USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### NOMINATING PARTY : The United States of America FILE NAME: USA CUN13 SOIL ORNAMENTALS Open Field and Protected Environments BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methyl Bromide Critical Use Nomination for Preplant Soil Use for Ornamentals in Open Fields and Protection Environments (Submitted in 2011 for 2013 Use Season) CROP NAME (OPEN FIEL D OR PROTECTED): Ornamentals

– Open Fields and Protected QUANTITY OF METHYL B ROMIDE NOMINATED:
T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE N OMINATED



### Year N OMINATION 

### A MOUNT 

### 201 3 48,164 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) 64 7

- 9799 Fax: (202) 647

- 5947 E

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

## ■ Yes  No

Signature Nam e Date Title: (Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone 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 firs t

-

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 CUN13 SOIL Ornamentals Open Field and Protected Environments



### CONTACT OR EX PE RT(S) FOR FURTHER TECHNICAL DETAILS: Contact/Expert Person: Jack Housenger Title: Director Address: Biological and Economic Analy sis Division Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mailcod e 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

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 CUN13 SOIL ORNAMENTALS Open Field and Protected Environments

* Identical to paper documentsUSA CUN13 SOIL Ornamentals Open Field and Protected Environments



## METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT SOIL USE ( OPEN FIELD OR PROTECTED ENVIRONMENT) ORNAMENT ALS 1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE: This re

- nomination is for methyl bromide for the production of ornamentals. The ornamental sector consists of cut flowers, cut greens, and bulbs in California and floriculture in Florida. Al l data comes from the applicants’ requests unless otherwise cited. California Ornamental growers in California have a demonstrated critical need for methyl bromide in 201 3

. Alternatives are not available due to regulatory constraints. Io domethane (meth yl iodide) was registered in December of 2010 in California, but its future registration status is uncertain because of lawsuit that was filed to stop its registration

. Many alternative fumigants contain 1,3

- dichloropropene and/or chloropicrin; these act ive ingredients are severel y restricted b y California state and local laws which effectivel y prevent their use as meth yl bromide alternatives for ornamental cultivation. Restrictions on chloropicrin also means the lowest formulation of methyl bromide used in California is 67:33 (methyl bromide: chloropicrin), as rates of chloropicrin higher than 225 kg/ha are prevented by law and lower rates are ineffective for pest control. A single grower may grow dozens of t yp es of species and cultivars, each of which may experience different pest pressures and may result in varying cultivar and species reactions to pest control measures, impacting an alternative’s ability to control the entire pest spectrum. Florida Iodomethane has been a registered pesticide in Flori da since earl y 2009

. Thus far, research results indicate that it is as efficacious as meth yl bromide, facilitating a transition away from methyl bromide. However, few long

- term trials have been conducted and concerns have been raised about application tec hniques and species

- specific interactions. For instance, there have been no iodomethane trials to treat permanent post

- rows using the “hot gas” method, which is a common management practice for Florida ornamental growers. Until more studies have been don e to address these concerns and growers have more time to adapt their production practi c es , there is a critical need for methyl bromide in 201 3 as part of a multi

- ye ar transition to alternatives. Some alternatives that appear effective in research trials are not currentl y registered, including acrolein and dimethyl disulfide ( DMDS )

.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### 2. REASONS WHY ALTERNAT IVES TO METHYL BROMI DE ARE NOT FEASIBLE The adoption of alternatives to methyl bromide b y the ornamentals sector is constrained b y regulatory

prohib itions, y ield losses, and higher costs which vary greatly by state. Additionally , some constraints appl y to the entire ornamentals industry. A single grower may grow dozens of ty pes of species and cultivars, each of which may experience different pest pr essures. For example, a 2008 study

in Florida found a significant difference between the pests of two cultivars of Delphinium and their pest loads (Rosskopf et al 2008). These differences may result in varying cultivar and species reactions to pest contro l measures, impacting an alternative’s ability to control the entire pest spectrum. Meth yl bromide is requested for ornamentals to allow time to test the alternatives for all the different crops and growing conditions. California In addition to federal regulations, the California Department of Pesticide Regulation (DPR) has implemented severe restrictions for soil fumigants, including larger buffer zone requirements and township caps, which limit the amount of each fumigant can be applied within a 36

- mi le area (Segawa et al 2005) . If these restrictions were not in place, the best meth yl bromide alternative for ornamental growers in California would be 1,3

- D plus chloropicrin followed by metam sodium (James Gerik, personal communication) . A recent study found that this fumigant combination was at least as efficacious as meth yl bromide (Klose et al 2008)

