USA CUN13 SOIL TOMATOES Open Field Page 1 of 28



### NOMINATING PARTY : The United States of America NAME USA CUN 13 SOIL TOMATOES Open Field BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Critical Use Nomination for Pre

- plant Soil Use for Tomato Grown in Open Fields (Submitted in 20 1 1 for 20 1 3 Use Season) CROP NAME (OPEN FIEL D OR PROTECTED): Tomato es Open Field QUANTITY OF METHYL B ROMIDE REQUESTED: T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE REQUESTED IN E ACH Y EAR OF N OMINATION

Year N OMINATION A MOUNT (K ILOGRAMS ) 2013 10,741 kg 

### NOMINATING PARTY CONTACT DETAILS: Contact Person: John Thompson Title: Division Director Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2658 Washington, D.C. 20520 U.S.A. Telephone: (202) 647

- 9799 Fax: (202) 647

- 5947 E
- ma il : thompsonje2 @state.gov Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption

. . 

### ■ Yes  No

Signature Name Date Title: (Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secreta riat website under Decision Ex. I/4(8).) This form is to be used by holders of single

- year exemptions to reapply for a subsequent year’s exemption (for example, a Party holding a single

- year exemption for 2005 and/or 2006 seeking further exemptions for 2 007). It does not replace the format for requesting a critical

- use exemption for the first time. In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on which the Party’s first

-

year exemption was ap

proved, as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not re - submit that earlier information. 

### CONTACT OR EXPERT(S) FOR FURTHER TEC HNICAL DETAILS:USA CUN13 SOIL TOMATOES Open Field Page 2 of 28

Contact/Expert Person: Jack Housenger Title: Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D .C. 20460 U.S.A. Telephone: (703) 308

- 8200 Fax: (703) 308

- 7042 E
- ma il: Housenger.Jack@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE: 1. PAPER DOCUMENTS: Ti tle of paper documents and appendices No. of pages Date sent to Ozone Secretariat USA CUN 1 3 SOIL TOMATOES Open Field 27

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming convention see notes above) N o. of kilobytes Date sent to Ozone

Secretariat USA CUN 1 3 SOIL TOMATOES Open Field
* Identical to paper documentsUSA CUN13 SOIL TOMATOES Open Field Page 3 of 28



## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE ( OPEN FIELD OR PROTECTED ENVIRONMENT) TOMATOES 1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE This nomination is for methy l bromide use in the production of tomatoes in Florida, Georgia , The Mid

- Atlantic (Maryland, and Virginia), and t he Southeast

. U .S. t omato growers have been reducing meth yl bromide use rates in all production areas. The USG has reviewed all factors affecting transition rates in this sector. Based on this assessment the transition rate has been greatl y increased for most portions of this sector. For the area covered in this nominat ion, the USG believes that the narrative discussion included in this document is technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on those sub

- sectors that cannot transition away from methy l bromide at the accelerated rate. Th e primary

fumigant alternatives for methyl bromide that have shown promise against key tomato pests the spring application of the fumigant combination of 1,3 D , followed by chloropicrin alone, followed b y metam - sodium and the newl y registered fumigant iodo methane. Current research has demonstrated that in many cases iodomethane (MIDAS®) formulated with chloropicrin can be an efficacious methy l bromide alternative, however, transition time will be needed for many

tomato producers to adapt production to usin g this material

. Growers will need this time to adapt to the use of new application equipment appropriate to the lower flow rates ty pical with iodomethane, to retro

- fit equipment in order to avoid corrosion by iodomethane, etc. In creased costs due to usin g iodomethane are described in the "economic assessment" section below

. For 2009, crop experts at the University of Georgia reported that the price of iodomethane went up so dramaticall y that they did not advise growers to use the product, despite its g ood efficacy

. It is not clear whether or not these high prices affected other tomato growing regions included in this nomination , or how long the high prices will persist . However, at the very least, this information does suggest that adoption of iodometha ne b y tomato growers will be significantl y affected b y price fluctuations

. Application protocols have not been sufficiently established due to limited results of long term on - farm research. A major concern with the use of iodomethane is the potential incr ease of plant

- back timing to avoid potential crop injury and loss

. In other recent work, some research results with dimethy l disulfide (DMDS) indicate that this fumigant is promis ing. Ho wever , preliminary research results from a single ye ar of fumigatio n in pepper production demonstrate that , as a stand

- alone product , the efficacy of DMDS is not comparable to meth yl bromide and will require chloropicrin (MacRae and Culpepper, 2008)

. Treatments with DMDS plus chloropicrin and/or metam - sodium are not sign ificantly different from methy l bromide + chloropicrin , though growers will need time to adapt to this alternative and the strong odor created by DMDS.USA CUN13 SOIL TOMATOES Open Field Page 4 of 28



### The application of a sequential 3 way fumigant combination , the “Geor gia 3 Way ” (consisting of 1,3
- D , f ollowed b y chloropicrin, followed b y metam - sodium or metam

- potassium), continues to be evaluated . It is considered to be useful as a spring applied fumigant mix in the state of Georgia

. It should be noted that a major part of developing a commercially fea sible protocol to use this sy stem in all regions will require adjustment of rates and application timing for field and strip applications

. Trials evaluating the “Georgia 3 Way ” show that it can be as efficacious against key

southern US tomato pests as methy l bromide and/or iodomethane + chloropicrin

. An exception to this i s a study b y Chellemi (2008) where , in some trials, pepper plant height and yi eld was reduced due to crop injury . H owever, the injury was later correlated with high levels of soil potassi um and probably not a direct result of the fumigation. W eed and nematode control for the “Georgia 3 Way ” as compared to methy l bromide were not different

. Adding to the slow adoption of this sy stem is the lack of established protocol that will be based on mitigating potential problems such as plant

- back timing, soil moisture, and location/edaphic variabilit y . The increased production costs, and cost of new or altered equipment needed for application will also be an impediment to adoption of the three fumi gant mix. Florida Some production areas in Florida are located above karst topographic formations which places restrictions on the use of 1,3

- D. Sting ing nematode problems require either methyl bromide or 1,3
- D. Some f

ields with key

disease problems ha ve achieved good control with chloropicrin, although there may

be regulatory

restrictions on its use at high rates

. Where 1,3

- D is allowed, the application of the three fumigant mix continues to be evaluated but is not considered a viable alternative. Pr eliminary

research has demonstrated that iodomethane can be an efficacious methy l bromide alternative, but protocols have not been sufficiently established . Given sufficient time to transition this fumigant can be worked into the production sy stem. Geor gia The three way fumigant combination (the ‘Georgia 3 Way ’) continues to be evaluated, and has proven to be efficacious for spring application in Georgia. However, the lack of established protocol and the cost of new or altered equipment have been a lim iting factor in the adoption of this fumigant combination. Preliminary

research has demonstrated that iodomethane can be an efficacious methy l bromide alternative , but protocols have not been sufficiently established

. Given suff

icient time to transition these fumigants can be worked into the production sy stem. Mid - Atlantic Current r esearch in this region has not been submitted and it is thus assumed that the use of iodomethane as a meth yl bromide replacement , gi ven time to transition , will be sufficie nt
. However, just as in many areas of the country , the establishment of protocols will slow farmerUSA CUN13 SOIL TOMATOES Open Field Page 5 of 28



### adoption

. Until results from on

- farm research projects have established a protocol a period of transition will be needed

