USA CUN13 SOIL Cucurbits Open Field Page 1 of 23



### NOMINATING PARTY : T HE 

### U NITED 

### S TATES OF 

### A MERICA 

### FILE NAME: USA CUN1 3 SOIL CUCURBITS Open Field BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Critical Use Nomination for Preplant Soil Use for Cucurbits Grown in Open Fields (Submitted in 20 1 1 for 2 01 3 Use Season) CROP NAME: Cucurbits Open Field QUANTITY OF METHYL B ROMIDE 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 ) 201 3 11,899 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) 6 47

- 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 critical because the lack of availability of methyl bromide for this use would result in a significant market disruption. 

### ■ Yes  No

Signature Nam e 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.USA CUN13 SOIL Cucurbits Open Field Page 2 of 23



### CONTACT OR EXPERT(S) FOR FURTHER TEC HNICAL DETAILS: Contact/Expert Person: Jack E. Housenger Title: Director Address: Biological and Economic Analy sis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsy lvania 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 p ages Date sent to Ozone Secretariat USA CUN1 3 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

Secretari at USA CUN1 3 SOIL CUCURBITS Open Field

* Identical to paper documentsUSA CUN13 SOIL Cucurbits Open Field Page 3 of 23



### 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 U SE: This renomination covers cucurbits of several t ypes (squash, melons, and/or cucumber) grown in the southeastern US (except Florida), Mary land, and Delaware. These crops generall y are grown in open fields on plastic tarps, often followed b y various oth er crops. Harvest is destined for the fresh market

. Only areas that cannot use alternative fumigants or non

- fumigant options, and that face moderate to severe infestations of key pests, have been included in the calculation of nominated amounts and area to be treated. The applicants’ requests have also been adjusted downward to account for the lower meth yl bromide dose rates (see BUNNIE in Appendix A) for the southern regions of US cucurbit production, since increased use of high barrier films in conjunct ion with lower rates has been reported there. For the mid

- Atlantic region, the low dose rates requested by the applicants were incorporated into calculations. The USG has reviewed all factors affecting transition rates in this sector. Based on this asses sment 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 document is technicall y valid. The USG has nominated amounts of methy l bromide based onl y on those sub

- sectors that cannot transition away from methy l bromide at the accelerated rate. In developing this renomination the USG examined several recent studies to determine whether yi eld losses and market window losses ass ociated with the best available fumigant alternative could be altered from previous nominations. Unfortunately none of the studies located by the USG met the criteria that earlier cited studies did. These criteria include: the use of fumigant alternatives registered for the crop nominated, the presence of both a methyl bromide standard and an untreated control as treatments as well as the monitoring of yi elds under each treatment. Several recent studies included a methy l bromide treatment or an untreated co ntrol but not both, or included both but did not monitor yield, or included unregistered alternatives. However, research conducted at the University of Georgia that examined use of a three way combination of alternative fumigants (1,3 D followed b y chlorop icrin followed by metam
- sodium) did meet these criteria, Therefore, southern US areas were adjusted to reflect the technical feasibility of this three way

combination of alternative fumigants under VIF or metallized films, as a replacement for spring

- tim e applications of meth yl bromide+chloropicrin, after accounting for areas in the south that face prohibition of 1,3 D due to karst topographical features.USA CUN13 SOIL Cucurbits Open Field Page 4 of 23



### The U.S. nomination is only for those areas where the alternatives are not suitable. For example, c ontinuing research indicates that the three way combination mentioned above (the “UGA 3 way ”) does not adequately control key

pests when used in place of methy l bromide in “fall” (i.e. August or September) fumigations. In U.S. cucurbit production there are several factors that make the potential alternatives to methy l bromide unsuitable. These include:

 The efficacy

of alternatives may

be significantl y less effective than meth yl bromide in some areas, making these alternatives technicall y and/or economical ly infeasible for use in cucurbit production.
 Some alternatives may be comparable to methy l 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 moderat e to high 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. U.S. reliance on met hy l 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 a nd 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 r egional 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 ye ars. However, as the amount of methy l bromide available for use decre ases 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 disulfide (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 all 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 whe n 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 st ill 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 all 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.USA CUN13 SOIL Cucurbits Open Field Page 5 of 23



### These concerns about the alternatives have onl y recently been brought to the USG attention and insufficient supporting infor mation was provided. Because of the uncertainties and challenges associated with the use of the available alternatives, the USG believes it most prudent and the best public policy

to collect additional information so that the technical and economic impact s 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 not it supports a compelling case and confirms problems with the feasibility of alternatives. Then, on that basis, the USG w ill either support or withdraw this nominated sector at that meeting. The nomination attached specifies the correct year (2013) and amount of methyl 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 t he USG learned of the issues facing the growers within this sector, after speaking directl y with researchers familiar with the specif ic problems only

very recentl y , this information was not available at the time the USG recommendation was developed.

