**USA CUN10 SOIL TOMATOES Open Field**  **Page 1 of 27**



### NOMINATING PARTY: **The United States of America**

NAME **USA CUN11 SOIL TOMATOES Open Field** 

BRIEF DESCRIPTIVE TITLE OF NOMINATION: **Methyl Bromide Critical Use Nomination for Pre-plan t Soil Use for Tomato**  **Grown in Open Fields (Submitted in 2009 for 2011 Use Season)** 

CROP NAME (OPEN FIELD OR PROTECTED): **Tomatoes Open Field** 

QUANTITY OF METHYL BROMIDE REQUESTED IN EACH YEAR O F

NOMINATION:

T ABLE 

### 1: Q UANTITY OF 

### M ETHYL 

### B ROMIDE 

### R EQUESTED IN 

### E ACH 

### Y EAR OF 

### N OMINATION



### Y EAR 

### N OMINATION 

### A MOUNT


### 2011 336,191 kilograms

NOMINATING PARTY CONTACT DETAILS:
**Contact Person: Hodayah Finman Title: Foreign Affairs Officer**  **Address: Office of Environmental Policy U.S. Department of State**  **2201 C Street, N.W. Room 2658 Washington, D.C. 20520** 

**U.S.A. Telephone: (202) 647-1123**  **Fax: (202) 647-5947 E-mail: Finmanhh@state.gov** 

Following the requirements of Decision IX/6 paragra ph (a)(1) The United States of America has determin ed that the specific use detailed in this Critical Use Nominati on is critical because the lack of availability of methyl bromide for
this use would result in a significant market disru ption

**.** . 

### ■ **Yes**  **No**

**Signature Name Date**

**Title:**

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

This form is to be used by holders of single-year e xemptions to reapply for a subsequent year’s exempt ion (for example, a Party holding a single-year exemption fo r 2005 and/or 2006 seeking further exemptions for 2 007). It does not replace the format for requesting a critic al-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomi nation on which the Party’s first-year exemption was approved , as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Pa rty need not re-submit that earlier information.**USA CUN10 SOIL TOMATOES Open Field**  **Page 2 of 27**



### CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

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

**U.S.A. Telephone: (703) 308-8200**  **Fax: (703) 308-7042**

**E-mail: 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 CUN11 SOIL TOMATOES Open Field** 

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: *Title of each electronic file (for naming conventi on see notes above) No. of kilobytes Date sent to Ozone

Secretariat

**USA CUN11 SOIL TOMATOES Open Field** 

*** Identical to paper documents USA CUN10 SOIL TOMATOES**  **Open Field Page 3 of 27** 



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

TOMATOES

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

**This nomination is for methyl bromide use in the pr oduction of tomatoes in Florida, Georgia,**  **The Mid-Atlantic (Maryland, and Virginia), and the Southeast. U.S. tomato growers have been**  **reducing methyl bromide use rates in all production areas.** 

**The primary fumigant alternatives for methyl bromid e that have shown promise against key**  **tomato pests the spring application of the fumigant combination of 1,3 D + chloropicrin,**  **followed by chloropicrin alone, followed by metam-s odium and the newly registered fumigant** 

**iodomethane.**

**Current research has demonstrated that in many case s iodomethane (MIDAS®) formulated with**  **chloropicrin can be an efficacious methyl bromide a lternative, however, transition time will be**  **needed for many tomato producers to adapt productio n to using this material. Growers will need**  **this time to adapt to the use of new application eq uipment appropriate to the lower flow rates**  **typical with iodomethane, to retro-fit equipment in order to avoid corrosion by iodomethane, etc.**  **Increased costs due to using iodomethane are descri bed in the "economic assessment" section**  **below. Given that 2009 will be the first cropping season under the new label for the use of this**  **fumigant, farmer adoption will be slow. Applicatio n protocols have not been sufficiently**  **established due to limited results of long term on- farm research. A major concern with the use of**  **iodomethane is the potential increase of plant-back timing to avoid potential crop injury and loss.** 

**In other recent work, some research results with di methyl disulfide (DMDS) indicate that this**  **fumigant is promising. However, preliminary researc h results from a single year of fumigation in**  **pepper production demonstrate that, as a stand-alon e product, the efficacy of DMDS is not**  **comparable to methyl bromide and will require chlor opicrin (MacRae and Culpepper, 2008).**  **Treatments with DMDS plus chloropicrin and/or metam -sodium are not significantly different**  **from methyl bromide + chloropicrin. In any case, t his fumigant is not registered in the US and**  **therefore cannot at this time be considered a pract ical methyl bromide alternative.** 

**The application of a sequential 3 way fumigant comb ination, the “Georgia 3 Way” (consisting of**  **1,3-D + chloropicrin, followed by chloropicrin, fol lowed by metam-sodium or metam**  **potassium), continues to be evaluated. It is consid ered to be useful as a spring applied fumigant**  **mix in the state of Georgia. It should be noted th at a major part of developing a commercially**  **feasible protocol to use this system in all regions will require adjustment of rates and application**  **timing for field and strip applications. Trials ev aluating the “Georgia 3 Way” show that it can be**  **as efficacious against key southern US tomato pests as methyl bromide and/or iodomethane +**  **chloropicrin. An exception to this is a study by Ch ellemi (2008) where, in some trials, pepper**  **plant height and yield was reduced due to crop inju ry. However, the injury was later correlated**  **with high levels of soil potassium and probably not a direct result of the fumigation. Weed and**  **nematode control for the “Georgia 3 Way” as compare d to methyl bromide were not different.** **USA CUN10 SOIL TOMATOES Open Field**  **Page 4 of 27**



### Adding to the slow adoption of this system is the l **ack of established protocol that will be based on mitigating potential problems such as plant-back**  **timing, soil moisture, and location/edaphic variability. The increased production costs, and c**  **ost of new or altered equipment needed for application will also be an impediment to adoption**  **of the three fumigant mix.**

Florida

**Some production areas in Florida are located above karst topographic formations which places**  **restrictions on the use of 1,3-D. Stinging nematod e problems require either methyl bromide or**  **1,3-D. Some fields with key disease problems have achieved good control with chloropicrin,**  **although there may be regulatory restrictions on it s use at high rates. Where 1,3-D is allowed,**  **the application of the three fumigant mix continues to be evaluated but is not considered a viable** 

**alternative.**

**Preliminary research has demonstrated that iodometh ane can be an efficacious methyl bromide**  **alternative, but protocols have not been sufficient ly established. Given sufficient time to**  **transition this fumigant can be worked into the pro duction system.** 

Georgia

**The three way fumigant combination continues to be evaluated, and has proven to be efficacious**  **for spring application in Georgia. However, the la ck of established protocol and the cost of new**  **or altered equipment have been a limiting factor in the adoption of this fumigant combination.** 

**Preliminary research has demonstrated that iodometh ane can be an efficacious methyl bromide**  **alternative, but protocols have not been sufficient ly established. Given sufficient time to**  **transition these fumigants can be worked into the p roduction system.** 

Mid-Atlantic

**Current research in this region has not been submit ted and it is thus assumed that the use of**  **iodomethane as a methyl bromide replacement, given time to transition, will be sufficient.**  **However, just as in many areas of the country, the establishment of protocols will slow farmer**  **adoption. Until results from on-farm research proj ects have established a protocol a period of** 