. Southeast The “Georgia 3 Way ” f

umigant combination continues to be evaluated in the southeast. In a comment by

Craig Anderson of the Universit y of Arkansas, the cool temperatures and wet soils in earl y spring will extend the plant back timing due to the additional time needed for soil fumigant levels to dissipate to avoid crop injury and subsequent y ield loss (Toth, 2008) Preliminary

research conducted in states other than those in the southeast have demonstrated that iodomethane can be an efficacious meth yl bromide alternative, but p rotocols have not been sufficiently

established

. Concerns in the southeast about injury and delay ed planting have lead some to question their usefulness in this region. Currentl y, there are several economic drawbacks that include the cost of iodomethane, the cost of using VIF or metalized mulches, and an initial cost of some minor equipment alteration. U.S. reliance on meth yl bromide has dramatically and rapidl y been reduced over the last eight ye ars. Critical use exemption (CUE) requests have decreased every y ear since the U.S. phase

out process began. The development, registration, and use of new pest control products and production methods have been key to the progress and reductions made to

- date. As alternatives have demonstrated their suitability , as thorough reviews of research results and applicant information have been conducted, and contacts have been made with regional crop experts to assess the technical and economic feasibility of alternatives, U.S. Government (USG) requests have reduced b y 99%, for the fruiting vegetables, over the last 9 y ears. However, as the amount of methy l bromide available for use decreases each y ear, substantial challenges exist in the collection of needed data to substantiate on

- going critical needs through the CUE process. There are now several alternatives for soil fumigation, including 1,3

- dichloropropene plus chloropicrin, the “UGA 3 Way ” combination (1,3

- dichloropropene plus chloropicrin followed b y metam sodium), iodomethane plus chloropicrin, and dimethy l d isulfide (DMDS) which have demonstrated some technical and economic feasibility for pest control in a number of vegetable crops in the U.S. Southeast. However, CUE applicants in this nominated sector have indicated that they are not alway s suitable for al l situations. While DMDS has a Federal registration and has demonstrated effectiveness, it is not currentl y registered in all the relevant states. Given the timing of state registrations, lack of experience using this alternative, and application methods still under development to minimize odor in communities surrounding treated fields there is uncertaint y in predicting when this alternative can be reasonabl y expected to adequatel y replace methy l bromide in specific application scenarios. While the DMDS registrant has been working with the product to reduce the odor, and growers are gaining experience in its use, work is still needed on application approaches for the alternative to be fully available for use in U.S. southeast vegetable crops. For example individual operators and small farms, which account for up to eight y percent of the growers in this nominated sector are especially hard

- pressed to make this transition, because one of the most promising alternatives requires additional money to convert their fumigation equipment and custom fumigation applicators are not available in allUSA CUN13 SOIL TOMATOES Open Field Page 6 of 28



### areas. In addition to the expense to convert to the alternatives, there have been reports that the alternatives do not perform as well as the MeBr:pic combination. Th ese concerns about the alternatives have onl y recently been brought to the USG attention and insufficient supporting information was provided. Because of the uncertainties and challenges associated with the use of the available alternatives, the USG belie ves it most prudent and the best public policy

to collect additional information so that the technical and economic impacts of these reported problems can be evaluated. The USG will request the applicants provide additional information to us no later than June 1, 2011 so that the information can be anal yz ed and provided to MBTOC by July 15, prior to the Open Ended Work Group (OEWG) meeting in earl y August. The quality of an y additional information received will first be evaluated in terms of whether or no t it supports a compelling case and confirms problems with the feasibility of alternatives. Then, on that basis, the USG will either support or withdraw this nominated sector at that meeting. The nomination attached specifies the correct year (2013) and amount of methy l bromide that is being requested for the individual crops within this sector. However, there has been no attempt to update the information in this document regarding the new research, availability of alternatives, etc. Since the USG lear ned of the issues facing the growers within this sector, after speaking directl y with researchers familiar with the specific problems only very recentl y , this information was not available at the time the USG recommendation was developed.
2. SUMMARIZ E WHY KEY ALTERNATIVES ARE NOT FEASIBLE Our review of available research on other meth yl bromide alternatives discussed by MBTOC for tomatoes suggests that, of the registered (i.e., legally available) chemistries , iodomethane, and combinations of metam so dium , 1,3
- D , and/or chloropicrin have shown some potential as commerciall y viable replacement to meth yl bromide. Non

- che mical alternatives are either not viable for US tomatoes or requi re more research and commercial development before they can be technic all y and economically feasible. For some areas in the state of Georgia , a 3 way fumigant combination of 1,3 D , followed by chloropicrin alone, followed by metam - sodium, has shown promise against key tomato pests in spring season only fumigation. However, the aforementioned fumigant combination has not met with success in other areas of the southeast. The transition rate included in the BUNNIE incorporates an estimate of projected use of this strategy as well as the use of iodomethane

. Many of the alternatives require the evaluation of their relationship between fumigant alternatives, various mulches, and herbicide s ys tems under different growing conditions. From this information on

- farm protocols can be established. Alternatives are considered not feasi ble where : 1) they have not been sufficiently tested or protocols have not been sufficiently developed for their use 2) costs are excessive 3) application difficulties exist due to such factors as equipment requirementsUSA CUN13 SOIL TOMATOES Open Field Page 7 of 28



### 4) pest pressure is so high that alternatives ar e not effective 5) not registered for use in the US (such as DMDS )

. 6) There are significant restrictions on which crops can be rotated through after use of a given alternative (e.g., halosulfuron has rotational restrictions that prevent its use in southeastern US tomatoes). 7) Resistance management prevents use of the alternative (e.g., gl yphosate resistant weeds, such as Amaranth, in the southern US, prevent use of this alternative as a post

- emergent weed control in those regions). The US nomination is only fo r those areas where the alternatives are still under extensive evaluation and pest pressure is high . In US tomato production there are several factors that make some of the assumed alternatives , other than iodomethane, unsuitable. These include: 1) Pest control efficacy

of alternatives: the efficacy of alternatives may

not be comparable to meth yl bromide in some areas, making these alternatives technicall y and/or economically

infeasible for use in tomato production. 2) Geographic distribution of key target pest s: i.e., some alternatives may be comparable to methy l bromide as long as key pests occur at low pressure. The US is only nominating a CUE for tomato where the key pest pressure is moderate to high such as nutsedge in the Southeastern US. 3) Regulatory

constraints: e.g., in Florida due to the presence of karst topographical features. 4) In Virginia and much of the mid

- Atlantic, high water tables and the close proximity of production areas to environmentally sensitive estuaries makes the use of 1,3

- D limited. 5) D elay in planting and harvesting: e.g., the plant

- back interval for telone+chloropicrin is two weeks longer than methy l bromide+chloropicrin. Delay s in planting and harvesting result in users missing key market windows, and adversel y affect revenues through lower prices. 6) Alternatives that are nonselective are restrictive as a preplant burndown only

. 3. IS THE USE COVERED B Y A CERTIFICATION ST ANDARD? N ot used to meet a certification standard

. 4 . IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, I NDICATE THE REASON W HY METHYL BROMIDE IS NOT USED IN THE OTHE R AREA, AND IDENTIFY W HAT ALTERNATIVE STRA TEGIES ARE USED TO CONTROL THE TARGET P ATHOGENS AND WEEDS W ITHOUT METHYL BROMIDE THERE. In the areas where meth yl bromide is not currentl y used there i s ofte n low weed and/or pathogen pressure and/or no restrictions on 1,3

- D use
. I n areas where 1,3

- D can be used, there are a man y growers have cooperated with universities and others on developing application protocolsUSA CUN13 SOIL TOMATOES Open Field Page 8 of 28



### specific to their conditions for th e 3 way fumigant combination ( 1,3 D, followed b y chloropicrin alone, followed b y metam - sodium )

