­­­­
Forwarded
by
Hodayah
Finman/
DC/
USEPA/
US
on
09/
09/
02
03:
01
PM
­­­­­
Jan
Sharp
<
JSharp@
calstrawberry.
org>
09/
09/
02
01:
59
PM
To:
Bill
Chism/
DC/
USEPA/
US@
EPA,
Bromide
Methyl@
EPA
cc:
Subject:
California
Strawberry
Commission
CUE
Application
for
Production
S
trawberries
Attached
is
the
Excel
CUE
form
for
production
Strawberries
in
California.
It
is
a
large
document,
so
please
be
patient
with
the
download.
A
second
email
will
follow
with
pertinent
Narratives
and
accompanying
spreadsheets.
Hardy
copies
are
being
sent
by
Courier
today
as
well
as
a
CD
with
electronic
versions
of
nearly
all
the
Appendices.
Similarly,
electronic
and
hard
copy
are
also
going
directly
to
Roberta
Firoved
at
CDPR.
Any
questions,
please
call
or
email.
Thank
you.
Jan
<<
CA
Strawberry
Commission
CUE
Application.
xls>>
Janice
K.
Sharp,
Ph.
D.
Director
of
Regulatory
and
Environmental
Affairs
California
Strawberry
Commission
P.
O.
Box
269
Watsonville,
CA
95077­
0269
831
724­
1301
ext
149
phone
818
707­
7680
fax
818
903­
0762
mobile
1,3­
Dichloropropene
and
Chloropicrin
Technical
Feasibility
Efficacy.
Telone
 
(
1,3­
dichloropropene)
is
used
as
a
nematocide
with
minimal
efficacy
against
disease
and
weeds
when
used
alone.
Because
it
is
not
effective
against
the
entire
pest
complex
in
California
strawberries,
this
alone
prevents
it
from
being
a
methyl
bromide
replacement
(
Table
1,
Pest
Complex,
in
application).
Early
efficacy
work
with
Telone
alone
demonstrated
its
poorer
activity
compared
to
methyl
bromide/
chloropicrin
standards
(
Appendix
CC,
91­
15
Pink
Sheet).
And
in
fact
in
that
study
of
repeated
use
over
three
years,
already
poor
yields
dropped
with
time.
The
MBTOC
1998
report
(
page
51)
also
indicated
it
is
effective
only
in
combination
with
other
components.
The
Federal
Use
Label
also
shows
it
is
labeled
only
against
nematodes.

Chloropicrin
alone
has
some
activity
against
much
of
the
California
Pest
Complex.
Chloropicrin
has
good
efficacy
against
Pseudomonas
solancearum,
Cylindrocladium
fungi,
Phytophthora,
Fusarium,
Pyrenochaeta,
Pythium,
Rhizoctonia,
Sclentina,
Slcerotium,
Verticillium,
clubroot
organism
Plasmodiophora,
soil
pox
Actinomyces
ipomoea
(
Table
1,
Pest
Complex,
in
application).
Chloropicrin
alone
has
some
control
of
cut
worms,
grubs,
wireworms,
and
suppression
of
weeds
if
used
with
tarps
(
Appendix
G,
Metapicrin
label.)
It
has
no
control
over
some
key
weeds,
knotweed,
clovers,
and
filaree
and
limited
control
over
others
that
MBC
does
control
(
Appendix
DD,
Fennimore
2002
handout).
While
used
primarily
as
a
fungicide,
its
control
of
anthracnose
is
unknown,
and
this
disease
has
become
an
increasingly
important
problem
in
California
strawberries
and
is
controlled
by
MBC.
Chloropicrin
has
no
reported
activity
against
nematodes.
Nematodes
may
likely
become
an
increasing
problem
with
repeated
use
of
Chloropicrin.
MBC
has
controlled
nematodes
so
well
for
decades
and
it
is
difficult
to
measure
the
future
impact
of
this
pest
when
faced
with
less
than
adequate
control
from
Chloropicrin.

Combined
Efficacy
The
main
drawback
of
the
1,3­
D
chloropicrin
alternative
combination
is
the
lack
of
control
of
weeds.
Some
increased
control
of
weeds
has
been
observed
with
InLine
applications
using
VIF
mulch.
However,
as
in
all
drip
applications,
weed
control
is
not
observed
along
the
sides
of
the
beds
where
the
drip
application
did
not
reach.
Application
of
herbicides
is
not
a
simple
solution
because
these
side
weeds
are
under
the
mulch.
Removal
requires
extensive
labor
to
lift
the
tarp
sides,
pull
the
weeds,
and
replace
the
tarp
along
the
sides.
Use
of
additional
herbicides
would
simply
add
to
the
operational
costs
as
would
increased
labor
to
hand
weed.
Yields
When
the
yield
data
is
analyzed
for
both
shank
and
drip
applications
of
Telone
C35
or
InLine,
some
interesting
overall
results
are
observed.
When
only
data
from
trials
where
untreated
controls
had
yields
of
80%
or
less
of
the
MBC
standard
are
considered,
the
overall
yields
with
1,3­
D/
chloropicrin
averages
94%
of
the
MBC
standard
(
Appendix
T,
1,3­
D
Pic
tab).
When
drip
and
shank
applications
are
separated,
drip
was
better
at
97%
versus
90%
for
shank.
Analysis
of
10
studies
comparing
MBC
with
1,3­
D/
chloropicrin
applications
by
Shaw
and
Larson
showed
an
overall
loss
of
14.7%
compared
to
MBC.
No
studies
or
work
is
available
on
repeated
use
of
1,3­
D/
chloropicrin
on
the
same
land.
Since
Shaw
and
Larson
showed
steady
declines
in
yields
over
3
years
of
chloropicrin
use,
and
1,3­
D
has
limited
efficacy
on
the
pest
complex,
one
would
anticipate
steady
losses
with
use
of
this
material.
In
particular,
weed
pressure
may
increase
so
significantly
with
repeated
use
to
further
contribute
to
yield
loss.

Other
problems
have
been
experienced
with
drip
applications
of
InLine.
Phytoptoxicity
is
seen
sometimes
if
appropriate
plant
back
timings
were
not
used
during
the
study.
Soil
temperatures
are
critical
to
calculating
accurate
plant
back
times,
the
cooler
the
temperature,
the
longer
the
plant
back.
Damaged
to
irrigation
piping
and
systems
can
occur
if
proper
flushing
of
the
system
is
not
done
after
fumigation.
And
leaks
in
an
irrigation
system
can
result
in
pooling
of
chemical
and
therefore
spotty
delivery
to
the
field
resulting
in
variable
efficacy
throughout
the
field
or
phytotoxicity
after
planting
strawberry
transplants.
And
volume
delivery
of
the
drip
material
has
been
found
to
be
inappropriate
for
very
sandy
soils
(
no
spread
through
the
bed)
or
resulted
in
collapsed
beds
with
too
much
volume,
of
poor
efficacy
and
spread
in
heavier
soil.
In
short,
use
of
this
drip
material
requires
more
specific
soil
type,
moisture,
and
delivery
conditions.
All
of
these
problems
are
still
under
investigation
by
researchers,
particularly
rates
in
different
soils,
to
find
optimal
conditions
from
which
growers
can
then
safely
trial
the
material
in
their
own
specific
circumstances.

Economic
Analysis
For
drip
applications,
the
most
economical
and
safest
application
technology,
there
are
potential
up
front
costs
for
ensuring
irrigation
systems
are
leak
proof
and
proper
valves
and
safeguards
are
in
place
to
prevent
backflow
of
materials
into
water
sources.
In
addition,
1,3­
Dichloropropene
and
chloropicrin
are
very
corrosive
substance
and
if
proper
care
is
not
taken
to
clean
out
systems
after
application,
valves
and
piping
corrode
and
need
replacement.
Growers
need
to
replace
PVC
pipe,
which
is
corroded
by
1,3­
D
and
chloropicrin,
with
non­
PVC
piping
such
as
Oval
Hose.
The
first
growers
using
the
technology
state
that
they
had
minimal
up
front
costs
or
donations
of
equipment
to
upgrade
their
systems.
For
the
general
grower
upgrade
costs
could
run
thousands
of
dollars
to
replace
PVC
piping
and
add
proper
valve
and
flow
equipment.
We
estimate
yearly
costs
of
$
100
per
acre
to
upgrade
and
maintain
drip
systems
based
on
discussions
with
experienced
growers.

The
economics
associated
with
soil
preparation
come
into
play
for
1,3­
D/
chloropicrin
applications.
Soil
preparation
and
soil
moisture
are
more
critical
than
with
MBC
applications
(
Appendix
G,
Telone
C35
and
InLine
labels).
Soil
temperature
is
also
more
critical.
According
to
label
directions,
if
soil
temperatures
drop
below
40
°
F,
the
material
loses
effectiveness
on
application
and
requires
an
even
longer
plant
back
period.
The
normal
plant
back
period
is
roughly
1
week
for
every
10
gallons
per
acre
applied
(
Appendix
G).
At
best
this
leaves
a
plant
back
period
of
21
days
compared
to
the
7
days
for
MBC.
Even
so,
the
Southern
grower
pulling
crop
at
the
beginning
of
July
can
fit
in
Telone
C35
or
InLine
applications.

The
Northern
growers
however
will
lose
revenue
from
not
harvesting
the
second
half
of
September
($
1,262
per
acre)
for
rotational
growers.
There
is
some
savings
in
not
paying
harvest
costs
for
two
weeks,
a
total
of
$
459
per
week
(
fresh
harvest
costs
for
North
divided
by
35
weeks
harvest),
or
$
918
per
acre.
The
nonrotational
growers
will
have
to
obtain
their
land
sooner,
paying
one
quarter
year's
rent
to
prevent
the
vegetable
grower
from
doing
one
last
vegetable
crop.
Land
rent
in
the
northern
region
ranges
from
$
1800­
2400
per
acre.
One
quarter
of
the
average
rent,
$
2,100,
is
$
525.

Economic
analysis
was
done
with
best
case
scenarios.
For
the
Southern
grower
and
the
Northern
non­
rotation
grower,
it
was
assumed
drip
application
of
InLine
was
the
most
efficacious
and
cost
effective.
In
addition,
for
the
Southern
grower
it
is
assumed
he
has
just
enough
time
for
soil
preparation,
fumigation,
and
plant
back
time
of
21
days.
For
the
rotation
grower
in
the
North,
flat
fumigation
of
Telone
C35
is
the
only
option
to
ensure
coverage
of
the
entire
field
in
anticipation
of
use
the
next
year
by
vegetable
growers.
As
such,
when
these
costs
are
added
in,
the
Southern
grower
still
sees
a
loss
of
$
520
per
acre
a
total
loss
of
$
20,800
for
the
40
acre
representative
user.
In
the
North,
the
non­
rotation
grower
experiences
a
loss
of
$
895
per
acre
for
a
total
loss
of
$
35,800.
The
rotational
grower
experiences
the
greater
loss
of
$
2,099
per
acre
to
use
of
the
more
expensive
flat
fumigation
with
Telone
C35,
and
greater
yield
loss
with
that
treatment.
The
total
loss
for
the
40­
acre
representative
rotation
grower
is
$
83,960.
On
average
for
the
Northern
grower,
losses
would
be
$
1,497
per
acre,
or
$
59,880
for
the
40­
acre
Northern
grower.
This
are
minimum
possible
losses
because
if
plant
back
time,
particularly
in
the
colder
north,
increases
so
does
loss
of
revenue
by
having
to
take
land
back
earlier.

Regulatory
Pressures
1,3­
Dichloropropene
The
Federal
Label
requires
a
100
foot
buffer
zone
for
drip
applied
Telone
(
Appendix
G).
For
shank
applied
Telone,
a
100
foot
buffer
zone
is
required
the
first
year
and
a
300
foot
buffer
zone
is
required
for
the
next
two
years
on
the
same
ground.
In
addition,
in
California,
use
is
limited
by
township
caps,
as
an
additional
protection
with
respect
to
the
classification
of
1,3­
D
as
a
B2
carcinogen
(
Appendix
O,
P,
and
S).
Recently
township
caps
were
doubled
in
townships
where
historical
Telone
use
did
not
reach
the
maximum
allowed
under
the
caps,
in
general
90,000
lbs
per
township
(
Appendix
S).
This
is,
however
a
temporary
increase
until
the
amount
of
Telone
"
banked"
from
previous
years
is
used
up,
or
the
registrant
convinces
the
California
Department
of
Pesticide
Regulation
that
permanent
increases
are
justified
by
reassessing
the
oncogenic
risk.

Township
caps
originally
set
by
California
were
90,250
"
adjusted"
pounds
per
township
per
year
(
Appendix
P).
Adjusted
pounds
are
actual
pounds
of
1,3­
D
applied
times
an
application
factor.
This
calculates
out
to
approximately
345
acres
in
a
township
can
be
treated
with
InLine
using
VIF
mulch.
Since
a
township
is
approximately
25,000
acres,
and
many
townships
in
the
Northern
and
Southern
strawberry
growing
regions
have
over
a
thousand
acres
in
strawberries
in
many
townships,
obviously
not
all
strawberries
growers
could
use
Telone
products.

DPR
recently
doubled
the
township
cap
in
many
of
the
townships
where
previous
use
did
not
equal
the
maximum
amount
allowed
under
the
old
township
cap.
In
essence,
the
unused
amount
was
"
banked"
for
future
use.
This,
however,
is
only
a
temporary
solution
until
the
banked
amounts
are
used
up.
Meanwhile
the
1,3­
D
registrant
is
working
with
DPR
to
revise
regional
modeling
schemes
to
determine
whether
permanent
caps
should
be
recalculated
based
on
each
regions
weather
conditions.
Such
analysis
so
far
is
predicted
to
result
in
caps
close
to
the
current
increased
caps
or
between
the
old
and
new.

Dr.
Tom
Trout
of
USDA
has
provided
an
analysis
of
the
impacted
acres
of
strawberries
in
each
county
based
on
the
old
and
new
township
cap
(
Appendix
P).
His
analysis
shows
at
best
that
Telone
products
will
not
be
available
to
47%
of
the
total
strawberry
acreage
in
the
state.
For
the
strawberry
growing
regions,
his
study
projects
unavailable
acres
according
to
the
following
table
(
based
on
2001
acreage):

Region
Total
Acres
Straw
Acres
Unavailable
%
of
Acres
Watsonville
10,759
4,344
40.4%
Santa
Maria
3,817
1,645
43%
Ventura
County
7,777
4,228
54%
Orange
County
2,446
243
10%

Roughly
half
of
the
Southern
acreage
would
not
be
able
to
use
Telone
products.
And
roughly
40%
of
the
Northern
acreage
would
not.
Considering
it
is
not
economical
for
the
Northern
rotation
growers,
to
account
for
concentration
of
non­
rotation
acres
in
the
same
affected
townships,
from
40­
100%
of
the
2,500
acres
of
non­
rotational
growers
acres
in
the
Watsonville
area
could
use
the
material,
although
they
could
still
suffer
losses
using
it
over
MBC.
Much
of
the
land
in
the
Watsonville
area
however
is
not
amenable
to
drip
applications
because
of
soil
type
and
hilliness,
further
reducing
use
of
the
material.
The
1645
acres
in
Santa
Maria
would
be
available
and
only
4,228
acres
in
Ventura.
At
best
then,
8,373
strawberries
acres
may
be
able
to
use
the
material.
This
roughly
calculates
to
availability
to
approximately
30%
of
strawberry
growers
at
best
even
under
the
expanded
township
caps.

!,
3­
D
is
also
classified
as
a
toxic
air
contaminant
in
the
state
of
California
and
will
undergo
additional
scrutiny
in
future.
This
classification,
in
addition
to
the
classification
as
a
B­
2
probable
carcinogen
contributes
to
an
uncertain
regulatory
future
in
California.

Chloropicrin
The
California
Department
of
Pesticide
Regulation
is
re­
evaluating
chloropicrin
at
this
time
with
anticipated
completion
of
the
review
in
approximately
2­
3
years.
There
are
already
sensitivities
around
the
use
of
the
material
due
to
its
physiological
effects
(
lacrimation
and
upper
respiratory
discomfort)
at
very
low
levels
in
the
air.
Chloropicrin
is
also
currently
listed
as
a
toxic
air
contaminant
in
the
state,
and
could
be
subject
to
additional
regulatory
restraints
after
thorough
review
by
the
Scientific
Review
Panel
of
the
California
Air
Resources
Board.
Of
greatest
concern
is
what
additional
regulatory
restraints
could
be
in
place
in
2005
as
a
result
of
the
DPR
re­
evaluation,
particularly
increases
in
required
buffer
zones,
which
would
limit
the
products
use
in
the
highly
urbanized
strawberry
growing
regions
(
Appendix
S).

Buffer
zones
for
chloropicrin
currently
vary
from
county
to
county
and
depend
upon
local
conditions
such
as
proximity
of
a
field
to
sensitive
sites
(
Appendix
X).
In
most
cases
if
a
sensitive
site
(
occupied
buildings,
residences,
businesses,
schools,
hospitals
etc.)
is
within
300
feet
of
a
field,
a
100
foot
or
more
buffer
zone
is
required
depending
on
the
size
of
the
acreage
to
be
fumigated
at
a
given
time.
These
buffer
zones
are
actually
larger
than
buffer
zone
requirements
for
methyl
bromide
applications
near
most
sensitive
sites
(
60
feet
minimum
depending
upon
application
method
and
acres
to
be
fumigated
at
a
given
time.)

Conclusion
The
combined
soil
fumigation
regime
of
1,3­
dichloropropene
and
chloropicrin
is
questionable
as
a
methyl
bromide
alternative.
It
is
on
the
edge
economically
for
some
growers
and
significantly
limited
by
township
caps
in
California,
at
best
limiting
it
to
33%
of
the
strawberry
acreage.
The
most
efficacious
application
is
drip
application
of
InLine,
yet
its
use
is
limited
by
various
geographical
and
soil
factors.
For
instance
drip
applications
are
difficult
on
hilly
land,
of
which
approximately
half
of
the
Watsonville
growing
region
has
hills.
In
addition,
if
the
soil
is
too
sandy,
the
material
does
not
spread
out
in
the
bed
giving
poor
coverage.
If
the
soil
is
too
heavy,
again
poor
coverage
results
because
it
cannot
move
effectively
through
the
heavy
soil.
Or
worse
yet,
if
material
is
applied
too
quickly
in
high
volumes,
beds
can
collapse,
as
they
have
in
some
of
the
experimental
trials.
Finally,
if
not
properly
rinsed,
irrigation
systems
can
corrode
increasing
grower
costs
for
replacements,
or
phytotoxicity
can
result
if
material
left
in
the
system
reaches
transplants.

This
combination
is
also
under
continual
regulatory
scrutiny
because
of
acute
toxicity
and
the
carcinogenic
classification
of
1,3­
D.
While
research
work
continues
on
improving
yield
and
use
potential,
1,3­
D/
chloropicrin
is
not
currently
an
alternative
for
the
majority
of
strawberry
growers.

Growers
need
3­
4
years
of
practice
with
this
regime
in
their
own
specific
field
and
climate
conditions
to
perfect
any
potential
use
of
the
regime.
With
the
very
low
margins
present
in
the
current
strawberry
market,
growers
can
only
afford
to
do
relatively
small
acreage
at
a
time
to
minimize
potential
losses
until
they
perfect
conditions
using
the
alternatives.
1.

2.

3.

4.

Light
80%
Medium
20%
Heavy
County
Soil
Maps
0
to
2%
51%
2
to
3
%
49%
over
3%
Appendix
E
5.

6.
Specialty
(
check
one)

7.
Jan
ice
K.
Sharp,
Ph.
D.
agronomic
XX
8.
economic
XX
9.
Daytime
phone
10.
FAX
11.

List
an
additional
contact
person
if
available.
Specialty
(
check
one)

12.
agronomic
XX
13.
economic
14.
15.
FAX
16.
Watsonville,
CA
95077
jsharp@
calstrawberry.
org
Crop
prefers
coastal
climate
of
cool
nights,
moderate
daytime
temperatures,
little
to
no
freezing,
no
rain
during
majority
of
production
season.
Grow
best
on
deep,
well­
drained,
sandy
loam
soils.
Crop
is
salt
sensitive.

831
724­
5973
Contact
name
Address
831
724­
1301
E­
mail
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
The
following
information
will
be
used
to
determine
the
amount
of
methyl
bromide
requested
and
the
contact
person
for
this
request.
It
is
important
that
we
know
whom
to
contact
in
case
we
need
additional
information
during
the
review
of
the
application.

Other
geographic
factors
that
may
affect
crop/
commodity
yield
(
e.
g.,
water
table).

California
Strawberry
Commission
California,
counties
of
San
Diego,
Orange,
Ventura,
Santa
Barbara,
San
Luis
Obispo,
Monterey,
Santa
Cruz,
San
Benito,
and
small
acreage
in
the
San
Jaoquin
Valley
primarily
Fresno
County.
See
Appendices
A
and
B.

Production
strawberries.
Some
rotation
to
vegetables;
broccoli,
celery,
lettuce,
radish,
leeks,
artichokes,
see
Appendix
C.

Soil
Type:

Organic
Matter:
Soil
type
Check
the
box(
es)
for
the
soil
types
and
percent
organic
matter
that
apply
to
your
area.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
soil
type.

Consortium
name
910
K.
Street,
Suite
325
Location
(
Enter
the
state,
region,
or
county.
Provide
more
detail
about
the
location
if
relevant
to
the
feasibility
of
alternatives
to
methyl
bromide.)

Crop/
commodity
(
Include
all
crops/
commodities
that
benefit
from
the
application
of
methyl
bromide
in
a
fumigation
cycle.
A
fumigation
cycle
is
the
period
of
time
between
methyl
bromide
fumigations.)

Climate
(
Individual
users
should
enter
their
climate
zone
designation
by
reviewing
the
U.
S.
climate
zone
map.
If
a
consortium
is
submitting
this
application,
please
indicate
the
estimated
percentage
of
consortium
users
in
each
climate
zone.
This
map
is
located
at
the
end
of
this
workbook
or
it
can
be
reviewed
online
at
http://
www.
usna.
usda.
gov/
Hardzone/
ushzmap.
html).
Hardiness
zone
9b,
minimum
temperatures
25­
30F,
climate
heavily
influenced
by
close
proximity
to
ocean.
Strawberries
do
best
in
areas
with
daytime
temperatures
in
the
70'
s
and
nighttime
temperatures
in
the
50'
s
(
Appendix
D)

P.
O.
Box
269
916
443­
2793
916
443­
3071
For
EPA
Use
Only
ID#

Contact
name
Address
Daytime
phone
E­
mail
Sacramento.
CA
95814
jwells@
exponent.
com
Jim
Wells
Worksheet
1.
Contact
and
Methyl
Bromide
Request
Information
17.
lbs.

17a.
acres
units
18.
Yes
XX
No
18a.

19.

20.

20a.

OMB
Control
#
4,500,000
Unit
of
Area
Treated
See
attached
narrative
"
Pest
Complex
Narrative",
Appendix
F,
and
Table
1,
Pest
Complex,
in
this
form
(
next
tab)
Year
2006
Quantity
ai
(
lb.)
of
Methyl
Bromide
4,500,000
Area
to
be
Treated
25,000
If
yes,
please
list
year
and
quantity
active
ingredient
(
ai)
of
methyl
bromide
requested
in
the
table
below
and
explain
why
you
need
authorization
for
multiple
years.

If
a
consortium
is
submitting
this
application,
the
data
below
should
be
the
total
for
the
consortium.

Explain
why
this
user
represents
the
typical
user
in
the
consortium.
25,000
For
the
reasons
stated
above
and
in
this
application,
the
consortium
is
requesting
the
full
amount
of
methyl
bromide
anticipated
to
be
used
in
the
2002
production
cycle
for
the
years
2006
and
2007.
If
the
two
year
trend
in
adoption
of
alternatives
(
2000­
2001)
continues,
or
if
economically
viable
alternatives
gain
registration,
future
applications
for
critical
use
exemptions
will
be
adjusted
accordingly.
25,000
For
EPA
Use
Only
ID#

4,500,000
17.
Approximately
3%
of
the
strawberry
acreage
in
2000
and
10%
of
the
acreage
in
2001
was
treated
with
alternatives
to
methyl
bromide.
If
this
trend
continues,
we
would
expect
that
alternatives
could
be
employed
on
approximately
30%
of
the
acreage
by
2005,
resulting
in
a
need
for
3,500,000
pounds
in
that
year.
However,
for
reasons
detailed
in
this
application,
the
sustainability
and
the
economic
viability
of
the
current
alternative
pest
control
regimes
is
questionable.
Therefore,
this
application
requests
the
amount
of
ai
the
consortium
expects
to
be
used
for
the
2002
production
cycle.

See
attached
narrative
"
Representative
UserDescription",
Appendix
I.

See
attached
narrative
"
Representative
UserDescription",
Appendix
I.
How
much
active
ingredient
(
ai)
of
methyl
bromide
are
you
requesting
for
2005?

If
applying
as
a
consortium
for
many
users
of
methyl
bromide,
please
define
a
representative
user
.
Define
exactly,
issues
such
as
size
of
the
operation
(
acres
treated
with
methyl
bromide
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications),
whether
the
representative
user
owns
or
rents
the
land
or
operation,
intensity
of
methyl
bromide
use
(
treat
regularly
or
only
when
pest
reaches
a
threshold),
pest
pressure,
etc.
Target
Pest(
s)
or
Pest
Problem(
s):
(
Be
as
specific
as
possible
about
the
species
or
classes
of
pests
relevant
to
the
feasibility
of
alternatives.)
If
a
consortium
is
submitting
this
application,
the
data
for
question
17
and
17a.
should
be
the
total
for
the
consortium.

Are
you
requesting
methyl
bromide
for
additional
years
beyond
2005?

acres
acres
2007
In
the
table
below,
area
is
defined
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post
harvest
operations,
and
square
feet
for
structural
applications.
How
much
area
will
this
be
applied
to?
Please
list
units.
Pest
Complex
Efficacy
of
Pest
Complex
Controlled
by
Methyl
Bromide/
Chloropicrin
Importance
Pest
Common
Name
Scientific
Name
Rating
MBr/
Pic
Chloropricrin
Metam
1,3­
D
Nematocides
Pic,
Metam
1,3­
D,
Pic
1,3,­
D,
Pic,
metam
Diseases
None
None
Verticillium
Wilt
Verticillium
dahlia
1
Some
control
Control
Some
control
Control
Control
Control
Phytophthora
root,

crown,
and
leather
rots
Phytophthora
cactorum,

Phytophthora
citricola,
Phytophthora
parasitica,

Phytophthora
megasperma
3
Control
Control
Some
control
Control
Control
Control
Red
Stele
root
rot
y
p
fragariae
3
Control
Control
Some
control
Control
Control
Control
Anthracnoseolletotrichum
accutatum
3
Control
Black
root
rot
Pythium
sp.,

Cylindrocarpon
sp.
5
Control
Control
Some
control
Control
Control
Control
Charcoal
rot
Macrophomina
phaseolina
5
Control
Control
Some
control
Control
Control
Control
Arthropods
Root
weevils
Otiorhynchus
cribicollis,
Nemocestes
incomptus,

Otiorhynchus
sulcatus,
Pantomorus
cervinus
7
Control
Cutworms
Agrotis
ipsilon,

Athetis
mindara
4
Control
Some
control
Some
control
Some
control
Some
control
strawberry
rootworm
Paria
fragariae
7
Control
white
grubs
Hoplia
oregona
8
Control
Some
control
Some
control
Some
control
Some
control
garden
symphalan
Scutigerlla
immaculata
9
Control
Control
Control
ground
mealy
bug
Rhizoecus
falcifer)
9
Control
Nematodes
Control
Foliar
helenchoides
fragariae
1
Control
Some
control
Control
Some
control
Control
Control
Root­
knot
Meloidogyne
hapla
1
Control
Some
control
Control
Some
control
Control
Control
InLine
/
Shank
Weeds
Some,
with
tarp
None
None
Some,
with
tarp
Some,
with
tarp
Common
Chickweed
Stellaria
media
1
Control
Some
control
Control
Control
Control
Control
Burning
nettle
Urtica
urens
1
Control
Filaree
Erodium
spp.
3
No
Control
No
Control
No
control
Bluegrass
Poa
annua
1
control
Some
control
Control
Califronia
Burclover
Medicago
spp.
2
No
Control
No
Control
No
control
Common
Purslane
Portulaca
oleracea
1
Control
Some
control
Control
Control
Control
Control
Pigweed
Amaranthus
retoflexus
2
Control
Control
Control
Control
Sowthistle
Sonchus
spp,
2
Control
Little
mallow
Malva
parviflora
1
Some
control
Little
control
Little
Control
Knotweed
Polygonum
aviculare
2
Some
control
No
Control
Control
Common
Grounsel
Senecio
vulgaris
3
Control
Control
Control
Common
Lambsquarters
Chenopodium
album
3
Control
Control
Control
Control
Shepardspurseaspsella
bursa­
pastoris
3
Control
Yellow
Nutsedge
Cyperus
esculentus
5
Control
Yellow
Sweetclover
Melilotus
indica
2
No
Control
No
Control
No
control
Worksheet
Title
Instructions
specific
to
each
worksheet
are
located
at
the
top
of
each
sheet.

2­
A
Methyl
Bromide
Use
for
1997
­
2000
This
worksheet
provides
data
in
actual
usage
for
1997­
2000.

2­
B
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
1997­

2000
This
worksheet
provides
crop/
commodity
yield
and
gross
revenue
for
1997
through
2000.

2­
C
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
2001
This
data
provides
historical
information
on
crop/
commodity
yield
and
gross
revenue
for
2001.

2­
D
Methyl
Bromide
Use
and
Costs
for
2001
This
worksheet
isolates
use
and
cost
data
for
2001.

2­
E
Methyl
Bromide
­
Other
Operating
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
operating
costs
in
order
to
estimate
the
impact
on
operating
profit
and
short­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

2­
F
Methyl
Bromide
­
Fixed
And
Overhead
Costs
for
2001
This
data
is
needed
to
estimate
a
baseline
for
total
costs
in
order
to
estimate
the
impact
on
profitability
and
long­
run
economic
viability
as
a
result
of
not
using
methyl
bromide.

Purpose
of
Data:
To
establish
a
baseline
estimate
of
crop/
commodity
yields,
gross
revenues,
and
costs
using
methyl
bromide.
Worksheet
2.
Methyl
Bromide
­
Historical
Use
of
Methyl
Bromide
Col
A:
Formulation
of
Methyl
Bromide
Col
B,
E,
H,
K:
Actual
Area
Treated
Col
C,
F,
I,
L:
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Col
D,
G,
J,
M:
Actual
Average
lbs.
ai
Applied
per
Area
A
B
C
D
E
F
G
H
I
J
K
L
M
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
Total
Actual
Area
Treated
Actual
Total
lbs.
ai
of
Methyl
Bromide
Applied
Average
lbs.
ai
Applied
per
Area
over
95%
methyl
bromide
75%
methyl
bromide,
25%
chloropicrin
67%
methyl
bromide,
33%
chloropicrin
50%
methyl
bromide,
50%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
__%
methyl
bromide,
__%
chloropicrin
All
formulations
of
methyl
bromide
16,823
4041595
240
18338
4251831
232
21252
5213472
214
20382
4231204
207
Comments:
Data
obtained
from
the
California
Department
of
Pesticide
Registration
Pesticide
Use
Reporting
database,

http://
www.
cdpr.
ca.
gov/
docs/
pur/
purmain.
htm
Active
ingredient
reported
for
use
on
strawberries
statewide
NOTE:
majority
of
methyl
bromide
applied
in
a
given
year
is
done
in
the
fall
for
the
next
year's
crop
Formulation
information
not
available.
Major
formulations
used
for
strawberries
are
67:
33
and
57:
43.

OMB
Control
#
The
average
application
rates
in
pounds
ai
of
methyl
bromide
per
area
are
automatically
calculated
from
the
previous
2
columns.
2000
Enter
the
total
actual
area
treated.
Note:
This
number
should
be
the
total
actual
area
treated
by
the
individual
user
or
total
actual
area
for
the
entire
consortium,
for
the
year
indicated.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Formulation
of
Methyl
Bromide
Enter
the
actual
total
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied.
Note:
This
number
should
be
the
total
pounds
ai
applied
by
the
individual
user
or
the
entire
consortium,
for
the
year
indicated.

1997
1998
1999
For
EPA
Use
Only
ID#

Worksheet
2­
A.
Methyl
Bromide
­
Use
1997­
2000
Enter
the
appropriate
data
in
Col
B­
M
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations.
If
you
enter
only
the
total
and
averages
for
all
formulations
in
the
last
row
of
the
table,
please
describe
in
the
comments
section
the
formulations
typically
used,
or
the
approximate
proportions
of
the
formulations
used.

If
a
consortium
is
submitting
this
application,
all
data
should
reflect
the
actual
data
for
the
consortium.
For
EPA
Use
Only
ID#

A
C
D
E
F
Year
Methyl
Bromide
was
Applied
Unit
of
Crop/
Commodity
(
pounds
fruit)
Crop/
Commodity
Yield
(
Lbs/
acre)
Price
(
dollar/
pound)
Revenue
(
per
acre)
$
0
1996
(
1997
crop)
865064400
39908
$
0.520
$
20,752
309671298
11256
$
0.270
$
3,039
1997
(
1998
crop)
835527600
38212
$
0.555
$
21,208
361753506
14343
$
0.204
$
2,926
1998
(
1999
crop)
924309600
43876
$
0.614
$
26,940
416962692
11946
$
0.312
$
3,727
1999
(
2000
crop)
1036602000
41512
$
0.486
$
20,175
365125626
11983
$
0.216
$
2,588
$
0
$
0
$
0
Total
Revenue
for
1997
$
23,791
Total
Revenue
for
1998
$
24,134
Total
Revenue
for
1999
$
30,667
Total
Revenue
for
2000
$
22,763
Average
Revenue
Per
Year
$
25,339
Comments:
Data
source
USDA
Agricultural
Marketing
Service,
Federal
State
Market
News,
www.
ams.
usda/
gov/
marketnews.
htm
Numbers
used
in
Section
18
applications,
See
also
Appendix
K,
tab
"
1997­
2000
Revenues"

Total
pounds
fresh
fruit
are
for
season
starting
January
1
through
mid
October
for
each
given
year
(
prices
not
available
after
mid­
October)

Price
is
a
weighted
average
calculated
from
daily
averages
throughout
the
season
from
Jan
1
through
mid
October
OMB
Control
#
Worksheet
2­
B.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
1997­
2000
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
actual
averages
for
the
consortium.

Enter
the
average
prices
received
by
the
users
for
the
year
and
crop/
commodity
indicated
(
1997­
2000).

This
number
is
calculated
automatically
using
the
values
you
entered
in
Cols.
D
and
E.
You
may
override
the
formula
to
enter
a
different
revenue.
Please
explain
why
the
revenue
amount
is
different
in
the
comment
section
below.

Enter
the
unit
of
measurement
for
each
crop/
commodity.

Be
sure
to
enter
the
year.
Use
as
many
rows
as
needed
for
each
year
for
all
the
crops/
commodities
in
the
fumigation
cycles
from
1997
to
2000.
If
a
fumigation
cycle
overlaps
more
than
one
calendar
year,
then
the
year
of
the
fumigation
cycle
is
the
year
methyl
bromide
was
applied.

Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
each
fumigation
cycle.
(
For
example,
if
normally
methyl
bromide
is
applied
and
tomatoes
are
grown
and
harvested
followed
by
peppers
without
an
additional
treatment
of
methyl
bromide,
then
both
tomatoes
and
peppers
would
be
part
of
the
same
fumigation
cycle.)
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.

