Attachment_One_-_Brand_Name_Justification_Telone.pdf

Brand Name Justification and Approval Page 1 of 2

AG-6395-S-16-0127

BRAND NAME JUSTIFICATION AND APPROVAL

PPQ Pale Cyst Nematode Program, Idaho Falls, ID

1. Agency and Contracting Activity: United States Department of Agriculture (USDA), Animal Plant Health Inspection Services (APHIS), Plant Protection and Quarantine (PPQ) Pale Cyst Nematode (PCN) Program Idaho.

USDA, APHIS, AAMD Division

Minneapolis, MN 55403

2. Description of Action being approved: New firm fixed price indefinite delivery indefinite quantity contract for the purchase of the pesticide Telone.

3. Description of Product, Supplies or Services Required to Meet Agency Needs:

APHIS requires the nematicide Telone II (1,3-dichloropropene) for its PCN treatments in 2016.

As many as 900 acres of PCN-infested farmland will be treated at a rate of 36 gallons per acre;

therefore as much as 32,400 gallons of Telone II product are needed for the project.

4. An identification of the statutory authority permitting other than full and open competition:

The Statutory Authority for this action is 41 USC 3304 (a)(1) The particular brand name, product, or feature is essential to the Government’s requirements, and historical use and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs.

5. Identification of the Justification Rationale:

The PCN Program is seeking the use of Telone II (1,3-Dichloropropene) as a soil fumigant against the soil-borne potato pest Globodera pallida, also known as the pale cyst nematode (PCN). Telone II was used by the PCN program in 2007 - 2008, 2010 - 2011, and on a small trial basis again in 2015. Telone II has been shown to be very effective against PCN when used under ideal conditions of soil moisture and temperature, and using best practices for application.

Telone II has been fully vetted by APHIS in the Supplemental Environmental Assessment (April 2016) for the Pale Cyst Nematode in Bingham and Bonneville Counties, Idaho. For more information, visit: https://www.aphis.usda.gov/plant_health/ea/downloads/2016/pcn-bingham-bonneville-counties-ea.pdf

At program inception (2006) and at regular intervals since, an international panel of nematology experts has reviewed the PCN eradication program and made recommendations to APHIS for continued success at reducing PCN populations. Telone II, along with methyl bromide and dimethyl-disulfide (DMDS), were identified as nematicide options. Methyl bromide is extremely effective against PCN and was used by the program 2007 – 2014, but after APHIS was made aware of a concern regarding the methyl bromide soil fumigant used to treat pale cyst nematode (PCN) infested fields, APHIS decided not to use methyl bromide soil fumigation in April 2015.

After concerns were raised by stakeholders, the USDA has been working with the U.S.

Environmental Protection Agency and others to investigate the concerns over the use of methyl bromide before resuming its use in soil fumigation in the PCN Eradication Program.

DMDS (under the trade name Paladin) is not labeled for use against PCN in the State of Idaho, and has significant treatment block restrictions (only 40 acres per contiguous site) which is not workable within the treatment window available for the PCN Program eradication treatments. In addition, environmental impacts of DMDS in the PCN Program area have not yet been fully explored by APHIS.

https://www.aphis.usda.gov/plant_health/ea/downloads/2016/pcn-bingham-bonneville-counties-ea.pdf https://www.aphis.usda.gov/plant_health/ea/downloads/2016/pcn-bingham-bonneville-counties-ea.pdf

Brand Name Justification and Approval Page 2 of 2

AG-6395-S-16-0127

6. Best Value Determination:

The solicitation for this product will be posted in the open market on the Federal Business Opportunities website. Because competitive quotes will be solicited from authorized retailers of the brand in a competitive environment this will ensure fair and reasonable pricing. Since vendors know it’s a competitive environment there would be no reason to overstate their pricing.

7. Market Research conducted:

The PCN program has been active for many years in Idaho. The APHIS program personnel are well aware of the products available in the market to treat this potato pest. They have conducted research to identify a number of sources who sell this product.

8. Statement of actions, if any to remove barriers to competition in the future:

The program specialists are continually reviewing the program and analyzing alternatives for treating this pest. If other products become available that are effective in treating this plant pest the USDA, APHIS will consider other products.

9. Any other facts supporting justification:

NA

As the technical or requirement personnel, I certify that the evidence of the supporting data that forms the basis of this justification is complete and accurate.

Technical/Requirements Personnel Printed Name Date

Contracting Officer Date

06/07/2016 tgresham Typewritten Text 06/07/2016