**transition will be needed.**

Southeast

**The “Georgia 3 Way” fumigant combination continues to be evaluated in the southeast. In a**  **comment by Craig Anderson of the University of Arka nsas, the cool temperatures and wet soils**  **in early spring will extend the plant back timing d ue to the additional time needed for soil**  **fumigant levels to dissipate to avoid crop injury a nd subsequent yield loss (Toth, 2008)** 

**Preliminary research conducted in states other than those in the southeast have demonstrated that**  **iodomethane can be an efficacious methyl bromide al ternative, but protocols have not been**  **sufficiently established. Concerns in the southeas t about injury and delayed planting have lead** **USA CUN10 SOIL TOMATOES Open Field**  **Page 5 of 27**



### some to question their usefulness in this region. **Currently, there are several economic drawbacks that include the cost of iodomethane, the**  **cost of using VIF or metalized mulches, and an initial cost of some minor equipment alteration.** 

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

**Our review of available research on other methyl br omide alternatives discussed by MBTOC for**  **tomatoes suggests that, of the registered (i.e., le gally available) chemistries, iodomethane, and**  **combinations of metam sodium, 1,3-D, and/or chlorop icrin have shown some potential as**  **commercially viable replacement to methyl bromide. Non-chemical alternatives are either not**  **viable for US tomatoes or require more research and commercial development before they can be**  **technically and economically feasible. For some are as in the state of Gerogia, a 3 way fumigant**  **combination of 1,3 D + chloropicrin, followed by ch loropicrin alone, followed by metam**  **sodium, has shown promise against key tomato pests in spring season only fumigation. However,**  **the aforementioned fumigant combination has not met with success in other areas of the** 

**southeast. The transition rate included in the BUN NIE incorporates an estimate of projected use**  **of this strategy as well as the use of iodomethane.**

**Many of the alternatives require the evaluation of their relationship between fumigant**  **alternatives, various mulches, and herbicide system s under different growing conditions. From**  **this information on-farm protocols can be establish ed.** 

**Alternatives are considered not feasible where: 1)**  **they have not been sufficiently tested or protocols have not been sufficiently developed** 

**for their use 2)**  **costs are excessive 3)**  **application difficulties exist due to such factors as equipment requirements**  **4) pest pressure is so high that alternatives are not**  **effective 5)**  **not registered for use in the US (such as DMDS).**

**The US nomination is only for those areas where the alternatives are still under extensive**  **evaluation and pest pressure is high. In US tomato production there are several factors that make**  **some of the assumed alternatives, other than iodome thane, unsuitable. These include:**  **1) Pest control efficacy of alternatives: the efficacy**  **of alternatives may not be comparable to methyl bromide in some areas, making**  **these alternatives technically and/or economically infeasible for use in tomato pr**  **oduction. 2)**  **Geographic distribution of key target pests: i.e., some alternatives may be comparable**  **to methyl bromide as long as key pests occur at low pressure. The US is only**  **nominating a CUE for tomato where the key pest pres sure is moderate to high such as**  **nutsedge in the Southeastern US. 3)**  **Regulatory constraints: e.g., in Florida due to the presence of karst topographical** 

**features. 4)**  **In Virginia and much of the mid-Atlantic, high wate r tables and the close proximity of**  **production areas to environmentally sensitive estua ries makes the use of 1,3-D** 

**limited. USA CUN10 SOIL TOMATOES**  **Open Field Page 6 of 27** 



### 5) **Delay in planting and harvesting: e.g., the plant-b ack interval for telone+chloropicrin**  **is two weeks longer than methyl bromide+chloropicri n. Delays in planting and**  **harvesting result in users missing key market windo ws, and adversely affect revenues**  **through lower prices. 6)**  **Alternatives that are nonselective are restrictive as a preplant burndown only.** 

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

**Not used to meet a certification standard.**

4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE,

INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY W HAT ALTERNATIVE STRATEGIES ARE USED TO

CONTROL THE TARGET PATHOGENS AND WEEDS W ITHOUT METHYL

BROMIDE THERE.

**In the areas where methyl bromide is not currently used there is often low weed and/or pathogen**  **pressure and/or no restrictions on 1,3-D use. In a reas where 1,3-D can be used, there are a many**  **growers have cooperated with universities and other s on developing application protocols**  **specific to their conditions for the 3 way fumigant combination (1,3 D + chloropicrin, followed**  **by chloropicrin alone, followed by metam-sodium).**

5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE

THIS?

**No, areas that use methyl bromide do so because env ironmental sensitivity and/or heavy pest**  **pressure preclude the use of fumigants that are emp loyed when these conditions are not present.** 

**Researchers are continuing to evaluate fumigant con centration and mulch interaction using the 3**  **way fumigation combination and iodomethane (Culpepp er et al, 2007). However, there is still**  **the need for more research to determine the fumigan t rates and mulch combinations needed for**  **pest control and crop safety where there is heavy p est pressure. In a study by Culpepper**  **(Georgia CUE appendix 2011; see Appendix A for a re production of this submission), the 3 way**  **fumigant combination resulted in tomato plant heigh ts that were lower than the methyl bromide**  **treated plots. When using the Blockade mulch (low permeability tarp) injury was severe with**  **plant damage and tomato yields being reduced even w hen the soil was allowed to air, but they**  **have seen good results in spring applications. Thi s is similar to information provided by growers**  **and university personnel in the southeast (Toth, 20 08)** **USA CUN10 SOIL TOMATOES Open Field**  **Page 7 of 27**

T ABLE 2. T OMATO PLANT YIELDS AND HEIGHT IN RESPONSE TO TIME O F PLANTING AFTER FUMIGATING

**.**

**Fumigant Mulch**  **Planting days after fumigation**  **Gas in bed at**

**planting (ppm)**  **Yield**

**(#/plot, highest value fruit only; no difference**  **noted with total fruit) Heights (cm)**  **(3 wk after planting)**

**MB LDPE 7 29 127 a 38 a** 

**3-WAY LDPE 7 77 127 a 32 cd** 

**3-WAY Blockade 7 368 55 c 14 f** 

**MB LDPE 7 + 1 2 117 a 37 ab** 

**3-WAY LDPE 7 + 1 13 132 a 33 cd** 

**3-WAY Blockade 7 + 1 31 99 b 27 e** 

**MB LDPE 14 2 142 a 37 ab** 

**3-WAY LDPE 14 4 132 a 34 bc** 

**3-WAY Blockade 14 38 114 a 30 de** 

**MB LDPE 14 + 1 0 133 a 35 abc** 

**3-WAY LDPE 14 + 1 3 127 a 33 cd** 

**3-WAY Blockade 14 + 1 27 119 a 30 de**  **Source: Georgia CUE Appendix; see Appendix A for a reproduction of this submission.** 



### Developing a protocol for this system includes the **titration of rates for field and strip applications (table 3). In preliminary data compar**  **ing the 3 fumigant combination, results have demonstrated that methyl bromide and iodomethane do**  **not significantly differ in efficacy. However variability among results across locations**  **demonstrates the need for further research (Toth, 2008). An exception to these findings was a**  **study by Chellemi (2008) where pepper plant height and yield was reduced due to crop injury; ho**  **wever, the injury was later correlated with high levels of soil potassium and probably not a di**  **rect result of the fumigation. On the other hand, in three of the trials weed and nematode cont**  **rol for the three fumigant combination and methyl bromide were low; less than 0.01 weeds / foo**  **t of row and nematode concentration was**

**less than 1.0 / 100 cc of soil.**

TABLE 3. UGA Three FUMIGANT COMBINATION Adjusted Ra tes 11-2008.