Enter
the
number
of
units
of
crop/
commodities
produced
per
area.

If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
1997
­
2000
when
using
methyl
bromide.
Post­
harvest
and
structural
users
may
work
with
EPA
to
modify
this
form
to
accommodate
differences
in
operations
when
providing
gross
revenue
data.

Col.
A:
Year
Col.
B:
Crop/
Commodity
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Revenue
Crop/
Commodity
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Average
Revenue
per
Year:
The
average
revenue
per
year
is
calculated
automatically
using
the
summary
data
you
enter
for
each
year.

Total
Revenue
for
1997­
2000
Enter
the
total
revenue
per
year
by
adding
the
revenue
for
all
crops
for
that
year.

Strawberry
fresh
Strawberry
processed
B
Strawberry
fresh
Strawberry
processed
Strawberry
fresh
Strawberry
processed
Strawberry
fresh
Strawberry
processed
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
time)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
pounds/
acre)
Price
(
dollar/
pound)
Revenue
($/
acre)

Strawberry,
Fresh
January
13512500
1322
$
1.290
$
1,705
Strawberry,
Fresh
February
25415000
2486
$
1.109
$
2,757
Strawberry,
Fresh
March
53072500
5191
$
0.912
$
4,735
Strawberry,
Fresh
April
129872950
12704
$
0.666
$
8,461
Strawberry,
Fresh
May
83725750
8190
$
0.363
$
2,973
Strawberry,
Fresh
June
4169900
408
$
0.494
$
201
Subtotal,
lbs/
acre
30301
Subtotal
$
20,832
Strawberry,
Processed
April
2960262
290
$
0.306
$
89
Strawberry,
Processed
May
76302774
7464
$
0.306
$
2,284
Strawberry,
Processed
June
92174400
9016
$
0.306
$
2,759
Strawberry,
Processed
July
11687598
1143
$
0.306
$
350
Strawberry,
Processed
August
351558
34
$
0.306
$
11
Subtotal,
lbs/
acre
17947
Subtotal
$
5,492
Total
Yield,
lbs/
acre
48249
Total
Revenue
$
26,324
Comments:
Because
of
market
changes,
prices
are
weighted
monthly
averages,
See
Appendix
K,
"
Monthly
Prices"
tab
Data
source
USDA
Agricultural
Marketing
Service,
Federal
State
Market
News,
www.
ams.
usda/
gov/
marketnews.
htm
Total
pounds
fresh
fruit
are
for
season
starting
January
1
through
mid
October
for
each
given
year
(
prices
not
available
after
mid­
October
Total
acres
for
Southern
region
10,223
Market
for
2001
broken
into
South
(
San
Diego,
Orange,
and
Ventura
Counties)
region
because
of
harvest
schedule
Note
ratio
of
Fresh
to
Processed
is
63%
to
37%

OMB
Control
#

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Revenue
is
automatically
calculated
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
t
Enter
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,

grade,
market
(
e.
g.
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
ro
Enter
the
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
2001when
using
methyl
bromide.
Post­
harvest
users
may
modify
this
form
to
accommodate
differences
when
providing
gross
revenue
data.
If
2001
was
not
a
typical
year
for
the
individual
or
f
Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
the
fumigation
cycle
(
interval
between
fumigations)
beginning
with
the
treatment
of
methyl
bromide
in
2001.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Col.
A:
Crop/
Commodity
Worksheet
2­
C
South.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
time)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
pounds/
acre)
Price
(
dollar/
pound)
Revenue
($/
acre)

Strawberry,
Fresh
February
135700
9
$
1.109
$
10
Strawberry,
Fresh
March
2010200
138
$
0.778
$
107
Strawberry,
Fresh
April
31156950
2138
$
0.551
$
1,178
Strawberry,
Fresh
May
164310850
11273
$
0.413
$
4,656
Strawberry,
Fresh
June
156811700
10758
$
0.525
$
5,648
Strawberry,
Fresh
July
110612750
7589
$
0.596
$
4,523
Strawberry,
Fresh
August
81290050
5577
$
0.790
$
4,406
Strawberry,
Fresh
September
49579260
3401
$
0.683
$
2,323
Strawberry,
Fresh
October
34718500
2382
$
0.737
$
1,755
Strawberry,
Fresh
November
4052600
278
$
0.648
$
180
Subtotal,
lbs/
acre
non­
rotation
40883
Subtotal
$
22,851
Subtotal,
lbs/
acre
rotation
43533
Subtotal
$
24,787
Strawberry,
Processed
April
2470104
169
$
0.306
$
52
Strawberry,
Processed
May
18981198
1302
$
0.306
$
398
Strawberry,
Processed
June
53232084
3652
$
0.306
$
1,118
Strawberry,
Processed
July
21421638
1470
$
0.306
$
450
Strawberry,
Processed
August
14161176
972
$
0.306
$
297
Strawberry,
Processed
September
9603846
659
$
0.306
$
202
Strawberry,
Processed
October
3563802
244
$
0.306
$
75
Strawberry,
Processed
November
1726146
118
$
0.306
$
36
Subtotal,
lbs/
acre
non­
rotation
8224
Subtotal
$
2,516
Subtotal,
lbs/
acre
rotation
8587
Subtotal
$
2,628
Total
Yield,
lbs/
acre
non­
rotation
49107
Total
Revenue
non­
rotation
$
25,367
Total
Yield,
lbs/
acre
rotation
52120
Total
Revenue
rotation
$
27,414
Comments:
Because
of
market
changes,
prices
are
weighted
monthly
averages,
See
Appendix
K,
"
Monthly
Prices"
tab
October/
November
revenues
removed
for
ground
prep
and
fume
for
coming
year
for
Non­
Rotation
grower
Data
source
USDA
Agricultural
Marketing
Service,
Federal
State
Market
News,
www.
ams.
usda/
gov/
marketnews.
htm
Total
pounds
fresh
fruit
are
for
season
starting
January
1
through
mid
October
for
each
given
year
(
prices
not
available
after
mid­
October)

Total
acres
for
Northern
Region
are
14576
Market
for
2001
broken
into
South
(
Santa
Barbara,
San
Luis
Obisbo,
Santa
Cruz,
and
Montery
Counties)
region
because
of
harvest
schedule
Note
ratio
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#

The
purpose
of
this
worksheet
is
to
estimate
the
gross
revenue
for
2001when
using
methyl
bromide.
Post­
harvest
users
may
modify
this
form
to
accommodate
differences
when
providing
gross
revenue
data.
If
2001
was
not
a
typical
year
for
the
individual
or
f
Enter
all
crops/
commodities
that
benefit
from
methyl
bromide
in
the
fumigation
cycle
(
interval
between
fumigations)
beginning
with
the
treatment
of
methyl
bromide
in
2001.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Col.
A:
Crop/
Commodity
Worksheet
2­
C
North.
Methyl
Bromide
­
Crop/
Commodity
Yield
and
Gross
Revenue
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
the
representative
user
for
the
consortium.

Enter
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

Revenue
is
automatically
calculated
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
revenue
amount
is
different
in
t
Enter
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,

grade,
market
(
e.
g.
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
more
than
one
ro
Enter
the
unit
of
measurement
for
each
crop/
commodity.

Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Area
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Area
over
95%
methyl
bromide
$
0.00
75%
methyl
bromide,
25%
chloropicrin
$
0.00
67%
methyl
bromide,
33%
chloropicrin
$
0.00
50%
methyl
bromide,
50%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
$
0.00
Total
South
Region,
custom
application
$
1,778.00
10223
$
1,778.00
Comments:
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

South
Coast
Region
­
Ventura
County",
http://
coststudies.
ucdavis.
edu
See
Appendix
L
OMB
Control
#
For
EPA
Use
Only
ID#

If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,
all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
If
you
pr
If
the
methyl
bromide
is
custom
applied
then
put
the
cost
per
area
in
Column
G
and
fill
in
the
average
lb
ai
of
methyl
bromide
applied
per
area
(
Col
B)
and
the
Total
Actual
Area
Treated
(
Col
F).

Worksheet
2­
D
South.
Methyl
Bromide
­
Use
and
Costs
for
2001
If
a
consortium
is
submitting
this
application,
the
data
in
Cols.
B,
C,
D,
and
E
should
reflect
the
representative
user
in
the
consortium.
The
data
in
Col.
F
should
reflect
the
actual
area
treated
by
all
users
in
the
consortium.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Enter
the
appropriate
data
in
Col
B­
G
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations
of
methyl
bromide.
If
you
just
enter
data
in
the
bottom
row
in
the
table
(
All
formulations
of
methyl
bromide),
please
describe
in
th
Enter
the
average
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied
per
area.

Enter
the
average
price
per
pound
active
ingredient
(
ai)
of
methyl
bromide
in
Col.
C
and
the
average
cost
of
applying
methyl
bromide
per
area
treated
in
Col.
D.
In
Col.
E,
enter
the
average
other
costs
per
area
associated
with
applying
methyl
bromide
(
e.
g
Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.
Col.
A:
Formulation
of
Methyl
Bromide
Col
B:
Average
lbs.
active
ingredient
(
ai)
of
Methyl
Bromide
Applied
per
Area
Cols.
C,
D,
E,
G:
Prices
and
Costs
Col.
F:
Actual
Area
Treated
A
B
C
D
E
F
G
Formulation
of
Methyl
Bromide
Lb.
ai
of
Methyl
Bromide
Applied
per
Area
(
2001
Average)
Price
per
lb.
ai
of
Methyl
Bromide
(
2001
Average)
Cost
of
Applying
Pesticide
per
Area
(
2001
Average)
Other
MBr
Costs
(
e.
g.
tarps,

etc.)
per
Area
(
2001
Average)
Total
Actual
Area
Treated
in
the
Consortium
Cost
per
Area
over
95%
methyl
bromide
$
0.00
75%
methyl
bromide,
25%
chloropicrin
$
0.00
67%
methyl
bromide,
33%
chloropicrin
$
0.00
50%
methyl
bromide,
50%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
__%
methyl
bromide,
__%
chloropicrin
$
0.00
$
0.00
Total
North
Region,
custom
application
$
1,728.00
14920
$
1,728.00
Comments:
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

Central
Coast
,
http://
coststudies.
ucdavis.
edu
Fumigation
costs
(
flat
fume)
in
Monterey/
Santa
Cruz,
$
1,728/
acre
from
Cost
of
Production,
Central
Coast
Region
See
Appendix
L
OMB
Control
#

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Enter
the
appropriate
data
in
Col
B­
G
for
each
formulation,
if
known,
and/
or
the
totals
and
averages
for
all
formulations
of
methyl
bromide.
If
you
just
enter
data
in
the
bottom
row
in
the
table
(
All
formulations
of
methyl
bromide),
please
describe
in
th
Enter
the
average
pounds
active
ingredient
(
ai)
of
methyl
bromide
applied
per
area.

Enter
the
average
price
per
pound
active
ingredient
(
ai)
of
methyl
bromide
in
Col.
C
and
the
average
cost
of
applying
methyl
bromide
per
area
treated
in
Col.
D.
In
Col.
E,
enter
the
average
other
costs
per
area
associated
with
applying
methyl
bromide
(
e.
g
Enter
the
actual
area
treated.
Note:
This
number
should
be
the
total
area
treated
by
all
users
in
the
consortium.

For
EPA
Use
Only
ID#

If
2001
was
not
a
typical
year
for
the
individual
or
for
the
representative
user
of
a
consortium,
the
applicant
may
provide
additional
data
for
a
different
year.
However,
all
applicants
must
complete
this
worksheet
for
the
year
2001
regardless.
If
you
pr
If
the
methyl
bromide
is
custom
applied
then
put
the
cost
per
area
in
Column
G
and
fill
in
the
average
lb
ai
of
methyl
bromide
applied
per
area
(
Col
B)
and
the
Total
Actual
Area
Treated
(
Col
F).

Worksheet
2­
D
North.
Methyl
Bromide
­
Use
and
Costs
for
2001
If
a
consortium
is
submitting
this
application,
the
data
in
Cols.
B,
C,
D,
and
E
should
reflect
the
representative
user
in
the
consortium.
The
data
in
Col.
F
should
reflect
the
actual
area
treated
by
all
users
in
the
consortium.
For
EPA
Use
Only
ID#

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
Ground
Preparation
$
627.00
$
0.00
Post
Fumigation
Preparation
$
1,454.00
$
0.00
Planting
$
2,356.00
$
0.00
Pesticides
$
1,253.00
$
0.00
Fresh
Harvest
$
12,850.00
$
0.00
Processed
Harvest
$
3,537.00
$
0.00
Weeding
$
713.00
$
0.00
Field
clearing
$
298.00
$
0.00
Assessment
$
131.00
$
0.00
Interest
on
Capital
$
1,204.00
$
0.00
$
0.00
$
0.00
$
0.00
Total
Custom
per
Area
$
24,423.00
User
Total
per
area
$
0.00
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

South
Coast
Region
­
Ventura
County",
http://
coststudies.
ucdavis.
edu
See
next
page
and
Appendix
L
OMB
Control
#
Operation
Done
by
User
Worksheet
2­
E
South.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Custom
Operation
Cost
per
Area
Operation
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Do
not
include
methyl
bromide
costs.

Identify
the
typical
equipment
used
for
operations
done
by
user.
Please
be
specific,
such
as
tractor
horsepower.
No
cost
data
is
required
in
this
column.

If
you
do
not
incur
custom
operation
costs,
enter
the
material
cost
per
area.

The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.

If
you
do
not
incur
custom
operation
costs,
enter
the
labor
cost
per
area.

Enter
all
operating
costs
except
methyl
bromide
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Enter
these
costs
in
Col
B
for
custom
operations,
or
in
Col
C
and
D
for
operations
done
by
user.

Identify
in
Col
A
the
operations
(
except
methyl
bromide)
to
which
the
costs
apply.
For
growers,
these
operations
should
include
but
are
not
limited
to
(
1)
prepare
soil,
(
2)
fertilize,
(
3)
irrigate,
(
4)
plant,
(
5)
harvest,
(
6)
other
pest
controls,
etc.
You
must
include
all
other
operating
costs.

If
you
incur
custom
operation
costs,
enter
those
costs
in
Col.
B.

Submit
crop
budgets
for
each
crop,
if
available.
You
may
submit
crop
budgets
electronically
or
in
hard
copy.
If
your
costs
are
significantly
different
than
the
crop
budgets,

please
explain
in
the
comments.
Cost
of
Production
Operations
Breakdown
Ventura
County
2001
Operation
Detail
Elements
Individual
Costs
($/
acre)
Total
for
Operation
Ground
Preparation
400
627
227
Post­
Fumigation
Preparation
List
Bed
4
1454
Shape
Beds
2X
6
Fertilize
18­
6­
8
364
Install
Drip
Tape
2
line/
bed
274
369
44
Lay
Laterals/
Connect
Drip
110
Irrigate­
Drip
270
Punch
Holes
13
Planting
Plant
2352
2356
Roll
Plants
4
Pesticides
Disease­
Mildew
49
1253
Disease­
Botrytis/
Mildew
90
Insect­
Predatory
Mite
2X
323
285
Disease­
Botrytis/
Mildew
98
Disease­
Botrytis/
Mildew
73
Disease­
Botrytis/
Mildew
1X
93
Disease­
Botrytis/
Mildew
2X
124
Inssects­
Cutworms
31
87
Fresh
Harvest
Harvest/
Record
Fresh
12573
12850
Haul/
Load
Fresh
277
Processed
Harvest
Harvest
Freezer/
Haul/
Record
3537
3537
Weed­
Hand
Weed­
Hand
713
713
Field
Clearing
Cut
Mulch
Prior
to
Harvest
146
298
152
Assessment
131
131
Interest
on
Operating
Capital
Interest
@
10.51%
1204
1204
Cash
Overhead
(
Not
Included)
3050
NonCash
Overhead
(
Not
Included)
455
Disease/
Insect­
Botrytis/
Mildew/
Worms
Remove/
Haul/
Dump­
Plastic/
Tape
Land
prep:
Disc,
Plow,
Subsoil,
Level
Irrigate­
Sprinkler/
Layout,
Pickup
Pipe
Lay
Mulch
Cut/
Grade
Roads/
Maintain
Roads
Disease/
Insect­
Botrytis/
Mildew/
Mite
For
EPA
Use
Only
ID#

Col
A:
Operation
Col
B:
Custom
Operation
Cost
Col
C:
Material
Cost
per
Area
Col
D:
Labor
Cost
per
Area
Col
E:
Total
Cost
per
Area
Col
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
Typical
Equipment
Used
$
0.00
Ground
Preparation
$
263.00
$
0.00
Post
Fumigation
Preparation
$
1,348.00
$
0.00
Planting
$
1,707.00
$
0.00
Pesticides
$
1,153.00
$
0.00
Fresh
Harvest
$
16,077.00
$
0.00
Processed
Harvest
$
1,044.00
$
0.00
Weeding
$
893.00
$
0.00
Field
clearing
$
105.00
$
0.00
Assessment
$
133.00
$
0.00
Interest
on
Capital
$
1,250.00
$
0.00
$
0.00
Total
Custom
per
Area
$
23,973.00
User
Total
per
area
$
0.00
Weighted
average
of
Santa
Maria
and
Watsonville
areas
representative
of
Northern
region
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

Central
Coast
,
http://
coststudies.
ucdavis.
edu
See
next
page
and
Appendix
L
OMB
Control
#
Operation
Done
by
User
Worksheet
2­
E
North.
Methyl
Bromide
­
Other
Operating
Costs
for
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Custom
Operation
Cost
per
Area
Operation
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Do
not
include
methyl
bromide
costs.

Identify
the
typical
equipment
used
for
operations
done
by
user.
Please
be
specific,
such
as
tractor
horsepower.
No
cost
data
is
required
in
this
column.

If
you
do
not
incur
custom
operation
costs,
enter
the
material
cost
per
area.

The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.

If
you
do
not
incur
custom
operation
costs,
enter
the
labor
cost
per
area.

Enter
all
operating
costs
except
methyl
bromide
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Enter
these
costs
in
Co
Identify
in
Col
A
the
operations
(
except
methyl
bromide)
to
which
the
costs
apply.
For
growers,
these
operations
should
include
but
are
not
limited
to
(
1)
prepare
soil,
(
2)
fertilize,
(
3)
irrigate,
(
4)
plant,
(
5)
harvest,
(
6)
other
pest
controls,
etc.
Y
If
you
incur
custom
operation
costs,
enter
those
costs
in
Col.
B.

Submit
crop
budgets
for
each
crop,
if
available.
You
may
submit
crop
budgets
electronically
or
in
hard
copy.
If
your
costs
are
significantly
different
than
the
crop
budgets,

please
explain
in
the
comments.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Cost
Item
Description
Allocation
Method
Cost
per
Area
Cash
and
Non­
cash
Overhead
$
5,070.00
Total
$
5,070.00
Comments:
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

Central
Coast
,
http://
coststudies.
ucdavis.
edu
See
next
page
and
Appendix
L
OMB
Control
#
Worksheet
2­
F
North.
Methyl
Bromide
Fixed
and
Overhead
Costs
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.

Enter
all
fixed
and
overhead
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Cost
Item
Description
Allocation
Method
Cost
per
Area
Cash
Overhead
$
3,050.00
Non­
cash
overhead
$
455.00
Total
$
3,505.00
Comments:
Data
from
University
of
California
Cooperative
Extension,
"
2001
Sample
Costs
to
Produce
Strawberries,

South
Coast
Region
­
Ventura
County",
http://
coststudies.
ucdavis.
edu
See
next
page
and
Appendix
L
OMB
Control
#
Worksheet
2­
F
South.
Methyl
Bromide
Fixed
and
Overhead
Costs
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.

Enter
all
fixed
and
overhead
costs
incurred
during
the
fumigation
cycle
(
interval
between
fumigations)
beginning
in
2001.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
Cost
of
Production
Operations
Breakdown
Central
Coast
2001
(
Northern
Growers)
Santa
Maria
Monterey/
Santa
Cruz
(
26.2%
SM
+
73.8%
M/
SC)

Operation
Detail
Elements
Costs
($/
acre)
Costs
($/
ac
Total
for
Operation
Ground
Preparation
$
263
152
Fertilize
469
Land
Prep:
Disc,
Subsoil,
Chisel,
Level
136
Post­
Fumigation
Preparation
Install
Drip
Tape
2
line/
bed
$
1,348
List/
Shape
52"
beds
9
Shape
Beds
2X
Fertilize
preplant
230
Install
Drip
Tape
2
line/
bed
275
277
412
55
Lay
Laterals/
Connect
Drip
110
7
Irrigate­
Drip
421
338
Irrigate­
Sprinkle/
Layout/
Pickup
Pipe
279
131
Punch
Holes
13
13
Planting
Plant
1994
1601
$
1,707
Roll
Plants
4
Pesticides
Worms
25
$
1,154
Botrytis
55
Insect­
Predatory
Mite
2X
367
Botrytis/
Mildew
45
84
Botrytis/
Mildew
67
Mildew/
Mite
143
100
Mildew/
Mite
125
Botrytis/
Mildew/
Mite
138
59
Botrytis/
Mildew/
Lygus
46
97
35
37
Botrytis/
Mildew/
Worm
363
Botrytis/
Lygus
71
Botrytis/
Mite
136
Botrytis/
Mite/
Worm
195
Botrytis/
Mite/
Worm/
Lygus
49
Fresh
Harvest
Harvest/
Record
Fresh
9398
17903
$
16,077
Haul/
Load
Fresh
215
469
Processed
Harvest
Harvest/
Record
Freezer
3799
$
1,044
Haul/
Load
Freezer
186
Weed­
Hand
Weed­
Hand
713
957
$
893
Field
Clearing
Yearend
Plastic
Retrieval/
Landfill
108
102
$
104
Assessment
118
138
$
133
Interest
on
Operating
Capital
Interest
@
10.51%
911
1370
$
1,250
Cash
Overhead
(
Not
Included)
2,014
1937
$
1,957
NonCash
Overhead
(
Not
Included)
429
4065
$
3,112
OMB
Control
#
Land
prep:
Disc/
Roll,
Subsoil,
Plow,
Level/

Smooth
Field,
List/
Shape
Beds,
Fertilize
Lay
Mulch
Cut/
Grade
Roads/
Maintain
Roads
Mildew/
Mite/
Lygus
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
26,201
$
26,324
$
122.98
Northern
Region
(
w/
o
overhead)

Non­
rotation
$
25,701
$
25,367
­$
333.57
Rotation
$
25,701
$
27,414
$
1,713.10
Total
Revenues
for
South
$
122.98
Total
Revenues
for
North
$
689.77
Comments:
Overhead
cost
for
both
North
and
South
put
both
representative
users
in
the
red
unless
they
bed
fume
Overhead
costs
not
included
at
this
time
as
best
case
scenario
OMB
Control
#
Worksheet
2­
G.
Methyl
Bromide
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Worksheet
Title
3­
A
Alternatives
­
Technical
Feasibility
This
form
is
used
to
obtain
information
on
the
chemical
alternatives
identified
by
the
Methyl
Bromide
Technical
Options
Committee
(
MBTOC)
that
are
registered
for
use
in
the
United
States,
as
well
as
the
non­
chemical
alternatives
identified
by
the
MBTOC.
Applicants
must
address
the
technical
feasibility
of
all
the
chemical
and
non­
chemical
alternatives
identified
on
the
list.

3­
B
Alternatives
­
Pest
Control
Regimen
Costs
This
form
is
used
to
estimate
the
cost
of
using
alternative
pest
control
regimens.

3­
C
Alternatives
­
Crop/

Commodity
Yield
and
Gross
Revenue
This
form
is
used
to
estimate
the
crop/
commodity
yields
and
gross
revenues
when
using
alternative
pest
control
regimens.

3­
D
Alternatives
­
Changes
in
Other
Costs
This
form
is
used
to
estimate
change
in
any
other
costs
as
a
result
of
using
the
alternatives.

Complete
each
of
the
worksheets
below
(
3­
A,
3­
B,
3­
C,
and
3­
D)
for
each
alternative
pest
control
regimen
listed
in
the
"
U.
S.
Matrix"
for
chemical
controls
(
www.
epa.
gov/
ozone/
mbr/
cueqa.
html)
and
the
"
International
Matrix"
for
non­
chemical
pest
controls
(
www.
epa.
gov/
ozone/
mbr/
cue).
Each
worksheet
contains
a
place
holder
in
the
title
for
you
to
insert
the
name
of
the
specific
alternative
pest
control
regimen
addressed.
You
should
add
additional
worksheets
as
required.
Please
add
a
number
designation
to
each
worksheet
title
to
indicate
a
different
alternative.
For
example,
for
the
first
alternative
pest
control
regimen
label
the
worksheets
as
3­
A(
1),
3­
B(
1),
3­
C(
1),
and
3­
D(
1).
For
the
second
alternative
pest
control
regimen
label
the
worksheets
3­
A(
2),
3­
B(
2),
3­
C(
2),
and
3­(
D)(
2).

Purpose
of
Data
on
Alternative
Pest
Control
Regimens:
To
estimate
the
loss
as
a
result
of
not
having
methyl
bromide
available.
EPA
needs
to
compare
data
(
yields,
crop/
commodity
prices,
gross
revenues
and
costs)
on
the
use
of
methyl
bromide
and
alternative
pest
control
regimens.

Worksheet
3.
Alternatives
­
Feasibility
of
Alternative
Pest
Control
Regimens
Enter
all
alternative
pesticides
and
pest
control
methods
(
and
associated
cost
and
yield
data)
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
fumigation
cycle
worksheet
for
a
comprehensive
definition.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXX
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Nematocide
Technical
Feasibility
wrt
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Nematocides
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Enzone
and
fozthiazate,
the
nematocides
mentioned
in
2001
TEAP
report
are
not
registered
in
US.

Avermectin,
also
from
the
2001
TEAP
report,
is
not
registered
in
California
for
use
on
nematodes
(
http://
www.
cdpr.
ca.
gov/
docs/
label/
labelque.
htm#
regprods)

See
Nematocide
Narrative,
Appendix
M
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Nematocide
Narrative,
Appendix
M
Fosthiazate
is
only
active
against
nematodes
and
does
not
impact
soil
borne
disease
or
weeds
Nematocides
do
not
encompass
the
entire
pest
complex
of
strawberries
in
California
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Nematocide
Narrative,
Appendix
M
Worksheet
3­
A.
Nematocide
Technical
Feasibility
wrt
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Nematocide
Narrative,
Appendix
M
OMB
Control
#

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Worksheet
3­
A
2.
Alternatives
­
Nematocide
Technical
Feasibility
with
Respect
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Nematocides
[
Insert
Study
Title]
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
XXX
Caps
impact
from
11,000
­
18,000
acres
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXX
See
Appendix
N,
"
1,3­
Dichloropropene
Narrative"

Local
restrictions
near
sensitive
sites
and
buffer
zone
requirements
See
Telone
II
use
Label,
Appendix
G,
http://
www.
cdpr.
ca.
gov/
docs/
dprdocs/
methbrom/
telone/
mgmtplan.
pdf,

Appendix
O,
http://
www.
cdpr.
ca.
gov/
docs/
enfcmpli/
penfltrs/
penf2001/
2001040.
pdf
Appendix
P,
Impact
of
Township
Caps
on
California
Strawberry
Production
For
EPA
Use
Only
ID#

Worksheet
3­
A.
1,3­
Dichloropropene
Technical
Feasibility
wrt
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

1,3­
Dichloropropene
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Appendix
N,
"
1,3­
Dichloropropene
Narrative"
Work
being
done
is
in
combination
with
other
materials
imited
activity
and
others
have
seen
rapid
loss
of
activity
in
some
instances.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Primarily
effective
against
nematodes.
MBTOC
report
states
used
alone
has
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Appendix
N,
"
1,3­
Dichloropropene
Narrative"
Worksheet
3­
A.
1,3­
Dichloropropene
Technical
Feasibility
wrt
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
N,
"
1,3­
Dichloropropene
Narrative"

OMB
Control
#

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Worksheet
3­
A
1.
Alternatives
­
1,3­
D
Technical
Feasibility
with
Respect
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

1,3­
Dichloropropene
[
Insert
Study
Title]
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXX
See
Appendix
Q,
"
Metam
Sodium
Narrative"
Metam
Sodium
is
classified
as
a
toxic
air
contaminant
by
the
California
Department
of
Pesticide
Regulation
and
is
currently
undergoing
re­
evaluation.
Current
buffer
zone
permit
requirements
Appendix
R,
http://
www.
cdpr.
ca.
gov/
docs/
empm/
pubs/
mitc/
augfinl02/
augdirdeter.
pdf
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Metam
Sodium
Technical
Feasibility
wrt
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Metam
Sodium
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
are
in
danger
of
becoming
impractical
(
500
feet
possibly)
which
would
severely
limit
its
usability
Appendix
S,
http://
www.
cdpr.
ca.
gov/
docs/
dprdocs/
methbrom/
mb_
main.
htm
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
XXX
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Appendix
Q,
"
Metam
Sodium
Narrative"
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Metam
sodium
CUE
Narrative
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Appendix
Q,
"
Metam
Sodium
Narrative"
Worksheet
3­
A.
Metam
Sodium
Technical
Feasibility
wrt
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:

OMB
Control
#
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Metam
Sodium
[
Insert
Study
Title]

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
See
Appendix
Q,
"
Metam
Sodium
Narrative"

See
Appendix
T,
"
Alt
Sum
Yield
Data.
xls",
tab
Metam
Worksheet
3­
A.
Alternatives
­
Metam
Sodium
Technical
Feasibility
with
Respect
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J,
M:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Gallons
of
product
per
Acre
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)
$
0.00
$
0.00
Metam
Sodium
Drip
Application
50
gals
$
698.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
Comments:

If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

See
Appendix
U,
"
mebr_
alts_
prices.
xls"

See
Appendix
V,
"
Vegetable
Rotation
Narrative"

OMB
Control
#
For
EPA
Use
Only
ID#

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.

B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regardin
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Metam
Sodium
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
lbs
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)
$
0.00
$
0.00
South
$
0.00
Strawberries
Fresh
and
Processed
Total
yield
per
acre
39,081
$
0.00
Fresh
63%
24,621
$
0.695
$
17,111.77
Processed
37%
14,460
$
0.306
$
4,424.79
$
0.00
North
$
0.00
Strawberries
Fresh
and
Processed
$
0.00
Rotation
42,217
Fresh
84%
35,463
$
0.576
$
20,426.42
Processed
16%
6,755
$
0.306
$
2,066.96
Non­
Rotation
39,776
Fresh
84%
33,412
$
0.576
$
19,245.38
Processed
16%
6,364
$
0.306
$
1,947.45
$
0.00
$
0.00
Total
Revenue
South
$
21,536.56
Total
Rev
Rot
North
$
22,493.38
Total
Rev
Non­
Rot
Nor
$
21,192.83
Comments:
Weighted
average
yearly
price
for
fresh
berries
is
$
0.695
South
and
$
0.576
based
on
calculations
used
for
Section
18
applications,
Appendix
K
Percentage
of
fresh
vs
processed
based
on
2001
baseline,
Worksheets
2­
CS
and
2­
CN,
63:
37
and
84:
16
respectively
Crop/
Commodity
Yield
calculated
from
the
average
percent
yield
from
California
strawberry
trials
of
81%
of
MBC
Standard,
Appendix
T,
Metam
tab
Note
ratio
in
South
of
Fresh
to
Processed
is
63%
to
37%

Note
ratio
in
North
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#
Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternati
Metam
Sodium
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
f
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
m
Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
diff
Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
Custom
Fumigation
$
698
$
0.00
$
0.00
Lost
revenue
for
early
crop
pull
S
$
11
$
0.00
$
0.00
Lost
revenue
for
early
crop
pull
N
$
1,262
$
0.00
$
0.00
Additional
rent
for
rotation
North
525
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
South
Total
Rotation
per
Area
$
708.52
User
Total
per
area
$
0.00
North
Total
Non­
Rotation
per
Area
$
1,960.40
North
Total
Rotation
per
Area
$
1,223.00
Comments:
Custom
fumigation
cost,
Apprendix
U
Lost
crop
revenue
for
the
North
based
on
loss
of
two
weeks
of
September
income
See
Appendix
Q,
"
Metam
Sodium
Narrative"

OMB
Control
#

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
Metam
Sodium
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operatio
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
25,132
$
21,537
­$
3,594.97
Northern
Region
(
w/
o
overhead)
Rotation
$
25,196
$
22,493
­$
2,702.62
Non­
Rotation
$
25,933
$
21,193
­$
4,740.57
Total
Revenues
for
South
­$
3,594.97
Total
Revenues
for
North
Rotation
­$
2,702.62
Comments:
Total
Revenues
for
North
Non­
Rotation
­$
4,740.57
Overhead
costs
not
included
at
this
time
as
best
case
scenario
See
Appendix
Q,
"
Metam
Sodium
Narrative"

OMB
Control
#
Worksheet
3­
E.
Metam
Sodium
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
xxxx
Efficacious
amount
of
200
lbs/
acre
or
more
not
allowed
or
discouraged
by
County
Ag
Commissioners
(
Personal
Communication,
Ag
Commissioners
in
Orange,
Ventura,
Santa
Barbara,
Santa
Cruz,
and
Monterey
Counties)

See
Appendix
W,
"
Chloropicrin
Narrative"
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Chloropicrin­
Technical
Feasibility
to
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Chloropicrin
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Appendix
W,
"
Chloropicrin
Narrative"
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Appendix
W,
"
Chloropicrin
Narrative"
Worksheet
3­
A.
Chloropicrin­
Technical
Feasibility
to
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
W,
"
Chloropicrin
Narrative"

See
Appendix
T,
"
Alt
Sum
Yield
Data.
xls"

OMB
Control
#
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Chloropicrin
[
Insert
Study
Title]

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
for
pest
1
in
the
Col
F
header
below
and
stunt
nematode
for
pest
2
in
the
Col.
L
header
below.
In
the
comments
section
describe
the
rating
system
used
(
0
to
100
scale
where
0
is
no
control,
number
of
nematodes
per
gram
of
soil,
number
of
colony
forming
units
per
gram
of
soil,

etc.).

Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
should
directly
compare
methyl
bromide
and
the
alternative
regimen.

List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
treatment,
and
6
weeks
after
treatment.
In
this
example,
type
over
the
words
"
Rating
Interval
1"
with
"
pre­
treatment",
type
over
"
Rating
Interval
2"
with
"
3
weeks",
and
type
over
"
Rating
Interval
3"
with
"
6
weeks."
If
you
are
completing
the
printed
version,
please
define
Rating
Interval
in
the
comments
below.
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J,
M:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)
$
0.00
$
0.00
$
0.00
Chloropicrin
EC,
drip
application
24
gallons
$
1,455.00
Chloropicrin,
shank
flat
application
200
lbs
$
1,208.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
$
2,663.00
Comments:

If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

See
Appendix
U,
"
mebr_
alts_
prices.
xls"

See
Appendix
V,
"
Vegetable
Rotation
Narrative"

OMB
Control
#
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied.
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Chlorpicrin
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
during
the
interval
between
fumigations
(
e.
g.
tomatoes
followed
by
peppers
in
a
single
growing
season,
or
strawberries
followed
by
lettuce
over
2
or
3
years)
include
all
of
the
pesticides
that
replace
methyl
bromide
for
the
entire
interval.
Do
not
include
pesticides
that
are
used
along
with
methyl
bromide­­
enter
only
the
additional
pest
control
if
methyl
bromide
were
not
available.

Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Col.
I.
Enter
any
other
costs
associated
with
applying
this
product
in
Col.
J,
specifying
what
they
are
in
the
comments
section
at
the
bottom
of
this
sheet.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
For
EPA
Use
Only
ID#

See
attached
narrative
Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.

