## Summary of the US EPA Analysis

of the Methyl Bromide Critical Use Exemption f or Use in 2015

APPLICA N TS

CUE 00 15: CA Dried Plum Board

CUE 00 30 : CA Walnut Commission



### MBTOC REQUESTED DATA:
MBTOC: data must be provided to demonstrate that supplemental heater cannot be used to increase the efficacy of SF MBTOC: after 10 years, efforts must have been made to prevent re

- infestation in storage or ability to use something other than MBr



### EPA ANALYSIS : Technical:
Insufficient evidence to estimate number of facilities with high pest pressure

Insufficient evid ence to estimate loss of commodity due to pests Walnut applicant supplied ambient low temperatures during winter, but not warehouse/commodity

temperature. New pest feeds on mold, and requires high relative humidity to survive

-- occurrence indicates

sanitati on problem, not need for MBr. Stored product pests not active at temperatures near 55 ° F; in fact, USDA recommends storage at

55 ° F or below for insect & pathogen prevention. No evidence that fumigation at these temperatures

is critical.

Data indicate S ulfuryl F luoride (SF) effective against key pests. Low temperature data demonstrate lack of performance on pest eggs (esp. dried fruit beetle (DFB); but storage/harvest temperatures not provided. Also variable results in studies. Applicants told MBTOC during Fall 2010 conference call that 90+% of industry had transitioned to SF because MBr was either too expensive or unavailable.


### Economic ( Walnut Example ) 

### :
S F treatment for a facility is $ 4,000 less than MeBr SF treatment plus he at is $ 4,000 more expensive than MeBr (due to cost of equipment) despite the fact that the cost of the heat is somewhat offset by the reduced need for sulfuryl fluoride A yearly program with 2 SF treatments added to 1 SF treatment plus heat is ~ $ 4,000 le ss than 3 treatments of MeBr per year Net revenue for fumigated quantities is over $440 million dollars per year so cost difference is

0.00 % of gross revenue ( less than 1/100 th of a percent)

. 

### Regulatory Constraints:
None; SF registered for these uses.



### Em issions:
Reduction of number of fumigations indicative of reducing emissions 

### Market Disruption:
No evidence to demonstrate market disruption.



### Synopsis of Alternatives Sulfuryl Fluoride (SF) Works well on post

- embryonic life stages; matches MBr at higher temperatures; egg kill reducedat lower temperatures, esp. for dried fruit beetle and carob moth ; extended exposure time can

significantly reduce concentration ; increase temperature can reduce concentration; combination of time, temperature & co ncentration. No significant cost difference (activities & material cost ) similar or less than MBr

C ommodities in storage do not have time constraints Currently registered for these uses (Proposed regulatory actions published in 2011 and 2012; no

Final Rule) Phosphine (PH 3 ) Needs more time than MBr or SF; some stored product pests resistant; needs much less gas than

MBr Because of time constraint not an option at peak harvest; but for storage is an option Stored commodities should not require a rapid tu rn

- around time Cheaper than MBr, but to accommodate through

- put during harvest , more fumigation chambers required (10

- 15x more) No regulatory constraints Propylene Oxide Very effective on insect eggs More expensive Regulatory constraints: maximum volume i s 10,000 ft 3 , commodity must be heated to 100 ° F

Table 1. Analysis of transition to alternatives for walnuts (m etric )

. Methyl Bromide Sulfuryl Fluoride Phosp h ine Cubic meters to be treated (example) 7,450 7,450 7,450 Total gas needed for fumigation (kg) 179 239 30 Price of fumigant ($/kg) 39.68 11.02 9.37 Total cost of fumigant gas ($) 7,103 2,631 280

Cost difference between MBr & alternative ($) --- ( 4,472 ) (6,824)

Assumes rate of 24 g/cu m for MeBr, 32 g/cu m for SF, 4 g/cu m for PH 3 )

. Temperatures at harvest are fairly high so rates should be similar

.



### EPA CONCLUSION : Dried fruit (dried plums, figs, raisins, and walnuts ) in storage not critical. The i ndustry has mostly converted to SF, and no market disruption has occurred . Time is not critical in storage therefore, product treated with SF or PH 3 

### can be held for re latively long periods of time with o ut impacting industry and SF or PH 3 

### can be used

.

OTHER CONSTRAINTS
Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions requesting the cancellation of tolerances for Sulfuryl Fluoride

. USEPA is currently addressing public comment related to a proposed rule to grant the stay of tolerances. The Proposed Order granting objections to toleranc es for Sulfuryl Fluoride was published. No Final Rule has been published.



### REFERENCES: Stored Product Protection. 2012. Eds: DW Hagstrum, TW Phillips, and G Cuperus. K

- State Research

and Extension. http://www.ksre.ksu.edu/bookstore/pubs/S156.pdf Several Chapters including but limited

to:Burks, CS, and JA Johnson. Biology, behavior, and ecology of stored fruit and nut insects. Chapter

3, p 21

- 31. Arthur, FH and B Subramanyam. Chemical C ontrol in Stored Products. Chapter 9, p. 95

- 100.

Barakat, D. A., D. Klementz, and C. Reichmuth, 2009. Response of Eggs of Corcyra cephalonica towards Sulfuryl Fluoride . Presentation at 2009 MBAO, Nov. 10

- 12, 2009, San Diego, CA.

Available online at: http://mbao.org/2009/061Reichmuth.pdf

. Burks, Charles S. and L.P.S. Kuenen. 2011. Monitoring Indianmeal moth in the p resence of mating disruption. Presentation at the 2011 Annual International Research Conference on Methyl Bromide Alternatives, San Diego, CA, Oct 31

- Nov 2, 2011. Available at: http://mbao.org/2011/59Burks. pdf

. Emekci, Mevlut (55) 2010. The efficacy of sulfuryl f luoride against egg stage of the dried fruit b eetle.

Presentation at 2010 MBAO, Nov. 1

- 5, 2010 , Orlan do, Fl. Available at: http://mbao.org/2010/55Emeki.pdf

. Ferizli, Guray (56) 2010. Does sulfuryl fluoride and h eat combination overcome the egg weakness of

almond m oth? P resentation at 2010 MBAO, Nov. 1

- 5, 2010 , Orlando, Fl. Available at: http://mbao.org/2010/56Ferizli.pdf

. Hosoda, Ed. 2009. California ProFume Update, 2009. Presentation at 2009 MBAO, Nov. 10

- 12, 2009, San Diego, CA. Available online at: http://mbao.org/2009/069Hosada.pdf

. Hosoda, Ed. 2008. Eco2Fume® an d VaporPH3OS®. Presentation at 2008 MBAO, Nov. 11

- 14, 2008, Orlando, Fl. Available at: http://mbao.org/2008/125Hosoda.pdf Johnson, Judy . 2012. High Temperature CO2 Treatments for i nshell w alnuts . 2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations number 37 available at: http://mbao.org/

. Liu, Yong

- Biao. 2011. Potential of oxygenated phosphine fumigation for postharvest pest control. Presentation at the 2011 Annual International Research Conference on Methyl Bromide Alternatives, San Diego, CA, Oct 31

- Nov 2, 2011. Available online at: http://mbao.org/2011/53Liu.pdf

. Muhareb, Jeannette. 2009. Evaluation of Combining Sulfuryl Fluoride, Propylene Oxide & CO2 for

Stored Product Insect Control . Presentation at 2009 MBAO, Nov. 10

- 12, 2009, San Diego, CA.

