### NOMINATING PARTY: The United States of America

NAME USA CUN12 SOIL TOMATOES Open Field

BRIEF DESCRIPTIVE TITLE OF NOMINATION: Methyl Bromide Critical Use Nomination for Pre-plant Soil Use for Tomato Grown in Open Fields (Submitted in 2010 for 2012 Use Season)

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

QUANTITY OF METHYL BROMIDE REQUESTED:

T ABLE 1: Q UANTITY OF M ETHYL B ROMIDE R EQUESTED IN E ACH Y EAR OF N OMINATION



### Year N OMINATION 

### A MOUNT 

### (K ILOGRAMS 

### )

2012 54,423 kg



### NOMINATING PARTY CONTACT DETAILS:

Contact Person: John Thompson

Title: Division Director

Address: Office of Environmental Policy U.S. Department of State 2201 C Street, N.W. Room 2658 Washington, D.C. 20520

U.S.A. Telephone: (202) 647-9799 Fax: (202) 647-5947 E-mail: thompsonje2@state.gov

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

. . 

### ■ Yes  No

Signature Name Date

Title:

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

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

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



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

USA CUN12 SOIL TOMATOES Open Field Page 1 of 27C ontact/Expert Person: Jack Housenger

Title: Director

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

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

E-mail: Housenger.Jack@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:

1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozone

Secretariat

USA CUN12 SOIL TOMATOES Open Field 27

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

Secretariat

USA CUN12 SOIL TOMATOES Open Field

* Identical to paper documents

USA CUN12 SOIL TOMATOES Open Field Page 2 of 27

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

TOMATOES

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

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

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

The primary fumigant alternativ es for methyl bromide that have shown promise against key tomato pests the spring application of the fumigant combination of 1,3 D, followed by chloropicrin alone, followed by metam-sodium and the newly registered fu migant iodomethane.

Current research has demonstrated that in ma ny cases iodomethane (MI DAS®) formulated with chloropicrin can be an efficacious methyl bromide alternative, however, transition time will be needed for many tomato producers to adapt produc tion to using this material. Growers will need this time to adapt to the use of new applicati on equipment appropriate to the lower flow rates typical with iodomethane, to retr o-fit equipment in order to avoi d corrosion by iodomethane, etc. Increased costs due to using iodomethane are de scribed in the "economic assessment" section

below.

For 2009, crop experts at the Univers ity of Georgia reported that the price of iodomethane went up so dramatically that they di d not advise growers to use the product, despite its good efficacy.

It is not clear whether or not th ese high prices affected other to mato growing regions included in this nomination, or how long the high prices will persist. However, at the very least, this information does suggest that adoption of iodo methane by tomato growers will be significantly affected by price fluctuations. Application 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 dimethyl disulfide (DMDS) indicate that this fumigant is promising. However, preliminary resear ch results from a single year of fumigation in pepper production demonstrate that, as a stand- alone product, the efficacy of DMDS is not comparable to methyl bromide and will require chloropicrin (MacRae and Culpepper, 2008). Treatments with DMDS plus chloropicrin and/or metam-sodium are not significantly different from methyl bromide + chloropicri n. In any case, this fumigant is not registered in the US and

therefore cannot at this time be considered a practical methyl bromide alternative.

USA CUN12 SOIL TOMATOES Open Field Page 3 of 27

### The application of a sequential 3 way fumigant combination, the “Georgia 3 Way” (consisting of 1,3-D, followed by chloropicrin, followed by meta m-sodium or metam-potassium), continues to

be evaluated. It is considered to be useful as a spring applie d fumigant mix in the state of Georgia. It should be noted that a major part of developing a comm ercially feasible protocol to use this system in all regions will require adjust ment of rates and application timing for field and strip applications. Trials eval uating 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 Chellemi (2008) wh ere, in some trials, 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. Weed and nematode control for the “Georgia 3 Way” as compared to methyl bromide were not different. Adding to the slow adoption of this system is the lack of established protocol that will be based on mitigating potential problems such as plant-back timing, soil moisture, and locati on/edaphic variability. The increased production costs, and cost 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 nemat ode 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 re strictions on its 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 i odomethane can be an efficacious methyl bromide alternative, but protocols have not been su fficiently established. Given sufficient time to transition this fumigant can be worked into the production system.

