### NOMINATING PARTY: T HE 

### U NITED 

### S TATES OF 

### A MERICA



### FILE NAME: USA CUN12 SOIL ORNAMENTALS Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Preplant Soil Use for Ornamentals Grown in Open Fields (Submitted in 2010 for 2012 Use Season)

CROP NAME: Ornamentals 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 

### (K ILOGRAMS 

### )

2012 48,164



### NOMINATING PARTY CONTACT DETAILS: Contact Person: John Thompson
Title: Division Director 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) 647-9799 Fax: (202) 647-5947
E-mail: thompsonje2@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the specific use detailed in this Critical Use Nomination is critic al because the lack of availability of methyl bromide for

this use would result in a significant market disruption. 

## ■ Yes  No

Signature Name Date

Title:

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

This form is to be used by holders of single-year exemptions to reapply for a subsequent year’s exemption (for example, a Party holding a single-year exem ption for 2005 and/or 2 006 seeking further exemptions for 2007). It does not replace the format for requesting a critical-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination 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 Party need not re-submit that earlier information.

USA CUN12 SOIL Ornamentals Open Field Page 1 of 19

### CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
Contact/Expert Person: Jack E. Housenger
Title: Director 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: jack.housenger@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 CUN12 SOIL ORNAMENTALS Open Field 18

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

USA CUN12 SOIL ORNAMENTALS Open Field

* Identical to paper documents

USA CUN12 SOIL Ornamentals Open Field Page 2 of 19

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

ORNAMENTALS

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

This renomination is for methyl bromide for th e production of ornamentals. The ornamental sector consists of cut flowers, cut greens, and bulb s in California and floriculture in Florida. All data comes from the applicants’ requests unless otherwise cited.

The USG has reviewed all factor s affecting transition rates in this sector. Based on this assessment the transition rate has been greatly incr eased for most portions of this sector. For the area covered in this nomination, the USG believes that the narrative discussion included in this document is technically valid. The USG has nomi nated amounts of methyl bromide based only on those sub-sectors that cannot transition away from methyl bromide at the accelerated rate.

California Ornamental growers in California have a demonstr ated critical need for methyl bromide in 2012.
Alternatives are not available due to regulatory constraints. Iodomethane is not currently registered in California, and its future registration status is uncertain. Furthermore, many alternative fumigant regimens contain 1,3-dich loropropene and/or chlo ropicrin; these active ingredients are severely restrict ed by California state and local laws which effectively prevent their use as methyl bromide alternatives for orna mental cultivation. Rest rictions on chloropicrin also means the lowest formulation of methyl bromide used in California is 67:33 (methyl bromide: chloropicrin), as rates of chloropicrin higher than 225 kg/ha are prevented by law and lower rates are ineffective for pest control.

Florida Iodomethane is now a registered pesticide in Flor ida. Research results indicate that it is as efficacious as methyl bromide, facilitating a tran sition away from methyl bromide. However, few long-term trials have been conducted a nd serious concerns have been raised about application techniques and species -specific interactions. For instance, there have been no iodomethane trials to treat permanent post-rows using the “hot gas” method, which currently uses methyl bromide and chloropicrin (98:2 ra tio), and is a common management practice for Florida ornamental growers. Until more studies have been done to address these concerns, there is a critical need for methyl bromide in 2012 as part of a multi-year transition to alternatives.

USA CUN12 SOIL Ornamentals Open Field Page 3 of 19

### 2. REASONS WHY ALTERNATIVES TO METHYL BROMIDE ARE NOT FEASIBLE

The adoption of alternatives to methyl bromide by the ornamentals sector is constrained by regulatory prohibitions, yield losses, and higher costs. Many of thes e restrictions vary by state. Additionally, some constraints a pply to the entire ornamentals industry. A single grower may grow dozens of types of species and cultivars, each of which may experience different pest pressures. For example, a 2008 study in Florid a found a significant difference between the pests of two cultivars of Delphinium and their pest lo ads (Rosskopf et al 2008). These differences may result in varying cultivar a nd species reactions to pest co ntrol measures, impacting an alternative’s ability to contro l the entire pest spectrum.

