USA CUN11 SOIL Cucurbits Open Field Page 1 of 21



### NOMINATING PARTY: T HE 

### U NITED 

### S TATES OF 

### A MERICA



### FILE NAME: USA CUN11 SOIL CUCURBITS Open Field

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

CROP NAME: Cucurbits 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 218,032 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 w ebsite under Decision Ex. I/4(8).)

This form is to be used by holders of single-year e xemptions to reapply for a subsequent year’s exempt ion (for example, a Party holding a single-year exemption fo r 2005 and/or 2006 seeking further exemptions for 2 007). It does not replace the format for requesting a critic al-use exemption for the first time.

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 Cucurbits Open Field Page 2 of 21



### CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS: Contact/Expert Person: Jack E. 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: 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 CUN11 SOIL CUCURBITS Open Field 21

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 CUCURBITS OPEN FIELD

* Identical to paper documentsUSA CUN11 SOIL Cucurbits Open Field Page 3 of 21



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

CUCURBITS

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

This renomination covers cucurbits of several types (squash, melons, and/or cucumber) grown in the southeastern US (except Florida), Maryland, and Delaware. These crops generally are grown in open fields on plastic tarps, often followed by various other crops. Harvest is destined for the
fresh market.

Only areas that cannot use alternative fumigants or non-fumigant options, and that face moderate to severe infestations of key pests, have been incl uded in the calculation of nominated amounts and area to be treated. The applicants’ requests ha ve also been adjusted downward to account for the lower methyl bromide dose rates (see BUNNIE in Appendix A) for the southern regions of US cucurbit production, since increased use of high barrier films in conjunction with lower rates has been reported there. For the mid-Atlantic regio n, the low dose rates requested by the applicants were incorporated into calculations.

In developing this renomination the USG examined se veral recent studies to determine whether yield losses and market window losses associated wi th the best available fumigant alternative could be altered from previous nominations. Unfortu nately none of the studies located by the
USG met the criteria that earlier cited studies did . These criteria include: the use of fumigant alternatives registered for the crop nominated, the presence of both a methyl bromide standard
and an untreated control as treatments as well as t he monitoring of yields under each treatment. Several recent studies included a methyl bromide tr eatment or an untreated control but not both, or included both but did not monitor yield, or incl uded unregistered alternatives. However, research conducted at the University of Georgia tha t examined use of a three way combination of alternative fumigants (1,3 D followed by chloropicr in followed by metam-sodium) did meet these criteria, Therefore, southern US areas were adjusted to reflect the technical feasibility of this three way combination of alternative fumigants under VIF or metalized films, as a replacement for spring-time applications of methyl bromide+chloropicrin, after accounting for areas in the south that face prohibition of 1,3 D d ue to karst topographical features.

The U.S. nomination is only for those areas where t he alternatives are not suitable. For example, continuing research indicates that the three way co mbination mentioned above (the “UGA 3 way”) does not adequately control key pests when us ed in place of methyl bromide in “fall” (i.e. August or September) fumigations. In U.S. cucurbit production there are several factors that make the potential alternatives to methyl bromide u nsuitable. These include:

• The efficacy of alternatives may be significantly l ess effective than methyl bromide in some areas, making these alternatives technically a nd/or economically infeasible for use in cucurbit production.USA CUN11 SOIL Cucurbits Open Field Page 4 of 21



### • Some alternatives may be comparable to methyl bromi de as long as key pests occur at low pressure. The U.S. is only nominating a critic al use exemption (CUE) for cucurbits where the key pest pressure is moderate to high suc h as nutsedge in the Southeastern U.S.

• Regulatory constraints prevent use of some chemical s, e.g., 1,3-dichloropropene (1, 3- dichloropropene ) use is limited in Georgia due to the presence of karst topographical
features.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE:

Our review of available research on other methyl br omide alternatives discussed by MBTOC for cucurbits suggests that, of registered (i.e., legal ly available) chemistries only metam sodium and 1,3 D + chloropicrin have shown potential as commer cially viable replacement to methyl
bromide. Non-chemical alternatives are either unvi able for US cucurbits or require more research and commercial development before they can be technically and economically feasible. For some areas in the southeastern US, a 3 way comb ination of 1,3 D + chloropicrin, followed by chloropicrin alone, followed by metam-sodium, has s hown promise against key cucurbit pests in spring season fumigation. The transition rate inclu ded in the BUNNIE incorporates an estimate of projected use of this strategy.

The recent Federal registration of iodomethane has not been used to adjust the amount of methyl bromide requested in this CUE, because this materia l has not been registered on cucurbits.

The following is the procedure followed for the 200 8 allocation year:

For Southeastern U.S. and Georgia, metam-sodium and 1, 3 D + chloropicrin are the most promising alternatives for nutsedges and nematodes, respectively, which are the key target pests in these regions. However, where nutsedges are seve re, metam-sodium, used alone, is technically and economically infeasible due to planting delays, yield losses and inconsistent efficacy, while 1,3 D + chloropicrin is infeasible in some areas du e to (1) its use being prohibited on Karst topographic features, which are widespread in these regions, (2) a 21 day planting delay, and (3) yield losses.

