USA CUN11 SOIL Ornamentals Open Field Page 1 of 20



### NOMINATING PARTY: T HE 

### U NITED 

### S TATES OF 

### A MERICA



### FILE NAME: USA CUN11 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 2009 for 2011 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 

### 2011 70,178 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 Ornamentals Open Field Page 2 of 20



### 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 ORNAMENTALS Open Field 20

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 ORNAMENTALS Open Field

* Identical to paper documentsUSA CUN11 SOIL Ornamentals Open Field Page 3 of 20



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

ORNAMENTALS

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

This renomination is for methyl bromide for the pro duction of ornamentals. The ornamental sector consists of cut flowers, cut greens, and bul bs in California; floriculture in Florida; and hybrid anemones and ranunculus in New York. All da ta comes from the applicants’ requests

unless otherwise cited.

California Ornamental growers in California have a demonstrate d critical need for methyl bromide in 2011. Alternatives are not available due to regulatory co nstraints. Iodomethane is not currently registered in California, and its future registrati on status is uncertain. Furthermore, many alternative fumigant regimens contain 1,3-dichlorop ropene and/or chloropicrin; these active ingredients are severely restricted by California s tate and local laws which effectively prevent their use as methyl bromide alternatives for orname ntal cultivation. Restrictions on chloropicrin also means the lowest formulation of methyl bromide used in California is 67:33 (methyl bromide: chloropicrin), as rates of chloropicrin hi gher than 225 kg/ha are prevented by law and lower rates are ineffective for pest control.

Florida Iodomethane is now a registered pesticide in Florid a. Research results indicate that it is as efficacious as methyl bromide, facilitating a trans ition away from methyl bromide. However, few long-term trials have been conducted and seriou s concerns have been raised about application techniques and species-specific interac tions. For instance, there have been no iodomethane trials to treat permanent post-rows usi ng the “hot gas” method, which currently uses methyl bromide and chloropicrin (98:2 ratio), and is a common management practice for Florida ornamental growers. Until more studies hav e been done to address these concerns, there is a critical need for methyl bromide in 2011 as pa rt of a multi-year transition to alternatives.

New York The applicant in New York has a demonstrated critic al needed for methyl bromide in the 2011 growing season, as many of the alternatives registe red for open fields do not have a label allowing greenhouse usage, such as Telone (1,3-dich loropropene and chloropicrin) and Vapam (metam sodium). Furthermore, iodomethane is not re gistered in New York, and the possibility of its registration in the future is unknown. Stea m sterilization appears to be the best pest control option; however, there is a lack of research and th us efficacy data on methyl bromide alternatives for ornamental growers using enclosures. Therefore , methyl bromide is a critical component of a multiyear transition process.USA CUN11 SOIL Ornamentals Open Field Page 4 of 20



### 2. REASONS WHY ALTERNATIVES TO METHYL BROMIDE ARE N OT FEASIBLE

The adoption of alternatives to methyl bromide by t he ornamentals sector is constrained by regulatory prohibitions, yield losses, and higher c osts. Many of these restrictions vary by state. Additionally, some constraints apply 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 Florida fo und a significant difference between the pests of two cultivars of Delphinium and their pest loads (Rosskopf et al 2008). These differences may result in varying cultivar and species reactions to pest control measures, impacting an alternative’s ability to control the entire pest sp ectrum.

California

In addition to federal regulations, the California 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 fumig ant can be applied within a 36-mile area (Segawa et al 2005). If these restrictions were no t 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 rec ent study found that this fumigant combination was at least as efficacious as methyl b romide (Klose et al 2008). The state buffer and township cap regulations currently prevent the use of this alternative. Moreover, another recent study found that the most effective alternat ive 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 currently available alternatives despite any proven efficacy.

Some alternatives that appear effective in research trials are not currently registered, including acrolein, DMDS, and iodomethane (Rosskopf et al 200 7b). The future registration status of these products and other alternatives is unknown.