California

In addition to federal regulations, the Californi a Department of Pesticide Regulation (DPR) has implemented severe restrictions for soil fumigants, including larger buffer zone requirements and township caps, which limit the amount of each fumigant can be applied within a 36-mile area (Segawa et al 2005). If these restrictions were not in place, the best methyl bromide alternative for ornamental growers in California would be 1,3-D plus chloropicrin followed by metam sodium (James Gerik, personal communication) . A recent study found that this fumigant combination was at least as efficacious as methyl bromide (Klose et al 2008). The state buffer and township cap regulations curre ntly prevent the use of this a lternative. Moreover, another recent study found that the most eff ective alternative treatments contain chloropicrin (Gerik et al 2002). However, any pesticide combinations includi ng either 1,3-D or chloropicrin are subject to prohibitory regulations and cannot be considered curre ntly available altern atives despite any proven efficacy.

Some alternatives that appear effective in research trials are not curr ently registered, including acrolein, DMDS, and iodomethane (Rosskopf et al 2007b). The future registration status of these products and other alternatives is unknown.

Florida

Iodomethane is now fully registered in Florida. a nd recent research results s howed it is at least as effective as methyl bromide for pest contro l in Florida ornamental s (Rosskopf et al 2006, Rosskopf et al 2007a, Rosskopf et al 2007b, Kokalis -Burelle et al 2006). However, no studies have been conducted on the same fields for more than two years, so long-term efficacy and application issues have yet to be fully identifi ed and understood. Moreover, efficacy has varied between the species and cultivars te sted in research trials; it is impossible to predict how each of the many species and cultivars of ornamentals would respond to iodomethane. Additionally, research is needed on the compatibility of iodo methane with ‘hot gas’ fumigant application currently used for methyl bromide; it is a comm on management method for ornamental growers.

The majority of methyl bromide alternatives re search for ornamentals has been conducted in Florida (Rosskopf et al 2005). More studies are needed in order to understand the climatespecific constraints faced by Florida ornamental growers.

USA CUN12 SOIL Ornamentals Open Field Page 4 of 19

### 3. IS THE USE COVERED BY A CERTIFICIATION STANDARD?

Methyl bromide is not used to meet a certif ication standard for ornamental production.

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE,
INDICATE THE REASON WH Y METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTER NATIVE STRATEGIES ARE USED TO
CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL
BROMIDE THERE.

Methyl bromide is only being requested for orna mental crop acreage with demonstrated critical need and is not being requested for acreage that has had succe ss with alternatives, such as
caladiums in Florida.

Enclosures Some ornamental growers using gr eenhouses have had success contro lling pests with substrates. Crops successfully grown in soilless media include roses, gerbera, lilies, and tulips. However, even substrates are fumigated after multiple cropping seasons to control diseases such as Pythium and continue using the substrate, which must be reused in order for the cropping system to be cost effective. Certain crops actually experience yield or quality gains when grown in substrates, such as roses; however, for most crops there is not such a gain to offset the increased
costs associated with substrate production. Soilless media system s also require altered watering and fertilization management practices, which may incur additional costs. Ultimately, the use of substrates requires greenhouses w ith benches, as opposed to grow ing crops in enclosures with open bottoms to the soil.

Steam sterilization has been adopted by some shade house and greenhouse growers to produce
lilies. While steam is considered effective in co ntrolling pests, there ar e many costs required to set up a steaming system within an existing enclosure structure. The cost of fuel required to heat soil beds uniformly also impacts the feasibility of steam sterilization. Some growers who attempted transitioning to steam sterilization sw itched back to fumigation due to application
issues and additional costs.