Available online at: http://mbao.org/2009/064Muhareb.pdf

. Russo, C., Green, R.D. & Howitt, R.E. “Estimation of Supply and Demand Elasticities of California

Co mmodities”. Department of Agricultural and Resource Economics University of California, Davis, Working Paper No. 08

- 001, June 2008. Walse, S. 2011. Postharvest Fumigation Research at USDA

- ARS

- SJVASC

. Presentation at 2011 MBAO, Oct.31

- Nov 2, 20 11 , San Di ego, CA. Available online at: http://mbao.org/2011/68Walse.pdf Walse, Spencer, J.G. Leesch, and S. Tebbets. 2009. Ovicidal Efficacy of Sulfuryl Fluoride to Stored

Product Pests of Dried Fruits . USDA/ARS, San Joaquin Valley Agricultural Sciences Center, Parlier, CA 93648. Presentation at 2009 MBAO, Nov. 10

- 12, 2009, San Diego, CA. Available

online at: http:// mbao.org/2009/060Walse.pdf

. Walse, Spencer

. 2012. (52)

- Postharvest Fumigation Research at USDA

- ARS .2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations number 52 available at: http://mbao.org/

. Williams, Robert. 2009. Control of Carob Moth ( Ectomyelosis ceratonia ) in Fresh Dates Fumigated with

ProFume® . Presentation at 2009 MBAO, Nov. 10

- 12, 2009, San Diego, CA. Available online at: http://mbao.org/200 9/063Williams.pdf

. Williams, R. and E. Thoms. 2008. ProFume® gas fumigant update: post

- harvest commercial acceptance and performance in North America. Presentation at 2008 MBAO, Nov. 11

- 14, 2008, Orlando, Fl.

Available at: http://mbao.org/2008/084Thoms.pdf

### APPLICA N TS

CUE 00 59: CA Date Commission



### MBTOC REQUESTED DATA:
MBTOC: data must be provided to demonstrate that supplemental heater cannot be used to increase the efficacy of S ulfuryl F louride (SF)



### EPA ANALYSIS : Technical:
Data indicate SF effective against most key pests. However, data demonstrate lack of performance on pest eggs (esp. dried fruit beetle (DFB) and carob moth) which may be present throughout

harvest.

Dates harvested and sent to market within 3 days; longer fumigation time results in loss of quality.

Data to quantify this loss would be helpful in defending this to MBTOC.


### Economic:
The price of MBr is about 3.5 times more expensive than SF by pound. Even at higher application rates, SF would be less expensive than MBr 

### Regulatory Constraints:
None; SF registered for these uses. 

### Active Research Program: Presentations by Dr. Spencer Walse USDA/ARS at MBAO

Emissions:
Reduction of number of fumigations indicative of reducing emissions 

### Market Disruption:

Without MBr fresh dates cannot be delivered to market

.



### Synopsis of Alternatives Sulfuryl Fluoride (SF) Works well on post

- embryonic life stages and match es MBr at higher temperatures;

Insufficient for DFB and carob moth e gg k ill ; extended exposure time cannot accommodate

harvest to market timeframe No significant cost difference (activities & material cost ) similar or less than MBr

C urrently registered for this use (Proposed regulatory actions published in 2011 and 2012; no Final Rule) Phosphine (PH 3 ) Needs more time than MBr or SF; some stored product pests resistant; needs much less gas than

MBr

Because of time constraint (PH 3 takes more time than MBR) not an option during harvest to
market timefram e ; but for storage /processed dates is an option No regulatory constraints Propylene Oxide Not registered for dates. Very effective on insect eggs More expensive Regulatory constraints: maximum volume is 10,000 ft 3 , commodity must be heated to 100 ° FEconomic Analysis of transition to SF for dates treated with MBr ( metric )

. Methyl Bromide Sulfuryl Fluoride Cubic meters to be treated (example) 15,500 15,500 Total gas needed for fumigation (kg) 310 310 Price of fumigant ($/kg) 39.68 11.02 Total cost of fumigant gas ($) 12,316 3,421 Cost difference between MBr & alternative ($)

--- (8,892)

Assumes rate of 1.25 lb/1,000 cu ft (20 g/cu m) for both MBr and SF.

Because t emperatures at harvest, rates should be equivalent.



### EPA CONCLUSION :
MBr remains critical for fresh ly harvested dates , which the industry is trying to get to market in 3 days

. DFB and carob moth eggs coul d be present on these harvested dates and studies by Walse show that SF does not kill the eggs of these pests in the time needed at legal concen trations

.

OTHER CONSTRAINTS
Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions requesting the cancellation of tolerances for Sulfuryl Fluoride

. USEPA is currently addressing public comment related to a proposed rule to grant the stay of tolerances. The Proposed Order granting objections to tolerances for Sulfuryl Fluoride was published. No Final Rule has been published.



### REFERENCES: Kadar, AA and AM Hussein. 2009. Harvesting and postharvest handling of dates. I nternational Center for Agricultural Research in the Dry Areas. Available at: http://postharvest.ucdavis.edu/files/71533.pdf

.

Nay, JE and TM Perring. 2008. Influence of host plant stages o n carob moth (Lepidoptera:Pyralidae) development and fitness. Environ. Entomol. 37(2):568

- 574.

Park, J

- J and TM Perring. 2010. Development of a binominal sampling plan for the carob moth (Lepidoptera: Pyralidae), a pest of California dates. J. Econ. Entomol. 103(4):1474

- 1482.

Vetter, RS, S Tatevossian, and TC Baker. 1997. Reproductive behavior of the female carob moth (Lepidoptera: Pyralidae). Pan

- Pacific Entomologist 73(1):28

- 35.

Walse, Spencer

. 2012. Postharvest Fumigation Research at USDA

- ARS . 2012 MBAO, Orlando, Florida,

November 6

- 8, 2013. Presentation number 52 available at: http://mbao.org/

.

Yahia , EM. 2004. Date. USDA

- ARS

- Ag Handbook #66: Commercial Storage of Fruits, Vegetables, and Florist and Nursery Stocks. Available at: http://www.ba.ars.usda.gov/hb66/059date.pdf

. Accessed: Augus t 13, 2012.

### APPLICA N TS

CUE 0023 : U.S. Rice Federation

CUE 0027 : Pet Food Institute (PFI)

CUE 00 31 : North American Millers’ Association (NAMA)



### MBTOC REQUESTED DATA:

D ata must be provided to demonstrate that supplemental heat cannot be used to increase the efficacy of Sulfuryl Fluoride (SF)

N ew, specific, and detailed data showing that IPM and heat is not effective for pet food establishments is required



### EPA ANALYSIS

Technical:
Published data demonstrates not statistically significant difference between MBR and SF or heat treatments. Insufficient evidence to estimate number of facilities with high pest pressure

Insufficient evidence to estimate loss of product due to pests

Insufficient evidence that alternatives are not effective Economic thresholds need to be determined for each pest


### Economic:
Cost of alternatives generally less than cost of methyl bromide (except for heat alone); even for heat alone in first year cost is ~ 1% of net revenue Cost of heat plus SF similar to cost of SF alone; added cost of heat largely offset by reduced use of SF 

### Regulatory:
No regulatory constraints: SF is still registered for these sites.



### A ctive Research:

Presentations at 2012 MBAO demonstrated research at rice mills

Emissions:
Reduction of fumigations indicative of emissions reduction 

### Market Disruption:

Insufficient evidence of significant market disruption



### Synopsis of Alternatives

Sulfu ryl Fluoride (SF):
Effective for pests in these structures and commodities Highly effective on post

- embryonic insects, but egg kill requires increased dosage, increased te mperature,
increase d time of exposure , and/or combination

. Comparative Product Performance studies

– no statistical difference between SF & M e Br

. Majority of fumigations take place from end of May to early September. No significant difference in costs ; SF is much less per pound and increased concentration at lower temperatures does not result in higher costs. Currently registered



### Heat: Technically feasible and effective for some structures, but not appropriate for many wooden structures Several comparative performance studies indicate no statistical difference between heat and M e Br Small reductions in net revenue are possible and more likely in smaller mills when considering the cost of investment in equipment.* No regulatory c onstraints



### SF + Heat:May be an option for some producers



### Microsanitation:
Mechanical control technique that is labor intensive;

M ay have potential for replacing disinfestation but research has not been published IPM strategies, including use of insecticides/fogging may be used to manage stored product pests

* Based on economic analysis from CUN for 2013



### OTHER CONSTRAINTS and CONSIDERATIONS
Fluoride Action Network, Environmental Work Group, and Beyond Pesticides have petitions requesting the cancellation of tolerances for Sulfuryl Fluoride

. The Proposed Order granting objec tions to tolerances for Sulfuryl Fluoride was published. No Final Rule has been published.