. 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 B E NECESSARY TO ENABL E THIS? No, areas that use meth yl bromide do so because environmental sensitivity and /or heav y pest pressure preclude the use of fumigants that are employ ed when these conditions are not present. The USG has reviewed all factors affec ting transition rates in this sector. Based on this assessment the transition rate has been greatl y increased for most portions of this sector. For the area covered in this nomination, the USG believes that the narrative discussion included in this docume nt is technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on those sub

- sectors that cannot transition away from methy l bromide at the accelerated rate. Research ers are continuing to evaluate fumigant concentration and mulch inter action using the 3 way fumigation combination and iodomethane ( Culpepper et al, 2007 ). However, there is still the need for more research to determine the fumigant rate s and mulch combinations needed for pest control and crop safety where there is heavy p est pressure . In a study by Culpepper ( Georgia C U E appendix 20 11 ; see Appendix A for a reproduction of this submission ) , the 3 way fumigant combination resulted in tomato plant heights that were lower than the methy l bromide treat ed plots. When using the Blockade mulch (low permeabilit y tarp) injury was severe with plant damage and tomato y ields being reduced even when the soil was allowed to air, but they have seen good results in spring applications

. This is similar to information provided b y growers and university

personnel in the southeast (Toth , 2008 ) T ABLE 2 . T OMATO P LANT YIELDS AND HEIG HT IN RESPONSE TO TI ME OF PLANTING AFTER FUMIGATING . Fumigant Mulch Planting days after fumigation Gas in bed at

planting (ppm) Yield

(#/plot, highest value fruit only; no difference noted with total fruit) Heights (cm) (3 wk after planting) MB LDPE 7 29 127 a 38 a 3
- WAY LDPE 7 77 127 a 32 cd 3
- WAY Blockade 7 368 55 c 14 f MB LDPE 7 + 1 2 117 a 37 ab 3
- WAY LDPE 7 + 1 13 132 a 33 cd 3
- WAY Blockade 7 + 1 31 99 b 27 e MB LDPE 14 2 142 a 37 ab 3
- WAY LDPE 14 4 132 a 34 bc 3
- WAY Blockade 14 38 114 a 30 de MB LDPE 14 + 1 0 133 a 35 abc 3
- WAY LDPE 14 + 1 3 127 a 33 cd 3
- WAY Blockade 14 + 1 27 119 a 30 de Source: Georgia CUE Appendix ; see Appendix A for a reprodu ction of this submission

. 

### Developing a protocol for this sy stem includes the titration of rates for field and stripUSA CUN13 SOIL TOMATOES Open Field Page 9 of 28



### applications ( table 3 ). Inpreliminary data comparing the 3 fumigant combination , results have demonstrated that methyl bromide and iodome thane do not significantly differ in efficacy

. However variabilit y among results across locations demonstrates the need for further research ( Toth, 2008 ). An exception to th ese findings was a study by Chellemi (2008) where pepper plant height and yi eld w as reduced due to crop injury ; however, the injury was later correlated with high levels of soil potassium and probabl y not a direct result of the fumigation. On the other hand, i n three of the trials weed and nematode control for the three fumigant combi nation and methy l bromide were low ; less than 0.01 weeds / foot of row and nematode concentration was less than 1.0 / 100 cc of soil. TABLE 3. UGA Three FUMIGANT COMBINATION Adjusted Rates 11 - 2008.

Fumigant(s) Rate (lb/acre) Rate Adjusted for Strip

Treat me nt (lb / acre) Me thod Methyl Bromide 143 83 83 bedded, shank, standard tarp Chloropicrin 143 Methyl Bromide 143 83 83 bedded, shank, high barrier tarp Chloropicrin 143 1,3
- Dichloropropene 171 99 87 186 bedded, shank, standard tarp Chloropi crin 150 Metam Sodium 320 1,3
- Dichloropropene 171 99 87 186 bedded, shank, high barrier tarp Chloropicrin 150 Metam Sodium 320 Source: Rates and application methods represent likely scenarios based on information from USDA NASS, EPA proprietary data, and/or stakeholder

- submitted comments. Table taken from Georgia CUE Appendix ; see Appendix A for a reproduction of this submission

. 

### Tomato growers in Maryland have again requested methyl bromide. These growers have historically

used meth yl bromid e in their tomato production, purchasing it from the stockpile since the 2005 ban. Mary land growers, in common with other tomato growers in the mid

Atlantic region, have production areas with high water tables and in close proximity to environmentally

sen sitive estuaries; these factors make the use of 1,3

- D limited, and thus the three fumigant combination cannot be considered as an alternative. Techniques such as g rafting , resistant rootstock s immune to target fungal pathogens , plant breeding , soil

- less c ulture , organic production , substrates , plug , are not commercially feasible

. Availability

of such transplants is further hampered by the lack of infrastructure to make grafted tomato plants available on a large scale, concomitant with this is the high pre mium associated with these transplants at this time. Grafting and plant breeding are thus also rendered technically infeasible as meth yl bromide alternatives for control of fungal pathogens, nutsedges and nematodes. Grafting of solanaceous plants is relatively new to US growers, and has met with a great deal of concern regarding the potential for the establishment of off

- ty pe plants developing from the rootstock and/or fruit seeds

. N. Burell et al

. (200 8 ) evaluated various grafted tomato cultivars in fiel ds where iodomethane, DMDS, or methy l bromide were applied. The results of their research demonstrated that regardless of rootstock, yields of tomato plants responded equally without regard to fumigant t ype. In this case it would seem that the stead y pac e of on going transitioning to alternative herbicides such as iodomethane would be more advantageous to pursue .USA CUN13 SOIL TOMATOES Open Field Page 10 of 28



### 6. SUMMARY OF RECENT RESEARCH As mentioned earlier in this document, iodomethane formulated with chloropicrin has shown good efficacy

against key

tomato pests, including nutsedge, in a number of trials with tomato and related vegetables such as peppers (e.g., Louws et al. 2006, Culpepper 2006, 2007, 2008, Culpepper et al. 2008, Olsen 2008). Iodomethane had time limitations removed from its fede ral label in October, 2008, and has received state

- level approval in 47 US states (California, Washington, and New York are the exceptions at this time). However, other important constraints must be considered when assessing the feasibility of iodomethane as a meth yl bromide alternative. These include: (1) the cost of iodomethane formulations is higher than methy l bromide, and will probably remain so for the next several y ears, (2) growers and researchers will need time to evaluate iodomethane use in the v arious local production conditions covered b y this nominations, and (3) growers and applicators will need to make some equipment modifications to adapt to the lower flow rates t ypical with less expensive iodomethane application rates and to avoid the corro sion of some metals that can occur with iodomethane (Sumner 2005, Noling et al. 2006). The economic impact of using iodomethane is further described in item 7 in this document (below). A consideration of these aspects has led the USG to conclude that whil e iodomethane appears to be technicall y feasible to manage key tomato pests in all parts of the US where it has been registered, time will be needed for growers and extension service experts to adapt its use successfully . Therefore, the amount of methy l br omide nominated for tomato has been adjusted downward while also considering the time needed to transition to iodomethane. Performance data presented by B. Olsen at the November 2008 MBAO conference reported tomato yield data from 12 field sites where th e average increase in yi elds from iodomethane treated plots over meth yl bromide treated plots was 11 percent. Ten of the 12 study sites were in the southeast. It must be noted that there was no statistical anal ys is present with this data and as such ther e is no confirmation on whether this reported average increase in yields is significant. Despite these results, representatives of the southeast tomato growers’ consortia are currently cautious about recommending iodomethane as a methy l bromide replacement (Toth , 2008). R esearch conducted in Georgia demonstrated that , in small plot s, purple nutsedge control for methy l bromide, iodomethane, and DMDS were not significantl y different under LDPE, metalized, or VIF mulch (table 4 ). Yields of pepper and cucumb er plants fumigated with iodomethane under VIF were not different from yields for untreated plots (Culpepper et al, 2007). The reader should keep in mind here that DMDS is not registered for use in the USA. In a study by Chellemi (2008) , pepper plant he ight and yield was reduced due to crop injury