Georgia

The three way fumigant combination (the ‘Georgia 3 Way’) continues to be evaluated, and has proven to be efficacious for spring application in Georgia. However, the lack 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 i odomethane can be an efficacious methyl bromide alternative, but protocols have not been suffi ciently established. Given sufficient time to transition these fumigants can be wo rked into the production system.

Mid-Atlantic

Current research in this region has not been s ubmitted 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

USA CUN12 SOIL TOMATOES Open Field Page 4 of 27

### 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 co mbination continues to be evalua ted in the southeast. In a comment by Craig Anderson of the University of Arkansas, the cool temperatures and wet soils in early spring will extend the plant back timi ng due to the additional time needed for soil fumigant levels to dissipat e to avoid crop injury and s ubsequent yield loss (Toth, 2008)

Preliminary research conducted in states other than those in the s outheast have demonstrated that iodomethane can be an efficacious methyl bromid e alternative, but protocols have not been sufficiently established. Concerns in the southe ast about injury and dela yed planting have lead 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 ALTER NATIVES ARE NOT FEASIBLE

Our review of available research on other met hyl bromide alternatives discussed by MBTOC for tomatoes suggests that, of the registered (i.e., legally available) chemis tries, iodomethane, and combinations of metam sodium, 1,3-D, and/or chloropicrin 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 feasib le. For some areas in the state of Georgia, a 3 way fumigant combination of 1,3 D, followed by chloropicrin alone, followed by metam-sodium, has shown promise against key tomato pests in sp ring season only fumigation. However, the aforementioned fumigant combination has not met w ith success in other area s of the southeast.

The transition rate included in the BUNNIE inco rporates an estimate of projected use of this strategy as well as the use of iodomethane.

Many of the alternatives require the evaluati on of their relationship between fumigant alternatives, various mulches, and herbicide systems under different growing conditions. From this information on-farm protocols can be established.

Alternatives are considered not feasible where: 1) they have not been sufficiently tested or prot ocols have not been su fficiently 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). 6) There are significant restrictions on which crops can be rotated through after use of a given alternative (e.g., halosulfuron has rotational restrictions that pr event its use in southeastern US tomatoes).

USA CUN12 SOIL TOMATOES Open Field Page 5 of 27

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

The US nomination is only for those areas wh ere the alternatives ar e still under extensive evaluation and pest pressure is high. In US toma to production there are seve ral factors that make some of the assumed alternatives, other than iodomethane, unsuitable. These include: 1) Pest control efficacy of a lternatives: the efficacy of alternatives may not be comparable to methyl bromide in some ar eas, making these alternatives technically and/or economically infeasible for use in tomato production. 2) Geographic distribution of key ta rget 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 pressure is moderate to high such as nutsedge in the Southeastern US. 3) Regulatory constraints: e.g., in Florida due to the pres ence of karst topographical

features. 4) In Virginia and much of the mid-Atlantic, high water tables and the close proximity of production areas to environmentally sens itive estuaries makes the use of 1,3-D

limited. 5) Delay in planting and harvesting: e.g., the pl ant-back interval for telone+chloropicrin is two weeks longer than methyl bromide+ chloropicrin. Delays in planting and harvesting result in users missing key market windows, and adversely affect revenues through lower prices. 6) Alternatives that are non selective 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 WH Y METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTER NATIVE STRATEGIES ARE USED TO

CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL

BROMIDE THERE.

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

USA CUN12 SOIL TOMATOES Open Field Page 6 of 27

### 5. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO

COVER AT LEAST PART OF THE CRO P THAT HAS REQUESTED USE OF

METHYL BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE

THIS?

No, areas that use methyl bromide do so because environmental sensitivity and/or heavy pest pressure preclude the use of fumigants that ar e employed when these conditions are not present.