### EPA CONCLUSION : SF is currently registered for these facilities. H eat is also ava ilable for this industry. SF is cost effective.

T here is no evidence that MBr is a critical need in this industry.



### REFERENCES: Adam, B. D., Bonjour, E. L., & Criswell, J. T. (2010). Cost Comparison of Methyl Bromide and Sulfuryl Fluoride (ProFume®) for Fumigating Food Processing Facilities, Warehouses, and Cocoa Beans. 10 th
International Working Conference on Stored Product Protection, 27 June

- 2 July 2010, Portugal, Estoril Congress Center. Available at http://pub.jki.bund.de/index.php/JKA/article/vi ewFile/495/446 . Accessed July 19, 2010.

Arthur, F. H., A. E. Sutton, K. Y. Zhu, and J. F. Campbell. 2010. Residual efficacy of pyrethrin

- methoprene aerosols on packaging surfaces. Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/64Arthur.pdf

. Arthur, Frank H., L. Ted Wilson, Yubin Yang, James F. Campbell, Tanja McKay, Brian Adam, and Thomas E.
Reagan. 2011a. Insect pest management in rice mills. Presentation at the 2011 Annual International
Research Conference on Methyl Bromide Alternatives, San Diego, CA, Oct 31

- Nov 2, 2011. Available at:
http://mbao.org/2011/57Arthur%201.pdf

. Arthur, F. H., J. F. Campbell, E. A. Fontenot. 2011b. Efficacy of Insecticide Treatments on Resident Populations
of the Red Flour Beetle. Presentation at the 2011 Annual International Research Conference on Methyl
Bromide Alternatives, San Diego, CA, Oct 31

- Nov 2, 2011. Available at:
http://mbao.org/2011/58Arthur%202.pdf

. Arthur, FH and EA Fontenot. 2012.Residual activity of methoprene and novaluron as surface treatments to manage the flour beetles, Tribolium castaneum and Tribolium con fusum . Journal of Insect Science 12:95

Available at: http://www.insectscience.org/12.95

. Beckett, S. J., Fields, P. G., & Subramanyam, Bh. (2007). Disinfestation of Stored Products and Associated
Structures Using Heat. In J. Tang, E. Mitcham, S. Wang, & S. Lurie (Eds.), Heat Treatments for
Postharvest Pest Control Theory and Practice (pp. 182

- 237). CABI International, Wallingford, UK.

[online] Available at http://home.cc.umanitoba.ca/~fieldspg/fields/heat

- rev.pdf

. Accessed July 15, 2010.
Brijwani, M., B.Subramanyam, M. Hartzer, D. E. Maier, W. Chayaprasert, S. Savoldelli , P. Flinn, and J. Campbell. 2009. Efficacy of structural heat treatments against Tribolium castaneum life stages. Presentation at Methyl Bromide Alternatives Outlook Conference, San Diego, November 2009. Available

at: http://mbao.org/2009/066Brijwani.pdf

.Campbell, JF. 2010. Impact of structural fumigation on pest populations in food processing facilities.

Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/63Campbell.pdf

. Campbell, James 2012. Evaluating Structural Fumigation Efficacy in Rice Mills . Presentation 42, 2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations availa ble at: http://mbao.org/

. Campbell, James . 2012.

- Spatial Pattern in Aerosol Insecticide Deposition in a Flour Mill . Presentation 43, 2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations available at: http://mbao.org/

. Hartzer, M. Subramanyam, B., Brijwani, M., Chayaprasert, W., and Maier, D. E. 2010. Methyl bromide, sulfuryl fluoride and heat: effectiveness against red flour beetle. Presentation at MBAO, Nov. 2

- 5, 2010, Orlando,

Fl. Available at: http://mbao.org/2010/67Hartzer.pdf

. Hartzer, M., B. Subramanyam, W. Chayaprasert, D. E. Maier, and S. Savoldelli. 2009. Methyl Bromide and Sulfuryl Fluoride Effectiveness Again st Red Flour Beetle Life Stages. Presentation at Methyl Bromide Alternatives Outlook Conference, San Diego, November 2009. Available at: http://mbao.org/2009/072Hartzer.pdf

. Holcomb, M. and M. McLean. 2010. An IPM approach to methyl bromide replacement: in pet food processing plants and warehouses. Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/65Holcomb.pdf

. Hor n, P., Horn, F. and Rogers, M. 2010 Automated structural fumigations with phosphine using the Horn Diluphos System. Presentation at MBAO, Nov. 2

- 5, 2010, Orlando, Fl. Available at: http://mbao.org/2010/06 6HornP.pdf

. Kenkel, P., & Holcomb, R. 2004. Flour Milling Feasibility Template. Oklahoma State University. [online]

Available at : agecon.okstate.edu/coops/files/ flour _milling_template_4

- 5

- 2004.xls. Accessed July 13, 2010.
McKay, Tanja 2012. Integrated Insect Pest Management in Rice Mills

. Presentation 41, 2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations available at: http://mbao.org/

. Ranville, M. and Cook, C. 2011. Assessment of Impacts on Fl our Mill Operators of a Stay in Sulfuryl Fluoride
Food Tolerances. U.S. Environmental Protection Agency.
Stored Product Protection. 2012. Eds: DW Hagstrum, TW Phillips, and G Cuperus. K

- State Research and

Extension. http://www.ksre.ksu.edu/bookstore/pubs/S156.pdf Several Chapters including but limited to: Mahroof, RM and DW Hagstrum. Biology, behavior, and ecology of insects in processed commodities. Chapter 4, p. 33

- 43. Campbell, JF, J Perez

- Mendoza, and J Weier. Insect Pest Mangement Decisions in Food Processing Facilities. Chapter 19, p. 219

- 232. Adam, BD and C Alexander. Economics of IPM Decisions. Chapter 28, p. 317

- 325. Walse, Spencer . 2012. Postharvest Fumigation Research at USDA

- ARS

. Presentation 52, 2012 MBAO, Orlando, Florida, November 6

- 8, 2013. Presentations available at: http://mbao.org/

.

### APPLICANTS

CUE 0033: Gwaltney

- Smithfield CUE 0057: National Country Ham Association

CUE 0075: Nahunta CUE 0076: American Association of Meat Producers



### MBTOC REQUESTED DATA:
Evidence must be provided to demonstrate that facilities have improved gas tightness Evidence must be provided to demonstrate all efforts to reduce frequency of fumigations have been made by facility

“Fuller” nomination



### EPA ANALYSIS:

Technical

Evidenc e provided demonstrate that neither sulfuryl fluoride (SF) nor phosphine (PH 3 ) are effective in reducing mites Evidence provided indicates producers with high pest pressure

Economic No technically feasible alternative identified; therefore, no economic analysis conducted Regulatory Constraints:
None; no alternatives identified

. Active Research Program Presentations by Dr Wes Schilling & Dr. Tom Phillips at MBAO Very active research program investigating chemical and non

- chemical means of control

Proces sors very cooperative with researchers and eager to participate in studies

Emissions Reduction Reduction of number of fumigations may be indicative of reducing emissions Market Disruption: Without MBr this type of ham would not be available for consumers.



### SYNOPSIS OF ALTERNATIVES: Sulfuryl Fluoride: Currently registered and effective for ham skippers & red

- legged ham beetles

Does not control mites at l abel rates , even in the laboratory Phosphine: Is effective for ham skippers & red

- legged ham beetles Laboratory studies indicate control of mites; Field studies have not provided control of mites. Much corrosion of metals (copper, silver, and their alloys) occurred during trials, resulting in substantial costs for replacements.