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

Treatment (lb / acre) Method

**Methyl Bromide 143 Chloropicrin 143**  **83**

**83 bedded, shank, standard tarp** 

**Methyl Bromide 143 Chloropicrin 143**  **83**

**83 bedded, shank,**  **high barrier tarp 1,3-Dichloropropene 171**  **Chloropicrin 150**

**Metam Sodium 320 99** 

**87**

**186 bedded, shank, standard tarp** 

**1,3-Dichloropropene 171 Chloropicrin 150** 

**Metam Sodium 320 99** 

**87**

**186 bedded, shank,**  **high barrier tarp**

**Source: Rates and application methods represent lik ely**  **scenarios based on information from USDA NASS, EPA proprietary data, and/or stakeholder-submitted comm**  **ents. Table taken from Georgia CUE Appendix; see Appendix**  **A for a reproduction of this submission. USA CUN10 SOIL TOMATOES**  **Open Field Page 8 of 27** 



### Tomato growers in Maryland have again requested met **hyl bromide. These growers have historically used methyl bromide in their tomato pr**  **oduction, purchasing it from the stockpile since the 2005 ban. Maryland growers, in common wi**  **th other tomato growers in the mid Atlantic region, have production areas with high wa**  **ter tables and in close proximity to environmentally sensitive estuaries; these factors**  **make the use of 1,3-D limited, and thus the three fumigant combination cannot be considered as**  **an alternative.**

**Techniques such as grafting, resistant rootstocks i mmune to target fungal pathogens, plant**  **breeding, soil-less culture, organic production, su bstrates, plug, are not commercially feasible.**  **Availability of such transplants is further hampere d by the lack of infrastructure to make grafted**  **tomato plants available on a large scale, concomita nt with this is the high premium associated**  **with these transplants at this time. Grafting and plant breeding are thus also rendered technically**  **infeasible as methyl bromide alternatives for contr ol of fungal pathogens, nutsedges and**  **nematodes. Grafting of solanaceous plants is relat ively new to US growers, and has met with a**  **great deal of concern regarding the potential for t he establishment of off-type plants developing** 

**from the rootstock and/or fruit seeds. N. Burell et al. (2008) evaluated various grafted tomato**  **cultivars in fields where iodomethane, DMDS, or met hyl bromide were applied. The results of**  **their research demonstrated that regardless of root stock, yields of tomato plants responded**  **equally without regard to fumigant type. In this c ase it would seem that the steady pace of on**  **going transitioning to alternative herbicides such as iodomethane would be more advantageous to** 

**pursue.**

6. SUMMARY OF RECENT RESEARCH

**As mentioned earlier in this document, iodomethane formulated with chloropicrin has shown**  **good efficacy against key tomato pests, including n utsedge, in a number of trials with tomato and**  **related vegetables such as peppers (e.g., Louws et al. 2006, Culpepper 2006, 2007, 2008,**  **Culpepper et al. 2008, Olsen 2008). Iodomethane had time limitations removed from its federal**  **label in October, 2008, and has received state-leve l approval in 47 US states (California,**  **Washington, and New York are the exceptions at this time). However, other important**  **constraints must be considered when assessing the f easibility of iodomethane as a methyl**  **bromide alternative. These include: (1) the cost of iodomethane formulations is higher than**  **methyl bromide, and will probably remain so for the next several years, (2) growers and** 

**researchers will need time to evaluate iodomethane use in the various local production conditions**  **covered by this nominations, and (3) growers and ap plicators will need to make some equipment**  **modifications to adapt to the lower flow rates typi cal with less expensive iodomethane**  **application rates and to avoid the corrosion of som e metals that can occur with iodomethane**  **(Sumner 2005, Noling et al. 2006). The economic impact of using iodomethane is further**  **described in item 7 in this document (below). A consideration of these aspects has led the USG**  **to conclude that while iodomethane appears to be te chnically feasible to manage key tomato**  **pests in all parts of the US where it has been regi stered, time will be needed for growers and**  **extension service experts to adapt its use successf ully. Therefore, the amount of methyl bromide**  **nominated for tomato has been adjusted downward whi le also considering the time needed to** 

**transition to iodomethane. USA CUN10 SOIL TOMATOES**  **Open Field Page 9 of 27** 



### Performance data presented by B. Olsen at the Novem **ber 2008 MBAO conference reported tomato yield data from 12 field sites where the ave**  **rage increase in yields from iodomethane treated plots over methyl bromide treated plots was**  **11 percent. Ten of the 12 study sites were in**

**the southeast. It must be noted that there was no statistical analysis present with this data and as**  **such there is no confirmation on whether this repor ted average increase in yields is significant.**  **Despite these results, representatives of the south east tomato growers’ consortia are currently**  **cautious about recommending iodomethane as a methyl bromide replacement (Toth, 2008).** 

**Research conducted in Georgia demonstrated that, in small plots, purple nutsedge control for**  **methyl bromide, iodomethane, and DMDS were not sign ificantly different under LDPE,**  **metalized, or VIF mulch (table 4). Yields of peppe r and cucumber plants fumigated with**  **iodomethane under VIF were not different from yield s for untreated plots (Culpepper et al,**  **2007). The reader should keep in mind here that DM DS is not registered for use in the USA.** 

**In a study by Chellemi (2008), pepper plant height and yield was reduced due to crop injury.**  **However, the injury was later correlated with high levels of soil potassium and probably not a**  **direct result of the fumigation. In this same stud y, three of the four trials reported weed and**  **nematode control for the three fumigant combination and methyl bromide at less than 0.01 weeds** 

**/ foot of row and nematode concentration at less th an 1.0 / 100 cc of soil.** 

T ABLE 

### 4. P URPLE NUTSEDGE PLANTS IN SMALL PLOT PEPPER CROP 

### (20 SQ FT 

### )

Mulch *Fumigant(s) LDPE Metalized VIF

**Methyl Bromide 0.5 a 0.0 a 0.3 a**

**Iodomethane 0.8 a 0.3 a 0.8 a**

**DMDS 2.5 a 0.5 a 0.0 a**

**Untreated 84 d 76 d 54 c** ***All fumigation treatments contain chloropicrin.Tab le taken from Culpepper et al (2007)** 



### Hausbeck and Cortright (2007) measured cucurbit pla **nt vigor to determine fumigant/mulch interactions using either LPDE or VIF plastic mulch**  **for the control of** Fusarium oxysporum **. Of the fumigants used in the study, the methyl bromide**  **and iodomethane treatments resulted in cantaloupe plants with the highest vigor (Table 5).**  **In general, treatments under LPDE had higher plant vigor when compared with plants grown**  **under VIF. It is noteworthy that in this study VIF tarps were prone to wind removal, which r**  **educed their reliability under some growing**

**conditions. USA CUN10 SOIL TOMATOES**  **Open Field Page 10 of 27**

T ABLE 5: E VALUATION OF F UMIGANTS AND P LASTIC M ULCHES FOR M ANAGING F USARIUM IN C UCURBIT C ROPS
2007



### Treatment (time after treatment to planting) Rate of

formulated product Vigor *



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



### Iodomethane+chloropicrin 50:50 under LDPE (10 days) **196 kg/ha 1.0 a**

**Iodomethane+chloropicrin 50:50 under VIF (10 days) 196 kg/ha 3.0 c** 

**Methyl bromide+chloropicrin 67:33 under LDPE (10 da ys) 280 kg/ha 1.0 a** 

**Methyl bromide+chloropicrin 67:33 under VIF (10 day s) 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 vari**  **able stand, 10=complete plant death.** 

