Page
1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
STRAWBERRY
NURSERIES
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
Methyl
Bromide
Technical
Options
Committee
(
MBTOC),
the
United
States
(
U.
S.)
has
organized
this
version
of
its
Critical
Use
Exemption
Nomination
in
a
manner
that
would
enable
a
holistic
review
of
relevant
information
by
each
individual
sector
team
reviewing
the
nomination
for
a
specific
crop
or
use.
As
a
consequence,
this
nomination
for
strawberry
nurseries,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
United
States
believes
is
crucial
to
enabling
review
of
our
nomination
in
a
manner
that
meets
the
requirements
of
the
Parties'
critical
use
decisions.
With
that
understanding,
the
fully
integrated
U.
S.
nomination
for
strawberry
nurseries
follows.

2.
Background
In
1997,
the
Parties
to
the
Montreal
Protocol
adjusted
Article
2H
of
the
Protocol,
and
agreed
to
accelerate
the
reduction
in
the
controlled
production
and
consumption
of
methyl
bromide.
This
adjustment
included
a
provision
calling
for
a
phaseout
of
methyl
bromide
by
the
year
2005
"
save
to
the
extent
that
the
Parties
decide
to
permit
the
level
of
production
or
consumption
that
is
necessary
to
satisfy
uses
agreed
by
them
to
be
critical
uses."
At
the
same
time,
the
Parties
adopted
decision
IX/
6,
the
critical
use
exemption
decision,
which
laid
out
the
terms
under
which
critical
use
exemptions
under
Article
2H
would
be
granted.

3.
Criteria
for
Critical
Uses
Under
the
Montreal
Protocol
In
crafting
Decision
IX/
6
outlining
the
criteria
for
a
critical
use
exemption,
the
Parties
recognized
the
significant
differences
between
methyl
bromide
uses
and
uses
of
other
ozone­
depleting
chemicals
previously
given
scrutiny
under
the
Protocol's
distinct
and
separate
Essential
Use
exemption
process.
The
United
States
believes
that
it
is
vitally
important
for
the
MBTOC
to
take
into
account
the
significant
differences
between
the
critical
use
exemption
and
the
essential
use
exemption
in
the
review
of
all
methyl
bromide
critical
use
nominations.

During
the
debate
leading
up
to
the
adoption
of
the
critical
use
exemption
Decision
IX/
6,
an
underlying
theme
voiced
by
many
countries
was
that
the
Parties
wanted
to
phase
out
methyl
bromide,
and
not
agriculture.
This
theme
was
given
life
in
various
provisions
of
the
critical
use
exemption,
and
in
the
differences
in
approach
taken
between
the
critical
use
exemption
and
the
essential
use
exemption.
Those
differences
are
outlined
below.

The
Protocol's
negotiated
criteria
for
the
critical
use
exemptions
for
methyl
bromide
are
much
different
from
the
criteria
negotiated
for
"
Essential
Uses"
for
other
chemicals.
Page
2
Under
the
Essential
Use
provisions,
in
order
to
even
be
considered
for
an
exemption,
it
was
necessary
for
each
proposed
use
to
be
"
critical
for
health,
safety
or
the
functioning
of
society."
This
high
threshold
differs
significantly
from
the
criteria
established
for
the
methyl
bromide
Critical
Use
exemption.
Indeed,
for
methyl
bromide,
the
Parties
left
it
solely
to
the
nominating
governments
to
find
that
the
absence
of
methyl
bromide
would
create
a
significant
market
disruption.

For
the
U.
S.
nomination
for
strawberry
nurseries,
following
detailed
technical
and
economic
review,
the
United
States
has
determined
that
the
level
of
methyl
bromide
being
requested
is
critical
to
ensuring
that
there
is
no
significant
market
disruption.
The
detailed
analysis
of
technical
and
economic
viability
of
the
alternatives
listed
by
MBTOC
for
use
in
strawberry
nurseries
is
discussed
later
in
this
nomination.

In
the
case
of
methyl
bromide,
the
Parties
recognized
many
agricultural
fumigants
were
inherently
toxic,
and
therefore
there
was
a
strong
desire
not
to
replace
one
environmentally
problematic
chemical
with
another
even
more
damaging.

The
critical
use
exemption
language
explicitly
requires
that
an
alternative
should
not
only
be
technically
and
economically
feasible,
it
must
also
be
acceptable
from
the
standpoint
of
health
and
environment.
This
is
particularly
important
given
the
fact
that
most
chemical
alternatives
to
methyl
bromide
are
extremely
toxic,
and
can
involve
threats
to
human
health
or
the
environment
that
are
even
greater
than
the
threats
posed
by
methyl
bromide.

In
the
case
of
methyl
bromide,
the
Parties
recognized
that
evaluating,
commercializing
and
securing
national
approval
of
alternatives
and
substitutes
is
a
lengthy
process.

In
fact,
even
after
an
alternative
is
tested
and
found
to
work
against
some
pests
in
a
controlled
setting,
adequate
testing
in
large­
scale
commercial
operations
can
take
many
cropping
seasons
before
the
viability
of
the
alternative
can
be
adequately
assessed
from
the
standpoint
of
the
climate
and
soil
for
various
potential
users.
In
addition,
the
process
of
securing
national
and
sub­
national
approval
of
alternatives
may
require
extensive
analysis
of
environmental
consequences
and
toxicology.
The
average
time
for
the
national
review
of
scientific
information
in
support
of
a
new
pesticide,
starting
from
the
date
of
submission
to
registration,
is
approximately
38
months.
In
most
cases,
the
company
submitting
the
information
has
spent
approximately
7­
10
years
developing
the
toxicology
and
other
environmental
data
necessary
to
support
the
registration
request.

The
Parties
to
the
Protocol
recognized
that
unlike
other
chemicals
controlled
under
the
Montreal
Protocol,
the
use
of
methyl
bromide
and
available
alternatives
could
be
site
specific
and
must
take
into
account
the
particular
needs
of
the
user.

The
Essential
Use
exemption
largely
assumed
that
an
alternative
used
in
one
place
could,
if
approved
by
the
government,
be
used
everywhere.
Parties
clearly
understood
that
this
was
not
the
case
with
methyl
bromide
because
of
the
large
number
of
variables
involved,
such
as
crop
type,
soil
types,
pest
pressure
and
local
climate.
That
is
why
the
methyl
bromide
Critical
Use
exemption
calls
for
an
examination
of
the
feasibility
of
the
alternative
from
the
standpoint
of
the
user,
and
in
the
context
of
the
specific
circumstances
of
the
nomination,
including
use
and
geographic
location.
In
order
to
effectively
implement
this
last,
very
important
provision,
we
believe
it
is
critical
for
MBTOC
reviewers
to
Page
3
understand
the
unique
nature
of
U.
S.
agriculture,
as
well
as
U.
S.
efforts
to
minimize
the
use
of
methyl
bromide,
to
research
alternatives,
and
to
register
alternatives
for
methyl
bromide.

4.
U.
S.
Consideration/
Preparation
of
the
Critical
Use
Exemption
for
Strawberry
Nurseries
Work
on
the
U.
S.
critical
use
exemption
process
began
in
early
2001.
At
that
time,
the
U.
S.
Environmental
Protection
Agency
(
U.
S.
EPA)
initiated
open
meetings
with
stakeholders
both
to
inform
them
of
the
Protocol
requirements,
and
to
understand
the
issues
being
faced
in
researching
alternatives
to
methyl
bromide.
During
those
meetings,
which
were
attended
by
State
and
association
officials
representing
thousands
of
methyl
bromide
users,
the
provisions
of
the
critical
use
exemption
Decision
IX/
6
were
reviewed
in
detail,
and
questions
were
taken.
The
feedback
from
these
initial
meetings
led
to
efforts
by
the
United
States
to
have
the
Protocol
Parties
establish
international
norms
for
the
details
to
be
in
submissions
and
to
facilitate
standardization
for
a
fair
and
adequate
review.
These
efforts
culminated
in
decision
XIII/
11
which
calls
for
specific
information
to
be
presented
in
the
nomination.

Upon
return
from
the
Sri
Lanka
meeting
of
the
Parties,
the
U.
S.
took
a
three
track
approach
to
the
critical
use
process.
First,
we
worked
to
develop
a
national
application
form
that
would
ensure
that
we
had
the
information
necessary
to
answer
all
of
the
questions
posed
in
decision
XIII/
11.
At
the
same
time,
we
initiated
sector
specific
meetings.
This
included
meetings
with
representatives
of
strawberry
nurseries
across
the
United
States
to
discuss
their
specific
issues,
and
to
enable
them
to
understand
the
newly
detailed
requirements
of
the
critical
use
application.
These
sector
meetings
allowed
us
to
fine
tune
the
application
so
we
could
submit
the
required
information
to
the
MBTOC
in
a
meaningful
fashion.

Finally,
and
concurrent
with
our
preparation
phase,
we
developed
a
plan
to
ensure
a
robust
and
timely
review
of
any
and
all
critical
use
applications
we
might
receive.
This
involved
the
assembly
of
more
than
45
PhDs
and
other
qualified
reviewers
with
expertise
in
both
biological
and
economic
issues.
These
experts
were
divided
into
interdisciplinary
teams
to
enable
primary
and
secondary
reviewers
for
each
application/
crop.
As
a
consequence,
each
nomination
received
by
the
U.
S.
was
reviewed
by
two
separate
teams.
In
addition,
the
review
of
these
interdisciplinary
teams
was
put
to
a
broader
review
of
experts
on
all
other
sector
teams
to
enable
a
third
look
at
the
information,
and
to
ensure
consistency
in
review
between
teams.
The
result
was
a
thorough
evaluation
of
the
merits
of
each
request.
A
substantial
portion
of
requests
did
not
meet
the
criteria
of
decision
IX/
6,
and
a
strong
case
for
those
that
did
meet
the
criteria
has
been
included.