. H owever, the injury

was later correlated with high levels of soil potassium and probabl y not a direct result of the fumigation. Inthis same study, three of the four trials reported weed and nematode control for the three fumigant combination and methy l bromide at less than 0.01 weeds / foot of row and nematode concentration at less than 1.0 / 100 cc of soil.USA CUN13 SOIL TOMATOES Open Field Page 11 of 28

T ABLE 4 . P URPLE NUTSEDGE PLANT S IN SMALL PLOT PEPP ER CROP (20 SQ FT )

* Fumigant(s) Mulch LDPE Me ta lized VIF Methyl Bromide 0.5 a 0.0 a 0.3 a Iodom ethane 0.8 a 0.3 a 0.8 a DMDS 2.5 a 0.5 a 0.0 a Untreated 84 d 76 d 54 c *All fumigation treatments contain chloropicrin

. Table taken from Culpepper et al ( 2007 ) 

### Hausbeck and Cortright (2007) measured c u curbit plant vigor to determine fumigant/mulch interactions using either LPDE or VIF plastic mulch for the control of Fusarium oxysporum . Of the fumigants used in the study , the meth yl bromide and iodomethane treatments resulted in cantaloupe plants with the highest vigor (Table 5 ) . In general, treatments under L PDE had higher plant vigor when compared with plants grown under VIF. It is noteworthy that in this study VI F tarps were prone to wind removal, which reduce d their reliabilit y under some growing conditions.
T ABLE 5 : E VALUATION OF F UM IGANTS AND P LASTIC M ULCHES FOR M ANAGING F USARIUM IN C UCURBIT C ROPS 2007 Treatment (time after treatment to planting) Rate of formulated product Vigor *
Untreated control under LDPE (5 days) 1.0
- 1.3 a ** Iodometh ane+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 days) 280 kg/ha 1.0 a Methyl bromide+chloropicrin 67:33 under VIF (10 days) 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 variable stand, 10=complete plant death. ** Column means with a letter in common are not significantly different (Fisher LSD Method; P=0.05). From Hausbeck and Cortright 2007. 

### In addition to the limitations of VIF discussed above, the USG notes that the plant vigor in 1,3 D treatments in these new trials is lower than that seen in methyl bromide treatments. This is similar to what was seen in previo us y ear s ’ tests (Hausbeck and Cortright 2004; see also discussion in the cucurbit nominations ).USA CUN13 SOIL TOMATOES Open Field Page 12 of 28



### As far as the USG has been able to determine, no other studies have been conducted since 2007 to evaluate the technical and commercial feasibility of fumigant alternatives to methyl bromide for controlling F. oxysporum subty pes under production conditions relevant to the Maryland/Delaware r egions.
7. ECONOMIC FEASIBILITY OF ALTERNATIVES The following economic anal ys is is organized by methy l bromide critica l use application regions. Reader s should note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct losses of income that may be suffered by

the users. It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability

of an operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net income should be smaller than the net revenue measured in thi s study

. F ixed costs were not included because they are often difficult to measure and verify

. Summary of Economic Feasibility The economic anal ys is of the tomato application compared data on yi elds, crop prices, revenues and costs using meth yl bromide and using alternative pest control regimens in order to estimate the loss of methy l bromide availability . The alternatives identified as technically feasible

- in cases of low pest infestation 1



### – for different regions by the U.S. are: (a) i odomethane and (b) 1,3

- dichloropropene and c hloropicrin followed b y chloropicrin, followed b y metam sodium/potassium (otherwise referred to as the Georgia 3

- Way)

. The economic factors that drive the feasibility analy sis for fresh market tomato uses of methyl bromide a lternatives are: (1) yi eld losses, referring to reductions in the quantity produced, (2) increased production costs, which may be due to the higher

- cost of using an alternative, additional pest control requirements, and/or resulting shifts in other product ion or harvesting practices (3) qualit y losses, which generall y affect the quantity and price received for the goods, and (4) missed market windows due to plant back time restrictions, which also affect the quantity and price received for the goods. The e conomic reviewer then anal yz ed crop budgets for pre

- plant sectors to determine the likel y economic impact if methy l 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. Itis relatively eas y to measure, but may

be difficult to interpret in isolation. (2) Loss per Kilogram of Methyl Bromide . This measure indicates the value of methy l bromide to crop production.
1 It should be noted that the USG does not request methyl bromide for use in areas of low to m oderate pest pressure. Only cases where key pests are present at moderate to high levels require methyl bromide for pest pressure.USA CUN13 SOIL TOMATOES Open Field Page 13 of 28



### (3) Loss as a Perc entage of Gross Revenue. This measure has the advantage that gross revenues are usually

eas y to measure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high value commodities or crops may provide high revenues but may a lso entail high costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity

. (4) Loss as a Percentage of Net Operating Revenue . We define net cash revenues as gross revenues minus operatin g costs. This is a very good indicator as to the direct losses of income that may be suffered by

the owners or operators of an enterprise. However, operating costs can often be difficult to measure and verify

. (5) Operating Profit Margin . We define ope rating profit margin to be net operating revenue divided by

gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methy l bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more difficult, therefore fixed costs were not included in the anal ys is. These measures represent different way s to assess the economic feasibility of methy l bromide alternatives for meth yl bromide users, who are tomato producers in th is case. Because producers (suppliers) represent an integral part of an y definition of a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using meth yl bromide. The econo mic measures provide the basis for making that determination. E astern US We conclude that, at present, iodomethane would be the economically fe asible alternative to methy l bromide for use in Eastern US tomato production in areas exhibiting karst topograph ical features

. However, see the technical discussion above for a description of reasons wh y time will be needed for growers to transition to routine, commerciall y feasible iodomethane use. In areas where karst features are not present it appears that tomato growers can use a combination of three fumigants applied sequentially (1,3

- D, chloropicrin , and metam

- sodium/potassium ) and achieve yi elds that are comparable to those produced by using methy l bromide for spring crops only . The USG factored this new te chnique into their request by adding a four y ear transition (assuming that all non

- karst spring fumigations for tomatoes in the Southeast will transition away from methy l bromide over four y ears) for spring fumigations.USA CUN13 SOIL TOMATOES Open Field Page 14 of 28

T ABLE 6 . V IRGINIA : E CONOMIC I MPAC TS OF M ETHYL B ROMIDE A LTERNATIVES VIRGINIA TOMATO GROW ERS M ETHYL B ROMIDE Iodomethane GA
– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0 % P RODUCTION PER H ECTARE ( CWT ) 920 920 920 * P RICE PER U NIT ( US $) $ 33 $ 33 $ 3 3

