### NOMINATING PARTY: T HE 

### U NITED 

### S TATES OF 

### A MERICA



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

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

CROP NAME: Cucurbits Open Field

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION Year N OMINATION A MOUNT (K ILOGRAMS )

2012 59,500 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-mail: thompsonje2@state.gov

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

## ■ Yes  No

Signature Name Date

Title:

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

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

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on which the Party’s first-year exemption was approved, as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not re-submit that earlier information.

USA CUN12 SOIL Cucurbits Open Field Page 1 of 22

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

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE: 1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozone Secretariat USA CUN12 SOIL CUCURBITS Open Field 23

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming convention see notes above) No. of kilobytes Date sent to Ozone Secretariat USA CUN12 SOIL CUCURBITS Open Field

* Identical to paper documents

USA CUN12 SOIL Cucurbits Open Field Page 2 of 22

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

CUCURBITS

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

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

Only areas that cannot use altern ative fumigants or non-fumigant options, and that face moderate to severe infestations of key pests, have b een included in the calcula tion of nominated amounts and area to be treated. The appli cants’ requests have also been adjusted downward to account for the lower methyl bromide dose rates (see BUNNIE in Appendix A) for the southern regions of US cucurbit production, since increased use of high barrier films in conjunction with lower rates has been reported there. For the mid-Atlant ic region, the low dose rates requested by the applicants were incorporat ed into calculations.

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

In developing this renomination the USG examin ed several recent studies to determine whether yield losses and market window losses associated with the best available fumigant alternative could be altered from previous nominations. Un fortunately none of th e studies located by the USG met the criteria that earlier cited studies di d. These criteria include : the use of fumigant alternatives registered for the crop nominated, the presence of both a methyl bromide standard and an untreated control as treatments as well as the monitoring of yields under each treatment. Several recent studies included a methyl bromide treatment or an untreat ed control but not both, or included both but did not m onitor yield, or included unregistered alternatives. However, research conducted at the Universi ty of Georgia that examined use of a three way combination of alternative fumigants (1,3 D followed by chlo ropicrin followed by metam-sodium) did meet these criteria, Therefore, southern US areas were adjusted to reflect the technical feasibility of this three way combination of alternative fu migants under VIF or metallized films, as a replacement for spring-time app lications of methyl bromide+ch loropicrin, after accounting for areas in the south that face prohibition of 1,3 D due to karst topographical features.

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### The U.S. nomination is only for those areas where th e alternatives are not su itable. For example, continuing research indicates that the three way combinati on mentioned above (the “UGA 3 way”) does not adequately control ke y pests when used in place of methyl bromide in “fall” (i.e. August or September) fumigations. In U.S. cucu rbit production there are several factors that make the potential alternatives to met hyl bromide unsuitable. These include:

 The efficacy of alternatives may be significan tly less effective than methyl bromide in some areas, making these alternatives technical ly and/or economically infeasible for use in cucurbit production.

 Some alternatives may be comparable to methyl bromide as long as key pests occur at low pressure. The U.S. is only nominating a critical use exemption (CUE) for cucurbits where the key pest pressure is moderate to hi gh such as nutsedge in the Southeastern U.S.

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

2. SUMMARIZE WHY KEY ALTER NATIVES ARE NOT FEASIBLE:

Our review of available research on other met hyl bromide alternatives discussed by MBTOC for cucurbits suggests that, of regist ered (i.e., legally avai lable) chemistries only metam sodium and 1,3 D + chloropicrin have shown potential as commercially viable replacement to methyl bromide. Non-chemical alternat ives are either unviable for US cucurbits or require more research and commercial development before they can be technically and economically feasible. For some areas in the southeastern US, a 3 wa y combination of 1,3 D followed by chloropicrin alone, followed by metam-sodium, has shown pr omise against key cucurbit pests in spring season fumigation. The transition rate included in the BUNNIE incorporates an estimate of projected use of this strategy. In this nomination, the Southeas tern U.S. includes the following states: Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Caro lina, South Carolina, Tennessee, and Virginia.

The recent Federal registration of iodomethane has not been used to adjust the amount of methyl bromide requested in this CUE, because this mate rial has not been registered on cucurbits. Other reasons for considering an alternative tec hnically infeasible for cucurbits include:

- There are significant restrictions on which cr ops can be rotated th rough after use of a given alternative (e.g., halosulf uron has rotational restrictions that prevent its use in southeastern US tomatoes).