Following
our
technical
review,
discussions
were
held
with
senior
risk
management
personnel
of
the
U.
S.
government
to
go
over
the
recommendations
and
put
together
a
draft
package
for
submission
to
the
parties.
As
a
consequence
of
all
of
this
work,
it
is
safe
to
say
that
each
of
the
sector
specific
nominations
being
submitted
is
the
work
of
well
over
150
experts
both
in
and
outside
of
the
U.
S.
government.
government.

5.
Overview
of
Agricultural
Production
5a.
U.
S.
Agriculture
Page
4
The
United
States
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
agricultural
climates.
These
factors
contribute
to
and
enable
the
U.
S.
to
be
a
uniquely
large
and
productive
agricultural
producer.
Indeed,
the
size
and
scope
of
farming
in
the
U.
S.
is
different
than
in
most
countries.
Specifically,
in
2001,
U.
S.
farm
land
totaled
381
million
hectares,
a
land
area
larger
than
the
size
of
many
entire
countries.
Of
this,
approximately
140
million
hectares
were
devoted
to
cropland,
with
the
rest
devoted
to
pasture,
forest,
and
other
special
uses.
There
were
2.16
million
farms,
with
average
farm
size
across
all
farms
of
176
hectares
(
approximately
10
times
larger
than
average
farm
size
in
the
European
Union).
The
availability
of
land
and
the
fact
that
so
many
U.
S.
regions
are
conducive
to
outdoor
cultivation
of
fruits
and
vegetables,
has
had
an
important
influence
on
the
way
agriculture
has
developed.
Specifically,
these
factors
have
meant
that
greenhouse
production
has
generally
proven
to
be
very
costly
(
in
relative
terms)
and
has
as
a
consequence,
been
limited.

Other
factors
also
affected
the
general
development
of
farming
in
the
U.
S..
While
land
for
farming
is
widely
available,
labor
is
generally
more
expensive
and
less
plentiful.
As
a
result,
the
U.
S.
has
developed
a
system
of
highly
mechanized
farming
practices
that
are
highly
reliant
on
pesticides
such
as
methyl
bromide
and
other
non­
labor
inputs.
The
extent
of
mechanization
and
reliance
on
non­
labor
inputs
can
be
best
demonstrated
by
noting
the
very
low
levels
of
labor
inputs
on
U.
S.
farms:
in
2001,
only
2.05
million
workers
operated
the
2.16
million
U.
S.
farms,
with
help
from
less
than
1
million
hired
workers.

U.
S.
agriculture
is
also
unique
in
terms
of
the
broad
range
of
crops
produced.
For
example,
the
fruit
and
vegetable
sector,
the
agricultural
sector
most
reliant
on
methyl
bromide,
is
diverse,
and
includes
production
of
107
separate
fruit
and
vegetable
commodities
or
groups
of
commodities.
With
this
diversity,
however,
has
come
a
large
number
of
pest
problems
that
methyl
bromide
has
proven
uniquely
able
to
address.

Finally,
the
above
factors
have
contributed
to
a
harvest
of
commodities
that
has
enabled
the
U.
S.
to
meet
not
only
its
needs,
but
also
the
needs
of
many
other
countries.
The
U.
S.
produced
88.3
million
metric
tonnes
of
fruits
and
vegetables
in
2001,
up
10
percent
from
1990.
At
the
same
time,
the
land
planted
in
fruits
and
vegetables
has
remained
stable,
and
individual
farm
size
has
increased
as
the
number
of
farms
has
fallen.
The
related
yield
increases
per
land
area
are
almost
exclusively
related
to
non­
labor
inputs,
like
the
adoption
of
new
varieties,
and
the
application
of
new
production
practices,
including
plastic
mulches,
row
covers,
high­
density
planting,
more
effective
pesticide
sprays,
and
drip
irrigation,
as
well
as
increased
water
irrigation
practices.
Optimization
of
yields
through
these
and
other
scientific
and
mechanized
practices
make
U.
S.
agricultural
output
very
sensitive
to
changes
in
inputs.
Therefore,
as
evidenced
by
the
U.
S.
nomination
for
critical
uses
of
methyl
bromide,
the
phaseout
of
methyl
bromide
can
have
a
very
significant
impact
on
both
the
technical
and
economic
viability
of
production
of
certain
crops
in
certain
areas.

5b.
Strawberry
Nursery
Production
Most
of
the
strawberry
nursery
stock
is
raised
in
California,
with
significant
additional
production
occurring
in
the
southeastern
U.
S.
including
the
states
of
North
Carolina
and
Tennessee.
California
nurserymen
produce
over
one
billion
plants
per
year
on
about
1,295
hectares
for
national
and
international
shipment.
The
typical
California
strawberry
nursery
is
about
80
to
160
hectares.
California
growers
use
approximately
600,000,000
of
these
plants
annually
and
400,000,000
plants
are
Page
5
exported
to
other
U.
S.
states,
Canada,
Europe,
and
Asia.
The
total
value
of
California
production
is
estimated
at
US$
60
million,
annually.
California
is
able
to
produce
strawberry
rootstock
for
this
wide
distribution
of
climates
because
they
have
both
high
elevation
and
low
elevation
strawberry
nurseries.
As
a
consequence,
this
nomination
covers
use
in
a
variety
of
areas
with
differing
soil
and
climactic
characteristics.
Production
of
strawberry
rootstock
in
the
southeastern
U.
S.
is
primarily
for
various
States
in
the
southeast.
In
the
United
States,
the
strawberry
nursery
industry
supplies
plants
that
are
used
as
root
stock
for
strawberry
fruit
production
and
nursery
plantings
for
the
U.
S.,
Canada,
Mexico,
Spain,
and
several
South
American
countries.
It
is
extremely
important
that
these
plants
are
pest
and
disease
free
in
order
to
avoid
the
introduction
of
pests
into
strawberry
fruit
production
areas
and
to
ensure
vigorous
fruit
producing
plants.
In
the
U.
S.,
strawberry
nursery
production
practices
vary
among
regions.
Strawberry
nurseries
produce
two
distinct
types
of
plants
­
runner
and
plug.

California.
In
California,
plug
plants
constitute
only
1
percent
of
the
strawberry
transplants
with
the
majority
of
production
going
to
runner
plants.
The
strawberry
nursery
growers
fumigate
plantings
every
year
with
methyl
bromide
as
they
move
the
plants
through
the
5
year
cycle
of:
year
1
­
foundation
plantings,
year
2
­
screenhouse
propagation,
year
3
­
foundation
increases,
year
4
­
registered
increases,
and
year
5
­
certified
field
increases.
Strawberry
nursery
fields
are
typically
rotated
out
of
strawberry
production
for
two
years.
The
rotation
crops
that
follow
strawberry
rootstock
production
benefit
from
the
low
levels
of
pests
due
to
methyl
bromide.
These
crop
rotation
commodities
include:
onions,
garlic,
endive,
horseradish,
mint,
potatoes,
sugar
beets,
alfalfa,
barley,
oats,
wheat,
and
triticale.

California
strawberry
nurseries
are
at
both
high
and
low
elevations,
with
high
elevation
nurseries
representing
75%
of
the
land
area
and
low
elevation
nurseries
representing
25%
of
the
land
area.
.
Seventy
percent
of
the
soils
are
mostly
light
and
sandy
which
is
optimal
for
deep
root
development.
Sixty
percent
of
fields
are
planted
in
spring,
and
fumigation
may
either
be
performed
in
the
spring
or
fall,
with
deep
fumigation
required.
Planting
is
mechanical
and
fields
are
generally
hand
weeded
and
the
typical
field
size
is
80
to
160
hectares
(
200
to
400
acres).
Overhead
irrigation,
chemigation,
and
fertigation
are
used
as
plant
canopy
closes.

As
nursery
plants
are
harvested,
some
material
is
left
in
the
field
because
of
the
harvesting
techniques
and
the
removal
of
foliage.
Because
strawberry
plants
are
propagated
vegetatively
in
order
to
maintain
genetic
characteristics,
occurrence
of
volunteer
plants
from
seed
must
be
controlled
to
avoid
genetically
mixed
plantings
which
would
render
them
unsaleable.

Southeast.
The
Southeast
nurseries
produce
both
runner
and
plug
plants.
Runner
plants
are
propagated
on
flat,
unmulched
beds.
Methyl
bromide
is
broadcast
injected
below
the
soil
surface
and
then
tarped
in
one
operation
with
1
mil
clear
plastic.
When
they
reach
maturity
the
freshly
dug
plants
are
sold
primarily
to
North
Carolina
and
Florida
strawberry
producers.
About
1
hectare
of
nursery
runner
plants
(
about
1,235,000
plants
per
hectare)
supplies
plant
materials
for
about
5
hectares
of
production
berries.
Southeast
strawberry
nurseries
can
range
in
size
from
1
to
30
hectares
(
3
to
80
acres)
with
the
typical
strawberry
nursery
having
approximately
20
hectares
(
50
acres).

The
use
of
plug
plants
is
expanding
in
the
Southeast
and
in
contrast
to
runner
plants,
plug
plants
are
produced
from
plantlets
(
tips)
propagated
on
raised,
mulched
beds
that
require
fumigation.
Roughly
the
same
land
area
is
required
to
produce
these
tips
(
about
620,000
per
hectare)
as
is
required
to
produce
the
Page
6
bare­
root
plants.
The
cost
of
plug
plants
is
about
16
cents
per
plant
compared
to
8
cents
per
plant
for
the
traditional
bare
root
plants.
However,
the
use
of
plug
plants
reduces
the
costs
of
both
planting
and
plant
establishment
because
the
planting
can
be
mechanized
and
there
is
a
reduction
in
irrigation
cost.
Additionally,
the
plug
plant
system
is
more
tolerant
of
extreme
weather
conditions.
The
reduced
rates
required
to
fumigate
a
raised
bed
with
methyl
bromide
verses
the
rates
required
to
fumigate
a
flat
bed
would
result
in
a
40%
savings
in
terms
of
amount
of
actual
methyl
bromide
used.