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

Researchers are continuing to evaluate fumigant concentration and mulch interaction using the 3 way fumigation combination and iodomethane (Cul pepper et al, 2007). However, there is still

the need for more research to determine the fu migant rates and mulch combinations needed for pest control and crop safety where there is h eavy pest pressure. In a study by Culpepper (Georgia CUE appendix 2011; see Appendix A for a reproduction of this submission), the 3 way fumigant combination resulted in tomato plant he ights 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 ev en when the soil was allowed to air, but they have seen good results in spring applications. Th is is similar to information provided by growers and university personnel in the southeast (Toth, 2008)

T ABLE 2. T OMATO PLANT YIELDS AND HEIGHT IN RESPONSE TO TIME OF 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 pr eliminary data comparing the 3 fumigant combination, results have demonstrated that methyl bromide and iodomet hane do not significantly differ in efficacy. However variability among results across locations demonstrates th e need for further research (Toth, 2008). An exception to these findings was a study by Chellemi (2008) where pepper plant

USA CUN12 SOIL TOMATOES Open Field Page 7 of 27

### 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. On the other hand, in three of the trials weed and nematode control for the three fumigant combination and methyl bromide were low; less than 0.01 weeds / foot of row and nematode concentration was

less than 1.0 / 100 cc of soil.

TABLE 3. UGA Three FUMIGANT COMB INATION Adjusted Rates 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 likely scenarios based on information from USDA NASS, EPA proprietary data, and/or stakeholder-submitted comments. Table taken from Georgia CUE Appendix; see Appendix A for a reproduction of this submission.



### Tomato growers in Maryland have again reques ted methyl bromide. These growers have historically used methyl bromide in their to mato production, purchasing it from the stockpile since the 2005 ban. Maryland growers, in co mmon with other tomato growers in the midAtlantic region, have production areas with hi gh water tables and in close proximity to environmentally sensitive estuaries; these fact ors make the use of 1,3-D limited, and thus the three fumigant combination cannot be considered as an alternative.

Techniques such as grafting, re sistant rootstocks immune to target fungal pathogens, plant breeding, soil-less culture, organi c production, substrates, plug, ar e not commercially feasible. Availability of such transplants is further hampered by the lack of infrastructure to make grafted tomato plants available on a large scale, concom itant with this is the high premium associated with these transplants at this time. Grafting a nd plant breeding are thus also rendered technically infeasible as methyl bromide alternatives for control of fungal pathogens, nutsedges and nematodes. Grafting of solanaceous plants is re latively new to US growers, and has met with a great deal of concern regarding the potential for the establishment of off-type plants developing

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

pursue.

USA CUN12 SOIL TOMATOES Open Field Page 8 of 27

### 6. SUMMARY OF RECENT RESEARCH

As mentioned earlier in this document, iodomet hane formulated with chloropicrin has shown good efficacy against key tomato pests, including nut sedge, 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 ha d time limitations removed from its federal label in October, 2008, and has re ceived state-level approval in 47 US states (California, Washington, and New York are the exceptions at this time). However, other important

constraints must be considered when assessi ng the feasibility 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 iodometha ne use in the various local production conditions covered by this nominations, and (3) growers and applicators will need to make some equipment modifications to adapt to the lower flow ra tes typical with less expensive iodomethane application rates and to avoid the corrosion of some 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 technically feasible to manage key tomato pests in all parts of the US where it has been registered, 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 downwar d while also considering the time needed to

transition to iodomethane.

Performance data presented by B. Olsen at the November 2008 MBAO conference reported tomato yield data from 12 field sites where th e average increase in yields from iodomethane treated plots over methyl bromide treated plots wa s 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 whet her this reported average increase in yields is significant. Despite these results, representatives of the s outheast tomato growers’ consortia are currently cautious about recommending iodomethane as a methyl bromide replacement (Toth, 2008).

Research conducted in Georgia de monstrated that, in small plot s, purple nutsedge control for methyl bromide, iodomethane, and DMDS we re not significantly different under LDPE, metalized, or VIF mulch (table 4). Yields of pepper and cucumber plants fumigated with

iodomethane under VIF were not different from yields for untreated pl ots (Culpepper et al, 2007). The reader should keep in mind here that DMDS is not registered for use in the USA.