B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regarding
the
same
product.

Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
lbs
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)
$
0.00
$
0.00
South
$
0.00
Strawberries
Fresh
and
Processed
Total
yield
per
acre
45,836
$
0.00
Fresh
63%
28,877
$
0.695
$
20,069.36
Processed
37%
16,959
$
0.306
$
5,189.57
$
0.00
North
$
0.00
Strawberries
Fresh
and
Processed
$
0.00
Rotation
50,035
Fresh
84%
42,030
$
0.576
$
24,209.09
Processed
16%
8,006
$
0.306
$
2,449.73
Non­
Rotation
46,651
Fresh
84%
39,187
$
0.576
$
22,571.74
Processed
16%
7,464
$
0.306
$
2,284.05
Rotation
3
year
Repeated
use
44,980
Fresh
84%
37,783
$
0.576
$
21,762.96
Processed
16%
7,197
$
0.306
$
2,202.20
Total
Revenue
South
$
25,258.93
Total
Rev
Rot
North
$
26,658.82
Total
Rev
Non
Rot
Nort
$
24,855.79
Repeated
use
Total
Rev
Rot
North
$
23,965.16
Comments:
Weighted
averageyearly
price
for
fresh
berries
is
$
0.695
South
and
$
0.576
based
on
calculations
used
for
Section
18
applications,
Appendix
K
Percentage
of
fresh
vs
processed
based
on
2001
baseline,
Worksheets
2­
CS
and
2­
CN,
.63:
37
and
.84:
16
respectively
Crop/
Commodity
Yield
calculated
from
the
average
percent
yield
from
California
strawberry
trials,
Appendix
T,
Pic
Tab
Note
ratio
in
South
of
Fresh
to
Processed
is
63%
to
37%

Note
ratio
in
North
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#

Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternativ
Chloropicrin
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
f
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
m
Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
diff
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
Custom
Drip
Fumigation
$
1,455
$
0.00
Flat
Fumigation
$
1,208
$
0.00
Lost
revenue
for
early
crop
pull
S
$
11
$
0.00
$
0.00
Lost
revenue
for
early
crop
pull
N
$
1,262
$
0.00
Additional
rent
for
rotation
525
$
0.00
Weeding
costs
addition
South
319
$
0.00
$
0.00
Weeding
costs
addition
North
428
$
0.00
$
0.00
$
0.00
South
Total
Custom
per
Area
$
1,784.52
User
Total
per
area
$
0.00
North
Total
Rotation
per
Area
$
2,161.00
North
Total
Non­
Rotation
per
Area
$
3,145.40
Comments:
North
rotation
growers
must
flat
fume
to
rotate
to
vegetable
growers.

Weeding
costs
for
PIC
shank
calculated
as
$
1,032
versus
$
713
for
South,
$
1,385
versus
$
957
for
North,
Appendix
K,
Weeding
Costs
Weeding
costs
for
PIC
drip
calculated
as
$
1,282
versus
$
713
for
the
South,
$
1,721
versus
$
957
for
the
North,
Appendix
K,
Weeding
Cos
See
Appendix
W,
"
Chloropicrin
Narrative"

OMB
Control
#
Chloropicrin
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operatio
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
26,208
$
25,259
­$
948.60
Northern
Region
(
w/
o
overhead)
Rotation
$
26,134
$
26,659
$
524.82
Non­
Rotation
$
27,118
$
24,856
­$
2,262.61
3­
Year
Repeated
use
Rotation
$
26,134
$
23,965
­$
2,168.84
Total
Revenues
for
South
­$
948.60
Total
Revenues
for
North
­$
868.90
Comments:
Overhead
costs
not
included
at
this
time
as
best
case
scenario
See
Appendix
W,
"
Chloropicrin
Narrative"

OMB
Control
#
Worksheet
3­
E.
Chloropicrin
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXXX
Efficacious
amount
of
200
lbs/
acre
or
more
not
allowed
or
discouraged
by
County
Ag
Commissioners
(
Personal
Communication,
Ag
Commissioners
in
Orange,
Ventura,
Santa
Barbara,
Santa
Cruz,
and
Monterey
Counties)

See
Appendix
Y,
"
Chloropicrin/
Metam
Narrative"
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Chloropicrin/
Metam
Sodium
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Appendix
Y,
"
Chloropicrin/
Metam
Narrative"
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Appendix
Y,
"
Chloropicrin/
Metam
Narrative"
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
Y,
"
Chloropicrin/
Metam
Narrative"

OMB
Control
#
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Chloropicrin/
Metam
Sodium
[
Insert
Study
Title]

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J,
M:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)
$
0.00
$
0.00
$
0.00
Chloropicrin
EC
24
galloms
$
0.00
+
Metam
Sodium
drip
37­
50
galloms
$
1,571.00
Chloropicrin
bed
shank
200
pounds
$
0.00
+
Metam
Sodium
drip
37­
50
galloms
$
1,161.00
$
0.00
Average
$
1,366.00
$
0.00
Chloropicrin
flat
shank
+
Metam
drip
$
1,366.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
Non
Rotation
$
1,366.00
Comments:
Total
Rotation
$
1,366.00
If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

See
Appendix
U,
"
mebr_
alts_
prices.
xls"

See
Appendix
V,
"
Vegetable
Rotation
Narrative"

OMB
Control
#
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
Chlorpicrin
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
For
EPA
Use
Only
ID#

Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.

B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regardin
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
lbs
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)
$
0.00
$
0.00
South
$
0.00
Strawberries
Fresh
and
Processed
Total
yield
per
acre
47,284
$
0.00
Fresh
63%
29,789
$
0.695
$
20,703.13
Processed
37%
17,495
$
0.306
$
5,353.45
$
0.00
North
$
0.00
Strawberries
Fresh
and
Processed
$
0.00
Rotation
51,078
Fresh
84%
42,905
$
0.576
$
24,713.44
Processed
16%
8,172
$
0.306
$
2,500.77
Non­
Rotation
48,124
Fresh
84%
40,425
$
0.576
$
23,284.53
Processed
16%
7,700
$
0.306
$
2,356.17
Total
Revenue
South
$
26,056.58
Total
Rev
Rot
North
$
27,214.21
Total
Rev
Non­
Rot
Nor
$
25,640.71
Comments:
Weighted
averageyearly
price
for
fresh
berries
is
$
0.695
South
and
$
0.576
based
on
calculations
used
for
Section
18
applications,
Appendix
K
Percentage
of
fresh
vs
processed
based
on
2001
baseline,
Worksheets
2­
CS
and
2­
CN,
.63:
37
and
.84:
16
respectively
Crop/
Commodity
Yield
calculated
from
the
average
percent
yield
from
California
strawberry
trials,
Appendix
T,
"
Alt
Sum
Yield
Data.
xls"

Note
ratio
in
South
of
Fresh
to
Processed
is
63%
to
37%

Note
ratio
in
North
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#

Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternati
Chloropicrin/
Metam
Sodium
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
f
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
m
Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
diff
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
Drip
Fumigation
PIC
+
Metam
$
1,366
$
0.00
Flat
Fumigation
+
Drip
$
1,366
$
0.00
Additional
yearly
maintenance
of
drip
$
100
$
0.00
Lost
revenue
for
early
crop
pull
S
$
1,841
$
0.00
Savings
from
not
picking
1
month
S
­$
832
Lost
revenue
for
early
crop
pull
N
$
2,525
$
0.00
Savings
from
not
picking
1
month
N
­$
1,836
Additional
rent
for
rotation
525
$
0.00
Additional
Weeding
Costs
S
175
$
0.00
Additional
Weeding
Costs
N
235.5
$
0.00
(
average
of
two
weed
costs)
$
0.00
$
0.00
$
0.00
South
Total
Custom
per
Area
$
2,649.62
User
Total
per
area
$
0.00
North
Total
Rotation
per
Area
$
2,126.50
North
Total
Non­
Rotation
per
Area
$
2,390.29
Comments:
Weeding
costs
for
shank
application
calculated
as
$
773
versus
$
713
for
the
South,
$
1,038
versus
$
957
for
the
North
Weeding
costs
for
drip
application
calculated
as
$
1,003
versus
$
713
for
the
South,
$
1,347
versus
$
957
for
the
North
See
Appendix
Y,
"
Chloropicrin/
Metam
Sodium
Narrative"

OMB
Control
#
Chloropicrin/
Metam
Sodium
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operatio
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
27,073
$
26,057
­$
1,016.04
Northern
Region
(
w/
o
overhead)
Rotation
$
26,100
$
27,214
$
1,114.71
Non­
Rotation
$
26,363
$
25,641
­$
722.59
Total
Revenues
for
South
­$
1,016.04
Total
Revenues
for
North
$
196.06
Comments:
Overhead
costs
not
included
at
this
time
as
best
case
scenario
OMB
Control
#
Worksheet
3­
E.
Chloropicrin/
Metam
Sodium
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
XXXX
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXXX
See
Appendix
Z,
"
1,3­
D
Chloropicrin
Narrative"
See
Appendix
P,
Impact
of
Township
Caps
Local
restrictions
near
sensitive
sites
and
buffer
zone
requirements,
See
Appendix
O
For
EPA
Use
Only
ID#

Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
1,3­
Dichloropropen/
Chloropicrin
Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
For
EPA
Use
Only
ID#

See
Appendix
Z,
"
1,3­
D
Chloropicrin
Narrative"
Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.
See
Appendix
Z,
"
1,3­
D
Chloropicrin
Narrative"
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
Z,
"
1,3­
D
Chloropicrin
Narrative"

OMB
Control
#

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

1,3­
Dichloropropene/
Chloropicrin
[
Insert
Study
Title]
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J,
M:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)
$
0.00
$
0.00
$
0.00
InLine
+
VIF
tarp
drip
application
34
gallons
$
1,541.00
Telone
C35
shank
flat
application
350­
400
lbs
$
1,993.00
Telone
,
flat
application
350­
400
lbs
+
coinject
PIC
200­
400
lbs
$
2,563.00
Average
$
2,278.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
Non­
Rotation
$
1,541.00
Comments:
Total
Rotation
$
2,278.00
If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

See
Appendix
U,
"
mebr_
alts_
prices.
xls"

See
Appendix
V,
"
Vegetable
Rotation
Narrative"

OMB
Control
#
For
EPA
Use
Only
ID#

See
attached
narrative
Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.
B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regardin
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
1,3­
D/
Chloropicrin
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
lbs
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)
$
0.00
$
0.00
South
$
0.00
Strawberries
Fresh
and
Processed
Total
yield
per
acre
46,801
$
0.00
Fresh
63%
29,485
$
0.695
$
20,491.87
Processed
37%
17,316
$
0.306
$
5,298.82
$
0.00
North
$
0.00
Strawberries
Fresh
and
Processed
$
0.00
Non­
Rotation
47,633
Fresh
84%
40,012
$
0.576
$
23,046.94
Processed
16%
7,621
$
0.306
$
2,332.13
Rotation
46,908
Fresh
84%
39,403
$
0.576
$
22,696.02
Processed
16%
7,505
0.306
$
2,296.62
Total
Revenue
South
$
25,790.69
Total
Rev
N
non­
rot
$
25,379.07
Total
Rev
N
rotation
$
24,992.64
Comments:
Weighted
averageyearly
price
for
fresh
berries
is
$
0.695
South
and
$
0.576
based
on
calculations
used
for
Section
18
applications,
Appendix
K
Percentage
of
fresh
vs
processed
based
on
2001
baseline,
Worksheets
2­
CS
and
2­
CN,
.63:
37
and
.84:
16
respectively
Crop/
Commodity
Yield
calculated
from
the
average
percent
yield
from
California
strawberry
trials,
Appendix
T,
1,3­
D
Pic
tab
Note
ratio
in
South
of
Fresh
to
Processed
is
63%
to
37%

Note
ratio
in
North
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#

Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternativ
1,3­
D/
Chloropicrin
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
f
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
m
Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
diff
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
Custom
Fumigation
InLine
$
1,541
$
0.00
Flat
fumigation
Telone
C35
$
2,278
$
0.00
Additional
yearly
maintenance
of
drip
$
100
$
0.00
Lost
revenue
for
early
crop
pull
S
$
11
$
0.00
Lost
revenue
for
early
crop
pull
N
$
1,262
$
0.00
Gained
revenue
from
not
picking
N
­$
918
$
0.00
Weeding
costs
for
InLine
South
$
236
$
0.00
Weeding
costs
for
InLine
North
$
316
$
0.00
$
0.00
Additional
rent
for
rotation
$
525
$
0.00
$
0.00
South
Total
per
Area
$
1,887.52
User
Total
per
area
$
0.00
North
Total
Non­
Rotation
per
Area
$
2,301.40
North
Total
Rotation
per
Area
$
3,119.00
Comments:
Weeding
costs
for
shank
application
calculated
as
$
776
versus
$
713
for
the
South,
$
1,042
versus
$
957
for
the
North
Weeding
costs
for
drip
application
calculated
as
$
949
versus
$
713
for
the
South,
$
1,273
versus
$
957
for
the
North
See
Appendix
Z,
1,3­
D
Chloropicrin
Narrative
OMB
Control
#
Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
1,3­
D/
Chloropicrin
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operatio
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.

Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
26,311
$
25,791
­$
519.83
Northern
Region
(
w/
o
overhead)

Non­
Rotation
$
26,274
$
25,379
­$
895.33
Rotation
$
27,092
$
24,993
­$
2,099.36
Total
Revenues
for
South
­$
519.83
Total
Revenues
for
North
­$
1,497.35
Comments:
Overhead
costs
not
included
at
this
time
as
best
case
scenario
See
Appendix
Y,
"
1,3­
D
Chloropicrin
Narrative"

OMB
Control
#
Worksheet
3­
E.
1,3­
D/
Chloropicrin
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
XXXX
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)
XXXX
See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"
See
Appendices
P,
S,
R,
X
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

1,3­
D/
Chloropicrin/
Metam
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
For
EPA
Use
Only
ID#
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.

See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"
For
EPA
Use
Only
ID#
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"

OMB
Control
#
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

1,3­
Dichloropropene/
Chloropicrin/
Metam
[
Insert
Study
Title]

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
Col.
B:
Target
Pests
Col.
C:
Active
Ingredients
Col.
D:
Formulation
Col.
E,
F,
G:
Application
Rate
Col.
H,
I,
J,
M:
Prices
and
Costs
Col.
K:
Area
Treated
Col.
L:
#
of
Applications
per
Year
Col.
M:
Cost
per
Area
in
2001
Dollars
Non­
chemical
Control
A
B
C
D
E
F
G
H
I
J
K
L
M
lbs.
ai
per
Area
per
Application
Units
of
product
per
Area
per
Application
Product
Unit
(
e.
g.,
lbs.,

gals)
$
0.00
$
0.00
$
0.00
InLine
+
VIF
tarp
drip
application
34
gallons
+
Metam
drip
37­
50
gallons
$
1,799.00
Telone
C35
shank
flat
application
350­
400
lbs
+
Metam
drip
37­
50
gallons
$
2,152.00
Telone
,
flat
application
350­
400
lbs
+
coinject
PIC
200­
400
lbs
+
Metam
drip
37­
50
gallons
$
2,722.00
Average
$
2,437.00
$
0.00
$
0.00
Non­
Chemical
Pest
Control
Target
Pests
Description
Cost/
area
Total
Non­
Rotation
$
1,799.00
Comments:
Total
Rotation
$
2,437.00
If
you
do
not
have
the
quantitative
data
for
additional
crops
grown
on
the
same
land,
please
indicate
so
in
the
comment
section.

See
Appendix
U,
"
mebr_
alts_
prices.
xls"

See
Appendix
V,
"
Vegetable
Rotation
Narrative"

OMB
Control
#
Enter
the
cost
per
area
in
2001
dollars.
Col.
M
will
be
calculated
automatically
using
the
data
you
have
entered
for
a
chemical
pest
control,
or,
the
formula
in
Col.
M
can
be
overridden
if
the
cost
per
area
is
known
because
the
product
was
custom
applied
Area
Treated
at
Least
Once
Enter
data
near
the
bottom
of
the
form.
Identify
the
control
in
Col.
A.
Enter
the
target
pests
in
Col.
B.
Describe
the
non­
chemical
pest
control
Col.
B­
L.
Enter
the
costs
in
Col.
M
in
2001
dollars.
#
of
Applications
per
Year
Application
Rate
Formulation
of
Product
Target
Pests
Active
Ingredients
(
ai)
in
Product
Worksheet
3­
B.
Alternatives
­
Pest
Control
Regimen
Costs
for
Alternative:
1,3­
D/
Chloropicrin/
Metam
Enter
the
area
receiving
at
least
one
application
of
the
pesticide.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Enter
all
alternatives
and
non­
chemical
pest
control
that
would
replace
one
treatment
of
methyl
bromide
throughout
the
fumigation
cycle.
See
the
Fumigation
Cycle
Worksheet
for
a
comprehensive
definition
of
the
fumigation
cycle.
If
multiple
crops
are
grown
Be
as
specific
as
possible
regarding
the
species
or
classes
of
pests
controlled
by
the
active
ingredient
or
pesticide
product.

Col.
A:
Name
of
Product
and
Non­
chemical
Control
If
someone
other
than
the
applicant
previously
benefited
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

As
a
cross
check,
EPA
is
requesting
both
the
amount
of
active
ingredient
in
Col.
E
and
product
applied
per
area
in
Col.
F.
Indicate
the
unit
of
the
product
in
Col.
G.

Use
2001
prices
and
costs.
If
the
product
is
custom
applied
you
may
enter
the
total
cost
in
the
last
column
(
Col.
M)
and
override
the
formula.
If
a
pesticide
is
applied
by
the
user,
enter
the
price
of
the
product
in
Col.
H
and
the
cost
of
applying
it
in
Name
of
Product
Price
per
Unit
of
the
Product
Cost
of
Applying
Pesticide
per
Area
Other
Costs
per
Application
For
EPA
Use
Only
ID#

See
attached
narrative
Use
one
row
for
each
active
ingredient
(
ai).
For
example,
if
a
product
contains
2
ai's
use
2
rows
for
that
product.
Once
a
row
is
completed
for
a
given
product,
then
only
Col.
B
(
if
applicable),
C,
and
E
need
to
be
completed
for
additional
rows
regardin
Enter
the
number
of
applications
in
a
fumigation
cycle
comparable
to
methyl
bromide
for
this
alternative
pest
control
regimen.
Since
this
number
is
an
average,
it
does
not
need
to
be
a
whole
number.

Enter
the
formulation
or
the
%
of
active
ingredient.
Cost
per
Area
(
2001$)

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
For
EPA
Use
Only
ID#

Col.
B:
Price
Factors
Col.
C:
Unit
of
Crop/
Commodity
Col.
D:
Crop/
Commodity
Yield
Col.
E:
Price
Col.
F:
Gross
Revenue
A
B
C
D
E
F
Crop/
Commodity
Price
Factors
(
grade,
time,
market)
Unit
of
Crop/
Commodity
(
pounds)
Crop/
Commodity
Yield
(
lbs
per
acre)
Price
(
per
unit
of
crop/
commodity)
Revenue
(
per
area)
$
0.00
$
0.00
South
$
0.00
Strawberries
Fresh
and
Processed
Total
yield
per
acre
45,836
$
0.00
Fresh
63%
28,877
$
0.695
$
20,069.36
Processed
37%
16,959
$
0.306
$
5,189.57
$
0.00
North
$
0.00
Strawberries
Fresh
and
Processed
$
0.00
Non­
Rotation
46,651
Fresh
84%
39,187
$
0.576
$
22,571.74
Processed
16%
7,464
$
0.306
$
2,284.05
Rotation
49,514
Fresh
84%
41,592
$
0.576
$
23,956.91
Processed
16%
7,922
$
0.306
$
2,424.21
$
0.00
$
0.00
Total
Revenue
South
$
25,258.93
Total
Rev
Non­
rot
Nort
$
24,855.79
Total
Rev
Rot
North
$
26,381.12
Comments:
Weighted
averageyearly
price
for
fresh
berries
is
$
0.695
South
and
$
0.576
based
on
calculations
used
for
Section
18
applications,
Appendix
K
Percentage
of
fresh
vs
processed
based
on
2001
baseline,
Worksheets
2­
CS
and
2­
CN,
.63:
37
and
.84:
16
respectively
Crop/
Commodity
Yield
calculated
from
the
average
percent
yield
from
California
strawberry
trials,
Appendix
T,
1,3­
D
Pic
Metam
tab
Note
ratio
in
South
of
Fresh
to
Processed
is
63%
to
37%

Note
ratio
in
North
of
Fresh
to
Processed
is
84%
to
16%

OMB
Control
#
Enter
the
number
of
units
of
crop/
commodity
produced
per
area
for
that
price
factor
identified.

Enter
the
average
2001
prices
received
by
the
users
for
that
crop/
commodity
and
price
factor.

The
purpose
of
this
worksheet
is
to
identify
the
gross
revenue
for
units
(
crop,
commodity,
structure)
when
using
an
alternative
compared
to
gross
revenue
when
using
methyl
bromide.

Postharvest
and
structural
users
may
modify
this
form
to
accommodate
diff
Col.
A:
Crop/
Commodity
If
someone
other
than
the
applicant
benefits
from
the
application
of
methyl
bromide
in
the
fumigation
cycle
and
you
do
not
have
the
quantitative
data
for
the
crops
grown
on
the
same
land,
please
indicate
so
in
the
comments
section
below.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

Worksheet
3­
C.
Alternatives
­
Crop/
Commodity
Yield
and
Gross
Revenue
for
Alternati
1,3­
D
Chloropicrin
Metam
If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

In
the
electronic
version,
revenue
is
automatically
calculated
below
using
the
data
you
entered
for
yield
and
price.
If
revenue
is
not
equal
to
yield
times
price,
you
may
override
the
formula
and
enter
a
different
revenue
amount.
Please
explain
why
this
Enter
the
unit
of
measurement
for
your
crop/
commodity.

Enter
all
crops/
commodities
that
can
be
grown/
treated
during
the
same
interval
of
time
comprising
a
methyl
bromide
fumigation
cycle.
Please
discuss
changes
in
crop
cycles
resulting
from
alternative
use
in
the
comments.
See
the
Fumigation
Cycle
Worksheet
f
Enter
in
Col.
B
any
factors
that
determine
prices
(
e.
g.,
grade,
time,
market).
If
you
received
different
prices
for
your
crop/
commodity
as
a
result
of
quality,
grade,
market
(
e.
g.,
fresh
or
processing),
timing
of
harvest,
etc.,
you
may
itemize
by
using
m
For
EPA
Use
Only
ID#

Col.
A:
Operation
or
Cost
Item
Col.
B:
Custom
Operation
Cost
Col.
C,
D,
E:
Costs
per
Area
Col.
F:
Typical
Equipment
Used
A
B
C
D
E
F
Material
Cost
per
Area
Labor
Cost
per
Area
Total
Cost
per
Area
$
0.00
$
0.00
Custom
Fumigation
InLine+
metam
$
1,799
$
0.00
Flat
fumigation
Telone
C35
+
drip
$
2,437
$
0.00
Additional
yearly
maintenance
of
drip
$
100
$
0.00
Lost
revenue
for
early
crop
pull
S
$
1,841
$
0.00
Savings
from
not
picking
0.5
month
S
­$
416
Lost
revenue
for
early
crop
pull
N
$
2,525
$
0.00
Savings
from
not
picking
1
month
N
­$
1,836
Additional
rent
for
rotation
$
525
$
0.00
Weeding
costs
for
InLine
South
$
313
$
0.00
Weeding
costs
for
InLine
North
$
421
$
0.00
$
0.00
$
0.00
$
0.00
South
Total
Custom
per
Area
$
3,636.62
User
Total
per
area
$
0.00
North
Total
Non­
Rotation
per
Area
$
3,008.79
North
Total
Rotation
per
Area
$
3,383.00
Comments:
Weeding
costs
for
shank
application
calculated
as
$
745
versus
$
713
for
the
South,
$
999
versus
$
957
for
the
North
Weeding
costs
for
drip
application
calculated
as
$
1,026
versus
$
713
for
the
South,
$
1,378
versus
$
957
for
the
North
See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"

OMB
Control
#
Enter
custom
operation
costs
that
change
in
Col.
B.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user
.

Enter
in
Col.
C
and
D,
material
and
labor
costs
per
area
that
change
for
operations
done
by
user.
The
total
cost
per
area
is
calculated
automatically
from
the
values
you
enter
in
Cols.
C
and
D.
Typical
Equipment
Used
Operation
Done
by
User
1,3­
D
Chloropicrin/
Metam
Sodium
Worksheet
3­
D.
Alternatives
­
Changes
in
Other
Costs
for
Alternative:

Custom
Operation
Cost
per
Area
Operation
or
Cost
Item
Enter
data
only
for
costs
(
other
than
the
cost
of
alternative
pest
control)
that
change
as
a
result
of
using
the
alternatives
instead
of
methyl
bromide.
Enter
the
whole
cost,
not
just
the
incremental
changes.
Enter
the
cost
in
Col.
B
for
custom
operatio
Identify
changes
in
the
typical
equipment
used
by
the
user
as
a
result
of
not
using
methyl
bromide.
Please
be
specific
such
as
tractor
horsepower.
No
cost
data
are
required
in
this
column.

Identify
the
operations
or
cost
items
that
change
as
a
result
of
not
using
methyl
bromide.
For
EPA
Use
Only
ID#

Col
A:
Cost
Item
Col
B:
Description
Col
C:
Allocation
Method
Col
D:
Cost
per
Area
A
B
C
D
Reprentative
Use
Total
Operating
Costs
Total
Revenues
Net
Revenues
Southern
Region
(
w/
o
overhead)
$
28,060
$
25,259
­$
2,800.69
Northern
Region
(
w/
o
overhead)
Rotation
$
27,356
$
26,381
­$
974.88
Non­
Rotation
$
26,982
$
24,856
­$
2,126.01
Total
Revenues
for
South
­$
2,800.69
Total
Revenues
for
North
­$
1,550.44
Comments:
Overhead
costs
not
included
at
this
time
as
best
case
scenario
See
Appendix
AA,
"
1,3­
D
Chloropicrin
Metam
Narrative"

OMB
Control
#
Worksheet
3­
E.
1,3­
D/
Chloropicrin/
Metam
Total
Costs
and
Revenues
in
2001
Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.

If
a
consortium
is
submitting
this
application,
the
data
for
this
table
should
reflect
a
representative
user.

Identify
in
Col.
A
the
cost
items.
These
items
should
include,
but
are
not
limited
to:
(
1)
land
rent,
(
2)
interest,
(
3)
depreciation,

(
4)
management,
and
(
5)
overhead
such
as
office
and
administration.)

Please
describe
the
cost
in
more
detail.

Please
describe
how
you
estimated
the
portion
of
total
fixed
cost
of
the
farm
or
entity
that
applies
to
this
crop/
commodity.

Enter
the
cost
per
area
of
methyl
bromide
treated.
Use
additional
pages
as
needed.

Alternative:
Study:

Section
I.
Initial
Screening
on
Technical
Feasibility
of
Alternatives
1.
Are
there
any
location­
specific
restrictions
that
inhibit
the
use
of
this
alternative
on
your
site?

1a.
Full
use
permitted
1b.
Township
caps
1c.
Alternative
not
acceptable
in
consuming
country
1d.
Other
(
Please
describe)

See
Appendix
BB,
"
Non­
Chemical
Narrative"
If
you
prefer,
you
may
provide
the
information
requested
in
this
worksheet
in
a
narrative
review
of
one
or
more
relevant
research
reports.
The
narrative
review
must
reply
to
Section
I
and
questions
1
through
8
in
Section
II.
A
Research
Summary
Worksheet
Summarize
each
of
the
research
studies
you
cite
in
the
Research
Summary
Worksheet.

Whether
you
conduct
the
research
yourself
or
cite
studies
developed
by
others,
it
is
important
that
the
studies
be
conducted
in
a
scientifically
sound
manner.
The
studies
should
include
a
description
of
the
experimental
methodology
used,
such
as
applicati
The
Agency
has
posted
many
research
studies
on
a
variety
of
crops
on
its
website
and
knows
of
more
studies
currently
in
progress.
EPA
will
add
studies
to
its
website
as
they
become
publicly
available.
You
are
encouraged
to
review
the
EPA
website
and
othe
There
are
three
major
ways
you
can
provide
the
Agency
with
proof
of
your
investigative
work.
(
1)
Conduct
and
submit
your
own
research
(
2)
Cite
research
that
has
been
conducted
by
others
(
3)
Cite
research
listed
on
the
EPA
website
EPA
must
consider
whether
alternative
pest
control
measures
(
pesticide
and
non­
pesticidal,
and
their
combination)
could
be
used
successfully
instead
of
methyl
bromide
by
crop
and
circumstance
(
geographic
area.)
The
Agency
has
developed
a
list
of
possible
Worksheet
3­
A.
Non­
Chemical
Technical
Feasibility
wrt
Methyl
Bromide
[
Insert
Study
Title]
In
addition,
EPA
acknowledges
that,
for
certain
circumstances,
some
alternatives
are
not
technically
feasible
and
therefore
no
research
has
been
conducted
(
i.
e.
solarization
may
not
be
feasible
in
Seattle).
You
should
look
at
the
list
of
alternatives
pro
For
worksheet
3­
A
you
must
complete
one
worksheet
for
each
alternative,
for
each
research
study
addressed.
Please
number
the
worksheets
as
follows.
For
the
same
alternative,
first
research
study,
label
the
worksheet
3­
A(
1)(
a).
For
the
same
alternative,

BACKGROUND
If
use
of
this
alternative
is
precluded
by
regulatory
restriction
for
all
users
covered
by
this
application,
the
applicant
should
not
complete
Section
II.
When
completing
Section
II,
if
you
cite
a
study
that
is
on
the
EPA
website,
you
only
need
to
complete
questions
1,
5,
and
8.

Non­
Chemical
Alternatives
In
this
worksheet,
you
should
address
why
an
alternative
pest
management
strategy
on
the
list
(
see
previous
page)
is
or
is
not
effective
for
your
conditions.
This
worksheet
contains
9
questions.
You
must
complete
one
copy
of
worksheet
3­
A
for
each
resear
For
EPA
Use
Only
ID#
Section
II.
Existing
Research
Studies
on
Alternatives
to
Methyl
Bromide
1.
Is
the
study
on
EPA's
website?
Yes
No
1a.
If
not
on
the
EPA
website,
please
attach
a
copy.

2.
Author(
s)
or
researcher(
s)

3.
Publication
and
Date
of
Publication
4.
Location
of
research
study
5.

6.
Was
crop
yield
measured
in
the
study?
Yes
No
7.

8.

OMB
Control
#
See
Appendix
BB,
"
Non­
Chemical
Narrative"
Worksheet
3­
A.
Non­
Chemical
Technical
Feasibility
wrt
Methyl
Bromide
Name
of
alternative(
s)
in
study.
If
more
than
one
alternative,
list
the
ones
you
wish
to
discuss.

Discuss
how
the
results
of
the
study
apply
to
your
situation.
Would
you
expect
similar
results?
Are
there
other
factors
that
would
affect
your
adoption
of
this
tool?
Describe
the
effectiveness
of
the
alternative
in
controlling
pests
in
the
study.
None
of
the
non­
chemical
alternatives
identified
by
MBTOC
control
the
entire
For
EPA
Use
Only
ID#

See
Appendix
BB,
"
Non­
Chemical
Narrative"
pest
complex
Alternative:
Study:

Col.
A:
Treatment
Number
Col.
B:
Treatment
Col.
C:
Rate
Col.
D,
F,
H,
J,
L,
N:

Interval
Cols.
E,
G,
I,
K,
M,
O:
Rating
for
Interval:

Control
of
Pests
1
and
2
(
Cols.
D
­
I
and
Cols.
J
­
O):

Col.
J:
Yield
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Pest
1
Pest
2
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Interval
1
Rating
for
Interval
1
Interval
2
Rating
for
Interval
2
Interval
3
Rating
for
Interval
3
Comments:
See
Appendix
BB,
"
Non­
Chemical
Narrative"

OMB
Control
#
Worksheet
3­
A.
Alternatives
­
Technical
Feasibility
of
Alternatives
to
Methyl
Bromide
For
EPA
Use
Only
ID#

Treatment
Treatment
Number
Rate
(
lbs.
or
gals.
ai
per
area)

Enter
the
marketable
yield
of
the
crop
or
commodity
and
specify
the
units
(
lbs./
acre,
tons)
in
the
column
header
or
comments
section.

Area
is
defined
below
as
follows
for
each
user:
acres
for
growers,
cubic
feet
for
post­
harvest
operations,
and
square
feet
for
structural
applications.
Yield
(
units/
area)

Non­
Chemical
[
Insert
Study
Title]

Provide
one
summary
table
for
each
study
being
described.

Research
Summary
Table
For
the
target
pest(
s)
in
the
study
list
the
pest
or
pest
species
being
rated
in
the
column
header
or
the
comments
section.
For
example,
a
study
for
nematode
control
in
tomatoes
may
have
looked
at
sting
nematode
and
stunt
nematode.
Enter
sting
nematode
Provide
a
summary
table
of
research
information
that
will
allow
us
compare
the
impact
of
methyl
bromide
and
the
alternative
regimen
on
such
things
as
pest
control,
yield
or
quality
of
the
commodity
being
treated,
or
protected.

Ideally,
a
research
study
s
List
the
treatment
number
from
the
research
study
you
are
citing.

List
what
type
of
pest
control
method
was
used.

Enter
the
pounds
or
gallons
of
a
chemical
used,
days
of
solarization,
etc.

Enter
the
interval
after
treatment
that
the
rating
was
taken.
Enter
the
interval
(
days,
weeks
or
months)
in
the
column
heading
or
in
the
comments
section.
In
the
comments
describe
the
rating
scale
(
e.
g.
0
to
100
where
100
is
complete
control).

Use
these
columns
to
describe
the
level
of
control
provided
for
a
specific
pest
and
the
time
interval
at
which
the
rating
was
taken.
For
example,
a
study
for
nematode
control
may
have
looked
at
nematode
population
in
the
soil
pre­
treatment,
3
weeks
after
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
XX
No
7.

OMB
Control
#
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
Will
crop
yield
be
measured
in
the
study?
CSC/
UC/
USDA
Statewide
Methyl
Bromide
Alternatives
Project
(
Continuation)

See
Appendix
HH
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
(
All
available
methyl
bromide
alternatives
from
the
alternatives
list
should
have
been
tested
or
have
future
tests
planned.)
There
is
no
need
to
complete
a
separate
worksheet
for
future
research
plans
for
each
alternative
­
you
may
use
this
worksheet
to
describe
all
future
research
plans.

If
additional
testing
is
not
planned,
please
explain
why.
(
For
example,
the
available
alternatives
have
been
tested
and
found
unsuitable,
an
alternative
has
been
identified
but
is
not
yet
registered
for
this
crop,
available
alternatives
are
too
expensive
for
this
crop,
etc.)
California
Strawberry
Growing
Region
2003
on
Continuation
of
on
farm
demo
plots
of
methyl
bromide
alternatives
throughout
Strawberry
growing
region
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
XX
No
7.