****** **Column means with a letter in common are not signif icantly different (Fisher LSD Method;**  P **=0.05). From Hausbeck and Cortright 2007.** 



### In addition to the limitations of VIF discussed abo **ve, the USG notes that the plant vigor in 1,3 D**

**treatments in these new trials is lower than that s een in methyl bromide treatments. This is**  **similar to what was seen in previous years’ tests ( Hausbeck and Cortright 2004; see also**  **discussion in the cucurbit nominations).**

**As far as the USG has been able to determine, no ot her studies have been conducted since 2007** 

**to evaluate the technical and commercial feasibilit y of fumigant alternatives to methyl bromide**  **for controlling** F. oxysporum **subtypes under production conditions relevant to t he**  **Maryland/Delaware regions.**

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

**The following economic analysis is organized by met hyl bromide critical use application**  **regions.**

**Readers should note that in this study net revenue is calculated as gross revenue minus operating**  **costs. This is a good measure as to the direct los ses of income that may be suffered by the users.**  **It should be noted that net revenue does not repres ent net income to the users. Net income, which**  **indicates profitability of an operation of an enter prise, is gross revenue minus the sum of**  **operating and fixed costs. Net income should be sm aller than the net revenue measured in this**  **study. Fixed costs were not included because they are often difficult to measure and verify.** **USA CUN10 SOIL TOMATOES Open Field Page 11 of 27** 



### Summary of Economic Feasibility

**The economic analysis of the tomato application com pared data on yields, crop prices, revenues**  **and costs using methyl bromide and using alternativ e pest control regimens in order to estimate**  **the loss of methyl bromide availability. The alter natives identified as technically feasible - in**  **cases of low pest infestation 1**  

### – for different regions by the U.S. are: (a) iodom **ethane and (b) 1,3- dichloropropene and chloropicrin followed by chloro**  **picrin, followed by metam sodium/potassium (otherwise referred to as the Geor**  **gia 3-Way).**

**The economic factors that drive the feasibility ana lysis for fresh market tomato uses of methyl**  **bromide alternatives 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 requirements, and/or result ing shifts in other production or harvesting**  **practices (3) quality losses, which generally affec t the quantity and price received for the goods,**  **and (4) missed market windows due to plant back tim e restrictions, which also affect the quantity**  **and price received for the goods.**

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

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

**(2)** Loss per Kilogram of Methyl Bromide **. This 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 measure, at least over**  **some unit,** e.g. **, a hectare of land or a storage operation. However, high value commodities or crop**  **s may provide high revenues but may also entail high costs. Losses of even a small percenta**  **ge of gross revenues could have important impacts on the profitability of the activity.** 

**(4)** Loss as a Percentage of Net Operating Revenue **. We define net cash revenues as gross revenues minus operating costs. This is a very goo**  **d indicator as to the direct losses of income that may be suffered by the owners or operators of**  **an enterprise. However, operating costs can often be difficult to measure and verify.** 

**(5)** Operating Profit Margin **. We define operating profit margin to be net oper ating 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 en terprise. Again, operating costs may be** 

**difficult to measure and fixed costs even more diff icult, therefore fixed costs were not included**  **in the analysis.**

**1 It should be noted that the USG does not request me**  **thyl bromide for use in areas of low to moderate pe st pressure.**  **Only cases where key pests are present at moderate to high levels require methyl bromide for pest pres**  **sure. USA CUN10 SOIL TOMATOES**  **Open Field Page 12 of 27**



### These measures represent different ways to assess t **he economic feasibility of methyl bromide alternatives for methyl bromide users, who are toma**  **to producers in this case. Because producers (suppliers) represent an integral part of any defin**  **ition of a market, we interpret the threshold of significant market disruption to be met if there is**  **a significant impact on commodity suppliers using methyl bromide. The economic measures provid**  **e the basis for making that determination.**

Eastern US

**We conclude that, at present, iodomethane would be the economically feasible alternative to**  **methyl bromide for use in Eastern US tomato product ion in areas exhibiting karst topographical**  **features. However, see the technical discussion ab ove for a description of reasons why time will**  **be needed for growers to transition to routine, com mercially feasible iodomethane use. In areas**  **where karst features are not present it appears tha t tomato growers can use a combination of**  **three fumigants applied sequentially (1,3-D, chloro picrin, and metam-sodium/potassium) and**  **achieve yields that are comparable to those produce d by using methyl bromide for spring crops**  **only. The USG factored this new technique into the ir request by adding a four year transition**  **(assuming that all non-karst spring fumigations for tomatoes in the Southeast will transition**  **away from methyl bromide over four years) for sprin g fumigations.** 

T ABLE 6. V IRGINIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

VIRGINIA TOMATO GROW ERS M ETHYL
B ROMIDE Iodomethane G A

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE ( CWT ) 920 920 920

* P RICE PER U NIT ( US $) $ 33 $ 33 $ 33

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

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

= N ET R EVENUE PER H ECTARE ( US $) $ 2,995 $ 1,548 $ 2,215

1. L OSS PER H ECTARE ( US $) $ - $ 1,447 $ 78 0

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 17 $ 9

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 5% 3%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 48% 26%

5. O PERATING P ROFIT M ARGIN (%) 10% 5% 7%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs. USA CUN10 SOIL TOMATOES**  **Open Field Page 13 of 27**

T ABLE 7. M ARYLAND : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

MARYLAND TOMATO GROW ERS M ETHYL

B ROMIDE Iodomethane G A

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,953 4,953 4,953

* P RICE PER U NIT ( US $) $ 7 $ 7 $ 7

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

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

= N ET R EVENUE PER H ECTARE ( US $) $ 5,018 $ 3,319 $ 3,399

1. L OSS PER H ECTARE ( US $) $ - $ 1,699 $ 1,619

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 23 $ 22

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 5% 5%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 34% 32%

5. O PERATING P ROFIT M ARGIN (%) 14% 9% 10%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**

Error! Bookmark not defined.

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

SOUTHEASTERN TOMATO CONSORTIUM

** M ETHYL

B ROMIDE Iodomethane G A

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,942 4,942 4,942

* P RICE PER U NIT ( US $) $ 7 $ 7 $ 7

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

- O PERATING C OSTS PER H ECTARE ( US $)* $ 33,913 $ 35,428 $ 34,762

= N ET R EVENUE PER H ECTARE ( US $) $ 1,918 $ 402 $ 1,069

1. L OSS PER H ECTARE ( US $) $ - $ 1,516 $ 849

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 20 $ 11

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 4% 2%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 79% 44%

5. O PERATING P ROFIT M ARGIN (%) 5% 1% 3%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**   Includes: South-Eastern United States (Alabama,**  **Arkansas, Kentucky, Louisiana, Mississippi, North C arolina,**  **South Carolina, and Tennessee). USA CUN10 SOIL TOMATOES**  **Open Field Page 14 of 27**

T ABLE 9. G EORGIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA FRUIT & VEGETABLE

GROWERS ASSOCIATION M ETHYL

B ROMIDE Iodomethane G A

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 6,830 6,830 6,830

* P RICE PER U NIT ( US $) $ 9 $ 9 $ 9

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

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

= N ET R EVENUE PER H ECTARE ( US $) $ 1,820 $ 578 $ 164

1. L OSS PER H ECTARE ( US $) $ - $ 1,241 $ 1, 656

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8 $ 11

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 2% 3%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 68% 91%