There is also evidence that the pesticidal efficacy of both 1,3 D and metam-sodium declines in areas where it is repeatedly applied, due to enhanc ed degradation of methyl isothiocyanate by soil microbes (Ou et al., 1995; Verhagen et al., 19 96; Dungan and Yates, 2003; Gamliel et al., 2003).

While one study in 2006 showed good efficacy of a c ombination of 1,3 D + chloropicrin and the herbicides napropamide + halosulfuron or metolachlo r + trifloxysulfuron in small plots of Florida tomatoes (Santos et al. 2006), these result s are not applicable to cucurbits because neither metolachlor or trifloxysulfuron are registered in t he US for cucurbits, and halosulfuron can have phytotoxic effects on cucurbits.

All other potential or available methyl bromide alt ernatives are also technically infeasible for
U.S. cucurbits.USA CUN11 SOIL Cucurbits Open Field Page 5 of 21



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

Methyl bromide is not used to meet a certification standard for cucurbit vegetable production.

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 WHAT ALTERNATIVE STRATEGIES ARE USED TO
CONTROL THE TARGET PATHOGENS AND WEEDS W ITHOUT METHYL
BROMIDE THERE.

• In Southeastern U.S. Georgia, and Maryland, areas n ot treated do not have nutsedges or pathogens naturally present in cucurbit fields. Si mple absence of all pests is the only reason these areas are not presently treated with m ethyl bromide.

• In Delaware and Maryland areas without the existenc e of several races of Fusarium oxysporum niveum, one of which is highly aggressive

, or without high concentration of the pathogen could use some alternatives such as 1, 3-D.

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?

The primary reason that some cucurbits may be grown without methyl bromide in these regions is the absence of both key target pests and constra ints to use of alternatives (e.g., absence of nutsedge, nematodes, and fungal pathogens in the So utheast, and Georgia, several races of

Fusarium and nutsedges in Delaware and Maryland, and karst topographic features in Georgia).

6. SUMMARY OF RECENT RESEARCH:

Narrative description of studies relevant to key pa thogens

This section focuses on research relevant to effect iveness of methyl bromide alternatives against

Fusarium wilt, since that is the main key pest cited by CUE applicants from the Maryland/Delaware regions. In studies with vegetabl e crops in the southeastern US, 1, 3 D + chloropicrin has generally shown better control of fungi than metam-sodium formulations (though still not as good as control with methyl br omide). For example, in a study using a bell pepper/squash rotation in small plots, Webster et a l. (2001) found significantly lower fungal populations with 1,3 D + 35 % chloropicrin (drip ap plied, 146 kg/ha of 1,3 D), as compared to the untreated control. However, methyl bromide (44 0 kg/ha, shank-injected) reduced fungal populations even more. Iodomethane had no signific ant suppressive effect, as compared to the untreated control. However, neither of these methy l bromide alternatives increased squash fruitUSA CUN11 SOIL Cucurbits Open Field Page 6 of 21



### weight significantly over the untreated control. I ndeed, as compared to the methyl bromide standard treatment plots, squash fruit weight was 6 3 % lower in the 1,3 D plots, and 41 % lower in the iodomethane plots. The proportion of unmark etable squash fruit (defined only as those fruit so bad as to have to be discarded) in the 1,3 D plots was 30 % worse than that in the methyl bromide plots, though in the iodomethane plots it was equivalent to methyl bromide .

In another study conducted on tomatoes, Gilreath et al. (1994) found that metam-sodium treatments did not match methyl bromide in terms of plant vigor at the end of the season; again,

Fusarium was one of several pests present.

In another study, by Hausbeck and Cortright (2007), cucurbit plant vigor was measured to determine fumigant/mulch performance under either L PDE or VIF plastic mulch for the control
of Fusarium oxysporum . Of the fumigants used in the study, the methyl b romide and iodomethane treatments resulted in cantaloupe plant s with the highest vigor (Table 2). In general, treatments under LPDE had higher plant vig or when compared with plants grown under VIF. It is noteworthy that in this study VIF tarps were prone to wind removal, which reduces their reliability under some growing conditions.

T ABLE 

### 2: E VALUATION OF 

### F UMIGANTS AND 

### P LASTIC 

### M ULCHES FOR 

### M ANAGING 

### F USARIUM IN 

### C UCURBIT 

### C ROPS 

### 2007

T REATMENT 

### ( TIME AFTER TREATMENT TO PLANTING 

### ) R ATE OF

FORMULATED

PRODUCT 

### V IGOR 

### *

Untreated control under LDPE (5 days) ..............

.................. .......... 1.0-1.3 a **



### Iodomethane+chloropicrin 50:50 under LDPE (10 days)

................ 196 kg/ha 1.0 a

Iodomethane+chloropicrin 50:50 under VIF (10 days)

................... 196 kg/ha 3.0 c

Methyl bromide+chloropicrin 67:33 under LDPE (10 da ys)

........... 280 kg/ha 1.0 a

Methyl bromide+chloropicrin 67:33 under VIF (10 day s)

.............. 280 kg/ha 2.7 bc

1,3 D + chloropicrin 65:35 under LDPE (21 days)

.......................... 187 liters/ha 2.3 bc

1,3 D + chloropicrin 65:35 under VIF (21 days)

............................. 187 liters/ha 4.7 d

Chloropicrin under LDPE (14 days) ..................