. T he state buffer and township cap regulations currentl y prevent the use of this alternative. Moreover, another recent stud y found that the most effecti ve alternative treatments contain chloropicrin (Gerik et al 2002). However, an y pesticide combinations including either 1,3

- D or chloropicrin are subject to prohibitory

regulations and can onl y be considered as alternatives in areas where regulatory constraints do not restrict their use

. Iodomethane received a registration in California in December of 2010 . The rates registered in California are lower than those registered in the rest of the U.S. and the buffer distances to habited structures are up to 1 0X larger than in the rest of the U.S. Research will need to be conducted on the efficacy of these lower use rates. Some alternatives that appear effective in research trials are not currentl y registered, including acrolein , and DMDS

. The future registr ation status of these products and other alternatives is unknown. Florida Iodomethane is now fully registered in Florida and recent research results showed it is at least as effective as meth yl bromide for pest control in Florida ornamentals (Rosskopf et al 2006, Rosskopf et al 2007a, Rosskopf et al 2007b, Kokalis

- B urelle et al 2006). However, no studies have been conducted on the same fields for more than two y ears, so long

- term efficacy and a pplication issues have yet to be fully identified and understo od. Moreover, efficacy has varied between the species and cultivars tested in research trials; it is impossible to predict how each of the many species and cultivars of ornamentals would respond to iodomethane. Additionally , research is needed on the co mpatibility of iodomethane with ‘hot gas’ fumigant application currentl y used for meth yl bromide; it is a common management method for ornamental growers.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### More studies are needed in order to understand the climate

- specific constraints faced by Florida orn amental growers . The applicants continue to apply for grants and conduct research to this end in collaboration with California ornamental growers

. DMDS was registered in 2010 for ornamentals but not in Florida ( registered states currentl y include: G eorgia , Ohio, North and South Carolina, Michigan, New Mexico, Tennessee, Texas, and Virginia )

. If DMDS is registered in Florida additional time will be needed because there are very few long term DMDS efficacy studies on ornamentals

.

3. IS THE USE COVERED B Y A CERTIFICA TION STANDARD? Methyl bromide is n ot used to meet a certification standard for ornamental production

.
4. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE I S NOT USED IN THE OT HER AREA, AND IDEN TIFY WHAT ALTERNATIV E STRATEGIES ARE USE D TO CONTROL THE TARGET P ATHOGENS AND WEEDS W ITHOUT METHYL BROMIDE THERE. Methyl bromide is onl y being requested for ornamental crop acreage with demonstrated critical need and is not being requested for acreage th at has had success with alternatives, such as caladiums in Florida. Enclosures Some ornamental growers using greenhouses have had success controlling pests with substrates. Crops successfull y grown in soilless media include roses, gerbera, lilies, and tulips. However, even substrates are fumigated after multiple cropping seasons to control diseases such as Pythium and continue using the substrate, which must be reused in order for the cropping s ys tem to be cost effective. Certain crops actually experie nce yi eld or quality gains when grown in substrates, such as roses; however, for most crops there is not such a gain to offset the increased costs associated with substrate production. Soilless media sy stems also require altered watering and fertilization management practices, which may incur additional costs. Ultimately , the use of substrates requires greenhouses with benches, as opposed to growing crops in enclosures with open bottoms to the soil. Steam sterilization has been adopted b y some shade ho use and greenhouse growers to produce lilies. While steam is considered effective in controlling pests, there are many costs required to set up a steaming sy stem within an existing enclosure structure. The cost of fuel required to heat soil beds uniformly also impacts the feasibility of steam sterilization. Some growers who attempted transitioning to steam sterilization switched back to fumigation due to application issues and additional costs. Researchers in California and Florida have looked a steam st erilization for ornamental production sy stems ( Rosskopf 2010, and Hanson 2010). This work suggests with some additional testing that field applied steam could become a technically and economicall y feasible alternative.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### Open Field The U.S. does not hav e information about the proportion of ornamental or floriculture crops using alternatives to methyl bromide. It can be presumed that acreage not requesting methyl bromide has either transitioned to an alternative pesticide or does not have the same croppi ng practices or pest pressure as the applicants with critical use requests. For example, Easter lil y growers in California now use 1,3

- D and metam sodium applied sequentially instead of methyl bromide. However, these crops allow fallow periods between crops of more than 10 y ears, which is not feasible for other specialt y growers due to limited land resources. Additionally , some growers have reduced their planted acreage due to economic hardship in recent ye ars but intend to expand plantings and thereb y fumigated acres when the econom y improves.