In a study by Chellemi (2008), pepper plant heig ht 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 study, three of the four trials reported weed and nematode control for the three fumigant combinat ion and methyl bromide at less than 0.01 weeds

/ foot of row and nematode concentrati on at less than 1.0 / 100 cc of soil.

USA CUN12 SOIL TOMATOES Open Field Page 9 of 27

### 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.Table taken from Culpepper et al (2007)



### Hausbeck and Cortright (2007) measured cucurb it plant 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 br omide 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 gr own under VIF. It is noteworthy that in this study VIF tarps were prone to wind removal, whic h reduced their reliabil ity under some growing

conditions.

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 days) 280 kg/ha 1.0 a

Methyl bromide+chloropicrin 67:33 under VIF (10 days) 280 kg/ha 2.7 bc

1,3 D + chloropicrin 65:35 under LDPE (21 days) 187 liters/ha 2.3 bc

1,3 D + chloropicrin 65:35 under VIF (21 days) 187 liters/ha 4.7 d

Chloropicrin under LDPE (14 days) 187 liters/ha 2.7 c

Chloropicrin under VIF (14 days) 187 liters/ha 3.3 cd

* Vigor rating of plant health; 1=healthy plants with no stunting, 5= moderated plant stunting with variable stand, 10=complete plant death.

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



### In addition to the limitations of VIF discussed ab ove, the USG notes that the plant vigor in 1,3 D

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

USA CUN12 SOIL TOMATOES Open Field Page 10 of 27USA CUN12 SOIL TOMATOES Open Field Page 11 of 27 

### As far as the USG has been able to determin e, no other studies have been conducted since 2007

to evaluate the technical and commercial feasibil ity of fumigant alternatives to methyl bromide for controlling F. oxysporum subtypes under production conditions relevant to the Maryland/Delaware regions.

7. ECONOMIC FEASIBILITY OF ALTERNATIVES

The following economic analysis is organized by methyl 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 loss es of income that may be suffered by the users.

It should be noted that net revenue does not represent net income to the users. Net income, which indicates profitability of an operation of an enterprise, is gross revenue minus the sum of operating and fixed costs. Net income should be smaller than the net revenue measured in this study. Fixed costs were not included because th ey are often difficult to measure and verify.

Summary of Economic Feasibility

The economic analysis of the tomato applicati on compared data on yields, crop prices, revenues and costs using methyl bromide a nd using alternative pest control regimens in order to estimate the loss of methyl bromide availability. The alte rnatives identified as technically feasible - in cases of low pest infestation 1 

### – for different regions by the U.S. are: (a) iodomethane and (b) 1,3- dichloropropene and chloropicrin foll owed by chloropicrin, followed by metamsodium/potassium (otherwise referr ed to as the Georgia 3-Way).

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

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

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

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

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

### (3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually easy to meas ure, at least over some unit, e.g. , a hectare of land or a storage operation. However, high value commodities or cr ops may provide high revenues but may also entail high costs. Losses of even a small per centage of gross revenues could have important impacts on the profitability of the activity.

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

(5) Operating Profit Margin . We define operating profit ma rgin to be net operating revenue divided by gross revenue per hectare. This measure would provide the best indication of the total impact of the loss of methyl bromide to an enterprise. Again, operating costs may be

difficult to measure and fixed costs even more di fficult, therefore fixed costs were not included in the analysis.

These measures represent different ways to a ssess the economic feasibili ty of methyl bromide alternatives for methyl bromide users, who are tomato producers in this case. Because producers (suppliers) represent an integral part of any defi nition of a market, we in terpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using methyl bromide. The economic measures provide the basis for making that determination.

Eastern US

We conclude that, at present, iodom ethane woul d be the economically feasible alternative to methyl bromide for use in Eastern US tomato production in areas exhib iting karst topographical features. However, see the technical discussion above for a description of reasons why time will be needed for growers to transiti on to routine, commercially feasible iodomethane use. In areas where karst features are not present it appears that tomato growers can use a combination of three fumigants applied sequentially (1,3-D, ch loropicrin, and metam-sodium/potassium) and achieve yields that are comparable to those pr oduced by using methyl bromide for spring crops only. The USG factored this new technique into their 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 spring fumigations.