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE : Our review of available research on other meth yl bromide alternatives discussed by MBTOC for cucurbits suggests that, of registered (i.e., legally available) chemistries only metam sodium and 1,3 D + chloropicrin have shown potential as commerciall y viable replacement to methy l bromide. Non

- chemical alternatives are either unviable f or US cucurbits or require more research and commercial development before they can be technicall y and economically feasible. For some areas in the southeastern US, a 3 way combination of 1,3 D followed by chloropicrin alone, followed b y metam
- sodium, has shown promise 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 Southeastern U.S. includes the following states: Alabama, A rkansas, Kentucky , Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, and Virginia. The recent Federal registration of iodomethane has not been used to adjust the amount of methy l bromide requested in this CUE, because this material has no t been registered on cucurbits. Other reasons for considering an alternative technicall y i nfeasible for cucurbits include:

- There are significant restrictions on which crops can be rotated through after use of a given alternative (e.g., halosulfuron has ro tational restrictions that prevent its use in southeastern US tomatoes)

.

- 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).USA CUN13 SOIL Cucurbits Open Field Page 6 of 23



### The following is th e procedure followed for the 2009 allocation y ear : For Southeastern U.S. and Georgia, metam

- sodium and 1, 3 D + chloropicrin are the most promising alternatives for nutsedges and nematodes, respectively , w hich are the key target pests in these regions. However, where nutsedges are severe, metam

- sodium, used alone, is technicall y and economically

infeasible due to planting delays, y ield losses and inconsistent efficacy , while 1,3 D + chloropicrin is infeasib le in some areas due to (1) its use being prohibited on Karst topographic features, which are widespread in these regions, (2) a 21 day planting delay , and (3) yi eld losses. There is also evidence that the pesticidal efficacy of both 1,3 D and metam

- sod ium declines in areas where it is repeatedly applied, due to enhanced degradation of methy l isothiocy anate 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 effica cy of a combination of 1,3 D + chloropicrin and the herbicides napropamide + halosulfuron or metolachlor + triflox ys ulfuron in small plots of Florida tomatoes (Santos et al. 2006), these results are not applicable to cucurbits because neither metolachlor o r triflox ys ulfuron are registered in the US for cucurbits, and halosulfuron can have phy totoxic effects on cucurbits. All other potential or available methy l bromide alternatives are also technically infeasible for U.S. cucurbits.

3. IS THE USE COVERED BY A CERTIFIC ATION STANDARD ? Methy l bromide is n ot used to meet a certification standard for cucurbit vegetable production

.
4 . IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE I S NOT USED IN THE OT HER AREA , AND IDENTIFY WHAT ALTERNATIVE STRATEGI ES ARE USED TO CONTROL THE TARGET P ATHOGENS AND WEEDS W ITHOUT METHYL BROMIDE THERE.

 In Southeastern U.S. Georgia, and Mary land, areas not treated do not have nutsedges or pathogens naturall y present in cucurbit fie lds. Simple absence of all pests is the only reason these areas are not presentl y treated with methyl bromide.

 In Delaware and Mary land areas without the existence of several races of Fusarium oxysporum niveum, one of which is highl y aggressive , or witho ut high concentration of the pathogen could use some alternatives such as 1,3

- D.USA CUN13 SOIL Cucurbits Open Field Page 7 of 23



### 5 . WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NEC ESSARY TO E NABLE THIS? The primary

reason that some cucurbits may be grown without methy l bromide in these regions is the absence of both key target pests and constraints to use of alternat ives (e.g., absence of nutsedge, nematodes, and fungal pathogens in the South east, and Georgia, several races of Fusarium and nutsedges in Delaware and Mary land, and karst topographic features in Georgia). The USG has reviewed all factors affecting transition rates in this sector. Based on this assessment the transition rate has b een 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 document is technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on t hose sub

- sectors that cannot transition away from methy l bromide at the accelerated rate. 6 . SUMMARY OF RECENT RESEARCH: Narrative description of studies relevant to key pathogens This section focuses on research relevant to effectiveness of meth yl brom ide alternatives against Fusarium wilt, since that is the main key pest cited by

CUE applicants from the Mary land/Delaware regions. In studies with vegetable crops in the southeastern US, 1, 3 D + chloropicrin has generally shown better control of fungi th an metam
- sodium formulations (though still not as good as control with methy l bromide). For example, in a study using a bell pepper/squash rotation in small plots, Webster et al. (2001) found significantly lower fungal populations with 1,3 D + 35 % chloro picrin (drip applied, 146 kg/ha of 1,3 D), as compared to the untreated control. However, meth yl bromide (440 kg/ha, shank