### OTHER CONSTRAINTS a nd CONSIDERATIONS
Country hams are premium product and pest damage is not acceptable to consumers

. Temperatures and humidity for appropriate aging of country hams must be maintained and are also ideal for pest survival.



### EPA CONCLUSION:

EPA concludes a strong and defensible case for this sector based on the following:

o No technically feasible alternative has been identified to control mites

o No IPM strategy has been identified to control mites

o Very active research program, with support from producers

### APPLICA N T

C U E 0 0 0 4 : M i c h i g a n Tomato

, C U E 0005 : M i c h i g a n Cucurbits

, C U E 0061 : M i c h i g a n Pepper

, C U E 0062 : M i c h i g a n Eggplant



### E PA ANALYSIS

No one alternative wa s deemed to be effective for all pest problems but a review of multiple year data

indicated that the alternatives in various combinations provide control equal or superior to methyl bromide plus chloropicrin. Applicant would need to provide summarized mul tiple year data to show yield or economic impacts. Qualitative descriptions of impacts alone are not sufficient. Insufficient information to estimate percent of acres with high pest pressure. Qualitative descriptions of the failures of alternatives need to contain more detailed information on crop, alternative tested, minimum or maximum label rate used, and type of negative impact (e.g. yield loss, phytotoxicity, poor pest control, etc.). Insufficient information has been provided to demonstrate that fa ll fumigation is not feasible because of deer and rodent damage to tarps and drip lines. Not clear why this issue cannot be mitigated in other ways, or how many acres are affected.



### Synopsis of Alternatives
1,3

- D ichloropropene + chloropicrin or 1,3

- D + chloropicrin + metam sodium Several research studies show this can effectively suppress soilborne diseases and nematodes. This includes the key pathogens cited by MI ( P. capsici

, F. oxysporum ) (Hausbeck and Glaspie 2010)

. MI claims this alternative causes a 14 day plantback delay in cold spring soils. Economic impact analysis summarized below. Fall fumigation is recommended by MSU and could alleviate plantback delay regardless of the fumigant used

. DMDS + chloropicrin

Re search trials in Michigan (Hausbeck and Glaspie 2010) and the southeastern U.S. (Freeman and McAvoy 2011) indicate acceptable yield/quality with this alternative. Rates can be reduced under TIF tarps, according to new research

. DMDS should be tested in ea rly season MI application scenario to provide yield /quality data. Data has not been provided on plantback delays compared to MeBr plus chloropicrin under cool

soil conditions. Fluopicolide

A registered fungicide that is effective on P. capsici and registered for drip application use on vegetable crops. Could improve pathogen control beyond that provided by fumigation alone. Resistance could be a problem with this fungicide (Lu et al. 2011), but apparently this has not occurred in Michigan as yet.

Non

- fumigant alternatives: Anaerobic soil disinfestation (ASD), cover crops (Brassicas, hairy vetch) Research work suggests t hese alternatives could provide control for specific fields and growers facing relatively low pest pressure

.



### ECONOMIC ANALYSIS
EPA estimates a loss in gross revenue of about 9

- 11%, which is offset by significantly lower fumigant costs resulting in a loss as a percent of gross revenue of about 3%. See the tables below. These estimates

are based on: cost data f

rom the CUE application, seasonal tomato and cucumber prices, 6% yield loss, and 7 day planting delay

.Early production of fresh vegetables provides a niche market offering premium prices with fresh produce

scarcity for a limited time. The high input costs are offset by high prices they receive during this early production phase. Data from statistical sou rces do not fully show higher or lower prices but only average prices received for a crop. EPA considered the price data from Ngouajio, Rebekah and Ron 2011.



### Table 1. Michigan vegetable price information from different sources, Ngouajio et al 2011 data used.

Crop Source of Data Early

Season

Price Later

Season

Price Percent

D ecrease
Tomato CUE application $15.50 $11.35 27%

Tomato (Ngouajio, Struck, and Goldy, 2011)*** $18.00 $13.00 28%

Cucumber USDA NASS monthly prices $29.77 $21.97 26%

Cucumber Receipts from MI growers, average $12.25 $7.46 39%

Cucumber (Ngouajio, Struck, and Goldy, 2011)*** $24.00 $15.00 38% ***Ngouajio Mathieu, Struck Rebekah, and Goldy Ron. 2011.

Table 2. Estimated economic impact on Michigan tomatoes from the use of alternatives.



### Michigan Tomatoes

CUE# 12

- 04 Methyl

Bromide 1,3

- D +

Pic Georgia

3 Way DMDS

Yield 25 lb boxes per acre 1,525 1434 1525 1525

% Yield Loss 0% 6% 0% 0%
Plant Delay days compared to baseline 0 7 7 7 Price per 25 lb box

First Week after Early Harvest 10% of yield $18.00

2nd Week 10% of yield $16.00 $16.00 $16.00 $16.00

3rd Week 10% of yield $14.00 $14.00 $14.00 $14.00

Rest of Season $13.00 $13.00 $13.00 $13.00
Weighted Average Price per 25 lb box $13.90 $13.40 $13.40 $13.40

Gross Revenue per acre $21,198 $19,209 $20,435 $20,435

Loss $1,989 $763 $763

% of Gross Revenue 9.4% 3.6% 3.6%

Metric

Yield Loss (%) 0% 6% 0% 0%

Yield Kg per Hectare 42,732 40,168 42,732 42,732

× Average Price per Kg (us$) $1.23 $1.18 $1.18 $1.18

= Gross Revenue per Hectare (us$) $52,380 $47,466 $50,496 $50,496

% loss of gross revenue 9.4% 3.6% 3.6%

- Ope rating Costs per Hectare (us$) $43,167 $39,712 $42,667 $41,624

= Net Revenue per Hectare (us$) $9,213 $7,754 $7,829 $8,872

Five Loss Measures

1. Loss per Hectare (us$) $0 $1,459 $1,384 $342

2. Loss per Kilogram of Methyl Bromide (us$) $0 $8.14 $7.72 $1.90

3. Loss as a Percentage of Gross Revenue (%) 0% 2.8% 2.6% 0.7%

4. Loss as a Percentage of Net Operating Revenue (%) 0% 16% 15% 4%

5. Operating Profit Margin (%) 18% 16% 16% 18%

### Table 3. Estimated economic impact on Michigan cucumber from the use of alternatives.
Michigan Cucumbers

CUE# 12

- 05 Methyl

Bromide 1,3

- D +

Pic Georgia

3 Way DMDS

Yield crate (1 1/9 bushel = 55 lb) per acre 733 689 733 733

% Yield Loss 0% 6% 0% 0%
Plant Delay days compared to baseline 0 7 7 7 Early Season (3 weeks)

% of Yield 30% 20% 20% 20%
Price per 55 lb crate $24.00 $24.00 $24.00 $24.00

Rest of Season

% of Yield 70% 80% 80% 80%
Price per 55 lb crate $15.00 $15.00 $15.00 $15.00
Weighted Average Price per crate $17.70 $16.80 $16.80 $16.80

Gross Revenue per acre $12,981 $11,582 $12,321 $12,321

Loss $1,399 $660 $660

% of Gross Revenue 10.8% 5.1% 5.1%

Metric

Yield Loss (%) 0% 6% 0% 0%

Yield Kg per Hectare 45,212 42,499 45,212 45,212

× Average Price per Kg (us$) $0.71 $0.67 $0.67 $0.67

= Gross Revenue per Hectare (us$) $32,077 $28,619 $30,446 $30,446

% loss of gross revenue 10.8% 5.1% 5.1%

- Ope rating Costs per Hectare (us$) $32,496 $30,143 $32,441 $31,399

= Net Revenue per Hectare (us$) ($419) ($1,524) ($1,995) ($953)