USA CUN12 SOIL TOMATOES Open Field Page 12 of 27T ABLE 6. V IRGINIA : E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

VIRGINIA TOMATO GROWERS 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 $ 780

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 include fixed costs and net revenue equals gross revenue minus operating costs.

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

MARYLAND TOMATO GROWERS 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 include fixed costs and net revenue equals gross revenue minus operating costs.

Error! Bookmark not defined.

USA CUN12 SOIL TOMATOES Open Field Page 13 of 27T 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 include fixed costs and net revenue equals gross revenue minus operating costs. ** Includes: South-Eastern United States (Alabama, Arkansas, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, and Tennessee).

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 include fixed costs and net revenue equals gross revenue minus operating costs.



### Florida

We conclude that, at present, iodomethane woul d be the economically feasible alternative to methyl bromide for use in Florida tomato produ ction in areas of karst topography. Where karst

USA CUN12 SOIL TOMATOES Open Field Page 14 of 27

### features are not present the USG assumed that th e sequential application of the three chemicals (discussed above) would have results that are si milar to the performance of methyl bromide for spring plantings. Consequently, as described abov e, the transition was adjusted to account for

the new combination

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 $ 34,874

- 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 include fixed costs and net revenue equals gross revenue minus operating 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 include fixed costs and net revenue equals gross revenue minus operating costs.

USA CUN12 SOIL TOMATOES Open Field Page 15 of 27T 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 $ 50,152

- O PERATING C OSTS PER H ECTARE ( US $)* $ 48,230 $ 49,197 $ 48,530

= 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 include fixed costs and net revenue equals gross revenue minus operating 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 $ 50,152

- O PERATING C OSTS PER H ECTARE ( US $)* $ 48,230 $ 49,197 $ 48,530

= 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 include fixed costs and net revenue equals gross revenue minus operating costs.

USA CUN12 SOIL TOMATOES Open Field Page 16 of 27T 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 $ 29,643

- 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 include fixed costs and net revenue equals gross revenue minus operating costs.



### 8. RESULTANT CHANGES TO RE QUESTED EXEMPTION QUANTITIES

The USG has applied an aggressi ve transition rate, which is re flected in the nomination amount

and detailed in Table 15.

TABLE 15. N OMINATION 

### A MOUNT



### .

USA CUN12 SOIL TOMATOES Open Field Page 17 of 27

### CITATIONS

Baldwin, R.E. & C.M. Waldenmaier. 1991. Tr ellis Tomato Fumigation Trial 1991. Eastern Shore Agricultural Experiment Station. VA

Burelle, N.K, E.M. Rosskopf, M.G. Bausher, G. McCollum. Alternative fumigants and grafting for tomato and double-cropped muskme lon production in Florida 2008. Annual

International Research Conference on Me thyl Bromide Alternatives and Emissions Reduction. ( http://www.mbao.org/ )

Burnette, G. 2003. Personal co mmunication, November 25, 2003.

Chellemi, D. O. 2008. Field validation of a fumiga nt alternative. Proc. Annual Int. Res. Conf. on Methyl Bromide Alternatives and Emissi ons Reductions. Available on the web at http://mbao.org/2008/008Chellemi.pdf

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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-operativeagreement SCA # 58-6617-6-013, Executive Summary (1996-2001) submitted to the USEPA.

Chellemi, D.O. & J. Mirusso. 2006. Optimizing Soil Disinfestation Procedures for Fresh Market Tomato and Pepper. Plant Disease vol. 90 n. 5. p. 668-674.

Culpepper, Stanley. 2004. Faculty, University of Georgia, Athens, GA. Comments on methyl bromide Critical use nomination for preplant soil use 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/Publ ications/GFVGA%202007/Culpepper-13.doc

Driver , J.G., and F.J. Louws. 2000. Fumigants a nd varieties to manage s outhern 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 potential as methyl bromide replacemnts for disinfetation of soilborne pests in polyethyl ene-mulched 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 impermeable films in pepper. Crop Prot.

24: 285-287.