Open Field
The U.S. does not have information about the proportion of ornamental or floriculture crops using alternatives to methyl bromide. It can be presumed that acreag e not requesting methyl
bromide has either transitioned to an alternative pesticide or does not have the same cropping practices or pest pressure as the applicants with critical use reque sts. For example, Easter lily growers in California now use 1,3-D and metam s odium applied sequentially instead of methyl bromide. However, these crops allow fallow pe riods between crops of more than 10 years, which is not feasible for other specialty grower s due to limited land resources. Additionally, some growers have reduced their planted acreage due to economic hardship in recent years but intend to expand plantings and thereby fumi gated acres when the economy improves.

USA CUN12 SOIL Ornamentals Open Field Page 5 of 19

### 5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO
COVER AT LEAST PART OF THE CRO P THAT HAS REQUESTED USE OF
METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE
THIS?

No, it is not currently feasible to expand the use of alternative pest control measures to address
the demonstrated critical needs of the ornament als sector requesting methyl bromide for the 2012 growing season. Regulatory, t echnical, and economic barriers prevent thei r adoption and generally vary by state. Resear ch to find efficacious, safe, and co st effective alternatives is ongoing.

California State and local regulatio ns would have to change in orde r for fumigants such as 1,3-D and chloropicrin to be adopted as methyl bromide alternatives. Other fumigants currently being tested may prove effective in research trials but lack registration in the state of California, such as iodomethane (Rosskopf et al 2007a). Furtherm ore, some fumigants considered effective in
research trials for use in California lack both federal and state registra tion, including dimethyl
disulfide and acrolein (Gerik and Wong 2008).

Florida
Research is needed in order to determine the l ong-term efficacy and cost issues associated with iodomethane adoption as a methyl bromide altern ative. More research is also needed on nonfumigant alternatives. Critical use of methyl bromide could be further reduced by changing
the label to allow concentrations lower than 98: 2 (methyl bromide: chloropicrin) to be applied using the ‘hot gas’ method, which is a common mana gement practice. Concentrations as low as 50:50 (methyl bromide: chloropicrin) have b een found to achieved comparable control of nematodes and nutsedge as with the 98:2 formula (Noling et al 2001).

6. SUMMARY OF RECENT RESEARCH

CALIFORNIA 

### Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley. 2007. Status of methyl bromide alternatives for ornamental crop producti on in Florida and California. American Phytopathological Society Annual Meeting.

Midas 50:50 and 33:67 (iodomethane: chloropicrin) provided the best pest control in California.

FLORIDA 

### Rosskopf, Erin and Nancy Kokalis-Burelle. 200 8. Area-wide demonstration of chemical alternatives to methyl bromide for Florid a ornamentals. Proceedings of the Annual
International Research Conference on Met hyl Bromide Alternatives and Emissions
Reductions. http://mbao.org/2008/028Rosskopf.pdf

USA CUN12 SOIL Ornamentals Open Field Page 6 of 19

### No significant difference between methyl bromide and iodomethane efficacy was observed in terms of weeds per acre, rogues per acre, labor hours, and number of root-knot nematodes per
100cc of soil.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

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

T ABLE 

### 2: C ALIFORNIA CUT FLOWERS



### - C ALLA 

### L ILY 

### & R ANUNCULUS



### - E CONOMIC 

### I MPACTS OF


### M ETHYL 

### B ROMIDE 

### A LTERNATIVES

California Cut Flowers – Calla Lily & Bulbs M ETHYL B ROMIDE 1,3-D + Pic Dazomet Metam
Sodium

Y IELD L OSS (%) 0 25 25 20

Y IELD PER H ECTARE 55,937 41,952 41,952 44,749

* P RICE PER U NIT (U.S.$) 2.59 2.59 2.59 2.59

= G ROSS R EVENUE PER H ECTARE (U.S.$) 145,107 108,830 108,830 116,086

- O PERATING C OSTS PER H ECTARE (U.S.$) 160,030 160,030 160,030 160,030

= N ET O PERATING R EVENUE PER H ECTARE (U.S.$) -14,923 -51,200 -51,200 -43,945

1. L OSS PER H ECTARE (U.S.$) 0 36,277 36,277 29,021

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE (U.S.$) 0 137 137 110

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0 25 25 20

4. L OSS AS A P ERCENTAGE OF N ET O PERATING
R EVENUE (%) 0 -243 -243 -194



### T ABLE 

### 3: F LORIDA 

### C UT 

### F LOWERS



### - L ILIES



### - E CONOMIC 

### I MPACTS OF 

### M ETHYL 

### B ROMIDE 

### A LTERNATIVES

Florida Cut Flowers - Lilies M ETHYL B ROMIDE IODOMETHANE + PIC (98:2)