5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NEC ESSARY TO ENABLE THIS? No, it is not currently

fe asible to expand the use of alternative pest control measures to address the demonstrated critical needs of the ornamentals sector requesting methyl bromide for the 201 3 growing season. Regulatory , technical, and economic barriers prevent their adoption and generall y vary b y state. Research to find efficacious, safe, and cost ef fective alternatives is ongoing, and applicants have a long history of successfull y appl yi ng for grants and carrying out research on alternatives. California State and local regu lations would have to change in order for fumigants such as 1,3

- D and chloropicrin to be adopted as methyl bromide alternatives. Other fumigants currentl y being tested may

prove effective in research trials but lack registration in the state of California , such as DMDS ). Furthermore, some fumigants considered effective in research trials for use in California lack both federal and state registration, including dimethyl disulfide and acrolein (Gerik and Wong 2008)

. Florida Research is needed in order t o determine the long

- term efficacy and cost issues associated with iodomethane adoption as a methyl bromide alternative. More research is also needed on nonfumigant alternatives such as steam

. Critical use of methyl bromide could be further reduced by ch anging the label to allow concentrations lower than 98:2 (meth yl bromide: chloropicrin) to be applied using the ‘hot gas’ method, which is a common management practice. Concentrations as low as 50:50 (meth yl bromide: chloropicrin) have been found to achie ved comparable control of nematodes and nutsedge as with the 98:2 formula (Noling et al 2001).

6. SUMMARY OF RECENT RE SEARCH
CALIFORNIAUSA CUN13 SOIL Ornamentals Open Field and Protected Environments



### Hanson, B. 2010. Steam Disinfestation as a Methyl Bromide Alternative in California C ut Flower Nurseries. 

### Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2010/085HansonBSteamflowernursery .pdf Steam treatments were compared to methyl bromide for the product ion of snapdragon, and Asiatic lily in California. There were no difference between MeBr and steam for weed or Fusarium control at the snapdragon site. At the Asiatic lily site there were no difference in Fusarium or Pythium control, weed control or lily plant emergence.
FLORIDA 

### Rosskopf, E.N., N. Kokalis

- Burelle, E. Nissen, O. Nissen, R. Hartman, R. McSorley , E. Skvarch, T.J. Swaford, C. Owens, S. Brooks, and K. Register. 2010 . Evaluation of currentl y available alternatives to meth yl bromide for ornamental crop production in Florida. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2010/082RosskopfAreawideOrnamental..pdf The 2010 results were different than the 2008 results above. No significant difference between methyl bromide, DMDS, or iodomethane in terms of soil b orne fungi., However, none of the alternatives were as consistent as methyl bromide for weed control and there was a fungal plant pathogen with nematode interaction for the different fumigants that will need to be resolved.

. Rosskopf, E.N., N. Kokalis

- Burelle, D.M. Butler, J. Holzinger, S. Fennimore. 2010. Evalution of steam for nematode and weed control in cut flower production inFlorida. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reduct ions. http://mbao.org/2010/083RosskopfSteam.pdf The results of the 2010 study suggests that steam sterilization can control weeds, reduce root gall ratings compared to MeBr on snapdragon, larksp ur, and delphinium. The production of snapdragon, larkspur, and delphinium appeared similar between MeBr and steam treatments.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES Please note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct losses of income that may be suffered by

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

of an operation for an enterprise, is gross revenue minus the sum of operating and fixed costs. Net income is smaller than the net revenue measured in this study , often substantially

so. We did not include fixed costs because they are difficult to measure and verify

.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### T ABLE 

### 2 : C ALIFORNIA CUT FLOWERS 

### - C ALLA 

### L ILY 

### & R ANUNCULUS 

### - E CONOMIC 

### I MPACTS OF 

### M ETHYL 

### B ROMIDE 

### A LTERNATIVES California Cut Flowers

– Calla Lily & Bulbs M ETHYL B ROMIDE 1,3
- D + Pic Dazom et Me tam Sodium Y IELD L OSS (%) 0 25 25 20 Y IELD PER H ECTARE 55,937 41,9 52 41,952 44 , 749 * P RICE PER U NIT (U.S.$) 2

. 59 2.59 2.59 2.59

= G ROSS REVENUE PER H ECTARE (U.S.$) 145,107 108,830 108,830 116 ,0 86

- O PERATING C OSTS PER H ECTARE (U.S.$) 160 ,03 0 160 ,03 0 160 ,03 0 160 ,03 0

= N ET O PERATING REVENUE PER H ECTARE (U.S.$)

