FY24 Brand Name Justification Telone.pdf

Brand Name Justification and Approval Page 1 of 2

BRAND NAME JUSTIFICATION AND APPROVAL

PPQ Pale Cyst Nematode Program, Idaho Falls, ID

Fiscal Year 2024

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.

Contracting Activity:

USDA, APHIS, AAMD Division 250 Marquette Avenue, Suite 410 Minneapolis, MN 55401

2. Description of Action being approved: Firm fixed price commercial supply contract for the purchase of the Dow Teleos Ag pesticide Telone II® (1,3-Dichloropropene).

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 soil beginning in August 2023. As many as 674 acres of PCN-infested farmland will be treated at a rate of 36 gallons per acre; therefore, as much as 24,261 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 2015 - 2023.

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 (March 2017) for the Pale Cyst Nematode in Bingham and Bonneville Counties, Idaho. For more information, visit:

https://www.aphis.usda.gov/plant_health/ea/downloads/2017/pcn-idaho-sea-march-2017.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 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.

https://www.aphis.usda.gov/plant_health/ea/downloads/2017/pcn-idaho-sea-march-2017.pdf

Brand Name Justification and Approval Page 2 of 2

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.

6. Best Value Determination:

The solicitation for this product purchase will be posted 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. Market research has been conducted to identify a number of sources who sell this product. The APHIS program personnel are well aware of the products available in the market treat this potato pest. As a part of the market research efforts, the DowDuPont Representative is consulted to obtain names of companies that are certified DowDuPont Telone distributors as well as licensed pesticide dealers in Idaho.

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 Date

Robert Gourley

Contracting Officer Date

Robert Gourley