Y IELD L OSS (%) 0 0

Y IELD PER H ECTARE 31,135 31,135

* P RICE PER U NIT (U.S.$) 10 10

= G ROSS R EVENUE PER H ECTARE (U.S.$) 311,353 311,353

- O PERATING C OSTS PER H ECTARE (U.S.$) 262,715 262,715

= N ET O PERATING R EVENUE PER H ECTARE (U.S.$) 48,638 46,908

1. L OSS PER H ECTARE (U.S.$) 0 1,730

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE (U.S.$) 0 4

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



### Summary of Economic Feasibility

USA CUN12 SOIL Ornamentals Open Field Page 7 of 19

### The economic analysis evaluated methyl bromide alternative control scen arios for cut flower production for California and Florida by compari ng the economic outcome s of methyl bromide oriented production systems to those using alterna tives. However, due to the fact that there are over 100 species of ornamentals grown in all re gions of the country, the data from these examples are used to derive a proxy estimate for th e entire industry. A majo r factor that affected this economic analysis as compared to the pa st economic analyses was the availability of iodomethane (registered in 2008) in Florida, but not in California for use in ornamentals.

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

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

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

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

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

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

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

Several methodological approaches will help inte rpret the findings. Economic estimates were first calculated in pounds and acres and then co nverted to kilograms and hectares. Costs for
alternatives are based on mark et prices for the control pr oducts multiplied by the number of

USA CUN12 SOIL Ornamentals Open Field Page 8 of 19

### pounds of active ingredient that would be applied. Baseline costs were based on the average number of annual applications necessary to treat cut flowers with methyl bromide.

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

Loss per hectare measures the value of methyl bromide based on changes in operating costs and/or changes in yield. Loss e xpressed as a percentage of th e gross revenue is based on the ratio of the revenue loss to the gr oss revenue, likewise for the loss as a percentage of net revenue.
Yield loss estimates were based on data from th e CUE applications and U.S. EPA data, as well as expert opinion.

Regulatory constraints

California restricts tota l use of 1,3-d, at the lo cal level (township cap). Nematodes and weeds and pathogens are key pests in Florida and Califor nia bulb grower and are controlled with methyl bromide. Chloropicrin is not as effective in controlling weeds as methyl bromide. Using chloropicrin adds to producti on costs through increased chemi cal, weeding and labor costs.

Tables 2 though 4 provide a summary of the es timated economic losses. A measure of net revenue loss may not be completely accurate pa rtly because some nurseries are publicly owned and seedling prices or production co sts are subsidized. Indirect loss es arising from shifts in the production cycle were not quantified. Changes in production costs arise due to differences between the costs of methyl bromide and the alternatives, shifts in the production cycle (increasing the frequency of fumigation or le ngthening the fallow pe riod) and additional expenses such as supplementary irrigati on. These costs vary across regions.

As shown in Table 2, the alternatives to met hyl bromide for California cut flower production impose significant economic impacts on the growers. However, in Florida where iodomethane is available for use in ornamentals, economic impact s of using iodomethane as an alternative to methyl bromide are small.