- injected) reduced fungal populations even more. Iodomethane had no significant suppressive effect, as compared to the untreated con trol. However, neither of these methy l bromide alternatives increased squash fruit weight significantly

over the untreated control. Indeed, as compared to the methy l 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 un marketable squash fruit (defined only as those fruit so bad as to have to be discarded) in the 1,3 D plots was 30 % worse than that in the methy l bromide plots, though in the iodomethane plots it was equivalent to meth yl bromide . In another stud y conducted on tomatoes, Gilreath et al. (1994) found that metam

- sodium treatments did not match methy l bromide in terms of plant vigor at the end of the season; again, Fusarium was one of several pes ts present. In another study , by

Hausbeck and Cortright (2007) , cucurbit plant vigor was measured to determine fumigant/mulch performance under either L PDE or VIF plastic mulch for the control of Fusarium oxysporum . Of the fumigants used in the study , t he meth yl bromide and iodomethane treatments resulted in cantaloupe plants with the highest vigor (Table 7.1) . In general, treatments under L PDE had higher plant vigor when compared with plants grown under VI F. It is noteworthy

that in this study VI F tar ps were prone to wind removal, which reduces their reliability

under some growing conditions.USA CUN13 SOIL Cucurbits Open Field Page 8 of 23

T ABLE 2: E VALUATION OF F UM IGANTS AND P LASTIC M ULCHES FOR M ANAGING F USARIUM IN C UCURBIT C ROPS 2007
T REATMENT ( TIME AFTER TREATMENT TO PLANTING ) R ATE OF FORMULATED PRODUCT V IGOR * Untreated control under LDPE (5 days)

................................ .......... 1.0

- 1.3 a ** Iodomethane+chloropicrin 50:50 under LDPE (10 days)

................ 196 kg/ha 1.0 a Iodomethane+c hloropicrin 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 methy l bromide treatments. This is similar to what was seen in previous y ear s ’ tests (Hausbeck and Cortright 2004; see also discussions in earlier cucurbit nominations ). 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 methy l bromide for controlling F. oxysporum s ubty pes under production conditions relevant to the Mary land/Delaware regions. Research continues to also be conducted to identify Fusarium resistant watermelon stock that can be grafted on a commerciall y feasible basis. While rootstocks protective under conditions of low to moderate pathogen infestation have been identified and tested, this work will require several more ye ars before it produces methy l bromide alternatives that are both technically a nd economicall y feasible, and that functions under seve re infestations. Such work is being planned in the southeastern US (Roberts et al. 2007, Tay lor et al. 2007, Bruton, personal communication). Results of cucurbit rootstock resistant 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 evaluated rootstocks have potential as an option in an integrated multi

- tactic approach to replace methy l bromide. However, this work is i n its initial stages and further evaluation is needed to assess feasibility o f control of other soil pests. Furthermore, these trials did not evaluate resistance or commercial feasibility o f rootstocksUSA CUN13 SOIL Cucurbits Open Field Page 9 of 23



### against the Fusarium pests that are key t argets for th e Mary land/Delaware region

. In general , grafting of resistant rootstocks is still in an earl y stage of evaluation and commercial implementation for US east coast cucurbit production, and so the USG does not consider them viable alternatives to methy l bromi de for the purposes of this nomination. In conclusion, the USG continues to use the best case y ield loss estimates from the previous ye ars ’ nominations f

or the Mary land/Delaware region , since these need methy l bromide mainl y for F. oxysporum control

. To paraphrase these loss estimates: 1,3

- D +chloropicrin is the likely best available alternative for areas in this region that can use (i.e. areas not close to the water table). Even with this alternative, a yi eld loss of about 6 % is likely (based on Hausbec k and Cortright, 2004, and discussions in the 2004

- 2007 cucurbit nominations). The economic impact of this loss is further examined in other sections of this document, below. Narrative description of studies relevant to key weeds and nematodes For nutse dge pests, which are widespread in all requesting regions, cucurbit growers do not currentl y have technically feasible alternatives to methyl bromide use at planting. Metam

sodium and 1,3 D + chloropicrin have shown some efficacy in small

- plot trials in o ther vegetable crops (e.g, tomato). However, at best, metam sodium may allow at least 44 % y ield loss, while 1,3 D may

allow at least 29 % loss. Both often show less control than methy l bromide (in terms of population suppression) of nutsedges. These fa ctors suggest that even this 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 meth yl isothiocy anate levels decline more rapidl y, thus further comprom ising efficacy , in areas where these are repeatedl y applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003). This is probably due to enhanced degradation of these chemicals b y soil microbes (Dungan and Yates, 2003). Other chemical alternativ es to methy l bromide that have shown promise against nutsedges and nematodes (e.g., pebulate and dimethy l disulfide ) are curren tly unregistered for cucurbits, In one recent stud y, Culpepper and Langston (2004) conducted studies at 2 sites in spring 2003 and one site in the f

all season of 2004. Plot sizes were 20 feet X 32 inches (4.94 m 2 

### ). Treatments were: Meth yl bromide standard (67:33 formulation), untreated control, 2 formulations of Telone (1,3 D + chloropicrin) at various doses, followed b y an addit ional application of either chloropicrin or metam