OMB
Control
#
California
Strawberry
Commission
Research
Grants
See
Appendix
HH
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
(
All
available
methyl
bromide
alternatives
from
the
alternatives
list
should
have
been
tested
or
have
future
tests
planned.)
There
is
no
need
to
complete
a
separate
worksheet
for
futur
If
additional
testing
is
not
planned,
please
explain
why.
(
For
example,
the
available
alternatives
have
been
tested
and
found
unsuitable,
an
alternative
has
been
identified
but
is
not
yet
registered
for
this
crop,
available
alternatives
are
too
expensive
California
Strawberry
Growing
Region
2003­
2004
Continuation
research
in
Pomology,
Plant
Pathology,
Fumigant
efficacy,
and
Optimization
of
drip
fumigants
Will
crop
yield
be
measured
in
the
study?
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
1.
Name
of
study:

2.
Researcher(
s):

3.
Your
test
is
planned
for:

4.
Location:

5.
Name
of
alternative
to
be
tested:

6.
Yes
XX
No
7.

OMB
Control
#
For
EPA
Use
Only
ID#

Worksheet
4.
Alternatives
­
Future
Research
Plans
Will
crop
yield
be
measured
in
the
study?
Alternative
Fumigants
for
the
Control
of
Soil
Pests:
Strawberry
as
a
Model
System,
Renewal
See
Appendix
HH
Please
describe
future
plans
to
test
alternatives
to
methyl
bromide.
(
All
available
methyl
bromide
alternatives
from
the
alternatives
list
should
have
been
tested
or
have
future
tests
planned.)
There
is
no
need
to
complete
a
separate
worksheet
for
futur
If
additional
testing
is
not
planned,
please
explain
why.
(
For
example,
the
available
alternatives
have
been
tested
and
found
unsuitable,
an
alternative
has
been
identified
but
is
not
yet
registered
for
this
crop,
available
alternatives
are
too
expensive
California
Strawberry
Growing
Region
2003­
2004
Continuation
of
nursery
to
farm
research
on
alternatives,
testing
of
new
alternatives,
large
plot
studies
1.

1a.
Check
all
methods
you
will
use
Nothing
XX
Tarpaulin
(
high
density
polyethylene)
XX
Virtually
impermeable
film
(
VIF)
XX
Cultural
practices
(
please
specify)

1b.
Will
you
use
other
pesticides
to
reduce
use
of
methyl
bromide?
Yes
XX
No
If
yes
please
specify.

1c.
Other
non­
chemical
methods:
(
please
specify):

2.
Yes
No
XX
If
yes,
how
many
pounds?
lbs.

3.
Yes
No
XX
If
yes,
how
many
pounds?
lbs.

4.

$

5.

6.

When
do
you
expect
these
to
occur?

7.

0­
10
acres
10­
25
acres
25­
50
acres
50­
100
acres
100­
200
acres
200­
400
acres
over
400
acres
Sufficient
research
on
optimal
rates
of
MeI
and
other
alternatives,
without
phytotoxicity.
since
profit
margins
are
so
small,
losses
on
even
small
percentages
of
acres
could
put
growers
under
How
will
you
minimize
your
use
and/
or
emissions
of
methyl
bromide?

Colored
tarps
for
weed
control
and
VIF
film
for
lower
rates
and
better
efficacy.
No
non­
chemical
means
work.

Do
you
have
access
to
recycled
methyl
bromide?
Additions
of
nematocides,
herbicides
to
pest
management
program
Do
you
anticipate
that
you
will
have
any
methyl
bromide
in
storage
on
January
1,
2005?

$
8,000,000
Manufacturer
sponsored
"
insurance"
for
growers
trying
alternatives,
to
recoup
losses
should
alternatives
fail
organizing
and
running
Demonstrations
Field
Days.

Identify
what
factors
would
allow
you
to
stop
or
reduce
your
use
of
methyl
bromide
(
e.
g.
registration
of
particular
pesticide;
completion
of
research
plan;
capital
outlay).
What
is
the
cumulative
amount
spent
to
date
by
the
user
or
consortium
on
research
to
develop
alternatives
to
methyl
bromide
(
beginning
in
1992)?
CSC
money
only,
from
assessements
since
1992
Other
investments,
if
any,
made
to
reduce
your
reliance
on
methyl
bromide.
Describe
each
investment
and
its
associated
cost.
Staff
(
2
people
equivalent)
time
and
salary
assisting
USDA
and
Univsersity
researchers
over
the
years,
VIF
film
to
lower
MBr
rates
efficaciously
Worksheet
5.
Additional
Information
For
EPA
Use
Only
ID#

13%
Lower
ratio
formulations
(
50:
50)

10%
25%
33%
Due
to
complexity
of
Pest
complex,
expect
some
use
of
methyl
bromide
may
need
to
continue
for
periodic
field
cleanup
2006,
2007
15%

3%
1%
Range
of
acres
farmed
by
growers
included
in
this
application?
(
insert
number
of
users
in
each
category)
Worksheet
5.
Additional
Information
(
continued)

8.

0
­
5,000
sq.
ft.
5,001
­
10,000
sq.
ft.
10,001
­
20,000
sq.
ft.
20,001
­
40,000
sq.
ft.
40,001
­
80,000
sq.
ft.
80,001
­
160,000
sq.
ft.
over
160,000
sq.
ft.

I
certify
that
all
information
contained
in
this
document
is
factual
to
the
best
of
my
knowledge.

Signature
Date
Print
Name
Title
Signature
Date
Print
Name
Title
OMB
Control
#
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
324
hours
per
response
and
assumes
a
large
portion
of
applications
will
be
submitted
by
consortia
on
behalf
of
many
individual
users
of
methyl
bromide.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
OMB
control
number.
Range
of
square
feet
of
the
area
to
which
applicants
included
in
this
application
will
apply
methyl
bromide?
(
insert
number
of
users
in
each
category)

Information
in
this
application
may
be
aggregated
with
information
from
other
applications
and
used
by
the
United
States
government
to
justify
claims
in
the
national
nomination
package
that
a
particular
use
of
methyl
bromide
be
considered
"
critical"
and
authorized
for
an
exemption
beyond
the
2005
phaseout.
Use
of
aggregate
data
will
be
crucial
to
making
compelling
arguments
in
favor
of
critical
use
exemptions.
By
signing
below,
you
agree
not
to
assert
any
claim
of
confidentiality
that
would
affect
the
disclosure
by
EPA
of
aggregate
information
based
in
part
on
information
contained
in
this
application.
For
EPA
Use
Only
ID#
1.
2.
3.
4.
Pounds
of
Methyl
Bromide
Requested
2005
4,500,000
5.
Area
Treated
with
Methyl
Bromide
2005
25,000
acres
units
6.
If
methyl
bromide
is
requested
for
additional
years,
reason
for
request:

2006
4,500,000
lbs.
Area
Treated
25,000
acres
units
2007
4,500,000
lbs.
Area
Treated
25,000
acres
units
Not
Technically
Feasible
Not
Economically
Feasible
X
X
X
X
X
X
X
X
X
X
X
X
Place
an
"
X"
in
the
column(
s)
labeled
"
Not
Technically
Feasible"
and/
or
"
Not
Economically
Feasible"
where
appropriate.
Use
the
"
Reasons"
column
to
describe
why
the
potential
alternative
is
not
feasible.

Non­
Chemical
Alternatives
1,3­
Dichloropropene/
Chloropicrin
1,3­
Dichloropropene/
Chloropicrin/
Metam
Sodium
Metam
Sodium
Chloropicrin/
Metam
Sodium
combination
1,3­
Dichloropropene
Chloropicrin
Potential
Alternatives
Nematocides
The
consortium
is
requesting
the
full
amount
of
methyl
bromide
anticipated
to
be
used
in
the
2002
production
cycle
for
the
years
2006
and
2007.
If
the
two
year
trend
in
adoption
of
alternatives
(
2000­
2001)
continues,

or
if
economically
viable
alternatives
gain
registration,
future
applications
for
critical
use
exemptions
will
be
adjusted
accordingly
Insufficient
efficacy
against
the
entire
strawberry
pest
complex
in
California
as
evidenced
by
yield
losses
showing
no
economic
feasibility.
Under
regulatory
restrictions
in
California.

Insufficient
long­
term
efficacy
against
the
entire
strawberry
pest
complex
in
California.
Further
work
on
lont­
term
efficacy
with
repeated
use
required.
Marginal
economic
feasibility.
Under
regulatory
restrictions
in
California.

Insufficient
efficacy
against
the
entire
strawberry
pest
complex
in
California
Insufficient
long­
term
efficacy
against
the
entire
strawberry
pest
complex
in
California.
Further
work
on
lont­
term
efficacy
with
repeated
use
required.
Marginal
economic
feasibility.
Under
regulatory
restrictions
in
California.

Insufficient
long­
term
efficacy
against
the
entire
strawberry
pest
complex
in
California.
Further
work
on
lont­
term
efficacy
with
repeated
use
required.
No
economic
feasibility.
Under
regulatory
restrictions
in
California.

Insufficient
efficacy
against
the
entire
strawberry
pest
complex
in
California.

Reasons
Insufficient
efficacy
against
the
entire
strawberry
pest
complex
in
California.
Under
regulatory
restrictions
in
California.
Insufficient
efficacy
against
the
entire
strawberry
pest
complex
in
California.
Under
regulatory
restrictions
in
California.

Name
of
Applicant:

Location:

Crop:
California
Strawberry
Commission
P.
O.
Box
269,
Watsonville,
CA
95077­
0269
Production
Strawberries
For
EPA
Use
Only
ID#

Worksheet
6.
Application
Summary
This
worksheet
will
be
posted
on
the
web
to
notify
the
public
of
requests
for
critical
use
exemptions
beyond
the
2005
phase
out
for
methyl
bromide.
Therefore,
this
worksheet
cannot
be
claimed
as
CBI.
1,3­
Dichloropropene,
Chloropicrin
and
Metam
Sodium
Technical
Feasibility
Efficacy.
Telone
 
(
1,3­
dichloropropene)
is
used
as
a
nematocide
with
minimal
efficacy
against
disease
and
weeds
when
used
alone.
Because
it
is
not
effective
against
the
entire
pest
complex
in
California
strawberries,
this
alone
prevents
it
from
being
a
methyl
bromide
replacement
(
Table
1,
Pest
Complex,
in
application).
Early
efficacy
work
with
Telone
alone
demonstrated
it's
poorer
activity
compared
to
methyl
bromide/
chloropicrin
standards
(
Appendix
CC,
91­
15
Pink
Sheet).
And
in
fact
in
that
study
of
repeated
use
over
three
years,
already
poor
yields
dropped
with
time.
The
MBTOC
1998
report
(
page
51)
also
indicated
it
is
effective
only
in
combination
with
other
components.
The
Federal
Use
Label
also
shows
it
is
labeled
only
against
nematodes.

Chloropicrin
alone
has
some
activity
against
much
of
the
California
Pest
Complex.
Chloropicrin
has
good
efficacy
against
Pseudomonas
solancearum,
Cylindrocladium
fungi,
Phytophthora,
Fusarium,
Pyrenochaeta,
Pythium,
Rhizoctonia,
Sclentina,
Slcerotium,
Verticillium,
clubroot
organism
Plasmodiophora,
soil
pox
Actinomyces
ipomoea
(
Table
1).
Chloropicrin
alone
as
some
control
of
cut
worms,
grubs,
wireworms,
and
suppression
of
weeds
if
used
with
tarps
(
Appendix
G.)
It
has
no
control
over
some
key
weeds,
knotweed,
clovers,
and
filaree
and
limited
control
over
others
that
MBC
does
control
(
Appendix
DD,
Fennimore
2002
handout).
While
used
primarily
as
a
fungicide,
its
control
of
anthracnose
is
unknown,
and
this
disease
has
become
an
increasingly
important
problem
in
California
strawberries
and
is
controlled
by
MBC.
Chloropicrin
has
no
reported
activity
against
nematodes.
Nematodes
may
likely
become
an
increasing
problem
in
repeated
use
of
Chloropicrin.
MBC
has
controlled
nematodes
so
well
for
decades,
hard
to
measure
future
impact
of
this
pest
when
faced
with
less
than
adequate
control
from
Chloropicrin.

Metam
Efficacy
Metam
sodium
has
some
activity
against
most
of
the
California
strawberry
pest
complex.
However,
that
activity
is
limited
in
many
cases.
For
instance
metam
has
weed
activity
against
weeds
and
weed
seeds
of
Bermudagrass,
Chickweed,
Dandelions,
Ragweed,
Henbit,
Labsquarter,
Pigweed,
Watercress,
Johnsongrass,
Nightshade,
Nutsedge
(
suppression
only),
Wild
Morning­
Glory
and
Purslane.
But
methyl
bromide/
chloropicrin
(
MBC)
controls
nutsedge
well
(
S.
Fennimore)
compared
to
metam
and
MBC
controls
prostrate
knotweed
better
than
metam
alone
(
Appendix
DD,
Fennimore
2000
handout).
Overall,
weed
biomass
compared
to
the
MBC
standard
was
37%
higher
when
metam
alone
was
used
at
75
gal/
acre
(
Appendix
DD,
Fennimore
2000
handout).

Metam
only
suppresses
active
forms
of
nematodes
versus
eggs
(
requires
preirrigation
for
best
activity
and
fully
decomposed
plant
residues).
It
is
also
reported
to
have
activity
against
garden
symphalan
and
against
the
soil­
borne
diseases
Rhizoctonia,
Pythium,
Phytophthora,
Verticillium,
and
Sclerotina.

Combined
Efficacy
Of
all
the
alternative
regimes
the
1,3­
D
chloropicrin
metam
alternative
combination
would
appear
to
have
the
closest
combined
efficacy
to
methyl
bromide.
Some
increased
control
of
weeds
has
been
observed
in
InLine
applications
using
VIF
mulch.
However,
as
in
all
drip
applications,
weed
control
is
not
observed
in
areas
of
the
beds
where
the
drip
application
did
not
reach,
such
as
the
sides.
Application
of
herbicides
is
not
a
simple
solution
because
these
side
weeds
are
under
the
mulch.
Removal
requires
extensive
labor
to
lift
the
tarp
sides,
pull
the
weeds,
and
replace
the
tarp
along
the
sides.
Use
of
additional
herbicides
would
simply
add
to
the
operational
costs
as
would
increased
labor
to
hand
weed.
So
while
improved
weed
efficacy
would
be
expected
in
the
direct
area
of
application
of
metam,
weeds
would
still
cause
problems
and
add
to
costs
growing
along
the
sides
of
the
beds
and
in
furrows.
(
See
discussion
on
drip
fumigation
in
Appendix
Y,
1,3­
D
Chloropicrin
Narrative.)

Yields
Efficacy
of
the
combine
1,3­
D,
chloropicrin,
metam
sodium
regime
was
highly
variable
depending
on
the
pest
pressure
at
the
site
(
Appendix
T,
1,3­
D
Pic
Metam
tab).
When
only
trials
where
untreated
controls
had
yields
of
80%
or
less
of
the
MBC
standard
are
considered,
the
overall
yields
with
1,3­
D/
chloropicrin/
metam
averages
95%
of
the
MBC
standard.
When
drip
and
shank
applications
are
separated,
drip
was
better
at
97%
versus
90%
for
shank.
Analysis
of
10
studies
comparing
MBC
with
1,3­
D/
chloropicrin
applications
by
Shaw
and
Larson
showed
an
overall
loss
of
14.7%
compared
to
MBC.
No
studies
or
work
is
available
on
repeated
use
of
1,3­
D/
chloropicrin/
metam
on
the
same
land.
Since
Shaw
and
Larson
showed
steady
declines
over
3
years
of
chloropicrin
use,
and
1,3­
D
has
limited
efficacy
on
the
pest
complex,
one
would
anticipate
steady
losses
with
use
of
this
material.
In
particular,
weed
pressure
may
increase
so
significantly
with
repeated
use
to
further
contribute
to
yield
loss.

Economic
Analysis
For
drip
applications,
the
most
economical
and
safest
application
technology,
there
are
potential
up
front
costs
for
ensuring
irrigation
systems
are
leak
proof
and
proper
valves
and
safeguards
are
in
place
to
prevent
backflow
of
materials
into
water
sources.
In
addition,
1,3­
Dichloropropene
and
chloropicrin
are
very
corrosive
substance
and
if
proper
care
is
not
taken
to
clean
out
systems
after
application,
valves
and
piping
corrode
and
need
replacement.
Growers
need
to
replace
PVC
pipe,
which
is
corroded
by
1,3­
D
and
chloropicrin,
with
non­
PVC
piping
such
as
Oval
Hose.
The
first
growers
using
the
technology
state
that
they
had
minimal
up
front
costs
or
donations
of
equipment
to
upgrade
their
systems.
For
the
general
grower
upgrade
costs
could
run
thousands
of
dollars
to
replace
PVC
piping
and
add
proper
valve
and
flow
equipment.
We
estimate
yearly
costs
of
$
100
per
acre
to
upgrade
and
maintain
drip
systems
based
on
discussions
with
experienced
growers.

The
economics
associated
with
soil
preparation
come
into
play
for
1,3­
D/
chloropicrin/
metam
applications.
Soil
preparation
and
soil
moisture
are
more
critical
than
with
MBC
applications
(
Appendix
G).
Soil
temperature
is
also
more
critical.
According
to
label
directions,
if
temperatures
drop
below
40
°
F,
the
material
loses
effectiveness
on
application
and
requires
an
even
longer
plant
back
period.
The
normal
plant
back
period
is
roughly
1
week
for
every
10
gallons
per
acre
applied
for
1,3­
D
and
with
the
waiting
period
and
plant
back
time
for
metam
sodium,
at
best
this
leaves
a
plant
back
period
of
28
days
compared
to
the
7
days
for
MBC.
The
Southern
grower
needs,
at
best,
to
pull
plants
in
mid­
June
to
do
all
the
preparation,
fumigations,
and
have
sufficient
plantback
time
for
planting
by
the
end
of
September.

The
Southern
grower
will
lose
some
revenue
for
pulling
crop
early
in
mid­
June.
Lost
revenue
would
equal
two
weeks
of
fresh
and
processed
revenue
($
1,841).
Savings
would
be
incurred
for
not
having
two
weeks
of
processed
harvest
costs
at
$
208
per
week
($
416)(
processed
harvest
cost
divided
by
17
weeks
processed
harvest
time
in
the
south),
since
it
is
almost
exclusively
processed
harvest
going
on
in
June.
The
Northern
growers
however
will
lose
revenue
from
not
in
September
($
2,525
per
acre)
for
rotational
growers.
There
is
some
savings
in
not
paying
fresh
harvest
costs
for
four
weeks,
a
total
of
$
459
per
week
(
fresh
harvest
costs
for
North
divided
by
35
weeks
harvest),
or
$
1,836
per
acre.
The
non­
rotational
growers
will
have
to
obtain
their
land
sooner,
paying
one
quarter
year's
rent
to
prevent
the
vegetable
grower
from
doing
one
last
vegetable
crop.
Land
rent
in
the
northern
region
ranges
from
$
1800­
2400
per
acre.
One
quarter
of
the
average
rent,
$
2,100,
is
$
525.

Economic
analysis
was
done
with
best
case
scenarios.
For
the
Southern
grower
and
the
Northern
non­
rotation
grower,
it
was
assumed
drip
application
of
InLine
and
metam
were
the
most
efficacious
and
cost
effective.
For
the
rotation
grower
in
the
North,
flat
fumigation
of
Telone
C35
is
the
only
option
to
ensure
coverage
of
the
entire
field
in
anticipation
of
use
the
next
year
by
vegetable
growers.
As
such,
when
these
costs
are
added
in,
the
Southern
grower
sees
a
loss
of
$
2,801
per
acre
a
total
loss
of
$
112,040
for
the
40
acre
representative
user.
In
the
North,
the
non­
rotation
grower
experiences
a
loss
of
$
2,126
per
acre
for
a
total
loss
of
$
85,040.
The
rotational
grower
experiences
a
loss
of
$
975
per
acre
to
use
of
the
more
expensive
flat
fumigation
with
Telone
C35.
The
total
loss
for
the
40­
acre
representative
rotation
grower
is
$
39,000.
On
average
for
the
Northern
grower,
losses
would
be
$
1,550
per
acre,
or
$
62,000
for
the
40­
acre
Northern
grower.
This
are
minimum
possible
losses
because
if
plant
back
time,
particularly
in
the
colder
north,
increases
so
does
loss
of
revenue
by
having
to
pull
crop
even
earlier.

Regulatory
Pressures
1,3­
Dichloropropene
The
Federal
Label
requires
a
100
foot
buffer
zone
for
drip
applied
Telone.
For
shank
applied
Telone,
a
100
foot
buffer
zone
is
required
the
first
year
and
a
300
foot
buffer
zone
is
required
for
the
next
two
years
on
the
same
ground
(
Appendix
G).
In
addition,
in
California,
use
is
limited
by
township
caps,
as
an
additional
protection
with
respect
to
the
classification
of
1,3­
D
as
a
B2
carcinogen.
Recently
township
caps
were
doubled
in
townships
where
historical
Telone
use
did
not
reach
the
maximum
allowed
under
the
caps,
in
general
90,000
lbs
per
township
(
Appendix
S,
P)
This
is,
however
a
temporary
increase
until
the
amount
of
Telone
"
banked"
from
previous
years
is
used
up,
or
the
registrant
convinces
the
California
Department
of
Pesticide
Regulation
that
permanent
increases
are
justified
by
reassessing
the
oncogenic
risk
Township
caps
originally
set
by
California
were
90,250
"
adjusted"
pounds
per
township
per
year
(
Appendix
P).
Adjusted
pounds
are
actual
pounds
of
1,3­
D
applied
times
an
application
factor.
This
calculates
out
to
approximately
345
acres
in
a
township
can
be
treated
with
InLine
using
VIF
mulch.
Since
a
township
is
approximately
25,000
acres,
and
many
townships
in
the
Northern
and
Southern
strawberry
growing
regions
have
over
a
thousand
acres
in
strawberries
in
many
townships,
obviously
not
all
strawberries
growers
could
use
Telone
products.

DPR
recently
doubled
the
township
cap
in
many
of
the
townships
where
previous
use
did
equal
the
amount
allowed
under
the
old
township
cap
(
Appendix
S).
In
essence,
the
unused
amount
was
"
banked"
for
future
use.
This,
however,
is
only
a
temporary
solution,
until
the
"
banked"
amounts
are
used
up.
Meanwhile,
the
1,3­
D
registrant
is
working
with
DPR
to
revise
regional
modeling
schemes
to
determine
whether
permanent
caps
should
be
recalculated
based
on
each
region's
weather
conditions.
Such
analysis
so
far
is
predicted
to
result
in
caps
close
to
the
current
increased
caps
or
between
the
old
and
new.

Dr.
Tom
Trout
of
USDA
has
provided
an
analysis
of
the
impacted
acres
of
strawberries
in
each
county
based
on
the
old
and
new
township
cap
(
Appendix
P).
His
analysis
shows
at
best
that
Telone
products
will
not
be
available
to
47%
of
the
total
strawberry
acreage
in
the
state.
For
the
strawberry
growing
regions,
his
study
projects
unavailable
acres
according
to
the
following
table
(
based
on
2001
acreage):

Region
Total
Acres
Straw
Acres
Unavailable
%
of
Acres
Watsonville
10,759
4,344
40.4%
Santa
Maria
3,817
1,645
43%
Ventura
County
7,777
4,228
54%
Orange
County
2,446
243
10%

Roughly
half
of
the
Southern
acreage
would
not
be
able
to
use
Telone
products.
And
roughly
40%
of
the
Northern
acreage
would
not.
Considering
it
is
not
economical
for
the
Northern
rotation
growers,
to
account
for
concentration
of
non­
rotation
acres
in
the
same
affected
townships,
from
40­
100%
of
the
2,500
acres
of
non­
rotational
growers
acres
in
the
Watsonville
area
could
use
the
material,
although
they
could
still
suffer
losses
using
it
over
MBC.
Much
of
the
land
in
the
Watsonville
area
however
is
not
amenable
to
drip
applications
because
of
soil
type
and
hilliness,
further
reducing
use
of
the
material.
The
1645
acres
in
Santa
Maria
would
be
available
and
only
4,228
acres
in
Ventura.
At
best
then,
8,373
strawberries
acres
may
be
able
to
use
the
material.
This
roughly
calculates
to
availability
to
approximately
30%
of
strawberry
growers
at
best
even
under
the
expanded
township
caps.
1,3­
D
is
also
classified
as
a
toxic
air
contaminant
in
the
state
of
California
and
will
undergo
additional
scrutiny
in
future.
This
classification
in
addition
to
the
classification
of
13­
D
as
a
B­
2
probable
carcinogen
contributes
to
an
uncertain
regulatory
future
in
California.

Chloropicrin
The
California
Department
of
Pesticide
Regulation
is
re­
evaluating
chloropicrin
at
this
time
with
anticipated
completion
of
the
review
in
approximately
2­
3
years.
There
are
already
sensitivities
around
the
use
of
the
material
due
to
its
physiological
effects
(
lacrimation
and
upper
respiratory
discomfort)
at
very
low
levels
in
the
air.
Chloropicrin
is
also
currently
listed
as
a
toxic
air
contaminant
in
the
state,
and
could
be
subject
to
additional
regulatory
restraints
after
thorough
review
by
the
Scientific
Review
Panel
of
the
Air
Board.
Of
greatest
concern
is
what
additional
regulatory
restraints
could
be
in
place
in
2005
as
a
result
of
the
DPR
re­
evaluation,
particularly
increases
in
required
buffer
zones
which
would
limit
the
products
use
in
the
highly
urbanized
strawberry
growing
regions.

Buffer
zones
for
the
material
currently
vary
from
county
to
county
and
depend
upon
local
conditions
such
as
proximity
of
a
field
to
sensitive
sites.
In
most
cases
if
a
sensitive
site
(
occupied
buildings,
residences,
businesses,
schools,
hospitals
etc.)
is
within
300
feet
of
a
field,
a
100
foot
or
more
buffer
zone
is
required
depending
on
the
size
of
the
acreage
to
be
fumigated
at
a
given
time.
These
buffer
zones
are
actually
larger
than
buffer
zone
requirements
for
methyl
bromide
applications
near
most
sensitive
sites
(
60
feet
minimum
depending
upon
application
method
and
acres
to
be
fumigated
at
a
given
time.)
(
Appendix
X)

Metam
Sodium
Metam
sodium
recently
completed
review
as
a
Toxic
Air
Contaminant
with
the
California
Air
Resources
Board's
Scientific
Review
Panel
(
Appendix
R).
While
DPR
continues
their
re­
evaluation
of
the
material
there
is
a
great
deal
of
concern
regarding
eventual
buffer
zone
requirements
when
all
the
analyses
are
complete.
It
is
possible
buffer
zone
requirements
of
500
feet
or
more
may
be
required
in
some
situations,
which
would
render
the
material
unusable
in
particularly
urbanized
settings.
If
metam
sodium
buffer
zones
are
increased
this
high,
combined
treatments
with
1,3­
D/
chloropicrin
would
also
be
rendered
unfeasible
particularly
in
urbanized
settings.

Conclusion
The
combined
foil
fumigation
regime
of
1,3­
dichloropropene,
chloropicrin,
and
metam
sodium
is
not
economically
feasible
for
California
strawberry
growers.
This
combined
with
the
continual
regulatory
scrutiny
on
all
three
compounds
renders
the
regime
questionable
in
terms
of
future
viability
in
California.
Biofumigation
All
California
cultivars
are
highly
susceptible
to
Verticillium
wilt,
a
devastating
disease
because
it
causes
premature
plant
death.
It
is
the
most
important
pest
to
strawberries,
and
is
managed
in
the
past
only
with
soil
fumigation.
The
wide
host
range
of
Verticillium
dahliae
and
wide
distribution
in
California
soils
has
rendered
crop
rotation
ineffective.
Broccoli
can
be
an
effective
rotation
crop
for
cauliflower
and
so
was
tested
by
Dr.
Frank
Martin
of
the
USDA­
ARS
in
strawberry
culture
(
Appendix
CC,
Pink
Sheet
01­
11).
While
broccoli
rotations
reduced
disease
severity.
Yields
were
only
77%
of
the
methyl
bromide/
chloropicrin
control,
a
yield
which
is
not
economically
feasible
in
California
strawberry
culture
(
see
economic
analysis
of
metam
sodium.)

Solarization
For
solarization
to
work,
temperatures
under
the
tarp
must
reach
50
°
C.
Solarization
has
been
somewhat
effective
in
the
Central
Valley
of
California
where
air
temperatures
regularly
reach
the
90s
and
100s
during
the
spring
summer
and
fall
and
constant
sunshine
is
the
norm
(
Appendix
DD,
Molinar
handouts).
However,
the
San
Joaquin
Valley
only
accounts
for
approximately
300
acres
of
the
27,000
acres
of
strawberries
produced
in
California
in
2002.

Along
the
coast
of
California,
fog
and
clouds
predominate
in
the
morning
hours
during
most
of
the
growing
season,
and
only
rarely
reach
90
°
F
or
above.
Without
constant
sun
and
high
temperatures
like
the
San
Joaquin
Valley,
solarization
is
not
a
viable
alternative
to
soil
fumigation.
Work
by
Dr.
Steve
Fennimore
et
al.
has
shown
solarization
utilizing
single
layer
tarps
has
little
impact
on
weed
control
(
Appendix
FF,
PMA
Report.)
Work
continues
with
double
layer
tarps,
but
is
so
far
inconclusive.

Steam
In
California
strawberry
culture,
steam
is
not
an
economically
feasible
alternative.
To
control
Verticillium
wilt,
the
steam
needs
to
penetrate
more
than
2
feet
into
the
soil.
The
machinery
needs
to
go
slowly
in
the
field
to
apply
the
superheated
water.
In
doing
so,
an
extremely
large
amount
of
water
is
needed
to
create
enough
steam
to
bring
the
relatively
cool
soil
up
to
a
temperature
where
sterilization
can
occur.
That
much
water
creates
retention
problems
in
the
soil
which
then
requires
a
long
drying
period.
Soil
also
has
to
be
bone
dry
with
no
clods
for
steam
to
work
effectively.
And
finally,
the
fuel
costs
to
create
steam
for
our
representative
40
acres
is
extremely
costly.

Biological
Control
Dr.
John
Duniway
of
the
University
of
California,
Dr.
Carolee
Bull
of
USDA­
ARS,
and
Dr.
Frank
Martin
of
USDA­
ARS
have
done
extensive
work
with
bacterial
inoculums
in
strawberries
searching
for
beneficial
organisms
that
would
increase
yield
in
the
absence
of
soil
fumigation.
None
of
the
scientists
have
identified
effective
mycorrhizal
organisms
(
Appendix
FF,
PMA
Report.)
This
represents
extensive
work
over
3­
4
years.

Cover
Crops
and
Mulching
Cover
crops
are
not
economically
feasible
for
strawberries
growers
because
the
economics
of
cropping
in
the
California
growing
regions
demands
full
use
of
the
land
year
round.
Nearly
all
strawberry
growers
rent
their
land
at
anywhere
from
$
1000­
3000
per
acre.
The
land
must
be
used
all
season
long,
so
there
is
no
allowance
for
fallowing
land
with
cover
crops
such
as
rye,
which
would
not
bring
in
enough
income
to
pay
for
rent
in
this
region.

Plastic
mulch
has
been
used
in
strawberry
culture
for
decades
to
help
control
moisture
content
of
the
beds
and
for
weed
control.
Dr.
Steve
Fennimore
et
al.
has
done
extensive
work
with
colored
tarps
and
VIF
films
in
strawberry
culture
with
and
without
chemical
fumigation.
Colored
tarps
are
used
primarily
for
weed
control
as
an
adjunct
to
potential
alternative
regimes
with
poor
weed
control.

In
organic
production,
black
and
brown
tarps
resulted
in
the
highest
yields
followed
by
white
(
on
black),
red
(
on
brown),
green,
and
yellow
(
on
brown).
However,
overall
yields
were
one
quarter
the
yields
of
marketable
berries
in
fumigated
strawberry
culture
(
Appendix
FF,
PMA
Report.)

In
conventional
production,
clear
tarp
had
significantly
higher
yields
than
any
of
the
colored
tarps
tested.
Most
colored
tarps
do
not
warm
the
soil
as
much
as
clear
tarp,
and
soil
temperature
has
a
significant
impact
on
early
plant
growth
and
berry
production.
Clear
tarps
are
generally
used
more
in
the
Southern
region
where
the
earlier
the
berry
production
the
higher
the
profits.
In
the
Northern
region,
colored
tarps
are
used
more,
but
the
economics
of
that
region
requires
more
a
long
steady
season
of
production.
Black
and
green
tarps
appear
to
control
weeds
best,
but
at
the
expense
of
somewhat
reduced
yield
(
PMA
Report).

Experimentation
with
Virtually
Impermeable
Film
(
VIF)
began
in
California
in
conjunction
with
the
use
of
InLine
soil
fumigant.
While
weed
control
is
weak
with
the
1,3­
D/
chloropicrin
alternative
regime,
VIF
film
used
with
drip
applied
InLine
seems
to
improve
weed
control.
It
is
theorized
that
use
of
VIF
film
holds
fumigant
in
the
soil
longer
increasing
its
effectiveness.
At
the
same
time,
VIF
film
because
of
this
ability,
increases
plant
back
times
to
avoid
potential
phytotoxicity.
Results
of
experiments
up
to
now
with
VIF
film
and
chemical
alternatives
have
been
quite
variable.
Current
experimentation
with
VIF
film
is
aimed
at
determining
appropriate
rates
to
achieve
pest
control
without
subsequent
phytotoxicity
to
transplanted
strawberries.
VIF
film
also
still
suffers
from
quality
and
supply
problems
(
one
major
supplier
will
no
longer
produce
the
material).
For
instance
the
first
year
it
was
tested,
the
VIF
disintegrated
in
the
fields
during
the
growing
season
because
no
UV
barrier
had
been
incorporated.
It
is
also
very
difficult
film
to
distribute
in
the
fields
with
conventional
equipment
and
before
a
large
number
of
growers
find
it
economically
feasible
to
use
the
materials,
an
appropriate
method
of
laying
the
material
down
in
the
field
must
be
found.
So
while
promising,
VIF
film
use
is
still
in
the
experimental
stages
and
not
ready
for
mass
grower
use.

Crop
Rotation/
Fallow
All
California
cultivars
are
highly
susceptible
to
Verticillium
wilt,
a
devastating
disease
because
it
causes
premature
plant
death.
It
is
the
most
important
pest
to
strawberries,
and
is
managed
in
the
past
only
with
soil
fumigation.
The
wide
host
range
of
Verticillium
dahliae
and
wide
distribution
in
California
soils
has
rendered
crop
rotation
ineffective.

Biofumigation
with
crop
rotation
of
Brassica
sp.
has
been
investigated
with
strawberries.
Broccoli
can
be
an
effective
rotation
crop
for
cauliflower
and
so
was
tested
by
Dr.
Frank
Martin
of
the
USDA­
ARS
in
strawberry
culture
(
Appendix
CC,
Pink
Sheet
01­
11).
Rotations
of
broccoli,
brussels
sprouts,
and
lettuce.
While
broccoli
rotations
reduced
disease
severity,
yields
were
only
77%
of
the
methyl
bromide/
chloropicrin
control,
a
yield
which
is
not
economically
feasible
in
California
strawberry
culture
(
see
economic
analysis
of
metam
sodium.)

Flooding
and
Water
Management
Water
is
a
luxury
in
California.
Nearly
all
of
the
water
used
in
agriculture
is
from
the
collection
of
winter
rains
and
snow
melt
into
reservoirs.
Water
is
an
expensive
commodity
and
is
not
available
in
a
large
enough
quantity
at
a
low
enough
price
to
make
flooding
a
viable
option
to
fumigation.
Nematodes
can
survive
in
flooded
fields
as
can
Phytophthora
sps
which
also
renders
this
method
ineffective.
In
addition,
not
all
of
the
strawberry
growing
region
is
flat
land.
Much
of
it
in
the
northern
region
around
Watsonville
is
quite
hilly,
precluding
any
ability
to
successfully
flood
the
fields
and
retain
the
water.
As
more
water
originally
destined
for
agriculture
is
funneled
into
the
burgeoning
urban
areas,
it
is
becoming
an
even
more
precious
commodity
for
growers.
Flooding
is
not
feasible
technically
or
economically
in
this
state.