USA CUN12 SOIL Ornamentals Open Field Page 9 of 19

### 8. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES

T ABLE 

### 4: N OMINATION 

### A MOUNT

California Cut

Flower

Commission Florida Cut

Flowers Sector Total / Average

Quantity Requested for 2011: Amount (kgs) 57,963 12,141 70,104

Quantity Recommended by

MBTOC/TEAP for 2011 : Amount (kgs) 52,167 12,141 64,308

Amount (kgs) 52,167 12,141 64,308

Area (ha) 261 61 322

Rate 200 200 200

Transition from 2011 Baseline Adjusted Value Percentage (%) -10% -90% -25%

Amount (kgs) 

## 46,950 1,214 48,164

Area (ha) 

### 235 6 241

Rate 

### 200 200 200 Quantity Approved by Parties

for 2011:



### Quantity Required for

2012 Nomination: ORNAMENTALS

SECTOR

USA CUN12 SOIL Ornamentals Open Field Page 10 of 19

### CITATIONS

Gerik, JS; CL Elmore, ID Greene. 2002. Alternative soil treatments for fiel d grown ornamentals. Proceedings of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions. http://mbao.org/2002proc/093gerikj%20mbao_2002.pdf

Gerik, James and Dong Wang. 2008. Control of Agr obacterium tumafaciens with soil fumigants. Proceedings of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions. http://mbao.org/2008/110Gerik.pdf

Gerik, James. Personal communicati on via telephone. October 28, 2008.

Klose, Susanne; Jim Gerik, Hussein Ajwa, Cher yl Wilen, Mike Mellano. 2008. Proceedings of
the Annual International Res earch Conference on Methyl Bromide Alternatives and
Emissions Reductions. http://mbao.org/2008/029Klose.pdf

Kokalis-Burelle, Nancy; Erin Rosskopf, Randy Dr iggers. 2006. Efficacy of Midas for control of Meloidognye incognita on Celosia in Florida. Proceedi ngs of the Annual International Research Conference on Methyl Bromide A lternatives and Emissions Reductions. http://mbao.org/2006/06Proceedings/112B urelleNMBAOAbstractBurelleetal2006.pdf

McSorley, R., Wang, K.H., Churc h, G. 2004. Fumigant alternatives to methyl bromide for managing nematodes and weeds in snapdragon. Pr oceedings of Florida State Horticulture Society. 117:334-337.

National Agricultural Statis tics Service (NASS). 2008. Flor iculture Crops 2007 Summary. USDA Sp Cr 6-1 (08) http://usda.mannlib.cornell.edu/usda/current/FlorCrop/FlorCrop-04-24-2008.pdf

Noling, J.W; J.P. Gilreath, E.R. Rosskopf. 2001. Alte rnatives to methyl bromide field research
efforts for nematode control in Florida. Pro ceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2001proc/014%20Noling%20JW%20MBAO2-2001.pdf

Rosskopf, Erin; D.O. Chellemi, N. Kokalis-Burel le, G.T. Church. 2005. Alternatives to methyl bromide: a Florida perspective. APSnet Feature June 2005: http://www.apsnet.org/onlin e/feature/m ethylbromide/

Rosskopf, Erin; Nancy Kokalis-Burelle, Randy Driggers. 2006. Evaluation of Midas for production of ornamental cockscomb in Florid a. Proceedings of the Annual International Research Conference on Methyl Bromide A lternatives and Emissions Reductions. http://mbao.org/2006/06Proceedi ngs/037Rosskopfetalcelosia2006.pdf

Rosskopf, Erin; Nancy Kokalis-Burelle, a nd Randy Driggers. 2007a. Reduced rates and alternatives to methyl bromide for snapdra gon production in Florida. Proceedings of the

USA CUN12 SOIL Ornamentals Open Field Page 11 of 19

### Annual International Research Conference on Me thyl Bromide Alternatives and Emissions
Reductions. http://mbao.org/2007/Proceedings/106RosskopfEMBAOsnapdragon2007.pdf

Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley. 2007b. Status of methyl bromide alternatives for ornamental crop producti on in Florida and California. American Phytopathological Society Annual Meeting.