Production
in
the
strawberry
nursery
sector
is
also
subject,
as
is
all
nursery
production,
to
a
number
of
legal
requirements
designed
to
restrict
the
spread
of
pest
to
areas
not
currently
infested.
In
some
cases
these
restrictions
explicitly
require
fumigation
with
methyl
bromide.
In
other
cases,
the
need
for
pests
to
be
controlled
to
non­
detectable
levels
has
implicitly
required
that
methyl
bromide
be
used
because
of
its
efficacy
and
reliability.
Because
methyl
bromide
is
known
to
be
so
effective,
some
protocols
for
nursery
facilities
do
not
even
require
sampling
of
the
nursery
stock
to
determine
that
it
is
pest
free,
it
is
simply
assumed
to
be
so.
If
an
alternative
to
methyl
bromide
is
used,
sampling
may
be
required
with
the
potential
for
destruction
of
100
percent
of
the
strawberry
stock
if
detectable
levels
of
pests
are
found.

In
general,
U.
S.
society
has
a
strong
interest
in
avoiding
the
spread
of
pests
and
in
maintaining
healthy
and
pest­
free
propagative
material
which
must
be
weighed
against
other
kinds
of
environmental
damage.
In
addition,
vigorous,
healthy,
pest­
free
stock
produces
more
fruit
when
in
production
than
plants
burdened
with
a
pest
or
disease
infestation.
Specifically,
according
to
the
California
Strawberry
Nursery
Association,
when
data
is
generated
for
alternative
chemical
replacements
for
methyl
bromide
using
strawberry
transplants
that
have
not
been
produced
in
nursery
beds
fumigated
with
methyl
bromide,
7.5
percent
yield
reduction
in
fruit
production
can
be
calculated
relative
to
fruit
produced
by
nursery
plants
fumigated
with
methyl
bromide
irrespective
of
the
type
of
pesticide
treatment
of
the
fruit­
producing
plant..
In
the
U.
S.,
producers
of
organically
grown
strawberries
have
stated
that
they
cannot
produce
organically
grown
strawberries
unless
they
receive
root
stock
that
has
been
treated
with
methyl
bromide.
(
Communication
from
the
U.
S.
methyl
bromide
review
team.)

Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematicide
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640).

Additionally,
there
are
specific
soil
treatment
and
handling
procedures
to
facilitate
compliance
with
the
regulations
for
the
Nursery
Stock
Nematode
Control
Program.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
and
"
commercially
clean
with
respect
to
established
pests
of
general
distribution"
in
order
to
qualify
for
a
nursery
stock
certificate
for
interstate
and
intrastate
shipments.
Strawberry
nurserymen
must
document
compliance
on
a
monthly
basis
and
if
they
are
found
to
have
nursery
stock
with
nematodes,
100%
of
their
strawberry
root
stock
is
at
risk
for
a
loss.
These
plants
represent
a
5
year
investment
by
the
nursery
grower
and
are
shipped
worldwide
as
both
nursery
and
production
plants.
There
are
wide
and
specific
destination
quarantine
restrictions
and
international
quarantine
control
issues
involved
with
shipment
of
nursery
stock.

Tennessee,
North
Carolina,
and
most
of
the
other
Southeastern
states,
have
either
general
and/
or
specific
plant
protection
and
nursery
stock
regulations
that
require
strawberry
nursery
plants
being
transported
within
or
into
the
state,
to
be
essentially
free
of
pests
and
diseases.
Page
7
6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Strawberry
Nurseries
6a.
Target
Pests
Controlled
with
Methyl
Bromide
Strawberry
nurseries
in
the
U.
S.
contend
with
a
variety
of
pests.
The
pests
which
have
a
significant
impact
on
the
quantity
and
quality
of
the
rootstock
and
the
subsequent
production
of
strawberry
fruit
are
the
fungi
which
produce
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.),
Crown
rot
(
Phytophthora
cactorum);
the
Root
Knot
nematode
(
Meloidogyne
spp.);
and
the
weed
species
Yellow
nutsedge
(
Cyperus
esculentus)
and
Purple
nutsedge
(
Cyperus
rotundus).
Although
nutsedge
is
generally
less
of
a
problem
in
nursery
soils
than
in
fruit
production
operations,
when
there
is
weed
pressure,
more
likely
in
the
Southeast
than
in
other
regions,
hand
and
mechanical
weed
control
is
limited
and
difficult
in
runner
plant
production.
The
critical
use
exemption
nomination
is
based
primarily
on
the
need
to
provide
pestfree
root
stock
to
have
healthy
and
vigorous
producing
stock
and
to
avoid
introducing
pest
species
into
areas
where
they
are
not
already
common,
although
the
need
to
control
the
above
mentioned
pests
is
also
important
in
maintaining
yield
and
quality
of
the
runner
plants.

Fungal
diseases.
Crown
root
rot,
caused
by
Phytophthora
cactorum,
causes
rotting
of
the
crown
of
the
plant,
followed
by
plant
death,
often
just
as
fruiting
is
starting.
Phytophthora
blight
is
one
of
the
most
destructive
diseases
and
there
are
few
control
measures.
Resistance
to
metalaxyl
has
been
documented
for
Phytophthora
species.
Black
root
rot,
caused
by
Rhizoctonia
and
Pythium
spp.,
is
also
very
common
and
destructive
syndrome
affecting
strawberry
and
other
crops.
Plants
with
black
root­
rot
complex
do
not
grow
properly
and
soon
die.
The
root
system
will
be
dark
and
rotten,
and
there
will
be
a
noticeable
absence
of
small
feeder
roots.
In
California's
strawberry
nursery
areas,
phytophthora
is
the
major
problem
controlled
with
methyl
bromide,
and
this
disease
is
endemic
to
California.

Root­
knot
nematode
(
Meloidogyne
spp.)
Root
damage
caused
by
these
nematodes
leads
to
reduced
rooting
systems,
which
in
turn
lead
to
reduced
water
and
nutrient
uptake.
The
gall
formation
induced
by
the
nematodes
at
their
root
feeding
sites
results
in
symptoms
like
stunting,
wilting,
and
chlorosis,
and
renders
the
plant
more
susceptible
to
secondary
infections.
Preplant
control
of
nematodes
is
important
because
once
root
damage
is
done
and
symptoms
are
evident,
it
is
very
difficult
to
avoid
significant
yield
losses.
Nematodes
are
found
in
all
nursery
areas
in
the
U.
S.

Yellow
&
purple
nutsedge:
(
Cyperus
spp.)
Yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
Cyperus
rotundus
L.)
are
perennial
species
of
the
Cyperacea
family
that
are
widely
recognized
for
their
detrimental
economic
impact
on
agriculture.
Purple
nutsedge
is
considered
the
world's
worst
weed
due
to
its
widespread
distribution
and
the
difficulties
in
controlling
it
(
Holm
et
al.,
1977).
Purple
nutsedge
is
considered
a
weed
in
at
least
92
countries
and
is
reported
infesting
at
least
52
different
crops.
Yellow
nutsedge
is
listed
among
the
top
fifteen
worst
weeds.
Yellow
nutsedge
is
found
throughout
the
continental
U.
S.
Purple
nutsedge
is
primarily
found
in
southern
coastal
U.
S.
and
along
the
Pacific
coast
in
California
and
Oregon.
A
survey
conducted
in
Georgia
ranked
the
nutsedges
as
the
most
troublesome
weeds
in
vegetable
crops
(
there
are
more
30
vegetable
crops
grown
in
Georgia)
and
among
the
top
five
most
troublesome
weeds
in
corn,
cotton,
peanut,
and
soybean
(
Webster
et
al.,
2001).
Page
8
Nutsedge
is
propagated
by
tubers
formed
along
underground
rhizomes
and
corms.
The
parent
tuber
could
be
a
tuber
or
a
corm
from
the
previous
generation.
During
tillage
of
the
soil,
the
underground
stems
are
broken
and
new
plants
are
established
from
either
single
or
chains
of
tubers
or
corms.
A
single
plant
is
capable
of
producing
1,200
new
tubers
within
25
weeks
(
Gilreath
et
al.,
1999).
Each
tuber
is
capable
of
sprouting
several
times
(
Thullen
et
al.,
1975).
Tuber
populations
between
1,000
and
8,700
per/
m2
have
been
reported
for
purple
nutsedge
(
Gamini
et
al.,
1987).
Nutsedge
is
very
difficult
to
eradicate
once
it
is
established
because
of
dormancy
factors
in
the
tubers
and
their
ability
to
survive
an
array
of
adverse
conditions
for
long
periods
of
time.
Nutsedge
species
are
strong
competitors
with
most
vegetable
crops
for
water
and
nutrients
and
can
dramatically
reduce
crop
yields,
even
at
low
plant
densities,
if
not
controlled
effectively.

Purple
and
yellow
nutsedge
are
serious
problems
in
polyethylene
film
mulch
vegetable
production
systems.
Most
weeds
are
controlled
by
these
films,
but
nutsedges
are
able
to
penetrate
the
plastic
films
and
actively
compete
with
the
vegetable
crops,
causing
yield
losses
reported
between
41
and
89
percent
(
Patterson,
1998).