General
IPM
California
Strawberry
growers
already
use
an
established
and
comprehensive
IPM
program.
For
example,
predatory
mites
are
introduced
early
into
fields
to
control
two­
spotted
spider
mites.
Much
of
the
cultural
practices
already
in
place
are
part
of
that
IPM
program.
Unfortunately,
they
have
not
yet
found
a
nonchemical
IPM
practice
alone
to
control
Verticillium
Wilt
or
Phytophthora
sp.,
the
main
soil
borne
diseases
in
strawberries
(
Appendix
D,
Crop
Profile).
Only
utilizing
land
in
which
no
susceptible
crops
have
ever
been
(
http://
www.
ipm.
ucdavis.
edu/
PMG/
selectnewpest.
strawberry.
html)
has
some
success,
a
very
unlikely
prospect
in
the
heavily
farmed
strawberry
growing
regions.

Grafting/
Resistant
Root
Stock/
Plant
Breeding
Strawberry
plants
cannot
be
grafted
this
only
applies
to
tree
crops.

Plant
breeding
efforts
are
hampered
by
the
severity
and
number
of
diseases
that
affect
California
strawberries.
The
University
plant
breeders,
Dr.
Doug
Shaw
and
Dr.
Kirk
Larson,
have
tried,
testing
49
strawberry
genotypes
over
the
course
of
7
years
in
fumigated
and
non­
fumigate
soil
(
Appendix
GG,
Shaw
and
Larson
2001).
They
found
no
evidence
of
genes
conferring
specific
adaptation
to
nonfumigated
soils,
or
that
genes
that
can
confer
resistance
are
selected
out
by
continual
growth
on
non­
fumigated
soil.
Efforts
will
continue,
but
even
if
genes
were
identified
today
in
available
cultivars,
breeding,
selection,
testing,
and
scale
up
to
commercial
scale
still
take
6­
7
years.

Organic
Amendments/
Compost
Organic
amendments
and
composting
have
also
been
tested
extensively
in
California
strawberry
culture.
Dr
John
Duniway
et
al.
(
Appendix
FF,
PMA
Report)
have
experimented
with
composting
and
high
nitrogen
amendments
in
Verticillium
infested
soil
in
strawberry
production
using
blood,
feather,
and
fish
meal
at
8,
4,
and
8
tons/
acre
respectively.
While
reducing
Verticillium
wilt,
these
treatments
were
also
phytotoxic
to
strawberries,
not
to
mention
very
expensive
at
these
rates.
In
addition,
chicken
manure
and
mature
compost
were
tested
at
8
and
12
tons/
acre
respectively
as
well
as
stabilized
urea,
none
of
which
reduced
Verticillium
wilt
significantly.

See
Biological
Control
for
discussion
of
microorganism
inoculum
as
an
amendment.

Organic
Production
Organic
production
of
strawberries
in
California
is
difficult.
Only
383
acres
of
organic
strawberries
were
projected
for
the
2002
season.
Successful
acreage
is
largely
due
to
having
the
land
available
which
has
little
to
no
Verticillium
wilt
and
other
components
of
the
strawberry
pest
complex.
As
reported
most
recently
at
the
MBAO
2001
conference
by
Dr.
Frank
Sances
(
Appendix
EE),
organic
culture
was
slow,
with
significantly
lower
yields
than
conventional
culture.
In
addition,
weed
growth
resulted
in
very
high
hand
weeding
costs.
In
another
study
by
Dr.
Steve
Fennimore,
yields
in
organic
culture
were
at
best
28%
of
conventional
culture
using
soil
fumigation.
While
research
continues
on
organic
cultural
techniques,
root
diseases
take
the
heaviest
toll
on
organic
strawberries
(
Appendix
EE,
Sances
2001.)
The
most
striking
reality
of
strawberry
production
without
soil
fumigation
was
to
remember
what
strawberry
yields
and
culture
were
like
before
the
advent
of
soil
fumigation
in
the
late
1950'
s.
Then,
even
with
the
continually
improving
University
cultivars,
average
yields
of
strawberries
were
approximately
5,000
lbs
per
acre
(
Appendix
GG,
Wilhelm.)
Compared
to
the
on
average
50,000
lbs
per
acre
achieved
with
soil
fumigation
with
MBC,
organic
culture
would
never
be
able
to
replace
conventional
strawberry
production
in
California.

Resistant
Cultivars
Work
by
Browne
et
al.
(
Appendix
CC,
Pink
Sheet
02­
09)
indicates
that
the
major
University
derived
strawberry
cultivars
used
in
California
are
moderately
to
highly
susceptible
to
Phytophthora
sp.
While
some
other
cultivars
in
the
country
show
some
potentially
useful
resistance,
breeding
with
them
if
they
were
available
would
take
6­
7
years
before
they
were
available
to
growers.
Shaw
and
Larson's
work
also
support
the
lack
of
sufficient
genes
in
strawberry
genotypes
to
withstand
culture
in
non­
fumigated
soil
(
Appendix
GG,
Shaw
and
Larson
2001)

All
California
cultivars
are
highly
susceptible
to
Verticillium
wilt,
a
devastating
disease
because
it
causes
premature
plant
death.
It
is
the
most
important
pest
to
strawberries,
and
is
managed
in
the
past
only
with
soil
fumigation
(
Appendix
FF,
PMA
Report).

Soilless
Culture
Soilless
culture
is
another
very
expensive
cultural
practice
not
feasible
in
California
strawberry
production.
Soilless
culture
takes
up
enormous
greenhouse
space,
resource
and
energy
requirements
for
climate
control,
and
would
require
off­
season
premium
prices
for
strawberries
to
approach
economic
feasibility.
The
capital
outlay
alone
to
construct
enough
greenhouses
to
accommodate
half
a
billion
strawberry
plants
is
unfathomable.
Production
strawberries
are
grown
in
high
density
culture
in
fields
because
it
is
the
most
economical
way
to
produce
large
quantities
of
affordable
strawberries.
Substrates/
Plug
Plants
The
economics
of
production
with
substrates
is
equally
prohibitive
to
that
of
soilless
culture
discussed
above
for
large
scale
California
strawberry
production.
Rockwool
for
instance
is
not
a
cheap
material
and
it
is
doubtful
sufficient
quantities
exist
to
grow
the
over
half
a
billion
strawberry
plants
currently
grown
in
California
strawberry
production.
Substrate
culture
also
requires
greenhouses,
expensive
to
build
and
maintain.
Substrate
culture
has
only
been
successful
on
small
scale,
off­
season
(
therefore
high
prices),
such
as
the
Netherlands,
where
their
strawberry
production
is
a
fraction
of
California
production.

Plug
plants
are
used
to
a
small
extent
in
California
strawberry
production.
Usually
only
Southern
growers
plant
them
for
the
very
early,
high
revenue
market.
Only
Southern
growers
can
do
plug
plants,
usually
only
2­
4
rows,
because
only
short­
day
varieties
are
amenable
to
plug
plant
culture.
The
day
neutral
varieties
used
in
the
north
cannot
be
converted
to
plug
plants
because
of
the
need
for
dormancy
before
planting.
In
addition,
Northern
markets
never
harvest
in
time
for
sufficient
prices
to
make
up
the
difference
in
the
price
of
plug
plants,
25
cents
per
plug
plant
versus
4­
5
cents
regular
plants.
The
price
difference
adds
$
5,400
per
acre
operating
cost
to
a
grower
if
he
were
to
convert
completely
to
plug
plants.
With
the
small
margins
in
strawberry
production,
the
additional
costs
cannot
be
made
up.
Pest
Complex
Controlled
by
Methyl
Bromide/
Chloropicrin
Soil
Fumigation
Pre­
plant
soil
fumigation
with
methyl
bromide
combined
with
chloropicrin
has
been
in
use
in
California
strawberry
production
for
over
forty
years.
The
regime
controls
a
number
of
soil­
borne
diseases,
arthropods,
nematodes,
and
weeds.
In
searching
for
chemical
and
non­
chemical
alternative
regimes,
the
entire
pest
complex
needs
to
be
controlled.
Key
pests
controlled
by
methyl
bromide,
and
their
importance
as
economic
pest
is
found
in
Table
1,
Pest
Complex,
in
the
application
form.
In
addition,
the
7
chemical
regimes
from
the
U.
S.
EPA
matrix
and
their
efficacy
against
these
pests
are
listed
in
Table
1.
[
Labels
(
Appendix
G),
Crop
Profile
(
Appendix
D),
Integrated
Pest
Management
for
Strawberries,
Univeristy
of
California,
Statewide
Integrated
Pest
Management
Project,
Division
of
Agriculture
and
Natural
Resources,
Publication
3351,
1994
http://
www.
ipm.
ucdavis.
edu/
PMG/
selectnewpest.
strawberry.
html,
Field
Day
Handout
Fennimore
2002
(
Appendix
DD)]

At
this
time
in
California,
the
key
primary
pests
controlled
by
methyl
bromide/
chloropicrin
soil
fumigation
are
Verticillium
Wilt,
Phytophthora
diseases
and
a
number
of
weeds.
Nematodes
are
important
and
have
probably
been
kept
in
check
largely
through
the
decades
of
soil
fumigation
and
the
California
Department
of
Food
and
Agriculture
certification
program
requiring
nursery
stock
to
be
free
of
nematode
pests
before
intrastate
transport
and
transplanting.
The
arthropod
complex
has
also
been
kept
in
check
to
some
degree
with
the
decades
of
soil
fumigation.

What
is
unknown
is
to
what
degree
the
importance
and
impact
of
some
of
these
pests
will
change
with
repeated
use
of
alternatives
with
apparent
technical
feasibility.
For
instance,
Dr.
Frank
Martin
studies
"
root
nibler"
diseases
such
as
black
root
rot,
currently
controlled
by
methyl
bromide
and
chloropicrin
mixtures,
but
which
may
grow
into
a
much
larger
problem
with
some
technically
feasible
alternatives.
(
Martin
2001Handout,
Appendix
DD).
Similar
problems
could
erupt
with
the
arthropod
complex
For
instance,
arthropods
not
consider
significant
pests
at
this
time
such
as
root
weevils
and
Strawberry
rootworms,
were
significant
pests
in
the
1950'
s
before
the
advent
of
soil
fumigation
(
Dr.
Frank
Zalom,
2002
Appendix
H).
Representative
User
Description
Introduction
Strawberry
production
is
an
important
component
of
the
agricultural
industry
in
the
state
of
California.
California
produces
83%
of
the
strawberries
consumed
in
the
United
States
and
20%
of
the
strawberries
consumed
in
the
rest
of
the
world
on
50%
of
the
US
acreage.
California
strawberries
brought
a
yearly
average
of
$
734,000,000
gross
revenues
to
the
state
in
the
last
five
years
produced
on
an
average
of
25,000
acres
along
the
south
and
central
coast
of
California
(
California
Strawberry
Commission,
http://
www.
nass.
usda.
gov/
ca/).

Nearly
all
of
the
acreage
is
farmed
by
small
family
farmers
along
the
coast
from
San
Diego
to
Santa
Cruz
(
Appendix
A).
The
mean
size
farm
is
approximately
40
acres,
and
71%
of
the
growers
farm
on
50
acres
or
less
(
see
Worksheet
5).
The
coastal
areas
constitute
99%
of
the
production
strawberry
acres
in
the
state.
The
strawberry
industry
employs
approximately
65,000
people
throughout
the
growing
regions.
Communities
in
strawberry
growing
areas
are
heavily
dependent
on
the
industry
for
major
portions
of
their
local
economies.
Before
fumigation,
over
40
years
ago,
yields
averaged
5
tons
per
acre,
although
variability
of
yields
was
high
due
largely
to
pressure
from
soil
borne
diseases
which
could
wipe
out
a
filed
in
a
matter
of
weeks
(
Wilhelm,
Appendix
GG).
Although
some
of
the
change
in
production
is
due
to
new
varieties
with
higher
yields,
today's
average
yield
of
25
tons
per
acre
with
pre­
plant
soil
fumigation
with
methyl
bromide/
chloropicrin
is
less
variable.
But
in
today's
markets
and
in
today's
highly
regulated
environment
revenue
from
25
tons
per
acre
barely
pays
for
the
costs
of
production.

California
Strawberry
Culture
(
from
California
Strawberry
Crop
Profile)
Strawberries
have
been
described
as
a
perennial
crop
grown
as
an
annual.
To
a
large
extent
this
is
true
once
the
strawberry
plant
reaches
the
production
field.
But
strawberries
are
also
a
fragile
fruit,
highly
perishable
and
susceptible
to
a
multitude
of
diseases
and
pests.
Hence
great
care
is
taken
in
all
stages
of
strawberry
production
including
a
dependence
upon
soil
fumigation
in
the
strawberry
nursery
to
ensure
healthy
stock
for
berry
production.
Included
in
this
package
is
a
Power
Point
presentation,
Overview
of
the
California
Strawberry
Industry
(
Appendix
J).

Nursery
Propagation
of
Strawberry
Stock
The
berry
producing
plant
starts
five
years
earlier
as
nuclear
plant
stock
from
Foundation
Plant
Materials
Services
at
the
University
of
California
or
from
inhouse
meristem
and
clean
stock
programs
in
individual
nurseries.
The
nuclear
plant
stock
is
planted
in
hanging
pots
in
heat
chambers,
and
allowed
to
produce
aerial
runners,
which
never
touch
the
ground.
These
runners
are
then
meristemmed
to
produce
virus
and
disease
free
plants.
The
clean,
meristemmed
plants
are
then
planted
in
the
second
year
in
an
enclosed
screenhouse
(
the
first
foundation
generation)
where
there
is
100%
testing
for
virus
and
nematodes
through
the
California
Department
of
Food
and
Agriculture
Certification
Program.
The
plants
are
also
checked
for
diseases
and
pests
as
well
as
checked
for
"
true
to
type".
The
plants
that
test
clean,
are
then
planted
the
following
year
in
an
outside
foundation
block
where,
again,
they
are
tested
for
virus
and
nematodes
and
visually
inspected
through
out
the
season
for
pests
and
diseases.
Before
planting
either
in
the
screenhouse
or
in
the
outside
foundation
field,
it
is
critical
that
the
ground
be
thoroughly
fumigated
to
control
diseases
and
pests
that
could
infect
the
clean
plants.
Pre­
plant
fumigation
is
required
by
the
California
Department
of
Food
and
Agriculture
Certification
Program.

From
there,
the
stock
is
multiplied
in
the
field
over
the
course
of
two
more
years,
one
more
generation
in
the
field
at
low
elevation
nursery
locations
(
to
produce
registered
stock)
and
the
final
generation
in
the
field
at
high
elevation
nursery
locations
(
to
produce
certified
stock).
In
these
fields
as
well,
it
is
critical
that
ground
be
fumigated
before
each
transplanting
event.
The
plants
are
certified
under
the
California
Department
of
Agriculture
to
be
free
of
nematodes
and
viruses.
Finally,
in
year
six
the
certified
planting
stock
is
planted
in
the
fruit
production
field.
It
is
vital
that
the
fruit
producer
receive
clean,
pest
and
pathogen
free
planting
stock
from
the
nursery.
Once
planted
into
production
fields,
transplants
are
dormant
and
in
a
weakened
state
requiring
clean
fumigated
soil
to
help
fight
off
pests
and
diseases
while
taking
root
in
their
new
environment
through
the
winter.

Fumigation.
Several
weeks
before
planting,
in
all
but
the
organically­
grown
acreage,
the
soil
is
fumigated
with
a
combination
of
methyl
bromide
and
chloropicrin
applied
under
a
sealed
plastic
tarp
(
mulch),
which
is
removed
after
5
days.
Methyl
bromide
alternatives
are
also
beginning
to
be
used
including
drip
applied
1,3­
dichloropropene,
chloropicrin,
and
combinations
thereof,
with
and
without
metam­
sodium.
For
drip­
applied
materials
and
bed
fumigation
with
methyl
bromide,
beds
are
preformed
and
tarped
before
the
fumigation
occurs.
For
flat,
or
broadcast
fumigation,
the
ground
is
first
fumigated
and
then,
after
an
appropriate
waiting
period
to
allow
the
chemical
to
dissipate,
the
ground
is
reworked.
Raised
beds
are
formed,
irrigation
tape
laid,
and
beds
covered
with
the
plastic
mulch,
sheets
of
thin
plastic
which
are
laid
over
the
top
of
the
soil.

Mulch.
Plastic
mulch
is
used
primarily
to
maintain
adequate
soil
temperatures
for
root
growth
but
also
prevents
the
strawberries
from
coming
into
contract
with
soil.
This
reduces
pathogen
transfer
to
the
fruit
and
it
also
enhances
soil
warming
while
improving
water
management.
The
color
of
the
tarp
chosen
for
use
determines
the
efficiency
in
promoting
soil
temperatures
and/
or
weed
control.
Typically,
clear
polyethylene
mulch
is
used
which
is
best
for
warming
the
soil
and
increasing
early
plant
growth.
In
all
growing
regions,
use
of
black
or
colored
tarps
reduce
weed
populations
but
can
result
in
a
10%
early
yield
reduction
due
to
less
effective
soil
warming.
Typcially
fields
tarped
with
clear
vs
colored
tarp
come
into
production
earlier
when
the
market
price
is
higher
Planting.
Clean
plants,
purchased
from
certified
nurseries,
are
planted
in
raised
beds
of
fumigated
soil
containing
irrigation
drip
tape
and
with
plastic
mulch
covering
the
beds.
The
soil
is
fumigated
before
planting.
Drip
tape
and
plastic
mulch
may
be
laid
down
before
planting,
in
which
case
plants
are
planted
in
holes
made
in
the
plastic.
Otherwise
plants
are
planted
directly
into
a
planting
slot
if
the
beds
and
drip
tape
is
laid
down
during
the
planting
process.
Strawberry
plants
are
hand
planted
in
the
fruit
production
fields.
The
plastic
mulch
stays
in
place
until
the
fruit
production
season
is
finished
and
the
plants
are
removed.
In
the
northern
growing
regions
beds
usually
only
contain
two
rows
of
plants
while
the
southern
regions
have
somewhat
wider
beds
with
four
rows
of
plants.

Harvesting.
The
grower
assumes
control
of
all
operations
related
to
harvest.
Once
harvesting
commences,
hand­
harvesting
continues
for
several
months
on
a
3
to
5
day
cycle
for
fresh
berries
and
a
5
to
7
day
cycle
for
processing
berries.
Harvest
season
in
Southern
California
generally
begins
in
January
and
continues
through
May
for
fresh
market
fruit,
through
June
or
July
for
processing
fruit.
Harvest
season
in
the
more
Northern
Districts
begins
in
March
or
April
and
continues
through
October
or
November
depending
on
weather
conditions.
The
Camarosa
variety,
used
predominantly
in
Southern
Districts,
allows
for
the
harvesting
of
fresh
berries
for
the
bulk
of
the
season,
followed
by
the
harvest
of
processing
berries
in
the
last
couple
months.
Diamante
is
the
predominant
variety
for
the
northern
districts
and
is
mainly
suited
for
fresh
production.

The
bulk
of
the
crop
is
planted
in
fall
for
winter
through
summer
production.
Smaller
acreage
of
spring
and
summer
planted
strawberries
planted
in
the
Southern
district
are
harvested
from
late
October
through
January.
With
such
a
long
harvest
season
and
day­
to­
day
picking,
this
is
one
of
the
few
crops
in
California
that
offers
long
term
stability
to
large
numbers
of
workers
in
one
location.
This
fuels
any
number
of
local
economies
and
offers
families
educational
and
economic
opportunities
that
employment
with
other
crops
cannot
provide.

Fresh
strawberries
are
harvested
carefully
by
hand
and
are
not
subject
to
washing
at
the
time
of
harvest
or
subsequent
cooling.
Processing
berries
are
also
carefully
harvested
and
the
calyx
removed
in
the
field
with
a
harvesting
tool.
Processing
berries
are
gently
washed
at
the
packing
facility.
Harvested
strawberries
are
placed
in
trucks
within
an
hour
or
two
of
picking
and
transported
to
the
cooling
facility.
Strawberries
are
typically
forced­
air
cooled
at
temperatures
of
34
°
F
one
to
four
hours
after
harvest.
Cooling
reduces
decay
and
prolongs
the
fruit
shelf
life.
Nearly
all
fresh
strawberries
are
shipped
in
high
nitrogen
atmosphere
to
the
market
in
refrigerated
trucks,
at
temperatures
in
the
range
of
34­
36
°
F
during
shipment.
The
following
examples
are
provided
to
indicate
typical
times
associated
with
the
harvesting,
cooling,
and
shipping
operations:

Time
After
Harvest
Activity
Day
1
Harvest.
Delivery
to
yard
and
cooling
(
1­
4
hours).

Day
2­
6
Shipping
within
the
United
States:
To
Seattle
1
day
To
Denver
2
days
To
Chicago
3
days
To
New
York/
Boston
4
days
Receiving
dock
to
supermarket:
1
day
Day
2­
6
Shipping
outside
the
United
States:
Canada
3­
5
days
Mexico
3­
5
days
Japan(
air
freight)
1
day
Varieties.
Over
a
dozen
major
cultivars
of
strawberries
are
grown
commercially
in
California.
Strawberry
cultivars
are
developed
based
on
several
factors
including
desired
day
length,
productivity,
fruit
size,
flavor,
appearance,
and
vigor.
Cultivars
vary
in
their
susceptibility
to
some
pests
and
abiotic
disorders.
In
2001,
the
Camarosa
strawberry
variety
was
planted
in
43%
of
the
state's
acreage,
with
the
Diamante
variety
planted
in
20%
of
the
acreage.
Proprietary
varieties
account
for
29%
of
the
acreage.
Other
varieties,
for
instance
Chandler
and
Aromas,
comprised
8%
of
the
cultivars
in
2001.
Two
new
varieties
developed
by
the
University
of
California,
Ventana
and
Camino
Real,
were
released
for
the
2002
growing
season.

The
primary
cultivar
grown
in
the
central
and
southern
coastal
regions
is
the
short
day
cultivar
Camarosa,
with
this
variety
accounting
for
98%,
55%,
and
74%
of
the
acreage
in
the
Orange/
San
Diego,
Oxnard,
and
Santa
Maria
districts,
respectively
in
2001.
In
contrast,
Camarosa
is
only
14%
of
the
Watsonville/
Salinas
district.
The
day
neutral
variety
Diamante
and
other
day
neutral,
proprietary
varieties
are
primarily
used
in
the
Watsonville/
Salinas
district
whereas
the
short
day
variety
Chandler
predominates
in
the
San
Joaquin
Valley.
Other
cultivars
that
are
grown
include
Seascape,
Aromas,
and
Selva.
Specific
planting
and
harvest
seasons
vary
from
one
growing
area
to
another;
however,
two
planting
seasons
are
used
in
most
areas
although
winter
planting
is
by
far
the
preferred
planting
season.
Summer
plantings
in
Southern
areas
are
usually
are
made
in
July
or
August,
summer
planting
in
Northern
areas
in
August
or
September.
The
main,
winter
planting
season
for
the
Southern
areas
are
the
last
week
of
September
through
the
first
half
of
October.
The
winter
planting
season
for
the
Northern
districits
starts
in
mid
October
with
short
day
varieties
and
continues
into
mid
November
for
strong
day
neutral
varieties.

Cultural
Practices.
Decisions
related
to
various
cultural
practices
are
made
daily
by
growers.
Decisions
related
to
field
selection,
soil
nutrient
supplements,
and
cultivars
are
made
well
in
advance
of
planting.
Fields
are
graded
and
planting
beds
designed
to
allow
proper
drainage
and
irrigation.
Clean
tillage,
raised
beds,
plastic
mulches
and
water
management
are
all
aspects
of
a
systems
approach
practiced
by
California
strawberry
growers.

Crop
Rotation.
Strawberry
fields
are
sometimes
rotated
with
another
cash
crop
such
as
beans,
broccoli,
lettuce,
and
cauliflower
to
reduce
pest
populations
and
improve
soil
structure.
Cover
crops
such
as
rye
or
barley,
are
also
sometimes
rotated
but
where
land
and
water
costs
are
high,
cover
crops
are
not
economically
feasible.

Sanitary
Techniques.
Growers
rely
on
high
quality
pathogen­
free
cultivar
transplants
and
the
Strawberry
Certification
Program
overseen
by
the
California
Department
of
Food
and
Agriculture
to
help
maintain
their
field
free
of
pests
and
pathogens.
The
certification
program
is
based
on
nursery
soil
treatment
with
methyl
bromide
prior
to
planting.
Grower
are
also
developing
improved
field
sanitations
methods
when
possible
including
such
measures,
working
the
"
cleanest"
(
pathogen
free)
fields
first,
rinsing
the
equipment
with
hot
water
to
remove
soil
and
plant
debris
before
moving
people
and
equipment
into
another
field.
Weeds
are
removed
by
hand
from
and
around
strawberry
fields
before
they
produce
seed.
Growers
also
try
to
ensure
that
manure
or
other
organic
amendments
added
to
the
fields
have
been
properly
composted
or
sterilized.

Pesticide
Application
Practices.
All
applications
of
pesticides
in
California
are
under
the
control
of
the
growers,
and/
or
their
Pest
Control
Adviser
(
PCA),
or
Pest
Control
Operator
(
PCO).
Growers,
PCAs,
and
PCOs
work
closely
to
insure
that
only
registered
pesticide
products
are
used
and
that
they
are
applied
in
compliance
with
all
state
and
federal
laws,
rules
and
regulations,
and
labeled
recommendations.

Communication
between
growers,
PCAs,
and
PCOs
is
maintained
during
the
planting
and
production
periods
through
frequent
field
visitations
by
grower
representatives
and/
or
their
PCAs.
The
applicator
must
inform
all
affected
parties
in
close
proximity
to
the
intended
treated
area
(
e.
g.,
harvesting
crews,
weeding
crews,
irrigators,
etc.)
of
their
intent
to
apply
pesticides
in
advance
of
the
application
and
must
also
post
fields
and
file
post­
application
paperwork
with
the
appropriate
state
and/
or
federal
agency.
Closed
systems
are
also
mandatory
for
the
application
of
Toxicity
Category
I
pesticides
in
California.

Fall
planted
berries
are
hand
weeded
approximately
multiple
times
during
the
season,
soon
after
planting,
and
again
in
January
or
March
and
then
as
needed
throughout
the
season.
Runner
are
cut
multiple
times
during
the
season
at
the
same
times
crews
are
weeding
the
fields.
Strawberries
are
all
hand
harvested,
once
or
twice
a
week
from
depending
on
time
of
year
and
varietal
production
patterns.
Most
of
the
fruit
is
picked
two
times
a
week
on
a
two
or
three
day
rotational
cycle.
.
Picking
crews
generally
work
six
days
a
week
during
this
period.
Processing
berries,
usually
picked
toward
the
end
of
the
season
in
Southern
California,
are
generally
picked
once
a
week.
In
the
northern
districts,
processing
berries
are
picked
on
the
same
schedule
as
fresh
market
fruit.
The
decision
to
switch
from
fresh
to
processed
product
is
determined
by
fruit
quality
and
market
conditions.
Irrigation,
fertilization,
and
many
pesticide
applications
are
done
through
drip
irrigation.
Sprinkler
irrigation
is
only
done
right
after
planting
from
October
through
Thanksgiving.
Summer
planted
berries
have
similar
regimes.

Summary
Pre­
plant
soil
fumigation
allows
production
of
approximately
650,000
tons
of
strawberries
on
the
total
acreage
equivalent
to
one
township,
approximately
25,000
acres.
Strawberry
production
in
California
reflects
one
of
the
most
environmentally
friendly
facts
about
modern,
high
intensity
agriculture;
high
quality
productivity
impacting
fewer
and
fewer
acres.

Representative
User
The
representative
strawberry
production
grower
in
California
is
a
small
family
farmer
who
grows
strawberries
on
an
average
of
40
acres
of
rented
land
along
the
south
or
central
coast
of
California
(
growing
region
map.)
The
grower
usually
fumigates
the
soil
and
plants
in
the
fall
for
harvest
during
the
winter,
spring
and
summer
of
the
following
year.
Two
distinct
regions
can
be
identified
with
somewhat
different
harvest
schedules
although
their
overall
economics
of
costs
and
revenues
are
nearly
identical.
In
2001,
the
Southern
region
(
41%
of
total
acreage)
resides
along
the
coast
in
Orange
and
San
Diego
counties
plus
the
Oxnard
plain
in
Ventura
County
(
Appendix
A).
This
region
plants
early
and
starts
harvesting
early,
profiting
from
higher
berry
prices
due
to
limited
supply
and
high
demand.
In
2001,
the
Northern
region
(
58%
of
total
acreage)
resides
along
the
Santa
Maria
coast
in
northern
Santa
Barbara
and
San
Luis
Obispo
counties
plus
the
Watsonville
coast
of
Santa
Cruz
and
northern
Monterey
counties
(
Appendix
A).
This
region
plants
a
little
later
and
harvests
later
over
a
longer
time
period,
profiting
from
high
volume
through
a
long
season
into
early
fall.

We
have
three
representative
users
to
discuss
for
purposes
of
this
application,
two
for
the
Northern
Region
and
one
for
the
Southern
Region.
Since
the
economics
of
production
and
farm
production
practices
of
each
of
these
regions
overlaps
with
many
of
the
sub­
markets,
we
feel
these
users
adequately
represent
the
entire
consortium
of
California
Strawberry
growers.

Southern
Region
Representative
User.

Soil
fumigation
occurs
in
July­
September
with
planting
commencing
in
late
September
and
early
October.
Flat,
or
broadcast,
soil
fumigation
with
methyl
bromide
and
chloropicrin
formulations
are
the
predominant
method,
usually
a
custom
application
done
by
a
fumigation
company.
When
flat
fuming,
the
ground
is
disked,
plowed
and
leveled,
and
sprinklers
are
put
in.
After
a
thorough
irrigation,
the
pipes
are
pulled
and
the
edges
are
disked
when
dry
enough
to
prepare
for
fumigation.
At
the
proper
moisture
level
the
ground
is
flat
fumed,
a
method
in
which
a
tractor
injects
methyl
bromide
into
the
ground
and
immediately
(
on
the
same
tractor)
the
ground
is
covered
with
plastic.
With
each
pass
the
tarp
is
glued
to
the
tarp
from
the
previous
pass
so
that
when
finished
the
field
is
sealed
with
one
continuous
sheet
of
plastic.
After
at
least
5
days,
the
plastic
is
cut
and
removed,
the
field
re­
irrigated,
and
at
the
proper
moisture
level,
beds
are
pulled
up.
Usually
any
broadcast
applications
of
fertilizer/
amendments
are
done
just
before
the
beds
are
made.
As
the
beds
are
pulled
a
slow
release
fertilizer
is
placed
into
the
top
of
the
bed.
The
drip
tape
for
irrigation
is
then
laid
in
the
bed
and
the
plastic
mulch
is
applied.
Slits
are
mechanically
cut
into
the
plastic
mulch
on
the
beds
and
nursery
transplants
placed
into
the
holes
at
least
7
days
after
the
fumigation,
usually
longer
because
of
the
field
preparation
time.
Sprinklers
are
put
in
the
field
and
supplement
irrigation
after
planting
for
the
first
two
months.

Timing
of
fumigation
activities
are
governed
primarily
by
when
growers
need
to
plant
the
new
crop
for
the
next
season.
Planting
in
the
southern
region
needs
to
be
done
by
mid­
October
at
the
latest
and
can
occur
as
early
as
late
September
to
get
the
level
of
growth
and
berry
production
necessary
for
producing
at
the
earliest
possible
date
when
prices
are
highest.
By
May
and
June
most
of
the
harvest
switches
over
to
processed
freezer
berries,
which
generally
run
half
the
price
of
fresh
berries.

The
plants
after
harvest
is
complete
are
usually
removed
by
the
beginning
of
July
to
provide
adequate
preparation
time
for
fumigation
and
planting
for
the
following
season.
Such
activities
consist
of
taking
down
old
beds,
reworking
the
ground
and
irrigating
to
proper
moisture
levels
(
2­
3
weeks)
and
fumigating
the
soil
(
under
current
California
regulations
1­
3
weeks
depending
on
size
of
the
fields
and
proximity
to
sensitive
areas).
Additional
time
needs
to
be
incorporated
for
the
plant
back
time
of
at
least
7
days
from
the
time
of
fumigation
with
methyl
bromide/
chloropicrin
(
MBC),
and
the
additional
time
for
bed
formation,
preparation
and
mulching,
and
finally
planting
of
transplants
for
the
next
season.

The
Southern
Region
winter
planted
varieties
are
short­
day
cultivars
and
are
planted
in
late
September
and
early
October.
Growers
use
high
quality
pathogen­
free
cultivar
transplants
thanks
to
the
Strawberry
Certification
Program
of
the
California
Department
of
Food
and
Agriculture
and
the
production
practices
of
the
California
strawberry
nurseries,
to
help
maintain
their
fields
free
of
pathogens.
The
certification
program
is
based
on
nursery
soil
treatment
with
methyl
bromide
prior
to
planting.

After
planting,
transplants
grow
vegetatively
the
first
two
months
and
start
producing
marketable
berries
in
January
and
continue
in
fresh
production
into
May,
sometimes
June,
before
switching
to
freezer
(
processed)
production.
In
some
cases,
lower
quality
berries
during
the
primary
fresh
picking
season
are
also
harvested
separately
for
juice
production.
Once
harvesting
commences,
hand­
harvesting
continues
for
several
months
on
a
3
to
5
day
cycle
for
fresh
berries
and
a
5
to
7
day
cycle
for
processing
berries.
This
continual
harvesting
ceases
when
the
productivity
of
the
field
diminishes
significantly.
The
predominant
variety
in
the
Southern
region,
Camarosa
(
65%
in
2001,
Appendix
B),
allows
harvesting
of
fresh
berries
for
the
bulk
of
the
season,
followed
by
processing
berries
in
the
last
couple
months
of
harvest.
The
remaining
35%
of
acres
are
planted
in
proprietary
varieties.

Fresh
harvest
lasts
26
weeks
in
the
south,
(
January
1
through
June
30),
and
processed
harvest
will
last
17
weeks
(
mid
April
to
mid
August)
(
Appendix
K,
Economics
Spreadsheet,
Tab
"
2001
Fresh
Prices").
Fresh
strawberries
are
harvested
carefully
by
hand
every
three
to
five
days
and
are
not
subject
to
washing
at
the
time
of
harvest
or
subsequent
cooling.
Processing
berries
are
also
hand­
harvested
once
a
week
and
the
calyx
removed
in
the
field
with
a
harvesting
tool.
Processing
berries
are
gently
washed
at
the
packing
facility.
Harvested
strawberries
are
placed
in
trucks
within
an
hour
or
two
of
picking
and
transported
to
the
cooling
facility.
Strawberries
are
typically
forced­
air
cooled
at
temperatures
of
34
°
F
one
to
four
hours
after
harvest.
Cooling
reduces
decay
and
prolongs
the
fruit
shelf
life.

Nearly
all
fresh
strawberries
are
shipped
to
the
market
in
refrigerated
trucks,
at
temperatures
in
the
range
of
34­
36
°
F
during
shipment.
Transportation
by
truck
across
North
America
takes
from
2­
6
days
to
the
retail
markets.