= G ROSS REVENUE PER H ECTARE ( US $) $ 29,902 $ 29,902 $ 29,902

- O PERATING C OSTS PER H ECTARE ( US $)* $ 26,907 $ 28,354 $ 27,687

= N ET REVENUE PER H ECTARE ( US $) $ 2,995 $ 1,548 $ 2,215 1. L OSS PER H ECTARE ( US $) $ - $ 1,447 $ 780 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 17 $ 9 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 5% 3% 4. L OSS AS A P ERCENTAGE OF N E T O PERATING REVENUE (%) 0% 48% 26% 5. O PERATING P ROFIT M ARGIN (%) 10% 5% 7% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. T ABLE 7 . M ARYLAND : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES MARYLAND TOMATO GROW ERS M ETHYL B ROMIDE Iodomethane GA
– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0 % P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,953 4,953 4,953 * P RICE PER U NIT ( US $) $ 7 $ 7 $ 7

= G ROSS REVENUE PER H ECTARE ( US $) $ 35,287 $ 35,287 $ 35,287

- O PERATING C OSTS PER H ECTARE ( US $)* $ 30,269 $ 31,969 $ 31,888

= N ET REVENUE PER H ECTARE ( US $) $ 5,018 $ 3,319 $ 3,399 1. L OSS PER H ECTARE ( US $) $ - $ 1,699 $ 1,619 2. L OSS PER KIL OGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 23 $ 22 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 5% 5% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 34% 32% 5. O PERATING P ROFIT M ARGIN ( %) 14% 9% 10% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. Error! Bookm ark not defined.USA CUN13 SOIL TOMATOES Open Field Page 15 of 28

T ABLE 8 . S OUTHEASTERN US: E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES SOUTHEASTERN TOMATO CONSORTIUM

** M ETHYL B ROMIDE Iodomethane GA
– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0 % P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,942 4,942 4,942 * P RICE PER U NIT ( US $) $ 7 $ 7 $ 7

= G ROSS REVENUE PER H ECTARE ( US $) $ 35,830 $ 35,830 $ 35,830

- O PERATING C OSTS PER H ECTARE ( US $)* $ 33,913 $ 35,4 28 $ 34,762

= N ET REVENUE PER H ECTARE ( US $) $ 1,918 $ 402 $ 1,069 1. L OSS PER H ECTARE ( US $) $ - $ 1,516 $ 849 2. L OSS PER KILOGRAM OF M ETHYL B ROMI DE ( US $) $ - $ 20 $ 11 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 4% 2% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 79% 44% 5. O PERATING P ROFIT M ARGIN (%) 5% 1% 3% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. ** Includes: South

- Eastern United States (Alabama, Arkansas, Kentucky, Louisiana, Mississip pi, North Carolina, South Carolina, and Tennessee)

. T ABLE 9 . G EORGIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES GEORGIA FRUIT & VEGE TABLE GROWERS ASSOCIATION M ETHYL B ROMIDE Iodomethane GA
– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0 % P RODUCTIO N PER H ECTARE (BOX 25 LBS ) 6,830 6,830 6,830 * P RICE PER U NIT ( US $) $ 9 $ 9 $ 9

= G ROSS REVENUE PER H ECTARE ( US $) $ 58,342 $ 58,342 $ 58,342

- O PERATING C OSTS PER H ECTARE ( US $)* $ 56,522 $ 57,763 $ 58,178

= N ET REVENUE PER H ECTARE ( US $) $ 1,820 $ 578 $ 164 1. L OSS PER H ECTARE ( US $) $ - $ 1,241 $ 1,656 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8 $ 11 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 2% 3% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 68% 91% 5. O PERATING P ROFIT M ARGIN (%) 3% 1% 0% *Note that the measures in the tables below m ust be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. 

### Florida We conclude that, at present, iodomethane would be the ec onomically feasible alternative to methy l bromide for use in Florida tomato production in areas of karst topograph y . Where karstUSA CUN13 SOIL TOMATOES Open Field Page 16 of 28



### features are not present the USG assumed that the sequential application of the three chemicals (discussed above) would have results that are similar to the performance of methy l b romide for spring plantings. Consequently , as described above, the transition was adjusted to account for the new combination T ABLE 10 . F LORIDA N ORTH : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FLORIDA FRUIT & VEGE TABLE ASSOCIATION

– NORTH FLORIDA M ETHYL B ROMIDE Iodomethane GA

– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0% P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3,548 3,548 * P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

= G ROSS REVENUE PER H ECTARE ( US $) $ 34,874 $ 34,874 $ 34,874

- O PERATING C OSTS PER H ECTARE ( US $)* $ 30,804 $ 32,515 $ 31,848

= N ET REVENUE PER H ECTARE ( US $) $ 4,070 $ 2,359 $ 3,026 1. L OSS PER H ECTARE ( US $) $ - $ 1,711 $ 1,044 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 20 $ 12 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 5% 3% 4. L OSS AS A P ERCENTAGE OF N ET O PERATI NG REVENUE (%) 0% 42% 26% 5. O PERATING P ROFIT M ARGIN (%) 12% 7% 9% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. T ABLE 1 1 . F LORIDA RUSKIN PALMET TO : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FLORIDA FRUIT & VEGE TABLE ASSOCIATION

– RUSKIN PALMETTO M ETHYL B ROMIDE Iodomethane GA

– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0% P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3 ,548 3,548 * P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

= G ROSS REVENUE PER H ECTARE ( US $) $ 34,874 $ 34,874 $ 34,874

- O PERATING C OSTS PER H ECTARE ( US $)* $ 32,722 $ 33,452 $ 32,785

= N ET REVENUE PER H ECTARE ( US $) $ 2,152 $ 1,422 $ 2,089 1. L OSS PER H ECTARE ( US $) $ - $ 730 $ 63 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 7 $ 1 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 2% 0% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 34% 3% 5. O PERATING P ROFIT M ARGIN (%) 6% 4% 6% *Note that the measures in the tables below mu st be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.USA CUN13 SOIL TOMATOES Open Field Page 17 of 28

T ABLE 12 . F LORIDA PALM B EACH : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FLORIDA FRUIT & VEGE TABLE ASSOCIATION

– PALM BEACH M ETHYL B ROMIDE Iodomethane GA

– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0% P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,666 4,666 4,666 * P RICE PER U NIT ( US $) $ 11 $ 11 $ 11

= G ROSS REVENUE PER H ECTARE ( U S $) $ 50,152 $ 50,152 $ 50,152

- O PERATING C OSTS PER H ECTARE ( US $)* $ 48,230 $ 49,197 $ 48,530

= N ET REVENUE PER H ECTARE ( US $) $ 1,922 $ 955 $ 1,622 1. L OSS PER H ECTARE ( US $) $ - $ 967.11 $ 300.23 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8.63 $ 2.68 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 2% 1% 4. L OSS AS A P ERCENTAGE OF N ET O PE RATING REVENUE (%) 0% 50% 16% 5. O PERATING P ROFIT M ARGIN (%) 4% 2% 3% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. T ABL E 13 . F LORIDA S OUTHWEST : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FLORIDA FRUIT & VEGE TABLE ASSOCIATION

– SOUTHWEST M ETHYL B ROMIDE Iodomethane GA

– 3 W AY M ETHOD P RODUCTION L OSS (%) 0% 0% 0% P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,666 4,666 4,66 6 * P RICE PER U NIT ( US $) $ 11 $ 11 $ 11

= G ROSS REVENUE PER H ECTARE ( US $) $ 50,152 $ 50,152 $ 50,152

- O PERATING C OSTS PER H ECTARE ( US $)* $ 48,230 $ 49,197 $ 48,5 30

= N ET REVENUE PER H ECTARE ( US $) $ 1,922 $ 955 $ 1,622 1. L OSS PER H ECTARE ( US $) $ - $ 967.11 $ 300.23 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8.63 $ 2.68 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 2% 1% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 50% 16% 5. O PERATING P ROFIT M ARGIN (%) 4% 2% 3% *Note that the measures in the tables below must be interpreted care fully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.USA CUN13 SOIL TOMATOES Open Field Page 18 of 28