- Resistance management prevents use of the alternative (e.g., glyphosate resistant weeds, such as Amaranth, in the southern US, preven t use of this alternative as a post-emergent weed control in those regions).

The following is the procedure followed for the 2009 allocation year:

For Southeastern U.S. and Georgia, metam-s odium and 1, 3 D + chloropicrin are the most promising alternatives for nutsedges and nematode s, respectively, which are the key target pests

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### in these regions. However, where nutsedges are se vere, metam-sodium, used alone, is technically and economically infeasible due to planting delays, yield losses and inconsistent efficacy, while 1,3 D + chloropicrin is infeasible in some ar eas due to (1) its use being prohibited on Karst topographic features, which are wi despread in these regions, (2 ) a 21 day planting delay, and (3) yield losses.

There is also evidence that the pesticidal effi cacy of both 1,3 D and metam-sodium declines in areas where it is repeatedly appl ied, due to enhanced degradati on of methyl isothiocyanate by soil microbes (Ou et al., 1995; Verhagen et al., 1996; Dungan and Yates, 2003; Gamliel et al., 2003).

While one study in 2006 showed good efficacy of a combination of 1,3 D + chloropicrin and the herbicides napropamide + halosulfuron or meto lachlor + trifloxysulfur on in small plots of Florida tomatoes (Santos et al. 2006 ), these results are no t applicable to cucurbits because neither metolachlor or trifloxysulfuron are registered in the US for cucurbit s, and halosulfuron can have phytotoxic effects on cucurbits.

All other potential or available me thyl bromide alternatives are also technically infeasible for U.S. cucurbits.

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

Methyl bromide is not used to meet a certific ation standard for cucu rbit vegetable production.

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

 In Southeastern U.S. Georgia, and Maryland, areas not treated do not have nutsedges or pathogens naturally present in cucurbit fields. Simple absence of all pests is the only reason these areas are not presently treated with methyl bromide.

 In Delaware and Maryland areas without the existence of several races of Fusarium oxysporum niveum, one of which is highly aggressive

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

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

The primary reason that some cucurbits may be grown without methyl bromide in these regions is the absence of both key target pests and cons traints to use of altern atives (e.g., absence of nutsedge, nematodes, and fungal pathogens in th e Southeast, and Georgia, several races of Fusarium and nutsedges in Delaware and Maryland, a nd karst topographic feat ures in Georgia).

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

6. SUMMARY OF RECENT RESEARCH:

Narrative description of studi es relevant to key pathogens

This section focuses on research relevant to effe ctiveness of methyl brom ide alternatives against Fusarium wilt, since that is the main key pest cited by CUE applicants from the Maryland/Delaware regions. In st udies with vegetable crops in the southeastern US, 1, 3 D + chloropicrin has generally shown better contro l of fungi than metam-sodium formulations (though still not as good as control with methyl bromide). For example, in a study using a bell pepper/squash rotation in small plots, Webste r et al. (2001) found signi ficantly lower fungal populations with 1,3 D + 35 % chloropicrin (drip applied, 146 kg/ha of 1,3 D), as compared to the untreated control. However, methyl br omide (440 kg/ha, shank-in jected) reduced fungal populations even more. Iodomethane had no signif icant suppressive effect, as compared to the untreated control. However, neither of these me thyl bromide alternatives increased squash fruit weight significantly over the untr eated control. Indeed, as co mpared to the methyl bromide standard treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots, and 41 % lower in the iodomethane plots. The proportion of unm arketable squash fruit (defined only as those fruit so bad as to have to be discarded) in th e 1,3 D plots was 30 % worse th an that in the methyl bromide plots, though in the iodomethane plot s it was equivalent to methyl bromide .

In another study conducted on tomatoes, Gilrea th et al. (1994) found that metam-sodium treatments did not match methyl bromide in terms of plant vigor at the en d of the season; again, Fusarium was one of several pests present.