Florida

Iodomethane is now fully registered in Florida and recent research results showed it is at least as effective as methyl bromide for pest control in Flo rida ornamentals (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 tha n two years, so long-term efficacy and application issues have yet to be fully identified and understood. Moreover, efficacy has varied between the species and cultivars tested in researc h 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 iodometh ane with ‘hot gas’ fumigant application currently used for methyl bromide; it is a common m anagement method for ornamental growers.

The majority of methyl bromide alternatives researc h for ornamentals has been conducted in California (Rosskopf et al 2005). More studies are needed in order to understand the climatespecific constraints faced by Florida ornamental gr owers.USA CUN11 SOIL Ornamentals Open Field Page 5 of 20



### New York

The critical use nomination for the 2011 growing se ason is entirely in greenhouse production, which has unique constraints for pest control optio ns compared to open field production. Many fumigant alternatives currently registered do not h ave a label for use in greenhouses, including 1,3-D and metam sodium. Iodomethane is not registe red for any uses in New York and its future registration status is unknown.

Moreover, very little research is conducted on the efficacy of methyl bromide alternatives in greenhouses. As such, efficacy data obtained from field trials is not translatable into predicting how even the same cultivar or species would perform in greenhouse conditions.

Steam sterilization appears to be the best currentl y available alternative to methyl bromide for greenhouse production. While no regulations preven t the adoption of steam, the small size of the grower’s operation necessitates that the margin of error for research testing is very small. Methyl bromide is therefore critical in the 2011 gr owing season to a multi-year transition.

For a more comprehensive list of methyl bromide alt ernatives and why they are not feasible for

use in the ornamental sector due to technical and r egulatory constraints, please see Appendix C.

3. IS THE USE COVERED BY A CERTIFICIATION STANDARD?

Methyl bromide is not used to meet a certification standard for ornamental 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 W HAT ALTERNATIVE STRATEGIES ARE USED TO

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METH YL

BROMIDE THERE.

Methyl bromide is only being requested for ornament al crop acreage with demonstrated critical need and is not being requested for acreage that ha s had success with alternatives, such as
caladiums in Florida.

Enclosures Some ornamental growers using greenhouses have had success controlling pests with substrates. Crops successfully grown in soilless media include roses, gerbera, lilies, and tulips. However, even substrates are fumigated after multiple croppi ng seasons to control diseases such as Pythium and continue using the substrate, which must be re used in order for the cropping system to be cost effective. Certain crops actually exper ience 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. Soille ss media systems also require altered watering and fertilization management practices, which may i ncur additional costs. Ultimately, the use ofUSA CUN11 SOIL Ornamentals Open Field Page 6 of 20



### substrates requires greenhouses with benches, as op posed to growing 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 con trolling pests, there are many costs required to set up a steaming system within an existing enclosu re 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 swit ched back to fumigation due to application

issues and additional costs.

Open Field The U.S. does not have information about the propor tion of ornamental or floriculture crops using alternatives to methyl bromide. It can be pr esumed that acreage not requesting methyl bromide has either transitioned to an alternative p esticide or does not have the same cropping practices or pest pressure as the applicants with c ritical use requests. For example, Easter lily growers in California now use 1,3-D and metam sodiu m applied sequentially instead of methyl bromide. However, these crops allow fallow periods between crops of more than 10 years, which is not feasible for other specialty growers d ue to limited land resources.

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?

No, it is not currently feasible to expand the use of alternative pest control measures to address

the demonstrated critical needs of the ornamentals sector requesting methyl bromide for the 2011 growing season. Regulatory, technical, and econom ic barriers prevent their adoption and generally vary by state. Research to find efficaci ous, safe, and cost effective alternatives is ongoing.

California State and local regulations would have to change in order for fumigants such as 1,3-D and chloropicrin to be adopted as methyl bromide altern atives. Other fumigants currently being tested may prove effective in research trials but l ack registration in the state of California, such as iodomethane (Rosskopf et al 2007a). Furthermore , some fumigants considered effective in

research trials for use in California lack both fed eral and state registration, including dimethyl disulfide and acrolein (Gerik and Wong 2008).