- 14,923

- 51,200

- 51,200

- 43,945 1. L OSS PER H ECTARE (U.S.$) 0 36 , 277 36 , 277 29,021 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE (U.S.$) 0 1 37 137 110 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0 25 25 20 4. L OSS AS A P ERCENTAGE OF N ET O PERATING REVENUE (%) 0

- 243

- 243

- 194


### T ABLE 

### 3 : F LORIDA 

### C UT 

### F LOWERS 

### - L ILIES 

### - E CONOMIC 

### I MPACTS OF 

### M ETHYL 

### B ROMIDE 

### A LTERNATIVES Florida Cut Flowers

– Lilies M ETHYL B ROMIDE IODOMETHANE + PIC (98:2) Y IELD L OSS (%) 0 0 Y IELD PER H ECTARE 3 1 , 135 3 1 , 135 * P RICE PER U NIT (U.S.$) 10 10

= G ROSS REVENUE PER H ECTARE (U.S.$) 311,353 311,353

- O PERATING C OSTS PER H ECTARE (U.S.$) 262,715 262,715

= N ET O PERATING REVENUE PER H ECTARE (U.S.$) 48,638 46,908 1. L OSS PER H ECTARE (U.S.$) 0 1,730 2. L OSS PER KILOGRAM OF M ETHYL B ROMIDE (U.S.$ ) 0 4 3. L OSS AS A P ERCENTAGE OF G ROSS REVENUE (%) 0 1 4. L OSS AS A P ERCENTAGE OF N ET O PERATING R EVENUE (%) 0 4 

### Summary of Economic Feasibility The economic anal ys is evaluated methyl bromide alternative control scenarios for cut flower pro duction for California and Florida by comparing the economic outcomes of methyl bromide oriented production s ys tems to those using alternatives. However, due to the fact that there are over 100 species of ornamentals grown in all regions of the country , the data from these examples are used to derive a prox y estimate for the entire industry

. A major factor that affected this economic anal ys is as compared to the past economic anal ys es was the availability of iodomethane (registered in 2008) in Florida, but not in Cali fornia for use in ornamentals. The economic factors that most influence the feasibility of methyl bromide alternatives for fresh cut flower production are: (1) yield losses, referring to reductions in the quantity and qualit y produced, (2) increased pro duction costs, which may be due to the higher

- cost of using an alternative, additional pest control requirements, and/or resulting shifts in other production or harvesting practices, and (3) missed market windows due to plant back time restrictions, which also affect the quantit y and price received for the goods.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### The economic reviewers anal yz ed crop budgets for 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. Itis relativel y eas y to measure, but may

be difficult to interpret in isolation. (2) Loss per Kilogram of Methyl Bromide. This measure indicates the n ominal marginal value of methyl bromide to crop production. (3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usuall y eas y to measure, at least over some unit, e.g., a hectare of land or a storage operation

. However, high value commodities or crops may provide high revenues but may also entail high costs. L osses of even a small percentage of gross revenues could have important impacts on the profitability

of the activity

. (4) Loss as a Percentage of Net O perating 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 b e difficult to measure and verify

. These measures represent different way s to assess the economic feasibility of methyl bromide alternatives for meth yl bromide users, who are producers in this case. Because producers (suppliers) represent an integral par t of any definition of a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using meth yl bromide. The economic measures provide the basis for making that determination. Se veral methodological approaches will help interpret the findings. Economic estimates were first calculated in pounds and acres and then converted to kilograms and hectares. Costs for alternatives are based on market prices for the control products multipl ied by the number of pounds of active ingredient that would be applied. Baseline costs were based on the average number of annual applications necessary to treat cut flowers with methyl bromide. Net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct losses of income that may be suffered by the users. It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability of an operation of an enterprise , is gross revenue minus the sum of operating and fixed costs. Net income should be smaller than the net revenue measured in this study . Fixed costs were not included because they

are difficult to measure and verify

. Loss per hectare measures the valu e of meth yl bromide based on changes in operating costs and/or changes in yield. Loss expressed as a percentage of the gross revenue is based on the ratio of the revenue loss to the gross revenue, likewise for the loss as a percentage of net revenue. Yi e ld loss estimates were based on data from the CUE applications and U.S. EPA data, as well as expert opinion.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### Regulatory

constraints California restricts total use of 1,3

- D at the local level (township cap). Nematodes and weeds and pathogens are key

pest s in Florida and California bulb grower and are controlled with methyl bromide. Chloropicrin is not as effective in controlling weeds as meth yl bromide. Using chloropicrin adds to production costs through increased chemical, weeding and labor costs. Tab les 2 though 4 provide a summary of the estimated economic losses. A measure of net revenue loss may

not be completely

accurate partly

because some nurseries are publicl y owned and seedling prices or production costs are subsidized. Indirect losses arisi ng from shifts in the production cycle were not quantified. Changes in production costs arise due to differences between the costs of methyl bromide and the alternatives, shifts in the production cycle (increasing the frequency of fumigation or lengthenin g the fallow period) and additional expenses such as supplementary irrigation. These costs vary across regions