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### 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. Weed 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 Complemented with Chloropicrin and

Herbicides in Commercial To mato Farms. Crop Prot. 25:79-82.

Gilreath, J.P. B.M. Santos, C.A. Chase, S. J. Locascio. 2006. Influence of Soil Fumigation on 2,4- D and Dicamba Carryover in Fresh Market Tomato. Crop 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 temperature data submitted to BEAD (OPP, US-EPA) in support of methyl bromide critic al use exemption application.

Hausbeck, M.K. & B.D. Cortright. 2003. Alte rnatives for methyl bromide on cucurbit and Solanaceous crops. Unpublished.

Hausbeck, M.K. & B.D. Cortright. 2004. Eval uation of Fumigants for Managing Phytophthora

Crown and Fruit Rot of Solanaceous a nd Cucurbit Crops; 2004. . Unpublished.

Hausbeck, M. K. and B. D. Cortright. 2007. Comparison 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 w ith Michigan’s CUE package for 2010 (07-0005).

IR-4. 2003. IR-4 Project Annual Report 2003. Available online at http://ir4.rutgers.e du/annreport/report2003.pdf

Jacob, W. C. 1977. Range of mean outside temp erature and rainfall in South-Eastern United

States. Climatic Atlas of the United Stat es. Published by the US Department of

Commerce.

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

Locasio, S.J., Gilreath, J.P., Di ckson, D.W., Kucharek, T.A., Jones, J.P. and Noling, J.W. 1997. Fumigant alternatives to methyl bromide for polyethylene-mulched tomato. HortScience 32(7) 1208-1211.

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### Locasio, S.J. & Dickson, D.W. 2000. Broadcas t 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 alternatives for Verticillium and weed management in tomatoes. North Carolina State University.

Louws, F.J., L.M. Ferguson, N.P. Lynch, & P. B. Shoemaker. 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 fruit yield. Weed Science Technology 11: 672-676.

Minuto, A., A. Garibaldi, and M.L. Lodovica Gu llino. 2003. Chemical Alternatives to Methyl Bromide in Italy: An Update . Proceedings of the MBAO.

Minuto, A. M.L. Gullino, F. Lamberti, T.D’Adda bbo, E. Tescari, H. Ajwa, A. Garibaldi. 2006. Application of an Emulsifiable Mixture of 1,3-Dichloropropene and Chloropicrin Against

Root Knot Nematodes and Soilborne F ungi for Greenhouse 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-inhibi ting herbicides. 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 bromid e for pre-plant soil fu migant in California tomatoes. USDA IR-4 methyl bromide al ternatives program for minor crop. Report submitted to the US-EPA during 2003 in s upport of methyl bromide critical use exemption.

Olsen, B. 2008. Midas soil fumigant 2008. Proc. A nnual Int. Res. Conf. on Methyl Bromide

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

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

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

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the MBAO

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niveum in Commercial Watermelon Fields in Maryland and Delaware . Amer. Phytopath.

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USA CUN12 SOIL TOMATOES Open Field Page 21 of 27

### APPENDIX A

Reproduced from the 2011 Critical Use Exemption Application 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% of the land fumigated for vegetable crops in the spring was treated with the 3-WAY which includes a system s approach of 1,3-dichloropropene, chloropicrin, and metam sodium. It is likely that 30 to 40% of Ge orgia’s total crop will be treated with this alternative during 2008. Dimethyl disulfide (DMDS) plus chlor opicrin 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 deve loped 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 me thyl bromide available is essential.

The two aforementioned fumigant systems also po se significant challenges when determining the time interval needed between fumigating and planting. In itial research results suggest the plant back interval 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 results available by September of 2008. Early indications suggest that the plant back for DMDS plus 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 determining the amount of time that must pass between fumigating with these alternatives and planting.

USA CUN12 SOIL TOMATOES Open Field Page 22 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 alterna tive to methyl bromide during the spring fumigation cycle. However, research is needed to determine if this alternative is effective during the summer/fall fumigation period. Fumigants may be less effectiv e in the summer/fall when compared to the spring because of warmer soils causing increased gas dissipation.