- sodium, a third formulation of 1,3 D + chloropicrin (“Inline”), and iodomethane . An additional set of plots received the same fumigant treatments but also received an herbicide treatment (clomazone + halos ulfuron) later in the season. Watermelon

– the only

cucurbit crop addressed in these experiments

– showed no significant (final) yi eld differences across an y fumigant treatment. The same lack of difference was observed when herbicides were added. In fa ct, there was no difference in y ield even when pesticide treatments were compared to the untreated control. However, nutsedge populations in the study appeared to be relativel y low (e.g., 667 plants per plot or 135/m 2 

### , in the untreated control, at the end of the study ).USA CUN13 SOIL Cucurbits Open Field Page 10 of 23



### 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 particul arly worrisome given the highl y variable results reported by other researchers for the same methy l bromide alternatives. (2) The nutsedge populations in this study were dominated by

y ellow nutsedge (90 % of the total number). It is not clear if populations wh ere purple nutsedge is dominant will be controlled as effectively . A number of other studies have indicated that purple nutsedge is a hardier species, and even in Culpepper and Langston’s study , it appeared more resistant to the methy l bromide alternative s. For example, iodomethane gave “77 % control” of yellow nutsedge, but onl y “37 % control” of purple nutsedge. Control in this case was apparentl y defined as the reduction in nutsedge populations as compared to populations in the untreated control. (3) Thi s study

was done onl y with watermelons, and it is not clear if other cucurbits will respond so favorabl y in terms of yi eld, or lack of phy totoxic response. Also, a custom

built applicator had to be used for the metam

- sodium applications to eliminate worke r exposure risks, according to the authors. I t is not y et clear if such an applicator can be mass - produced and/or used reliabl y in a commercial setting. Another recent stud y of methyl bromide alternatives involving key weed pests was done by Gilreath et al. 2005 (Crop Prot (24): 903

- 908 ) . One of 3 trials in that study showed an average of 30 % lower bell pepper yields with nutsedge and nematodes as the key pests present. In the other 2 trials y ields were not significantly different across different fumig ant treatments, but nutsedge pressure was lower in those trials as compared to the third. Other i mportant caveats to these results are

- this was a small

- plot study and was done in Florida. Thus it is not clear how applicable the results are to the more no rthern regions requesting methy l bromide for vegetable crops (e.g., Delaware, Mary land, and Virginia )

. In addition to the studies described above, several other recent studies conducted in the production circumstances of the southeastern US have examined several fumigant alternatives to methy l bromide, most done in crops other than cucurbits/peppers (e.g., Santos et al. 2006, Candole et al. 2007, Santos and Gilreath 2007, Gilreath and Santos 2005, 2007). These studies either focused solel y on nutsedge wee ds or a combination of nutsedges, diseases, and nematodes. However, USG has examined these papers and concludes that for cucurbits, these studies do not meet all the criteria that allowed the use of earlier studies in estimating y ield and quality losses th at may occur if such methy l bromide alternatives are used as direct replacements for meth yl bromide. These criteria are: the use of fumigant alternatives registered for the crop nominated, the presence of both a meth yl bromide standard and an untreated c ontrol as treatments as well as the monitoring of yi elds under each treatment. Several such studies included a methy l bromide treatment or an untreated control but not both (Santos and Gilreath 2007, Johnson and Mullinix 2007), or included both but did not monitor y ield (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 methy l bromide alternat ives such as 1,3

- D, metam

- sodium, chloropicrin, herbicides, or combinations thereof, they cannot y et be used to alter yi eld estimates .USA CUN13 SOIL Cucurbits Open Field Page 11 of 23



### Therefore, for this nomination, the USG concludes that , for cucurbit growers who can only use either 1,3

- D + chloropic rin or metam

- sodium+chloropicrin in fall

- season fumigations to control nutsedge and nematode pests, the y ield loss estimates used in last y ear’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 LI KELY METHYL BROMIDE ALTERNATIVES AND NUT SEDGE PRESENT AS A CROP PE ST .