. As shown in Table 2, the alternatives to meth yl bromide for California cut flower production impose significant economic impacts on the grow ers. However, in Florida where iodomethane is available for use in ornamentals, economic impacts of using iodomethane as an alternative to methyl bromide are small.

8 . RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES Table 4. Nomination Amount.

C al if or nia C ut Fl ow er Co mmission F

lo ri da C ut Fl ow er s S ec tor T otal / Av er age Qu an ti ty Re ques ted fo r 2012: Am ou nt (k gs) 46,950 1, 214 48,164 Qu an ti ty Re co mme nde d by MB TO C/ TE

APfo r 2012 : Am ou nt (k gs) 46,950 1, 214 48,164 Am ou nt (k gs) 46,950 1, 214 48,164 Area (ha) 261 61 322 Rate 180 20 150 Tr ans itio n fr om 2 012 Ba se lin e Ad jus te d Val ue Pe rcent age (% ) 0% 0% 0%
Am ou nt (k gs) 

## 46,950 1, 214 48,164 Area (ha) 

### 235 6 241 Rate 

### 200 200 200 Qu an ti ty Approve d by Part ie s fo r 2012:



### Quan tityR eq uire d fo r 2013 N om

ination : OR NA MENTALS SE CTORUSA CUN13 SOIL Ornamentals Open Field and Protected Environments



### CITATIONS Rosskopf, E.N., N. Kokalis

- Burelle, E. Nissen, O. Nissen, R. Hartman, R. McSorley , E. Skvarch, T.J. Swaford, C. Owens, S. Brooks, and K. Register. 2010. Evaluation of currentl y available alternatives to meth yl bromide for ornamental crop prod uction in Florida. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2010/082RosskopfAreawideOrnamenta.pdf Rosskopf, E.N., N. Kokalis

- Burelle, D.M. Butler, J. Holzinger, S. Fennimore. 2010. Evalution of steam for nematode and weed control in cut flower production inFlorida. Proceedings of the Annual International Research Conference on Methyl Bromid e Alternatives and Emissions Reductions. http://mbao.org/2010/083RosskopfSteam.pdf Gerik, JS; CLElmore, ID Greene. 2002. Alternative soil treatments for field grown ornamentals. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2002proc/093gerikj%20mbao_2002.pdf Gerik, James and Dong Wang. 2008 . Control of Agrobacterium tumafaciens with soil fumigants. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2008/110Gerik.pdf Gerik, James. Personal communication via telephone. October 28, 2008. Hanson, B. 2010. Steam Disinfestation as a Methyl Bromide Alternative in California Cut Flower Nurseries. 

### Proceedings of the Annual Internation al Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2010/085HansonBSteamflowernursery .pdf Klose, Susanne; Jim Gerik, Hussein Ajwa, Cheryl Wilen, Mike Mellano. 2008. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2008/029Klose.pdf Kokalis

- Burelle, Nancy ; Erin Rosskopf, Randy Driggers. 2006. Efficacy of Midas for control of Meloidognye incognita on Celosia in Florida. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2006/06Proceedings/112BurelleNMBAOAbstractBurelleetal2006.pdf McSorley , R., Wang, K.H., Church, G. 2004. Fumigant alternatives to methyl bromide for managing nematode s and weeds in snapdragon. Proceedings of Florida State Horticulture Society . 117:334

- 337. National Agricultural Statistics Service (NASS). 2008. Floriculture Crops 2007 Summary

. USDA Sp Cr 6

- 1 (08) http://usda.mannlib.cornell.edu/usda/current/FlorCrop/Fl orCrop

- 04

- 24

- 2008.pdfUSA CUN13 SOIL Ornamentals Open Field and Protected Environments



### Noling, J.W; J.P. Gilreath, E.R. Rosskopf. 2001. Alternatives to methyl bromide field research efforts for nematode control in Florida. Proceedings of the Annual International Research Conference on Meth yl Bromide Alternatives and Em issions Reductions. http://mbao.org/2001proc/014%20Noling%20JW%20MBAO2