Materials and Methods

An experiment was conducted in TyTy Georgia at th e University of Georiga’s Ponder Farm. The trial was conducted on a Tifton sandy loam soil with 92% sand, 2% silt, and 6% clay w ith a pH of 6.4 and 1% organic matter. Land was prepared by disking the tr ial area multiple times and then roto-tilling a 6 foot wide bed by 60 feet in length for each plot imme diately prior to fumigating and installing mulch.

The study was fumigated during the fall of 2007 on Ju ly 17. Soil temperature was 84 degrees at 8 inches. 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) followe d by chloropicrin (150 lb/A) followed by Vapam (75 gal/A). The Telone II was placed 12 inches deep using 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 was injected 4 inches deep and 4 inches apart using disc blades in the final bed just prior to covering with mu lch. Methyl bromide was applied at 240 lb/A. All 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 four times, once a week for four weeks.

Table 1. Comparing methyl bromide and the 3-Way for 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-W AY system when applied under LDPE or Blockade mulch. Fumigant gas emissions occurred so rapidl y that nutsedge tubers were likely not under a high enough concentration of gases long enough to provide adequate control as is the case in the spring. Methyl bromide was far more effective with nearly tw ice the level of control noted with the 3-WAY even under blockade mulch. As expected, yields followed tr ends in nutsedge control since it was the only pest 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 yi eld was improved with the 3-WAY applied under

USA CUN12 SOIL TOMATOES Open Field Page 23 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 methyl 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 effec tive fumigant system must be developed.

USA CUN12 SOIL TOMATOES Open Field Page 24 of 27

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

Introduction

The UGA 3-WAY system is replacing methyl bromide rapi dly in Georgia. Although this system has been effective during the spring, the progr am has the potential to delay planting after fumigation. Research is

needed to determine the time in terval needed between fumigati on and planting vegetable crops.

Materials and Methods

An experiment was conducted in Tifton Georgia at the 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 disk ing the trial area multiple times and then roto-tilling a 6 foot wide bed by 20 feet in length for each plot immediately prior to fumigating and installing mulch.

The study was fumigated during the spring of 2007 on Fe bruary 27. Soil temperature was 59 degrees at 8 inches. The experiment consisted of 12 treatments (Tab le 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 inches deep using a Yetter system having 3 injection knives on a 32 inch bed top, chloropicrin was placed 8 inches deep with a super bedder using 3 injection 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 only applied in the bed. Mulch used included low densit y polyethylene or Blockade high barrier. Crops were planted 7 or 14 days after fumigating while poking th e plant hole through the mulch. Crops were also planted on days 8 or 15 which was 1 day after poking the hole on days 7 and 14 in an attempt to air the bed. Crops planted included tomato, pepper and cucumber.

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

Table 1. Plant heights in response to time of planting 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

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### 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

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### Table 2 . Plant yields in response to time of planting 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 w ith any treatment at 3 wk after transplanting (data not shown). When planting 7 days after fumiga ting with the 3-WAY under LDPE mulch, crop heights were reduced at least 20% when compared to the me thyl bromide control (Table 1). Growth reduction from the 3-WAY under Blockade mulch was far greate r and ranged from 60 to 80%. Airing the bed for one day did not alleviate stunting. Waiting 14 da ys after fumigating before planting did alleviate fumigant stunting when crops were planted on the LDPE mulch. However, significant reduction in plant growth was still noted when planting into the blockade mulch. Airing the bed for 1 d did not eliminate crop stunting when planting on the blockade mulch.

Tomato and cucumber were resilient in overcomi ng early season reduction in plant growth with only minor trends for reduced yields when planted on LDPE mulch, when compared to the methyl bromide control. Yield reductions were noted with tomato when planted on Blockade mulch at 7 or 8 d after fumigating. Pepper tended to be more sensitive than other crops with lower yields or a trend for lower yields when planting on both mu lches at each planting date except for the 15 day plant date on LDPE

mulch.

Results and Discussion

This research is the first step in determining the tim e interval needed between fumigating and planting. The most effective tactic will likely not be days af ter 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 pp m should be in the bed at time of planting.