There
are
very
few
herbicides
that
provide
effective
nutsedge
control
in
high
pest
pressure
scenarios
and
none
are
registered
for
use
in
strawberry
plant
production
in
the
U.
S.
The
herbicides
that
are
available
for
these
crops
are
generally
older
chemicals
that
are
marginally
effective
against
the
spectrum
of
weeds
that
are
problematic
for
strawberry
plants.
Among
the
areas
covered
by
this
nomination
for
continued
methyl
bromide
use
in
strawberry
nurseries,
40
to
60
percent
of
the
area
in
the
southeast,
including
North
Carolina
and
Tennessee,
are
moderately
to
highly
infested
with
nutsedge.

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Methyl
bromide
has
been
recognized
as
being
a
significant
contributor
to
the
success
of
a
robust
U.
S.
strawberry
nursery
industry
by
providing
consistent
and
effective
treatment
for
target
pests.
Most
chemical
alternatives
do
not
deliver
the
deep
fumigation
control
obtained
with
methyl
bromide
and
nonchemical
alternatives
alone
are
insufficient.
Refer
to
Table
1
and
Table
2
below
for
a
complete
listing
of
the
MBTOC
alternatives.

There
has
been
extensive
research
on
alternatives
for
the
strawberry
fruit
sector,
and
some
of
the
research
is
applicable
to
the
strawberry
nursery
sector.
The
findings
have
been
incorporated
into
nursery
production
where
possible.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
preliminary.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide,
and
no
combination
has
been
shown
to
provide
effective,
economical
pest
control
to
the
level
necessitated
by
the
legal
and
market
requirements
for
nursery
stock.

1,3­
Dichloropropene
appears
to
be
an
effective
alternative
to
methyl
bromide
for
various
crops.
However,
since
1,3
dichloropropene
is
a
hazardous
air
pollutant
and
is
managed
to
prevent
groundwater
contamination,
the
California
Department
of
Pesticide
Regulation
(
CDPR)
has
set
limits
on
how
much
1,3
dichloropropene
can
be
used
in
each
township
in
California.
In
1997,
40%
of
1,3
dichloropropene
use
was
for
carrots,
with
potatoes,
including
sweet
potatoes,
being
the
next
largest
single
crop
use,
and
perennial
crops,
including
grapes,
almonds,
and
walnuts,
also
accounting
for
a
substantial
proportion
of
use
(
Carpenter
and
Lynch
1999).
As
a
result
of
the
methyl
bromide
phase­
out,
likely
crops
to
switch
to
Page
9
1,3
dichloropropene
include
strawberries,
strawberry
nurseries,
various
other
vegetable
crops,
and
perennials.
These
other
crops
will
compete
for
1,3­
dichloropropene
with
crops
that
currently
use
methyl
bromide.
Given
the
regulatory
caps
on
total
use
of
this
alternative,
which
are
applied
by
townships
(
subdivisions
of
counties)
some
growers
will
require
continued
use
of
methyl
bromide
because
they
will
be
`
closed
out'
of
use
of
the
1,3
dichloropropene.
Timing
of
use
is
also
an
issue
with
caps.
If
the
caps
are
exceeded
early
in
the
year,
when
most
crops
are
planted,
there
will
be
no
more
1,3­
dichloropropene
allocation
available
for
growers
who
want
to
use
it
later.

We
begin
our
technical
and
economic
assessment
by
presenting
in­
kind
(
chemical)
alternatives,
and
then
describe
the
attributes
of
the
not­
in­
kind
alternatives.

6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Table
.
In­
Kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Strawberry
Nurseries.
Methyl
Bromide
Alternatives
Technically
Feasible
Economically
Feasible
1,3­
dichloropropene/
chloropicrin
No
No
1,3­
dichloropropene/
chloropicrin/
Metam­
sodium
No
No
1,3­
dichloropropene/
Metam­
sodium
No
No
1,3­
Dichloropropene/
chloropicrin
General
Issues:
The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
not
technically
feasible
because
it
does
not
adequately
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3
Dichloropropene
provides
good
nematode
control,
only
moderate
disease
control,
and
poor
weed
control.
A
90
meter
(
300
feet)
buffer
requirement
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas,
which
is
particular
concern
for
the
southeastern
U.
S.
Personal
Protective
Equipment
(
PPE)
requirements
also
limit
operations
that
require
workers
in
the
field,
particularly
given
the
high
temperatures
which
occur
both
in
California
and
the
southeast,
exacerbated
by
high
humidity
in
the
southeast.
Workers
wearing
the
required
Personal
Protective
Equipment
become
at
risk
for
possible
heat
exhaustion
or
heat
stroke.
For
example,
PPE
may
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
are
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity,
rapidly
become
unbearable
for
a
typical
applicator.
Growers
believe
that
the
requirements
for
buffers
and
PPE
may
make
it
impractical
to
adopt
1,3­
dichloropropene.
The
buffer
requirements,
especially
for
the
small
farms
in
the
Eastern
U.
S.,
eliminate
so
much
area
around
the
perimeter
of
a
field
that
there
is
very
little
left
that
can
be
treated
using
1,3­
dichloropropene
alone
to
grow
strawberries.
Chloropicrin
provides
good
disease
control,
but
poor
nematode
and
weed
control.
Workers
complain
about
eye
and
lung
irritation
when
applying
chloropicrin.

Chloropicrin
has
been
determined
to
be
a
toxic
air
contaminant
by
California's
Department
of
Pesticide
Regulation.
This
compound
may
be
subject
to
future
regulatory
constraints,
including
increased
buffer
zones.
Effective
rates
for
chloropicrin
of
225
kg/
ha
(
200
pounds
per
acre)
or
greater
are
prohibited
or
strongly
discouraged
for
both
shank
and
drip
applications
of
this
product.
Products
containing
chloropicrin
cannot
be
applied
through
PVC
pipe
because
of
the
corrosive
Page
10
nature
of
this
chemical.
Workers
have
also
expressed
concerns
about
eye
and
lung
irritation
when
applying
chloropicrin.

If
sequential
application
of
these
two
chemicals
is
used,
as
opposed
to
applying
both
at
the
same
time,
more
time
is
required
than
using
methyl
bromide
alone
since
growers
must
wait
longer
after
soil
fumigation
to
set
the
root
stock
in
the
ground.
Growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
Integrated
Pest
Management
practices,
timing
of
planting
and
harvest
for
strawberry
fruit
production,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.

California:
The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
not
technically
feasible
because
it
does
not
adequately
control
nematodes
to
the
level
required
by
state
law
and
results
in
yield
losses
in
nursery
plants.
Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematode
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640).
Additionally,
there
are
specific
soil
treatment
and
handling
procedures
to
facilitate
compliance
with
the
regulations
for
the
Nursery
Stock
Nematode
Control
Program.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
and
"
commercially
clean
with
respect
to
established
pests
of
general
distribution."

The
yield
loss
estimate
for
the
1,3­
dichloropropene
and
chloropicrin
combination
is
approximately
9
percent
which
is
based
on
data
presented
in
peer
reviewed
scientific
publications.
Findings
from
California
nurseries
reveal
losses
of
9
percent
of
the
nursery
stock
with
a
high
proportion
of
chloropicrin
(
30/
70,
1,3­
dichloropropene/
chloropicrin).
With
a
low
proportion
of
chloropicrin
(
70/
30,
1,3­
dichloropropene/
chloropicrin),
the
yield
loss
was
16
percent
of
the
nursery
stock.
The
degree
of
yield
reduction
with
alternative
fumigants
depends
on
the
production
scenario.
Less
runner
production,
less
vigorous
plants,
and
phytotoxicity
can
also
cause
a
loss
in
fruit
production.
Amplification
of
pest
problems
that
occur
in
nurseries
is
highly
likely.
Complete
crop
loss
can
occur
if
the
nursery
stock
cannot
be
certified
as
nematode
free.

Southeast:
The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
not
technically
feasible
because
it
does
not
adequately
control
pests
to
the
level
required
by
state
law
and,
because
areas
with
high
infestations
of
nutsedge
will
not
be
adequately
controlled.
Tennessee
state
regulations
say
that,
"
No
strawberry
plants
shall
be
sold,
offered,
stored,
or
held
for
sale,
or
transported
within
or
into
the
State
of
Tennessee
unless
they
have
been
certified
as
being
essentially
free
of
insect
pests
and
plant
diseases
by
a
legally
constituted
agency
designated
for
such
purpose
in
the
states,
other
states,
territories,
or
counties."

Similarly
in
North
Carolina,
state
regulations
mandate
that
"
No
person
shall
distribute,
sell
or
offer
for
sale
nursery
stock
or
collected
plants
without
a
valid
nursery
dealer
certificate,
plant
inspection
certificate,
or
nursery
registration
certificate
as
required
in
these
rules."
A
plant
inspection
certificate
is
"
a
document
issued
by
the
North
Carolina
Department
of
Agriculture
or
the
appropriate
Page
11
plant
pest
regulatory
agency
of
any
other
state
which
declares
that
the
plants
grown
by
the
person
named
on
the
certificate
have
been
inspected
and
found
apparently
free
of
injurious
plant
pests.
"

The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
being
used
on
a
limited
basis
in
the
Southeast,
but
its
usefulness
is
limited
due
to
the
juxtapostion
of
the
small
size
of
the
nursery
operations
and
the
300
ft
buffer
requirements.
The
estimates
for
Southeastern
strawberry
nurseries
yield
losses
range
from
0
percent
to
20
percent.
The
yield
loss
estimate
calculated
based
on
data
presented
in
production
field
trials
is
5
percent.
The
most
likely
estimate
of
expected
yield
loss
associated
with
1,3­
dichloropropene
and
chloropicrin
in
the
southeast
is
approximately
10
percent,
but
could
go
as
high
as
60
percent
if
there
are
low
levels
of
phytotoxicity
from
chloropicrin
(
some
studies
show
that
chloropicrin
can
cause
high
levels
of
phytotoxicity).
Since
1,3­
dichloropropene
dissipates
more
slowly
than
methyl
bromide
(
about
3
weeks
verses
1­
2
weeks),
there
are
increased
risks
associated
with
weather
related
delays
in
planting
which
may
result
in
a
less
robust
plant.