- 2001.pdf Rosskopf, Erin; D.O. Chellemi, N. Kokalis

- Burelle, G.T. Church. 2005. Alternatives to methyl bromide: a Florida perspective. APSnet Feature June 2005: http://www.apsnet.org/online/feature/meth yl bromide/ Rosskopf, Erin; Nancy

Kokalis

- Burelle, Rand y Driggers. 2006. Evaluation of Midas for production of ornamental cockscomb in Florida. Proceedings of the Annu al International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2006/06Proceedings/037Rosskopfetalcelosia2006.pdf Rosskopf, Erin; Nancy

Kokalis

- Burelle, and Randy Driggers. 2007 a . Reduced rates and alternatives to meth yl bromide for snapdragon production in Florida. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductio ns. http://mbao.org/2007/Proceedings/106RosskopfEMBAOsnapdragon2007.pdf Rosskopf, EN; JS Gerik, NK Burelle, G Church, R McSorley . 2007 b . Status of methyl bromide altern atives for ornamental crop production in Florida and California. American Phy topathological Society

Annual Meeting. Rosskopf, Erin and Nancy Kokalis

- Burelle. 2008. Area

- wide demonstration of chemical alternatives to meth yl bromide for Florida ornamentals. Proceedings of the Annual International Research Conference on Meth yl Bromide Alternatives and Emissions Reductions. http://mbao.org/2008/028Rosskopf.pdf Segawa, Rand y. 2005. Methods for developing f umigant regulatory

requirements in California. Proceedings of the Annual International Research Conference on Methyl Bromide Alternatives and Emissions Reductions. http://mbao.org/2005/05Proceedings/001%20SegawaR%20mbao_2005_conf_segawa_sum mary .pdf Zinati, Gladis; Herbert Bry an and Merl yn Codallo. 2002. Solarization as a potential approach for recycling wastes for potting media and as an alternative to methyl bromide for field

- grown bedding plants. Proceedings of Florida State Horticulture Society . 115: 123

– 127.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



## APPENDIX A: ORNAMENTAL SPECIES GROWN The very large and con stantly changing number of species and cultivars grown in the ornamentals sector means that compiling a complete list of species and acreage grown is not possible. There are hundreds of t ypes of cut flower, foliage, and bulb crops grown each year and ofte n several species are grown in the same field simultaneously . However, the U.S. has tried to describe the major crops below. Additional information is not available from public or private sources. California APPENDIX B - T ABLE 1 : C ALIFORNIA O RNAMENTALS - P RODUCTION OF M AJOR S PECIES S PECIES # F LOWER B UNCHES IN 2003 Alstroemeria 892,789 Carnations 1,694,870 Delphinium 3,617,186 Gladiolus Data not released Gerbera 62,638,650 Iris 5,823,242 Lilium 6,247,027 Chrysanthemums 1,273,742 Pom pons 6,350,127 Roses 7,360,729 Snapdragons 2,976,219
A PPENDIX B - T ABLE 2 : C ALIFORNIA O RNAMENTALS - P ARTIAL L ISTING AND E STIMATE OF C UT F LOWER AND F OLIAGE A REA P RODUCED IN C ALIFORNIA IN 2002

C ROP A REA ( USUALLY FIELD )
- HA A REA ( USUALLY GREENHOUSE )
- HA Alstroemeria 8 5 Antirrhinum (snapdragon) 126 17

Aster 6 Calla lily 16 Carnation 30 2 Chrysanthemum 88 28 Delphinium 22 Eucalyptus 54 Gerbera 21 Gypsophila 55 Iris (Dutch) 18 Larkspur 6 Lilium 32 21 Limonium spp. 13 Lisianthus 13 Protea 190 Rose 41 12 Stock ( Matthiola ) 26 Wax flower 317 Other 791 6 Greenhouse misc. 70 28 Field misc. 303 Cut greens misc. 389 Total 2609 145 ha 1 Total does not add due to rounding.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



### Florida The only three cut flower species identified by the Fl orida Agricultural Statistics Service are gladioli, lilies and snapdragon. These are assumed to have the highest acreage and they have been identified b y the applicant as using meth yl bromide.
A PPENDIX B T ABLE 3. F LORIDA O RNAMENTALS - C ROP P RODUCTION F OR C ERTAIN C UT F LOWER S PECIES 2 2001 2002 2003 C ROP # OF