Five Loss Measures

1. Loss per Hectare (us$) $0 $1,105 $1,577 $534

2. Loss per Kilogram of Methyl Bromide (us$) $0 $7.04 $10.05 $3.40

3. Loss as a Percentage of Gross Revenue (%) 0% 3.4% 4.9% 1.7%

4. Loss as a Percentage of Net Operating Revenue (%) 0%

- 264%

- 377%

- 128%

5. Operating Profit Margin (%)

- 1%

- 5%

- 7%

- 3%



### REFERENCES Freeman, J. and T. McAvoy. 2011 Reduced rates of dimethyl disulfide in combination with t otally impermeable film mulch. Proceedings of the 13 th 

### Methyl Bromide Alternatives Outreach

Conference. Available online at: http://www.mbao.org/2011/Proceedings/35FreemanJDMDSTIF.pdf

. Granke, L.L., Hausbeck, M.K. & Cortright, B.D. 2009. Methyl bromide alternatives for control of Phytophthora crown and root rot of summer squash, 2008. Plant Dis. Mgmt. R e p or ts. 3:V014. Hausbeck, M.K. and S.L. Glaspie. 2010. Evaluation of fumigants for control of P hytophthora cro wn and root rot on summer squash, 2009 . Plant Dis. Mgmt. R e p orts. 4 :V0 55

. Lu, X.H., Hausbeck, M.K., Liu, X.L., & Hao, J.J. 2011. Wild type sensitivity and mutation analysis for resistance risk to fluopicolide in Phytophthotra capsici. Plant Dis. 95:1535

- 1541. Ngouajio M., S. Rebekah, and G. Ron. 2011. Low Tunnels for Early Vegetable Production and High Profits, Michigan State University. Available online at: http://glvwg.ag.ohio

state.edu/documents/LowTunnelPresentationNgouajio.pdf

### APPLICA N T :

CUE: 0024 California Strawberry Commission



### APPLICANT ASSERTIONS
Township caps on 1,3

- dichloropropene (1,3

- D) prevent its use on some of the requested acres Emergence of Macrophomina and Fusarium in some locations where 1,3

- D drip applications have been

used for a few seasons

CSC estimate d a 5% yield loss when diseases emerge in production fields using drip

- applied 1,3

- D Infested acres that affect production are estimated by CSC to range from 2

- 10% depending on pathogen and production region CSC submitted a transition plan



### E PA ANALYSIS : Macrophomina and Fusarium have been most commonly recovered from Santa Barbara ( Macrophomina ), Ventura ( Macrophomina and Fusarium ) and Orange ( Macrophomina ) counties

In 2010 and 2011, Macrophomina and Fusarium were detected for the first time in the central coast production region (Monterey and Santa Cruz counties)



### o According to Koike et al. (2012), “virtually all of these plant collapse situations involve fields that have switched from methyl bromide + chloropicrin to alternative fumigant products and bed fumigation practices.” ( http://www.calstrawberry.com/fileData/docs/Koike_2010_11_mac.pdf )

I nformation was not available regarding the efficacy of broadcast treatments of 1, 3

- D/chloropicrin in

California



### o Gordon et al. (2012) found that inadequate distribution of dripped fumigant r esulted in significant

differences in Fusarium populations in locations within the bed
( http://www.calstrawberry.com/fileData/docs/Gordon_2010_11_Mac_Fus.pdf 2012 

### )

o I n Florida, 1,3

- D/chloropicrin distribution even with two drip tapes were inferior to shank applications ( http://www.mbao.org/2012/Proceedings/27NolingJ%20AreaWide%202012.pdf 

### )
Acreage within townships over the cap for 1,3

- D would be eligible for CUE methyl bromide



### o Broadcast 1,3

- D may increase impact of township versus drip applications



### ECONOMIC ANALYSIS:
Where there are restrictions on use of alternatives (e.g., township caps) or lack of efficacy (e.g., unmanageable diseases), losses can be as high as

- 37% of net revenue

W here alternatives have been used they have generally been effective at preventing yie ld losses and, therefore, there would not appear to be losses from transitioning to alternatives



### o Economic returns with alternatives are at least as high as with MeBr

— this is because the alternatives are less expensive



### OTHER CONSTRAINTS and CONSIDERATIONS

Some acres appear to be affected by township restrictions on the use of 1,3

- D. Chloropicrin is a feasible alternative to MeBr where permits have been granted. 

### The California Department of Pesticide Regulation (Cal DPR) is currently reviewing the registra tion of chloropicrin and 1,3

- D and should announce its recommendations in early 2013. Based on the Cal DPR review the use of conditions for chloropicrin and 1,3

- D (e.g. buffers, reentry intervals, tarps, use rate, etc.) could change before 2015. In addit ion, the 1,3

- D review could lead to changes in how the 1,3

- D township caps are calculated.

E PA CONCLUSION:

### The CUE nomination for MeBr was for production areas where 1) 1,3

- D is limited by township caps

,

2 ) where a transition period is needed for the use of broadcast 100% chloropicrin, or 3) where Macrophomina and Fusarium have not been acceptably controlled with alternative fumigant methods. There is an expectation that there will continue to be a reduced critical need for MeBr in the near future as advances are made 1) in safely applying 100% chloropicrin, 2) in strategies to improve efficacy in applying 1,3

- D, and 3) in transitioning from experimental to commercial use of

non

- chemical tools, such as stea m, anaerobic soil disinfestations, and substrate production.

### APPLICA N T :

CUE 0034: California Strawberry Nursery Association



### E PA ANALYSIS : If 1,3

- D township caps are restrictive the applicant should document those areas or townships impacted. A Special Local Need (SLN) label for Telone II allows dual application of 1,3

- D as described in NIPM

#7

, Schedule C, Chart I

 This SLN allows for the use of Telone II at the rates defined in Schedules B, C, or D using a dual application method in accordance with the Regulations for the Nursery Stock Nematode Control Program, California Code of Regulations (CCR) Title 3 Sections 3055 to 3055.6 and 3640.

 Label was approved 8/28/2012 and is effective until 7/21/2017
( http://www.cdms.net/ldat/ld02E006.pdf 

### ) Growers could use a combination of methyl bromide for quarantine situations and 1,3

- D plus chloropicrin for non

- quarantine situations to meet certification requi rements.

ECONOMIC ANALYSIS:

No information was submitted concerning actual losses or market disruption.



### OTHER CONSTRAINTS and CONSIDERATIONS Requested 47 acres should be clearly defined to support critical designation. Nursery stock must receive

cert ification for stock to be sold.



### E PA CONCLUSION : It was not possible to determine a critical need for MeBr for strawberry nurseries based on lack of feasible

al ternatives or market disruption. Telone label allows its use in accordance with NIPM #7 certification

standards.

### APPLICA N T :

CUE 00 35: California Association of Nurseries and Garden Centers



### E PA ANALYSIS : If 1,3

- D township caps are restrictive the applicant should document those areas or townships impacted. A Special Local Need (SLN) label for Telone II allows dual application of 1,3

- D as described in NIPM #7

 This SLN allows for the use of Telone II at the rates defined in Schedules B, C, or D using a dual application method in accordance with the Regulation s for the Nursery Stock Nematode Control Program, California Code of Regulations (CCR) Title 3 Sections 3055 to 3055.6 and 3640.

 Label was approved 8/28/2012 and is effective until 7/21/2017
( http://www.cdms.net/ldat/ld02E006.pdf 

### ) Growers could use a combination of methyl bromide for quarantine situations and 1,3

- D plus chloropicrin for non

- quarantine situations to meet certification requirements.

ECONOMIC ANALYSIS:

No information was submi tted concerning actual losses or market disruption.



### OTHER CONSTRAINTS and CONSIDERATIONS Requested 30 acres should be clearly defined to support critical designation. Nursery stock must receive

certification for stock to be sold.



