NOMINATING PARTY: The United States of America

FILE NAME: USA CUN12 SOIL FOREST SEEDLING NURSERIES Open Field

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

CROP NAME (OPEN FIELD OR PROTECTED): Forest Seedling Nurseries Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE NOMINATED
Year N OMINATION A MOUNT

2012 34,230 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).)

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 Forest Seedling Nurseries Open Field Page 1 of 15CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:
Contact/Expert Person: Jack Housenger

Title: Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460

U.S.A. Telephone: (703) 308-8200 Fax: (703) 308-7042
E-mail: Housenger.Jack@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 FOREST SEEDLING NURSERIES Open Field

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 FOREST SEEDLING NURSERIES Open Field

* Identical to paper documents

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 2 of 15

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

FOREST SEEDLING NURSERIES

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

Forests are increasingly important as challenges to the environment have global implications. The first step in forest establishment is the produ ction of tree seedlings by forest tree nurseries. These nurseries provide healthy st arting material for newly planted forests. The U.S. nomination is for a critical use of methyl bromide for thos e nurseries where register ed alternatives are not effective or sufficiently tested to enable comm ercial use. The use of methyl bromide is
considered critical where alternatives are not suitable because of regulatory, economic, or

technical constraints.

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 2009, four consortia submitted applications. Ho wever, only three consortia requested critical use exemptions for methyl bromide—the Southe rn Forest Nursery Management Cooperative (Alabama, Arkansas, Florida, Georgia, Kentuc ky, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, a nd Virginia), the Michigan Seedling Growers (Michigan, one nursery in Indi ana), and the Northeastern Forest and Conservation Nursery Association (Illinois, Indiana, Kentucky, Maryla nd, Missouri, New Jersey , Ohio, Pennsylvania, West Virginia, and Wisconsin). The Northeastern Forest and Conservation Nursery Association has reduced their request for cr itical use of methyl bromide to 3,257 kg for use on 16 ha.

ArborGen submitted an application, but appears to have no additional critical use request (states
with ArborGen nurseries are included in the So uthern Forest Nursery Management Cooperative request). The application states that “all use is QPS for Arbor Gen, LLC.” The purpose of the submission was to provide ”the EPA with an estimate of current and future MBr use and to provide information on the effectiveness of cu rrent and future MBr use reduction measures.”

Of the registered alternatives, iodomethane offers a potential alternative to methyl bromide for forest seedling nurseries. A major hindrance in adop ting this newly registered product is its lack of availability for nurseries even for experiment al trials. The register ed product for iodomethane is controlled by the registrant and forest nursery representative s throughout the U.S. have not been able to contract fumigant applicators to fumigate with iodo methane. Continuing field trials should address uncertainties associated with appropr iate use rates, formul ation type, application techniques, and certifica tion acceptability. Ongoi ng area-wide trials in the southeastern U.S. continue to refine the efficacy of alternatives (Quicke et al., 2009). However, the status of

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 3 of 15effective glue technology for low permeable f ilms remains uncertain for commercial broadcast fumigation. Quicke et al. (2009) found that glui ng virtually impermeable film required five hours to treat 0.5 ha as compared to four hours to treat 1.5 ha with standard film. The U.S. believes a transition period requiring continued critical use of methyl bromide is necessary to
resolve these issues.

For some other alternatives, inconsistency in overall pest management performance (e.g. metamsodium and dazomet) has been the primary concer n for this sector, and the reason that methyl
bromide continues to have some critical use. While direct yield losses, in terms of seedlings/hectare, may not be large on average, in tensive seedling production relies on the ability of nursery managers to meet quality and yield goa ls as well as certification that plants are essentially pest-free.

Effective fumigation can manage fungal pathogens (e.g., Fusarium

, Alternaria

, Phytophthora

, Pythium, Rhizoctonia

, Cylindrocladium spp., Cylindrocarpon , and Macrophomina ), nematodes (e.g., Circonemoides

, Helicotylenchus ), and yellow and purple nutsedges (species of Cyperus ). Nutsedge species are generally considered among the major pests of forest seedling nurseries in the eastern U.S. and the pests most difficult to manage.