In another study, by Hausbeck and Cortright ( 2007), cucurbit plant vi gor was measured to determine fumigant/mulch performance under either LPDE or VIF plastic mulch for the control of Fusarium oxysporum . Of the fumigants used in the study, the methyl bromide and iodomethane treatments resulted in cantaloupe pl ants with the highest vigor (Table 7.1). In general, treatments under LPDE had higher plant vigor when compared with plants grown under VIF. It is noteworthy that in this study VIF tarps were prone to wind removal, which reduces their reliability under so me growing conditions.

USA CUN12 SOIL Cucurbits Open Field Page 6 of 22T ABLE 2: E VALUATION OF F UMIGANTS AND P LASTIC M ULCHES FOR M ANAGING F USARIUM IN C UCURBIT C ROPS 2007

T REATMENT ( TIME AFTER TREATMENT TO PLANTING ) R ATE OF
FORMULATED
PRODUCT V IGOR *

Untreated control under LDPE (5 days) ......................................... 1.0-1.3 a **

Iodomethane+chloropicrin 50:50 unde r LDPE (10 days)............... 196 kg/ha 1.0 a
Iodomethane+chloropicrin 50:50 unde r 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 unde r 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 ab ove, the USG notes that the plant vigor in 1,3 D treatments in these new trials is lower than th at seen in methyl bromide treatments. This is similar to what was seen in previous years’ tests (Hausbeck and Cortright 2004; see also discussions in earlier cucurbit nominations).

As far as the USG has been able to determin e, no other studies have been conducted since 2007 to evaluate the technical and commercial feasibil ity of fumigant alternatives to methyl bromide for controlling F. oxysporum subtypes under production conditions relevant to the Maryland/Delaware regions.

Research continues to also be conducted to identify Fusarium resistant watermelon stock that can be grafted on a commercially feasible basis. While rootstocks protective under conditions of low to moderate pathogen infestation have been identified and tested, this work will require several more years before it produces methyl brom ide alternatives that are both technically and economically feasible, and that functions under seve re infestations. Such work is being planned in the southeastern US (Roberts et al. 2007, Ta ylor et al. 2007, Bruton, pe rsonal communication). Results of cucurbit rootstock re sistant to root knot nematode ( Meloidogyne incognita ) were presented at the MBAO conference in November 2008 (Kokalis Burrell et al. 2008, Kubota et al. 2008). Results with muskmelon showed that the eval uated rootstocks have potential as an option in an integrated multi-tactic approach to replace methyl bromide. However, this work is in its initial stages and further evaluation is needed to assess feasibility of control of other soil pests. Furthermore, these trials did not evaluate resist ance or commercial feas ibility of rootstocks

USA CUN12 SOIL Cucurbits Open Field Page 7 of 22

### against the Fusarium pests that are key targets for the Ma ryland/Delaware regi on. In general, grafting of resistant rootstocks is still in an early stage of evaluation and commercial implementation for US east coast cucurbit prod uction, and so the USG does not consider them viable alternatives to methyl bromid e for the purposes of this nomination.

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

Narrative description of studies rel evant to key weeds and nematodes

For nutsedge pests, which are widespread in all requesting regions, cucurbit growers do not currently have technically feasible alternativ es to methyl bromide use at planting. Metamsodium and 1,3 D + chloropicrin have shown some e fficacy in small-plot trials in other vegetable crops (e.g, tomato). However, at best, metam s odium may allow at least 44 % yield loss, while 1,3 D may allow at least 29 % loss. Both often show less control than methyl bromide (in terms of population suppression) of nutsedges. These fact ors suggest that even th is alternative will not be economically feasible even in the best-case technical scenario. It should be noted also that there is evidence that both 1,3 D and methyl isot hiocyanate levels decline more rapidly, thus further compromising efficacy, in areas where th ese are repeatedly applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003). This is probably due to enhanced degradation of these chemicals by soil microbes (Dungan and Yates, 2003).

Other chemical alternatives to methyl bromide that have shown promise against nutsedges and nematodes (e.g., pebulate and dimethyl disulfid e) are currently unregistered for cucurbits,

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

### ). Treatments were: Methyl bromide standard (6 7:33 formulation), untreated control, 2 formulations of Telone (1,3 D + chloropicrin ) at various doses, followed by an additional application of either chloropicr in or metam-sodium, a third formulation of 1,3 D + chloropicrin (“Inline”), and iodomethane. An additional set of plots received the same fumigant treatments but also received an herbicid e treatment (clomazone + halosu lfuron) later in the season.