.............. ................ 187 liters/ha 2.7 c

Chloropicrin under VIF (14 days)...................

............. .................... 187 liters/ha 3.3 cd

* Vigor rating of plant health; 1=healthy plants with no stunting, 5= moderated plant stunting with vari able stand, 10=complete plant death.

** Column means with a letter in common are not signif icantly different (Fisher LSD Method; P =0.05). From Hausbeck and Cortright 2007.



### In addition to the limitations of VIF discussed abo ve, the USG notes that the plant vigor in 1,3 D
treatments in these new trials is lower than that s een in methyl bromide treatments. This is similar to what was seen in previous years’ tests ( Hausbeck and Cortright 2004; see also discussions in earlier cucurbit nominations).USA CUN11 SOIL Cucurbits Open Field Page 7 of 21



### As far as the USG has been able to determine, no ot her studies have been conducted since 2007
to evaluate the technical and commercial feasibilit y of fumigant alternatives to methyl bromide for controlling F. oxysporum subtypes under production conditions relevant to t he Maryland/Delaware regions.

Research continues to also be conducted to identify Fusarium resistant watermelon stock that can be grafted on a commercially feasible basis. Wh ile rootstocks protective under conditions of low to moderate pathogen infestation have been iden tified and tested, this work will require several more years before it produces methyl bromid e alternatives that are both technically and economically feasible, and that functions under sev ere infestations. Such work is being planned in the southeastern US (Roberts et al. 2007, Taylor et al. 2007, Bruton, personal communication).
Results of cucurbit rootstock resistant to root kno t nematode ( Meloidogyne incognita ) were presented at the MBAO conference in November 2008 ( Kokalis Burrell et al. 2008, Kubota et al. 2008). Results with muskmelon showed that the evalu ated rootstocks have potential as an option in an integrated multi-tactic approach to replace m ethyl bromide. However, this work is in its initial stages and further evaluation is needed to assess feasibility of control of other soil pests. Furthermore, these trials did not evaluate resistan ce or commercial feasibility of rootstocks against the Fusarium pests that are key targets for the Maryland/Delawa re region. In general, grafting of resistant rootstocks is still in an ear ly stage of evaluation and commercial implementation for US east coast cucurbit productio n, and so the USG does not consider them viable alternatives to methyl bromide for the purpo ses of this nomination.

In conclusion, the USG continues to use the best ca se yield loss estimates from the previous years’ nominations for the Maryland/Delaware region , since these need methyl bromide mainly
for F. oxysporum control. To paraphrase these loss estimates: 1,3- D +chloropicrin is the likely best available alternative for areas in this region that can use (i.e. areas not close to the water table). Even with this alternative, a yield loss of about 6 % is likely (based on Hausbeck and Cortright, 2004, and discussions in the 2004-2007 c ucurbit nominations). The economic impact
of this loss is further examined in other sections of this document, below.

Narrative description of studies relevant to key we eds and nematodes

For nutsedge pests, which are widespread in all req uesting regions, cucurbit growers do not currently have technically feasible alternatives to methyl bromide use at planting. Metamsodium and 1,3 D + chloropicrin have shown some eff icacy in small-plot trials in other vegetable crops (e.g, tomato). However, at best, metam sodiu m may allow at least 44 % yield loss, while 1,3 D may allow at least 29 % loss. Both often sho w less control than methyl bromide (in terms of population suppression) of nutsedges. These fac tors suggest that even this alternative will not be economically feasible even in the best-case tech nical scenario. It should be noted also that there is evidence that both 1,3 D and methyl isothi ocyanate levels decline more rapidly, thus further compromising efficacy, in areas where these are repeatedly applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003). This is pr obably due to enhanced degradation of these chemicals by soil microbes (Dungan and Yates, 2003)

.

Other chemical alternatives to methyl bromide that have shown promise against nutsedges and nematodes (e.g., pebulate and dimethyl disulfide) a re currently unregistered for cucurbits,USA CUN11 SOIL Cucurbits Open Field Page 8 of 21



### In one recent study, Culpepper and Langston (2004) conducted studies at 2 sites in spring 2003
and one site in the fall season of 2004. Plot size s were 20 feet X 32 inches (4.94 m 2 

### ). Treatments were: Methyl bromide standard (67:33 for mulation), untreated control, 2 formulations of Telone (1,3 D + chloropicrin) at va rious doses, followed by an additional application of either chloropicrin or metam-sodium, a third formulation of 1,3 D + chloropicrin (“Inline”), and iodomethane. An additional set of plots received the same fumigant treatments but also received an herbicide treatment (clomazone + halosulfuron) later in the season.