C HEMICALS R ATE ( KG / HA ) A VE RAGE

N UTSEDGE D ENSITY (#/ M 2 ) A VE RAGE

M ARKETABL E Y I ELD ( TON / HA ) % Y IELD

L OSS ( COMPARED TO MB) Untreated (control)

- 300 ab 20.1 a 59.1 Methyl B romide + Pic (67
- 33), chisel
injected 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 3 20 a 22.6 a 54.0 Metam Sodium , drip irrigated 300 l 220 b 32.3 c 34.2 Locascio et al. 1997. 

### Recent studies that are useful (within the context of this nomination) in assessing technical feasibility of a combination of methy l bromide alternatives includ e the series of trials being conducted b y Culpepper et al. at the Universit y of Georgia (e.g., Culpepper 2006, Culpepper et al. 2007a,b, Culpepper 200 8 ). These studies indicate that a 3

- way , sequential combination of several fumigant alternatives is techni call y 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 b y metam
- sodium, all under VIF or metallized (high barrier) tarps, and will henceforth be refer red to as the ‘UGA 3 way ’, as Culpepper et al. have. An example of the results obtained in spring fumigation with this combination in peppers is presented in the table below. Results have been similar for cucurbit crops (Culpepper, personal communication; also see several research reports available from the Universit y 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 Jum bo 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 Jum bo + X

- Large + Large 402 b 505 a Footnote: Culpepper 2006. fb means followed by or a sequential treatment. Plots w ere 3 row s by 100 feet long. 

### Since Georgia is similar to other areas of the southeaster n US, except Mary land/Delaware cucurbits which face a different key pest ( F. oxysporum niveum ) , these results should beUSA CUN13 SOIL Cucurbits Open Field Page 12 of 23



### applicable to spring usage of meth yl bromide in these regions. However, other results thus far indicate that summer / fall fumigation is n ot similarly effective with this combination of alternatives (Culpepper, personal communication, Culpepper 2006 , 2008 ). R esults 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 methy l bromide for fall

- season fumigations in vegetable production. In this ex periment, fields were fumigated during for fall

- season crop production on July 17 2007 . Soil temperature was 84 degrees at 8 inches. Th e experiment consisted of 4 fumigant treatments (Table 7.4) that were replicated three times. Even under high

- barrier film (“Blockade”), the ‘UGA 3 way ’ gave less control of purple nutsedge as compared to the methy l bromide standard under the same t ype 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 implications of thi s level o f y ield loss for Georgia cucurbit growers are further d escribed in Part E, below. T ABLE 5: C OM PARING METHYL BROM IDE AND THE 3
- W AY FOR THE CONTROL O F NUTSEDGE AND PEPPER YIELD . F UM IGANT M ULCH L ATE - SEASON PURPLE NUTSEDGE CONTROL H ARVESTS 1
- 2

(J UMBO PEPPER) H ARVESTS 1
- 4 (J UMBO PEPPER) % # 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 w as applied in a 50:50 mix at approximately 160 kg/ha of each. R ates as shown are not planting bed

- strip adju sted. (2) “Mulch” refers to the tarp type. LDPE = traditional high permeability tarp; Blockade = low perm eability tarp manufactured by Pliant Corp. 

### It is important to note that caveats accompan y even the technical feasibility of the ‘UGA 3 way ’ use in sp ring fumigations . Growers must make several application modifications to properly use the approach, and this may incur significant capital expenditure. Culpepper et al. estimate their costs to do this for their research trials at about $ 15,000 (Culpepper et al. 2 007 ). Application costs will also increase as more chemicals and runs of tractor equipment are required to conduct the ‘UGA 3 way ’, and the cost of VIF or metallized film is between 1.75 and two times greater than standard LBPF (Culpepper , personal 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 example of this issue is illustrated in recent work by Chellemi et al. (2008). These researchers evaluated the ‘UGA 3 way ’ in on

- farm tests in Florida peppers. Results of four trails were highl y variable, with two showing better y ields than the methy l bromide stan dard, and two showing worse results . All four trials showed a reduction in larger (more profitable) peppers in the ‘UGA 3 way ’ as compared to the methy l bromide standard. The cause appeared to be an overload of potassium in the soil, created b y the combine dUSA CUN13 SOIL Cucurbits Open Field Page 13 of 23



### use of the metam

- potassium in the ‘UGA 3 way ’ and the growers’ standard practice of appl yi ng a high

- potassium fertilizer.