PRODUCERS Q UANTITY

SOLD (1000 SPIKES ) 1 # OF

PRODUCERS Q UANTITY

SOLD (1000 SPIKES ) 1 # OF

PRODUCERS Q UANTITY

SOLD (1000 SPIKES ) Gladioli 4 40,331 4 49,581 4 39,444 Snapdragons 5 6,806 4 4,415 4 4,7 57 Lilies 4 3,031 3 2,257

- - 1 Quantity of lilies sold 1000 stems. 2 This table only includes data for growers with sales over $100,000.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



## APPENDIX B: KEY TARGET PESTS The ornamentals industry is complex; therefore, the following list is not comprehen sive but is intended to demonstrate the large number of pests affecting ornamental production and creating a critical need for meth yl bromide in the U.S

. for the 201 3 growing season. TABLE C 1. KEY PESTS Region wh ere methyl bromide use is requested Key disease(s) and weed(s) to

species and, if known, to level of race Specific reasons why me thyl bromide needed ( e.g. Effective herbicide available, but not registered for this crop; mandatory requirement to meet certif ication for disease tolerance; no host resistance for a specific race ) A: California Cut Flowers, Cut Greens and Perennials Verticillium spp., Fusarium spp.,

Pythium spp., Meloidogyne spp., Nutsedge ( Cyperus spp.), Malva spp., Poa spp., and previous crop propagules. Specific pest problems vary by individual crop and variety. The diversity and complexity of the industry, makes it difficult to control all root pathogens and w eeds with currently available pest control methods. Som e methyl bromide alternat ives used for other sectors are not feasible for floriculture due to high cost s, difficulty timing applications to allow intercropping , and regulatory restrictions including township caps and buffer zone r equirements. B: Florida Floriculture Soilborne d iseases, weeds, and

nematodes including Fusarium spp., Rhizoctonia spp., Phytoplithora , Stromatinia, Pythium spp., Erwinia , and most soil nematodes e.g . Meliodogyne spp., and previous crop propagules. Specific pest problems vary by individual c rop and vari ety

. These diseases are common, abundant, and spread via water , exacerbated by Florida’s regions of tropical and sub

- tropical climate s . Due to the complexity of the ornamentals sector, a lternative pest control measures have not been found for all species but research efforts are ongoing

. Iodom ethane is now registered; how ever, other methyl bromide alternatives preliminarily considered effective, such as dimethyl disulfide, are not currently registered for use.USA CUN13 SOIL Ornamentals Open Field and Protected Environments



## APPENDIX C: STATUS OF METHYL BRO MIDE A LTERNATIVES

T ABLE C 1. R

EASON FOR ALTERNATIVES N OT BEING FEASIB LE N AME OF ALTERNATIVE T ECHNICAL AND REGULAT ORY * REASONS FOR THE ALTE RNATIVE NOT BEING FE ASIBLE OR AVAILABLE
1,3

- Dichloropropene (1,3

- D) Technical

Controls nematodes but will not provide adequate control of diseases and weeds at label rates. Regulatory Buffer zones limit its use and township caps in Florida and California further restrict its use in those states

. Mandated plant

- back times can be 1 to 2 w eeks longer with 1,3

- D than with other fumigants

. 1,3

- D is not registered for use in greenhouses.

Chloropicrin Technical

Weed control is poorer than with methyl bromide Control of the entire pest spectrum cann ot be achieved with lower use rates, but there are concerns about phytotoxicity to nearby plantings if greater than 2% chloropicrin is used in a fumigant combination Regulatory There is concern over the real or perceived public exposure to higher rates of chloropicrin, especially in highly populated urban areas, due to increased worker exposure, offsite mo vement, and smells.

Metam sodium Technical

Efficacy data is inconsistent, depending on soil type, moisture content, and temperature. Regulatory M etam sodium is not registered for use in greenhouses.

Iodom ethane Technical

More research needs to be done to understand application and long

- term efficacy issues. Regulatory Iodom ethane is not registered for use in California

. Large buffer zones and lo wer use rates ma y also prevent widespread adoption.

1,3

- D + chloropicrin Technical

This alternative does not control the entire pest spectrum. Regulatory In California, 1,3

- D + chloropicrin is considered one of tthe best currently available alternatives , if label application rates were increased Tow nship caps and buffer zones that exist for the individual chemicals also apply for the combination.

