectare Conifer (2-0) 185,329 185,329 * Price per Unit (U.S. $/seedling) $0.26 $0.26
Gross Revenue per Proportion (4% of acres) $1,927 $1,927
Yield (seedling) per Hectare Conifer (3-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.35 $0.35
Gross Revenue per Proportion (14% of acres) $6,054 $6,054
Yield (seedling) per Hectare Deciduous Trees (1-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.32 $0.32
Gross Revenue per Proportion (55% of acres) $21,745 $21,745
Yield (seedling) per Hectare Deciduous Trees (2-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.37 $0.37
Gross Revenue per Proportion (9% of acres) $4,114 $4,114
Yield (seedling) per Hectare Deciduous Shrubs (1-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.29 $0.29
Gross Revenue per Proportion (10% of acres) $3,583 $3,583

= G ROSS R EVENUE PER H ECTARE ( US $) $42,564 $42,564

− O PERATING C OSTS PER H ECTARE ( US $)** $31,879 $33,418

= N ET R EVENUE PER H ECTARE ( US $) $10,684 $9,146

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,538

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $16

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 4%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 14%

5. O PERATING P ROFIT M ARGIN (%) 25% 21%

** Note that the measures in this table must be int erpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating co sts.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 14 of 17

T ABLE 6. M ICHIGAN S EEDLING A SSOCIATION : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

M ICHIGAN S EEDLING A SSOCIATION M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%
Yield (seedling) per Hectare Conifer Seedlings 963,710 963,710 * Price per Unit (U.S. $/seedling) $0.14 $0.14
Gross Revenue per Proportion (60 % of acres) $80,952 $80,952
Yield (seedling) per Hectare Conifer Transplants 74,132 74,132 * Price per Unit (U.S. $/transplant) $0.60 $0.60
Gross Revenue per Proportion (10% of acres) $4,448 $4,448
Yield (seedling) per Hectare Deciduous Seedlings 296,526 296,526 * Price per Unit (U.S. $/seedling) $0.50 $0.50
Gross Revenue per Proportion (30% of acres) $44,479 $44,479

= G ROSS R EVENUE PER H ECTARE ( US $) $129,878 $129,878

− O PERATING C OSTS PER H ECTARE ( US $)** $90,235 $91,898

= N ET R EVENUE PER H ECTARE ( US $) $39,644 $37,980

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,663

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $6

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 1%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 4%

5. O PERATING P ROFIT M ARGIN (%) 31% 29%

** Note that the measures in this table must be int erpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating co sts.USA CUN11 SOIL Forest Seedling Nurseries Open Field Page 15 of 17



### 8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTI TIES

T ABLE 

### 7. N OMINATION 

### A MOUNT

Southern Forest Nursery International

Paper Weyer- haeuser

(SE) Weyer- haeuser

(NW) NE Forest &

Conserv. Nursery Michigan

Seedling Assoc. Sector Total / Average

Quantity Requested for 2010: Amount (kgs) 66,340 5,050

13,889

15,302

13,971

6,301

120,853

Quantity Recommended by
MBTOC/TEAP for 2010 : Amount (kgs) 66,300 4,940

13,780

15,190

12,096

5,520

117,826

Amount (kgs) 66,300

4,940

13,780

15,190

12,096

5,520

117,826
Area (ha) 255

19

53

72

47

21

467

Rate 260

260

260

211

257

263

252

Transition from 2010 Baseline Adjusted Value Percentage (%) -10% -12% -11% -11% -22% -21% -12%

Amount (kgs) 59,670

4,446

12,402

13,671

10,886

4,968

106,043

Area (ha) 230 17 48 65 42 19 421

Rate 259 262

258

210

259

261

252 

### 2011 Methyl Bromide Usage Newer Numerical Index (BU NNI)
Transition Use Reduction Description Spreadsheet

Quantity Required for
2011 Nomination: Quantity Approved by Parties

for 2010: SECTOR FOREST SEEDLINGSUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 16 of 17



### CITATIONS

ADAI (Alabama Department of Agriculture and Industr ies). 2004. Chapter 80-10-1, Nursery and Nursery Stock. Plant Industry Administrative Co de. http://www.msapms.org/new/newsletters/Nursery%20and %20Nursery%20Stock%20Regula tions_New.pdf

Ajwa, H. 2008. Personal communication, original em ail to S. Weiss, SRRD-OPP, EPA, November 20, 2008.

Enebak, S. 2008. Personal communication, email to L. Yourman, October 28, 2008.

Enebak, S. 2007. Personal communication, email to L. Yourman, Aug. 16, 2007.

Enebak, S., Starkey, T., and McCraw, D. 2006. Tree seedling quality and weed control with Basimid, MBR and methyl iodide. Annual Internationa l Research Conference on Methyl
Bromide Alternatives. http://www.mbao.org/2006/06Proceedings/040StarkeyTM BAOMIMBrBasamidTES.pdf

Lowerts, G. 2008. Personal communication (ArborGen ), email to L. Yourman, October 29,
2008.

MDAC (Mississippi Department of Agriculture and Com merce). 2003. Summary of plant protection regulations.Bureau of Plant Industry, Pl ant Pest Division.
http://nationalplantboard.org/docs/mississippi.doc 

### . Moulton, R. J. and Hernandez, G. 2000. Tree planting in the United States, 1998. Tree Planters Notes V49(2). USDA Forest Service. pp
1-36.

NPB (National Plant Board). 2008. Laws and Regula tions. http://www.nationalplantboard.org/laws/index.html

Overton, R. 2008. Personal communication (Purdue University, NE Area Regeneration Specialist, email to L. Yourman, October 31, 2008.

Quicke, M., Starkey, T., and Enebak, S. 2008. 2008 Area-wide demonstration of alternatives:
Forest nurseries in the southern U.S. Annual Inter national Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008 ).

South, D. B. 2007. Chloropicrin as a soil fumigatio n treatment in southern pine nurseries. Southern Journal of Applied Forestry 31(1):47-51.

Starkey, T., Enebak, S., and McCraw, D. 2007. Seedl ing quality and weed control with dazomet, methyl bromide and methyl iodide at the Glennville Regeneration Center 2005-2006. Research Report 06-05, Southern Forest Nursery Mana gement Cooperative, Auburn, AL. also, http://www.mbao.org/2006/06Proceedings/040StarkeyTM BAOMIMBrBasamidTES.pdf 

### ; http://mbao.org/2006/06PowerPoints/MBAO%20PDFs/Prep lant/7%20- %20Ornamentals,%20Tree%20Crop%20and%20Forest%20tree %20Nurseries/Starkey.pdfUSA CUN11 SOIL Forest Seedling Nurseries Open Field Page 17 of 17



### Talbert, C. B. 2008. Personal communication with D irector of Forestry and Regeneration , Weyerhaeuser Corporation, Western Timberlands. Oct ober 31, 2008.

USDA-APHIS (Animal and Plant Health Inspection Serv ice), Plant Protection and Quarantine. 2004. Sudden Oak Death. Amended order restricting movement of nursery stock from
California nurseries.. http://www.aphis.usda.gov/ppq/ispm/pramorum/pdf_fil es/sodorder4-22-04signed.pdf



### Weiland, J., Pinkerton, J. N., Littke, W., Browning , J., Masters, C., Rose, R., Haase, D., Miller, T., Edmonds, B. and Leon A. 2008. Methyl bromide alternatives in Oregon and Washington forest tree nurseries. Annual Internatio nal Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008 ).