T ABLE 14. F LORIDA D ADE : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES FLORIDA FRUIT & VEGE TABLE ASSOCIATION

– DADE M ETHYL B ROMIDE Iodomethane M ETAM P LUS C HLOROPICRIN P RODUCTION L OSS (%) 0% 0% 15% P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3,548 3,016 * P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

= G ROSS REVENUE PER H ECTARE ( US $) $ 34,874 $ 34,874 $ 29,643

- O PERATING C OSTS PER H ECTARE ( US $)* $ 34,172 $ 34,665 $ 34,202

= N ET REVENUE PER H ECTARE ( US $) $ 702 $ 209 $ (4,559) 1. L OSS PER H ECTARE ( US $) $ - $ 493 $ 5,261 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 3 $ 35 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0% 1% 15% 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0% 70% 750 % 5. O PERATING P ROFIT M ARGIN (%) 2% 1% - 15% *Note that the measures in the tables below must be interpreted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs. 

### 8. RESULTANT CHANGES TO REQU ESTED EXEMPTION QUANTITIES The USG has applied an aggressive transition rate , which is reflected in the nomination amount and deta iled in Table 15
. TABLE 15 . N OMINATION 

### A MOUNT 

### .
M ar ylan d Tom at oe s Virg in ia T om at o S outhe as t To mat o Tota l G eo rg ia T om at o F lo rid a Tom at o Tot al S ec to r T ot al / A ve rag e Qu an tity R eq ues te d for 2 012: Amou nt

( kg s) 73 64 6 8,16

4 3, 88

2 41 ,6

57 54

,42 3 Qu an tit y Re co mm en de d by MB TO C/ TEA P for 2 012 : Amou nt

( kg s) 73 64 6 8,16

4 3, 88

2 41 ,6

57 54

,42 2 Amou nt ( kg s) 73 64 6 8,16

4 3, 88

2 41 ,6

57 53

,70 3 Ar ea ( ha ) 2 86 27 2 12

9 1, 46

1 1,95

1 Rat e 30 8 30 30 29 28 Tr an si ti on f ro m 2012 Ba se li ne Ad ju st ed V al ue Pe

rcen tag e (% ) -8 0% -80

% -80

% -8

0% -8

0% -8

0% Amou nt ( kg s) 

## 15 129 1, 63 3 776 8, 331 10, 74 1 Ar ea ( ha ) 

### 0. 1 1 11 5 56 72 Rat e 

### 150 15 0 15

0 150 15

0 15

0 SEC TO R TOM AT OE S

Quant it y Appr oved byPa rt ies f or 2012:


### Qua nt ity R equi re d fo r 2013 No mi nat io n:

CITATIONSUSA CUN13 SOIL TOMATOES Open Field Page 19 of 28



### Baldwin, R.E. & C.M. Waldenmaier. 1991. Trellis Tomato Fum igation Trial 1991. Eastern Shore Agricultural Experiment Station. VA Burelle, N.K, E.M. Rosskopf, M.G. Bausher, G. McCollum. Alternative fumigants and grafting for tomato and double

- cropped muskmelon production in Florida 2008. Annual International Research Conference on Meth yl Bromide Alternatives and Emissions Reduction. ( http://www.mbao.org/ ) Burnette, G. 2003. Personal communication, November 25, 2003. Chellemi, D. O. 2008. Field validation of a fumigant alternative

. Proc. Annual Int. Res. Conf. on Methy l Bromide Alternatives and Emissions Reductions. Available on the web at http://mbao.org/2008/008Chellemi.pdf

. Chellemi, D., Botts, D.A. and Noling, J.W. 2001. Field scale demonstration/validation studies of methy l bromide in plastic mulch culture in Florida, USDA ARS specific co

- operative agreement SCA # 58
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EPA. Chellemi, D.O. & J. Mirusso

. 2006. Optimizing Soil Disinfestation Procedures for Fresh Market Tomato and Pepper. Plant Disease vol. 90 n. 5. p. 668

- 674. Culpepper, Stanley . 2004. Facult y, University of Georgia, Athens, GA. Comments on methyl bromide Critical use nomination for prep lant soil use for tomato grown in open fields. Culpepper, A.S., A.L. Davis, A.W. MacRae, and, T.L . Grey . Meth yl bromide alternatives

– best options for 2007. From the 2007 Proceedings of the Southeast Regional Vegetable Conference, Georgia, USA. Availab le on the web at: http://www.tifton.uga.edu/veg/Publications/GFVGA%202007/Culpepper

- 13.doc Driver , J.G., and F.J. L ouws. 2000. Fumigants and varieties to manage s outhern bacterial wilt of tomato. North Carolina State Universit y. Florida. 2000. Florida soil temperatures. Available on the web at www.imok.ufl/edu/weather/archive/200/clim00 Gilreath , J.P., J.P. Jones, T.N. Motis, B.M. Santos , J.W. Noling, and E.R. Rosskopf . 2003. Evaluation of various chemical treatment for potential as methyl bromide replacemnts for disinfetation of soilborne pests in poly eth yl ene - mulched tomato. Proc. Fla. State Hort. Soc. 116: 151
- 158. Gilreath, J.P., T.N. Motis, and B.M. Santos. 2005. Cyperus spp . Control with reduced meth yl bromide plus chloropicrin doses under virtuall y i mpermeable films in pepper. Crop Prot. 24: 285
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### Gilreath, J.P. & B.M. Santos. 20 05. Efficacy of 1,3

- Dichloropropene Plus Chloropicrin in Combination with Herbicides on Purple Nutsedge ( Cyperus rotundus ) Control in Tomato. Weed Tech. 19: 101

- 104
. Gilreath, J.P. & B.M. Santos. 2005. Purple Nutsedge ( Cyperus rotundus ) Control with Fumig ation and Pebulate Combinations in Tomato. Weed Tech. 19:575

- 579
. Gilreath, J.P. B.M. Santos, J.D. Busacca, J.E. Eger Jr., J.M. Mirusso, P.R. Gilreath. 2006. Validation Broadcast Application of Telone C

- 35 Complemented with Chloropicrin and Herbicides in Commercial Tomato Farms. Crop Prot. 25:79

- 82. Gilreath, J.P. B.M. Santos, C.A. Chase, S.J. L ocascio. 2006. Influence of Soil Fumigation on 2,4

- D and Dicamba Carry over in Fresh Market Tomato. Crop Prot. 25:1095

- 1100. Gilreath, J.P. B.M. Santos, T.M. Motis , J.W. Noling, and J.M. Mirusso. (2005) Methyl bromide alternatives for nematode and Cyperus control in bell pepper ( Capsicum annuum ). Crop Prot. 24: in press. Hausbeck, M. and Cortright, B. 2003. Soil temperature data submitted to BEAD (OPP, US

- EPA) in support of methy l bromide critical use exemption application. Hausbeck, M.K. & B.D. Cortright. 2003. Alternatives for meth yl bromide on cucurbit and Solanaceous crops. Unpublished. Hausbeck, M.K. & B.D. Cortright. 2004. Evaluation of Fumigants for Managing Ph yt ophthora Crown and Fruit Rot of Solanaceous and Cucurbit Crops; 2004. . Unpublished. Hausbeck, M. K. and B. D. Cortright. 2007 . Comparison of low densit y poly eth yl ene and virtually impermeable film and their effect on the efficacy of fumig ants for the control of Fusarium on melon. Unpublished study supplied with Michigan’s CUE package for 2010 (07