### E PA CONCLUSION :
It was not possible to determine a critical need for MeBr for tree nurseries based on lack of feasible

al ternatives or market disruption. Telone label allows its use in accordance with NIPM #7 certification

standards.

### APPLICA N TS :

C UE 0013 : California Grape & Tree Fr uit League

— Stone Fruit replant

C UE 0014: California Grape & Tree Fruit League

— Raisin and Table Grape replant

C UE 004 3 : Almond Hullers and Process ors Association

— Almond replant

C UE 0029: California Walnut Commission & Walnut Marketing Board

— Walnut replant



### APPLICANT ASSERTIONS

1. Township caps on 1,3

- D prevent its use on some acres

2. Soil moisture requirements (<12%) reduce use of 1,3

- D on some acres (use of 1,3

- D @ 330 lb/A) + chloropicrin (170 lb/A) is effective, except where moisture is >12%)

3. VOC rules limit applications in San Joaquin Valley to unfavorable soil temperature after November 1 (MB is more forgiving in colder soils)

4. Almond and walnut have shifted to MB application to individual holes to replace dead trees in recently established orchards; applicants stated that no other fumigant can be used due to inability of rigs to maneuver within an existing orchard in a small are a.

a. Browne (email statement 12

- 12

- 2012) stated that 5’ injection of 1,3

- D for tree replacement in individual holes “...would make the treatment undesirable and perhaps ineffective unless a large diameter auger or backhoe lowers bulk density of soil around i njection. A 3’ requirement seems ok, but still rather deep, assuming efficient equipment has been developed to inject it.”

5. Primary pests are nematodes and replant problem and alternatives to MB are generally not effective for requested sites

6. Armillaria ro t is a pest of almond, grape, and stone fruit production and requires MB in infested orchard locations (estimated to infest 2

- 5% of replant sites)



### E PA ANALYSIS

If 1,3

- D township caps are restrictive the applicant should document those areas or townships impacted.
Alternatives are very effective for most conditions; clay soils with high moisture may be mitigated with deep ripping so that many sites can effectively use 1,3

- D (e.g., Caprile and McKenry, 2007; http://cemerced.ucdavis.edu/newsletters/October_200723186.pdf )



###  Description of particular conditions and identify land area (s) where alternatives are not

effective We have received no data substantiating lack of efficacy if 1,3

- D is used in compliance with VOC regulations

 Growers may fumigate in suboptimal soil temperatures to use higher rainfall to meet soil moisture requirements and due to VOC regulations

— although impact on efficacy is unknown (see Beede et al.,

2012

-- http://www.mbao.org/2012/Proceedings/63BeedeB.pdf 

### )

 Beede et al. (2012, see link above) stated that Pacific Areawide studies indicate that TIF may help solve

emissions issue



### Research wi th s ingle hole treatment to replace individual trees in an established orchard did not appear to warrant a critical need for methyl bromide

 Lacked a description and accounting for the actual acreage requesting critical use of MB

o There was some impression that MB might only be used if cost is lower, thus suggesting that MB is preferred, but not necessarily critical

 If technical aspects prevent the use of alternative treatments for individual tree replacement, provide a description of technical aspects and l imitations of, for example, 5 ft injection of alternative (e.g., 1,3

- D).

o It was not made clear why 5 ft injection cannot be done (versus is not being done)

o Detailed d escription of technical difficulties of deep injection (e.g., MB protocol for Armillaria

calls for injection to 3 ft

— that should be technically feasible ? Why not 5 ft? ) Both chloropicrin and 1,3

- D are labeled for application to individual holes for replacement of trees in

existing orchards

o Applications stated that rigs for alternatives canno t maneuver in fewer than 2

- acre areas

o Description should be provided describing the technical aspects of MB vs. alternative application

under these conditions

 Numerous published reports indicate efficacy for spot treatments. These results, if not applicab le to the critical need for MB, need to be addressed

o Browne (2011) found adequate (although not optimal) control of Prunus Replant Disease with spot fumigation at tree sites ( 

### http://mbao.org/2011 /Proceedings/32BrowneG.pdf )

o Browne (2009) found that preplant spot treatments have “maintained very good tree growth with large savings in fumigant, compared to strip and broadcast treatments” ( http://www.mbao.org/2009/Proceedings/033BrowneGmbao2009fin.pdf )

o 1,3

- D/chloropicrin or chloropicrin is as effective or more effective than MB against nematodes and replant problem ac cording to data of trials from several seasons (see Beede et al., 2012

-- http://www.mbao.org/2012/Proceedings/63BeedeB.pdf ; Browne et al., 2012

-- http://www.mbao.org/2012/Proceedings/19BrowneG.pdf ; Jhala et al., 2012

— Pest Management

Science 668:225

- 230, http://onlinelibrary.wiley.com/doi/10.1002/ps.2249/pdf )

o “It seems clear that for the most prevalent replant problems [replant disease and nematodes] combinations of alternative fumigants and horticultural practices have effectively replaced MB.” (Beede et al., 2012

-- http://www.mbao.org/2012/Proceedings/63BeedeB.pdf )

o For almond/stone fruit, “Chloropicrin and mixtures of it with 1,3

- dichloropropene (i.e., Telone C35, Pic

- clor 60)... prevent PRD [Prunus replant disease] and often do so more effectively than
MB or 1,3

- dichloropropene (Telone II) alone.” (Browne et al., 2011; http://mbao.org/2011/Proceedings/32BrowneG.pdf )

o For walnut: “The untreated plots remain highest in lesion numbers, and the Tel one II plus chloropicrin plot remains the lowest.” (Beede et al., 2011; http://mbao.org/2011/Proceedings/22BeedeB.pdf )

o Pacific Area

- Wide Project (Almonds/stone fruit) found significantly greater y ields with chloropicrin, 1,3

- D/chloropicrin, and PicClor 60 as compared to MB (Browne, 2011 MBAO presentation)

o Steam technology is in development for individual hole treatment; it may be effective, but appears to require further evaluation (e.g., Hanson et al., 2011; http://ucanr.edu/blogs/UCDWeedScience/blogfiles/5828.pdf )

o In University of California trials supported by the Almond Board of California, spot fumigation

treatments of chlor opicrin using the irrigation system installed for the replant trees was effective in preventing replant disease (Almond Board website, 

### http://www.almondboard.com/Growers/orchardmanagement/PestManagement/Fumigatio n/Pages/default.aspx ) 

### We have no data substantiating losses caused by Armillaria with alternative treatments compared to methyl bromide

 Will require supporting data and descripti on of impact :

o To indicate that MB ameliorates the disease for certain defined areas where Armillaria is known

to be severe and where orchards have contended with Armillaria infestation

— and ideally, compare to areas where alternatives have been used unsucce ssfully where Armillaria infestation

was severe

 Extension information indicates that eradication of Armillaria is rarely achieved with any fumigant (e.g., http://www.ipm.ucdavis.edu/PMG/r60210081 1.html )

o Describe conditions where MB is critical and has led to successful orchard replant in infested areas, whereas use of alternatives have resulted in failure Chloropicrin, metam

- sodium (forms MITC), and sodium tetrathiocarbanate (Enzone®) (forms carb on

disulfide) are registered and, for example, are recommended by UC Pest Management Guidelines against Armillaria (e.g., http://www.ipm.ucdavis.edu/PMG/r602100811.html ; http://www.ipm.ucdavis.edu/PMG/r302100811.html )

o Required description of registered alternatives and if registered alternatives are not effective, supporting information that MB will prevent adverse impact s



### ECONOMIC ANALYSIS Description and supporting information addressing the following:

 The available data show that alternatives to methyl bromide are available and effective.

 Numerous field trials indicate a lternatives to methyl bromide are effective, there fore, there would not appear to be substantial losses from transitioning to the alternatives

.