When
1,3­
dichloropropene
is
used
in
combination
with
chloropicrin,
Southeast
growers
can
experience
limited
flexibility
in
scheduling
fumigation
operations
due
to
the
higher
required
soil
temperatures
for
this
combination
to
be
used.
Delays
in
soil
fumigation
for
the
root
stock
could
force
growers
to
set
all
of
their
transplants
out
at
one
time
instead
of
spacing
out
the
plantings
so
that
they
don't
have
to
harvest
all
the
berries
at
one
time.
This
could
also
eliminate
the
planting
and
harvest
of
early
cultivars,
which
are
often
the
cultivars
of
great
demand
and
high
value
in
the
strawberry
market.
Also,
delays
in
planting
often
decrease
the
yield
and
quality
of
the
fruit
In
the
instances
where
weeds
are
a
problem
(
in
the
southeast
nutsedge
is
of
particular
concern),
this
chemical
combination
would
require
an
effective
herbicide
to
adequately
control
the
problems.
This
combination
of
chemicals
would
require
a
herbicide
companion
or
hand
weeding
at
great
expense,
approximately
US$
1,250
per
hectare
(
US$
500
per
acre).
Hand
weeding
is
not
a
desirable
practice
for
controlling
nutsedge.
The
process
of
hand
weeding
will
remove
nutsedge
plants
on
the
surface
but
results
in
releasing
the
below
ground
tubers
from
dormancy
and
resulting
in
their
growth.
Since
nutsedge
plants
can
have
10
to
30
tubers
per
plant
this
cascading
effect
results
in
a
10
to
30
fold
increase
in
nutsedge
plants
in
the
field.
There
are
no
herbicides
registered
or
currently
undergoing
testing
in
the
U.
S.
for
control
of
nutsedge
in
strawberries.

1,3­
Dichloropropene/
chloropicrin/
metam
sodium
General
Issues:
The
combination
of
1,3­
dichloropropene,
chloropicrin
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3­
Dichloropropene
is
a
good
nematicide
and
chloropicrin
is
a
good
fungicide.
Metam
sodium
provides
moderate
but
unpredictable
disease,
nematode,
and
weed
control
since
it
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
Metam
sodium
degrades
in
the
soil
to
form
methylisothiocyanate,
which
has
activity
against
nematodes,
fungi,
insects,
and
weeds.
Methyl
bromide
has
a
higher
vapor
pressure
than
metam
sodium,
therefore
can
penetrate
and
diffuse
throughout
the
soil
more
effectively
than
metam
sodium.
In
addition,
the
effectiveness
of
metam
sodium
is
very
dependent
on
the
organic
matter
and
moisture
content
of
the
soil.
Studies
to
evaluate
best
delivery
systems
for
metam
sodium
are
being
conducted.
Some
studies
have
shown
that
soil
injections
and
drenches
are
more
effective
than
drip
irrigation.
Research
trials
show
that
Page
12
incorporation
of
metam
sodium
with
a
tractor­
mounted
tillovator
provides
good
results
but
most
growers
do
not
have
this
equipment.
A
3­
week
time
interval
before
planting
is
recommended
to
avoid
phytotoxic
levels;
causing
delays/
adjustments
in
production
schedules
that
could
lead
to
missing
specific
market
windows,
thus
reducing
profit
or
actually
causing
a
loss
for
a
grower.

The
combination
of
the
three
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
full
spectrum
of
weeds
could
most
lead
to
increased
disease
pressure
over
time
because
the
weeds
can
be
reservoirs
for
disease
or
act
as
harborage
for
insect
vectors
of
disease.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.

As
with
the
1,3­
dichloropropene/
chloropicrin
combination
(
above)
there
are
issues
with
the
use
of
Personal
Protective
Equipment
(
PPE)
in
the
hot
or
hot
and
humid
climates
of
California
and
the
southeastern
U.
S.
In
addition,
the
buffer
requirement
of
90
meters
(
300
feet)
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas.
For
small
strawberry
nursery
operations
in
the
southeastern
U.
S.,
the
1,3­
dichloropropene
buffer
requirements
eliminate
a
a
large
area
around
the
field
perimeter
which
impacts
the
total
area
available
for
strawberry
nursery
production.

Chloropicrin
has
been
determined
to
be
a
toxic
air
contaminant
by
California's
Department
of
Pesticide
Regulation.
This
compound
may
be
subject
to
future
regulatory
constraints,
including
increased
buffer
zones.
Effective
rates
for
chloropicrin
of
225
kg/
ha
(
200
pounds
per
acre)
or
greater
are
prohibited
or
strongly
discouraged
for
both
shank
and
drip
applications
of
this
product.
Products
containing
chloropicrin
cannot
be
applied
through
PVC
pipe
because
of
the
corrosive
nature
of
this
chemical.
Workers
have
also
expressed
concerns
about
eye
and
lung
irritation
when
applying
chloropicrin.

Sequential
application
of
each
one
of
these
chemicals
requires
significantly
more
time
than
using
methyl
bromide
alone
since
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
root
stock
in
the
ground.
Growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
Integrated
Pest
Management
practices,
timing
of
planting
and
harvest
for
strawberry
fruit
production,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
Since
growers
will
require
rootstock
at
a
fixed
time
during
the
year,
the
nursery
plants
could
be
of
lower
grade
and
quality
(
smaller)
causing
loss
to
both
the
nursery
grower
and
the
fruit
grower.

California:
The
combination
of
1,3­
dichoropropene,
chloropicrin
and
metam
sodium
is
not
a
technically
feasible
alternative
because
complete
crop
loss
can
occur
if
the
nursery
stock
cannot
be
certified
as
nematode
free.
Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematode
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640).
Page
13
Southeast:
The
combination
of
1,3­
dichloropropene,
chloropicrin
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
to
the
level
required
by
state
law.
Tennessee
state
regulations
say
that,
"
No
strawberry
plants
shall
be
sold,
offered,
stored,
or
held
for
sale,
or
transported
within
or
into
the
State
of
Tennessee
unless
they
have
been
certified
as
being
essentially
free
of
insect
pests
and
plant
diseases
by
a
legally
constituted
agency
designated
for
such
purpose
in
the
states,
other
states,
territories,
or
counties."

Similarly
in
North
Carolina,
state
regulations
mandate
that
"
No
person
shall
distribute,
sell
or
offer
for
sale
nursery
stock
or
collected
plants
without
a
valid
nursery
dealer
certificate,
plant
inspection
certificate,
or
nursery
registration
certificate
as
required
in
these
rules."
A
plant
inspection
certificate
is
"
a
document
issued
by
the
North
Carolina
Department
of
Agriculture
or
the
appropriate
plant
pest
regulatory
agency
of
any
other
state
which
declares
that
the
plants
grown
by
the
person
named
on
the
certificate
have
been
inspected
and
found
apparently
free
of
injurious
plant
pests.
"

In
the
instances
where
weeds
are
a
problem
(
in
the
southeast
nutsedge
is
of
particular
concern),
this
chemical
three
way
combination
still
not
provide
effective
control
of
nutsedge.
This
combination
of
chemicals
would
require
a
herbicide
companion
or
hand
weeding
at
great
expense,
approximately
US
$
1,250
per
hectare
(
US$
500
per
acre).
Hand
weeding
is
not
a
desirable
practice
for
controlling
nutsedge.
The
process
of
hand
weeding
will
remove
nutsedge
plants
on
the
surface
but
results
in
releasing
the
below
ground
tubers
from
dormancy
and
resulting
in
their
growth.
Since
nutsedge
plants
can
have
10
to
30
tubers
per
plant
this
cascading
effect
results
in
a
10
to
30
fold
increase
in
nutsedge
plants
in
the
field.
There
are
no
herbicides
registered
or
currently
undergoing
testing
in
the
U.
S.
for
control
of
nutsedge
in
strawberries.

1,3­
Dichloropropene/
Metam­
Sodium.

General
Issues:
The
combination
of
1,3­
dichloropropene
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
and
diseases
to
the
level
required
by
various
state
laws,
and
results
in
yield
losses
in
nursery
plants.
1,3­
Dichloropropene
is
a
good
nematicide
and
metam
sodium
provides
moderate
but
unpredictable
disease,
nematode,
and
weed
control.
As
indicated
above,
metam
also
suffers
from
erratic
efficacy,
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
The
combination
of
these
chemicals
would
still
require
a
companion
herbicide
or
hand
weeding.
Failure
to
control
the
weed
seed
in
soil
would
most
likely
lead
to
increased
disease
pressure
over
time.
Also,
in
strawberry
fruit
production,
there
is
demand
for
pest
free
strawberry
root
stock.
The
nursery
growers
who
do
not
supply
this
type
of
product
will
be
forced
out
of
the
market.

As
with
the
other
suggested
combinations
(
above)
there
are
issues
with
the
use
of
Personal
Protective
Equipment
(
PPE)
in
the
hot
or
hot
and
humid
climates
of
California
and
the
southeastern
U.
S.
In
addition,
the
buffer
requirement
of
90
meters
(
300
feet)
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas.
For
small
strawberry
nursery
operations
in
the
southeastern
U.
S.,
the
1,3­
dichloropropene
buffer
requirements
eliminate
a
a
large
area
around
the
field
perimeter
which
impacts
the
total
area
available
for
strawberry
nursery
production.
Sequential
application
of
each
one
of
these
chemicals
requires
significantly
more
time
than
using
methyl
bromide
alone
since
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
root
Page
14
stock
in
the
ground.
Growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
Integrated
Pest
Management
practices,
timing
of
planting
and
harvest
for
strawberry
fruit
production,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
Since
growers
will
require
rootstock
at
a
fixed
time
during
the
year,
the
nursery
plants
could
be
of
lower
grade
and
quality
(
smaller)
causing
loss
to
both
the
nursery
grower
and
the
fruit
grower.