Florida Research is needed in order to determine the long-t erm efficacy and cost issues associated with iodomethane adoption as a methyl bromide alternativ e. More research is also needed on nonfumigant alternatives. Critical use of methyl br omide 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 manag ement practice. Concentrations as low as 50:50 (methyl bromide: chloropicrin) have been foun d to achieved comparable control of nematodes and nutsedge as with the 98:2 formula (No ling et al 2001).USA CUN11 SOIL Ornamentals Open Field Page 7 of 20



### New York Some fumigant alternatives available for open field ornamental growing are not registered for greenhouse use and as such cannot be used barring a change in their registration status. Research is needed to address the efficacy and cost issues a ssociated with steam sterilization.

6. SUMMARY OF RECENT RESEARCH

CALIFORNIA 

### Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McS orley. 2007. Status of methyl bromide alternatives for ornamental crop production in Flor ida and California. American Phytopathological Society Annual Meeting.

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

FLORIDA 

### Rosskopf, Erin and Nancy Kokalis-Burelle. 2008. Are a-wide demonstration of chemical alternatives to methyl bromide for Florida ornament als. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions

Reductions. http://mbao.org/2008/028Rosskopf.pdf

No significant difference between methyl bromide an d iodomethane efficacy was observed in terms of weeds per acre, rogues per acre, labor hou rs, and number of root-knot nematodes per

100cc of soil.

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 of 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.USA CUN11 SOIL Ornamentals Open Field Page 8 of 20



### 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: N EW YORK ANEMONES



### - E CONOMIC 

### I MPACTS OF 

### M ETHYL 

### B ROMIDE 

### A LTERNATIVES 

### *

N EW Y ORK C UT F LOWERS

– A NEMONES M ETHYL
B ROMIDE S TEAM S TEAM S TEAM

Y IELD L OSS (%) 0 0 10 20

Y IELD PER H ECTARE 247,105 247,105 222,395 197,684

* P RICE PER U NIT (U.S.$) 3.75 3.75 3.75 3.75

= G ROSS R EVENUE PER H ECTARE (U.S.$) 926,644 926,644 833,980 741,315

- O PERATING C OSTS PER H ECTARE (U.S.$) 34,595 115,781 115,781 115,781

= N ET O PERATING R EVENUE PER
H ECTARE (U.S.$) 892,050 810,863 718,199 625,534

1. L OSS PER H ECTARE (U.S.$) 0 81,186 173,851 266,515

2. L OSS PER K ILOGRAM OF M ETHYL
B ROMIDE (U.S.$) 0 110,86 237.38 364

3. L OSS AS A P ERCENTAGE OF G ROSS
R EVENUE (%) 0 8.8 18.8 29

4. L OSS AS A P ERCENTAGE OF N ET
O PERATING R EVENUE (%) 0 9.1 19.5 30



### * Due to a lack of research on steam sterilization as a methyl bromide alternative for pre-plant fumigat ion for ornamentals in enclosures, yield loss estimates do not exist. Scenarios were therefore calculated with 0%, 10%, and 20% yield loss estimates.USA CUN11 SOIL Ornamentals Open Field Page 9 of 20



### T ABLE 

### 4: 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

The economic analysis evaluated methyl bromide alte rnative control scenarios for cut flower production for California, New York, and Florida by comparing the economic outcomes of methyl bromide oriented production systems to those using alternatives. However, due to the fact that there are over 100 species of ornamentals grown in all regions of the country, the data from these examples are used to derive a proxy esti mate for the entire industry. A major factor that affected this economic analysis as compared to the past economic analyses was the availability of iodomethane (registered in 2008) in Florida, but not in California and New York

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 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, and (3) missed market windows due to pla nt back time restrictions, which also affect the quantity and price received for the goods.

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 c losely 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 meas ure indicates the nominal marginal value of methyl bromide to crop production.