2. SUMMARIZE WHY KEY ALTER NATIVES ARE NOT FEASIBLE

For the 2012 use season, methyl bromide remains a cr itical need for forest seedling nurseries to produce plants free of pests in order to meet st ate certification standards, as well as customer expectations. The use protocols for the eff ective alternatives have not been developed sufficiently to provide effective control of the key pests to depths of 1 m. In addition, there are few, if any, markets for plants that do not m eet the certification standards, which mean that losses up to 100% are possible when inadequate pest control occu rs. Failure to adequately manage pests in transplants will jeopardize the viability of the planted forests.

A new registration for iodomethane presents a po tential alternative to methyl bromide (it is currently registered in all states except Calif ornia, New York, and Washington). Iodomethane use rates and formulations (98:2 or 50:50) need to be tested by seedling nurseries to determine
what rates are the most effective and cost-feasib le. However, a lack of availability of the iodomethane product for forest nursery testing ha s been a disappointment to nursery managers and researchers. Chloropicrin appears to be a po ssible alternative, but stri ct regulations make its future uncertain when used at the high rates th at have been shown to be effective (South, 2007; Enebak, 2007).

According to nursery specialists from reque sting consortia (Enebak, 2008; Lowerts, 2008; Talbert, 2008; Overton, 2008), iodomethane holds pr omise as an effective alternative to methyl bromide. However, the following comments highli ght concerns by nursery experts of potential problems with a transition to iodomethane for the forest seedling nursery industry:

 Research has been scant for testing the e fficacy of iodomethane in forest seedling nurseries. One two-year study conducted in the southeast U.S. (Starkey et al., 2007)

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 4 of 15indicated that the size of pine seedlings with iodomethane were similar to that with methyl bromide for both years. Weed populatio ns were significantly greater in one of the two years of the study. There is a need to validate the studies to determine if iodomethane manages weed populations sufficiently for commercial production.

 The limited number of field studies that have been conducted is not sufficient to confirm that iodomethane is a suitable alternative to methyl bromide; the industry cannot afford to risk production until the new product is rigorously tested. One

consortium stated that “most researchers consider 3 years of trials over several locations are needed to develop reliable data for pesticide guidelines.” Trials for this sector have not been comple ted or reported. Trials c onducted in the northeast are limited to a few vegetable crops with cust om applicators from outside the region.

 Research trials with iodomethane conducte d in Washington (where iodomethane is not currently registered for commercial use) have found encouraging results.

 Cost estimates for the south east for application and tarp removal of 350 lb/acre [392 kg/ha] of 98:2 methyl bromide was approxi mately $4,450 per hectare. The cost of 175 lb/acre [196 kg/ha] of 98:2 iodomethane was approximately $6,280 per hectare. Cost in the northeast for iodomethane pr oducts range from $15 per kg (50:50) to $20 per kg (98:2). This compares to $7 per kg for methyl bromide (98:2). Estimated costs of fumigation per hectare for no rtheastern nurseries average $8,300 for iodomethane (98:2), $10,500 for iodome thane (50:50), and $4,820 for methyl bromide (98:2). If these cost differen ces are maintained the industry would find iodomethane to be economically infeasible.

 Regional fumigation contractors do not curr ently have the equipment to broadcast iodomethane. According to the iodomethane label, “The treated ground must be sealed using closing shoes, roller, compacti on roller, cultipacker or other equivalent equipment that will sufficiently cover ch isel marks left after soil injection. The equipment shall cover the chisel marks with soil immediately prior to the placement of the tarpaulin being laid down (with fumigant injection) by tarpaulin-laying equipment mounted on the application tractor.” Demand for the product may change this situation, but th e industry is not able current ly to broadcast iodomethane.