California:
The
combination
of
1,3­
dichloropropene
and
metam
sodium
is
not
a
technically
feasible
alternative
because
complete
crop
loss
can
occur
if
the
nursery
stock
cannot
be
certified
as
nematode
free.
Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematode
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640).

Southeast:
The
combination
of
1,3­
dichloropropene
and
metam
sodium
is
not
technically
feasible
because
it
does
not
adequately
control
pests
to
the
level
required
by
state
law.
Tennessee
state
regulations
say
that,
"
No
strawberry
plants
shall
be
sold,
offered,
stored,
or
held
for
sale,
or
transported
within
or
into
the
State
of
Tennessee
unless
they
have
been
certified
as
being
essentially
free
of
insect
pests
and
plant
diseases
by
a
legally
consituted
ageny
designated
for
such
purpose
in
the
states,
other
states,
territories,
or
counties."

Similarly
in
North
Carolina,
state
regulations
mandate
that
"
No
person
shall
distibute,
sell
or
offer
for
sale
nursery
stock
or
collected
plants
without
a
valid
nursery
dealer
certificate,
plant
inspection
certificate,
or
nursery
registration
certificate
as
required
in
these
rules."
A
plant
inspection
certificate
is
"
a
document
issued
by
the
North
Carolina
Department
of
Agriculture
or
the
appropriate
plant
pest
regulatory
agency
of
any
other
state
which
declares
that
the
plants
grown
by
the
person
named
on
the
certificate
have
been
inspected
and
found
apparently
free
of
injurious
plant
pests.
"

6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
None
of
the
alternatives
listed
by
MBTOC
and
reviewed
above
were
found
to
be
technically
feasible
for
strawberry
nurseries
therefore
no
economic
analysis
was
conducted.

As
discussed
above,
this
critical
use
exemption
nomination
is
based
primarily
on
the
need
to
provide
pest­
free
root
stock
to
have
healthy
and
vigorous
producing
stock
and
to
avoid
introducing
pest
species
into
areas
where
they
are
not
already
common,
although
the
need
to
control
the
above
mentioned
pests
is
also
important.
Research
findings
submitted
by
applicants
indicate
that
when
strawberry
nursery
stock
that
has
not
been
treated
with
methyl
bromide
is
used
to
produce
strawberry
fruit,
fruit
production
is
7.5
percent
lower
that
if
methyl
bromide­
treated
stock
is
used.
This
result
is
independent
of
the
pesticide
regimen
used
during
field
production
of
strawberry
fruit.
In
addition,
requirements
that
nursery
stock
have
non­
detectable
levels
of
pests,
and
the
associated
costs
and
risk
imposed
by
the
certification
requirements,
mean
that
there
is
no
feasible
alternative
to
methyl
bromide
in
practice.
It
is
often
the
case
with
certification
programs
that
if
one
uses
methyl
bromide,
one
is
assumed
to
have
met
the
pest­
free
standard,
but
if
an
alternative
is
used
one
must
prove
that
the
standard
has
been
met.
Proof
requires
testing,
which
has
costs,
and
carries
with
it
the
Page
15
risk
that
the
standard
has
not
met
which
will
require
destruction
of
the
entire
shipment
of
nursery
stock.

6e.
Technical
Feasibility
of
Not­
In­
Kind
(
Non­
Chemical)
Alternatives
This
section
summarizes
the
analysis
of
the
remainder
of
the
methyl
bromide
alternatives
identified
by
MBTOC
for
strawberry
nursery
production,
primarily
non­
chemical
alternatives.
Table
2
contains
a
summary
of
the
technical
assessment,
which
is
that
none
of
these
alternatives
were
found
to
be
technically
feasible.
Because
no
alternative
was
found
to
be
technically
feasible
no
economic
assessment
was
conducted.
A
description
of
each
alternative
follows.

Table
.
Not­
in­
Kind
Methyl
Bromide
Alternatives
Identified
by
the
MBTOC
for
Strawberry
Nursery
Production.
Methyl
Bromide
Alternative
Technically
Feasible
Economically
Feasible
Crop
rotation/
fallow
No
No
General
IPM
(
Integrated
Pest
Management)
No
No
Biofumigation
No
No
Solarization
No
No
Soilless
culture
No
No
Substrates/
plug
plants
No
No
Crop
Rotation/
Fallow.
Crop
rotation/
fallow
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
when
used
alone
to
control
target
pests.
In
the
U.
S.,
is
it
common
for
nursery
growers
to
rotate
strawberries
with
other
non­
host
crops
to
provide
non­
host
periods
of
production.
In
California,
crop
rotation
serves
as
an
effective
pest
management
technique
that
helps
keep
per
hectare
strawberry
productivity
50%
higher
than
that
of
the
national
average
yield.
In
the
Southeast
where
production
areas
per
grower
is
small,
rotation
does
not
always
work
since
easy
access
to
fields,
and
more
importantly,
visibility
of
the
fields
from
passing
cars
is
especially
important
for
U­
pick
operations.

Crop
rotation/
fallow
are
not
technically
feasible
alternatives
because
they
do
not
control
nutsedge.
Crop
rotation
and
fallow
are
effective
tool
for
management
of
weeds,
diseases
and
nematodes,
especially
as
part
of
an
IPM
program.
However,
these
practices
may
be
difficult
for
growers
of
high­
value
crops;
especially
in
areas
were
land
is
a
limited
and
expensive
resource.
Agronomic
crops
are
more
effective
competitors
than
vegetable
crops
and
planting
dates
are
difficult
to
adjust
for
vegetable
crops
due
to
marketing
factors.
There
are
registered
herbicides
that
are
effective
for
nutsedge
control
in
agronomic
crops.
These
herbicides
are
not
available
for
most
fruit
or
vegetable
crops,
and
many
of
them
have
12­
to
26­
month
carryover
restrictions
for
vegetable
crops.

Crop
rotation
and
fallow
will
not
suppress
nutsedge.
Johnson
&
Mullinix
(
1997)
showed
that
uninterrupted
plantings
of
peanut,
corn,
or
cotton,
with
moderate
levels
of
weed
management
suppressed
yellow
nutsedge
in
Georgia.
Their
data
also
showed
an
increase
in
nutsedge
densities
in
fallow
plots,
likely
due
to
the
longevity
of
nutsedge
tubers
in
soil,
mild
winters
that
prevent
winter­
kill
of
tubers,
and
the
ability
of
tubers
to
regenerate
with
the
long
growing
season
in
the
southeastern
Page
16
coastal
plain.
There
are
also
reports
of
increasing
populations
of
yellow
nutsedge
in
fallowed
fields,
even
when
weed
control/
management
is
performed.
Since
there
are
no
herbicides
registered
for
use
on
strawberry
plants
that
will
effectively
control
nutsedge,
management
of
these
weeds
during
short­
term
rotations
and
fallow
is
not
effective.

General
IPM
(
Integrated
Pest
Management).
IPM,
the
use
of
pest
monitoring
activities
coupled
with
chemical
and
non­
chemical
management
tools,
has
been
adopted
for
management
of
weed,
diseases,
and
nematodes
on
solanaceous
crops.
However,
problematic
weeds
like
nutsedge
and
nightshade,
and
soilborne
diseases
and
nematodes
are
not
effectively
controlled
by
these
practices.

General
IPM
is
being
used
in
strawberry
nursery
stock
production,
but
it
is
not
technically
feasible
alone
to
provide
adequate
pest
control.
IPM
practices
include
field
sanitation
to
limit
inoculum
buildup,
crop
rotation
to
provide
non
host
periods,
and
breeding
for
resistance
to
pathogens.

Biofumigation.
Biofumigation
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
target
pests
to
produce
a
certifiable
strawberry
nursery
stock.
Research
conducted
in
Florida
showed
some
control
of
plant
pathogens
but
no
control
of
nematodes
or
weeds
in
the
soil.
In
cases
where
biofumigation
have
been
shown
to
control
weeds,
the
data
are
mostly
for
small­
seeded
weed
species
that
have
small
carbohydrate
energy
sources
compared
to
nutsedge.
The
data
on
biofumigation
are
too
limited
to
consider
it
as
a
practical
alternative
to
methyl
bromide.

In
addition,
biofumigation
is
not
technically
feasible
because
the
quantity
of
Brassica
crop
needed
to
control
target
pests
would
be
approximately
3
hectares
for
every
hectare
of
strawberry
production.
Incorporation
of
Brassica
at
these
levels
are
likely
to
have
allelopathic
effects
on
the
target
crop.
In
the
Southeast,
production
field
trials
with
cabbage
residue
and
tomato
produced
inconsistent
and
inadequate
efficacy,
and
poor
yields
in
two
years
out
of
three.
The
yield
losses
could
range
from
0%
­
50%.

Solarization.
Solarization
is
not
a
technically
feasible
alternative
because
it
does
not
provide
adequate
control
of
target
pests
to
produce
certifiable
strawberry
nursery
stock.
Use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed,
nematodes,
and
disease
organisms.
The
time
for
solarization
to
raise
soil
temperatures
to
the
level
needed
to
kill
soil
pathogens
in
any
strawberry
nursery
region
is
likely
to
also
be
the
time
when
the
crops
themselves
must
complete
their
growth
cycle.
Unpredictable,
stormy
summer
weather
still
creates
risks
and
may
damage
mulch.
In
one
Southeast
field
trial,
solarization
gave
poor
yields
in
two
years
out
of
three
with
a
loss
ranging
from
0%
to
40%.

