USA CUN13 SOIL Eggplant Grow n in Open F ields Page 1 of 16 NOMINATING PARTY : The United States of America FILE NAME : USA CUN 1 3 SOIL EGGPLANT GROWN IN OPEN FIELDS BRIEF DESCRIPTIVE TI TLE OF NOMINATION : Methy l Bromide Critical Use Nomination for Pre

- plant Soil Use for Eggplants Grown in Open Fields ( Submitted in 201 1 for 20 1 3 Use Season) CROP NAME (OPEN FIEL D OR PROTECTED): Pre
- plant Soil Use for Eggplant Grown in Open Field s QUANTITY OF METHYL B ROMIDE REQUESTED IN EACH YEAR OF NOMINATION: T ABLE 1 : Q UANTITY OF M ETHYL B ROMIDE REQUESTED IN E ACH Y EAR OF N OMIN ATION

Y EAR N OMINATION A MOUNT 20 1 3 1,381 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. 2 0520 U.S.A. Telephone: (202) 647

- 9799 Fax: (202) 647

- 5947 E
- ma il: thompsonje2@state.gov Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that th e specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this use would result in a significant market disruption. ■ Yes  No

Signature Nam e Date Title: (Details on this page are requested under Decision Ex. I/4(7), for posting on the Ozone Secretariat website under Decision Ex. I/4(8).) In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the origin al nomination on which the Party’s first

-

year exemption was approved, as well as any supplementary information provided by the Party in relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not re - submit that earlier information.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 2 of 16 CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS : Contact/Expert Person: Jack Housenger Title: Director Address: Biological and Economic Analysis Division Office of Pesticide Programs U.S. Environmental Protection Agenc y 1200 Pennsylvania Avenue, N.W. Mailcode 7503P Washington, D.C. 20460 U.S.A. Telephone: (703) 308

- 8200 Fax: (703) 308

- 7042 E
- ma il: Housenger.Jack@epa.gov
LIST OF DOCUMENTS SENT TO THE OZONE SECRETA RIAT IN OFFICIAL NOMINATION PACKAGE : 1. PAPER DOCUMENTS: Title of paper documents and appendices No. of pages Date sent to Ozone Secretariat USA CUN 1 3 SOIL EGG PLANT GROWN IN O PEN FIELDS 15

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 CUN1 3 Soil E ggplant Open Field
* Identical to paper documentsUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 3 of 16 

### METHYL BROMIDE CRITICAL USE RE NOMINATION FOR PREPL ANT SOIL USE ( OPEN FIELD OR PROTECTED ENVIRONMENT) EGGPLANT 1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A C RITICAL USE This nomination covers eggplant grown for fresh market in the States of Florida and Georgia

. Th e crop is gener all y grown in open f ields and followed by

various other crops. Harvest is mainly for fresh market. The USG has reviewed all factors affecting transition rates in this sector. Based on this assessment the transition rate has been greatl y increased 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 technicall y valid. The USG has nominated amounts of meth yl bromide based onl y on those sub

- sectors that cannot transition away fro m methy l bromide at the accelerated rate. Georgia Continued efforts are underway in Georgia to implement effective and economical alternatives to methy l bromide. A 3

- WAY fumigation sy stem , developed by University

of Georgia , and d imethy l disulfide ( DMDS , currentl y unregistered in the US ) plus chloropicrin are two alternatives that appear to be potential replacements for methy l bromide

. During 2008, 40% of the fumigated plasticulture land for vegetable crops was treated with the 3

- WAY which includes a sy s tems approach of 1,3

- dichloropropene, chloropicrin, and metam sodium. Dimethyl disulfide plus chloropicrin has also proven to be effective in managing many pests , including nutsedge , and has the potential to be adopted once the product is registered assum ing it is economicall y feasible

. Although both the Georgia 3

- WAY and DMDS + chloropicrin appear promising, neither fumigant s ys tem will stand alone in managing pests . An effective herbicide program must also be developed to comple ment these fumigant sy s tems. The 3

- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequatel y control grasses or Amaranthus species. Until a program using fumigants and herbicides is developed, having meth yl bromide avai lable is essential. The two aforementioned fumigant s ys tems also pose significant challenges when determining the time interval needed between fumigating and planting. Initial research results suggest the plant back interval for the 3

- WAY will be at leas t 3 times longer than that noted with methy l bromide

. Earl y indications suggest that the plant back interval for DMDS plus chloropicrin applied under high barrier mulch will be similar to the 3