Rosskopf, Erin and Nancy Kokalis-Burelle. 200 8. Area-wide demonstration of chemical alternatives to methyl bromide for Florid a ornamentals. Proceedings of the Annual
International Research Conference on Met hyl Bromide Alternatives and Emissions
Reductions. http://mbao.org/2008/028Rosskopf.pdf

Segawa, Randy. 2005. Methods for deve loping fumigant regulatory re quirements in California. Proceedings of the Annual International Research Conference on Methyl Bromide
Alternatives and Emissions Reductions. http://mbao.org/2005/05Proceedings/001% 20Seg awaR%20mbao_2005_conf_segawa_sum mary.pdf

Zinati, Gladis; Herbert Bryan and Merlyn Codallo. 2002. Solarization as a potential approach for recycling wastes for potting media and as an al ternative to methyl bromide for field-grown bedding plants. Proceedings of Florida State Horticulture Society. 115: 123 – 127.

USA CUN12 SOIL Ornamentals Open Field Page 12 of 19

## APPENDIX A: ORNAMENTAL SPECIES GROWN

The incredibly large and consta ntly changing number of species and cultivars grown in the ornamentals sector means that compiling a comple te list of species and acreage grown is not possible. There are hundreds of types of cut fl ower, foliage, and bulb crops grown each year and often several species are grown in the same fiel d simultaneously. However, the U.S. has tried to describe the major crops below. Additional info rmation is not available from public or private

sources.

California

APPENDIX B -T ABLE 1: C ALIFORNIA O RNAMENTALS

- P RODUCTION OF M AJOR S PECIES S PECIES # F LOWER B UNCHES IN 2003
Alstroemeria 892,789

Carnations 1,694,870 Delphinium 3,617,186

Gladiolus Data not released
Gerbera 62,638,650

Iris 5,823,242
Lilium 6,247,027 Chrysanthemums 1,273,742 Pompons 6,350,127

Roses 7,360,729 Snapdragons 2,976,219

A PPENDIX B

- T ABLE 2: C ALIFORNIA O RNAMENTALS

- P ARTIAL L ISTING AND E STIMATE OF C UT F LOWER AND
F OLIAGE A REA P RODUCED IN C ALIFORNIA IN 2002
C ROP A REA ( USUALLY FIELD )

- HA A REA ( USUALLY GREENHOUSE )

- HA
Alstroemeria 8 5
Antirrhinum (snapdragon) 126 17
Aster 6 Calla lily 16
Carnation 30 2 Chrysanthemum 88 28

Delphinium 22 Eucalyptus 54

Gerbera 21 Gypsophila 55

Iris (Dutch) 18

Larkspur 6

Lilium 32 21

Limonium spp. 13

Lisianthus 13

Protea 190

Rose 41 12 Stock ( Matthiola ) 26
Wax flower 317
Other 791 6
Greenhouse misc. 70 28
Field misc. 303 Cut greens misc. 389
Total 2609 145 ha

USA CUN12 SOIL Ornamentals Open Field Page 13 of 191 Total does not add due to rounding.



### Florida The only three cut flower species identified by the Florida Agricultural Statistics Service are gladioli, lilies and snapdragon. These are assu med to have the highest acreage and they have been identified by the applicant as using methyl bromide.

A PPENDIX B T ABLE 3. F LORIDA O RNAMENTALS

- C ROP P RODUCTION FOR C ERTAIN C UT F LOWER S PECIES 2 3.
2001 2002 2003

C ROP # OF

PRODUCERS Q UANTITY

SOLD (1000

SPIKES ) 1 # OF

PRODUCERS Q UANTITY

SOLD (1000

SPIKES ) 1 # OF

PRODUCERS Q UANTITY

SOLD (1000

SPIKES )
Gladioli 4 40,331 4 49,581 4 39,444 Snapdragons 5 6,806 4 4,415 4 4,757
Lilies 4 3,031 3 2,257
- - 1 Quantity of lilies sold 1000 stems.

2 This table only includes data fo r growers with sales over $100,000.

USA CUN12 SOIL Ornamentals Open Field Page 14 of 19

## APPENDIX B: KEY TARGET PESTS

The ornamentals industry is complex; therefore, the following list is no t comprehensive but is intended to demonstrate the large number of pe sts affecting ornamental production and creating a critical need for methyl bromide in the U.S. for the 2012 growing season.