 Use of iodomethane resulted in a reduction of beneficial Trichoderma fungi populations in soil 12 and 18 months following treatment in both years of a two-year study (Starkey et al., 2007). This effect will have to be confirmed by additional studies, but would result in long- term reduced production quality.

 Methyl bromide is accepted by state control boards as meeting phytosanitary requirements for nursery shipments. Iodom ethane will require the same acceptance, but as yet, this certificati on standard has not been addr essed by the registrant of iodomethane or state regulators.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 5 of 15 According to consortia representing northeast and southeast nurseries, Arysta (manufacturer of MIDAS iodomethane) has no representatives or applicators of the iodomethane product for forest nurseries in northeastern or s outheastern states.

 The iodomethane label (MIDAS) does not make clear if use is allowed for production of deciduous tree seedlings (“ strawberries, stone fruits, tree nuts, and conifer trees ”). Deciduous seedlings are generally more valu able than conifer seedlings and have greater pest management requirements.

3. IS THE USE OF METHYL BROMIDE COVERED BY A CERTIFICATION
STANDARD?

This sector is covered by certi fication requirements. All states have certification standards and
all nurseries have addi tional internal quality control standards as well (NPB, 2008 for summaries of nursery plant regulations for all states). USDA-APHIS has guidelines for containment of sudden oak death through movement of nursery material (USDA-APHIS, 2004). An example from Mississippi, “All nursery stock shipped in to Mississippi must carry on each container or bundle a valid nursery inspection tag (inspection certificate) of the State of origin. Containers should also be plainly marked with the names and addresses of shipper and consignee” (MDAC, 2003). Similarly from Alabama, “Nursery stock en tering the State of Alabama must be certified as being apparently free from plant pests. Certificate tags issued by the official certifying agency of the state of origin stating such must be firmly attached to each box, bundle or package of nursery stock moved into the state” (ADAI, 2004). In addition, “No inspec tion certificate shall be issued for the sale, offering for sale, or m ovement of any nursery stock until the stock in question shall have been inspec ted by the Commissioner and found to be apparently free from seriously injurious plant pests” (ADAI, 2004). Other states have simila r regulations (NPB, 2008).

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.

All nurseries currently treat pr oduction beds with methyl br omide due to certification and production requirements. Where weeds are of prim ary pests, methyl bromide has been the most effective treatment and accepted by state inspectors. Methyl bromide allows conifer seedling beds to be fumigated after two or three crops (as opposed to after ever y crop) because of the effectiveness of methyl bromide, which usua lly makes a second-year treatment unnecessary. Iodomethane is a new fumigant and may be an e ffective alternative, but multi-season information

on its use for forest nurseries is lacking and product availability appears to be limited for testing in forest seedling nurseries.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 6 of 155. 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?

Preliminary results of research suggest iodomet hane has value as a replacement for methyl bromide, but it first must be tested to prove efficacy and acceptability for certification. In addition, as with all new products, adjustment of use rates and applica tion experience with iodomethane will require a few seasons where nu rseries can transition from methyl bromide, assuming costs do not limit the use of iodomethane. Nursery managers attest to their inability to find iodomethane to use even for testing purposes . Apparently distribution of the product to professional applicators has been limite d by the registrant for this sector.

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

Research with low permeability films and met hods to glue them for broadcast fumigation appears to be progressing. However, the f easibility for commercial broadcast with low permeable films is still questionable. The standa rd width of film used in the nursery industry (400 cm) is not available for the film that cu rrently can be glued, which may slow adoption, according to a representative of Pliant Corpora tion, a major manufacturer of low permeable films in the U.S. Research trials with VIF have pr imarily been conducted w ith bed, rather than the standard broadcast fumigation due to problems glui ng film. Glues are appa rently proprietary and manufacturing information is difficult to a ttain. Ajwa (2008) repor ted some preliminary successes in strawberry research trials gluing VIF and totally impermeable film (TIF). He cited reports that researchers in Flor ida had had difficulty gluing TIF.