- WAY fumigation sy stem. The l atest research information indicate s that 3

- way s ys tem continues to perform well in the spring, but perform poorly on nutsedge control in the fall. Applications of mixture of DMDS and chloropicrin (79:2 1 ) , at 45 to 50 gallons/acre in the spring and fall will effective ly control nutsedge. Present and f

uture research is focus ing on developing and implementing a herbicideUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 4 of 16 program to compliment both the 3

- WAY and DMDS fumigant s ys tems as well as determining the amount of time that must pass between fumigating with these alternatives and plant ing

. Florida The nutsedge, root

- knot nematodes, and fungal diseases like phy topthora blight, and southern blights are continued to be major problems in eggplant production in Florida. In this State, eggplant is grown year - round , and often double cropped with pepper or cucumber following the eggplant harvest. The crop that follows eggplant in a double cropping production sy stem depends upon prevailing environmental and economic factors. Growers in Florida often p lant eggplant as an extra crop and grow okr a, squash, or cucumbers after eggplant has been harvested. A spring crop of eggplant may

follow as a second crop after a fall crop of pepper or tomato. Eggplant does best on well

- drained, fertile, sandy

- loam soils at a pH of 6.0

- 6.5. Poorly drained soil s may result in slow plant growth, reduced root s ys tems, and low y ields. Eggplant requires a long, warm, frost

- free growing season, usuall y of 14

- 16 weeks. Cold temperatures below 5 o C injure th is crop. The best temperatures are 27

- 32 o C during the day and 2 1

- 32 o C during the night. Plant growth is curtailed at temperatures below 16 o C. Additionally , soil temperature below 16 o C restricts germination. However, most of the eggplant is started in the field from transplants. Methy l bromide is always used in the full

- bed mulch process. Until 1999, the chemical formulation primarily used was 98 percent meth yl bromide and two percent chloropicrin. Since then, growers have shifted to formulations with lower concentrations of methy l bromide and higher amounts of chl oropicrin due to the phase

- out schedule of methy l bromide. At present, the standard formulation contains 50% methy l bromide in Florida

. T he best alternative, 1,3

- D (Telone), may not be applied in Florida in the areas overl yi ng karst geology , which is co mmon throughout the Southeastern States. There is also a 21

- day planting delay (vs. 14 day s for MB) due to regulatory restrictions for 1,3

- D + chloropicrin

. Currently , the best alternative to use of meth yl bromide in Florida seems to be appl yi ng Telone C

- 35 (1,3

- Dichloropropene + 35% Chloropicrin), applied at prebed 35 gal./acre rate 3 to 5 wks before transplanting. This fumigant application is supplemented by an herbicide treatment (tank mixed treatment of 2 lbs of napropamide with 0.5 lbs of triflur alin per acre to achieve a proper weed control. However, the use of Telone in 63% of Florida eggplant production land is restricted due to the presence of Kast topograph y. Iodomethane, a new methy l bromide alternative, was registered in the U.S., in Oc tober, 2007. Iodomethane, however, is not registered for use on eggplant. EPA feels that it is appropriate not to include iodomethane as a methy l bromide substitute for eggplant at this time. The U.S. nomination is only

for those areas in Georgia and Flor ida where the alternatives are not feasible. If methyl bromide were to be unavailable for U.S. eggplant, growers in the region s cited in this nomination would have to discontinue growing this crop or suffer substantial losses. G rowers would either leave agriculture entirel y or switch to other crops that do not rely on pre

- plant fumigation to control soil pest s . The extent of this impact on the affected growers is debatable, but given the earl y state of commercial deploy ment of methy l bromide alternative s, it is possible that growers who currently use meth yl bromide would face this outcome.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 5 of 16 U.S. reliance on meth yl bromide has dramatically and rapidl y been reduced over the last eight ye ars. Critical use exemption (CUE) requests have decreased every y e ar since the U.S. phase

out process began. The development, registration, and use of new pest control products and production methods have been key to the progress and reductions made to

- date. As alternatives have demonstrated their suitability , as thoro ugh reviews of research results and applicant information have been conducted, and contacts have been made with regional crop experts to assess the technical and economic feasibility of alternatives, U.S. Government (USG) requests have reduced b y 99%, for the fruiting vegetables, over the last 9 y ears. However, as the amount of methy l bromide available for use decreases each y ear, substantial challenges exist in the collection of needed data to substantiate on

- going critical needs through the CUE process. There are now several alternatives for soil fumigation, including 1,3