TABLE C 1. KEY PESTS Region where methyl
bromide use is requested Key disease(s) and weed(s) to species and, if known, to level of

race Specific reasons why methyl bromide needed ( e.g. Effective herbicide available, but not registered for this crop; mandatory requirement to meet certification for disease tolerance; no host resistance for a specific race )

A: California Cut Flowers,
Cut Greens

and
Perennials Verticillium spp., Fusarium spp., Pythium spp., Meloidogyne spp., Nutsedge ( Cyperus spp.), Malva spp., Poa spp., and previous crop propagules. Specific pest problems vary by individual crop and variety. The diversity and complexity of the industry, makes it difficult to control all root pathogens and weeds with currently available pest control methods. Some methyl
bromide alternatives used for other sectors are not feasible for floriculture due to high costs, difficulty timing applications to allow intercropping, and regulatory restrictions including township caps and buffer zone requirements.

B: Florida
Floriculture Soilborne diseases, weeds, and nematodes including Fusarium spp., Rhizoctonia spp., Phytoplithora

, Stromatinia, Pythium spp., Erwinia

, and most soil nematodes e.g. Meliodogyne spp., and previous crop propagules. Specific pest problems vary by individual crop and variety. These diseases are common, abundant, and spread via water, exacerbated by Florid a’s regions of tropical and sub-tropical climates. Due to the complexity of the ornamentals sector, alternative pest control measures have not been found for all species but research efforts are ongoing. Iodo methane is now registered; however, other methyl bromide alternatives preliminarily considered effective, such as dimethyl disulfide, are not currently registered for use.

USA CUN12 SOIL Ornamentals Open Field Page 15 of 19

## APPENDIX C: STATUS OF ME THYL BROMIDE ALTERNATIVES

T ABLE C 1. R EASON FOR ALTERNATIVES N OT BEING FEASIBLE
N AME OF

ALTERNATIVE T ECHNICAL AND REGULATORY * REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR

AVAILABLE

1,3- Dichloropropene (1,3-D) Technical Controls nematodes but will not provide adequate co ntrol of diseases and weeds at label rates.

Regulatory Buffer zones limit its use and township caps in Florida and California further restrict its use in those states. Mandated plant-back times can be 1 to 2 weeks longer with 1,3-D than with other fumigants. 1,3-D is not registered for use in greenhouses.

Chloropicrin Technical Weed control is poorer than with methyl brom ide Control of the entire pest spectrum cannot be achieved with lower use rates, but there are concerns about phytotoxicity to nearby plantings if greater than 2% chloropicrin is used in a fumigant combination

Regulatory There is concern over the real or perceived public exposure to higher rates of chloropicrin, especially in highly populated urban areas, due to increased worker exposure, offsite movement, and smells.

Metam sodium Technical Efficacy data is inconsistent, depending on soil type, moisture content, and temperature.

Regulatory Metam sodium is not registered for use in greenhouses.

Iodomethane Technical

More research needs to be done to understan d application and long -term efficacy issues.

Regulatory Iodomethane is not registered for use in California. Large buffer zones may also prevent widespread adoption.

1,3-D + chloropicrin Technical This alternative does not control the entire pest spectrum.

Regulatory In California, 1,3-D + chloropicrin is cons idered one of tthe best currently available alternatives, if label application rates were incr eased Township caps and buffer zones that exist
for the individual chemicals also apply for the combination.

Metam sodium + chloropicrin Technical This combination does not adequately contro l nematodes and weeds, and performance is
inconsistent.

Regulatory Restrictions and concerns existing for the individual chemicals also apply for the combination.

1,3-D + metam
sodium Technical Efficacy data is inconsistent.

Regulatory
Restrictions for the individual chemi cals also apply for the combinations.

USA CUN12 SOIL Ornamentals Open Field Page 16 of 19USA CUN12 SOIL Ornamentals Open Field Page 17 of 19 N AME OF

ALTERNATIVE T ECHNICAL AND REGULATORY * REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR

AVAILABLE

1,3-D + chloropicrin +
metam sodium Technical Weed control is incomplete.