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

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

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### Furthermore, a number of important caveats must be mentioned when considering these results: (1) Plots used were quite small, and it is not at all clear if the promising results will hold reliably in larger commercial fields. This is particularly worrisome given the highly variable results reported by other researchers for the same methyl bromide alternatives. (2) The nutsedge populations in this study were dominated by yellow nutsedge (90 % of the total number). It is not clear if populations where purple nu tsedge is dominant will be controlled as effectively. A number of other studies have indicated that purple nutsedge is a hardier species, and ev en in Culpepper and Langston’s study, it appeared more resistant to the methyl bromide alternativ es. For example, iodomethane gave “77 % control” of yellow nutsedge, but only “37 % c ontrol” of purple nutsedge . Control in this case was apparently defined as the reduction in nutsedge pop ulations as compared to populations in the un treated control. (3) This study was done only with watermelons, a nd it is not clear if other cucurbits will respond so favorably in terms of yield, or l ack of phytotoxic response. Also, a custombuilt applicator had to be used for the meta m-sodium applications to eliminate worker exposure risks, according to the authors. It is not yet clear if such an applicator can be mass-produced and/or used reliab ly in a commercial setting.

Another recent study of methyl bromide altern atives involving key weed pests was done by Gilreath et al. 2005 (Crop Prot ( 24): 903-908). One of 3 tria ls in that study showed an average of 30 % lower bell pepper yields with nutsedge and nematodes as the ke y pests present. In the other 2 trials yields were not significantly different across different fu migant treatments, but nutsedge pressure was lower in those trials as compared to the third. Other impor tant caveats to these results are - this was a small-plot study and wa s done in Florida. Thus it is not clear how applicable the results are to the more northern regions requesting methyl bromide for vegetable crops (e.g., Delaware, Maryland, and Virginia).

In addition to the studies described above, se veral other recent studi es conducted in the production circumstances of the southeastern US ha ve examined several fumigant alternatives to methyl bromide, most done in crops other th an cucurbits/peppers (e.g., Santos et al. 2006, Candole et al. 2007, Santos and Gilreath 2007, Gi lreath and Santos 2005, 2007). These studies either focused solely on nutsedge weeds or a comb ination of nutsedges, diseases, and nematodes. However, USG has examined these papers and conc ludes that for cucurbits, these studies do not meet all the criteria that allowed the use of earli er studies in estimating yield and quality losses that may occur if such methyl bromide alternatives are used as direct replacements for methyl bromide.

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

.

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### Therefore, for this nomination, the USG concl udes that, for cucurbit growers who can only use either 1,3-D + chloropicrin or metam-sodium+chl oropicrin in fall-season fumigations to control nutsedge and nematode pests, the yield loss estimates used in last year’s nomination continue to be applicable. These loss estimates are illustrated in Table 7.2 below, and are used as the basis of part of the economic assessment in the following section.

T ABLE 3: DATA ON YIELD LOSSES WITH LIKELY ME THYL BROMIDE ALTERNATIVES AND NUTSEDGE
PRESENT AS A CROP PEST

.

C HEMICALS R ATE ( KG / HA ) A VERAGE N UTSEDGE

D ENSITY

(#/ M 2 ) A VERAGE M ARKETABL

E Y IELD ( TON / HA ) % Y IELD L OSS ( COMPARED

TO MB) Untreated (control) - 300 ab 20.1 a 59.1Methyl Bromide + Pic (67-33), chiselinjected 390 kg 90 c 49.1 b

--- 1,3 D + Pic (83-17), chisel-injected 327 l 340 a 34.6 c 29.5 Metam Sodium, Flat Fumigation 300 l 320 a 22.6 a 54.0 Metam Sodium, drip irrigated 300 l 220 b 32.3 c 34.2
Locascio et al. 1997.



### Recent studies that are useful (within the cont ext of this nomination) in assessing technical feasibility of a combination of methyl bromide al ternatives include the series of trials being conducted by Culpepper et al. at the University of Georgia (e.g., Culpepper 2006, Culpepper et al. 2007a,b, Culpepper 2008). These studies indicate that a 3-wa y, sequential combination of several fumigant alternatives is technically feasible for spring- time fumigation of most vegetable crops. The 3-way combination consists of 1,3 D followed by chloropicrin at about 168 kg/ha, followed by metam-sodium, all under VIF or metallized (high barrier) tarps, and will henceforth be referred to as the ‘UGA 3 way’, as Culpeppe r et al. have. An example of the results obtained in spring fumigation with this combination in pe ppers is presented in the table below. Results have been similar for cucurbit crops (Culpe pper, personal communicatio n; also see several research reports available from the University of Georgia at www.gaweed.com ).