 When the alternatives are as effective as m ethyl b romide, the economic returns with alternatives are at least as high as with methyl bromide

— this is because the alternatives are less expensive than methyl

bromide.

 Research from 2011 MBAO indicates significant economic return and higher yields with 1,3

- D/chloropicrin compared to MB. For example

, for almond “The ranking from most efficient to least efficient by fumigant is the same for the strip, strip plus tarp, and broadcast treatments with Telone II the most efficient and Methyl Bromide the least efficient for each category of treatments.” In peaches, highest income and greatest yield was from 1, 3

- D/pic (Telone C35) strip treatment (Klonsky, 2011;
http://mbao.org/2011/Proceedings/23KlonskyK.pdf )

 If yields with 1,3

- D and chloropicrin are equal to those with MB, then the present value of the returns to the orchard with these alternatives are estimated to be at least as high as with MB. Although the available research does not substantiate yield losses with the alternatives, if yields with alternatives were lower, the losses could be large . The estimates are based on the UC Davis crop and return studies, using the estimates of costs for methyl bromide and the alternatives from the CUE applications.



### E PA CONCLUSION It was not possible to determine a critical need for MB for orchard replant based on lack of feasible alternatives or market disruption:

In spite of assertions of impacts from township caps on 1,3

- D, townships have not been

identified that are affected by restrictions on 1,3

- D use

. Published research show that for the most preval ent replant problems (Prunus replant disease and parasitic nematodes) combinations of alternative fumigants and cultural practices have effectively replaced methyl bromide (Browne et al., 2012; Wang et al., 2010; Beede et al., 2012). Registered alternative s are available for individual

- hole treatments . For example, in University of California trials supported by the Almond Board of California, spot fumigation treatments of chloropicrin using the irrigation system installed for the replant trees was effecti ve in preventing replant disease (Almond Board website

, http://www.almondboard.com/Growers/orchardmanagement/PestManagement/Fumigation/Pages/def ault.aspx 

### ). Soil preparation procedures are available to enable effective treatment with alternatives even in soils with high moisture content (Caprile and McKenry, 2007

, http://cemerced.ucdavis.edu/newsletters/October_200723186.pdf 

### ) The economic returns with alternatives are at least as high as with methyl bromide

— this is because the alternatives are less expensive than methyl bromide. For example, significant

### economic r eturns and higher yields were reported with 1,3

- D/chloropicrin compared to MB

(e.g., Klonsky et al., 2011).

No data ha ve been submitted substantiating losses experienced due to Armillaria rot with the best, registered alternative control methods compared to methyl bromide. Replant in soils

infested with Armillaria is not ideal under any circumstance. While methyl bromide has been a treatment for infested soils, fumigants (including methyl bromide) are not eradicative, although they may provide suppressi on in a limited treatment area. Where orchards must be planted in infested soils recommended, cultural practices, rootstock selection, soil preparation, herbicides, fallow/cover crops, and chloropicrin and other soil treatments, have been recommended by U C Pest Management Guidelines, and others.

### APPLICA N T

CUE 0018 : California Cut Flower Commission

CUE 0078 : Florida Cut Flower



### E PA ANALYSIS
No one alternative is deemed to be effective for all pest problems but a review of multiple year data indicated that the alternatives provide equal or superior control to methyl bromide plus chloropicrin. Applicant would need to provide summarized multiple year data to show yield or economic impacts. Qualitative descriptions of impacts

alone are not su fficient

. Insufficient information to estimate perc ent of acres with high pest pressure. Regulatory impacts would need to be clearly defined and compared to the current methyl bromide plus chloropicrin label restrictions. Qualitative descriptions of the failures of alternatives need to contain informati on on crop or ornamental species, alternative tested, minimum or maximum label rate used , and type of negative impact (e.g. yield loss, phytotoxicity, poor pest control, etc.).



### Synopsis of Alternatives 1,3

- dichloropropene (Telone) plus Chloropicrin

Research demonstrates excellent results. High rates of 1,3

- D alone under VIF can provide pathogen and weed control equal to MeBr:Pic (Jhala 2012). PicChlor 60 Calla lily yields and pathogen control equivalent to MeBr:Pic (Gerik 2012b).
Economic analysis indicates that for CA calla lilly and ranunculus there was not loss as a percent of gross revenue. For FL there was no loss data provided. Price is lower than MeBr:chloropicrin.
Suitable for use in areas without karst topography. 

### 1,3

- dichloropropene (Telone) plus Chloropicrin plus Metam sodium (e.g. In

- Line plus Vapam, In

Line followed by kPam)
Research demonstrates excellent results. Applicant listed Vallad (MBAO 2010) yield equal to MeBr:Pic in

tomato. Calla lilies stand not impacted by pathogens b y Pythium control better than Fusarium control, Inline better than PicChlor and KPam improved disease control (Gerik 2012a) Weed, pathogen, and ranunculus bulb yield better than MeBr:Pic when drip applied. Gladiolus

- most alternatives equivalent to MeB r:Pic for yield and Fusarium. (Gerik 2012b).
Economic analysis indicates that for CA there was not loss as a percent of gross revenue. For FL there was no loss as a percent of gross revenue. Price is lower than MeBr:chloropicrin.

Suitable for use in area s without karst topography. Dimethyl Disulfide (DMDS) plus Chloropicrin (Paladin TM ) Research demonstrates excellent results. Yields equal to MeBr:Pic but Fusarium control not as effective. Applicant sent tomato data where yield equal to MeBr:Pic but her bicide needed (Vallad 2010).
Nematode control equal to MeBr:Pic in FL (Kokalis

- Burelle 2012). Gladiolus

- DMDS equivalent to MeBr:Pic for yield and Fusarium. (Gerik 2012b)
Insufficient multiple year data to conduct economic analysis but low yield loss should lead to a low economic impact.
Registered in FL but not CA. Can be used in areas of karst topography
Effective alternative that requires TIF type plastic tarps because of odor issues. Anaerobic Soil Disinfestation (ASD)
Research demonstrates good results, more pests and pathogens need to be tested. Nematode and weed control equal to MeBr:Pic in FL (Kokalis

- Burelle 2012).
Only preliminary data available for CA or FL. Ornamental yield equal to MeBr:Pic in FL (Kokalis

- Burelle2012). Insufficient multiple year data to conduct economic analysis but low yield loss should lead to a low

economic impact.
No regulatory constraints

- could be part of an organic program.



### ECONOMIC ANALYSIS Economic considerations in fumigant selection d oes not make a compelling case for a critical need, i.e., if MeBr is available, but not used because of lack of funds, yet the course continues to operate, there is a suggestion that MeBr may be desirable, but not critical to the operation.



### ECONOMIC IMPACT (LOSSES) California Economic Analysis for Calla Lily and Ranunculus

Florida Economic Analysis for Lilies

### REFERENCES

Gerik, J.S., S. R. Dangi, H. Ajwa. 2012 a . Calla lily production with methyl bromide alternatives Year 2. 

### Methyl

Bromide Alternatives Outreach Conference. Gerik, J.S., S.R. Dangi, H. Ajwa. 2012b. Technology Transfer Methods for Adoption of Methyl Bromide Alternatives in California Cut Flower and Bulb Crops

. 

### Methyl Bromide Alternatives Outreach

Conference. Holzinger, J. 2 012. Letter stating methyl bromide is critical for flower production in Florida. Email sent from Erin Rosskopf of USDA on Dec. 10, 2012. Jhala, A.J., S

. Gao, J

. S

. Gerik, R

. Qin and B

. D Hanson . 2012 Effects of surface treatments and application shank s on nematode, pathogen and weed control with 1,3

- dichloropropene. Pest Manag Sci 2012; 68: 225

– 230

Kokalis

- Burelle, N. and E. N. Rosskopf. 2012. Alternatives to methyl bromide for nematode control in ornamental

crops. 