- dichloropropene plus chloropicrin, the “UGA 3 Way ” combination (1,3

- dichloropropene plus chloropicrin followed b y metam sodium), iodomethane plus chloropicrin, and dimethy l disulfide (DMDS) which have demonstrated some technical and economic feasibility for pest control in a number of vegetable crops in the U.S. Southeast. However, CUE applicants in this nominated sector have indicated that they are not alway s suitable for all situati ons. While DMDS has a Federal registration and has demonstrated effectiveness, it is not currentl y registered in all the relevant states. Given the timing of state registrations, lack of experience using this alternative, and application methods still un der development to minimize odor in communities surrounding treated fields there is uncertaint y in predicting when this alternative can be reasonabl y expected to adequatel y replace methy l bromide in specific application scenarios. While the DMDS registrant has been working with the product to reduce the odor, and growers are gaining experience in its use, work is still needed on application approaches for the alternative to be fully available for use in U.S. southeast vegetable crops. For example individu al operators and small farms, which account for up to eight y percent of the growers in this nominated sector are especially hard

- pressed to make this transition, because one of the most promising alternatives requires additional money to convert their fumi gation equipment and custom fumigation applicators are not available in all areas. In addition to the expense to convert to the alternatives, there have been reports that the alternatives do not perform as well as the MeBr:pic combination. These conce rns about the alternatives have onl y recently been brought to the USG attention and insufficient supporting information was provided. Because of the uncertainties and challenges associated with the use of the available alternatives, the USG believes it mo st prudent and the best public policy

to collect additional information so that the technical and economic impacts of these reported problems can be evaluated. The USG will request the applicants provide additional information to us no later than June 1, 2011 so that the information can be anal yz ed and provided to MBTOC by July 15, prior to the Open Ended Work Group (OEWG) meeting in earl y August. The quality of an y additional information received will first be evaluated in terms of whether or not it supp orts a compelling case and confirms problems with the feasibility of alternatives. Then, on that basis, the USG will either support or withdraw this nominated sector at that meeting. The nomination attached specifies the correct year (2013) and amount o f methy l bromide that is being requested for the individual crops within this sector. However, there has been no attemptUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 6 of 16 to update the information in this document regarding the new research, availability of alternatives, etc. Since the USG learned of th e issues facing the growers within this sector, after speaking directl y with researchers familiar with the specific problems only very recentl y , this information was not available at the time the USG recommendation was developed.
2. SUMMARIZE W HY KEY AL TERNATIVES ARE NOT FEASIBLE Although both the 3

- WAY and DMDS ( d imethyl disulfide ) plus chloropicrin appear promising, neither fumigant s ys tem will stand alone in managing pests . An effective herbicide program must be developed to compl e ment these fumigant sy stems. It is also important to keep in mind that DMDS remains unregistered for use in the US. Current review of available research indicate that the 3

- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS sy stem do es not adequatel y control grasses or Amaranthus species. The most recent studies have reported that a 79:21 mixture of DMDS and chloropicrin is the most effective combination of these two fumigants (Culpepper et al., 2008). I n the Southern U

. S

. , mainly i n Florida and Georgia, where nutsedge is a main methy l bromide target pest , 1,3

- D or metam sodium , alone or in combination , may not adequately control this weed

. In k arst t opographical feature areas , which include 31 counties in Florida

. 1,3

- D ( Telone II ) is highl y restricted and metam sodium or metam potassium is the best alternatives available. However, further testing of these chemicals in large scale commercial fields is needed

. I n Florida and Georgia , farmers using 1,3

- D and metam sodium in the fal l would require longer waiting periods for planting

. M etam sodium or 1,3

- D require s waiting periods of 28 and 21 day s , respectively , whereas o nly 14 day s are needed for meth yl bromide . S uch delay s could result in miss ed market windows. M etam sodium eff icacy appears to decline where it is applied repeatedly

due to enhanced degradation of its active ingredient, methy l isothiocy anate , by soil microorganisms (Ashley , et al. , 1963 ; Ou et al. , 1995 ; Verhagen et al

. , 1996 ; Gamlied et al

. , 2003). Iodomethane , a new methy l bromide alternative, was registered for some crops in the U.S., in October, 2007. Iodomethane, however, is not registered for use on eggplant. EPA feels that it is appropriate not to include iodomethane as a methyl bromide substitute for eg gplant at this time.
3 IS THE USE COVERED BY A CERTIFICATION STANDARD? Methy l bromide is not used to meet a certification standard for eggplant production
4 IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO CONTROL THE TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 7 of 16 A three