In 2008, iodomethane was registered in all states requesting a critical use of methyl bromide, except Washington, for use in forest seedling nurs eries. Unfortunately, research on iodomethane use for this industry is minimal and rates, formul ation, and application tec hniques will have to be optimized for commercial applications. The regi strant, Arysta, has not yet completed work to support pest-free certification wi th the product and the product is not available to most of the nurseries even for testing purpos es. Fumigant trials have be en conducted with conifers, not hardwoods, which constitute a valuab le portion of many nurseries.

 At two sites in Alabama forest seedli ng nurseries, Quicke et al. (2009) found no significant differences in seedling counts among several fumigant treatments (98:2 methyl bromide at both 450 kg/ha and 264 kg/ha and 392 kg/ha of 67:33; 70:30 methyl bromide [98:2]:solvent A at 450 kg/ha; Pic+ solvent A at 33 6 kg/ha; chloropicrin at 336 kg/ha; Chlor60 [60% chloropicrin, 40% 1,3-D] at 450 kg/ha; DMDS/Pic [79:21] at 480 kg DMDS/ha; iodomethane at 180 kg/ha of 50:50 and 112 kg/ha of 98:2). At one

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 7 of 15location no differences were observed in Trichoderma populations, at one location the DMDS treatment resulted in the highest Trichoderma population. The use of virtually impermeable film with the iodomethane treatme nts were said to be the largest broadcast trials with this product. Results were pos itive, but time of gluing after fumigation was seen as a hindrance for commercial adoption of this product (five hour s to treat 0.5 ha as compared to four hours to treat 1.5 ha with standard film).

 Quicke et al. (2008) studied two nursery si tes in South Carolina. Randomized blocks were treated with one of seven fumigants (98:2 methyl bromide at both 450 kg/ha and 264 kg/ha; 70:30 methyl bromide at 450 kg/ha; Pic+ at 336 kg/ha; chloropicrin at 336 kg/ha; Chlor60 at 450 kg/ha; DMDS/Pic at 480 kg DMDS/ha). At both sites, all treatments provided comparable seedling densit ies. No nematodes were detected in any fumigated soil. Trichoderma populations were greatest in soil that had been treated with a high rate of chloropicrin.

 Results from experiment-sized plots c onducted in Mt. Vernon Research Center, Washington (Talbert, 2008) in 2007 in coope ration with USDA, found that iodomethane treatments generally provided acceptable w eed and pathogen control. Concerns were raised about the effectiveness of spring fumigation with iodomethane and consistency throughout different locations. Additional test ing is planned for western nurseries and
two to three seasons is considered nece ssary to gauge efficacy and feasibility.

 Research (Weiland et al., 2008) to study the efficacy of reduced doses of fumigants (methyl bromide, iodomethane, and DM DS) under VIF and their effects on soil pathogens and weeds is underway in Oregon and Washington. Trials will be analyzed in
the fall of 2009.

 In a two-year study conducted in Geor gia, Starkey et al. (2007) found that iodomethane:chloropicrin (168 kg/ ha of 98:2) produced seed lings with characteristics (density, diameter, height, root and shoot biomass) comparable to methyl bromide-treated beds. Methyl bromide and chloropicrin (168 kg/ha of 98:2) with VIF produced seedlings comparable to methyl bromide:chloropicrin ( 336 kg/ha of 98:2) with standard films.
Weeds in iodomethane-treated beds were co mparable to methyl bromide in a 2006 trial and more than in methyl-bromide-treated beds in a 2005 trial. This was attributed to the
rate of iodomethane that was used. Th e regeneration of the beneficial fungus
Trichoderma was reduced under VIF and with iodo methane treatments compared to methyl bromide.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

This study calculated net revenue as gross re venue minus operating costs. This is a good measure of the direct losses of income that may be suffered by the users. It should be noted that net revenue does not represent net income to the us ers. Net income, which indicates profitability of an operation for an enterprise, is gross reve nue minus the sum of operating and fixed costs.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 8 of 15Net income is smaller than the net revenue measur ed in this study, often s ubstantially so. Fixed costs were not included because they are difficult to measure and verify.