### Methyl Bromide Alternatives Outr each Conference.
Rainbolt, C.M. B.D. Hanson, S.A. Fennimore, and J.S. Gerik . 2010

. Steam disinfestation as a methyl bromide

alternative in California cut flower nurseries

. 

### Reference cited by applicant. Methyl Bromide Alternatives

Outreach Conference. Rosskopf, E.N ., N. Kokalis

- Burelle, E. and O. Nissen, B. Hartman, E. Skvarch, R

. McSorley, T.J. Swaford, S

. Brooks

, K

. Register, C . Owens . E valuation of currently available alternatives to methyl bromide for ornamental crop production in Florida . Availa ble online at http://mbao.org/2010/Proceedings/082RosskopfAAWP.pdf
Vallad, G., A.W. 

### MacRae, T. Jacoby, and J. W. Noling

. 

### MBAO 2010. Sustainability of Methyl Bromide

Alternatives

– Tomato and Pepper Initial Crop , Reference cited by applicant. Methyl Bromide

Alternatives Outreach Conference.

### APPLICA N T : Golf Course Superintendents Association of America (CUE 12

- 0055)



### E PA ANALYSIS
To substantiate a critical need, a description of industry standard(s) must indicate that either the entire golf industry requires MeBr for acceptable turf after reconstruction , or only a portion of the reconstruction projects

per year use MeBr

. If only a portion require MeBr it is unclear how that portion is determined

. Data must provide a clear and consistent picture of critical needs

 Worksheet 2

- B states that <0.04% of total golf course acreage requires fumigation, with 3 acres per facility on average that are fumigated out of a total of 1,504,210 acres of maintained turfgrass

o This calculates to 200 facilities ( x 3 acres/facility =600 acres, therefore, 0.04%) claimed to have a critical need for MeBr, yet u sage data submitted for MeBr indicates that an average of 79 facilities per year use MeBr

o If critical needs for MeBr are for 200 facilities, data must be able to support that request, and the data appea r to give inconsistent needs

— a clear description must be presented

 Worksheet 2

- C states that there a re a total of 16,052 facilities. T he 200 facilities that have requested

MeBr , therefore, make up 1.25% of the total.

o If a course reconstruction lasts for 2 0 years, is it correct to assume that approximately 800 reconstruction projects might be required per year (16,052/20)?

o 20 years is significantly longer than other applicants have claimed for MeBr efficacy. Does

GCSAA have data to substantiate this durati on fo r efficacy ?

o If this is a correct assumption, why do 200 facilities require MeBr as critical, whereas the other

600 facilities do not ? If this is not a correct calculation, please explain. Again, data show that an average of 79 facilities used MeBr

.

o If reconstruction lasts fewer than 20 years, presumably even more facilities would require fumigation per year . What methods are used in facilities that do not use MeBr? If the entire industry considers MeBr as critical, supporting data must be presente d, such as usage data showing that MeBr is the only option available and alternatives (such as dazomet, metam

- sodium, etc.) have not been successfully used , such that turf is unacceptable for play and cause adverse economic impacts

. If only a portion of the industry has a critical need for MeBr (as suggested in the usage data submitted

— i.e., ~79 facilities per year fumigate with MeBr ) then a description with supporting data should be presented to

differentiate those cases where MeBr is critical to maintai n the course, and the majority of construction

situations where non

- MeBr methods are used successfully

. Aspects to c onsider in an application might include, for example :

 Since it appears that the major pest s are off

- type grasses (as indicated in the application)

, state how many facilities on average per year would undergo some type of construction, resurfacing, or renovation that would require herbicidal treatment (fumigant and/or herbicide) ?

 What portion of total construction projects ha s a critical need for MeBr annually and what are the specific problems?

 Of the facil i ties that do not require MeBr to successfully maintain their businesses , why can they use

alternatives that are unavailable to the critical needs facilities ?

 If not all projects use MeBr, w hat do the other projects use or do ?

For example, are there differences in pest issues, climate conditions, playing seasons, topography, etc. that would account for the need for MeBr in some facilities, but not others. This s hould be clearly described.



### ECONOMIC ANALYSIS

A n economist familiar with golf course operations and the golf industry may be able to provide a description of the important economic aspects that need to be addressed.Economic considerations in fumigant selection does not make a compelling case for a critical need, i.e., if

MeBr is available, but not used because of lack of funds

, yet the course continues to operate, there is a suggestion that MeBr may be desirable, but not critical to the operation. For the golf industry, a “yield loss” might be described as increased downtime, or loss of business due to the course being shutdown during construction. An application might describe and provide support for any extenuating factors that applicant would want to be

considered. Economic aspects of golf course operations may be different from many sectors that apply for CUE nominations. For example, farm crop yield losses have been clearly defined and examples are fa miliar

, whereas losses associated with golf course operations may not be obvious. In addition, “downtime loss” is an important variable in golf course impact analysis, but may not be a familiar concept to the Parties. According to our analysis, however, the cost differences between MeBr and the alternatives are insignificant compared to downtime costs. Regarding the notion of yield loss, perhaps one might think of the number of rounds played or the number of memberships per year as the annual “production ” of a golf course, which can be valued at the market price of $xx per 18

- hole round. If the data were presented regarding the number of rounds played, on courses treated with and without MeBr, the estimation of the economic loss caused by the unavailabil ity of MeBr might be feasible. Supporting evidence might be included that would demonstrate that pest pressure (e.g., off

- type grasses) causes golfers reduce playing time or play at a different course, thus creating market disruption for an individual course that is included in the application

This might include, for example, reduced or cancelled membership from affected courses Supporting evidence might be included that would demonstrate that alternatives lead to more frequent resurfacing and therefore, greater adverse economic impacts.

Quantitative, rather than qualitative, informa tion should be provided. Analysis based on t he data provided by GCSAA indicate s that the cost differences between MeBr and the alternatives do not significantly contribute to the economic impact, compared to the

downtime losses

. The application might inclu de sufficient evidence that would demonstrate that alternatives lead to more frequent resurfacing ; again, this should be quantitative data
As mentioned above, the interpretation of the economic impact analysis depends on understanding the unique features ( e.g., downtime) of golf course operations, which may not be obvious to everyone

.



### E PA CONCLUSION More than 10 years after the CUE process began, the Parties demand robust and data

- supported nominations. The GCSAA has indicated that they are committed to providing data and other information regarding their industry to best describe and support their request for a CUE for MeBr. While the U.S. Government declined to put forward the GCSAA request for 2015, any subsequent requests will be thoroughly evaluate d.



### REFERENCES
Chellemi, D.; B. Unruh, J. Mirusso, No date provided . Evaluation of soil fumigant retention under various solid tarp application methods. No source listed by applicant

. Clark. M. 2005. Gas and grass. Methyl bromide helps Troon G& CC get great greens fast. Golf Course Management. January 2005. Davis, D.J. 2002. Gas and grass. An olde Florida course made new. Golf Course Management. January 2002. Teuton, T.C., J.B. Unruh, B.J. Brecke, G.L. Miller, and T.C. Mueller. 2005. Hybri d Bermudagrass (Cynodon dactylon (L.) Pers. × C. transvaalensis Burtt

- Davy) Control with Glyphosate and Fluazifo p. Applied Turfgrass Science. J anuary 19, 2005. Unruh, J.B., B.J. Brecke, J.A. Dusky, J.S. Godbehere. 2002. Fumigant alternatives for methyl bromide p rior to turfgrass establishment. Weed Technology, 2002. 16:379

- 387.Unruh, B. 2005. Banned in the U.S.A. Grounds Maintenance.

Walker, R

. (108). 2008.

- Basamid + Eptam: Replacement for Methyl Bromide in Warm

- Season Sod Production. Methyl Bromi de Alternatives Outreach Program

. Walker, R.H. (35) 2007. Replacements for Methyl Bromide in a Centipedegrass

- Based Sod Rotation System. Methyl Bromide Alternatives Outreach Program

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