Regulatory In California, 1,3-D + chloropicrin is considered the best currently available alternative, if use restrictions, such as township caps, were rem oved. Restrictions existing for the individual chemicals also apply for the combinations.

1,3-D + chloropicrin +
herbicides Technical

None.

Regulatory Restrictions existing for the individual chemicals also apply for combinations.

Dazomet Technical: Dazomet does not control the entire pest spectrum unless in combination with 1,3-D, chloropicrin, and/or herbicides.

Regulatory: Restrictions on 1,3-D and chloropicrin prev ent the use of Dazomet as a methyl bromide
alternative.

Metam sodium + crop rotation Technical Treatment does not control the entire pest spectrum.

Regulatory Restrictions existing for metam sodium also apply to its use in combination with other pest
control measures.

Steam Technical Steam sterilization is not feasible in open field production due to the need to remove the steam piping after application in order to accomm odate cultural management practices. In greenhouses, steam has been successfully used in previous decades as a pest control method.

Regulatory

None.

Biological control
agents Technical No biological controls have been developed to cover all of the pests.

Regulatory

None.

Crop rotation Technical: Previous crops’ bulbs and corms often contaminate the following crop as volunteer weeds or reservoirs for pathogens.

Regulatory

None.

Herbicides Technical: Crop damage may occur from cont act with certain herbicides or in the following crop if soil
residues remain.

Regulatory Restrictions for registered pesticides vary depending on the active ingredient(s) and individual product labels.USA CUN12 SOIL Ornamentals Open Field Page 18 of 19 N AME OF

ALTERNATIVE T ECHNICAL AND REGULATORY * REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR

AVAILABLE

Biofumigation Technica:l Biofumigation is still largely in the experimental stages. Specific brassicas as well as specific years yield variable amounts of activity. While this alternative may provide some control, the control of all target pests is not sufficient.

Regulatory:

None.

Substrates Technical: The use of substrates is only technically feasible in greenhouses using benches,

Regulatory

None.

Dimethyl
disulfide (DMDS) Technical: Studies are currently being conducted to test the efficacy of DMDS in ornamentals under an Experimental Use Permit.

Regulatory: DMDS is not currently registered, and its future registration status is not known.

Acrolein Technical: Studies are currently being conducted to determ ine the efficacy of acr olein for ornamentals.

Regulatory: Acrolein is currently only regist ered as an aquatic herbicide and cannot be used on soil for this use. Its future registration status is unknown.

Propargyl
bromide Technical:

More research is needed to understand its efficacy as a methyl bromide alternative.

Regulatory: This alternative is not currently registered and its future regulatory status is unknown.

Sodium azide Technical: More research is needed to understand its efficacy.

Regulatory: This alternative is not currently registered and its future regulatory status is unknown.

Muscador albus Strain QST
20779 Technical: No commercially available formulation.

Regulatory:

None.

Ethane dinitrile (Cyanogen) Technical: Considered a viable alternative in Australia, no studies have been conducted in the U.S. comparing efficacy with methyl bromide and other alternatives.

Regulatory: This product is not currently registered in the U.S. and its future registration status is unknown.

Acidic electrolyzed oxidizing (EO)

water Technical: EO water only controls foliar fungal diseases in greenhouse ornamentals. No research has been conducted on this product as a pre-pl ant pesticide in at least 6 years.

Regulatory: There is no commercial development or planned registration of this product currently.USA CUN12 SOIL Ornamentals Open Field Page 19 of 19 N AME OF

ALTERNATIVE T ECHNICAL AND REGULATORY * REASONS FOR THE ALTERNATIVE NOT BEING FEASIBLE OR

AVAILABLE

Solarization Technical: Efficacy data is inconsistent between research trials. Regional subclimates with significant
cloud cover or cooler annual te mperatures will not receive enough degrees for solarization to be a feasible pest control option.

Regulatory:

None.

Furfural Technical: It does not control the entire pest spectrum.

Regulatory: Furfural has a federal registration for ornamentals and non-food commodities for greenhouse soil use only. However, it does not have state regi strations currently, and its future registration
status is unknown..

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