Watermelon – the only cucurbit crop addressed in th ese experiments – showed no significant (final) yield differences across any fumigant treat ment. The same lack of difference was observed when herbicides were added. In fact, ther e was no difference in yield even when pesticide treatments were compared to the untreated control. However, nutsedge populations in the study appeared to be relatively low (e.g., 667 plants per plot or 135/m 2 

### , in the untreated control, at the end of the study).

Furthermore, a number of important caveats must be mentioned when considering these results: (1) Plots used were quite small, and it is not at all c lear if the promising results will hold reliably in larger commercial fields. This is part icularly worrisome given the highly variable results reported by other researchers for the same methyl bromide alternatives. (2) The nutsedge populations in this study were dominat ed by yellow nutsedge (90 % of the total number). It is not clear if populations wher e purple nutsedge is dominant will be controlled as effectively. A number of other studi es have indicated that purple nutsedge is a hardier species, and even in Culpepper and Lan gston’s study, it appeared more resistant to the methyl bromide alternatives. For example, iodomethane gave “77 % control” of yellow nutsedge, but only “37 % control ” of purple nutsedge. Control in this case was apparently defined as the reduction in nut sedge populations as compared to populations in the untreated control. (3) This study was done only with watermelons, and it i s not clear if other cucurbits will respond so favorably in terms of yield, or lack of phytotoxic response. Also, a custombuilt applicator had to be used for the metam-sodiu m applications to eliminate worker exposure risks, according to the authors. It is no t yet clear if such an applicator can be mass-produced and/or used reliably in a commercial setting.

Another recent study of methyl bromide alternatives involving key weed pests was done by Gilreath et al. 2005 (Crop Prot (24): 903-908). One of 3 trials in that study showed an average of 30 % lower bell pepper yields with nutsedge and nem atodes as the key pests present. In the other 2 trials yields were not significantly different ac ross different fumigant treatments, but nutsedge pressure was lower in those trials as compared to t he third. Other important caveats to these results are - this was a small-plot study and was d one in Florida. Thus it is not clear how applicable the results are to the more northern reg ions requesting methyl bromide for vegetable crops (e.g., Delaware, Maryland, and Virginia).

In addition to the studies described above, several other recent studies conducted in the production circumstances of the southeastern US hav e examined several fumigant alternatives to methyl bromide, most done in crops other than cucur bits/peppers (e.g., Santos et al. 2006, Candole et al. 2007, Santos and Gilreath 2007, Gilr eath and Santos 2005, 2007). These studiesUSA CUN11 SOIL Cucurbits Open Field Page 9 of 21



### either focused solely on nutsedge weeds or a combin ation of nutsedges, diseases, and nematodes. However, USG has examined these papers and conclude s that for cucurbits, these studies do not
meet all the criteria that allowed the use of earli er studies in estimating yield and quality losses that may occur if such methyl bromide alternatives are used as direct replacements for methyl
bromide.

These criteria are: the use of fumigant alternative s registered for the crop nominated, the presence of both a methyl bromide standard and an u ntreated control as treatments as well as the monitoring of yields under each treatment. Several such studies included a methyl bromide treatment or an untreated control but not both (San tos and Gilreath 2007, Johnson and Mullinix 2007), or included both but did not monitor yield ( Candole et al. 2007), or included unregistered alternatives (e.g., Gilreath and Santos 2005, 2007, Santos et al. 2006). While these studies (the majority of which were small-plot trials) indicate continued promise of methyl bromide alternatives such as 1,3-D, metam-sodium, chloropic rin, herbicides, or combinations thereof, they cannot yet be used to alter yield estimates

.

Therefore, for this nomination, the USG concludes that, for cucurbit growers who can only use either 1,3-D + chloropicrin or metam-sodium+chlorop icrin in fall-season fumigations to control nutsedge and nematode pests, the yield loss estimat es used in last year’s nomination continue to be applicable. These loss estimates are illustrated in Table 3 below, and are used as the basis of part of the economic assessment in the following se ction.

T ABLE 

### 3: DATA ON YIELD LOSSES WITH LIKELY METHYL BROMIDE A LTERNATIVES AND NUTSEDGE

PRESENT AS A CROP PEST



### .

C HEMICALS 

### R ATE 

### ( KG 

### / HA 

### ) A VERAGE



### N UTSEDGE


### D ENSITY 

### (#/ M 2 

### ) A VERAGE



### M ARKETABL

E 

### Y IELD 

### ( TON 

### / HA 

### ) % Y IELD



### L OSS 

### ( COMPARED

TO 

### MB) Untreated (control) - 300 ab 

### 20.1 a 

### 59.1Methyl Bromide + Pic (67-33), chiselinjected 390 kg 90 c 

### 49.1 b



### ---
1,3 D + Pic (83-17), chisel-injected 327 l 

### 340 a 

### 34.6 c 

### 29.5
Metam Sodium, Flat Fumigation 300 l 

### 320 a 

### 22.6 a 

### 54.0
Metam Sodium, drip irrigated 300 l 

### 220 b 

### 32.3 c 

### 34.2

Locascio et al. 1997.



### Recent studies that are useful (within the context of this nomination) in assessing technical feasibility of a combination of methyl bromide alte rnatives include the series of trials being conducted by Culpepper et al. at the University of Georgia (e.g., Culpepper 2006, Culpepper et al. 2007a,b, Culpepper 2008). These studies indicat e that a 3-way, sequential combination of several fumigant alternatives is technically feasib le for spring-time fumigation of most vegetable crops. The 3-way combination consists of 1,3 D + ch loropicrin (“Telone C35” brand), followed by chloropicrin at about 168 kg/ha, followed by met am-sodium, all under VIF or metallized (high barrier) tarps, and will henceforth be referr ed to as the ‘UGA 3 way’, as Culpepper et al. have. An example of the results obtained in spring fumigation with this combination in peppers is presented in the table below (Table 4). Results have been similar for cucurbit cropsUSA CUN11 SOIL Cucurbits Open Field Page 10 of 21



### (Culpepper, personal communication; also see severa l research reports available from the University of Georgia at www.gaweed.com ).