T ABLE 4: N UMBER OF P EPPER F RUIT

- M ETHYL B ROMIDE : C HLOROPICRIN V ERSUS T HREE W AY C OMBINATION

. S PRING 2006

F RUIT S IZE M ETHYL B ROMIDE : C HLOROPICRIN

(# OF F RUIT ) UGA 3 WAY 1,3-D FB CHLOROPICRIN FB
METAM N A Jumbo 30 b 125 a X-Large 219 a 237 a

Large 153 a 143 a Chopper 217 a 252 a

Cull 11 a 9 a Jumbo + X-Large + Large 402 b 505 a Footnote: Culpepper 2006. fb means followed by or a sequential treatment. Plots were 3 rows by 100 feet long.



### Since Georgia is similar to other areas of the southeastern US, except Maryland/Delaware cucurbits which face a different key pest ( F. oxysporum niveum ), these results should be

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### applicable to spring usage of methyl bromide in these regi ons. However, other results thus far indicate that summer / fall fumigation is not similarly eff ective with this combination of alternatives (Culpepper, personal communication, Culpepper 2006, 2008).

Results of one of several experiments conducted by Culpepper et al. at the University of Georgia illustrate the infeasibility of the use of the ‘ UGA 3 way’ method in place of methyl bromide for fall-season fumigations in vegeta ble production. In this experiment , fields were fumigated during for fall-season crop production on July 17 2007. So il temperature was 84 degrees at 8 inches. The experiment consisted of 4 fumigant treatment s (Table 7.4) that were replicated three times. Even under high-barrier film (“Blockade”), th e ‘UGA 3 way’ gave less control of purple nutsedge as compared to the methyl bromide sta ndard under the same type of film. Yields were consistently lower with the ‘ UGA 3 way’ as well, with a roughly 50 % reduction in both number and weight of harvested vegetables (Table 7.4). The economic im plications of this level of yield loss for Georgia cucurbit growers are fu rther described in Part E, below.

T ABLE 5: C OMPARING METHYL BROMIDE AND THE 3-W AY FOR THE CONTROL OF NUTSEDGE AND

PEPPER YIELD

. L ATE

- SEASON
PURPLE NUTSEDGE
CONTROL H ARVESTS 1-2 (J UMBO PEPPER ) H ARVESTS 1-4 (J UMBO PEPPER ) F UMIGANT M ULCH

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

None LDPE 0 f 13 d 6 d 19 d 8 d
Notes : (1) The UGA 3 Way consisted of 1,3 D at approximately 192 kg/ha, followed by chloropicrin at 168 kg/ha, followed by metam-sodium at approximately 358 kg/ha. Methyl bromide + chloropicrin was applied in a 50:50 mix at approximately 160 kg/ha of each. Rate s as shown are not planting bed-strip ad justed. (2) “Mulch” refers to the tarp type. LDPE = traditional high permeability tarp; Blockade = low permeability tarp manufactured by Pliant Corp.



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

Time and further research and extension education will also be needed to implement the ‘UGA 3-way’ method in areas outside Georgia where the method has been less-studied, and where different problems may need to be resolved. An ex ample of this issue is i llustrated in recent work by Chellemi et al. (2008). These researchers ev aluated the ‘UGA 3 way’ in on-farm tests in Florida peppers. Results of four trails were highly variable, with two showing better yields than the methyl bromide standard, and two showing wors e results. All four tr ials showed a reduction in larger (more profitable) pe ppers in the ‘UGA 3 way’ as compared to the methyl bromide standard. The cause appeared to be an overload of potassium in the soil, created by the combined

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### use of the metam-potassium in the ‘UGA 3 way’ and the growers’ standa rd practice of applying a high-potassium fertilizer.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

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

Readers please note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct loss es 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 this study. We did not include fixed costs because it is often difficult to measure and verify.