Cover
crops/
Mulching.
Cover
crops/
mulching
is
currently
being
used
but
it
is
not
technically
feasible
as
a
complete
replacement
for
methyl
bromide
to
control
the
target
pest
and
certify
the
nursery
stock.
The
use
of
cover
crops
is
a
common
practice
to
improve
soil
structure
and
suppress
an
array
of
soilborne
pathogens.
Cover
crops
and
mulches
have
been
integrated
to
solanaceous
crop
production
management.

Some
cover
crops
that
have
been
shown
to
reduce
weed
populations
also
reduced
or
delayed
crop
maturity
and/
or
emergence,
as
well
as
yields
(
Burgos
et
al.,
1996;
Galloway
et
al.,
1996).
Cowpea
and
sunn
hemp
have
been
shown
to
suppress
nutsedge,
but
the
effect
is
short
lived,
due
to
the
weed's
Page
17
capacity
for
rapid
tuber
production.
Allelochemicals
released
by
some
cover
crops
or
organic
mulches
can
injure
crops
(
Johnson
et
al.,
1993;
Norsworthy,
2002).

Soilless
Culture.
Soilless
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
According
to
data
provided
by
The
National
Center
for
Food
and
Agricultural
Policy,
a
greenhouse
typically
costs
between
US$
12.5
million
and
US$
20
million
per
hectare.
Although
yields
obtained
through
greenhouse
production
are
higher
than
that
of
California's
best
conventional
growers,
the
issue
of
capitalization
for
this
and
other
Sectors
make
the
alternative
not
practically
feasible
as
a
near
term
strategy
to
reduce
reliance
on
methyl
bromide.

Substrates/
plug
plants.
Substrates/
plug
plants
are
currently
being
produced
and
sold
in
the
southeast
and
to
a
very
limited
extent
in
California
but
this
method
alone
does
not
provide
pest
control
and
would
fail
to
produce
a
pest
free
product.
Furthermore,
this
method
would
require
extensive
retooling
by
the
nursery
industry.

7.
Critical
Use
Exemption
Nomination
for
Strawberry
Nurseries
The
critical
use
exemption
nomination
for
the
strawberry
nursery
sector
were
submitted
by
consortia
representing
nurseries
in
two
different
regions
in
the
U.
S.:
California
and
the
southeastern
United
States
(
North
Carolina
and
Tennessee).

The
actual
amount
requested
by
for
California
strawberry
nurseries
for
the
years
2005,
2006
and
2007
on
a
total
of
1,295
hectares
is
in
Table
3.
The
application
rates
conform
to
standard
nursery
practices
in
this
region.

Table
3.
Methyl
Bromide
Usage
and
Request
for
Strawberry
Nurseries
in
California:
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
308,860
313,200
341,230
337,604
341,022
358,400
358,400
358,400
hectares
1,128
1,153
1,267
1,283
1,295
1,360
1,360
1,360
rate
(
kg/
ha)
274
272
269
263
263
264
264
264
It
appears
that
the
application
rate
in
California
may
be
declining
which
would
be
consistent
with
the
fact
that
the
applicant
has
changed
their
formulation
of
methyl
bromide
from
a
98/
2
formulation
with
proportions
of
methyl
bromide/
chloropicrin
to
a
formulation
with
67/
33
of
methyl
bromide/
chloropicrin.

The
actual
amount
requested
by
strawberry
nurseries
in
the
southeastern
for
the
years
2005,
2006,
and
2007
on
behalf
of
growers
in
North
Carolina
and
Tennessee
on
a
total
of
63
hectares
is
in
Table
4.
Application
rates
appear
to
be
declining
in
the
North
Carolina
and
Tennessee
as
well.
Page
18
Table
4.
Methyl
Bromide
Usage
and
Request
for
Strawberry
Nurseries
in
North
Carolina
and
Tennessee:
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
18,136
18,136
12,400
15,438
18,960
22,610
18,960
18,960
hectares
41
41
41
51
63
83
63
63
rate
(
kg/
ha)
439
439
300
300
300
271
300
300
The
total
U.
S.
nomination
has
been
determined
based
first
on
consideration
of
the
requests
we
received
and
an
evaluation
of
the
supporting
material.
This
evaluation,
which
resulted
in
a
reduction
in
the
amount
being
nominated,
included
careful
examination
of
issues.
These
issues
included:
proportion
of
the
growing
area
infested
with
the
key
target
(
economically
significant)
pests
for
which
methyl
bromide
is
required;
the
extent
of
regulatory
constraints
on
the
use
of
registered
alternatives
(
buffer
zones,
township
caps);
environmental
concerns
(
such
as
soil
based
restrictions
due
to
potential
drinking
water
contamination);
and,
historic
use
rates,
among
other
factors.

Table
5.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Strawberry
Nurseries.
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
380,948
54,988
8.
Minimizing
Use/
Emissions
of
Methyl
Bromide
in
the
United
States/
Stockpiles
In
accordance
with
the
criteria
of
the
critical
use
exemption,
we
will
now
describe
ways
in
which
we
strive
to
minimize
use
and
emissions
of
methyl
bromide.
While
each
sector
based
nomination
includes
information
on
this
topic,
we
thought
it
would
be
useful
to
provide
some
general
information
that
is
applicable
to
most
methyl
bromide
uses
in
the
country
The
use
of
methyl
bromide
in
the
United
States
is
minimized
in
several
ways.
First,
because
of
its
toxicity,
methyl
bromide
is
regulated
as
a
restricted
use
pesticide
in
the
United
States.
As
a
consequence,
methyl
bromide
can
only
be
used
by
certified
applicators
who
are
trained
at
handling
these
hazardous
pesticides.
In
practice,
this
means
that
methyl
bromide
is
applied
by
a
limited
number
of
very
experienced
applicators
with
the
knowledge
and
expertise
to
minimize
dosage
to
the
lowest
level
possible
to
achieve
the
needed
results.
In
keeping
with
both
local
requirements
to
avoid
"
drift"
of
methyl
bromide
into
inhabited
areas,
as
well
as
to
preserve
methyl
bromide
and
keep
related
emissions
to
the
lowest
level
possible,
methyl
bromide
is
machine
injected
into
soil
to
specific
depths.
In
addition,
as
methyl
bromide
has
become
more
scarce,
users
in
the
United
States
have,
where
possible,
experimented
with
different
mixes
of
methyl
bromide
and
chloropicrin.
Specifically,
in
the
early
1990s,
methyl
bromide
was
typically
sold
and
used
in
methyl
bromide
mixtures
made
up
of
98%
methyl
bromide
and
2%
chloropicrin,
with
the
chloropicrin
being
included
solely
to
give
the
chemical
a
smell
enabling
those
in
the
area
to
be
alerted
if
there
was
a
risk.
However,
with
the
outset
of
very
significant
controls
on
methyl
bromide,
users
have
been
experimenting
with
significant
increases
in
the
level
of
chloropicrin
and
reductions
in
the
level
of
methyl
bromide.
While
these
new
mixtures
have
generally
been
effective
at
controlling
target
pests,
it
must
be
stressed
that
the
long
term
efficacy
of
these
mixtures
is
unknown.
Reduced
methyl
bromide
concentrations
in
mixtures,
more
mechanized
soil
injection
techniques,
and
the
extensive
use
of
tarps
to
cover
land
treated
with
methyl
bromide
has
resulted
in
reduced
emissions
and
an
application
rate
that
we
believe
is
among
the
lowest
in
the
world.
Page
19
In
terms
of
compliance,
in
general,
the
United
States
has
used
a
combination
of
tight
production
and
import
controls,
and
the
related
market
impacts
to
ensure
compliance
with
the
Protocol
requirements
on
methyl
bromide.
Indeed,
over
the
last
 
years,
the
price
of
methyl
bromide
has
increased
substantially.
As
Chart
1
in
Appendix
D
demonstrates,
the
application
of
these
policies
has
led
to
a
more
rapid
U.
S.
phasedown
in
methyl
bromide
consumption
than
required
under
the
Protocol.
This
accelerated
phasedown
on
the
consumption
side
may
also
have
enabled
methyl
bromide
production
to
be
stockpiled
to
some
extent
to
help
mitigate
the
potentially
significant
impacts
associated
with
the
Protocol's
2003
and
2004
70%
reduction.
We
are
currently
uncertain
as
to
the
exact
quantity
of
existing
stocks
going
into
the
2003
season
that
may
be
stockpiled
in
the
U.
S.
We
currently
believe
that
the
limited
existing
stocks
are
likely
to
be
depleted
during
2003
and
2004.
This
factor
is
reflected
in
our
requests
for
2005
and
beyond.

At
the
same
time
we
have
made
efforts
to
reduce
emissions
and
use
of
methyl
bromide,
we
have
also
made
strong
efforts
to
find
alternatives
to
methyl
bromide.
The
section
that
follows
discusses
those
efforts.

9.
U.
S.
Efforts
to
Find,
Register
and
Commercialize
Alternatives
to
Methyl
Bromide
Over
the
past
ten
years,
the
United
States
has
committed
significant
financial
and
technical
resources
to
the
goal
of
seeking
alternatives
to
methyl
bromide
that
are
technically
and
economically
feasible
to
provide
pest
protection
for
a
wide
variety
of
crops,
soils,
and
pests,
while
also
being
acceptable
in
terms
of
human
health
and
environmental
impacts.
The
U.
S.
pesticide
registration
program
has
established
a
rigorous
process
to
ensure
that
pesticides
registered
for
use
in
the
United
States
do
no
present
an
unreasonable
risk
of
health
or
environmental
harm.
Within
the
program,
we
have
given
the
highest
priority
to
rapidly
reviewing
methyl
bromide
alternatives,
while
maintaining
our
high
domestic
standard
of
environmental
protection.
A
number
of
alternatives
have
already
been
registered
for
use,
and
several
additional
promising
alternatives
are
under
review
at
this
time.
Our
research
efforts
to
find
new
alternatives
to
methyl
bromide
and
move
them
quickly
toward
registration
and
commercialization
have
allowed
us
to
make
great
progress
over
the
last
decade
in
phasing
out
many
uses
of
methyl
bromide.
However,
these
efforts
have
not
provided
effective
alternatives
for
all
crops,
soil
types
and
pest
pressures,
and
we
have
accordingly
submitted
a
critical
use
nomination
to
address
these
limited
additional
needs.