The economic analysis compared data on yields, crop prices, re venues and costs using methyl bromide and using alternative pest control regi mens in order to estimate the loss of methyl bromide availability. The alternative analyzed as technically feasible was iodomethane/chloropicrin.

The economic factors that drive the feasibility analysis for nu rsery stock production uses of methyl bromide are: (1) yield losses, referri ng to reductions in the quantity produced, (2) increased production costs, which may be due to the higher-cost of using an alternative, additional pest control requireme nts, and/or resulting shifts in other production or harvesting practices (3) quality losses, which generally a ffect the quantity and price received for the goods, and (4) missed market windows due to plant back tim e restrictions, which al so affect the quantity and price received for the goods.

The economic reviewers then analyzed crop budget s forest nurseries 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 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 are tomato producers in this case. Because producers (suppliers) represent an integral part of any defi nition of a market, we in terpret the threshold of

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 9 of 15significant market disruption 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.

The results of the analysis of methyl bromide compared to iodo methane are shown in Tables 2 and 3. Iodomethane is assumed to provide the same yields as methyl bromide. Therefore, the only losses shown in the tables below as a resu lt of methyl bromide not being available are increased fumigation and hand weeding costs. Si nce one study (Starkey et al., 2007) indicated increased weed pressure with iodomethane co mpared to methyl bromide, almost $800 per hectare per year was added for hand weedi ng costs with the use of iodomethane.

The yields, revenues, and costs listed in Tables 2 and 3 are averages per year over fumigation cycles of 2 – 4 years. Most of the yields, re venues, and costs occur 1 – 2 years out of 2 – 4 fumigation cycles, while fumiga tions are usually done once du ring the fumigation cycle and sometimes twice for certain specie s. Since the costs are average annual costs, the increased costs
will be less than the full increased cost of a single iodomethane fumigation compared to methyl

bromide.

Also, revenues and costs will vary between region s due to different yields, species, and cultural and fumigation practices.

Furthermore, these tables do not show other possi ble losses discussed earli er in this nomination and summarized below, which include:

 Efficacy . While the analysis of economic feasib ility assumed equal yields, the limited

number of field studies that have been conducted is not sufficient to confirm that iodomethane has equal efficacy as methyl bromid e. If efficacy is not equal there could be impacts on seedling quality and forest health.

 Forest Health. Seedlings free of pathogens and other pests help establish forests with less pest pressure, thus resulting in fast er growth and less use of pesticides.

 Certification . Methyl bromide is accepted by state control boards as meeting phytosanitary requirements for nursery shipme nts. Iodomethane will require the same acceptance, but as yet, with limited efficacy studies, this certification standard has not been established. There are few, if any, markets for plants that do not meet the certification standards, which mean that loss es up to 100% are possible when inadequate pest control occurs.

 Product Availability and Application Equipment

. The lack of availability of

iodomethane to forest nurseries has been not ed. This has affected the scheduling of comparative field trials. In addition, the continued comments about the feasibility of gluing low permeable films for broadcast applications reduces the commercial applicability of iodomethane for forest nurseries. Demand for iodomethane may change this situation, but th e industry is not able current ly to broadcast iodomethane.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 10 of 15 Deciduous trees . The iodomethane label (MIDAS) does not make clear if use is allowed for production of deciduous tree seedlings, wh ich are generally more valuable than conifer seedlings and have greate r pest management requirements.