- way

fumigation sy stem developed by Univers ity

of Georgia , as well as d imethyl disulfide (DMDS) plus chloropicrin are the two alternatives that appear the most promising to replace methyl bromid e . 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 sy stems approach of 1,3

- dichloropropene, chloropicrin, and metam sodium. It is likely that 30 to 40% of Georgia’s total crop will be treated with this alternative during 2008. Dimeth yl disulfide (DMDS) plus chloropicrin also proven to be effective in managing man y 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 sy stem will stand alone in managing pests . An effective herbicide program must be developed to compliment these fumig ant s ys tems. The 3

- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS sy stem does not adequatel y control grasses or Amaranthus species. The reader is reminded that DMDS remains unregistered for use in the United Stat es. Until a program using fumigants and herbicides is developed, having meth yl bromide available is essential. In k arst topographical feature areas , which include 31 counties in Florida , Telone is highl y restricted and metam sodium or metam potassium is the best alternatives available. However, further testing of these chemicals in large scale commercial fields is needed

. In Florida and Georgia , farmers using 1,3

- D and metam sodium in the fall would require longer waiting periods for planting

. M etam so dium or 1,3

- D requires waiting periods of 28 and 21 day s, respectively , whereas o nly

14 day s are needed for meth yl bromide . S uch delay s could result in miss ed market windows. M etam sodium efficacy appears to decline where it is applied repeatedl y due to enhanced degradation of its active ingredient, methy l isothiocy anate , by soil microorganisms (Ashley , et al. , 1963 ; Ou et al. , 1995 ; Verhagen et al ., 1996 ; Gamlie l et al ., 2003).
5 . WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER AT LEAST PART OF THE CR OP THAT HAS REQUESTE D USE OF METHYL BROMIDE? WHAT CHANGES WOULD BE NEC ESSARY TO ENABLE THIS? The USG has reviewed all factors affecting transition rates in this sector. Based on this assessment the transition rate has been greatl y 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 nominated amounts of methy l bromide based only on those sub

- sectors that cannot transition away from methy l bromide at the accelerated rate.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 8 of 16 6 . STATE RELATIVE EFFECTIVENESS OF RELEVANT ALTERNATIVES COMPARED TO METHYL BROMIDE FOR THE SPECIFIC KEY TARGET PESTS AND WEEDS FOR WHICH IT IS BEING REQUESTED A: KEY PATHOGENS: Phytophthora capsici, Pythium spp. and nematodes ( Meloidogyne spp.) Summary of studies relevant to key pathogens New r esearch information on use of soil fumigants , specificall y in eggplant production is not available in the public domain. Hausbeck and Co rtright (2004 ) conducted a small

- plot field trial on several vegetables, including eggplant

. Results, submitted with the 200 7 CUE request, indicate that 1,3 D + 35 % chloropicrin treatments (shank

- injected at 56.7 liters/ha) for control of Phytophthora an d Fusarium resulted in a 44% yi eld loss , compared to methy l bromide plots

. Chloropicrin plots alone (shank

- injected at 233.6 l/ha) showed a 15.5% loss compared to methy l bromide plots . Metam
- potassium + chloropicrin plots showed yields similar to those tr eated with methy l bromide . Metam
- sodium was not tested, but can be assumed to be equivalent to metam

potassium since the active ingredient is the same

. E ven large differences in average yi elds across various treatments were often not statistically signific ant. In studies with other vegetable crops, fumigation with 1, 3 D + chloropicrin has generally provided better control of fungi than metam

- sodium , though still not as good as control with methy l bromide . For example, in a study using a bell pepper

- s quash rotation in small plots, Webster et al. (2001) found significantl y lower fungal populations with 1,3 D + 35 % chloropicrin (drip applied, 146 kg/ha of 1,3 D), as compared to the untreated control. However, methy l bromide (440 kg/ha, shank

- injected) reduced fungal populations even more. P. capsici was not present in test plots, though Fusarium sp p . were. However, as compared to the methy l bromide standard treatment plots, squash fruit weight was 63 % lower in the 1,3 D plots. The proportion of mark etable squash fruit in the 1,3 D plots was 30 % lower than that in the methy l bromide plots. In another study , conducted on tomatoes, Gilreath et al. (1994) found that metam

sodium treatments did not match methy l bromide in terms of plant vigor at the end of the season

. Fusarium (but not P. capsici ) was one of several pests present. These studies indicate that , trials show promis e for metam