- 0005). IR
- 4. 2003. I R
- 4 Project Annual Report 2003. Available online at http ://ir4.rutgers.edu/annreport/report2003.pdf Jacob, W. C. 1977. Range of mean outside temperature and rainfall in South

- Eastern United States. Climatic Atlas of the United States. Published by the US Department of Commerce. Lamour, H.H. and Hausbeck, M. 2003. Effect of crop rotation on the survival of Phytophthora capsici in Michigan. Plant Disease 87: 841

- 845. Locasio, S.J., Gilreath, J.P., Dickson, D.W., Kucharek, T.A., Jones, J.P. and Noling, J.W. 1997. Fumigant alternatives to methyl bromide for p olyethy lene

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### Locasio, S.J. & Dickson, D.W. 2000. Broadcast vs In - Row Application of 1,3

- D Plus Chloropicrin as an Alternative for Tomato Fumigants. Louws, F.J., L .M. Ferguson, K. Ivors, J. Driver, K. Jennings, D. Milks, P.B. Shoemaker & D.W. Monks. 2004. Efficacy

of methy l bromide alternatives for Verticillium and weed management in tomatoes. North Carolina State University

. Louws, F.J., L .M. Ferguson, N.P. Ly nch, & P. B. Shoemaker. 2002. Methy l bromide a lternatives in tomato production sy stems in North Carolina. North Carolina State University

. Morales, J.P., Santos, B.M., Stall, W.M. and Bewick. T.A. 1997. Effects of purple nutsedge ( Cyprus rotundus ) on tomato and bell pepper vegetative growth and fru it yield. Weed Science Technology

11: 672
- 676. Minuto, A., A. Garibaldi, and M.L . L odovica Gullino. 2003. Chemical Alternatives to Methy l Bromide in Ital y: An Update. Proceedings of the MBAO. Minuto, A. M.L . Gullino, F. Lamberti, T.D’Addabbo, E. Tescari, H. Ajwa, A. Garibaldi. 2006. Application of an Emulsifiable Mixture of 1,3

- Dichloropropene and Chloropicrin Against Root Knot Nematodes and Soilborne Fungi for Greenhouse Tomatoes in Italy . 2006. Crop Prot. 25:1244
- 1252 Nelson, M., B. Olsen, B. Vander M ey , G, Lepeze, and L . Rodriguez, B. Johnson, W. Currey , J. Norton. 2001. Proceedings of the MBAO Nelson, K.A. and Renner, K.A. 2002. Yellow nutsedge ( Cyprus esculentus ) control and tuber production with gl yphosate and ALS

- inhibiting herbicides. Weed Technology 16(3): 512
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- plant soil fumigant in California tomatoes. USDA I R
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- EPA during 2003 in support of methy l bromide critical use exemption. Olsen, B. 2008. Midas soil fumigant 2008. Proc. Annual Int. Res. Conf. on Methy l Bromide Alternatives and Emissions Reductions. Available on the web at http://mbao.org/2008/Proceedings/mbrpro08.html

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### Tostovrsnik, N.S., A.L . Shanks, I.J. Porter, S.W. Mattner, and R.W. 2005. Facilitating the Adoption of Alternatives to Methy l Bromide in Australian Horticulture. Proceedings of the MBAO Toth, S. 2008. Personal communication, email to C. August yniak, November 4, 2008. U.S. Environmental Protection Agency . 1998. Re
- registration Eligibility Decision (RED) 1,3 dichloroprppene. Available at http://www.epa.gov/REDs/0328red.pdf U.S. Environmental Protection Agency . 1998. Feasibility of using gas permeable tarps to reduce methy l bromide emissions associated with soil fumigation in the United States. Zhou, X.G. & K .L . Everts. 2003. Races and Inoculum Density of Fusarium oxysporum f. sp. niveum in Commercial Watermelon Fields in Maryland and Delaware. Amer. Phy topath. Soc. V. 87 n. 6 692
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### APPENDIX A Reproduced from the 2011 Critical Use Exemption Application su bmitted by the Georgia Fruit & Vegetable Association Summarized and Compiled by A. Stanley Culpepper, University of Georgia, Tifton 1. M ethyl Bromide Data Generated in Georgia Continued efforts are underway in Georgia to implement effective and economic al alternatives to methyl bromide. During the spring of 2008, at least 40% of the land fumigated for vegetable crops in the spring was treated with the 3

- WAY which includes a systems approach of 1,3

- dichloropropene, chloropicrin, and metam sodium. It is likely that 30 to 40% of Georgia’s total crop will be treated with this alternative during 2008. Dimethyl disulfide (DMDS) plus chloropicrin also has proven to be effective in managing many pests and has the potential to be adopted once the price structure is known. Although both the 3

- WAY and DMDS appear promising, neither fumigant system wil l stand alone in managing pests . A herbicide program must be developed to compliment these fumigant systems. The 3

- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequately control grasses or Amaranthus species. Until program using fumigants and herbicides can be developed, having methyl bromide available is essential. The two aforementioned fumigant syste ms also pose significant challenges when determining the time interval needed between fumigating and planting. Initial research results suggest the plant back interval for the 3

- WAY will be at least 3 times longer than that noted with methyl bromide ( It em 3 below ). For DMDS, the research is currently in progress with results available by September of 2008. Early indications suggest that the plant back for DMDS plus chloropicrin applied under a high barrier mulch will be similar to that noted with the 3

- W AY system. Future research will focus on developing and implementing a herbicide program to compliment both the 3
- WAY and DMDS fumigant systems as well as determining the amount of time that must pass between fumigating with these alternatives and plantin g .USA CUN13 SOIL TOMATOES Open Field Page 24 of 28

2. A herbicide system must be developed for the UGA 3 - WAY during summer/fall fumigation Introduction Georgia growers are adopting an effective alternative to methyl bromide during the spring fumigation cycle. However, research is needed to det ermine if this alternative is effective during the summer/fall fumigation period. Fumigants may be less effective in the summer/fall when compared to the spring because of warmer soils causing increased gas dissipation. Materials and Methods An experime nt was conducted in TyTy Georgia at the University of Georiga’s Ponder Farm. The trial was conducted on a Tifton sandy loam soil with 92% sand, 2% silt, and 6% clay with a pH of 6.4 and 1% organic matter. Land was prepared by disking the trial area multi ple times and then roto

- tilling a 6 foot wide bed by 60 feet in length for each plot immediately prior to fumigating and installing mulch. The study was fumigated during the fall of 2007 on July 17. Soil temperature was 84 degrees at 8 inches. The experi ment consisted of 4 treatments (Table 1) that were replicated three times. The UGA 3

- WAY consisted of a system of Telone II (12 gal/A) followed by chloropicrin (150 lb/A) followed by Vapam (75 gal/A). The Telone II was placed 12 inches deep using a Yette r system having 3 injection knives on a 32 inch bed top, methyl bromide and chloropicrin were injected 8 inches deep with a super bedder using 3 injection knives on a 32 inch bed top, and Vapam was injected 4 inches deep and 4 inches apart using disc blade s in the final bed just prior to covering with mulch. Methyl bromide was applied at 240 lb/A. All fumigant rates are provided as broadcast rates but were actually only applied in the bed. Mulch used included low density polyethylene or Blockade high bar rier mulch. Visual crop injury, visual weed control, and the number of nutsedge shoots penetrating the mulch were measured throughout the season. No visual injury was noted. Percent control and nutsedge penetrating the crop provided similar results thus only percent control is reported. Jumbo pepper was harvested four times, once a week for four weeks. Table 1. Comparing methyl bromide and the 3