T ABLE 

### 4: N UMBER OF 

### P EPPER 

### F RUIT



### - M ETHYL 

### B ROMIDE 

### : C HLOROPICRIN 

### V ERSUS 

### T HREE 

### W AY 

### C OMBINATION



### . S PRING 

### 2006

F RUIT 

### S IZE 

### M ETHYL 

### B ROMIDE 

### : C HLOROPICRIN 

### (# OF 

### F RUIT 

### ) UGA 3 WAY 

### 1,3-D FB CHLOROPICRIN FB

METAM 

### N A 

### Jumbo 30 b 125 a X-Large 219 a 237 a Large 153 a 143 a Chopper 217 a 252 a
Cull 11 a 9 a Jumbo + X-Large + Large 402 b 505 a Footnote: Culpepper 2006. fb means followed by o r a sequential treatment. Plots were 3 rows by 100 feet long.



### Since Georgia is similar to other areas of the sout heastern US, except Maryland/Delaware cucurbits which face a different key pest ( F. oxysporum niveum ), these results should be applicable to spring usage of methyl bromide in these regions. However, other results thus far
indicate that summer / fall fumigation is not similarly effective with this co mbination of alternatives (Culpepper, personal communication, Cu lpepper 2006, 2008).

Results of one of several experiments conducted by Culpepper et al. at the University of Georgia illustrate the infeasibility of the use of the ‘UGA 3 way’ method in place of methyl bromide for fall-season fumigations in vegetable production. In this experiment, fields were fumigated during for fall-season crop production on July 17 2007. S oil temperature was 84 degrees at 8 inches. The experiment consisted of 4 fumigant treatments ( Table 5) that were replicated three times. Even under high-barrier film (“Blockade”), the ‘UGA 3 way’ gave less control of purple nutsedge as compared to the methyl bromide standard under the same type of film. Yields were consistently lower with the ‘UGA 3 way’ as well, wi th a roughly 50 % reduction in both number and weight of harvested vegetables (Table 5). The e conomic implications of this level of yield loss for Georgia cucurbit growers are further descr ibed in Section 7, below.USA CUN11 SOIL Cucurbits Open Field Page 11 of 21



### T ABLE 

### 5: C OMPARING METHYL BROMIDE AND THE 

### 3-W AY FOR THE CONTROL OF NUTSEDGE AND

PEPPER YIELD



### . L ATE



### - SEASON

PURPLE NUTSEDGE

CONTROL 

### H ARVESTS 

### 1-2

(J UMBO PEPPER 

### ) H ARVESTS 

### 1-4 (J UMBO PEPPER 

### ) F UMIGANT 

### M ULCH

% # fruit/plot lbs/plot # fruit/plot lbs/plot 

### UGA-3 Way LDPE 48 d 34 c 16 c 44 c 19 c UGA-3 Way Blockade 60 c 50 b 24 b 71b 32 b Methyl Bromide + chloropicrin Blockade 85 b 106 a 48 a 136 a 61 a

None LDPE 0 f 13 d 6 d 19 d 8 d

Notes : (1) The UGA 3 Way consisted of 1,3 D + chloropicr in (“Telone C35” brand) at approximately 192 kg/ha, followed by chloropicrin at 168 kg/ha, followed by metam-sodium at approximately 358 kg/ha. Methyl bro mide + chloropicrin was applied in a 50:50 mix at approxim ately 160 kg/ha of each. Rates as shown are not pla nting bedstrip adjusted. (2) “Mulch” refers to the tarp typ e. LDPE = traditional high permeability tarp; Block ade = low permeability tarp manufactured by Pliant Corp.



### It is important to note that caveats accompany even the technical feasibility of the ‘UGA 3 way’ use in spring fumigations. Growers must make severa l application modifications to properly use the approach, and this may incur significant capita l expenditure. Culpepper et al. estimate their
costs to do this for their research trials at about $ 15,000 (Culpepper et al. 2007). Application
costs will also increase as more chemicals and runs of tractor equipment are required to conduct the ‘UGA 3 way’, and the cost of VIF or metallized film is between 1.75 and two times greater than standard LBPF (Culpepper, personal communicati on).

Time and further research and extension education w ill also be needed to implement the ‘UGA 3-way’ method in areas outside Georgia where the me thod has been less-studied, and where different problems may need to be resolved. An exam ple of this issue is illustrated in recent work by Chellemi et al. (2008). These researchers evalua ted the ‘UGA 3 way’ in on-farm tests in Florida peppers. Results of four trails were highly variable, with two showing better yields than the methyl bromide standard, and two showing worse results. All four trials showed a reduction in larger (more profitable) peppers in the ‘UGA 3 w ay’ as compared to the methyl bromide standard. The cause appeared to be an overload of p otassium in the soil, created by the combined use of the metam-potassium in the ‘UGA 3 way’ and t he growers’ standard practice of applying a high-potassium fertilizer.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

The following economic analysis is organized by met hyl bromide critical use application regions.