- sodium/potassium + chloropicrin, there is inconsistency

in efficacy

and protection from yield losses. However, the trials were conducted in June, and it is unclear whether these results would hold if fumigation were done under cooler spring temperatures
. Further, no large scale field trials have yet been performed to demonstrate consistent pest control similar to that provided b y methy l bromide. Culpepper and Langston (2004) compared the effectiveness of several soil fumigants on nematode s affecting peppers in Tifton, Georgia. Since e ggplants were not included in these test s , data from peppers are again used to “brid ge” a discussion. Results show that 1,3

- D followed b y chloropicrin was as effective as methyl bromide against nematodes. S pring and fall crop yi eld in these plots were similar to yi eld in methy l bromide plots

. R oot knot nematode s Meloidogyne spp., als o affect Georgia eggplant s. Their d amage to the root may facilitate plant invasion by fungal pathogens, which can lead to wilt, loss of plant vigor, andUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 9 of 16 yi eld losses. Fumigant alternatives such as metam

- sodium have proven inconsistent (Noling, 2003; FFVA , 2002). Diseases caused b y soil

- borne fungi, (e.g., Phytophthora spp., Pythium spp. and Sclerotium rolfsii ) are endemic in many vegetable production areas in Georgia. Fungicides such as chlorothalonil and azox ys trobilurin are onl y used prophy lactic all y and may not offer sufficient p lant protection . Resistance of Phytophthora spp . to metalax yl and mefenoxam has been reported in tomato and pepper (Lamour and Hausbeck, 2003) The use of 1,3

- D and metam sodium in the fall is impractical because of the lo ng waiting periods for planting following application under plastic mulch. For 1,3

- D there is a 28 day waiting period; for metam sodium, there is a 21

- day waiting period. Such delay s would cost growers at least half of the harvest season, thereb y missing the higher market windows. Thus, since the fall crop is dependent upon timely planting, the required waiting period would cost growers at least half of the harvest season, thereb y missing the higher market windows (Kelley, 2003).
B: KEY WEED S : Nutsedges T ABLE 2: DATA ON TRIALS OF F UMIGANT A LTERNATIVES TO M ETHYL B ROMIDE FOR P OLYETHYLENE - M ULCHED T OMATO (L OCASCIO ET AL . 1997 )

Chemicals Rate (kg/ha) Average

Nutsedge Density (#/m 2 ) Average

Marketable Yield (ton/ha) % Yield Loss

(com pared to methyl bromide ) Un treated (control)
- 300 ab 20.1 a 59.1 methyl bromide + Pic (67 - 33), chisel - injected 390 kg 90 c 49.1 b

--- 1,3 D + Pic (83 - 17), chisel - injected 327 l 340 a 34.6 c 29.5 Me tamNa, Flat Fum igation 300 l 320 a 22.6 a 54.0 Me tamNa, drip irrigated 300 l 2 20 b 32.3 c 34.2 Narrative description of studies relevant to target weeds For nutsedge, which is widespread in all requesting region s , growers do not have technically feasible alternatives to methy l bromide use at planting. Metam

- sodium and 1,3 D + ch loropicrin have shown some efficacy in small

- plot trials in other vegetable crops (e.g, tomato). However, metam sodium use may result in a 44% yield loss, while use of 1,3 D may result in a 29% loss. These fumigants often provide less control of nutsedge s than methy l bromide

. Furthermore, there is evidence that both 1,3 D and meth yl isothiocy nate levels decline more rapidl y due to enhanced degradation of these chemicals by soil micro organisms , thus further compromising efficacy , in areas where these are repeatedl y applied (Smelt et al., 1989; Ou et al., 1995; Gamliel et al., 2003 ; Dungan and Yates, 2003). Results from small plot studies conducted in Tifton, Georgia, b y Culpepper and Langston ( 2004 ) show that 1,3

- D followed by chloropicrin was significantly less effective than methyl bromide against both purple and yellow nutsedge , although this treatment performed as well as methy l bromide relative to spring and fall crop yi eld

. 1,3

- D + chloropicrin, followed by moreUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 10 of 16 chloropicrin was more effective than methy l bromide against ye llow nutsedge, but less effective against purple nutsedge. This treatment performed as well as methy l bromide in terms of spring yi eld, but poorl y in terms of fall yi eld. 1 ,3

- D + chloropicrin, followed by metam sodium was 36% le ss effective than methyl bromide for purple nutsedge control , but as effective as methy l bromide against yellow nutsedge. However, test p lots were small, and it is un clear if the se results will hold in commercial fields , considering the variable results r eported elsewhere for the se alternatives. The nutsedge population s in this study were dominated by

y ellow nutsedge (90% of the total). It is not clear if populations where purple nutsedge is dominant w ould be controlled as effectively , since o ther studie s have shown that purple nutsedge is a hardier species