Summary of Economic Feasibility

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

### ) to methyl bromide in Georgia and the Southeastern United States. Due to differences in climate and pests, it is uncertain whether or not the sa me assumption holds for Maryland and Delaware cucurbit production. 1,3-D + chloropicrin and metam sodium are al so presented in this analysis as recognized alternatives to methyl bromid e; however, neither are considered technically feasible as yield lo sses are expected.

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

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

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

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually easy to meas ure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high value commodities or cr ops may provide high revenues but may also

1 

### It should be noted that the USG does not request methyl bromide for use in areas of low to moderate pest pressure. Only cases where key pests are present at moderate to high levels require methyl bromide for pest pressure.

### entail high costs. Losses of even a small per centage 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 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 operating profit ma rgin 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 methyl bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more di fficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to a ssess the economic feasibili ty of methyl bromide alternatives for methyl bromide users, who ar e cucurbit producers in this case. Because producers (suppliers) represent an in tegral part of any definition of a market, we interpret the threshold of significant market di sruption to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

Maryland and Delaware

The U.S. concludes that, at present, no economi cally feasible a lternatives to methyl bromide exist for use in Maryland and Delaware me lon production. Yield loss and missed market windows, which are discussed indi vidually below, have proven most important in reaching this conclusion.

1. Yield Loss

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

2. Missed Market Windows

USG agrees with Maryland and Delaware’s assertion that growers will likely receive significantly lower prices for their produce if they switch to 1,3-D + chloropicr in. This is due to changes in the harvest schedule caused by the above described soil temperature complications and extended plant back intervals wh en using 1,3-D + chloropicrin.

The analysis of this effect is ba sed on the fact that prices farmers receive for their cucurbits vary widely over the course of the growing season. Driv ing these fluctuations ar e the forces of supply and demand. Early in the growing season, when relatively few cucurbits are harvested, the supply is at its lowest and the ma rket price is at its highest. As harvested quanti ties increase, the price declines. In or der to maximize their revenues, cucu rbit growers manage their production systems with the goal of harvesting the largest po ssible quantity of cucurbits when the prices are

USA CUN12 SOIL Cucurbits Open Field Page 13 of 22USA CUN12 SOIL Cucurbits Open Field Page 14 of 22 

### at their highs. The ability to sell produce at these higher prices make s a significant contribution toward the profitability of cucurbit operations.

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

Other Considerations:

In Maryland and De laware cucurbits, Fusarium oxypsorum niveum exists in three separate races, and no one crop cultivar has resistance to all ra ces. Crop experts in Maryland report that methyl bromide alternatives provided lower protec tion against the pathogen while also creating obstacles to meeting premium ma rket windows. USG believes that the best alternatives (1,3 D + chloropicrin) may offer some defense against the pathogen (with a yield loss similar to that likely in Michigan). However, since the crop acreage involved is in low-lying coastal plain, waterlogged soils frequently occur in rainy periods and this could delay fumigation with this and other alternatives (such as metam-sodium) and cause additional losses by forcing growers to miss key mid-July market windows.

The Southeastern USA 2 

### and Georgia

In the Southeastern U.S. and Georgia, using th e Georgia 3-Way on spring pl antings is believed to be a technically (and thus economically) feasible alternative to methyl bromide, although some limitations exist. Referring to Tables 6 through 1 4, the loss of gross revenue using the Georgia 3- Way is negligible for Georgia a nd the Southeastern U.S., while in some cases gains in gross revenue are expected in Georgia. Unlike spring plantings, however, yield losses are expected in fall plantings, with studies in Georgia’s application show a 50% yield loss. The Georgia 3-Way also cannot be used on cucurbits that are grown in karst soils since it cont ains 1,3-D. Therefore, for fall plantings and areas with karst soils, the use of methyl bromide is critical to Georgia’s and the Southeastern United States’ cucurbit producti on. Note that data describing Georgia cucurbit production is based on double cropp ing production practices.