(3) Loss as a Percentage of Gross Revenue. This me asure has the advantage that gross revenues are usually easy to measure, at least over some uni t, e.g., a hectare of land or a storage operation. However, high value commodities or crops may provid e high revenues but may also entail highUSA CUN11 SOIL Ornamentals Open Field Page 10 of 20



### costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue. We define net cash revenues as gross revenues minus operating costs. This is a very 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.

These measures represent different ways to assess t he economic feasibility of methyl bromide alternatives for methyl bromide users, who are prod ucers 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.

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

Net revenue is calculated as gross revenue minus op erating 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 in come, which indicates profitability of an operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net

income should be smaller than the net revenue measu red in this study. Fixed costs were not included because they are difficult to measure and verify.

Loss per hectare measures the value of methyl bromi de based on changes in operating costs and/or changes in yield. Loss expressed as a perce ntage of the gross revenue is based on the ratio of the revenue loss to the gross revenue, lik ewise for the loss as a percentage of net revenue.

Yield loss estimates were based on data from the CU E applications and U.S. EPA data, as well as expert opinion.

Regulatory constraints

California restricts total use of 1,3-d, at the loc al level (township cap). Nematodes and weeds and pathogens are key pests in Florida and Californ ia bulb grower and are controlled with methyl bromide. Chloropicrin is not as effective in contr olling weeds as methyl bromide. Using chloropicrin adds to production costs through incre ased chemical, weeding and labor costs.

Tables 2 though 4 provide a summary of the estimate d economic losses. A measure of net revenue loss may not be completely accurate partly because some nurseries are publicly owned and seedling prices or production costs are subsidi zed. Indirect losses arising from shifts in the production cycle were not quantified. Changes in p roduction costs arise due to differences between the costs of methyl bromide and the alterna tives, shifts in the production cycleUSA CUN11 SOIL Ornamentals Open Field Page 11 of 20



### (increasing the frequency of fumigation or lengthen ing the fallow period) and additional expenses such as supplementary irrigation. These c osts vary across regions.

As shown in Table 2, the alternatives to methyl bro mide for California cut flower production impose significant economic impacts on the growers. Similarly, for New York anemones growers, steam sterilization as an alternative to m ethyl bromide results in substantial economic impacts (Table 3). However, in Florida where iodom ethane is available for use in ornamentals, economic impacts of using iodomethane as an alterna tive to methyl bromide are small.

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 5.

T ABLE 5: N OMINATION A MOUNT

California Cut

Flower

Commission New York

Ornamentals Florida Cut

Flowers Sector Total /

Average

Quantity Requested for 2010: Amount (kgs) 67,946 272

24,281

92,499

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 57,963 74

24,281

82,318

Amount (kgs) 57,963

74

24,281

82,318

Area (ha) 290

0

121

411

Rate 200 200 201 200

Transition from 2010 Baseline Adjusted Value Percentage (%) -15% -73% -70% -37%

Amount (kgs) 

## 57,963

74

12,141

70,178

Area (ha) 

### 290

0

61

351

Rate 

### 200 200

200

200 ORNAMENTALS 

## 2011 Methyl Bromide Usage Newer Numerical Index (BU NNI)

Transition Use Reduction Description Spreadsheet

SECTOR

Quantity Approved by Parties

for 2010:



### Quantity Required for

2011 Nomination:USA CUN11 SOIL Ornamentals Open Field Page 12 of 20



### CITATIONS

Gerik, JS; CL Elmore, ID Greene. 2002. Alternativ e soil treatments for field grown ornamentals. Proceedings of the Annual Internationa l 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 Agro bacterium 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 communication via telephone. October 28, 2008.

Klose, Susanne; Jim Gerik, Hussein Ajwa, Cheryl Wil en, Mike Mellano. 2008. Proceedings of

the Annual International Research Conference on Met hyl Bromide Alternatives and

Emissions Reductions. http://mbao.org/2008/029Klose.pdf

Kokalis-Burelle, Nancy; Erin Rosskopf, Randy Drigge rs. 2006. Efficacy of Midas for control of Meloidognye incognita on Celosia in Florida. Proceedings of the Annual I nternational Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2006/06Proceedings/112BurelleNMBAOA bstractBurelleetal2006.pdf

McSorley, R., Wang, K.H., Church, G. 2004. Fumiga nt alternatives to methyl bromide for managing nematodes and weeds in snapdragon. Proceed ings of Florida State Horticulture Society. 117:334-337.