T ABLE 2 S OUTHERN F OREST N URSERY M ANAGEMENT C OOPERATIVE : E CONOMIC I MPACTS OF M ETHYL
B ROMIDE A LTERNATIVES PER Y EAR

S OUTHERN F OREST N URSERY M ANAGEMENT C OOPERATIVE M ETHYL B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%

Yield (seedling) per Hectare Pine 779,617 779,617 * Price per Unit (U.S. $/seedling) $0.05 $0.05
Gross Revenue per Proportion (88% of seedlings; 72% of acres) $25,234 $25,234

Yield (seedling) per Hectare Longleaf Pine 423,785 423,785 * Price per Unit (U.S. $/seedling) $0.09 $0.09
Gross Revenue per Proportion (3% of seedlings; 5% of acres) $1,759 $1,759

Yield (seedling) per Hectare Hardwood 243,399 243,399 * Price per Unit (U.S. $/seedling) $0.25 $0.25
Gross Revenue per Proportion (9% of seedlings; 24% of acres) $14,337 $14,337

= G ROSS R EVENUE PER H ECTARE ( US $) $41,330 $41,330

− O PERATING C OSTS PER H ECTARE ( US $)** $23,401 $24,648

= N ET R EVENUE PER H ECTARE ( US $) $17,929 $16,682

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,248

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $15

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

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 7%

5. O PERATING P ROFIT M ARGIN (%) 43% 40%
** Note that the measures in this table must be interpre ted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 11 of 15T ABLE 3. N ORTHEASTERN F OREST AND C ONSERVATION : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES PER Y EAR

N ORTHEASTERN F OREST AND C ONSERVATION M ETHYL
B ROMIDE I ODOMETHANE

Y IELD L OSS (%) 0% 0%

Yield (seedling) per Hectare Conifer (1-0) 247,105 247,105 * Price per Unit (U.S. $/seedling) $0.26 $0.26
Gross Revenue per Proportion (8% of acres) $5,140 $5,140

Yield (seedling) per Hectare Conifer (2-0) 185,329 185,329 * Price per Unit (U.S. $/seedling) $0.26 $0.26
Gross Revenue per Proportion (4% of acres) $1,927 $1,927

Yield (seedling) per Hectare Conifer (3-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.35 $0.35
Gross Revenue per Proportion (14% of acres) $6,054 $6,054

Yield (seedling) per Hectare Deciduous Trees (1-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.32 $0.32
Gross Revenue per Proportion (55% of acres) $21,745 $21,745

Yield (seedling) per Hectare Deciduous Trees (2-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.37 $0.37
Gross Revenue per Proportion (9% of acres) $4,114 $4,114

Yield (seedling) per Hectare Deciduous Shrubs (1-0) 123,553 123,553 * Price per Unit (U.S. $/seedling) $0.29 $0.29
Gross Revenue per Proportion (10% of acres) $3,583 $3,583

= G ROSS R EVENUE PER H ECTARE ( US $) $42,564 $42,564

− O PERATING C OSTS PER H ECTARE ( US $)** $31,879 $33,418

= N ET R EVENUE PER H ECTARE ( US $) $10,684 $9,146

L OSS M EASURES **

1. L OSS PER H ECTARE ( US $) $0 $1,538

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $0 $16

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 4%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0% 14%

5. O PERATING P ROFIT M ARGIN (%) 25% 21%
** Note that the measures in this table must be interpre ted carefully. Operating costs do not include fixed costs and net revenue equals gross revenue minus operating costs.

8. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES

Three consortia submitted applications. Two consortia requested critical use exemptions for methyl bromide—the Southern Forest Nursery Management Cooperative and the Northeastern Forest and Conservation Nursery Association.

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 12 of 15ArborGen’s submission appears to ha ve no critical use needs. The a pplication states that “all use is QPS for Arbor Gen, LLC.” The purpose of the submission was to provide ”the EPA with an estimate of current and future MBr use and to pr ovide information on the effectiveness of current

and future MBr use reduction measures.”

The Northeastern Forest and Conservation Nurs ery Association has reduced their request for critical use of methyl bromide to 3,257 kg for use on 16 ha.

The USG has also applied an aggressive transi tion rate, which is reflected in the nomination

amount and detailed in Table 4.