Readers 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 los ses of income that may be suffered by the users. It should be noted that net revenue does not repres ent net income to the users. Net income, which indicates profitability of an operation of an enter prise, is gross revenue minus the sum of operating and fixed costs. Net income should be sm aller than the net revenue measured in this study. We did not include fixed costs because it i s often difficult to measure and verify.USA CUN11 SOIL Cucurbits Open Field Page 12 of 21



### Summary of Economic Feasibility

The economic analysis of cucurbit applications comp ared data on the yields, crop prices, revenues and costs of using methyl bromide or alter native pest control regimens. This was done in order to estimate impacts on cucurbit growers wi th the decreasing availability of methyl bromide. The Georgia 3-Way (1,3-Dichloropicrin wit h Chloropicrin followed by metam sodium ) was identified as being a technically feasible al ternative (in cases of low pest infestation 1 

### ) to methyl bromide in Georgia and the Southeastern Unit ed States. Due to differences in climate and pests, it is uncertain whether or not the same assu mption holds for Maryland and Delaware cucurbit production. 1,3-D + chloropicrin and meta m sodium are also presented in this analysis as recognized alternatives to methyl bromide; howev er, neither are considered technically feasible as yield losses are expected.

The economic reviewers analyzed crop budgets for pr e-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
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 cucu rbit producers in this case. Because

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 Cucurbits Open Field Page 13 of 21



### 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.

Maryland and Delaware

The U.S. concludes that, at present, no economicall y feasible alternatives to methyl bromide exist for use in Maryland and Delaware melon produc tion. Yield loss and missed market windows, which are discussed individually below, ha ve proven most important in reaching this
conclusion.

1. Yield Loss

Expected yield losses of 6% are anticipated through out Maryland and Delaware melon production.

2. Missed Market Windows

USG agrees with Maryland and Delaware’s assertion t hat growers will likely receive significantly lower prices for their produce if the y switch to 1,3-D + chloropicrin. This is due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals when using 1,3-D + chloropicrin.

The analysis of this effect is based on the fact th at prices farmers receive for their cucurbits vary widely over the course of the growing season. Driv ing these fluctuations are the forces of supply and demand. Early in the growing season, when rela tively few cucurbits are harvested, the supply is at its lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenue s, cucurbit growers manage their production systems with the goal of harvesting the largest pos sible quantity of cucurbits when the prices are at their highs. The ability to sell produce at the se higher prices makes a significant contribution toward the profitability of cucurbit operations.

To describe economic conditions in Maryland and Del aware melon production, EPA used weekly and monthly cucurbit sales and production da ta from the U.S. Department of Agriculture for the previous three years to gauge the impact of early season price fluctuations on gross revenues. Though data availability was limiting, a nalysts assumed that if cucurbit growers adjust the timing of their production system, as required when using 1,3-D + Chloropicrin, gross revenues will decline by approximately 5% over the course of the growing season, due solely to price effects. The season average price was reduce d by 5% in the analysis of the alternatives to reflect this effect. Based on currently available information, the U.S. believes this reduction in price serves as a reasonable indicator of the typic al effect of planting delays resulting when methyl bromide alternatives are used in Maryland an d Delaware melon production.

Other Considerations:USA CUN11 SOIL Cucurbits Open Field Page 14 of 21



### In Maryland and Delaware cucurbits, Fusarium oxypsorum niveum exists in three separate races, and no one crop cultivar has resistance to all race s. Crop experts in Maryland report that methyl bromide alternatives provided lower protection agai nst the pathogen while also creating obstacles to meeting premium market windows. USG be lieves that the best alternatives (1,3 D + chloropicrin) may offer some defense against the pa thogen (with a yield loss similar to that likely in Michigan). However, since the crop acreage invol ved is in low-lying coastal plain, waterlogged soils frequently occur in rainy periods and this could delay fumigation with this and other alternatives (such as metam-sodium) and cause addit ional losses by forcing growers to miss key mid-July market windows.

The Southeastern USA 2 

### and Georgia

In the Southeastern U.S. and Georgia, using the Geo rgia 3-Way on spring plantings is believed to be a technically (and thus economically) feasible a lternative to methyl bromide, although some limitations exist. Referring to Tables 6 through 14 , the loss of gross revenue using the Georgia 3- Way is negligible for Georgia and the Southeastern U.S., while in some cases gains in gross revenue are expected in Georgia. Unlike spring plan tings, however, yield losses are expected in fall plantings, with studies in Georgia’s applicati on show a 50% yield loss. The Georgia 3-Way also cannot be used on cucurbits that are grown in karst soils since it contains 1,3-D. Therefore, for fall plantings and areas with karst soils, the use of methyl bromide is critical to Georgia’s and the Southeastern United States’ cucurbit production . Note that data describing Georgia cucurbit production is based on double cropping production p ractices.