National Agricultural Statistics Service (NASS). 2 008. Floriculture Crops 2007 Summary. USDA Sp Cr 6-1 (08) http://usda.mannlib.cornell.edu/usda/current/FlorCr op/FlorCrop-04-24-2008.pdf

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

Rosskopf, Erin; D.O. Chellemi, N. Kokalis-Burelle, G.T. Church. 2005. Alternatives to methyl bromide: a Florida perspective. APSnet Feature Jun e 2005: http://www.apsnet.org/online/feature/methylbromide/

Rosskopf, Erin; Nancy Kokalis-Burelle, Randy Drigge rs. 2006. Evaluation of Midas for production of ornamental cockscomb in Florida. Proc eedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2006/06Proceedings/037Rosskopfetalc elosia2006.pdf

Rosskopf, Erin; Nancy Kokalis-Burelle, and Randy Dr iggers. 2007a. Reduced rates and alternatives to methyl bromide for snapdragon produ ction in Florida. Proceedings of theUSA CUN11 SOIL Ornamentals Open Field Page 13 of 20



### Annual International Research Conference on Methyl Bromide Alternatives and Emissions

Reductions. http://mbao.org/2007/Proceedings/106RosskopfEMBAOsn apdragon2007.pdf

Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McS orley. 2007b. Status of methyl bromide alternatives for ornamental crop production in Flor ida and California. American Phytopathological Society Annual Meeting.

Rosskopf, Erin and Nancy Kokalis-Burelle. 2008. A rea-wide demonstration of chemical alternatives to methyl bromide for Florida ornament als. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions

Reductions. http://mbao.org/2008/028Rosskopf.pdf

Segawa, Randy. 2005. Methods for developing fumig ant regulatory requirements in California. Proceedings of the Annual International Research Co nference on Methyl Bromide

Alternatives and Emissions Reductions. http://mbao.org/2005/05Proceedings/001%20SegawaR%20 mbao_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 fieldgrown bedding plants. Proceedings of Florida State Horticulture Society. 115: 123 – 127.USA CUN11 SOIL Ornamentals Open Field Page 14 of 20



## APPENDIX A: ORNAMENTAL SPECIES GROWN

The incredibly large and constantly changing number of species and cultivars grown in the ornamentals sector means that compiling a complete list of species and acreage grown is not possible. There are hundreds of types of cut flowe r, foliage, and bulb crops grown each year and often several species are grown in the same field s imultaneously. However, the U.S. has tried to describe the major crops below. Additional informa tion 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. 389USA CUN11 SOIL Ornamentals Open Field Page 15 of 20 C ROP A REA ( USUALLY FIELD )

- HA A REA ( USUALLY GREENHOUSE )

- HA

Total 2609 145 ha

1 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 assumed to have the highest acreage and they have been identified by the applicant as using methyl br omide.

A PPENDIX B T ABLE 3. F LORIDA O RNAMENTALS

- C ROP P RODUCTION FOR C ERTAIN C UT F LOWER S PECIES 2

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 for growers with sale s over $100,000.



### New York The nomination is for methyl bromide critical use i n New York is for hybrid anemones and ranunculus grown in greenhouses.USA CUN11 SOIL Ornamentals Open Field Page 16 of 20



## APPENDIX B: KEY TARGET PESTS

The ornamentals industry is complex; therefore, the following list is not comprehensive but is intended to demonstrate the large number of pests a ffecting ornamental production and creating a critical need for methyl bromide in the U.S. for th e 2011 growing season.