7 . ECONOMIC FEASIBILITY OF ALTERNATIVES The following economic anal ys is is organized by methy l bromide critical use applicatio n 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 losses of income that may be suffered by

the users. It should be noted that net revenue does no t 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 anal ys is of cucurbit application s compared data on the yi elds, crop prices, revenues and costs of using methy l bromide or alternati ve pest control regimens . This was done in order to estimate impacts on cucurbit growers with the decreasing availability of meth yl bromide

. The Georgia 3

- Way (1,3

- Dichloropicrin with Chloropicrin followed by metam sodium ) was identified as being a techn ically feasible alternative ( in cases of low pest infestation 1 

### ) to methy l bromide in Georgia and the Southeastern United States. Due to differences in climate and pests, it is uncertain whether or not the same assumption holds for Mary land and Delaware cuc urbit production. 1,3

- D + chloropicrin and metam sodium are also presented in this analy sis as recognized alternatives to methy l bromide; however, neither are considered technicall y feasible as yi eld losses are expected. The economic reviewers anal yz ed crop budgets for pre

- plant sectors to determine the likely 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. It is 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. (3) Loss as a Percentage 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 also

1 

### Itshould be noted that the USG does not request methy l bromide for use in areas of low to moderate pest pressure. Only cases where key pests are present at moderate to high levels require meth yl bromide for pest pressure.USA CUN13 SOIL Cucurbits Open Field Page 14 of 23



### 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 operating costs. This is a very good i ndicator as to the direct losses of income that may be suffered by

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

. (5) Operating Profit Margin . We define operating profit margin to be net 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 diffic ult, 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 cucurbit producers in this case. Because producers ( suppliers) represent an integral part of any 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 economic measures provide the basi s for making that determination. Maryland and Delaware The U

. S

. concludes that, at present, no economically feasible alternatives to methy l bromide exist for use in Mary land and Delaware melon production. Y ield loss and missed market windows, which are discussed individually below, have proven most important in reaching this conclusion. 1. Yield L oss Expected y ield losses of 6% are anticipated throughout Mary land and Delaware melon production. 2. Missed Market Windows USG agrees with Mary land and D elaware’s assertion that growers will likely receive significantl y lower prices for their produce if they switch to 1,3

- D + chloropicrin. This is due to changes in the harvest schedule caused b y the above described soil temperature complications and exten ded plant back intervals when using 1,3

- D + chloropicrin. The anal ys is of this effect is based on the fact that prices farmers receive for their cucurbits vary widely over the course of the growing season. Driving these fluctuations are the forces of s uppl y and demand. Earl y in the growing season, when relatively few cucurbits are harvested, the supply is at its lowest and the market price is at its highest. As harvested quantities increase, the price declines. In order to maximize their revenues, cu curbit growers manage their production sy stems with the goal of harvesting the largest possible quantity of cucurbits when the prices areUSA CUN13 SOIL Cucurbits Open Field Page 15 of 23



### at their highs. The ability to sell produce at these higher prices makes a significant contribution toward the profit ability

of cucurbit operations. To describe economic conditions in Mary land and Delaware melon production , EPA used weekl y and monthl y cucurbit sales and production data from the U.S. Department of Agriculture for the previous three ye ars to gauge the imp act of earl y season price fluctuations on gross revenues. Though data availability was limiting, analy sts assumed that if cucurbit growers adjust the timing of their production sy stem, as required when using 1,3

- D + Chloropicrin, gross revenues will decli ne b y approximately 5% over the course of the growing season, due solel y to price effects. The season average price was reduced by 5% in the anal ys is of the alternatives to reflect this effect. Based on currentl y 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 methy l bromide alternatives are used in Mary land and Delaware melon production

. Other Considerations: In Mary land and Delaware cucurbits, Fu sarium oxypsorum niveum exists in three separate races, and no one crop cultivar has resistance to all races. Crop experts in Mary land report that methy l bromide alternatives provided lower protection against the pathogen while also creating obstacles to m eeting premium market windows. USG believes that the best alternatives (1,3 D + chloropicrin) may

offer some defense against the pathogen (with a yi eld loss similar to that likely in Michigan). However, since the crop acreage involved is in low

- ly ing coast al plain, water

logged soils frequentl y 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 the Georgia 3

- Way on spring plantings is believed to be a technically

(and thus economicall y) feasible alternative to methyl bromide, although some limitations exist. Referring to Table s 6 through 14 , the loss of gross revenue using the Georgia 3

- Way is negligible for Georgia and the Southeastern U.S., while in some cases gains in gross revenue are expected in Georgia. Unlike spring plantings, however, yi eld losses are expected in fall plantings, w ith studies in Georgia’s application show a 50% y ield loss. The Georgia 3

- Way also cannot be used on cucurbits that are grown in karst soils since it contains 1,3