5. O PERATING P ROFIT M ARGIN (%) 3% 1% 0%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**



### Florida

**We conclude that, at present, iodomethane would be the economically feasible alternative to**  **methyl bromide for use in Florida tomato production in areas of karst topography. Where karst**  **features are not present the USG assumed that the s equential application of the three chemicals**  **(discussed above) would have results that are simil ar to the performance of methyl bromide for**  **spring plantings. Consequently, as described above , the transition was adjusted to account for** 

**the new combination USA CUN10 SOIL TOMATOES**  **Open Field Page 15 of 27**

T ABLE 10. F LORIDA N ORTH : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA FRUIT & VEGETABLE

ASSOCIATION – NORTH FLORIDA M ETHYL

B ROMIDE Iodomethane GA

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3,548 3,548

* P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

= G ROSS R EVENUE PER H ECTARE ( US $) $ 34,874 $ 34,874 $ 3 4,874

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

= N ET R EVENUE PER H ECTARE ( US $) $ 4,070 $ 2,359 $ 3,026

1. L OSS PER H ECTARE ( US $) $ - $ 1,711 $ 1,044

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 20 $ 12

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 5% 3%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 42% 26%

5. O PERATING P ROFIT M ARGIN (%) 12% 7% 9%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**

T ABLE 11. F LORIDA RUSKIN PALMETTO : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA FRUIT & VEGETABLE

ASSOCIATION – RUSKIN PALMETTO M ETHYL

B ROMIDE Iodomethane GA

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3,548 3,548

* P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

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

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

= N ET R EVENUE PER H ECTARE ( US $) $ 2,152 $ 1,422 $ 2,089

1. L OSS PER H ECTARE ( US $) $ - $ 730 $ 63

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 7 $ 1

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 2% 0%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 34% 3%

5. O PERATING P ROFIT M ARGIN (%) 6% 4% 6%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs. USA CUN10 SOIL TOMATOES**  **Open Field Page 16 of 27**

T ABLE 12. F LORIDA PALM B EACH : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA FRUIT & VEGETABLE

ASSOCIATION – PALM BEACH M ETHYL

B ROMIDE Iodomethane GA

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,666 4,666 4,666

* P RICE PER U NIT ( US $) $ 11 $ 11 $ 11

= G ROSS R EVENUE PER H ECTARE ( US $) $ 50,152 $ 50,152 $ 50,1 52

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

= N ET R EVENUE PER H ECTARE ( US $) $ 1,922 $ 955 $ 1,622

1. L OSS PER H ECTARE ( US $) $ - $ 967.11 $ 300.23

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8.63 $ 2.68

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 2% 1%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 50% 16%

5. O PERATING P ROFIT M ARGIN (%) 4% 2% 3%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**

T ABLE 13. F LORIDA S OUTHWEST : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA FRUIT & VEGETABLE

ASSOCIATION – SOUTHWEST M ETHYL

B ROMIDE Iodomethane GA

– 3 W AY

M ETHOD

P RODUCTION L OSS (%) 0% 0% 0%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 4,666 4,666 4,666

* P RICE PER U NIT ( US $) $ 11 $ 11 $ 11

= G ROSS R EVENUE PER H ECTARE ( US $) $ 50,152 $ 50,152 $ 50,1 52

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

= N ET R EVENUE PER H ECTARE ( US $) $ 1,922 $ 955 $ 1,622

1. L OSS PER H ECTARE ( US $) $ - $ 967.11 $ 300.23

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 8.63 $ 2.68

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 2% 1%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 50% 16%

5. O PERATING P ROFIT M ARGIN (%) 4% 2% 3%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs. USA CUN10 SOIL TOMATOES**  **Open Field Page 17 of 27**

T ABLE 14. F LORIDA D ADE : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA FRUIT & VEGETABLE

ASSOCIATION – DADE M ETHYL

B ROMIDE Iodomethane M ETAM P LUS
C HLOROPICRIN

P RODUCTION L OSS (%) 0% 0% 15%

P RODUCTION PER H ECTARE (BOX 25 LBS ) 3,548 3,548 3,016

* P RICE PER U NIT ( US $) $ 10 $ 10 $ 10

= G ROSS R EVENUE PER H ECTARE ( US $) $ 34,874 $ 34,874 $ 29,6 43

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

= N ET R EVENUE PER H ECTARE ( US $) $ 702 $ 209 $ (4,559)

1. L OSS PER H ECTARE ( US $) $ - $ 493 $ 5,261

2. L OSS PER K ILOGRAM OF M ETHYL B ROMIDE ( US $) $ - $ 3 $ 35

3. L OSS AS A P ERCENTAGE OF G ROSS R EVENUE (%) 0% 1% 15%

4. L OSS AS A P ERCENTAGE OF N ET O PERATING

R EVENUE (%) 0% 70% 750%

5. O PERATING P ROFIT M ARGIN (%) 2% 1% -15%

***Note that the measures in the tables below must be interpreted carefully. Operating costs do not inc**  **lude fixed costs and net revenue equals gross revenue minus operatin**  **g costs.**



### 8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTI TIES

**The USG has applied an aggressive transition rate w hich is reflected in the nomination amount** 

**and detailed in Table 15.**

TABLE 15. N OMINATION 

### A MOUNT 

### : **2011 Methyl Bromide Usage Newer Numerical Index (BUNNI) – Transition Use Reduction**  **Description Spreadsheet**

.

Maryland

Tomatoes Virginia Tomato Southeast Tomato

Total Georgia Tomato Florida

Tomato Total Sector Total /
Average

Quantity Requested for 2010: Amount (kgs) 729 33,141

100,929

48,088

545,570

728,457

Quantity Recommended by

MBTOC/TEAP for 2010 : Amount (kgs) 729 33,141

100,929

48,088

545,570

728,457

Amount (kgs) 729

33,141

100,929

48,088

545,570

728,457

Area (ha) 5

203

619

296

3,356

4,479

Rate 146

163

163

162

163

163

Transition from 2010 Baseline Adjusted Value Percentage (%) -70% -82% -83% -81% -81% -81%

Amount (kgs) 

### 365

14,145

44,781

21,578

255,322

336,191

Area (ha) 2 87 275 132 1566 2062

Rate 183 163

163

163

163

163 Quantity Required for

2011 Nomination: TOMATOES

Quantity Approved by Parties

for 2010: SECTOR**USA CUN10 SOIL TOMATOES Open Field Page 18 of 27** 



### CITATIONS

**Baldwin, R.E. & C.M. Waldenmaier. 1991. Trellis T omato Fumigation Trial 1991. Eastern**  **Shore Agricultural Experiment Station. VA**

**Burelle, N.K, E.M. Rosskopf, M.G. Bausher, G. McCol lum. Alternative fumigants and grafting**  **for tomato and double-cropped muskmelon production in Florida 2008. Annual**  **International Research Conference on Methyl Bromid e Alternatives and Emissions**  **Reduction. (http://www.mbao.org/ )** 

**Burnette, G. 2003. Personal communication, Novemb er 25, 2003.** 

**Chellemi, D. O. 2008. Field validation of a fumigan t alternative. Proc. Annual Int. Res. Conf. on**  **Methyl Bromide Alternatives and Emissions Reduction s. Available on the web at**  **http://mbao.org/2008/008Chellemi.pdf**