. Current review of available research indicate that the 3

- WAY does not provide adequate nutsedge control with summer/fall fumigations and the DMDS system does not adequatel y control grasses or Amaranth us species. The most recent studies have reported that a 79:21 mixture of DMDS and chloropicrin is the most effective combination of these 2 chemicals (Culpepper et al., 2008 ). Present and f uture research are focusing on developing and implementing a herb icide program to compliment both the 3

- WAY and DMDS fumigant s ys tems as well as determining the amount of time that must pass between fumigating with these alternatives and planting

. In Florida , the best currently available alternative for eggplant prod uction (which cannot be used in areas containing karst topographical features ) is an application of Telone C

- 35 (1,3

- D + 35% chloropicrin), at 35 gallons per acre, 3

- 5 weeks before transplanting, followed by an application of a herbicide mix of napropamide and trifluralin to the top of the raised bed at the time of tarp laying (Noling and B o tts, 2007). A soil treatment recently

developed by

the University

of Georgia appears to be promising as a methy l bromide replacement for Georgia’s eggplant spring cro p, although not for the summer or fall crops. This treatment, known as the “ UGA 3

- WAY ” , consists of three successive soil fumigations, beginnin g with 1,3

- D , followed b y a chloropicrin application, followed b y a metam
sodium or metam

- potassium application (Culpepper, 2007a). In 2006, Culpepper et al . (2007a) tested the effectiveness of fall applications of methyl bromide alternatives, including the UGA 3 WAY treatment, on nutsedges infesting the spring bell pepper crop in Ty t y, Georgia. Results of this sm all

- plot study

show that the UGA 3

- WAY alternative (see above) performed as well as the standard meth yl bromide application. Similarly , reducing the standard rates of methy l bromide by 50%, from 392 kg/ha under standard LDPE film to 196 kg/ha under metali zed film, also provided excellent purple nutsedge control. Pepper y ields were comparable in all treated plots. In a related small plot trial, conducted b y Culpepper (2007b) in Echols County , Georgia, during the spring of 2006, excellent purple nutsedge control was achieved with 484 kg of meth yl bromide/ha under standard film and 336 kg of methy l bromide/ha under metalized film. However, further reducing the meth yl bromide rate by 50% to 224 kg/ha, under metalized film, resulted in poor nutsedge control . Soil fumigation took place in February . Culpepper concludes that, based on research conducted over the past three ye ars with meth yl bromide applied under metalized film, a 33% reduction of the standard 67:33 formulation is possible in fields heavil y in fested with weeds, and a 40% reduction in fields with light weed infestations, whereas reducing the meth yl bromide rate b y 50% would be unsustainable for weed control.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 11 of 16 Although these results are promising, results from small plot research need to be verif ied at the commercial level, in on

- farm trials. Furthermore, most research in Georgia has so far focused on nutsedge. Additional work is needed to determine the efficacy of alternatives on other weed species, such as morning glory and pigweed. Finally , the economics of transitioning to alternatives has not been fully worked out, including the cost and durabilit y of films and the modification of fumigation equipment
7. ECONOMIC FEASIBILITY OF ALTERNATIVES The following economic anal ys is is organize d by methy l bromide critical use application regions. Readers please note that in this study net revenue is calculated as gross revenue minus operating costs. This is a good measure as to the direct losses of income that may be suffered by

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

of an operation 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 . We did not include fixed costs because it is often difficult to measure and verify

. Summary of Economic Feasibility The economic anal ys is of eggplant application s compared data on the yi elds, crop prices, revenues and costs of using methy l bromide or alternative pest control regimens . This was done in order to estimate impacts on eggplant growers with the decreasing availability of meth yl bromide

. The Georgia 3

- Way (1,3

- d ichloro propene with c h loropicrin followed by me tam sodium) was identified as being a technically feasible alternative ( in cases of low pest infestation 1 and in spring fumigations onl y) to methy l bromide in Georgia and Florida eggplant production. 1,3

- D + chloropicrin is also being recognized as an alte rnative to methy l bromide; however, it is not considered technicall y feasible as yield losses are expected. The economic reviewers anal yz ed crop budgets for pre