- D. Therefore, for fall plantings and areas with karst soils, the use of meth yl bromide is cri tical to Georgia’s and the Southeastern United States’ cucurbit production. No te that data describing Georgia cucurbit production is based on double cropping production practices. Southeastern U.S. Anal yt ical Notes The applicant provided no data on th e operating costs of alternatives. Analy sts assumed, however, that these costs were similar to those of methy l bromide with slight upward adjustments for the costs of apply ing the alternatives and a slight downward adjustment for the cost of the alternati ve product. I n addition, the applicant did not provide data for second crops
2 

### Except GeorgiaUSA CUN13 SOIL Cucurbits Open Field Page 16 of 23



### (including revenues and operating costs). Analy sts assumed that Southeastern cucurbits are grown in a single crop production sy stem. However, if double cropping is practiced in the actual production sy stem, this assumption could make the critical need for methy l bromide appear smaller than it actuall y is, because the value the second crop derives from methyl bromide is not included in the anal ys is Georgia Anal yt ical Notes Oth er potentially

significant economic factors, such as price reductions due to missed market windows, were not anal yzed for this region as the case for critical use of methy l bromide is sufficiently

strong based solely on Georgia 3

- Way fall yi eld loss es . Ec onomic anal ys is of Georgia growing conditions 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 ME LON ME THYL BRO MIDE 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 PROFI T MARGIN (%) 18% 16% * Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.USA CUN13 SOIL Cucurbits Open Field Page 17 of 23

T ABLE 7 . S OUTHEASTERN USA ( EXCEPT G EORGIA ) C UCUM BER - : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES SOUTHEAST USA (EXCEPT GEORGIA) CUCUMBER ME THYL BROMIDE GEORGIA

3
- WAY 1,3
- D +

CHLOROPICRIN ME TAM

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 numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.

T ABLE 8 . S OUTHEASTERN USA ( EXCEPT G EORGIA ) M ELONS - E CO NOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES SOUTHEAST USA (EXCEPT GEORGIA) ME LON ME THYL BROMIDE GEORGIA

3
- WAY 1,3
- D +

CHLOROPICRIN ME TAM

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 numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.USA CUN13 SOIL Cucurbits Open Field Page 18 of 23

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

3
- WAY 1,3
- D +

CHLOROPICRIN ME TAM

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 numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses. T ABLE 10 . A LL S OUTHEASTERN US ( EXCEPT G EORGIA ) C UCURBITS - E CONOMIC I M PACTS OF M ETHYL B ROMIDE A LTERNATIVES ALL SOUTHEAST US (EXCEPT GEORGIA) CUCURBITS ME THYL BROMIDE GEORGIA 3
-

WAY 1,3
- D +

CHLOROPICRIN ME TAM

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 $2,47 2 $5,449 2. LOSS PER KILOGRAM OF ME THYL BROMIDE (US$) $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% * Inte rpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.USA CUN13 SOIL Cucurbits Open Field Page 19 of 23

T ABLE 11 . G EORGIA C UCUMBER - E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA CUCUMBERS ME THYL 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 $12 = GROSS REVENUE PER HECTARE (US$) $67,2 23 $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 numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.

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

GEORGIA MELONS ME THYL BROMIDE GEORGIA 3
-

WAY: SPRING APPLICATION GEORGI A 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 COS T 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 RE VENUE (%) 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 numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.USA CUN13 SOIL Cucurbits Open Field Page 20 of 23

T ABLE 13 . G EORGIA S QUASH - E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES GEORGIA SQUASH ME THYL 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 $3 1 , 348 $3 1 , 348 = N ET REVENUE PER HECTARE (US$)

- $ 3.183 $ 9,188

- $11, 079 LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0

- $1 2 , 3 72 $ 7,896 2. LOSS PER KILOGRAM OF ME THYL BROMIDE (US$) $0

- $1 32 $ 85 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0%

- 31 % 19 % 4. LOSS AS A PERCENTAG E OF NET OPERATING REVENUE (%) 0%

- 389 % 248 % 5. OPERATING PROFIT MARGIN (%)

- 6% 21%

- 58% * Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interp reted as losses.USA CUN13 SOIL Cucurbits Open Field Page 21 of 23

T ABLE 14 . A LL G EORGIA C UCURBITS - E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES GEORGIA CUCURBITS ME THYL 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 $43,999 = NET REVENUE PER HECTAR E (US$) $2,161 $6,222

- $16,995

- $10,675 LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0

- $4,062 $19,156 $12,835 2. LOSS PER KILOGRAM OF ME THYL BROMIDE (US$) $0

- $44 $206 $138 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0%

- 9% 41% 28% 4. LOSS AS A PERCEN TAGE OF NET OPERATING REVENUE (%) 0%

- 188% 887% 594% 5. OPERATING PROFIT MARGIN (%) 5% 13%

- 73%

- 32% * Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses.
8. RESULTANT CHANGES TO REQUESTED 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 