**.**

**Chellemi, D., Botts, D.A. and Noling, J.W. 2001. Fi eld scale demonstration/validation studies of**  **methyl bromide in plastic mulch culture in Florida, USDA ARS specific co-operative**  **agreement SCA # 58-6617-6-013, Executive Summary (1 996-2001) submitted to the US** 

**EPA.**

**Chellemi, D.O. & J. Mirusso. 2006. Optimizing Soil Disinfestation Procedures for Fresh Market**  **Tomato and Pepper. Plant Disease vol. 90 n. 5. p. 6 68-674.** 

**Culpepper, Stanley. 2004. Faculty, University of Ge orgia, Athens, GA. Comments on methyl**  **bromide Critical use nomination for preplant soil u se for tomato grown in open fields.** 

**Culpepper, A.S., A.L. Davis, A.W. MacRae, and, T.L. Grey. Methyl bromide alternatives – best**  **options for 2007. From the 2007 Proceedings of the Southeast Regional Vegetable**  **Conference, Georgia, USA. Available on the web at: http://www.tifton.uga.edu/veg/Publications/GFVGA%20**  **2007/Culpepper-13.doc**

**Driver , J.G., and F.J. Louws. 2000. Fumigants an d varieties to manage southern bacterial wilt**  **of tomato. North Carolina State University.**

**Florida. 2000. Florida soil temperatures. Available on the web at** 

**www.imok.ufl/edu/weather/archive/200/clim00**

**Gilreath, J.P., J.P. Jones, T.N. Motis, B.M. Santos , J.W. Noling, and E.R. Rosskopf. 2003.**  **Evaluation of various chemical treatment for potent ial as methyl bromide replacemnts for**  **disinfetation of soilborne pests in polyethylene-mu lched tomato. Proc. Fla. State Hort.** 

**Soc. 116: 151-158.**

**Gilreath, J.P., T.N. Motis, and B.M. Santos. 2005.** Cyperus spp **. Control with reduced methyl bromide plus chloropicrin doses under virtually imp**  **ermeable films in pepper. Crop Prot.**

**24: 285-287. USA CUN10 SOIL TOMATOES**  **Open Field Page 19 of 27**



### Gilreath, J.P. & B.M. Santos. 2005. Efficacy of 1,3 **-Dichloropropene Plus Chloropicrin in Combination with Herbicides on Purple Nutsedge (**  Cyperus rotundus **) Control in Tomato.**

**Weed Tech. 19: 101-104.**

**Gilreath, J.P. & B.M. Santos. 2005. Purple Nutsedge (**  Cyperus rotundus **) Control with Fumigation and Pebulate Combinations in Tomato. Wee**  **d Tech. 19:575-579.**

**Gilreath, J.P. B.M. Santos, J.D. Busacca, J.E. Eger Jr., J.M. Mirusso, P.R. Gilreath. 2006.**  **Validation Broadcast Application of Telone C-35 Com plemented with Chloropicrin and**  **Herbicides in Commercial Tomato Farms. Crop Prot. 2 5:79-82.** 

**Gilreath, J.P. B.M. Santos, C.A. Chase, S.J. Locasc io. 2006. Influence of Soil Fumigation on 2,4-**  **D and Dicamba Carryover in Fresh Market Tomato. Cro p Prot. 25:1095-1100.** 

**Gilreath, J.P. B.M. Santos, T.M. Motis, J.W. Noling , and J.M. Mirusso. (2005) Methyl bromide** 

**alternatives for nematode and** Cyperus **control in bell pepper (** Capsicum annuum **). Crop Prot. 24: in press.** 

**Hausbeck, M. and Cortright, B. 2003. Soil temperatu re data submitted to BEAD (OPP, US-EPA)**  **in support of methyl bromide critical use exemption application.** 

**Hausbeck, M.K. & B.D. Cortright. 2003. Alternative s for methyl bromide on cucurbit and**  **Solanaceous crops. Unpublished.**

**Hausbeck, M.K. & B.D. Cortright. 2004. Evaluation of Fumigants for Managing Phytophthora** 

**Crown and Fruit Rot of Solanaceous and Cucurbit Cro ps; 2004. . Unpublished.** 

**Hausbeck, M. K. and B. D. Cortright. 2007. Comparis on of low density polyethylene 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).**

**IR-4. 2003. IR-4 Project Annual Report 2003. Ava ilable online at**  **http://ir4.rutgers.edu/annreport/report2003.pdf**

**Jacob, W. C. 1977. Range of mean outside temperatur e and rainfall in South-Eastern United** 

**States. Climatic Atlas of the United States. Publis hed by the US Department of** 

**Commerce.**

**Lamour, H.H. and Hausbeck, M. 2003. Effect of crop rotation on the survival of**  Phytophthora
capsici **in Michigan. Plant Disease 87: 841-845.**

**Locasio, S.J., Gilreath, J.P., Dickson, D.W., Kucha rek, T.A., Jones, J.P. and Noling, J.W. 1997.**  **Fumigant alternatives to methyl bromide for polyeth ylene-mulched tomato. HortScience**  **32(7) 1208-1211. USA CUN10 SOIL TOMATOES**  **Open Field Page 20 of 27**



### Locasio, S.J. & Dickson, D.W. 2000. Broadcast vs In **-Row Application of 1,3-D Plus Chloropicrin as an Alternative for Tomato Fumigants** 

**.**

**Louws, F.J., L.M. Ferguson, K. Ivors, J. Driver, K. Jennings, D. Milks, P.B. Shoemaker & D.W.**  **Monks. 2004. Efficacy of methyl bromide alternati ves for Verticillium and weed**  **management in tomatoes. North Carolina State Unive rsity.** 

**Louws, F.J., L.M. Ferguson, N.P. Lynch, & P. B. Sho emaker. 2002. Methyl bromide**  **alternatives in tomato production systems in North Carolina. North Carolina State**  **University.**

**Morales, J.P., Santos, B.M., Stall, W.M. and Bewick . T.A. 1997. Effects of purple nutsedge**  **(** Cyprus rotundus **) on tomato and bell pepper vegetative growth and f ruit yield. Weed**  **Science Technology 11: 672-676.**

**Minuto, A., A. Garibaldi, and M.L. Lodovica Gullino . 2003. Chemical Alternatives to Methyl**  **Bromide in Italy: An Update. Proceedings of the MBA O.** 

**Minuto, A. M.L. Gullino, F. Lamberti, T.D’Addabbo, E. Tescari, H. Ajwa, A. Garibaldi. 2006.**  **Application of an Emulsifiable Mixture of 1,3-Dichl oropropene and Chloropicrin Against**  **Root Knot Nematodes and Soilborne Fungi for Greenh ouse Tomatoes in Italy. 2006.**  **Crop Prot. 25:1244-1252**

**Nelson, M., B. Olsen, B. Vander Mey, G, Lepeze, and L. Rodriguez, B. Johnson, W. Currey, J.**  **Norton. 2001. Proceedings of the MBAO**

**Nelson, K.A. and Renner, K.A. 2002. Yellow nutsedge (**  Cyprus esculentus **) control and tuber production with glyphosate and ALS-inhibiting herbi**  **cides. Weed Technology 16(3):**