- plant sectors to determine the likely economic impact if methyl bromide were unavailable. Various measures were used to quantify the impacts, including the following: (1) Loss per Hectare. For crops, this measure is closely tied to income. Itis relatively eas y to measure, but may

be difficult to interpret in isolation. (2) Loss per Kilogram of Methyl Bromide . This measure indicates the value of methy l bromide to crop production. (3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues are usually

eas y to measure, at least over some unit, e.g. , a hectar e of land or a storage
1 It should be noted that the USG does not request methy l bromide for use in areas of low to moderate pest pressure. Only cases where key

pests are present at moderate to high levels require meth yl bromide for pest pressure.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 12 of 16 operation. However, high value commodities or crops may provide high revenues but may also entail high costs. Losses of even a small percentage of gross revenues could have important impacts on the profitability of the activity

. ( 4) Loss as a Percentage of Net 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. Howe ver, operating costs can often be difficult to measure and verify

. (5) Operating Profit Margin . We define operating profit margin to be net operating revenue divided by

gross revenue per hectare. This measure would provide the best indication of the tot al impact of the loss of methy l bromide to an enterprise. Again, operating costs may be difficult to measure and fixed costs even more difficult, therefore fixed costs were not included in the anal ys is. These measures represent different way s to assess the economic feasibility of methy l bromide alternatives for meth yl bromide users, who are eggplant producers in this case. Because producers (suppliers) represent an integral part of any definition of a market, we interpret the threshold of significant market disruption to be met if there is a significant impact on commodity suppliers using meth yl bromide. The economic measures provide the basis for making that determination. Georgia and Florida In Georgia and Florida, using the Georgia 3

- Way on spring p lantings i s believed to be a technicall y and economically feasible alternative to methyl bromide, although some limitations exist. Referring to Table s 3 and 4 , the loss of net revenue using the Georgia 3

- Way is negligible for Florida in comparison to methyl bromide, while gains in net revenue are expected in Georgia. Unlike spring plantings, however, yi eld losses are expected in fall plantings, with studies in Georgia’s application show ing 50% yi eld loss es . The Georgia 3

- Way also cannot be used on eggplants that are grown in karst soils since it contains 1,3

- D. Therefore, for fall plantings and areas with karst soils, the use of meth yl bromide is critical to Georgia’s and Florida’s eggplant production. Note that data describing Georgia eggplant production is based on double cropping production practices. Florida Analy

tical Notes : F lorida’s application for methy l bromide critical use indicated that more than one crop is ty picall y grown per growing season but did not provide specific production and sales d ata for this crop. As a result of this gap in data, economic assessment of Florida eggplant production was based on a single crop production sy stem. This characterization of growing conditions could result in the critical need for methy l bromide appearin g smaller than it actuall y is, because the value the second crop derives from meth yl bromide is not included in the anal ys is.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 13 of 16 T ABLE 3 : G EORGIA - E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

GEORGIA EGGPLANT ME THYL BROMIDE GEORGIA 3 -

WAY: SPRING APPLICAT ION GEORGIA 3 -

WAY: FALL APPLICATION PRODUCTION LOSS (%) 0% 0% 50% PRODUCTION PER HECTARE 7,070 7,070 3,535 * PRICE PER UNIT (US$) $8 $8 $8 = GROSS REVENUE PER HECTARE (US$) $57,547 $57,547 $28,774

- OPERATING COST PER HECTARE (US$) $45,271 $34,6 10 $34,610 = NET REVENUE PER HECTARE (US$) $12,277 $22,938

- $5,836 LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 ($10,661) $18,113 2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 ($71) $121 3. LOSS AS A PERCENTAGE OF GROSS REVENUE (%) 0%

- 19% 31% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0%

- 87% 148% 5. OPERATING PROFIT MARGIN (%) 21% 40%

- 20% Note: Georgia eggplant revenue and cost measures were calculated using data from a tw o crop per growing season production system.  Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “gain”. Positive numbers can be interpreted as losses. T ABLE 4 : F LORIDA - E CONOMIC I MPACTS OF M ETHYL B ROMIDE A LTERNATIVES

FLORIDA EGGPLANT ME TH YL BROMIDE GEORGIA 3 -

WAY: SPRING APPLICATION 1,3 - D +

CHLOROPICRIN PRODUCTION LOSS (%) 0% 0% 29% PRODUCTION PER HECTARE 1,764 1,764 1,252 * PRICE PER UNIT (US$) $11 $11 $11 = GROSS REVENUE PER HECTARE (US$) $19,983 $19,983 $14,188