TABLE 4. N OMINATION A MOUNT :

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 13 of 15CITATIONS

ADAI (Alabama Department of Agriculture a nd Industries). 2004. Ch apter 80-10-1, Nursery and Nursery Stock. Plant I ndustry Administrative Code. http://www.msapms.org/new/newsletters/Nur sery%20and%20Nursery%20Stock%20Regula tions_New.pdf

Ajwa, H. 2008. Personal communication, origin al email to S. Weiss, SRRD-OPP, EPA, November 20, 2008.

Enebak, S. 2008. Personal communication, email to L. Yourman, October 28, 2008.

Enebak, S. 2007. Personal communication, email to L. Yourman, Aug. 16, 2007.

Enebak, S., Starkey, T., and McCraw, D. 2006. Tree seedling quality and weed control with Basimid, MBR and methyl iodide. Annual Inte rnational Research Conference on Methyl
Bromide Alternatives. http://www.mbao.org/2006/06Proceedings/ 040StarkeyTMBAOMIMBrBasam idTES.pdf

Lowerts, G. 2008. Personal communication (A rborGen), email to L. Yourman, October 29,

2008.

MDAC (Mississippi Department of Agricu lture and Commerce). 2003. Summary of plant protection regulations.Bureau of Pl ant Industry, Plant Pest Division.

http://nationalplantboard.org/docs/mississippi.doc . Moulton, R. J. and Hernandez, G. 2000. Tree planting in the United States, 1998. Tree Planters Notes V49(2). USDA Forest Service. pp

1-36.

NPB (National Plant Board). 2008. Laws and Regulations. http://www.nationalplant board.org/laws/index.htm l

Overton, R. 2008. Personal communication (P urdue University, NE Area Regeneration Specialist, email to L. Yourman, October 31, 2008.

Quicke, M., Starkey, T., and Enebak, S. 2009. 2009 Methyl bromide alternatives in Alabama forest tree seedling nurseries. Annual Internat ional Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2009). http://www.mbao.org/2009/Pro ceedings/038QuickeM2009%20Areawide%20Nov%20San%20Diego%20MBAO.pdf

Quicke, M., Starkey, T., and Enebak, S. 2008. 2008 Area-wide demonstration of alternatives:

Forest nurseries in the southe rn U.S. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008). http://www.mbao.org/2008/Proceedings/013QuickeM2008Area-wideNovOrlandopaper.pdf

USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 14 of 15USA CUN12 SOIL Forest Seedling Nurseries Open Field Page 15 of 15 South, D. B. 2007. Chloropicrin as a soil fumiga tion treatment in sout hern pine nurseries. Southern Journal of App lied Forestry 31(1):47-51.

Starkey, T., Enebak, S., and McCraw, D. 2007. Seed ling quality and weed control with dazomet, methyl bromide and methyl iodide at the Glennville Regeneration Center 2005-2006. Research Report 06-05, Southern Forest Nu rsery Management Cooperative, Auburn, AL. also, http://www.mbao.org/2006/06Proceedings/040StarkeyTMBAOMIMBrBasamidTES.pdf ; http://mbao.org/2006/06PowerPoints/MBAO%20PDFs/Preplant/7%20- %20Ornamentals,%20Tree%20Crop%20and% 20Forest%20tree%20Nurseries/Starkey.pdf

Talbert, C. B. 2008. Personal communication with Director of Forestry and Regeneration , Weyerhaeuser Corporation, Wester n Timberlands. October 31, 2008.

USDA-APHIS (Animal and Plant Health Inspecti on Service), Plant Protection and Quarantine. 2004. Sudden Oak Death. Amended order restricting movement of nursery stock from
California nurseries. http://www.aphis.usda.gov/ppq/ispm/pramorum/pdf_files/sodorder4-22-04signed.pdf

Weiland, J., Pinkerton, J. N., Littke, W., Browning, J ., Masters, C., Rose, R., Haase, D., Miller, T., Edmonds, B. and Leon A. 2008. Met hyl bromide alternatives in Oregon and Washington forest tree nurserie s. Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2008). http://www.mbao.org/2008/Proceedings/015WeilandJMBASummary01.pdf