Southeastern U.S. Analytical Notes

The applicant provided no data on the operating costs of alternatives. Analysts assumed, however, that these costs were similar to t hose of methyl bromide with slight upward adjustments for the costs of applying the alternatives and a sli ght downward adjustment for the cost of the alternative product. In addition, the applicant did not provide data for second crops

2 

### Except Georgia

### (including revenues and operating co sts). Analysts assumed that Southeastern cucurbits are grown in a single crop production system. However, if double cropping is pract iced in the actual production system, this assumption could make th e critical need for methyl bromide appear smaller than it actually is, becau se the value the second crop derive s from methyl bromide is not included in the analysis

Georgia Analytical Notes

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

Economic analysis of Georgia growing condi tions included cost and production data representing a second cucurbits or peppers crop.

T ABLE 6. M ARYLAND AND D ELAWARE M ELON

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

MARYLAND AND DELAWARE MELON METHYL BROMIDE 1,3-D + CHLOROPICRIN PRODUCTION LOSS (%) 0% 6% PRODUCTION PER HECTARE 2,347 2,207 * PRICE PER UNIT (US$) $11 $11 = GROSS REVENUE PER HECTARE (US$) $25,822 $24,273 - OPERATING COST PER HECTARE (US$) $21,073 $20,366 = NET REVENUE PER HECTARE (US$) $4,749 $3,907
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $843

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

3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 3% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 18% 5. OPERATING PROFIT MARGIN (%) 18% 16% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

USA CUN12 SOIL Cucurbits Open Field Page 15 of 22T ABLE 7. S OUTHEASTERN USA ( EXCEPT G EORGIA ) C UCUMBER -: E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) CUCUMBER METHYL BROMIDE GEORGIA 3-WAY 1,3-D + CHLOROPICRIN METAM SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44%
PRODUCTION PER HECTARE 828 828 588 464 * PRICE PER UNIT (US$) $16 $16 $16 $16 = GROSS REVENUE PER HECTARE (US$) $13,245 $13,245 $9,404 $7,417 - OPERATING COST PER HECTARE (US$) $10,556 $10,652 $9,691 $9,736 = NET REVENUE PER HECTARE (US$) $2,689 $2,593 -$288 -$2,319
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $96 $2,976 $5,007
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $32 $54
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 22% 38%
4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 4% 111% 186% 5. OPERATING PROFIT MARGIN (%) 20% 20% -3% -31% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

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

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

SOUTHEAST USA (EXCEPT GEORGIA) MELON METHYL BROMIDE GEORGIA 3-WAY 1,3-D + CHLOROPICRIN METAM SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44%
PRODUCTION PER HECTARE 815 815 579 457 * PRICE PER UNIT (US$) $15 $15 $15 $15 = GROSS REVENUE PER HECTARE (US$) $12,232 $12,232 $8,685 $6,850
- OPERATING COST PER HECTARE (US$) $11,202 $11,297 $10,337 $10,381 = NET REVENUE PER HECTARE (US$) $1,030 $934 ($1,652) -$3,531
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $96 $2,682 $4,562
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $29 $49
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 22% 37%
4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 9% 260% 443% 5. OPERATING PROFIT MARGIN (%) 8% 8% -19% -52% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

USA CUN12 SOIL Cucurbits Open Field Page 16 of 22T ABLE 9. S OUTHEASTERN USA ( EXCEPT G EORGIA ) S QUASH -: E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

SOUTHEAST USA (EXCEPT GEORGIA) SQUASH METHYL BROMIDE GEORGIA 3-WAY 1,3-D + CHLOROPICRIN METAM SODIUM

PRODUCTION LOSS (%) 0% 0% 29% 44% PRODUCTION PER HECTARE 311 311 221 174 * PRICE PER UNIT (US$) $29 $29 $29 $29
= GROSS REVENUE PER HECTARE (US$) $9,029 $9,029 $6,411 $5,056
- OPERATING COST PER HECTARE (US$) $7,338 $7,433 $6,473 $6,517 = NET REVENUE PER HECTARE (US$) $1,692 $1,596 -$62 -$1,461
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $96 $1,754 $3,152
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $19 $34
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 19% 35% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 6% 104% 186% 5. OPERATING PROFIT MARGIN (%) 19% 18% -1% -29% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