Northern
Region
Representative
Growers
Much
of
the
practices
in
the
North
mirror
the
South.
Custom
flat
fumigation
by
contract
fumigation
companies
is
the
norm,
although
some
grower­
conducted
bed
fumigation
(
see
below)
is
done
in
this
region.
Differences
between
the
regions
are
in
fumigation
timing,
September
through
November
for
the
North,
and
planting
times.

Watsonville
is
predominantly
winter
planted
with
fresh
plants.
If
the
plants
are
short
day
varieties
(
Camarosa),
then
they
are
dug
out
of
the
nurseries
in
early
October,
and
planted
with
about
one
week
additional
cold
storage.
These
plants,
depending
on
the
weather,
will
start
producing
in
late
March
or
early
April
and
continue
into
August.
If
a
day
neutral
variety
(
Diamante)
is
being
planted
in
the
Watsonville
area,
then
the
plants
are
dug
out
of
the
nursery
in
mid
to
late
October,
and
given
from
3
to
5
weeks
additional
cold
storage
before
planting.
The
actual
start
date
of
production
is
very
variety
dependent
but
they
should
start
producing
in
April
and
continue
until
the
rain
starts
in
the
fall
(
sometime
in
October
or
November).
So
planting
in
the
North
can
run
from
mid­
October
through
November.

The
predominant
cultivar
in
the
Northern
Region
is
Diamante
(
35%
of
acreage
in
2001),
a
day
neutral
variety.
Camarosa
is
also
grown,
mostly
in
the
Santa
Maria
area
(
29%
of
acreage
in
2001,
Appendix
B).
Propriety
varieties
constitute
27%
of
the
acreage.
The
remaining
9%
are
small
acreages
of
other
varieties.

Harvest
timings
run
longer
in
the
North
than
the
South.
Fresh
harvest
ran
35
weeks
in
2001,
from
mid­
March
through
mid­
November.
Processed
harvest
runs
mid­
April
through
mid­
November,
31
weeks
in
2001
(
Appendix
K,
Economics
Spreadsheet,
Tab
"
2001
Prices").

Approximately
half
of
the
growers
in
the
northern
region
alternate
the
fields
they
use
for
strawberry
production
with
vegetable
growers
over
the
course
of
two
years
(
three
quarters
of
Watsonville,
none
of
Santa
Maria).
A
field
fumigated
in
the
fall
is
taken
through
production
into
October
or
November
and
then
turned
over
to
a
vegetable
grower,
who
may
grow
two
to
three
crops
of
lettuce,
broccoli,
celery,
or
some
other
annual
vegetable
through
the
next
year.
The
land
will
then
go
back
to
the
strawberry
grower
at
the
end
of
the
next
summer
or
early
fall
in
time
for
soil
fumigation
and
start
of
another
strawberry
cycle,
typically
the
end
of
September.
We
are
calling
this
representative
grower
the
Rotation
grower.

If
a
grower
is
going
from
strawberries
to
strawberries,
they
will
not
harvest
through
November,
but
pull
the
crop
our
earlier
in
order
to
have
time
to
do
prep
and
fumigation
and
plant
mid­
late
October
or
November.
This
system
requires
pulling
out
last
years
crop
at
the
latest
at
the
end
of
September.
This
shortens
their
harvest
time
and
reduces
their
overall
revenue
compared
to
rotating
growers.
This
would
be
a
worst
case
scenario
financially
for
the
Northern
grower.
We
are
calling
this
grower
the
Non­
Rotation
grower.

For
rotation
growers
getting
the
land
back
from
the
vegetable
growers
in
a
timely
fashion
is
essential.
A
rotational
grower
can
experience
a
time
crunch
relating
to
their
fumigation
operation
if
they
cannot
get
ground
back
by
mid
September.
This
can
through
the
fumigation
and
planting
schedules
out
of
the
optimum
window.
Planting
even
a
week
or
two
beyond
the
window
for
the
cultivar
can
significantly
reduce
yields
for
the
coming
season
(
Shaw,
Larson
personal
communication).
In
addition,
this
grower
must
flat
fumigate
before
planting
strawberries
to
ensure
complete
coverage
and
pest
control
of
the
entire
field
or
the
vegetable
grower
will
not
accept
the
land
for
vegetables
following
the
strawberry
plant.
For
instance,
drip
fumigation
does
not
control
pests
and
weeds
along
the
sides
of
beds
or
in
the
furrows.
Without
thorough
fumigation
the
vegetable
grower
faces
intense
and
spotty
pest
pressure
when
the
field
is
turned
over
to
vegetables.

All
of
these
aspects
become
important
when
addressing
alternatives
and
their
longer
plant
back
and
preparation
times.
Given
longer
times
for
field
preparation
and
longer
plant
back
waiting
periods
required
for
alternative
fumigants,
rotation
growers
may
find
themselves
in
a
position
of
not
being
able
to
obtain
land
for
the
next
season.
Or
the
rotation
grower,
to
obtain
land,
must
take
the
land
from
the
vegetable
grower
early,
preventing
that
grower
from
growing
a
second
or
third
vegetable
crop.
In
the
best
case,
the
consequence
to
the
strawberry
grower
is
to
pay
approximately
¼
year's
extra
land
rent,
on
average
about
$
525/
acre
(
land
rent
is
$
1,800­
2,400
per
acre,
or
an
average
of
$
2,100
per
acre).
The
additional
time
can
be
used
by
the
strawberry
grower
for
ground
prep
and
fumigation
to
accommodate
longer
prep
times
and
plant
back
times
of
the
alternatives.
It
is
also
likely
the
strawberry
grower
will
also
have
to
compensate
the
vegetable
grower
for
lost
crop,
which
would
further
increase
the
rotation
growers
costs.

The
non­
rotation
grower
already
suffers
from
less
revenue
per
year
because
he
must
pull
crop
by
the
end
of
September,
at
the
latest
of
continuing
to
harvest
through
mid­
November
in
the
same
manner
as
the
rotational
grower.
For
longer
field
preparation
and
plant
back
times
with
alternatives,
the
non­
rotation
grower
will
have
to
pull
crop
even
sooner
to
have
sufficient
time
to
fumigate
and
plant
in
the
proper
planting
window
for
the
next
season.

To
deal
with
the
somewhat
different
economics
of
the
rotation
and
non­
rotation
scenario,
and
to
account
for
growers
who
may
do
both,
the
economics
are
separated
in
the
application,
but
the
final
net
income
result
is
averaged.
The
worst­
case
scenario
is
still
the
non­
rotational
grower.
But
also
taking
into
consideration
that
in
the
economics
we
have
left
out
overhead
costs
to
provide
an
overall
best­
case
scenario.
If
overhead
costs
are
included,
all
growers
average
in
the
red.

Bed
Fumigation
Fewer
and
fewer
growers
are
conducting
bed
fumigation,
largely
because
of
permit
restrictions
and
buffer
zones
imposed
by
the
California
Department
of
Pesticide
Regulation.
Less
than
10%
of
growers
do
bed
fumigation
anymore,
and
that
percentage
continues
to
drop
because
of
the
current
state
promulgated
permit
requirements
which
require
such
large
buffer
zones
that
bed
fumigation
is
no
longer
feasible
or
cost
effective
for
many
growers.
There
are
no
growers
that
can
do
exclusively
bed
fumigation
any
longer.

When
bed
fuming,
the
field
is
disked,
plowed
and
leveled,
and
sprinklers
are
put
in
for
pre­
irrigation.
At
the
proper
moisture
level
the
pipes
are
pulled,
any
broadcast
application
to
be
made
is
done,
the
ends
are
disked
and
the
beds
are
pulled.
The
irrigation
drip
tape
is
then
laid
and
another
tractor
injects
fumigant
while
laying
the
plastic
mulch.
Planting
cannot
be
done
for
14
to
21
days.
Costs
for
bed
fuming
generally
run
$
1000
per
acre
less
than
custom
flat
fumigation,
hence
many
small
growers
prefer
to
do
bed
fumigation
to
significantly
reduce
their
costs
of
production.

To
deal
with
this
for
representative
user,
the
economic
baseline
for
the
Northern
grower
is
a
weighted
average
of
the
Cost
of
Production
documents
for
the
Santa
Maria
area
and
the
Watsonville
area
since
the
Santa
Maria
COP
is
based
on
bed
fumigation
costs.
Since
most
growers
who
do
bed
fumigation
combine
bed
with
flat
fumigation,
this
weighted
average
is
actually
more
representative
of
average
costs
for
the
Northern
region.

Costs
of
Production
and
Revenues
Three
Cost
of
Production
documents
(
COP)
were
completed
in
2001
by
the
University
of
California,
Davis,
Cooperative
Extension
based
on
interviews
with
representative
growers
in
three
regions,
Ventura
County,
Santa
Maria
Valley,
and
the
Monterey
&
Santa
Cruz
County
region
(
Appendix
L,
http://
coststudies.
usdavis.
edu).
Based
on
typical
harvest
schedules
in
these
regions,
the
Santa
Maria
Valley
parallels
much
more
closely
the
berry
production
and
harvest
schedule
of
the
northern
most
region
Monterey
&
Santa
Cruz
counties
("
2001
Prices
tab",
Appendix
K).
Ventura
County
also
represents
the
most
southern
regions
of
Orange
and
San
Diego
County
in
harvest
schedule
and
practices.
We
have
therefore
used
the
data
from
these
studies
to
represent
the
Northern
and
Southern
growers
in
California.

The
COPs
are
far
more
detailed
than
needed
for
the
economic
feasibility
portion
of
the
CUE.
So
various
detail
activities
are
combined
into
more
general
cost
areas,
which
would
not
typically
change
with
use
of
alternatives
(
Worksheets
2­
E
of
Application).

Conclusion
California
strawberry
production
is
nearly
completely
represented
by
these
three
economic
representative
growers.
Production
is
highly
dependent
on
results
of
soil
fumigation
with
methyl
bromide
chloropicrin
mixtures.
Even
so,
this
highly
productive
agricultural
system
in
today's
markets
has
very
little
profit
margin.
So
even
seemingly
small
yield
losses
can
result
in
bankruptcy.
Transitions
to
alternatives
must
be
done
carefully
to
avoid
losses
that
put
a
grower
out
of
business
before
he's
been
able
to
determine
optimal
conditions
in
his
specific
circumstances
of
soil,
geography,
and
pest
pressure
with
any
promising
alternative.
20a.
Why
is
this
representative
user
typical?

The
three
Northern
and
Southern
Representative
Users
represents
85%
of
the
growers
in
the
consortium.
Even
though
their
market
timing
is
different,
the
costs
of
production
per
acre
are
remarkably
the
same
and
the
cultural
practices
are
almost
identical
with
some
differences
in
timing
of
specific
operations.

Smaller
sub­
markets
exist
in
California
as
well
(
Appendix
B).
Summer
berries,
6%
or
less
of
total
production
berries
in
2001,
are
found
only
in
the
Ventura
County
region.
Soil
fumigation
occurs
in
spring
and
planting
in
June
for
fall
harvest.
Economically,
the
bulk
of
this
market
follows
the
Northern
region
prices
and
harvesting
schedule
although
it
extends
longer
into
November
and
December.
The
Central
Valley,
down
to
1­
2%
of
berry
production,
parallels
the
main
planting
and
harvesting,
but
berries
go
primarily
to
processing
or
fruit
stands.
Second
year
berries
constitute
approximately
5­
7%
of
total
production
and
are
usually
have
lower
quality,
therefore
the
second
year
and
picked
primarily
for
processing.
The
economics
of
second
year
fruit
parallels
first
year
berries.
Finally
organic
berry
production
is
only
1­
2%
of
production,
but
relies
on
nursery
plants
produced
on
fumigated
soil
which
is
allowed
by
Organic
Certification
Regulations
and
required
to
meet
California
State
nursery
certification
cleanliness
requirements
(
http://
www.
cdfa.
ca.
gov).
2001
Fresh
Berry
Volume
and
Prices
Weekly
Price
­
Volume
Data
2001
California
FRESH
Week
SD,
O,
LA
ctys
Oxnard
South
total
Santa
Maria
Watsonvile
North
total
Ending
Volume
Price
Value
Volume
x
Price
Volume
Volume
Volume
Value
Vol
x
Price
Volume
Volume
Volume
Value
Vol
x
Price
1/
6
163800
$
25.95
$
3,821,250
$
0.05
91700
72100
163800
$
3,821,250
$
0.14
1/
13
182300
$
25.38
$
4,630,275
$
0.06
85000
97300
182300
$
4,630,275
$
0.17
1/
20
155600
$
19.61
$
2,510,675
$
0.03
69400
86200
155600
$
2,510,675
$
0.09
1/
27
446000
$
14.32
$
5,303,675
$
0.06
140800
305200
446000
$
5,303,675
$
0.20
2/
3
476500
$
13.06
$
6,185,550
$
0.07
124600
351900
476500
$
6,185,550
$
0.23
2/
10
994800
$
14.58
$
13,564,525
$
0.16
215900
767100
983000
$
13,564,525
$
0.50
11800
2/
17
272400
$
14.75
$
3,776,000
$
0.05
82200
190200
272400
$
3,776,000
$
0.14
2/
24
607400
$
10.46
$
9,156,908
$
0.11
161700
445700
607400
$
9,156,908
$
0.34
3/
3
224000
$
7.92
$
3,534,720
$
0.04
50700
173300
224000
$
3,534,720
$
0.13
3/
10
223000
$
7.89
$
3,518,940
$
0.04
135600
87400
223000
$
3,518,940
$
0.13
3/
17
882900
$
7.34
$
12,779,039
$
0.15
259700
619700
879400
$
12,734,414
$
0.47
3500
3500
$
44,625
$
0.00
3/
24
1811600
$
7.54
$
17,624,742
$
0.21
473100
1276600
1749700
$
17,096,823
$
0.63
61900
61900
$
527,919
$
0.01
3/
31
1746300
$
11.87
$
20,748,338
$
0.25
453000
1183900
1636900
$
19,511,077
$
0.72
91900
17500
109400
$
1,237,261
$
0.02
4/
7
1175900
$
13.96
$
16,072,502
$
0.19
271500
730400
1001900
$
13,856,277
$
0.51
99300
74700
174000
$
2,216,225
$
0.04
4/
14
2060200
$
15.73
$
31,147,250
$
0.37
495600
1371800
1867400
$
28,326,542
$
1.05
125100
67700
192800
$
2,820,708
$
0.05
4/
21
4371400
$
9.37
$
35,111,386
$
0.42
910600
2738700
3649300
$
29,009,643
$
1.08
449300
272800
722100
$
6,101,743
$
0.11
4/
28
5266700
$
6.47
$
33,920,560
$
0.41
886300
3168200
4054500
$
26,536,380
$
0.99
833000
379200
1212200
$
7,384,180
$
0.13
5/
5
5763200
$
6.06
$
34,441,951
$
0.41
384700
2981400
3366100
$
20,034,877
$
0.74
1369500
1027600
2397100
$
14,407,074
$
0.26
5/
12
5616300
$
6.06
$
34,439,763
$
0.41
113600
2366500
2480100
$
15,103,649
$
0.56
1613100
1523100
3136200
$
19,336,114
$
0.35
5/
19
4718900
$
5.69
$
27,473,360
$
0.33
22900
1196800
1219700
$
6,721,880
$
0.25
1643400
1855800
3499200
$
20,557,080
$
0.37
5/
26
4328500
$
6.14
$
27,944,850
$
0.34
11600
671400
683000
$
3,979,350
$
0.15
1518400
2127100
3645500
$
23,965,500
$
0.44
6/
2
3354100
$
6.92
$
24,600,740
$
0.30
5100
336500
341600
$
2,257,240
$
0.08
824400
2188100
3012500
$
22,343,500
$
0.41
6/
9
3635300
$
7.95
$
30,051,270
$
0.36
7400
194000
201400
$
1,591,060
$
0.06
596800
2837100
3433900
$
28,460,210
$
0.52
6/
16
3397700
$
6.68
$
22,664,880
$
0.27
8400
47300
55700
$
242,830
$
0.01
356300
2985700
3342000
$
22,422,050
$
0.41
6/
23
3029500
$
6.71
$
20,588,050
$
0.25
5400
2500
7900
$
52,860
$
0.00
174600
2847000
3021600
$
20,535,190
$
0.37
6/
30
2887700
$
7.90
$
22,812,830
$
0.27
5600
2200
7800
$
61,620
$
0.00
149100
2730800
2879900
$
22,751,210
$
0.41
7/
7
2375400
$
7.82
$
18,530,360
$
0.22
110500
2264900
2375400
$
18,530,360
$
0.34
7/
14
2303900
$
8.40
$
19,352,760
$
0.23
109100
2194800
2303900
$
19,352,760
$
0.35
7/
21
2055900
$
8.40
$
17,269,560
$
0.21
total
26936400
$
9.40
108800
1947100
2055900
$
17,269,560
$
0.31
7/
28
2105500
$
8.40
$
17,686,200
$
0.21
total
lbs
309,768,600
129800
1975700
2105500
$
17,686,200
$
0.32
8/
4
1931800
$
8.40
$
16,227,120
$
0.19
cool
costs
$
1.40
103700
1828700
1932400
$
16,227,120
$
0.29
8/
11
1829000
$
8.90
$
16,168,800
$
0.19
yield
30301
88500
1740500
1829000
$
16,168,800
$
0.29
8/
18
1576500
$
10.23
$
16,081,200
$
0.19
avr
less
cool
$
8.00
80400
1496100
1576500
$
16,081,200
$
0.29
8/
25
1392900
$
12.32
$
16,992,610
$
0.20
75200
1317700
1392900
$
16,992,610
$
0.31
9/
1
1276100
$
13.40
$
17,220,890
$
0.21
11.5
$
0.695
62300
1213800
1276100
$
17,220,890
$
0.31
9/
8
1279400
$
11.04
$
13,883,060
$
0.17
process
$
0.306
41700
1237700
1279400
$
13,883,060
$
0.25
9/
15
1039340
$
8.44
$
8,505,806
$
0.10
23200
1016100
1039300
$
8,505,806
$
0.15
9/
22
937000
$
8.36
$
6,119,400
$
0.07
25500
911500
937000
$
6,119,400
$
0.11
9/
29
949400
$
5.06
$
9,752,760
$
0.12
$
59,660
7600
23000
738600
761600
$
9,315,280
$
0.17
10/
6
964000
$
9.48
$
10,787,600
$
0.13
$
7.850
$
497,690
63400
26800
873800
900600
$
10,086,340
$
0.18
10/
13
942100
$
10.35
$
9,799,040
$
0.12
$
923,160
117600
24000
757500
781500
$
8,123,800
$
0.15
10/
20
801500
$
8.58
$
6,912,100
$
0.08
$
1,588,840
202400
26600
632500
659100
$
5,683,040
$
0.10
10/
27
794900
$
8.57
$
6,796,860
$
0.08
$
2,234,110
284600
28700
481900
510600
$
4,359,590
$
0.08
11/
3
510400
$
9.57
$
4,884,528
$
0.06
$
8.480
$
2,147,136
253200
6500
250700
257200
$
2,462,680
$
0.04
11/
10
478400
$
12.43
$
5,946,512
$
0.07
$
2,787,376
328700
19300
194900
214200
$
2,229,430
$
0.04
11/
17
$
1,301,680
153500
3200
10000
13200
11/
24
$
1,706,176
201200
11100
18600
29700
12/
1
$
8.49
$
1,253,344
147800
2200
3000
5200
12/
8
$
892,096
105200
5000
5000
12/
15
83335440
958,357,560
lbs
$
803,056
94700
7300
7300
12/
22
$
412,128
48600
10900
10900
weighted
avr
$
8.49
$
16,606,452
cool
costs
$
1.40
Summer
Total
1257500
total
55031900
$
8.02
Gross
avr
less
cool
$
7.09
26928.67453
total
lbs
632,866,850
cool
costs
$
1.40
yield
42417
11.5
$
0.616
avr
less
cool
$
6.62
process
$
0.306
Total
lbs
1,266,994,146
lbs/
acre
50392
11.5
$
0.576
18.42995308
tons/
acre
process
$
0.306
$
707,341,195.00
FOB
Freezer
lbs
308,636,586
$
590,671,579.00
w/
o
cooler
Freezer
trays
17146477
$
116,669,616.00
%
processed
0.245522342
processed
lbs
311869
24.6%
12359
fresh
lbs
958358
75.4%
37880
lbs/
acre
average
49983.33766
1,270,227
25413
extra
w/
o
price
0
49983.33766
Proc
Report
Total
1,276,716
lbs/
acre
average
total
50238.69673
10/
17/
2002
2001
Fresh
Prices
2001
Costs
Breakdown
Weighted
Averages
of
Costs
Region
Overhead
Costs
Total
Operating
costs
Ground
Prep
Fumigation
Post
fume
prep
Planting
Pesticides
Fresh
Harvest
Proc.
Harvest
Weeding
Field
clearing
CSC
assess
Capital
Interest
TOTALS
South
Coast
$
3,505
$
26,201
$
627
$
1,778
$
1,454
$
2,356
$
1,253
$
12,850
$
3,537
$
713
$
298
$
131
$
1,204
$
27,928
w/
o
fume
$
24,423
Santa
Maria
$
2,443
$
21,123
$
621
$
861
$
1,153
$
1,994
$
1,046
$
9,613
$
3,985
$
713
$
108
$
118
$
911
$
2,443
Watsonville
$
6,002
$
27,016
$
136
$
1,728
$
1,417
$
1,605
$
1,191
$
18,372
$
957
$
102
$
138
$
1,370
$
6,002
w/
o
fume
Weighted
averages
Wats
+
Santa
Mari
5,070
$
25,472
263
1,501
1,348
1,707
1,153
16,077
1,044
893
104
133
1,250
$
29,041
w/
o
fume
$
23,971
Total
Costs
$
4,363
$
25,411.15
$
407
$
1,592
$
1,372
$
1,947
$
1,177
$
14,541
$
3,761
$
807
$
181
$
130
$
1,214
$
29,774
$
25,917
Costs
North
14,920
$
89,549,840
$
403,078,720
Cultural
Costs
Fresh
Harvest
Proc
Harvest
South
10,223
$
285,507,944
$
267,852,823
$
8,828
$
14,541
$
3,761
Total
$
375,057,784.00
$
670,931,543.00
Revenues
North
$
399,031,282
South
$
269,881,802
Total
$
668,913,084
Costs
Total
$
748,617,035
Total
w/
o
overhead
$
638,912,544.45
10/
17/
2002
Costs
Breakdown
2001
Freezer
Volumes
Weekly
Price
­
Volume
Data
PROCESSED
Week
SD,
O,
LA
ctys
Oxnard
South
total
Santa
Maria
Watsonvile
North
total
Ending
Price
Volume
Volume
Volume
Monthly
vol
Monthly
lbs
Volume
Volume
Volume
Monthly
vol
Monthly
lbs
Value
Vol
x
Price
1/
6
1/
13
1/
20
1/
27
2/
3
2/
10
2/
17
2/
24
3/
3
3/
10
3/
17
3/
24
3/
31
4/
7
4/
14
4/
21
624
624
49420
49420
4/
28
81042
82793
163835
164459
2960262
87808
87808
137228
2470104
5/
5
372458
134752
507210
2190
217561
219751
5/
12
478753
283452
762205
27546
106936
134482
5/
19
530334
1031950
1562284
105093
163832
268925
5/
26
419963
987381
1407344
4239043
76302774
252626
178727
431353
1054511
18981198
6/
2
259863
855978
1115841
508709
139767
648476
6/
9
230520
900252
1130772
506003
83591
589594
6/
16
230886
923846
1154732
543455
135706
679161
6/
23
171241
849752
1020993
474661
143716
618377
6/
30
127260
571202
698462
5120800
92174400
290782
130948
421730
2957338
53232084
7/
7
56300
303897
360197
216795
134931
351726
7/
14
21059
174876
195935
196484
107253
303737
7/
21
7914
64464
72378
203818
57594
261412
7/
28
4091
16710
20801
649311
11687598
214118
59098
273216
1190091
21421638
8/
4
1449
14801
16250
203097
76805
279902
8/
11
3281
3281
19531
351558
157378
73340
230718
8/
18
97803
69434
167237
8/
25
58718
50157
108875
786732
14161176
9/
1
19714
46568
66282
9/
8
0
71052
71052
9/
15
555
197713
198268
9/
22
895
107700
108595
9/
29
89350
89350
533547
9603846
10/
6
26635
26635
10/
13
39730
39730
10/
20
86920
86920
10/
27
44704
44704
197989
3563802
11/
3
4043
78016
82059
11/
10
6399
7439
13838
95897
1726146
11/
17
12195
2790
11/
24
249
12/
1
11215
12/
8
5289
12/
15
974
12/
22
South
Total
10193144
North
Total
6953333
total
lbs
183476592
total
lbs
125159994
yield
17947
yield
8389
Total
total
17146477
10/
17/
2002
Freezer
Prices
Corrected
15­
Aug­
02
South
Acres
Total
trays
Total
lbs
Rounded
lbs
yld/
acre
lbs
Rounded
yld/
acre
Trays/
acre
FR
Trays/
acre
PR
FOB
­
cooler
Ave.
Price/
unit
Rounded
price/
a
Gross/
acre
2001
10223
January
Fresh
1175000
13512500
13512500
1322
1322
115
$
14.83
$
1.290
$
1.290
$
1,705
Frozen
February
Fresh
2210000
25415000
25415000
2486
2486
216
$
12.75
$
1.109
$
1.109
$
2,757
Frozen
March
Fresh
4615000
53072500
53072500
5191
5191
451
$
10.49
$
0.912
$
0.912
$
4,734
Frozen
April
Fresh
11,293,300
129872950
129872950
12704
12704
1105
$
7.66
$
0.666
$
0.666
$
8,461
Frozen
164459
2960262
2960262
290
290
16
$
0.306
$
0.306
$
89
May
Fresh
7280500
83725750
83725750
8190
8190
712
$
4.17
$
0.363
$
0.363
$
2,973
Frozen
4239043
76302774
76302774
7464
7464
415
$
0.306
$
0.306
$
2,284
June
Fresh
362600
4169900
4169900
408
408
35
$
5.68
$
0.494
$
0.494
$
202
Frozen
5120800
92174400
92174400
9016
9016
501
$
0.306
$
0.306
$
2,759
July
Fresh
Frozen
649311
11687598
11687598
1143
1143
64
$
0.306
$
0.306
$
350
August
Fresh
Frozen
19531
351558
351558
34
34
2
$
0.306
$
0.306
$
10
Total
Fresh
26936400
309768600
309768600
30301
30301
2635
Fresh
$
20,832
Processed
$
5,492
April
May
June
July
August
Total
Proc
10193144
183476592
17947
1561
997
Total
48249
4196
$
26,324
10898550
26901950
North
Acres
Total
trays
Total
lbs
Rounded
lbs
yld/
acre
lbs
Rounded
yld/
acre
Trays/
acre
FR
Trays/
acre
PR
FOB
­
cooler
Ave.
Price/
unit
Rounded
price/
a
Gross/
acre
2001
14576
February
Fresh
11800
135700
135700
9
9
1
$
12.75
$
1.109
$
1.109
$
10
March
Fresh
174800
2010200
2010200
138
138
12
$
8.95
$
0.778
$
0.778
$
107
April
Fresh
2709300
31156950
31156950
2138
2138
186
$
6.34
$
0.551
$
0.551
$
1,178
Frozen
137228
2470104
2470104
169
169
9
$
0.306
$
0.306
$
52
May
Fresh
14287900
164310850
164310850
11273
11273
980
$
4.75
$
0.413
$
0.413
$
4,656
Frozen
1054511
18981198
18981198
1302
1302
72
$
0.306
$
0.306
$
398
June
Fresh
13635800
156811700
156811700
10758
10758
935
$
6.04
$
0.525
$
0.525
$
5,648
Frozen
2957338
53232084
53232084
3652
3652
203
$
0.306
$
0.306
$
1,118
July
Fresh
9618500
110612750
110612750
7589
7589
660
$
6.85
$
0.596
$
0.596
$
4,523
Frozen
1190091
21421638
21421638
1470
1470
82
$
0.306
$
0.306
$
450
August
Fresh
7068700
81290050
81290050
5577
5577
485
$
9.08
$
0.790
$
0.790
$
4,406
Frozen
786732
14161176
14161176
972
972
54
$
0.306
$
0.306
$
297
September
Fresh
4311240
49579260
49579260
3401
3401
296
$
7.85
$
0.683
$
0.683
$
2,323
Frozen
533547
9603846
9603846
659
659
37
$
0.306
$
0.306
$
202
October
Fresh
3019000
34718500
34718500
2382
2382
207
$
8.48
$
0.737
$
0.737
$
1,756
Frozen
197989
3563802
3563802
244
244
14
$
0.306
$
0.306
$
75
November
Fresh
352400
4052600
4052600
278
278
24
$
7.45
$
0.648
$
0.648
$
180
Frozen
95897
1726146
1726146
118
118
7
$
0.306
$
0.306
$
36
Total
Fresh
43265
3786
Fresh
$
24,787
Total
Proc
8468
747
477
Processed
$
2,627
Total
51733
4533
Rotation
Revenues
TOTAL
$
27,414
Non­
rotation
revenues
thru
sept
MBr
$
25,367
Non­
rotation
revenues
1st
week
sept
$
24,242
10/
17/
2002
Monthly
Prices
Revenues
1997­
2000
Year
Acres
Grade
Total
Yield/
acre
Percent
yield
Yield/
acre
Ave.
Price/
unit
Gross/
acre
Gross
Revenue
2000
26340
Fresh
53,495
0.776
41512
$
0.486
$
22,763.03
$
599,578,341.14
Processed
0.196
11983
$
0.216
1999
24603
Fresh
55,822
0.786
43876
$
0.614
$
30,667.07
$
754,501,984.42
Processed
0.174
11946
$
0.312
1998
24164
Fresh
51,778
0.738
38212
$
0.555
$
24,133.72
$
583,167,283.06
Processed
0.202
14343
$
0.204
1997
22508
Fresh
51,164
0.78
39908
$
0.520
$
23,791.24
$
535,493,193.91
Processed
0.19
11256
$
0.270
Processed
combination
of
frozen
and
juice,
price/
unit
weighted
average
of
frozen
and
juice
prices
with
volumes
2001
25143
Fresh
50392
0.743
37441
$
0.616
$
27,026.74
$
679,533,358.01
Frozen
0.257
12951
$
0.306
south
10223
Fresh
48248
30301
$
0.695
$
26,550.98
$
271,430,637.87
Frozen
17947
$
0.306
north
14920
Fresh
50806
42417
$
0.576
$
26,999.23
$
402,828,451.92
Frozen
8389
$
0.306
$
674,259,089.79
10/
17/
2002
1997­
2000
Revenues
Watsonville
Rotation
Crop
Economics
Crops
majority
in
Monterey
or
Santa
Cruz
Countries
NASS
Monterey
County
Crop
Total
CA
Acres
Total
Crop
Worth
Total
Revenue/
Acre
Total
Acres
Total
Crop
Worth
Revenue/
acre
Cost
of
Production
Net
per
acre
Rent
Cultural
Harvest
Crops/
year
Time
to
Harvest
Acres
Lettuce
221500
1484115000
$
6,700
$
111,339
$
658,905,000
$
5,918
$
8,069
1,100
1,090
5,313
3
45
to
60
Head
143500
1003496000
$
6,993
$
106,173
$
775,283,000
$
7,302
Leaf
43000
276877000
$
6,439
$
6,610
Brocolli
124000
536757000
$
4,329
54,899
$
258,962,000
$
4,717
$
4,862
265
500
960
3,225
2
to
2.5
90
to
120
days
400
Cauliflower
42000
222996000
$
5,309
17,390
$
102,567,000
$
5,898
$
5,339
1,050
550
1,386
3,196
2
to
2.5
90
to
110
days
60
Celery
23500
309711000
$
13,179
10,030
$
97,988,000
$
9,769
Spinach,
fresh
17000
103785000
$
6,105
$
13,204
$
77,009,000
$
5,832
Cabbage,
fresh
13700
79583000
$
5,809
2,087
$
8,512,000
$
4,079
Peppers,
chili
3900
51427000
$
13,186
$
625
$
4,513,000
$
7,221
Greens,
kale
2000
18700000
$
9,350
$
1,005
$
4,825,000
$
4,801
All
Vegies
274120
2013549000
$
7,346
$
6,090
$
1,256
10/
17/
2002
Rotation
Crop
Costs
Nematocide
Narrative
Efficacy
Nematocides
used
alone
are
efficacious
against
only
a
small
portion
of
the
pest
complex
in
California
strawberries
(
Table
1,
Pest
Complex
in
application).
They
have
no
efficacy
against
soil
borne
disease,
some
insects,
and
weeds.
This
alone
disqualifies
nematocides
from
being
a
methyl
bromide
alternative
for
California
strawberries.
Currently
registered
nematocides
are
fenamiphos
(
Nemacur),
azadirachtin,
metam
sodium
and
1,3­
dichloropropene.
Metam
sodium
and
1,3­
dichloropropene
are
discussed
in
separate
sections
of
this
application.

Regulatory
Nematocides
named
in
the
TEAP
2001
report,
fosthiazate,
Enzone
and
avermectin,
are
not
registered
in
California
for
use
on
strawberries.
Enzone
and
fosthiazate
do
not
have
EPA
registrations.
1,3­
Dichloropropene
Narrative
Efficacy:

Telone
 
,
active
ingredient1,3­
dichloropropene
(
1,3­
D)
is
used
as
a
nematocide
with
minimal
efficacy
against
disease
and
weeds
when
used
alone.
Because
it
is
not
effective
against
the
entire
pest
complex
in
California
strawberries,
this
alone
prevents
it
from
being
a
methyl
bromide
replacement
(
Table
1,
Pest
Complex,
in
application).
Early
efficacy
work
with
Telone
alone
demonstrated
it's
poorer
activity
compared
to
methyl
bromide/
chloropicrin
standards
(
91­
15
Pink
Sheet,
Appendix
CC).
And
in
fact
in
that
study
of
repeated
use
over
three
years,
already
poor
yields
dropped
with
time.
The
MBTOC
1998
report
(
page
51)
also
indicated
Telone
is
effective
only
in
combination
with
other
components.
The
Federal
Use
Label
also
shows
it
is
labeled
only
against
nematodes.

The
vast
majority
of
work
with
Telone
products
(
1,3­
D
alone)
on
strawberries
in
California
has
been
done
in
combination
with
other
fumigants.

Regulatory:

Shank
applied
Telone
requires
a
100
foot
buffer
zone
the
first
year
it
is
used
on
a
plot,
and
a
300
foot
buffer
zone
if
used
the
next
two
years
on
the
same
ground
(
See
Telone
II
use
label,
Appendix
G).
In
addition
in
California,
use
is
limited
by
township
caps,
as
an
additional
protection
with
respect
to
the
classification
1,3­
D
as
a
B2
carcinogen
(
Appendices
O
and
P,
http://
www.
cdpr.
ca.
gov/
docs/
dprdocs/
methbrom/
telone/
mgmtplan.
pdf).
Recently
township
caps
were
doubled
in
townships
where
historical
Telone
use
did
not
reach
the
maximum
allowed
under
the
caps
(
in
general
90,000
lbs
per
township.)
This
is,
however
a
temporary
increase
until
the
amount
of
Telone
"
banked"
from
previous
years
is
used
up,
or
the
registrant
convinces
the
California
Department
of
Pesticide
Regulation
that
permanent
increases
are
justified
by
reassessing
the
oncogenic
risk.
See
further
discussion
on
township
caps
in
the
discussion
for
1,3­
D/
Pic
alternative
regime.
Metam
Sodium
Narrative
Technical
Feasibility
Metam
sodium
has
some
activity
against
a
larger
portion
of
the
California
strawberry
pest
complex
than
other
single
potential
alternatives
(
Table
1,
Pest
Complex,
in
application).
However,
that
activity
is
limited
in
many
cases.
For
instance
metam
has
weed
activity
against
weeds
and
weed
seeds
of
Bermudagrass,
Chickweed,
Dandelions,
Ragweed,
Henbit,
Labsquarter,
Pigweed,
Watercress,
Johnsongrass,
Nightshade,
Nutsedge
(
suppression
only),
Wild
Morning­
Glory
and
Purslane.
But
methyl
bromide/
chloropicrin
(
MBC)
controls
nutsedge
well
(
S.
Fennimore,
personal
communication)
compared
to
metam
and
MBC
controls
prostrate
knotweed
better
than
metam
alone
(
Appendix
DD,
Fennimore
2000
handout).
Overall,
weed
biomass
compared
to
the
MBC
standard
was
37%
higher
when
metam
alone
was
used
at
75
gal/
acre.