**512-519.**

**Norton, J., Nelson, R.D., Nelson, M.D., Olson, B.O. , Mey, B.V. and Lepez, G. 2000. Field**  **evaluation of alternatives to methyl bromide for pr e-plant soil fumigant in California**  **tomatoes. USDA IR-4 methyl bromide alternatives pr ogram for minor crop. Report**  **submitted to the US-EPA during 2003 in support of m ethyl bromide critical use**  **exemption.**

**Olsen, B. 2008. Midas soil fumigant 2008. Proc. Ann ual Int. Res. Conf. on Methyl Bromide** 

**Alternatives and Emissions Reductions. Available on the web at**  **http://mbao.org/2008/Proceedings/mbrpro08.html**

**.**

**Santos, B.M., J.P. Gilreath, T.N. Motis, J.W. Nolin g, J.P. Jones, and J.A. Norton. 2006.**  **Comparing Methyl Bromide Alternatives for Soilborne Disease, Nematode and Weed**  **Management in Fresh Market Tomato. Crop Prot. 25:69 0-695.** **USA CUN10 SOIL TOMATOES Open Field Page 21 of 27** 



### Stall, W.M. and Morales-Payan, J.P. 2003. The criti **cal period of nutsedge interference in tomato,**

**Florida. Web address: http://www.imok.ufl.edu/liv/groups/ipm/weed_con/nut**  **sedge.htm**

**Tostovrsnik, N.S., A.L. Shanks, I.J. Porter, S.W. M attner, and R.W. 2005. Facilitating the**  **Adoption of Alternatives to Methyl Bromide in Austr alian Horticulture. Proceedings of** 

**the MBAO**

**Toth, S. 2008. Personal communication, email to C. Augustyniak, November 4, 2008.** 

**U.S. Environmental Protection Agency. 1998. Re-regi stration Eligibility Decision (RED) 1,3**  **dichloroprppene. Available at http://www.epa.gov/REDs/0328red.pdf** 

**U.S. Environmental Protection Agency. 1998. Feasibi lity of using gas permeable tarps to reduce**  **methyl bromide emissions associated with soil fumig ation in the United States.** 

**Zhou, X.G. & K.L. Everts. 2003. Races and Inoculum Density of**  Fusarium oxysporum f. sp.

niveum **in Commercial Watermelon Fields in Maryland and De laware. Amer. Phytopath.** 

**Soc. V. 87 n. 6 692-698. USA CUN10 SOIL TOMATOES**  **Open Field Page 22 of 27** 

### APPENDIX A

Reproduced from the 2011 Critical Use Exemption App lication submitted by the Georgia Fruit & Vegetable Association

**Summarized and Compiled by A. Stanley Culpepper, University of Georgia, Tifton** 

1. Methyl Bromide Data Generated in Georgia

**Continued efforts are underway in Georgia to implem ent effective and economical alternatives to methyl**  **bromide. During the spring of 2008, at least 40% o f the land fumigated for vegetable crops in the spr**  **ing was treated with the 3-WAY which includes a systems**  **approach of 1,3-dichloropropene, chloropicrin, and metam sodium. It is likely that 30 to 40% of**  **Georgia’s total crop will be treated with this alte rnative**  **during 2008. Dimethyl disulfide (DMDS) plus chloro picrin also has proven to be effective in managing**  **many pests and has the potential to be adopted once the price structure is known.** 

**Although both the 3-WAY and DMDS appear promising, neither fumigant system will stand alone in**  **managing pests. A herbicide program must be develo ped to compliment these fumigant systems. The 3-**  **WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system**  **does not adequately control grasses or** Amaranthus **species. Until program using fumigants and herbicides can be developed, having methyl bromide**  **available is essential.**

**The two aforementioned fumigant systems also pose s ignificant challenges when determining the time**  **interval needed between fumigating and planting. I nitial research results suggest the plant back inte**  **rval for the 3-WAY will be at least 3 times longer than**  **that noted with methyl bromide (Item 3 below). For DMDS, the research is currently in progress with re**  **sults available by September of 2008. Early indications suggest that the plant back for DMDS pl**  **us chloropicrin applied under a high barrier mulch will be similar to that noted with the 3-WAY system** 

**.**

**Future research will focus on developing and implem enting a herbicide program to compliment both the**  **3-WAY and DMDS fumigant systems as well as determin ing the amount of time that must pass between**  **fumigating with these alternatives and planting. USA CUN10 SOIL TOMATOES**  **Open Field Page 23 of 27**



### 2. A herbicide system must be developed for the UGA 3-WAY during summer/fall fumigation

Introduction **Georgia growers are adopting an effective alternati ve to methyl bromide during the spring fumigation**  **cycle. However, research is needed to determine i f this alternative is effective during the summer/f**  **all fumigation period. Fumigants may be less effective**  **in the summer/fall when compared to the spring because of warmer soils causing increased gas dissi**  **pation.**

Materials and Methods

**An experiment was conducted in TyTy Georgia at the University of Georiga’s Ponder Farm. The trial**  **was conducted on a Tifton sandy loam soil with 92% sand, 2% silt, and 6% clay with a pH of 6.4 and 1%**  **organic matter. Land was prepared by disking the t rial area multiple times and then roto-tilling a 6**  **foot wide bed by 60 feet in length for each plot immedia**  **tely prior to fumigating and installing mulch.**

**The study was fumigated during the fall of 2007 on July 17. Soil temperature was 84 degrees at 8 inch**  **es. The experiment consisted of 4 treatments (Table 1)**  **that were replicated three times. The UGA 3-WAY consisted of a system of Telone II (12 gal/A) follo**  **wed by chloropicrin (150 lb/A) followed by Vapam (7 5**  **gal/A). The Telone II was placed 12 inches deep us ing a Yetter system having 3 injection knives on a**  **32 inch bed top, methyl bromide and chloropicrin were**  **injected 8 inches deep with a super bedder using 3 injection knives on a 32 inch bed top, and Vapam wa**  **s injected 4 inches deep and 4 inches apart using d isc**  **blades in the final bed just prior to covering with mulch. Methyl bromide was applied at 240 lb/A. A**  **ll fumigant rates are provided as broadcast rates but**  **were actually only applied in the bed. Mulch used included low density polyethylene or Blockade high**  **barrier mulch.**

**Visual crop injury, visual weed control, and the nu mber of nutsedge shoots penetrating the mulch were**  **measured throughout the season. No visual injury w as noted. Percent control and nutsedge penetrating**  **the crop provided similar results thus only percent control is reported. Jumbo pepper was harvested f**  **our times, once a week for four weeks.** 

**Table 1. Comparing methyl bromide and the 3-Way fo r the control of nutsedge and tomato yield.**  **Fumigant Mulch**  **Late-season purple nutsdege** 

**control Harvests 1-2** 

**(Jumbo pepper) Harvests 1-4**  **(Jumbo pepper)**

**% # fruit/plot**  **lbs/plot # fruit/plot**  **lbs/plot**

**3-WAY LDPE 48 d 34 c 16 c 44 c 19 c**

**3-WAY Blockade 60 c 50 b 24 b 71b 32 b** 

**MB Blockade 85 b 106 a 48 a 136 a 61 a** 

**None LDPE 0 f 13 d 6 d 19 d 8 d**

Results and Discussion

**Poor nutsedge control was noted with the UGA 3-WAY system when applied under LDPE or Blockade**  **mulch. Fumigant gas emissions occurred so rapidly that nutsedge tubers were likely not under a high**  **enough concentration of gases long enough to provid e adequate control as is the case in the spring.**  **Methyl bromide was far more effective with nearly t wice the level of control noted with the 3-WAY even**  **under blockade mulch. As expected, yields followed trends in nutsedge control since it was the only pe**  **st impacting the crop. Yields from plots treated with**  **methyl bromide were more than double that of the UGA 3-WAY applied under LDPE mulch. Although yield**  **was improved with the 3-WAY applied under USA CUN10 SOIL TOMATOES**  **Open Field Page 24 of 27**