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

- E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES ALL SOUTHEAST US (EXCEPT GEORGIA) CUCURBITS METHYL BROMIDE GEORGIA 3- WAY 1,3-D + CHLOROPICRIN METAM SODIUM PRODUCTION LOSS (%) 0% 0% 29% 44% PRODUCTION PER HECTARE 652 652 463 303 * PRICE PER UNIT (US$) $18 $18 $18 $17
= GROSS REVENUE PER HECTARE (US$) $11,502 $11,502 $8,166 $5,235
- OPERATING COST PER HECTARE (US$) $9,802 $9,899 $8,939 $8,984
= NET REVENUE PER HECTARE (US$) $1,700 $1,603 -$773 -$3,749
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $97 $2,472 $5,449
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $27 $59
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 1% 21% 47% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 6% 145% 321% 5. OPERATING PROFIT MARGIN (%) 15% 14% -9% -72% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

USA CUN12 SOIL Cucurbits Open Field Page 17 of 22T ABLE 11. G EORGIA C UCUMBER

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

GEORGIA CUCUMBERS METHYL BROMIDE GEORGIA 3-WAY: SPRING APPLICATION GEORGIA 3-WAY: FALL APPLICATION PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 5,740 5,740 2,870 * PRICE PER UNIT (US$) $12 $12 $12
= GROSS REVENUE PER HECTARE (US$) $67,223 $67,223 $33,611
- OPERATING COST PER HECTARE (US$) $54,251 $40,226 $40,226
= NET REVENUE PER HECTARE (US$) $12,972 $26,997 -$6,615
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 -$14,024 $19,587
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$151 $211
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -21% 29% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -108% 151%
5. OPERATING PROFIT MARGIN (%) 19% 40% -20% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

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

GEORGIA MELONS METHYL BROMIDE GEORGIA 3- WAY: SPRING APPLICATION GEORGIA 3- WAY: FALL APPLICATION PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 4,275 4,275 2,137 * PRICE PER UNIT (US$) $12 $12 $12 = GROSS REVENUE PER HECTARE (US$) $49,696 $49,696 $24,848
- OPERATING COST PER HECTARE (US$) $42,085 $43,288 $43,288 = NET REVENUE PER HECTARE (US$) $7,610 $6,408 -$18,440
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $1,202 $26,050
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $13 $280
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% 2% 52% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 16% 342% 5. OPERATING PROFIT MARGIN (%) 15% 13% -74% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

USA CUN12 SOIL Cucurbits Open Field Page 18 of 22T ABLE 13. G EORGIA S QUASH

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

GEORGIA SQUASH METHYL BROMIDE GEORGIA 3- WAY: SPRING APPLICATION GEORGIA 3- WAY: FALL APPLICATION PRODUCTION LOSS (%) 0% 0% 50%

PRODUCTION PER HECTARE 5,251 5,251 2,625 * PRICE PER UNIT (US$) $8 $8 $8
= GROSS REVENUE PER HECTARE (US$) $40,556 $40,538 $20,269
- OPERATING COST PER HECTARE (US$) $43,739 $31,348 $31,348
= NET REVENUE PER HECTARE (US$) -$3.183 $9,188 -$11,079
LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 -$12,372 $7,896
2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 -$132 $85
3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0% -31% 19% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -389% 248% 5. OPERATING PROFIT MARGIN (%) -6% 21% -58% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

USA CUN12 SOIL Cucurbits Open Field Page 19 of 22T ABLE 14. A LL G EORGIA C UCURBITS

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

GEORGIA CUCURBITS METHYL BROMIDE GEORGIA 3- WAY: SPRING APPLICATION GEORGIA 3- WAY: FALL APPLICATION 1,3-D + CHLOROPICRIN

PRODUCTION LOSS (%) 0% 0% 50% 29%
PRODUCTION PER HECTARE 4,741 4,741 2,370 3,404 * PRICE PER UNIT (US$) $10 $10 $10 $10

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

- OPERATING COST PER HECTARE (US$) $44,278 $40,213 $40,213 $43,999
= NET REVENUE PER HECTARE (US$) $2,161 $6,222 -$16,995 -$10,675

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

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

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

4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% -188% 887% 594% 5. OPERATING PROFIT MARGIN (%) 5% 13% -73% -32% * Interpret the loss measures with caution. Negative numb ers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbe rs can be interpre ted as losses.

8. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES



### The USG has applied an aggressi ve transition rate, which is re flected in the nomination amount and detailed in Table 15.

TABLE 15. N OMINATION 

### A MOUNT



### .

USA CUN12 SOIL Cucurbits Open Field Page 20 of 22

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