Metam
nematode
activity
is
suppression
only
against
active
forms
of
nematodes
versus
eggs
(
requires
pre­
irrigation
for
best
activity
and
fully
decomposed
plant
residues)
(
Appendix
G,
Vapam
Use
Label).
It
is
also
reported
to
have
activity
against
garden
symphalan
and
against
the
soil­
borne
diseases
Rhizoctonia,
Pythium,
Phytophthora,
Verticillium,
and
Sclerotina.

While
metam
sodium
has
activity
against
much
of
the
California
strawberry
pest
complex,
yields
of
strawberry
in
ground
treated
only
with
metam
sodium
are
not
comparable
with
the
methyl
bromide/
chloropicrin
standard
(
Appendix
T,
Metam
tab.)
Twenty­
seven
small
plot
trials
conducted
throughout
the
California
strawberry
growing
regions
from
1993
through
2001
show
average
total
yields
of
81%
compared
to
methyl
bromide/
chloropicrin
standard
for
all
forms
of
application
of
metam
sodium
alone.
Clearly
the
product
alone
is
not
comparable
to
the
MBC
standard
in
California.
Similar
results
are
seen
in
trials
in
other
parts
of
the
US
and
the
world.
Twenty­
six
trials
of
metam
alone
on
strawberries
averaged
79%
yield
compared
to
MBC
standard.
In
all
cases,
non­
fume
controls
averaged
63%
for
the
California
trials
(
omitting
4
trials
with
a
non­
fume
control
of
98%
of
MBC
yield
where
there
was
extremely
low
pest
and
disease
pressure)
and
60%
for
the
out
of
state
trials
indicating
a
healthy
degree
of
pest
pressure
was
observed
in
the
test
plots.

Economic
Analysis
An
overall
economic
analysis
was
done,
even
though
it
is
clear
metam
alone
is
not
technically
feasible,
to
illustrate
the
impact
of
a
20%
yield
loss
on
California
strawberry
culture.
When
that
overall
yield
of
81%
(
Appendix
T,
Metam
tab)
is
calculated
into
the
2001
baseline
revenue
for
each
region
(
Application
Worksheet
3­
E
Metam
Totals),
significant
losses
on
a
per
acre
basis
are
seen
in
the
South
and
North.
Even
with
the
cost
savings
of
the
Metam
application
(
generally
$
1,000
less
than
the
MBC
standard)
significant
losses
are
seen
in
both
regions.
In
the
South,
revenue
loss
was
$
3,594
per
acre.
In
the
North,
revenue
loss
was
$
2,703
per
acre
for
the
Rotation
grower
and
$
4,741
per
acre
for
the
Non­
Rotation
grower.
Since
the
median
acre
size
farm
of
our
representative
user
is
approximately
40
acres,
these
would
result
in
total
losses
of
$
137,600
in
the
South
and
$
108,120
and
$
189,640
in
the
North
for
rotation
and
non­
rotation
growers
respectively.

Regulatory
Pressures
Metam
sodium
recently
completed
review
as
a
Toxic
Air
Contaminant
with
the
California
Air
Resources
Board's
Scientific
Review
Panel
(
Appendix
R).
While
DPR
continues
their
re­
evaluation
of
the
material
there
is
a
great
deal
of
concern
regarding
eventual
buffer
zone
requirements
when
all
the
analyses
are
complete
(
Appendix
S,
personal
communications
from
Metam
Sodium
Task
Force).
It
is
possible
buffer
zone
requirements
of
500
feet
or
more
may
be
required
in
some
situations,
which
would
render
the
material
unusable
in
particularly
urbanized
settings.

Conclusion
Metam
Sodium
use
alone
is
not
a
methyl
bromide/
chloropicrin
replacement
in
California
strawberries
largely
because
of
lack
of
complete
efficacy
against
the
entire
pest
complex,
and
significantly
lower
yields
compared
to
the
MBC
standard
resulting
in
significant
per
acre
losses
in
revenue.
Metam
Sodium
Yield
Data
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Metam
yield
Significance
Metam
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
SCREC
1993
Small
plot
73%
100%
82%
sig
100
gal/
acre
drip
NA
Clear,
std
Chandler
20
yr
since
Strbr,

weeding
2.5
hr
more
94­
10
Pink
Sheet
SCREC
1993
Small
plot
69%
100%
84%
sig
100
gal/
acre
drip
NA
Clear,
std
Oso
Grande
20
yr
since
Strbr,

weeding
2.5
hr
more
94­
10
Pink
Sheet
Watsonville
1994
2
fields
56%
100%
56%
100
gal/
acre
spray
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Sheet
Monterey
Bay
Academy
1998
Small
plot
50%
100%
70%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
1998
Small
plot
50%
100%
79%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
1998
Small
plot
50%
100%
67%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
SCREC
1998
Small
plot
46%
100%
82%
70
gal/
acre
drip
NA
Black,
std
Camarosa
NA
98
MBAO
Larson
Spence
Farm
1998
Small
plot
98%
100%
99%
75
gal/
acre
drip
1
inch
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1998
Small
plot
98%
100%
110%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1998
Small
plot
98%
100%
98%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1998
Small
plot
98%
100%
103%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Fresno
Clovis
1999
NA
76%
100%
99%
NA
NA
NA
NA,
std
Chandler
NA
2000
Handout
Molinar
Monterey
Bay
Academy
1999
Small
plot
35%
100%
70%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
1999
Small
plot
35%
100%
80%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
1999
Small
plot
35%
100%
72%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1999
Small
plot
80%
100%
102%
75
gal/
acre
drip
1
inch
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1999
Small
plot
80%
100%
117%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1999
Small
plot
80%
100%
105%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
1999
Small
plot
80%
100%
97%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
California,
Oxnard
2000
Small
plot
71%
100%
79%
75
gal/
acre
drip
NA
std
IR­
4
data
MBAO
00
Haglund
California,
Oxnard
2000
Small
plot
71%
100%
75%
37
gal/
acre
spray
500­
1000g/
a
std
IR­
4
data
MBAO
00
Haglund
California,
Salinas
2000
Small
plot
65%
100%
74%
75
gal/
acre
drip
NA
std
IR­
4
data
MBAO
00
Haglund
California,
Salinas
2000
Small
plot
65%
100%
66%
37
gal/
acre
spray
500­
1000g/
a
std
IR­
4
data
MBAO
00
Haglund
Monterey
Bay
Academy
2000
Small
plot
45%
100%
86%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
2000
Small
plot
45%
100%
70%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Monterey
Bay
Academy
2000
Small
plot
45%
100%
67%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
2000
Small
plot
77%
100%
85%
75
gal/
acre
drip
1
inch
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
2000
Small
plot
77%
100%
81%
75
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
2000
Small
plot
77%
100%
79%
75
gal/
acre
drip
2.4
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
Spence
Farm
2000
Small
plot
77%
100%
81%
45
gal/
acre
drip
1.7
inches
Green,
std
Selva
MBr
previous
01­
02
Pink
Sheet
California,
Oxnard
2001
Small
plot
63%
100%
79%
50
gal/
acre
drip
NA,
std
Camarosa
IR­
4
data
MBAO
01
Nelson
California,
Salinas
2001
Small
plot
82%
100%
86%
50
gal/
acre
drip
NA,
std
Diamante
IR­
4
data
MBAO
01
Nelson
No
on
farm,
large
scale
67%
84%

70%
average
85%
28
plots,
omitting
trials
with
non­
fume
>
80%
of
MBC
stand
(
no
pest
pressure)

0.190186138
standard
deviation
0.147947152
South
67%
79%
7
trials
(
includes
Fresno)

0.157948153
0.067682733
North
71%
87%
21
trials
0.209087654
0.162328844
10/
17/
2002
Metam
1
Non­
California
Metam
Sodium
Yield
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Metam
yield
Significance
Metam
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
Florida
1993
Small
plot
78%
100%
92%
100
gal/
acre
drip
NA
std
Chandler
Had
trouble
with
drip
MBAO
94
Olsen
Florida
1993
Small
plot
78%
100%
97%
100
gal/
acre
broadcast
NA
std
Chandler
Had
trouble
with
drip
MBAO
94
Olsen
Florida
1996
Small
plot
73%
100%
97%
100
gal/
acre
spray
NA
32.7%
formulation
MBAO
96
Noling
Australia
1997
NA
60%
100%
80%
105
gal/
acre
NA
NA
NA
Selva
2nd
season
yield,
no
effects
1st
year!!
MBAO
97
Porter
France
1998
Small
plot
65%
100%
91%
138
gal/
acre
drip
NA
NA
NA
MBAO
98
Fritsch
France
1998
Small
plot
65%
100%
87%
138
gal/
acre
shank
NA
NA
NA
MBAO
98
Fritsch
North
Carolina
1998
Small
plot
88%
100%
103%
NA
NA
NA
NA,
std
Chandler
0,1,2
week
holes
MBAO
98
Louws
Spain
1998
Medium
plot
60%
100%
79%
140g/
m2
NA
NA
NA,
std
NA
Same
plot
2
yrs
MBAO
99
Cebolla
Spain
1998
Medium
plot
54%
100%
56%
140g/
m2
NA
NA
NA,
std
NA
Same
plot
2
yrs
MBAO
99
Cebolla
Florida
1999
Small
plot
41%
100%
62%
195
gal/
acre
spray
NA
NA
Chandler
MBAO
99
Locascio
Florida
1999
Small
plot
69%
100%
84%
195
gal/
acre
spray
NA
NA
Chandler
MBAO
99
Locascio
Florida,
Dover
2000
Small
plot
27%
100%
77%
75
gal/
acre
drip
NA
std
IR­
4
data
MBAO
00
Haglund
Florida,
Dover
2000
Small
plot
2%
100%
34%
75
gal/
acre
drip
NA
std
IR­
4
data
MBAO
00
Haglund
Florida,
Dover
2000
Small
plot
27%
100%
21%
37
gal/
acre
spray
500­
1000g/
a
std
IR­
4
data
MBAO
00
Haglund
Florida,
Dover
2000
Small
plot
2%
100%
1%
37
gal/
acre
spray
500­
1000g/
a
std
IR­
4
data
MBAO
00
Haglund
North
Carolina
2001
Small
plot
67%
100%
105%
37.5
gal/
a
shank?
NA
std?
Camarosa
MBAO
01
Ferguson
North
Carolina
2001
Small
plot
67%
100%
94%
37.5
gal/
a
drip
NA
std?
Camarosa
MBAO
01
Ferguson
Florida,
Chancey
2001
Small
plot
44%
100%
51%
37.5
gal/
a
spray
NA,
std
Camarosa
IR­
4
data
MBAO
01
Nelson
Florida,
Duke
2001
Small
plot
91%
100%
68%
37.5
gal/
a
spray
NA,
std
Camarosa
IR­
4
data
MBAO
01
Nelson
Spain,
Huelva
2001
Small
plot
80%
100%
80%
175
cc/
m2
NA
NA
Camarosa
MBAO
01
Lopez­
Aranda
Spain,
Huelva
2001
Small
plot
54%
100%
77%
175
cc/
m2
NA
NA
Camarosa
MBAO
01
Lopez­
Aranda
North
Carolina,
Plymouth
1998
Small
plot
78%
100%
109%
37.5
gal/
acre
shank?
drip?
Chandler
no
previous
strber
MBAO
00
Ferguson
North
Carolina,
Plymouth
1999
Small
plot
71%
100%
104%
37.5
gal/
acre
shank?
drip?
Chandler
no
previous
strber
MBAO
00
Ferguson
North
Carolina,
Plymouth
2000
Small
plot
78%
100%
108%
37.5
gal/
acre
shank?
drip?
Chandler
no
previous
strber
MBAO
00
Ferguson
Spain,
Huelva
1999
Small
plot
70%
100%
96%
125
cc/
m2
shank
Black
std
Camarosa
MBAO
00
Lopez­
Aranda
Spain,
Huelva
2000
Small
plot
68%
100%
94%
175
cc/
m2
shank
Black
std
Camarosa
MBAO
00
Lopez­
Aranda
Spain,
Huelva
2000
Small
plot
63%
100%
82%
175
cc/
m2
shank
Black
std
Camarosa
MBAO
00
Lopez­
Aranda
average
60%
79%

std
dev
23%
27%

Solar
plus
Metam
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Metam
yield
Significance
Metam
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
SCREC
1993
Small
Plot
0.73
1
0.83
Sig
100
gal/
acre
drip
NA
NA
Chandler
Weeding
took
1.5
hrs
longer
than
std
94­
10
Pink
Sheet
SCREC
1993
Small
Plot
0.69
1
0.8
sig
100
gal/
acre
drip
NA
NA
Oso
Grande
Weeding
took
1.5
hrs
longer
than
std
94­
10
Pink
Sheet
10/
17/
2002
Metam
2
Chloropicrin
Yield
Data
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Pic
yield
Significance
Pic
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
SCREC
1993
Small
Plot
73%
100%
100%
Non­
sig
100
lbs/
acre
flat
fume
NA
NA
Chandler
Weeding
took
2
hrs
longer
than
std
94­
10
Pink
Sheet
SCREC
1993
Small
Plot
69%
100%
100%
Non­
sig
100
lbs/
acre
flat
fume
NA
NA
Oso
Grande
Weeding
took
2
hrs
longer
than
std
94­
10
Pink
Sheet
San
Diego
County
1994
0.2
acre
92%
100%
107%
300
lbs/
acre
flat,
shank
NA
Clear,
std
Chandler
Pre
fumed
farm
field
96­
15
Pink
Watsonville
1994
Small
Plot
62%
100%
92%
Non­
sig
20
gal/
acre
shank?
NA
NA
Selva
95­
16
Pink
Watsonville
1994
2
fields
56%
100%
94%
Non­
sig
300
lbs/
acre
flat,
shank
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Watsonville
1995
2
fields
70%
100%
95%
Non­
sig
300
lbs/
acre
flat,
shank
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Merced
County
1997
0.5
acre
NA
100%
103%
Non­
sig
200
lbs/
acre
flat,
shank
NA
NA,
std
Chandler
Grower
did
not
allow
non­
fume
98­
24
Pink
Sheet
Oxnard
1997
NA
100%
103%
NA
200
lbs/
acre
flat
NA
NA
Camarosa
980609mbr_
alt_

summary.
xls
SCREC
1997
Small
Plot
77%
100%
87%
Non­
sig
(
1%)
166
lbs/
acre
bed,
shank
NA
NA,
std
Camarosa
32
weeds
vs
0
98­
1
Pink
Sheet
Watsonville
1997
NA
100%
92%
NA
200
lbs/
acre
flat
NA
NA
Camarosa
980609mbr_
alt_

summary.
xls
Watsonville
1997
NA
100%
93%
NA
200
lbs/
acre
bed,
shank
NA
NA
Selva
980609mbr_
alt_

summary.
xls
Merced
County
1998
0.5
acre
NA
100%
98%
Non­
sig
200
lbs/
acre
flat,
shank
NA
NA,
std
Chandler
2nd
year
berries
98­
24
Pink
Orange
County
1998
76%
100%
100%
NA
200
lbs/
acre
bed,
shank
NA
NA
Camarosa
980609mbr_
alt_

summary.
xls
Oxnard
1998
NA
100%
91%
NA
200
lbs/
acre
flat
NA
NA
Camarosa
980609mbr_
alt_

summary.
xls
Salinas
1998
Small
Plot
98%
100%
102%
14
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
San
Diego
County
1998
111%
100%
115%
NA
200
lbs/
acre
flat
NA
NA
Camarosa
980609mbr_
alt_

summary.
xls
Santa
Maria
1998
NA
100%
78%
200
lbs/
acre
bed,
shank
NA,
std
Camarosa
geeFumigation9
81.
xls
Watsonville
1998
1
acre
NA
100%
89%
NA
134
lbs/
acre
shank?
NA
NA,
std
Aromas
99fumigation
data
sheet.
xls
MBA
1999
Small
Plot
35%
100%
69%
14
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Merced
County
1999
0.5
acre
54%
100%
67%
Sig
200
lbs/
acre
flat,
shank
NA
NA,
std
Chandler
Refume
same
ground
01­
04
Pink
Orange
County
1999
0.15
acre
102%
100%
99%
NA
200
lbs/
acre
bed
shank
NA
Black,
std
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
104%
NA
14
gal/
acre
drip
NA
Black,
std
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
103%
NA
14
gal/
acre
drip
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
100%
NA
24
gal/
acre
drip
NA
Black,
std
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
103%
NA
24
gal/
acre
drip
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Oxnard
1999
0.5
acre
NA
100%
92%
NA
200
lbs/
acre
flat
shank
NA
Clear,
std
Camarosa
Jim_
m.
xls
Oxnard
1999
0.05
acre
86%
100%
108%
120
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
110%
200
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
98%
120
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
102%
200
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
99%
12
gal/
acre
drip
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
103%
20
gal/
acre
drip
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
104%
12
gal/
acre
drip
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
99%
1.02875
20
gal/
acre
drip
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Salinas
1999
Small
Plot
80%
100%
100%
14
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Santa
Maria
1999
0.02
acre
70%
100%
97%
NA
14
gal/
acre
drip
NA
Clear,
VIF
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.02
acre
70%
100%
97%
NA
24
gal/
acre
drip
NA
Clear,
VIF
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.02
acre
70%
100%
88%
NA
24
gal/
acre
drip
NA
Clear,
std
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.02
acre
70%
100%
83%
NA
24
gal/
acre
drip
NA
Black,
std
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.02
acre
70%
100%
81%
NA
14
gal/
acre
drip
NA
Black,
std
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.02
acre
70%
100%
75%
NA
14
gal/
acre
drip
NA
Clear,
std
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.44
acre
70%
100%
87%
NA
200
lbs/
acre
bed
NA
Clear,
VIF
Camarosa
9899mbalt_
on_
f
arm.
xls
Santa
Maria
1999
0.22
acre
70%
100%
94%
200
lbs/
acre
bed
NA
Clear,
std
Camarosa
9899mbalt_
on_
f
arm.
xls
Watsonville
1999
.05
acre
NA
100%
107%
NA
24
gal/
acre
drip
NA
Clear,
std
Aromas
99fumigation
data
sheet.
xls
Watsonville
1999
.05
acre
NA
100%
104%
NA
200
lbs/
acre
bed
shank
NA
Clear,
VIF
Aromas
99fumigation
data
sheet.
xls
Watsonville
1999
.05
acre
NA
100%
102%
NA
200
lbs/
acre
bed
shank
NA
Clear,
std
Aromas
99fumigation
data
sheet.
xls
Watsonville
1999
.05
acre
NA
100%
104%
NA
24
gal/
acre
drip
NA
Clear,
VIF
miguel.
xls,
99
summary
10/
17/
2002
PIC
1
Chloropicrin
Yield
Data
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Pic
yield
Significance
Pic
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
Watsonville
1999
.05
acre
NA
100%
89%
NA
24
gal/
acre
drip
NA
Green,
std
miguel.
xls,
99
summary
Watsonville
1999
.05
acre
NA
100%
98%
NA
24
gal/
acre
drip
NA
Clear,
std
miguel.
xls,
99
summary
MBA
2000
Small
Plot
45%
100%
94%
21
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Oxnard
2000
0.05
acre
77%
100%
95%
­
0.01
120
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
98%
0.09
200
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
93%
0.11
120
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
99%
0.03
200
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
93%
0.11
12
gal/
acre
drip
NA
Clear,
std
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
93%
­
0.04
20
gal/
acre
drip
NA
Clear,
std
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
91%
0.07
12
gal/
acre
drip
NA
Clear,
VIF
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Oxnard
2000
0.05
acre
77%
100%
92%
0.02
20
gal/
acre
drip
NA
Clear,
VIF
Camarosa
9900mbalt_
on_
f
arm_
trials.
xls
Salinas
2000
Small
Plot
77%
100%
103%
21
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Santa
Maria
2000
.73
acres
74%
100%
88%
0.9525
25
gal/
acre
drip
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
90%
0.055714286
75
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
83%
75
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
89%
100
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
98%
100
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
102%
100
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
107%
100
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
98%
125
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
106%
125
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
96%
160
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
97%
160
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
101%
200
lbs/
acre
bed,
shank
NA
Clear,
std
Fumigation
Data
SM
98­
01.
xls
Santa
Maria
2000
0.05
acre
76%
100%
107%
200
lbs/
acre
bed,
shank
NA
Clear,
VIF
Fumigation
Data
SM
98­
01.
xls
Watsonville
2000
1
acre
NA
100%
95%
drip
NA
Clear,
VIF
0001_
ramos_
yie
ld_
data.
xls
96%
All
trials
57
trials
95%
Trials
where
non­
fume
<
80%
MBC
18
trials
97%
South
39
trials
94%
North
drip
94%
8%

shank
96%
10%

low
rates
94%
8%

Non­
California
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Metam
yield
Metam
rate
Application
Volume
Tarp
type
Variety
Comments
Citation
10/
17/
2002
PIC
2
Chloropicrin/
Metam
Data
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Regime
yield
Significance
Regime
rate
Pic/
Metam
Ratio
Application
Volume
Tarp
type
Variety
Comments
Citation
MBA
1998
Small
Plot
50%
100%
51%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
1998
Small
Plot
98%
100%
106%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
MBA
1999
Small
Plot
35%
100%
76%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Oxnard
1999
0.5
acre
NA
100%
98%
NA
200
lbs/
acre
Met
45
gal/
acre
flat
shank,
drip
NA
Clear,
std
Camarosa
Jim_
m.
xls
Salinas
1999
Small
Plot
80%
100%
105%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
MBA
2000
Small
Plot
45%
100%
113%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
2000
Small
Plot
77%
100%
101%
14
gal/
acre
Met
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Watsonville
2000
1
acre
NA
100%
93%
drip
NA
Clear,
VIF
0001_
ram
os_
yield_
d
ata.
xls
Average
98%

Stdev
13%

10/
17/
2002
PicMetam
1
1,3­
D
Chloropicrin
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yRegime
yield
Significance
Regime
rate
Ratio
of
a.
i.
s
Application
Volume
Tarp
type
Variety
Comments
Citation
Watsonville?
1991
Small
Plot
51%
100%
64%
sig
38
gal/
acre
Telone
C
shank
NA
clear,
std
Seascape
3
yer
same
ground,
lower
yields
with
time,
less
weed
control
91­
15
Pink
Sheet
Watsonville?
1991
Small
Plot
51%
100%
91%
not
sig
76
gal/
acre
Telone
C
shank
NA
clear,
std
Seascape
3
yer
same
ground,
lower
yields
with
time,
less
weed
control
91­
15
Pink
Sheet
San
Diego
County
1994
0.2
acre
92%
100%
104%
454
lbs/
acre
70/
30
flat,
shank
NA
Clear,
std
Chandler
Pre
fumed
farm
field
96­
15
Pink
Watsonville
1994
2
fields
56%
100%
97%
Non­
sig
454
lbs/
acre
70/
30
flat,
shank
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Watsonville
1995
2
fields
70%
100%
1%
Non­
sig
454
lbs/
acre
70/
30
flat,
shank
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Watsonville
1995
2
fields
70%
100%
1%
Non­
sig
409
lbs/
acre
30/
70
flat,
shank
NA
NA,
std
Selva
Strw/
vegie
rota
96­
13
Pink
Merced
County
1997
0.5
acre
NA
100%
103%
Non­
sig
400
lbs/
acre
65/
35
flat,
shank
NA
NA,
std
Chandler
Grower
did
not
allow
nonfume
98­
24
Pink
Oxnard
1997
NA
100%
107%
NA
400
lbs/
acre
65/
35
flat
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
Santa
Maria
1997
NA
100%
94%
NA
400
lbs/
acre
65/
35
flat
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
SCREC
1997
Small
Plot
77%
100%
97%
Non­
sig
(
1%)
236
lbs/
acre
40/
60
bed,
shank
NA
NA,
std
Camarosa
14
weeds
vs
0
98­
1
Pink
Watsonville
1997
NA
100%
97%
NA
400
lbs/
acre
65/
35
flat
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
Watsonville
1997
NA
100%
72%
NA
400
lbs/
acre
65/
35
bed
NA
NA
Selva
980609mbr_
alt
_
summary.
xls
MBA
1998
Small
Plot
50%
100%
97%
42
gal/
acre
InLine
drip
1
inches
NA,
std
Selva
01­
02
Pink
MBA
1998
Small
Plot
50%
100%
92%
42
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
MBA
1998
Small
Plot
50%
100%
110%
42
gal/
acre
InLine
drip
2.4
inches
NA,
std
Selva
01­
02
Pink
MBA
1998
Small
Plot
50%
100%
95%
25
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
MBA
1998
Small
Plot
50%
100%
100%
40
gal/
acre
65/
35
bed
shank
NA,
std
Selva
01­
02
Pink
Merced
County
1998
0.5
acre
NA
100%
101%
Non­
sig
400
lbs/
acre
65/
35
flat,
shank
NA
NA,
std
Chandler
2nd
year
berries
98­
24
Pink
Orange
County
1998
76%
100%
103%
NA
400
lbs/
acre
65/
35
bed,
shank
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
Oxnard
1998
NA
100%
86%
NA
400
lbs/
acre
65/
35
flat
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
Salinas
1998
Small
Plot
98%
100%
110%
42
gal/
acre
InLine
drip
1
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1998
Small
Plot
98%
100%
110%
42
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1998
Small
Plot
98%
100%
112%
42
gal/
acre
InLine
drip
2.4
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1998
Small
Plot
98%
100%
115%
25
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1998
Small
Plot
98%
100%
98%
40
gal/
acre
65/
35
bed
shank
NA,
std
Selva
01­
02
Pink
San
Diego
County
1998
111%
100%
115%
NA
200
lbs/
acre
65/
35
flat
NA
NA
Camarosa
980609mbr_
alt
_
summary.
xls
Santa
Maria
1998
NA
100%
96%
420
lbs/
acre
65/
35
bed,
shank
NS,
std
Camarosa
geeFumigation
Watsonville
1998
1
acre
NA
100%
95%
NA
23
gal/
acre
NA
drip?
NA
NA,
std
Aromas
99fumigation
data
sheet.
xls
MBA
1999
Small
Plot
35%
100%
95%
42
gal/
acre
InLine
drip
1
inches
NA,
std
Selva
01­
02
Pink
MBA
1999
Small
Plot
35%
100%
92%
42
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
MBA
1999
Small
Plot
35%
100%
93%
42
gal/
acre
InLine
drip
2.4
inches
NA,
std
Selva
01­
02
Pink
MBA
1999
Small
Plot
50%
100%
69%
25
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
MBA
1999
Small
Plot
35%
100%
100%
40
gal/
acre
65/
35
bed
shank
NA,
std
Selva
01­
02
Pink
Merced
County
1999
0.5
acre
54%
100%
84%
Non­
sig
200
lbs/
acre
65/
35
flat,
shank
NA
NA,
std
Chandler
Refume
same
ground
01­
04
Pink
Orange
County
1999
.07
acre
102%
100%
96%
NA
35
gal/
acre
65/
35
drip
NA
Black,
std
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
95%
NA
35
gal/
acre
65/
35
drip
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
100%
NA
21
gal/
acre
65/
35
drip
NA
Black,
std
Camarosa
Jim_
m.
xls
Orange
County
1999
.07
acre
102%
100%
94%
NA
21
gal/
acre
65/
35
drip
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Orange
County
1999
.04
acre
102%
100%
105%
NA
240
lbs/
acre
65/
35
bed
shank
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Orange
County
1999
.15
acre
102%
100%
100%
NA
350
lbs/
acre
65/
35
bed
shank
NA
Black,
VIF
Camarosa
Jim_
m.
xls
Oxnard
1999
0.5
acre
NA
100%
92%
NA
425
lbs/
acre
65/
35
flat
shank
NA
Clear,
std
Camarosa
Jim_
m.
xls
Oxnard
1999
0.5
acre
NA
100%
93%
NA
388
lbs/
acre
65/
35
flat
shank
NA
Clear,
std
Camarosa
Jim_
m.
xls
Oxnard
1999
0.05
acre
86%
100%
102%
240
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
106%
350
lbs/
acre
bed,
shank
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
100%
240
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
96%
350
lbs/
acre
bed,
shank
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
104%
21
gal/
acre
drip
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
95%
20
gal/
acre
drip
NA
Clear,
std
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
102%
21
gal/
acre
drip
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Oxnard
1999
0.05
acre
86%
100%
94%
20
gal/
acre
drip
NA
Clear,
VIF
Camarosa
drip_
yields.
xls
Salinas
1999
Small
Plot
80%
100%
116%
42
gal/
acre
InLine
drip
1
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1999
Small
Plot
80%
100%
113%
42
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1999
Small
Plot
80%
100%
123%
42
gal/
acre
InLine
drip
2.4
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1999
Small
Plot
80%
100%
114%
25
gal/
acre
InLine
drip
1.7
inches
NA,
std
Selva
All
yields
much<
grower
std
01­
02
Pink
Salinas
1999
Small
Plot
80%
100%
107%
40
gal/
acre
65/
35
bed
shank
NA,
std
Selva
01­
02
Pink
10/
17/
2002
1,3­
D
Pic
1
1,3­
D,
Chloropicrin,
Metam
Data
California
Data
Location
Year
Test
Size
Non­
fume
yield
MBR
standard
yield
Regime
yield
Significance
Regime
rate
1,3­
D/
Pic/
Metam
Ratio
Application
Volume
Tarp
type
Variety
Comments
Citation
MBA
1998
Small
Plot
50%
100%
73%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
1998
Small
Plot
98%
100%
103%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
1998
Small
Plot
98%
100%
109%
25
gal/
acre
InLine/
45
gal/
acre
drip
2.4
inches
NA,
std
Selva
01­
02
Pink
Sheet
MBA
1999
Small
Plot
35%
100%
68%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
1999
Small
Plot
80%
100%
112%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
1999
Small
Plot
80%
100%
89%
25
gal/
acre
InLine/
45
gal/
acre
drip
2.4
inches
NA,
std
Selva
01­
02
Pink
Sheet
MBA
2000
Small
Plot
45%
100%
111%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
2000
Small
Plot
77%
100%
101%
25
gal/
acre
InLine/
45
gal/
acre
drip
1.7
inches
NA,
std
Selva
01­
02
Pink
Sheet
Salinas
2000
Small
Plot
77%
100%
107%
25
gal/
acre
InLine/
45
gal/
acre
drip
2.4
inches
NA,
std
Selva
01­
02
Pink
Sheet
Watsonville
2000
1
acre
NA
100%
95%
InLine
drip
NA
Clear,
VIF
0001_
ramo
s_
yield_
dat
a.
xls
Average
95%

Stdev
17%

10/
17/
2002
1,3­
D
Pic
Metam
1
Weeding
cost
Based
on
discussion
with
Dr.
Rachel
Goodhue,
University
of
California
Davis,
Department
of
Agricultural
Resources
and
Economics
Hand
Weeding
Costs
Adjustment
Study
South
adjusted
North
adjusted
MBr/
Pic
$
248
$
713
$
957
Pic
shank
$
359
$
1,032
$
1,385
Pic
shank
+
Metam
$
269
$
773
$
1,038
Telone
C35
shank
$
270
$
776
$
1,042
Telone
C35
shank
+
Metam
$
259
$
745
$
999
Pic
EC
drip
$
446
$
1,282
$
1,721
Pic
EC
drip
+
metam
$
349
$
1,003
$
1,347
InLine
drip
$
330
$
949
$
1,273
InLine
+
metam
$
357
$
1,026
$
1,378
10/
17/
2002
Weeding
Costs
1
Methyl
Bromide
Alternatives
Cost
and
Application
Analysis
­­
2001
Compiled
6/
8/
2001
Wait
Per
TREATED
Acre
Time
Minimum
Average
Combos
Material
Type
Low
High
Units
Days
Operation
Days
Well
?
Low
High
Low
High
Low
High
Low
High
Low
High
A
Flat
MBr
­
Pic
57/
43
Shank
250
375
lbs
7
Bed
up
7
1,
2,
3,
4
650
975
193
218
256
289
400
600
1,499
2,082
1,790
Bed
MBr
­
Pic
57/
43
Shank
250
375
lbs
7
7
1,
2,
3,
4
650
975
256
289
200
300
1,106
1,564
1,335
B
Flat
Telone
C35
Shank
350
400
lbs
21
Bed
up
21
1,
4
875
1,156
193
218
256
289
400
600
1,724
2,263
1,993
Tel
+
Metam
Flat
Telone
C35
Shank
350
400
lbs
7
Bed
up
875
1,156
193
218
256
289
400
600
1,866
2,438
2,152
2,437
Bed
Metam
sodium
Drip
37
50
gal
21
28
1,
2,
3,
4
2?
143
175
Tel
C35
Flat
Telone
C35
coinject
Shank
350
400
lbs
21
Flat
875
1,156
193
218
256
289
400
600
2,104
3,023
2,563
2,278
Pic
Shank
200
400
lbs
14
Bed
up
21
1,
2,
4
3?
380
760
Flat
Telone
C35
coinject
Shank
350
400
lbs
21
Flat
875
1,156
193
218
256
289
400
600
2,246
3,198
2,722
Pic
Shank
200
400
lbs
14
Bed
up
380
760
Bed
Metam
sodium
Drip
37
50
gal
21
28
1,
2,
3,
4
143
175
InLine
C
Bed
Inline
+
VIF
tarp
Drip
34
34
gal
21
21
1,
2,
4
731
731
526
594
200
300
1,457
1,625
1,541
1,541
Bed
Inline
+
VIF
tarp
Drip
34
34
gal
14
731
731
526
594
300
400
1,699
1,900
1,799
Inline
+
Met
Waiting
period
5
1,799
Bed
Metam
sodium
Drip
37
50
gal
21
26
1,
2,
3,
4
143
175
Pic
drip
Bed
Pic
EC
+
Std
tarp
Drip
24
24
gal
21
21
1,
2
3?
612
966
256
289
200
300
1,068
1,556
1,312
1,455
Bed
Pic
EC
+
VIF
tarp
Drip
24
24
gal
28
28
1,
2
3?
612
966
526
594
200
300
1,338
1,860
1,599
Pic
+
Met
Bed
Pic
EC
+
Std
tarp
Drip
24
24
gal
21
612
966
256
289
300
400
1,311
1,831
1,571
1,366
Waiting
period
5
Bed
Metam
sodium
Drip
37
50
gal
21
26
1,
2,
3
4?
143
175
Pic
Flat
Flat
Pic
Shank
200
200
lbs
7
Bed
up
380
380
193
218
256
289
300
400
1,271
1,462
1,366
1,208
Bed
Metam
sodium
Drip
37
50
gal
21
28
1,
2,
3
4?
143
175
Bed
Pic
Shank
200
200
lbs
21
380
380
256
289
300
400
1,079
1,244
1,161
Pic
flat
+
Met
Bed
Metam
sodium
Drip
37
50
gal
21
28
1,
2,
3
4?
143
175
1,366
Bed
Inline
+
Drip
34
34
gal
21
731
731
526
594
300
400
1,659
1,886
1,772
Pic
EC
+
VIF
tarp
Drip
4
4
gal
21
21
1,
2,
3
4?
102
161
Bed
Inline
+
Drip
34
34
gal
21
731
731
526
594
300
400
1,801
2,061
1,931
Pic
EC
+
VIF
tarp
Drip
4
4
gal
21
102
161
Waiting
period
5
Metam
sodium
Drip
37
50
gal
21
26
1,
2,
3,
4
143
175
Metam
Bed
Metam
sodium
Drip
50
50
gal
21
21
3
2?
4?
175
175
256
289
200
300
631
764
698
698
A
­
Standard
MBr
Applications
B
­
Telone
C35
Combinations
C
­
Drip
and
Shank
Combinations
*
Fumigation
is
conducted
in
order
to
obtain
Materials
Application
method
1
A
growth
response
Telone
C35
­
Telone
II
Shank
on
the
flat
2
Soil
borne
fungi
control
(
Verticillium,
Phytophthora
,
etc.)
Pic
Shank
on
the
flat,
shank
to
the
bed
3
Weed
control
Inline
Drip
to
the
bed
4
Nematode
control
Pic
EC
Drip
to
the
bed
Metam
sodium
Drip
to
the
bed,
rate
depending
on
objective
Bed
Costs
per
treated
acre
Rate
Total
Cost
Application
Method
and
Material
Tarp
Cost
Application
Cost
Controls*
Fumigant
Materials
Flat
Fumigant
costs
$/
Unit
Low
High
Unit
Lbs/
gal
1
Basamid
3.50
$
3.75
$
Lbs
2
Chloropicrin
1.90
$
2.60
$
Lbs
13.76
3
Chloropicrin
EC
1.90
$
3.00
$
Lbs
13.42
322.1419
966.43
$