### blockade mulch compared to LDPE mulch, this higher **yield was only approximately half of that noted with the methyl bromide system.** 

Conclusions

**The UGA 3-WAY is not a stand alone replacement to m ethyl bromide during a summer/fall fumigation in**  **Georgia. Either an effective and economical herbic ide system must be developed to compliment this**  **alternative program or another more effective fumig ant system must be developed.** **USA CUN10 SOIL TOMATOES Open Field Page 25 of 27**  

### 3. Determining plant back intervals when fumigatin g with the UGA 3-WAY

Introduction

**The UGA 3-WAY system is replacing methyl bromide ra pidly in Georgia. Although this system has been**  **effective during the spring, the program has the po tential to delay planting after fumigation. Resear**  **ch is**

**needed to determine the time interval needed betwee n fumigation and planting vegetable crops.** 

Materials and Methods

**An experiment was conducted in Tifton Georgia at th e University of Georgia’s Tifton Vegetable Park.**  **The trial was conducted on a Tifton sandy loam soil with 94% sand, 2% silt, and 4% clay with a pH of 6**  **.2 and 1% organic matter. Land was prepared by diskin**  **g the trial area multiple times and then roto-tilli ng a**  **6 foot wide bed by 20 feet in length for each plot immediately prior to fumigating and installing mulc**  **h.**

**The study was fumigated during the spring of 2007 o n February 27. Soil temperature was 59 degrees at**  **8 inches. The experiment consisted of 12 treatments (**  **Table 1) that were replicated three times. The UGA 3-WAY consisted of a system of Telone II (12 gal/A)**  **followed by chloropicrin (150 lb/A) followed by Vapam (75 gal/A). The Telone II was placed 12 inch**  **es deep using a Yetter system having 3 injection knives on a 32 inch bed top, chloropicrin was place**  **d 8 inches deep with a super bedder using 3 injecti on**  **knives on a 32 inch bed top, and Vapam was injected 4 inches deep and 4 inches apart using disc blades**  **in the final bed just prior to covering with mulch. Methyl bromide (MB) was included for comparison**  **and was applied at 350 lb/A. All fumigant rates ar e provided as broadcast rates but were actually onl**  **y applied in the bed. Mulch used included low densit**  **y polyethylene or Blockade high barrier. Crops wer e**  **planted 7 or 14 days after fumigating while poking the plant hole through the mulch. Crops were also**  **planted on days 8 or 15 which was 1 day after pokin g the hole on days 7 and 14 in an attempt to air th**  **e bed. Crops planted included tomato, pepper and cuc**  **umber.**

**Visual crop injury and crop heights (7 tomato, 20 p epper, 7 cucumber plants per plot) were measured**  **throughout the season. Tomato, pepper and cucumber were harvested five, four, and nine times,**  **respectively.**

**Table 1. Plant heights in response to time of plan ting after fumigating.**  **Fumigant Mulch**  **Planting days**

**after fumigation**  **Gas in bed**

**at planting Heights (cm)** 

**(3 wk after planting)**

**ppm Tomato**  **Pepper Cucumber** 

**MB LDPE 7 29 38 a 21 ab 30 ab**

**3-WAY LDPE 7 77 32 cd 17 d 24 d**

**3-WAY Blockade 7 368 14 f 4 f 12 f** 

**MB LDPE 7 + 1 2 37 ab 20 abc 32 a**

**3-WAY LDPE 7 + 1 13 33 cd 18 cd 26 cd**

**3-WAY Blockade 7 + 1 31 27 e 11 e 20 e** 

**MB LDPE 14 2 37 ab 22 a 32 a**

**3-WAY LDPE 14 4 34 bc 20 abc 31 ab**

**3-WAY Blockade 14 38 30 de 18 cd 28 bc** **USA CUN10 SOIL TOMATOES Open Field Page 26 of 27** 



### MB LDPE 14 + 1 0 35 abc 22 a 31 ab

**3-WAY LDPE 14 + 1 3 33 cd 21 ab 31 ab**

**3-WAY Blockade 14 + 1 27 30 de 19 bcd 28 bc** **USA CUN10 SOIL TOMATOES Open Field Page 27 of 27** 



### Table 2 . Plant yields in response to time of plan **ting after fumigating. Fumigant**  **Mulch Planting days** 

**after fumigation**  **Gas in**

**bed at planting**  **Yield**

**(#/plot, highest value fruit only;**

**no difference noted with total**

**fruit)**

**ppm Tomato**  **Pepper Cucumber** 

**MB LDPE 7 29 127 a 227 a 45 de**

**3-WAY LDPE 7 77 127 a 195 ab 60 a**

**3-WAY Blockade 7 368 55 c 114 c 40 e** 

**MB LDPE 7 + 1 2 117 a 212 a 47 cde**

**3-WAY LDPE 7 + 1 13 132 a 193 ab 57 ab**

**3-WAY Blockade 7 + 1 31 99 b 159 bc 47 cde** 

**MB LDPE 14 2 142 a 220 a 49 bcde**

**3-WAY LDPE 14 4 132 a 190 ab 55 abc**

**3-WAY Blockade 14 38 114 a 188 ab 49 bcde** 

**MB LDPE 14 + 1 0 133 a 204 ab 49 bcde**

**3-WAY LDPE 14 + 1 3 127 a 202 ab 50 bcd**

**3-WAY Blockade 14 + 1 27 119 a 190 ab 42 de** 

Results and Discussion

**No visual stunting from methyl bromide was noted wi th any treatment at 3 wk after transplanting (data**  **not shown). When planting 7 days after fumigating with the 3-WAY under LDPE mulch, crop heights**  **were reduced at least 20% when compared to the meth yl bromide control (Table 1). Growth reduction**  **from the 3-WAY under Blockade mulch was far greater and ranged from 60 to 80%. Airing the bed for**  **one day did not alleviate stunting. Waiting 14 day s after fumigating before planting did alleviate**  **fumigant stunting when crops were planted on the LD PE mulch. However, significant reduction in plant**  **growth was still noted when planting into the block ade mulch. Airing the bed for 1 d did not eliminat**  **e crop stunting when planting on the blockade mulch.** 

**Tomato and cucumber were resilient in overcoming ea rly season reduction in plant growth with only**  **minor trends for reduced yields when planted on LDP E mulch, when compared to the methyl bromide** 

**control. Yield reductions were noted with tomato w hen planted on Blockade mulch at 7 or 8 d after**  **fumigating. Pepper tended to be more sensitive tha n other crops with lower yields or a trend for lowe**  **r yields when planting on both mulches at each planti**  **ng date except for the 15 day plant date on LDPE**

**mulch.**

Results and Discussion

**This research is the first step in determining the time interval needed between fumigating and plantin**  **g. The most effective tactic will likely not be days a**  **fter fumigating but ppm of fumigant in the bed at planting as the environment plays such a role in th**  **e dissipation of gas from the soil. This research suggests that for the UGA 3-WAY, less than 5 ppm sh**  **ould be in the bed at time of planting.**