- Way for the control of nutsedge and tomato yield. Fumigant Mulch Late
- season purple nutsdege control Harv ests 1
- 2

(Jumbo pepper) Harvests 1
- 4 (Jumbo pepper) % # fruit/plot lbs/plot # fruit/plot lbs/plot 3
- WAY LDPE 48 d 34 c 16 c 44 c 19 c 3
- WAY Blockade 60 c 50 b 24 b 71b 32 b MB Blockade 85 b 106 a 48 a 136 a 61 a None LDPE 0 f 13 d 6 d 19 d 8 d Results and Discussion Poor nutsedge control was noted with the UGA 3

- WAY system when applied under LDPE or Blockade mulch. Fumigant gas emissions occurred so rapidly that nutsedge tubers were likely not under a high enough concentration of gases long enough to provide adequate control as is the case in the spring. Methyl bromide was far more effective with nearly twice the level of control noted with the 3

- WAY even under blockade mulch. As expected, yields followed trends in nutsedge contro l since it was the only pest impacting the crop. Yields from plots treated with methyl bromide were more than double that of the UGA 3
- WAY applied under LDPE mulch. Although yield was improved with the 3

- WAY applied underUSA CUN13 SOIL TOMATOES Open Field Page 25 of 28

blockade mulch compared to LDPE mulch, this higher yield was only approximately half of that noted with the methyl bromide system. Conclusions The UGA 3

- WAY is not a stand alone replacement to methyl bromide during a summer/fall fumigation in Georgia. Either an effective and economica l herbicide system must be developed to compliment this alternative program or another more effective fumigant system must be developed.USA CUN13 SOIL TOMATOES Open Field Page 26 of 28 3. Determining plant back intervals when fumigating with the UGA 3 - WAY Introduction The UGA 3

- WAY system is replac ing methyl bromide rapidly in Georgia. Although this system has been effective during the spring, the program has the potential to delay planting after fumigation. Research is needed to determine the time interval needed between fumigation and planting v egetable crops. Materials and Methods An experiment was conducted in Tifton Georgia at the University of Georgia’s Tifton Vegetable Park. The trial was conducted on a Tifton sandy loam soil with 94% sand, 2% silt, and 4% clay with a pH of 6.2 and 1% organic matter. Land was prepared by disking the trial area multiple times and then roto

- tilling a 6 foot wide bed by 20 feet in length for each plot immediately prior to fumigating and installing mulch. The study was fumigated during the spring of 2007 on February 27. Soil temperature was 59 degrees at 8 inches. The experiment consisted of 12 treatments (Table 1) that were replicated three times. The UGA 3
- WAY consisted of a system of Telone II (12 gal/A) followed by chloropicrin (150 lb/A) followed by Vapam (75 gal/A). The Telone II was placed 12 inches deep using a Yetter system having 3 injection knives on a 32 inch bed top, chloropicrin was placed 8 inches deep with a super bedder using 3 injection knives on a 32 inch bed top, and Vapam was injecte d 4 inches deep and 4 inches apart using disc blades in the final bed just prior to covering with mulch. Methyl bromide (MB) was included for comparison and was applied at 350 lb/A. All fumigant rates are provided as broadcast rates but were actually onl y applied in the bed. Mulch used included low density polyethylene or Blockade high barrier. Crops were planted 7 or 14 days after fumigating while poking the plant hole through the mulch. Crops were also planted on days 8 or 15 which was 1 day after po king the hole on days 7 and 14 in an attempt to air the bed. Crops planted included tomato, pepper and cucumber. Visual crop injury and crop heights (7 tomato, 20 pepper, 7 cucumber plants per plot) were measured throughout the season. Tomato, pepper an d cucumber were harvested five, four, and nine times, respectively. Table 1. Plant heights in response to time of planting after fumigating. Fumigant Mulch Planting days

after fumigation Gas in bed

at planting Heights (cm)

(3 wk after planting) ppm Tomato Pepper Cucumber MB LDPE 7 29 38 a 21 ab 30 ab 3
- WAY LDPE 7 77 32 cd 17 d 24 d 3
- WAY Blockade 7 368 14 f 4 f 12 f MB LDPE 7 + 1 2 37 ab 20 abc 32 a 3
- WAY LDPE 7 + 1 13 33 cd 18 cd 26 cd 3
- WAY Blockade 7 + 1 31 27 e 11 e 20 e MB LDPE 14 2 37 ab 22 a 32 a 3
- WAY LDPE 14 4 34 bc 20 abc 31 ab 3
- WAY Blockade 14 38 30 de 18 cd 28 bcUSA CUN13 SOIL TOMATOES Open Field Page 27 of 28

MB LDPE 14 + 1 0 35 abc 22 a 31 ab 3
- WAY LDPE 14 + 1 3 33 cd 21 ab 31 ab 3
- WAY Blockade 14 + 1 27 30 de 19 bcd 28 bcUSA CUN13 SOIL TOMATOES Open Field Page 28 of 28

Table 2 . Plant yields in response to time of planting after fumigating. Fumigant Mulch Planting days

after fumigation Gas in

bed at planting Yield

(#/plot, highest value fruit only; no difference noted with total

fruit) ppm Tomato Pepper Cucumber MB LDP E 7 29 127 a 227 a 45 de 3
- WAY LDPE 7 77 127 a 195 ab 60 a 3
- WAY Blockade 7 368 55 c 114 c 40 e MB LDPE 7 + 1 2 117 a 212 a 47 cde 3
- WAY LDPE 7 + 1 13 132 a 193 ab 57 ab 3
- WAY Blockade 7 + 1 31 99 b 159 bc 47 cde MB LDPE 14 2 142 a 220 a 49 bcde 3
- WAY LDPE 14 4 132 a 190 ab 55 abc 3
- WAY Blockade 14 38 114 a 188 ab 49 bcde MB LDPE 14 + 1 0 133 a 204 ab 49 bcde 3
- WAY LDPE 14 + 1 3 127 a 202 ab 50 bcd 3
- WAY Blockade 14 + 1 27 119 a 190 ab 42 de Results and D iscussion No visual stunting from methyl bromide was noted with any treatment at 3 wk after transplanting (data not shown). When planting 7 days after fumigating with the 3

- WAY under LDPE mulch, crop heights were reduced at least 20% when compared to the methyl bromide control (Table 1). Growth reduction from the 3

- WAY under Blockade mulch was far greater and ranged from 60 to 80%. Airing the bed for one day did not alleviate stunting. Waiting 14 days after fumigating before planting did alleviate fumi gant stunting when crops were planted on the LDPE mulch. However, significant reduction in plant growth was still noted when planting into the blockade mulch. Airing the bed for 1 d did not eliminate crop stunting when planting on the blockade mulch. Tomato and cucumber were resilient in overcoming early season reduction in plant growth with only minor trends for reduced yields when planted on LDPE mulch, when compared to the methyl bromide control. Yield reductions were noted with tomato when planted on Blockade mulch at 7 or 8 d after fumigating. Pepper tended to be more sensitive than other crops with lower yields or a trend for lower yields when planting on both mulches at each planting date except for the 15 day plant date on LDPE mulch. Result s and Discussion This research is the first step in determining the time interval needed between fumigating and planting. The most effective tactic will likely not be days after fumigating but ppm of fumigant in the bed at planting as the environment plays such a role in the dissipation of gas from the soil. This research suggests that for the UGA 3

- WAY, less than 5 ppm should be in the bed at time of planting.