Metam sodium + chloropicrin Technical

This combination does not adequately control nematodes and weeds, an d performance is inconsistent. Regulatory Restrictions and concerns existing for the individual chemicals also apply for the combination. 1,3

- D + metam sodium Technical

Efficacy data is inconsistent. Regulatory Restrictions for the individual chemica ls also apply for the combinations.USA CUN13 SOIL Ornamentals Open Field and Protected Environments

N AME OF ALTERNATIVE T ECHNICAL AND REGULAT ORY * REASONS FOR THE ALTE RNATIVE NOT BEING FE ASIBLE OR AVAILABLE
1,3

- D + chloropicrin + metam sodium Technical

Weed control is incomplete. Regulatory In California, 1,3

- D + chloropicrin is considered the best currently available alternative, if use restrictions, such as township cap s, w ere removed. Restrictions existing for the individual chemicals also apply for the combinations. 1,3

- D + chloropicrin + herbicides Technical

None. Regulatory Restrictions existing for the individual chemicals also apply for combinations.

Dazom et Te chnical:

Dazom et does not control the entire pest spectrum unless in combination with 1,3

- D, chloropicrin, and/or herbicides. Regulatory: Re strictions on 1,3

- D and chloropicrin prevent the use of Dazomet as a methyl bromide alternative.

Metam sodium + cr op rotation Technical

Treatment does not control the entire pest spectrum. Regulatory Restrictions existing for metam sodium also apply to its use in combination with other pest control measures.

Steam Technical

Steam sterilization is not feasible in open field production due to the need to remove the steam piping after application in order to accommodate cultural management practices. In greenhouses, steam has been successfully used in previous decades as a pest control method. Regulatory None. Biological control agents Technical

No biological controls have been developed to cover all of the pests. Regulatory None.
Crop rotation Technical :

Previous crops’ bulbs and corms of ten contaminate the following crop as volunteer w eeds or reservoirs f

or pathogens

. Regulatory None.

Herbicides Technical :

Crop damage may occur from contact with certain herbicides or in the following crop if soil residues remain. Regulatory Restrictions for registered pesticides vary depending on the active ingredie nt(s) and individual product labels.USA CUN13 SOIL Ornamentals Open Field and Protected Environments

N AME OF ALTERNATIVE T ECHNICAL AND REGULAT ORY * REASONS FOR THE ALTE RNATIVE NOT BEING FE ASIBLE OR AVAILABLE

Biofumigation Technica : l

Biofumigation is still largel y in the experimental stages. Specific brassicas as well as specific years yield variable amounts of activity. While this alternative may provide some control, th e control of all target pests is not sufficient. Regulatory : None.

Substrates Technical:

The use of substrates is only technically feasible in greenhouses using benches, Regulatory None.

Dim ethyl disulfide (DMDS) Technical:

Studies are currently b eing conducted to test the efficacy of DMDS in ornamentals under an Experimental Use Permit. Regulatory: DMDS is not currently registered in Florida or California , and its future registration status is not known.

Acrolein Technical:

Studies are currently being conducted to determine the efficacy of acrolein for ornamentals. Regulatory: Acrolein is currently only registered as an aquatic herbicide and cannot be used on soil for this use . Its future registration status is unknown. Propargyl bromide Techni cal:

More research is needed to understand its efficacy as a methyl bromide alternative. Regulatory: This alternative is not currently registered and its future regulatory status is unknown.

Sodium azide Technical:

More research is needed to understand its efficacy. Regulatory: This alternative is not currently registered and its future regulatory status is unknown. Muscador albus Strain QST 20779 Technical:

No commercially available formulation. Regulatory: None.

Ethane dinitrile (Cyanogen) Technica l:

Considered a viable alternative in Australia, no studies have been conducted in the U.S. comparing efficacy with methyl bromide and other alternatives. Regulatory: This product is not currently registered in the U.S. and its future registration status is unknown. Acidic electrolyzed oxidizing (EO) water Technical:

EO w ater only controls foliar fungal diseases in greenhouse ornamentals. No research has been conducted on this product as a pre

- plant pesticide in at least 6 years. Regulatory: There is no commercial development or planned registration of this product currently.USA CUN13 SOIL Ornamentals Open Field and Protected Environments

N AME OF ALTERNATIVE T ECHNICAL AND REGULAT ORY * REASONS FOR THE ALTE RNATIVE NOT BEING FE ASIBLE OR AVAILABLE

Solarization Technical:

Efficacy data is inconsistent betw een research trials. Regional subclimates with significant cloud cover or cooler annual temperatures will not receive enough degrees for solarization to be a feasible pest control option. Regulatory: None.

Furfural Technical:

It does not control the entire pest spectrum. Regulatory: Furfural has a federal registration for ornamentals and non

- food commodities for greenhouse soil use only. However, it does not have state registrations currently, and its future registration status is unknown.. Regulatory reasons include local restrictions (e.g. occupational health and safety, local environmental regulations) and lack of regi stration.