Southeastern U.S. Analytical Notes

The applicant provided no data on the operating cos ts of alternatives. Analysts assumed, however, that these costs were similar to those of methyl bromide with slight upward adjustments for the costs of applying the alternati ves and a slight downward adjustment for the cost of the alternative product. In addition, the applicant did not provide data for second crops (including revenues and operating costs). Analysts assumed that Southeastern cucurbits are grown in a single crop production system. However, if double cropping is practiced in the actual production system, this assumption could make the c ritical need for methyl bromide appear smaller than it actually is, because the value the second crop derives from methyl bromide is not included in the analysis

Georgia Analytical Notes

Other potentially significant economic factors, suc h as price reductions due to missed market windows, were not analyzed for this region as the c ase for critical use of methyl bromide is sufficiently strong based solely on Georgia 3-Way f all yield losses.

Economic analysis of Georgia growing conditions inc luded cost and production data representing a second cucurbits or peppers crop.

2 

### Except GeorgiaUSA CUN11 SOIL Cucurbits Open Field Page 15 of 21

T ABLE 6. M ARYLAND AND D ELAWARE M ELON

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

MARYLAND AND DELAWARE MELON METHYL
BROMIDE 1,3-D + CHLOROPICRIN PRODUCTION LOSS (%) 0% 6%

PRODUCTION PER HECTARE 2,347 2,207 * PRICE PER UNIT (US$) $11 $11 = GROSS REVENUE PER HECTARE (US$) $25,822 $24,273 - OPERATING COST PER HECTARE (US$) $21,073 $20,366
= NET REVENUE PER HECTARE (US$) $4,749 $3,907

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $843

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $11

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 3%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 18% 5. OPERATING PROFIT MARGIN (%) 18% 16% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.

T ABLE 7. S OUTHEASTERN USA ( EXCEPT G EORGIA ) C UCUMBER -: E CONOMIC I MPACTS OF M ETHYL B ROMIDE
A LTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA)
CUCUMBER METHYL
BROMIDE GEORGIA

3-WAY 1,3-D +

CHLOROPICRIN METAM

SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44%

PRODUCTION PER HECTARE 828 828 588 464
* PRICE PER UNIT (US$) $16 $16 $16 $16
= GROSS REVENUE PER HECTARE (US$) $13,245 $13,245 $9,404 $7,417
- OPERATING COST PER HECTARE (US$) $10,556 $10,652 $9,691 $9,736
= NET REVENUE PER HECTARE (US$) $2,689 $2,593 -$288 -$2,319

LOSS MEASURES *
1. LOSS PER HECTARE (US$) $0 $96 $2,976 $5,007

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $32 $54

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 22% 38%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 4% 111% 186%
5. OPERATING PROFIT MARGIN (%) 20% 20% -3% -31% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.USA CUN11 SOIL Cucurbits Open Field Page 16 of 21

T ABLE 8. S OUTHEASTERN USA ( EXCEPT G EORGIA ) M ELONS

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE
A LTERNATIVES SOUTHEAST USA (EXCEPT GEORGIA)
MELON METHYL
BROMIDE GEORGIA

3-WAY 1,3-D +

CHLOROPICRIN METAM

SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44%

PRODUCTION PER HECTARE 815 815 579 457
* PRICE PER UNIT (US$) $15 $15 $15 $15
= GROSS REVENUE PER HECTARE (US$) $12,232 $12,232 $8,685 $6,850

- OPERATING COST PER HECTARE (US$) $11,202 $11,297 $10,337 $10,381
= NET REVENUE PER HECTARE (US$) $1,030 $934 ($1,652) -$3,531

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $96 $2,682 $4,562

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $29 $49

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (% ) 0% 1% 22% 37%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 9% 260% 443%
5. OPERATING PROFIT MARGIN (%) 8% 8% -19% -52% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.

T ABLE 9. S OUTHEASTERN USA ( EXCEPT G EORGIA ) S QUASH -: E CONOMIC I MPACTS OF M ETHYL B ROMIDE
A LTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) SQUASH METHYL
BROMIDE GEORGIA

3-WAY 1,3-D +

CHLOROPICRIN METAM

SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44%

PRODUCTION PER HECTARE 311 311 221 174 * PRICE PER UNIT (US$) $29 $29 $29 $29

= GROSS REVENUE PER HECTARE (US$) $9,029 $9,029 $6,411 $5,056

- OPERATING COST PER HECTARE (US$) $7,338 $7,433 $6,473 $6,517

= NET REVENUE PER HECTARE (US$) $1,692 $1,596 -$62 -$1,461

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $96 $1,754 $3,152

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $19 $34

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 19% 35%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 6% 104% 186% 5. OPERATING PROFIT MARGIN (%) 19% 18% -1% -29% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.USA CUN11 SOIL Cucurbits Open Field Page 17 of 21

T ABLE 10. A LL S OUTHEASTERN US ( EXCEPT G EORGIA ) C UCURBITS

- E CONOMIC I MPACTS OF M ETHYL
B ROMIDE A LTERNATIVES ALL SOUTHEAST US (EXCEPT GEORGIA) CUCURBITS METHYL
BROMIDE GEORGIA 3-

WAY 1,3-D +

CHLOROPICRIN METAM

SODIUM PRODUCTION LOSS (%) 0% 0% 29% 44%

PRODUCTION PER HECTARE 652 652 463 303 * PRICE PER UNIT (US$) $18 $18 $18 $17

= GROSS REVENUE PER HECTARE (US$) $11,502 $11,502 $8,166 $5,235

- OPERATING COST PER HECTARE (US$) $9,802 $9,899 $8,939 $8,984

= NET REVENUE PER HECTARE (US$) $1,700 $1,603 -$773 -$3,749

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $97 $2,472 $5,449

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $27 $59

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 21% 47%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 6% 145% 321%