4
MeBr
3.00
$
3.50
$
Lbs
5
MeBr
50/
50
­

$
2.50
$
Lbs
6
MeBr
57/
43
­

$
2.60
$
Lbs
7
MeBr
67/
33
2.60
$
3.10
$
Lbs
8
MeBr/
Pic
in
general
2.50
$
3.10
$
Lbs
9
Inline
21.50
$
25.00
$
Gal
10.09
10
Telone
C35
2.50
$
2.89
$
Lbs
11
Telone
II
2.45
$
2.85
$
Lbs
Calculated
Telone
II
cost
from
Pic
and
Telone
C35
costs
12
Metam
sodium
2.85
$
3.50
$
Gal
10.09
$/
lb
Tarp
costs
Low
High
Lbs/
acre
Standard
tarp,
flat
0.77
$
0.87
$
250
via
Paul
Niday
Standard
tarp,
bed
0.77
$
0.87
$
333
VIF
tarp
1.55
$
1.75
$
339
Bed
width
Linear
ft/
acre
Lbs
tarp/
acre
Average
68
7,687
323
333
52
10,052
342
Few
materials
to
put
on
Many
materials
to
put
on
$/
acre
$/
acre
Application
costs
Low
High
Low
High
200
300
300
400
$/
Unit
Pricing
Sources
Material
Low
High
Unit
Ameribrom
(
Gene
BrownChloropicrin
­

$
1.90
$
Lbs
Ameribrom
(
Gene
BrownMeBr
50/
50
­

$
2.50
$
Lbs
Ameribrom
(
Gene
BrownMeBr
57/
43
­

$
2.60
$
Lbs
BASF
(
W.
Pennington)
Basamid
3.50
$
3.75
$
Lbs
TriCal
(
Paul
Niday)
Chloropicrin
2.20
$
2.60
$
Lbs
TriCal
(
Paul
Niday)
Chloropicrin
EC
2.40
$
3.00
$
Lbs
TriCal
(
Paul
Niday)
Inline
21.50
$
25.00
$
Gal
TriCal
(
Paul
Niday)
MeBr
3.00
$
3.50
$
Lbs
TriCal
(
Paul
Niday)
MeBr
67/
33
2.60
$
3.10
$
Lbs
TriCal
(
Paul
Niday)
Telone
C35
2.50
$
2.89
$
Lbs
AMVAC
(
Chuck
DuerksenMetam
sodium
2.85
$
3.50
$
Gal
1
2
34
5
6
7
8
9
10
11
12
A
B
C
D
E
F
G
Specific
gravity
of
materials
(
depends
on
temperate)
65.%

Material
Lbs/
gal
Gal/
A
Lbs/
trt
A
lbs
if
%
qround
trted
pure
chloropicrin
material
1.65
g/
ml
13.76
1
13.8
8.9
chloropicrin
EC
1.61
g/
ml
13.42
24
322.1
209.4
Inline
(
Telone
C35EC)
1.21
g/
ml
10.09
35
353.1
229.5
metam
sodium
1.21
g/
ml
10.09
50
504.4
327.9
propargyl
bromide,
toulene
f1.335
g/
ml
11.13
1
11.1
7.2
pure
methyl
iodide
2.28
g/
ml
19.01
15
285.1
185.3
methyl
iodide
with
emulsifie1.65
g/
ml
13.76
24
330.1
214.6
Telone
II
10.1
Coinjection
calculations
Gallons
Inline
34.0
LBS
Inline
343.1
Gal
Telone
22.1
Gal
Pic
11.9
LBS
Telone
183.6
LBS
Pic
159.5
Gals
Pic
to
get
to
200
lbs
Pic/
acre
4.0
Additional
lbs
of
Pic
53.6
Total
lbs
in
application
396.7
Area
calculations
Bed
width
52
Bed
top
24
Bed
ft/
acre
10,052
#
beds
1
Bed
length
400
Acres
0
Rate
350
Flat
amt
14
Bed
amt
6
Tarp
calculations
Tarp
width
68
Bed
ft/
acre
10,052
Tarp
thickness
(
mils)
1.25
Inches
12
Constant
30,000
Lbs/
acre
tarp
342
68
323
52
342
332.5
Most
use
1.25
mil
tarp
in
WAT
Most
use
1.5
mil
tarp
in
OX
About
half
and
half
1.25
and
1.5
in
SM
White
is
a
heavy
material,
so
add
2%
to
weight
High
density
is
a
heavy
material,
so
add
1%
in
weight
VIF
add
2%
in
weight
Tarp
costs
(
as
of
010507,
probably
will
not
change
much
for
a
year
or
so)
Tarp
costs
drive
by
butane
and
propoane
costs,
demand
of
which
drive
by
industry
not
heating
markets
$/
lbs
Tarp
Low
high
Clear
smooth
$
0.77
$
0.79
Clear
embossed
$
0.85
$
0.87
Black
embossed
$
0.83
$
0.85
Brown
and
green
$
1.33
$
1.38
Brown
and
green
$
1.45
$
1.45
VIF
$
1.60
$
1.60
12.00
in/
ft
43,560.00
ft2/
acre
52.00
Bed
c­
c
24.00
Bed
top
0.46
Top/
c­
c
Cost
of
fumigation
materials
$/
Unit
Approximate
Material
Low
High
Unit
Application
cost
($/
acre)

1
Chloropicrin
Lbs
2
MeBr
Lbs
3
MeBr
50/
50
Lbs
4
MeBr
57/
43
Lbs
5
MeBr
67/
33
Lbs
6
Basamid
Lbs
7
Inline
Gal
8
Telone
C35
Lbs
9
Metam
sodium
Gal
Other:

10
11
12
13
14
15
Vegetable
Rotation
Narrative
Vegetable
crop
growers
would
also
suffer
with
loss
of
previously
fumigated
land.
Many
vegetable
crops
in
the
Watsonville
area
rotate
with
strawberry
growers.
They
benefit
from
reduced
disease
and
weed
pressure,
saving
approximately
$
100­$
200
per
acre
all
the
way
to
$
400
per
acre
(
Appendix
C).
Vegetable
crops
on
average
brought
revenues
of
approximately
$
7,000
per
acre
in
Monterey
County
in
2001
(
Appendix
K,
tab
"
Rotation
Crop
Costs").
Yet
most
vegetable
crops
are
also
very
low
margin
at
present.
UC
Davis
cost
of
production
documents
for
Broccoli
and
Cauliflower
show
net
per
acre
calculations
of
$
265
and
$
1050
per
acre,
while
lettuce
has
costs
of
$
8069
per
acre
in
2001,
yet
gross
per
acre
on
average
of
only
$
5918
per
acre.
With
such
close
margins,
or
lack
thereof,
any
savings
may
make
the
difference
between
solvency
and
debt
for
vegetable
growers
by
using
strawberry
ground.
Chloropicrin
Narrative
Technical
Feasibility
Efficacy.
Chloropicrin
used
alone
has
some
activity
against
much
of
the
California
Pest
Complex,
but
not
comparable
to
the
MBC
standard.
Chloropicrin
has
good
efficacy
against
Pseudomonas
solancearum,
Cylindrocladium
fungi,
Phytophthora,
Fusarium,
Pyrenochaeta,
Pythium,
Rhizoctonia,
Sclentina,
Slcerotium,
Verticillium,
clubroot
organism
Plasmodiophora,
soil
pox
Actinomyces
ipomoea
(
Table
1,
Pest
Complex
in
application,
and
Appendix
G,
Metapicrin
label).
Chloropicrin
alone
as
some
control
of
cut
worms,
grubs,
wireworms,
and
suppression
of
weeds
if
used
with
tarps.
It
has
no
control
over
some
key
weeds,
knotweed,
clovers,
and
filaree
and
limited
control
over
others
that
MBC
does
control
(
Appendix
DD,
Fennimore
2002
handout).
Chloropicrin
has
no
reported
activity
against
nematodes.
Nematodes
may
likely
become
an
increasing
problem
then
in
repeated
use
of
Chloropicrin.
MBC
has
controlled
nematodes
so
well
for
decades,
hard
to
measure
future
impact
of
this
pest
when
faced
with
less
than
adequate
control
from
Chloropicrin.

Yield
data
A
large
number
of
small
plot
and
on
farm
trials
of
chloropicrin
alone,
applied
either
as
shank
or
drip,
have
been
done
in
the
California
strawberry
growing
regions
(
Appendix
T,
Pic
tab).
When
pest
pressure
is
present,
chloropicrin
applied
alone
averages
95%
of
the
MBC
standard.
The
preferred
method
of
application
for
reasons
of
safety
and
cost
savings,
drip
application,
is
slightly
lower
at
94%
of
the
MBC
standard.
Shank
applications
were
96%
of
the
MBC
standard,
but
this
method
of
application
is
not
allowed
in
some
areas
(
for
instance
Ventura
County)
because
of
the
greater
potential
of
escape
of
material
into
the
air
and
subsequent
exposure
to
workers
and
the
public.
Yet,
the
rotation
growers
in
the
Northern
region
would
have
to
do
flat
chloropicrin
soil
fumigation
to
provide
the
most
thorough
pest
control,
or
vegetable
growers
will
not
rent
the
land
in
the
second
year
for
their
purposes.

Nearly
all
of
the
data
was
generated
on
land
previously
and
repeatedly
fumed
with
the
MBC
standard.
Few
experiments
exist
which
showed
repeated
use
on
the
same
land.
The
trials
run
in
Merced
County
(
Appendix
CC,
Pink
Sheet
01­
04),
included
repeated
use
of
chloropicrin
on
the
same
land.
The
berries
were
carried
over
two
years
from
the
first
application,
and
re­
fumed
the
third
year.
Yield
reduction
from
year
1
to
3
on
the
same
ground
was
approximately
33%
of
the
MBC
standard.
A
similar
trend
begins
to
be
seen
in
the
Oxnard
data
of
1999
and
2000
(
Appendix
T,
Pic
tab).
A
drop
in
overall
yields
of
about
9%
occurred
the
second
year
paralleling
the
increase
in
pest
pressure
as
demonstrated
by
the
yields
on
non­
fumigated
land
which
dropped
from
86%
the
first
year
(
essentially
no
pest
pressure)
to
77%
of
MBC
the
second
year.
Most
conclusive
is
a
study
by
Dr.
Doug
Shaw
and
Dr.
Kirk
Larson
on
comparisons
of
repeated
alternative
use
with
the
MBC
standard
(
Appendix
GG,
Shaw
and
Larson,
1999).
Successive
treatments
with
chloropicrin
over
three
years
compared
to
MBC
showed
a
steady
decline
in
yield
compared
to
MBC
from
2.2%
the
first
year,
to10.6%
the
second
year,
ending
with
13.7%
the
third
year.

More
recently
work
with
very
impermeable
film
(
VIF)
has
been
conducted.
But
results
are
variable
with
many
examples
of
phytotoxicity
occurring.
Further
work
determining
rates
and
plant
back
times
with
VIF
are
underway.
Each
grower
needs
to
be
able
to
test
these
results
in
their
own
specific
conditions.
More
time
and
work
are
needed
to
determine
at
the
farm
level,
the
optimal
use
conditions
for
chloropicrin
because
of
the
very
small
economic
margins
that
California
strawberry
growers
currently
face.

Economic
Analysis
When
the
overall
yield
95%
(
Appendix
T,
Pic
tab)
is
calculated
into
the
2001
baseline
revenue
for
each
region
(
Application
Worksheet
3­
E
PIC
Totals),
losses
again
are
observed
on
a
per
acre
basis
in
both
regions.
In
the
South
losses
are
$
949
per
acre.
In
the
North,
rotation
grower
in
the
first
year
average
a
plus
$
525
per
acre,
although
this
is
a
$
1,188
per
acre
loss
from
the
MBC
standard.
For
the
northern
non­
rotation
grower
losses
average
$
2,263
per
acre.
The
overall
average
for
the
North
is
a
loss
of
$
869
per
acre.
Since
the
median
acre
size
farm
of
our
representative
user
is
approximately
40
acres,
these
would
result
in
total
losses
of
$
37,960
in
the
South
and
$
90,520
for
the
Northern
non­
rotation
grower.

More
critical
though
is
the
increasing
yield
loss
over
time.
Based
on
the
loss
of
13.7%
of
the
MBC
standard
after
three
successive
years
of
chloropicrin
use
(
Appendix
GG,
Shaw
and
Larson,
1999),
losses
for
the
Northern
rotation
grower
would
approach
$
2,459
per
acre,
a
total
loss
of
$
98,360
for
the
third
year
alone.

While
the
rotation
grower
almost
breaks
even
with
a
loss
of
$
31
per
acre,
one
must
consider
that
growers
aren't
all
rotation
or
non­
rotation,
and
that
accumulation
of
pest
pressure
with
repeated
use
of
chloropicrin
alone
will
continually
lower
yields
with
time.
It
is
also
unknown
the
economic
impact
of
yields
for
vegetable
growers
using
strawberry
land
only
fumigated
with
chloropicrin.

Regulatory
Pressures
The
California
Department
of
Pesticide
Regulation
is
re­
evaluating
chloropicrin
at
this
time
with
anticipated
completion
of
the
review
in
approximately
2­
3
years.
There
are
already
sensitivities
around
the
use
of
the
material
due
to
its
physiological
effects
(
lacrimation
and
upper
respiratory
discomfort)
at
very
low
levels
in
the
air
(
Appendix
S).
Chloropicrin
is
also
currently
listed
as
a
toxic
air
contaminant
in
the
state,
and
could
be
subject
to
additional
regulatory
restraints
after
thorough
review
by
the
Scientific
Review
Panel
of
the
Air
Board.
Of
greatest
concern
is
what
additional
regulatory
restraints
could
be
in
place
in
2005
as
a
result
of
the
DPR
re­
evaluation,
particularly
increases
in
required
buffer
zones
which
would
limit
the
products
use
in
the
highly
urbanized
strawberry
growing
regions.

Buffer
zones
for
the
material
currently
vary
from
county
to
county
and
depend
upon
local
conditions
such
as
proximity
of
a
field
to
sensitive
sites.
In
most
cases
if
a
sensitive
site
(
occupied
buildings,
residences,
businesses,
schools,
hospitals
etc.)
is
within
300
feet
of
a
field,
a
100
foot
or
more
buffer
zone
is
required
depending
on
the
size
of
the
acreage
to
be
fumigated
at
a
given
time.
These
buffer
zones
are
actually
larger
than
buffer
zone
requirements
for
methyl
bromide
applications
near
most
sensitive
sites
(
60
feet
minimum
depending
upon
application
method
and
acres
to
be
fumigated
at
a
given
time.)
(
Appendix
X,
Chloropicrin
Permit
Conditions)

In
addition,
the
most
effective
rates
of
chloropicrin
when
applied
alone
are
200
lbs/
acre
or
more.
The
local
county
Ag
Commissioner
offices
in
California
issue
permits
to
applicators
for
all
applications
of
chloropicrin.
All
of
the
Ag
Commissioner
offices
in
the
strawberry
growing
regions
either
highly
discourage
or
prohibit
shank
or
drip
applications
of
200
lbs/
acre
or
more
of
chloropicrin.
Even
drip
applications,
with
mitigation
measures
such
as
overhead
sprinklers
should
leaks
or
release
occur,
are
limited
to
less
than
200
lbs/
acre
by
the
Commissioners
(
personal
communications
with
Ag
Commissioners
in
Orange,
Ventura,
Santa
Barbara
[
limits
to
150
lbs/
acre],
San
Luis
Obispo,
Santa
Cruz,
and
Monterey
Counties.)
In
addition
California
Department
of
Pesticide
Regulation
is
also
highly
concerned
about
uses
at
or
above
200
lbs/
acre.

Conclusion
Chloropicrin
used
alone
is
not
a
replacement
for
the
MBC
standard
because
of
lack
of
full
efficacy,
lower
yield
performance
against
the
MBC
standard
particularly
with
repeated
use
over
time
on
the
same
ground,
and
increased
regulatory
pressures
within
California.
1,3­
Dichloropropene
and
Chloropicrin
Technical
Feasibility
Efficacy.
Telone
 
(
1,3­
dichloropropene)
is
used
as
a
nematocide
with
minimal
efficacy
against
disease
and
weeds
when
used
alone.
Because
it
is
not
effective
against
the
entire
pest
complex
in
California
strawberries,
this
alone
prevents
it
from
being
a
methyl
bromide
replacement
(
Table
1,
Pest
Complex,
in
application).
Early
efficacy
work
with
Telone
alone
demonstrated
its
poorer
activity
compared
to
methyl
bromide/
chloropicrin
standards
(
Appendix
CC,
91­
15
Pink
Sheet).
And
in
fact
in
that
study
of
repeated
use
over
three
years,
already
poor
yields
dropped
with
time.
The
MBTOC
1998
report
(
page
51)
also
indicated
it
is
effective
only
in
combination
with
other
components.
The
Federal
Use
Label
also
shows
it
is
labeled
only
against
nematodes.

Chloropicrin
alone
has
some
activity
against
much
of
the
California
Pest
Complex.
Chloropicrin
has
good
efficacy
against
Pseudomonas
solancearum,
Cylindrocladium
fungi,
Phytophthora,
Fusarium,
Pyrenochaeta,
Pythium,
Rhizoctonia,
Sclentina,
Slcerotium,
Verticillium,
clubroot
organism
Plasmodiophora,
soil
pox
Actinomyces
ipomoea
(
Table
1,
Pest
Complex,
in
application).
Chloropicrin
alone
has
some
control
of
cut
worms,
grubs,
wireworms,
and
suppression
of
weeds
if
used
with
tarps
(
Appendix
G,
Metapicrin
label.)
It
has
no
control
over
some
key
weeds,
knotweed,
clovers,
and
filaree
and
limited
control
over
others
that
MBC
does
control
(
Appendix
DD,
Fennimore
2002
handout).
While
used
primarily
as
a
fungicide,
its
control
of
anthracnose
is
unknown,
and
this
disease
has
become
an
increasingly
important
problem
in
California
strawberries
and
is
controlled
by
MBC.
Chloropicrin
has
no
reported
activity
against
nematodes.
Nematodes
may
likely
become
an
increasing
problem
with
repeated
use
of
Chloropicrin.
MBC
has
controlled
nematodes
so
well
for
decades
and
it
is
difficult
to
measure
the
future
impact
of
this
pest
when
faced
with
less
than
adequate
control
from
Chloropicrin.

Combined
Efficacy
The
main
drawback
of
the
1,3­
D
chloropicrin
alternative
combination
is
the
lack
of
control
of
weeds.
Some
increased
control
of
weeds
has
been
observed
with
InLine
applications
using
VIF
mulch.
However,
as
in
all
drip
applications,
weed
control
is
not
observed
along
the
sides
of
the
beds
where
the
drip
application
did
not
reach.
Application
of
herbicides
is
not
a
simple
solution
because
these
side
weeds
are
under
the
mulch.
Removal
requires
extensive
labor
to
lift
the
tarp
sides,
pull
the
weeds,
and
replace
the
tarp
along
the
sides.
Use
of
additional
herbicides
would
simply
add
to
the
operational
costs
as
would
increased
labor
to
hand
weed.
Yields
When
the
yield
data
is
analyzed
for
both
shank
and
drip
applications
of
Telone
C35
or
InLine,
some
interesting
overall
results
are
observed.
When
only
data
from
trials
where
untreated
controls
had
yields
of
80%
or
less
of
the
MBC
standard
are
considered,
the
overall
yields
with
1,3­
D/
chloropicrin
averages
94%
of
the
MBC
standard
(
Appendix
T,
1,3­
D
Pic
tab).
When
drip
and
shank
applications
are
separated,
drip
was
better
at
97%
versus
90%
for
shank.
Analysis
of
10
studies
comparing
MBC
with
1,3­
D/
chloropicrin
applications
by
Shaw
and
Larson
showed
an
overall
loss
of
14.7%
compared
to
MBC.
No
studies
or
work
is
available
on
repeated
use
of
1,3­
D/
chloropicrin
on
the
same
land.
Since
Shaw
and
Larson
showed
steady
declines
in
yields
over
3
years
of
chloropicrin
use,
and
1,3­
D
has
limited
efficacy
on
the
pest
complex,
one
would
anticipate
steady
losses
with
use
of
this
material.
In
particular,
weed
pressure
may
increase
so
significantly
with
repeated
use
to
further
contribute
to
yield
loss.

Other
problems
have
been
experienced
with
drip
applications
of
InLine.
Phytoptoxicity
is
seen
sometimes
if
appropriate
plant
back
timings
were
not
used
during
the
study.
Soil
temperatures
are
critical
to
calculating
accurate
plant
back
times,
the
cooler
the
temperature,
the
longer
the
plant
back.
Damaged
to
irrigation
piping
and
systems
can
occur
if
proper
flushing
of
the
system
is
not
done
after
fumigation.
And
leaks
in
an
irrigation
system
can
result
in
pooling
of
chemical
and
therefore
spotty
delivery
to
the
field
resulting
in
variable
efficacy
throughout
the
field
or
phytotoxicity
after
planting
strawberry
transplants.
And
volume
delivery
of
the
drip
material
has
been
found
to
be
inappropriate
for
very
sandy
soils
(
no
spread
through
the
bed)
or
resulted
in
collapsed
beds
with
too
much
volume,
of
poor
efficacy
and
spread
in
heavier
soil.
In
short,
use
of
this
drip
material
requires
more
specific
soil
type,
moisture,
and
delivery
conditions.
All
of
these
problems
are
still
under
investigation
by
researchers,
particularly
rates
in
different
soils,
to
find
optimal
conditions
from
which
growers
can
then
safely
trial
the
material
in
their
own
specific
circumstances.

Economic
Analysis
For
drip
applications,
the
most
economical
and
safest
application
technology,
there
are
potential
up
front
costs
for
ensuring
irrigation
systems
are
leak
proof
and
proper
valves
and
safeguards
are
in
place
to
prevent
backflow
of
materials
into
water
sources.
In
addition,
1,3­
Dichloropropene
and
chloropicrin
are
very
corrosive
substance
and
if
proper
care
is
not
taken
to
clean
out
systems
after
application,
valves
and
piping
corrode
and
need
replacement.
Growers
need
to
replace
PVC
pipe,
which
is
corroded
by
1,3­
D
and
chloropicrin,
with
non­
PVC
piping
such
as
Oval
Hose.
The
first
growers
using
the
technology
state
that
they
had
minimal
up
front
costs
or
donations
of
equipment
to
upgrade
their
systems.
For
the
general
grower
upgrade
costs
could
run
thousands
of
dollars
to
replace
PVC
piping
and
add
proper
valve
and
flow
equipment.
We
estimate
yearly
costs
of
$
100
per
acre
to
upgrade
and
maintain
drip
systems
based
on
discussions
with
experienced
growers.

The
economics
associated
with
soil
preparation
come
into
play
for
1,3­
D/
chloropicrin
applications.
Soil
preparation
and
soil
moisture
are
more
critical
than
with
MBC
applications
(
Appendix
G,
Telone
C35
and
InLine
labels).
Soil
temperature
is
also
more
critical.
According
to
label
directions,
if
soil
temperatures
drop
below
40
°
F,
the
material
loses
effectiveness
on
application
and
requires
an
even
longer
plant
back
period.
The
normal
plant
back
period
is
roughly
1
week
for
every
10
gallons
per
acre
applied
(
Appendix
G).
At
best
this
leaves
a
plant
back
period
of
21
days
compared
to
the
7
days
for
MBC.
Even
so,
the
Southern
grower
pulling
crop
at
the
beginning
of
July
can
fit
in
Telone
C35
or
InLine
applications.

The
Northern
growers
however
will
lose
revenue
from
not
harvesting
the
second
half
of
September
($
1,262
per
acre)
for
rotational
growers.
There
is
some
savings
in
not
paying
harvest
costs
for
two
weeks,
a
total
of
$
459
per
week
(
fresh
harvest
costs
for
North
divided
by
35
weeks
harvest),
or
$
918
per
acre.
The
nonrotational
growers
will
have
to
obtain
their
land
sooner,
paying
one
quarter
year's
rent
to
prevent
the
vegetable
grower
from
doing
one
last
vegetable
crop.
Land
rent
in
the
northern
region
ranges
from
$
1800­
2400
per
acre.
One
quarter
of
the
average
rent,
$
2,100,
is
$
525.

Economic
analysis
was
done
with
best
case
scenarios.
For
the
Southern
grower
and
the
Northern
non­
rotation
grower,
it
was
assumed
drip
application
of
InLine
was
the
most
efficacious
and
cost
effective.
In
addition,
for
the
Southern
grower
it
is
assumed
he
has
just
enough
time
for
soil
preparation,
fumigation,
and
plant
back
time
of
21
days.
For
the
rotation
grower
in
the
North,
flat
fumigation
of
Telone
C35
is
the
only
option
to
ensure
coverage
of
the
entire
field
in
anticipation
of
use
the
next
year
by
vegetable
growers.
As
such,
when
these
costs
are
added
in,
the
Southern
grower
still
sees
a
loss
of
$
520
per
acre
a
total
loss
of
$
20,800
for
the
40
acre
representative
user.
In
the
North,
the
non­
rotation
grower
experiences
a
loss
of
$
895
per
acre
for
a
total
loss
of
$
35,800.
The
rotational
grower
experiences
the
greater
loss
of
$
2,099
per
acre
to
use
of
the
more
expensive
flat
fumigation
with
Telone
C35,
and
greater
yield
loss
with
that
treatment.
The
total
loss
for
the
40­
acre
representative
rotation
grower
is
$
83,960.
On
average
for
the
Northern
grower,
losses
would
be
$
1,497
per
acre,
or
$
59,880
for
the
40­
acre
Northern
grower.
This
are
minimum
possible
losses
because
if
plant
back
time,
particularly
in
the
colder
north,
increases
so
does
loss
of
revenue
by
having
to
take
land
back
earlier.

Regulatory
Pressures
1,3­
Dichloropropene
The
Federal
Label
requires
a
100
foot
buffer
zone
for
drip
applied
Telone
(
Appendix
G).
For
shank
applied
Telone,
a
100
foot
buffer
zone
is
required
the
first
year
and
a
300
foot
buffer
zone
is
required
for
the
next
two
years
on
the
same
ground.
In
addition,
in
California,
use
is
limited
by
township
caps,
as
an
additional
protection
with
respect
to
the
classification
of
1,3­
D
as
a
B2
carcinogen
(
Appendix
O,
P,
and
S).
Recently
township
caps
were
doubled
in
townships
where
historical
Telone
use
did
not
reach
the
maximum
allowed
under
the
caps,
in
general
90,000
lbs
per
township
(
Appendix
S).
This
is,
however
a
temporary
increase
until
the
amount
of
Telone
"
banked"
from
previous
years
is
used
up,
or
the
registrant
convinces
the
California
Department
of
Pesticide
Regulation
that
permanent
increases
are
justified
by
reassessing
the
oncogenic
risk.

Township
caps
originally
set
by
California
were
90,250
"
adjusted"
pounds
per
township
per
year
(
Appendix
P).
Adjusted
pounds
are
actual
pounds
of
1,3­
D
applied
times
an
application
factor.
This
calculates
out
to
approximately
345
acres
in
a
township
can
be
treated
with
InLine
using
VIF
mulch.
Since
a
township
is
approximately
25,000
acres,
and
many
townships
in
the
Northern
and
Southern
strawberry
growing
regions
have
over
a
thousand
acres
in
strawberries
in
many
townships,
obviously
not
all
strawberries
growers
could
use
Telone
products.

DPR
recently
doubled
the
township
cap
in
many
of
the
townships
where
previous
use
did
not
equal
the
maximum
amount
allowed
under
the
old
township
cap.
In
essence,
the
unused
amount
was
"
banked"
for
future
use.
This,
however,
is
only
a
temporary
solution
until
the
banked
amounts
are
used
up.
Meanwhile
the
1,3­
D
registrant
is
working
with
DPR
to
revise
regional
modeling
schemes
to
determine
whether
permanent
caps
should
be
recalculated
based
on
each
regions
weather
conditions.
Such
analysis
so
far
is
predicted
to
result
in
caps
close
to
the
current
increased
caps
or
between
the
old
and
new.

Dr.
Tom
Trout
of
USDA
has
provided
an
analysis
of
the
impacted
acres
of
strawberries
in
each
county
based
on
the
old
and
new
township
cap
(
Appendix
P).
His
analysis
shows
at
best
that
Telone
products
will
not
be
available
to
47%
of
the
total
strawberry
acreage
in
the
state.
For
the
strawberry
growing
regions,
his
study
projects
unavailable
acres
according
to
the
following
table
(
based
on
2001
acreage):

Region
Total
Acres
Straw
Acres
Unavailable
%
of
Acres
Watsonville
10,759
4,344
40.4%
Santa
Maria
3,817
1,645
43%
Ventura
County
7,777
4,228
54%
Orange
County
2,446
243
10%

Roughly
half
of
the
Southern
acreage
would
not
be
able
to
use
Telone
products.
And
roughly
40%
of
the
Northern
acreage
would
not.
Considering
it
is
not
economical
for
the
Northern
rotation
growers,
to
account
for
concentration
of
non­
rotation
acres
in
the
same
affected
townships,
from
40­
100%
of
the
2,500
acres
of
non­
rotational
growers
acres
in
the
Watsonville
area
could
use
the
material,
although
they
could
still
suffer
losses
using
it
over
MBC.
Much
of
the
land
in
the
Watsonville
area
however
is
not
amenable
to
drip
applications
because
of
soil
type
and
hilliness,
further
reducing
use
of
the
material.
The
1645
acres
in
Santa
Maria
would
be
available
and
only
4,228
acres
in
Ventura.
At
best
then,
8,373
strawberries
acres
may
be
able
to
use
the
material.
This
roughly
calculates
to
availability
to
approximately
30%
of
strawberry
growers
at
best
even
under
the
expanded
township
caps.

!,
3­
D
is
also
classified
as
a
toxic
air
contaminant
in
the
state
of
California
and
will
undergo
additional
scrutiny
in
future.
This
classification,
in
addition
to
the
classification
as
a
B­
2
probable
carcinogen
contributes
to
an
uncertain
regulatory
future
in
California.

Chloropicrin
The
California
Department
of
Pesticide
Regulation
is
re­
evaluating
chloropicrin
at
this
time
with
anticipated
completion
of
the
review
in
approximately
2­
3
years.
There
are
already
sensitivities
around
the
use
of
the
material
due
to
its
physiological
effects
(
lacrimation
and
upper
respiratory
discomfort)
at
very
low
levels
in
the
air.
Chloropicrin
is
also
currently
listed
as
a
toxic
air
contaminant
in
the
state,
and
could
be
subject
to
additional
regulatory
restraints
after
thorough
review
by
the
Scientific
Review
Panel
of
the
California
Air
Resources
Board.
Of
greatest
concern
is
what
additional
regulatory
restraints
could
be
in
place
in
2005
as
a
result
of
the
DPR
re­
evaluation,
particularly
increases
in
required
buffer
zones,
which
would
limit
the
products
use
in
the
highly
urbanized
strawberry
growing
regions
(
Appendix
S).

Buffer
zones
for
chloropicrin
currently
vary
from
county
to
county
and
depend
upon
local
conditions
such
as
proximity
of
a
field
to
sensitive
sites
(
Appendix
X).
In
most
cases
if
a
sensitive
site
(
occupied
buildings,
residences,
businesses,
schools,
hospitals
etc.)
is
within
300
feet
of
a
field,
a
100
foot
or
more
buffer
zone
is
required
depending
on
the
size
of
the
acreage
to
be
fumigated
at
a
given
time.
These
buffer
zones
are
actually
larger
than
buffer
zone
requirements
for
methyl
bromide
applications
near
most
sensitive
sites
(
60
feet
minimum
depending
upon
application
method
and
acres
to
be
fumigated
at
a
given
time.)

Conclusion
The
combined
soil
fumigation
regime
of
1,3­
dichloropropene
and
chloropicrin
is
questionable
as
a
methyl
bromide
alternative.
It
is
on
the
edge
economically
for
some
growers
and
significantly
limited
by
township
caps
in
California,
at
best
limiting
it
to
33%
of
the
strawberry
acreage.
The
most
efficacious
application
is
drip
application
of
InLine,
yet
its
use
is
limited
by
various
geographical
and
soil
factors.
For
instance
drip
applications
are
difficult
on
hilly
land,
of
which
approximately
half
of
the
Watsonville
growing
region
has
hills.
In
addition,
if
the
soil
is
too
sandy,
the
material
does
not
spread
out
in
the
bed
giving
poor
coverage.
If
the
soil
is
too
heavy,
again
poor
coverage
results
because
it
cannot
move
effectively
through
the
heavy
soil.
Or
worse
yet,
if
material
is
applied
too
quickly
in
high
volumes,
beds
can
collapse,
as
they
have
in
some
of
the
experimental
trials.
Finally,
if
not
properly
rinsed,
irrigation
systems
can
corrode
increasing
grower
costs
for
replacements,
or
phytotoxicity
can
result
if
material
left
in
the
system
reaches
transplants.

This
combination
is
also
under
continual
regulatory
scrutiny
because
of
acute
toxicity
and
the
carcinogenic
classification
of
1,3­
D.
While
research
work
continues
on
improving
yield
and
use
potential,
1,3­
D/
chloropicrin
is
not
currently
an
alternative
for
the
majority
of
strawberry
growers.

Growers
need
3­
4
years
of
practice
with
this
regime
in
their
own
specific
field
and
climate
conditions
to
perfect
any
potential
use
of
the
regime.
With
the
very
low
margins
present
in
the
current
strawberry
market,
growers
can
only
afford
to
do
relatively
small
acreage
at
a
time
to
minimize
potential
losses
until
they
perfect
conditions
using
the
alternatives.