- OPERATING COST PER HECTARE (US$) $17,891 $17,976 $17,303 = NET REVENUE PER HECTARE (US$) $2,092 $2,007

- $3,116 LOSS MEASURES * 1. LOSS PER HECTARE (US$) $0 $85 $5,208 2. LOSS PER KILOGRAM OF METHYL BROMIDE (US$) $0 $1 $70 3. LOSS AS A PERCENTAGE OF GROSS REVE NUE (%) 0% 0% 26% 4. LOSS AS A PERCENTAGE OF NET OPERATING REVENUE (%) 0% 4% 249% 5. OPERATING PROFIT MARGIN (%) 10% 10%

- 22% * Interpret the loss measures with caution. Negative numbers presented in rows indicating a “loss” should be interpreted as a “ gain”. Positive numbers can be interpreted as losses.USA CUN13 SOIL Eggplant Grow n in Open F ields Page 14 of 16 8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES The USG has applied an aggressive transition rate , which is reflected in the nomination amount and deta iled in Table 5
. TABLE 5 . N OMINA TION A MOUNT :

Flo ri da Eg gpl an t Ge orgi a Eg gpl an t S ect or T ot al / Av erag e Qu an tity Reque ste d fo r 2012: Amount ( kgs) 3,8

43 3, 06 1 6, 904 Qu an tit y Re co mm

en de d by MB TOC /T EAP f

or 2 012 : Amount ( kgs) 3,8

43 3, 06 1 6, 904 Amount ( kgs) 3,8

43 3, 06 1 6, 904 Are a (h a) 73 58 13 1 Ra te 53 53 53 Tr an sit ion f ro m 2 012 Ba seli

ne Ad ju st ed Va lue Pe rcen ta ge ( %) -80 % -8 0% -8 0% Amount ( kgs) 

### 769 612 1,3 81 Are a (h a) 5 4 9. 2 Ra te 150 15 0 15 0 SE CT OR

Qu an ti ty A ppr ove d by Pa

rt ie s fo r 2012:
Qu an tity R eq ui re d for 2013 N omi na ti on : EG GP LA NT



### CITATIONS Aerts, M. 2003. Asst. Director, Environmental and Pest Management Division, Florida Fruit and Vegetable Association. Personal Communication with G. Tomimatsu, December 2, 2003. Banks, H. J. 2002. 2002 Report of the Meth yl Bromide Technical Options Committee, 2002 Assessment. Pg 46. Chellemi, D.O., R. C. Hochmuth, T. Winsberg, W. Guetler, K. D. Shuler, L. E. Datnoff, D. T. Kaplan, R. McSorley , R. A. Dunn, and S. M. Olson. 1997. Application of soil solarization to fall pro duction of cucurbits and pepper. Proc. Fla. State Hort. Soc. 10:333

- 336. Cortright, B. 2003. Field Research Associate University of Michigan. Personal Communication with G. Tomimatsu, November 24, 2003. Cortright, B.D. and M.K. Hausbeck. 2004. Evaluat ion of fumigants for managing Ph yt ophthora crown and fruit rot of solanaceous and cucurbit crops, plot two, 2003. Unpublished study (MI CUE # 03

- 0061). Csinos, A.S., D.R. Sumner, R.M. McPherson, C. Dowler, C.W. Johnson, and A.W. Johnson. 1999. Alternativ es for methy l bromide fumigation of tobacco seed beds, pepper, and tomato seedlings. Proc. Georgia Veg. Conf. Available on the Web at http://www.tifton.uga.edu/veg/Publications/Gfvga99.pdfUSA CUN13 SOIL Eggplant Grow n in Open F ields Page 15 of 16 Culpepper, A.S. 2007 a . Methy l bromide CUE data generated in Geo rgia (Fall, 2006

– Spring, 2007 ) , Appendix 1

. Culpepper, A.S. 2007 b . Impact of mulch t ype on rate of meth yl bromide needed to control nutsedge. Meth yl bromide CUE data generated in Georgia (Fall, 2006

– Spring, 2007 ) , Appendix 4. Culpepper, A.S. , A.L. Davis, T.M. Webster, A.W. MacRae, and D.L. Langston. 2007 a . Bell pepper and nutsedge response to fall applied methy l bromide alternative fumigants in Georgia. UGA Weed Science. At: www.gaweed.com Culpepp er, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. Mayfied, T. Webster, and W. Upchurch. 2007 b . Can Georgia growers replace methy l bromide? MBAO Conference, San Diego, Ca l ifornia, 2007. http://mbao.org/2007/PDF/Preplant/PP4/Culpepper(20).pdf Culpepper, A.S., P. Sumner, D. Langston, K. Rucker, G. Beard, J. May fied, T. Webster, and W. Upchurch. 2008. DMDS or the 3

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