APPENDIX B TABLE 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 f or this crop; mandatory requirement to meet certification f or disease tolerance; no host resistance for a specifi c 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 w ith currently available pest control methods. Some meth yl

bromide alternatives used for other sectors are not feasible for floriculture due to high costs, diffic ulty timing applications to allow intercropping, and reg ulatory restrictions including township caps and buffer zon e 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 Florida’s regions of tropical and sub-tropical climates. Due to the complexity of the ornamentals sector, alternative pest control measur es have not been found for all species but research ef forts are ongoing. Iodomethane is now registered; howeve r, other methyl bromide alternatives preliminarily considered effective, such as dimethyl disulfide, a re not currently registered for use.

C. New York

Anemones Soil borne diseases and pests,

including Rhizoctonia

, Pythium

, Thielaviopsis , nematodes, symphylids, and the Anthracnose fungus Colletotrichum Infected corms from previous cropping cycles must a lso be controlled. Iodomethane is not registered, and other alternatives may be cost prohibitive or do not cont rol the entire pest spectrum. Several methyl bromide alternatives considered effective and registered fo r open field use do not have labels for greenhouse use.USA CUN11 SOIL Ornamentals Open Field Page 17 of 20



## APPENDIX C: STATUS OF METHYL BROMIDE ALTERNATIVES

APPENDIX C T ABLE 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 Flo rida and California further restrict its use in those states. Mandated plant-back times can be 1 t o 2 weeks longer with 1,3-D than with other fumigants. 1,3-D is not registered for use in gree nhouses.

Chloropicrin Technical

Weed control is poorer than with methyl bromide Con trol of the entire pest spectrum cannot be achieved with lower use rates, but there are concer ns 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 ty pe, moisture content, and temperature.

Regulatory Metam sodium is not registered for use in greenhous es.

Iodomethane Technical

More research needs to be done to understand applic ation and long-term efficacy issues.

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

1,3-D + chloropicrin Technical

This alternative does not control the entire pest s pectrum.

Regulatory In California, 1,3-D + chloropicrin is considered o ne of tthe best currently available alternatives, if label application rates were incre ased Township caps and buffer zones that exist for the individual chemicals also apply for the com bination.

Metam sodium + chloropicrin Technical

This combination does not adequately control nemato des and weeds, and performance is

inconsistent.

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

1,3-D + metam
sodium Technical

Efficacy data is inconsistent.

Regulatory Restrictions for the individual chemicals also appl y for the combinations.USA CUN11 SOIL Ornamentals Open Field Page 18 of 20

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 t he best currently available alternative, if use restrictions, such as township caps, were removed. 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 u nless in combination with 1,3-D, chloropicrin, and/or herbicides.

Regulatory: Restrictions on 1,3-D and chloropicrin prevent 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 t o its use in combination with other pest

control measures.

Steam Technical

Steam sterilization is not feasible in open field p roduction due to the need to remove the steam piping after application in order to accommodate cu ltural management practices. In greenhouses, steam has been successfully used in pr evious 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 t he following crop as volunteer weeds or reservoirs for pathogens.

Regulatory

None.

Herbicides Technical:

Crop damage may occur from contact with certain her bicides or in the following crop if soil

residues remain.

Regulatory Restrictions for registered pesticides vary dependi ng on the active ingredient(s) and individual product labels.USA CUN11 SOIL Ornamentals Open Field Page 19 of 20

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 th is 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 e fficacy of DMDS in ornamentals under an Experimental Use Permit.

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

Acrolein Technical:

Studies are currently being conducted to determine the efficacy of acrolein for ornamentals.

Regulatory: Acrolein is currently only registered 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 it s future regulatory status is unknown.

Sodium azide Technical:

More research is needed to understand its efficacy.

Regulatory: This alternative is not currently registered and it s 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 st udies have been conducted in the U.S. comparing efficacy with methyl bromide and other al ternatives.

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 gr eenhouse ornamentals. No research has been conducted on this product as a pre-plant pesticide in at least 6 years.

Regulatory: There is no commercial development or planned regis tration of this product currently.USA CUN11 SOIL Ornamentals Open Field Page 20 of 20

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 tria ls. Regional subclimates with significant cloud cover or cooler annual temperatures 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 environmenta l regulations) and lack of registration.