5. OPERATING PROFIT MARGIN (%) 15% 14% -9% -72% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.

T ABLE 11. G EORGIA C UCUMBER

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA CUCUMBERS METHYL
BROMIDE GEORGIA 3-WAY:

SPRING

APPLICATION GEORGIA 3-WAY:

FALL
APPLICATION PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 5,740 5,740 2,870 * PRICE PER UNIT (US$) $12 $12 $12

= GROSS REVENUE PER HECTARE (US$) $67,223 $67,223 $33,611

- OPERATING COST PER HECTARE (US$) $54,251 $40,226 $40,226

= NET REVENUE PER HECTARE (US$) $12,972 $26,997 -$6,615

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 -$14,024 $19,587

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$151 $211

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -21% 29%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -108% 151%

5. OPERATING PROFIT MARGIN (%) 19% 40% -20% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.USA CUN11 SOIL Cucurbits Open Field Page 18 of 21

T ABLE 12. G EORGIA M ELON E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA MELONS METHYL
BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION GEORGIA 3-
WAY: FALL
APPLICATION PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 4,275 4,275 2,137 * PRICE PER UNIT (US$) $12 $12 $12

= GROSS REVENUE PER HECTARE (US$) $49,696 $49,696 $24,848

- OPERATING COST PER HECTARE (US$) $42,085 $43,288 $43,288 = NET REVENUE PER HECTARE (US$) $7,610 $6,408 -$18,440

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $1,202 $26,050

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $13 $280

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 2% 52%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 16% 342% 5. OPERATING PROFIT MARGIN (%) 15% 13% -74% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.

T ABLE 13. G EORGIA S QUASH

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA SQUASH METHYL
BROMIDE GEORGIA 3-

WAY: SPRING

APPLICATION GEORGIA 3-

WAY: FALL
APPLICATION
PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 5,251 5,251 2,625 * PRICE PER UNIT (US$) $8 $8 $8

= GROSS REVENUE PER HECTARE (US$) $40,556 $40,538 $20,269

- OPERATING COST PER HECTARE (US$) $42,865 $32,064 $32,064

= NET REVENUE PER HECTARE (US$) -$2,308 $8,474 -$11,795

LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 -$10,782 $9,487

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$116 $102

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -27% 23%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 467% -411%

5. OPERATING PROFIT MARGIN (%) -6% 21% -58% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.USA CUN11 SOIL Cucurbits Open Field Page 19 of 21

T ABLE 14. A LL G EORGIA C UCURBITS

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA CUCURBITS METHYL
BROMIDE GEORGIA 3-

WAY: SPRING
APPLICATION GEORGIA 3-

WAY: FALL
APPLICATION 1,3-D +

CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0% 50% 29%

PRODUCTION PER HECTARE 4,741 4,741 2,370 3,404

* PRICE PER UNIT (US$) $10 $10 $10 $10

= GROSS REVENUE PER HECTARE (US$) $46,439 $46,435 $23,217 $33,325

- OPERATING COST PER HECTARE (US$) $44,278 $40,213 $40,213 $43,999

= NET REVENUE PER HECTARE (US$) $2,161 $6,222 -$16,995 -$10,675

LOSS MEASURES *
1. LOSS PER HECTARE (US$) $0 -$4,062 $19,156 $12,835

2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$44 $206 $138

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -9% 41% 28%

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -188% 887% 594%

5. OPERATING PROFIT MARGIN (%) 5% 13% -73% -32% * Interpret the loss measures with caution. Negativ e numbers presented in rows indicating a “loss” sho uld be interpreted as a “gain”. Positive numbers can be i nterpreted as losses.



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

The USG has applied an aggressive transition rate w hich is reflected in the nomination amount
and detailed in Table 15.

T ABLE 15: N OMINATION A MOUNT

Mardel Cucurbit Southeast

Cucurbit Georgia - Squash Georgia -

Cucumber Georgia - Melon Sector Total / Average

Quantity Requested for 2010: Amount (kgs) 9,117 209,951

21,217

15,350

68,137

323,773

Quantity Recommended by
MBTOC/TEAP for 2010 : Amount (kgs) 6,862 174,691

21,217

15,350

68,204

286,324

Amount (kgs) 6,862

174,691

21,217

15,350

68,204

286,324

Area (ha) 46

1,046

127

93

406

1,718

Rate 150

167

167

165

168

167

Transition from 2010 Baseline Adjusted Value Percentage (%) -46% -51% -50% -49% -51% -51%

Amount (kgs) 4,969

142,534

14,714

11,185

44,630

218,032

Area (ha) 33 853 88 68 266 1308

Rate 151 167

167

164

168

167 

### 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 CUCURBITSUSA CUN11 SOIL Cucurbits Open Field Page 20 of 21



### CITATIONS

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.

Chellemi, D. O. 2008. Field validation of a fumig ant alternative. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissions Reduct ions. Available on the web at http://mbao.org/2008/008Chellemi.pdf

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.

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