### .

Ma rde l Cucurbit S

out he as t Cu cu rbit G eo rgia - S

qua sh G eo rgia -

Cuc um be r Geo rgi a -

M el on S

ec tor Tot al / A ve ra ge Qu an tity Re que ste d for 2012: Am

ount ( kgs) 1,7

39 38 ,32 1 4, 07 6 3, 28 5 12 ,07 3 59 ,4 96 Quant it y Re comm en de d by MBTO C/ TEAP for 2012 : Am ount ( kgs) 1,7

39 38 ,32 1 4, 07 6 3, 28 5 12 ,07 3 59 ,4 94 Am ount ( kgs) 1,7

39 38 ,32 1 4, 07 6 3, 28 5 12 ,07 3 59 ,4 94 Ar ea(h a) 33 85 3 88 68 26 4 1, 30

6 Ra te 52 45 46 48 46 46 Tr an sit io n fr om 2012 Basel in e Ad ju st ed Va lue Pe

rc en ta ge (%) -8

0% -8 0% -8 0% -8 0% -8

0% -8

0%
Am ount ( kgs) 348 7, 664 81 5 657 2, 415 11, 89 9 Ar ea(h a) 2 51 5 4 16 79 Ra te 150 15 0 15 0 150 15 0 15 0 SE CTOR

Qu an ti ty A pprove d by P ar ti es

f or 2012:

Qu antity Re quir ed for 2013 Nomination: CU CU RB IT S



### CITATIONSUSA CUN13 SOIL Cucurbits Open Field Page 22 of 23



### Candole, B.L., A.S. Csinos, and D. Wang. 2007. Concentrations in soil and efficacy of drip

- applied 1,3

- D+chloropicrin and metam sodium in plastic

- mulched sand y s oil beds. In press at: Crop Prot. (2007), doi:10.1016/j.cropro.2007.03.021. Chellemi, D. O. 2008. Field validation of a fumigant alternative

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

. Cul pepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfield, T. Webster, and W. Upchurch. 2007 . Can Georgia growers replace methy l bromide? Proc. Annual I nt. Res. Conf. on Methy l Bromide Alternatives and Emissions Reductions. Available on the we b at http://mbao.org/2007/Proceedings/mbrpro07.html Dungan, R.S. and S.R. Yates. 2003. Degradation of fumigant Pesticides. 1,3

- Dichloropropene, methy l isothiocy anate, and methy l bromide. Va do se Zone Jour. 2: 279

- 286. Gamliel, A., S. Triki, M. Austerweil, P. DiPrimo, I. Peretz

- Alon, O. Heiman, M. Beniches, B. Steiner, and J. Katan. 2003. Aceelerated degradation of metam sodium in the field and its management. Proc. Annual I nt. Res. Conf. on Me thy l Bromide Alternatives and Emissions Reductions. Available on the web at http://www.mbao.org/mbrpro03.html. Gilreath, J., J. P. Jones, and A. J. Overman. 1994. Soil

- borne pest control in mulched tomato with alternatives to methyl bromide. Proc. Annual In t. Res. Conf. on Methyl Bromide Alternatives and Emissions Reductions. Available on the web at http://www.mbao.org/mbrpro94.html

. Gilreath, J.P. B.M. Santos, T.M. Motis, J.W. Noling, and J.M. Mirusso. (2005) Methy l bromide alternatives for nematode and Cyperus control in bell pepper ( Capsicum annuum ). Crop Prot. 24: 903

- 908. Hausbeck, M. K. and B. D. Cortwright. 200 4 . Evaluation of fumigants for managing Phytophthora crown and fruit rot of solanaceous and cucurbit crops, plot two, 200 4

. Unpublished study

supplied with CUE package 0 4

- 0005. Hausbeck, M. K. and B. D. Cortright. 2007a. Comparison of low density poly eth yl ene and virtually impermeable film and their effect on the efficacy of fumigants for the control of Fusarium on melon. Unpublished study supplied with Michigan’s CUE package for 2010 (07

- 0005). Hausbeck, M. K. and B. D. Cortright. 2007b. Managing melon soil

- borne pathogens in Michigan. Proc. Annual Int. Res. Conf. on Methy l Bromide Alter natives and Emissions Reductions. Available on the web at http://mbao.org/2007/Proceedings/mbrpro07.html

. Johnson, W.C. and B.G. Mullinix. 2007. Yellow nutsedge ( Cyperus esculentus ) control w ith metham

- sodium in transplanted cantaloupe ( Cucumis melo ). Crop Prot. 26: 867

- 871.USA CUN13 SOIL Cucurbits Open Field Page 23 of 23



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