Research
Program
When
the
United
Nations,
in
1992,
identified
methyl
bromide
as
a
chemical
that
contributes
to
the
depletion
of
the
ozone
layer
and
the
Clean
Air
Act
committed
the
U.
S.
to
phase
out
the
use
of
methyl
bromide,
the
U.
S.
Department
of
Agriculture
(
USDA)
initiated
a
research
program
to
find
viable
alternatives.
Finding
alternatives
for
agricultural
uses
is
extremely
complicated
compared
to
replacements
for
other,
industrially
used
ozone
depleting
substances
because
many
factors
affect
the
efficacy
such
as:
crop,
climate,
soil
type,
and
target
pests,
which
change
from
region
to
region
and
even
among
localities
within
a
region.
Page
20
Through
2002,
the
USDA
Agricultural
Research
Service
(
ARS)
alone
has
spent
US$
135.5
million
to
implement
an
aggressive
research
program
to
find
alternatives
to
methyl
bromide
(
see
Table
below).
Through
the
Cooperative
Research,
Education
and
Extension
Service,
USDA
has
provided
an
additional
$
11.4m
since
1993
to
state
universities
for
alternatives
research
and
outreach.
This
federally
supported
research
is
a
supplement
to
extensive
sector
specific
private
sector
efforts,
and
that
all
of
this
research
is
very
well
considered.
Specifically,
the
phaseout
challenges
brought
together
agricultural
and
forestry
leaders
from
private
industry,
academia,
state
governments,
and
the
federal
government
to
assess
the
problem,
formulate
priorities,
and
implement
research
directed
at
providing
solutions
under
the
USDA's
Methyl
Bromide
Alternatives
program.
The
ARS
within
USDA
has
22
national
programs,
one
of
which
is
the
Methyl
Bromide
Alternatives
program
(
Select
Methyl
Bromide
Alternatives
at
this
web
site:
http://
www.
nps.
ars.
usda.
gov
).
The
resulting
research
program
has
taken
into
account
these
inputs,
as
well
as
the
extensive
private
sector
research
and
trial
demonstrations
of
alternatives
to
methyl
bromide.
While
research
has
been
undertaken
in
all
sectors,
federal
government
efforts
have
been
based
on
the
input
of
experts
as
well
as
the
fact
that
nearly
80
percent
of
preplant
methyl
bromide
soil
fumigation
is
used
in
a
limited
number
of
crops.
Accordingly,
much
of
the
federal
government
pre­
plant
efforts
have
focused
on
strawberries,
tomatoes,
ornamentals,
peppers
and
nursery
crops,
(
forest,
ornamental,
strawberry,
pepper,
tree,
and
vine),
with
special
emphasis
on
tomatoes
in
Florida
and
strawberries
in
California
as
model
crops.

Table
6.
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Million
(
US$)
1993
$
7.255
1994
$
8.453
1995
$
13.139
1996
$
13.702
1997
$
14.580
1998
$
14.571
1999
$
14.380
2000
$
14.855
2001
$
16.681
2002
$
17.880
The
USDA/
ARS
strategy
for
evaluating
possible
alternatives
is
to
first
test
the
approaches
in
controlled
experiments
to
determine
efficacy,
then
testing
those
that
are
effective
in
field
plots.
The
impact
of
the
variables
that
affect
efficacy
is
addressed
by
conducting
field
trials
at
multiple
locations
with
different
crops
and
against
various
diseases
and
pests.
Alternatives
that
are
effective
in
field
plots
are
then
tested
in
field
scale
validations,
frequently
by
growers
in
their
own
fields.
University
scientists
are
also
participants
in
this
research.
Research
teams
that
include
ARS
and
university
scientists,
extension
personnel,
and
grower
representatives
meet
periodically
to
evaluate
research
results
and
plan
future
trials.

Research
results
submitted
with
the
CUE
request
packages
(
including
published,
peer­
reviewed
studies
by
(
primarily)
university
researchers,
university
extension
reports,
and
unpublished
studies)
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
the
MBTOC
list.
Page
21
Government
funded
studies
related
to
U.
S.
strawberry
nursery
production
that
are
currently
on­
going
include
the
following:

1.
Cultural
and
Biological
Alternatives
to
Methyl
Bromide
Fumigation
of
Strawberries
(
Oct
2000
­
Sep
2004)
Identify
and
characterize
the
cultural
and
biological
alternatives
for
control
of
strawberry
black
root
rot
using
an
integrated
approach.
Specific
alternatives
to
be
tested
include:
1)
use
of
subsoiling
and
raised
beds;
2)
incorporation
of
suppressive
compost;
3)
use
of
rotation
crops;
4)
use
of
beneficial
microorganisms
with
compost
and
transplant
dips.
2.
Alternative
Fumigants
for
Control
of
Soilborne
Pests:
Strawberry
As
a
Model
System
(
Sep
2000
­
Mar
2005)
Evaluate
the
effect
of
methyl
bromide
replacement
soil
fumigants
on
pathogen
control
and
plant
health
in
strawberry
nursery
and
production
fields.
Also
will
evaluate
the
effect
of
fumigants
on
beneficial
microbes
in
the
soil.

3.
Biological
Agricultural
Systems
in
Strawberry
Organic
Agricultural
Systems
in
Strawberry
(
Jan
2000
­
Jun
2002)
An
organized
outreach
and
research
program
will
employ
collaboration
between
farmers,
PCAs,
weed
scientists,
entomologists
and
plant
pathologists.
The
group
will
document
the
efficacy
and
suitability
of
BASIS
and
OASIS
insect,
weed,
pathogen,
fertility
and
soil
management.
An
integrated
biological
control
system
and
bioherbicide
will
be
compared
to
conventional
production
with
methyl
bromide
and
pesticide
use.
Work
will
be
conducted
at
10
sites
this
year.
Plant
disease
and
weed
suppression
will
be
documented.
Treatments
will
be
evaluated
based
on
yield
of
strawberries.

4.
Biological
Control
of
Soil
Borne
Disease
of
Strawberry
Using
Pseudomonas
Fluorescens
Strain
Q8r1­
96
(
Feb
1999
­
Dec
2003)
To
evaluate
the
efficacy
of
applying
commercially
available
microbial
inoculant
through
the
drip
irrigation
system
for
controlling
root
diseases
of
strawberry.

5.
Weed
Control
Strategies
for
Basis:
Biological
Agricultural
Systems
in
Strawberry
(
Sep
2000
­
Sep
2002)
To
evaluate
state­
of­
the­
art
methods
for
biologically
integrated
weed
control
in
conjunction
with
control
of
other
pests.
The
control
treatment
in
fumigated
sites
will
be
fumigation
with
methyl
bromide
plus
chloropicrin.
To
deplete
weed
seedbanks
in
nonfumigated
sites
the
base
treatment
will
be:
perform
tillage,
use
ozone,
hot
water
(
99
degrees
C)
applied
at
4680
L/
ha
to
kill
shallow
weed
seeds
and
seedlings,
corn
gluten
meal
applied
as
part
of
an
integrated
system,
and/
or
weed
management
with
colored
mulches.
Weed
emergence
counts
m­
2
will
be
taken
at
regular
intervals
throughout
the
stand
establishment
phase
(
November­
March).

6.
Develop
Control
Procedures
for
Black
Root
Rot,
Evaluate
Host
Tolerance
and
Yield
Potential
(
Feb
2001
­
Jan
2004)
Evaluate
strawberry
cultivars
for
tolerance
to
black
root
rot
pathogens
in
field
and
greenhouse
evaluations.
Evaluate
cultivar
performance
in
the
field
when
planted
into
nonfumigated
soil
naturally
infested
with
these
pathogens
Page
22
7.
Biology
and
Management
of
Diseases
Caused
by
Phytophthora
Spp.
on
California
Strawberries
(
Jul
2002
­
Jan
2003)
1)
Characterize
and
assess
importance
of
different
Phytophthora
spp.
on
California
strawberries.
2)
Improve
genetic
strategies
for
management
of
Phytophthora­
induced
diseases
on
California
strawberries.
3)
Improve
cultural
strategies
for
management
of
Phytophthora­
induced
diseases
on
California
strawberries.
4)
Improve
chemical
strategies
for
management
of
Phytophthora­
induced
diseases
on
California
strawberries.

8.
Efficacy
and
Mode
of
Action
of
Plantpro
45
As
An
Alternative
to
Methyl
Bromide
(
Feb
1999
­
Jun
2003)
Define
rates
for
activity
against
root­
knot
nematodes,
Fusarium
wilt,
and
Phytophthora
capsici,
and
for
phytoxic
levels
in
strawberry.
Determine
mode
of
action
by
assessing
direct
effects
on
pathogens
and
plant
physiology.
Develop
application
methods
compatible
with
commercial
vegetable
production
systems
including
preplant
soil
disinfestation,
drip
application
with
soil
solarization,
foliar
application,
and
combinations
of
techniques
9.
Field
Scale
Demonstration/
validation
Studies
of
Alternatives
for
Methyl
Bromide
in
Plastic
Mulch
(
Apr
2000
­
Jun
2003)
Evaluate
and
validate
the
effectiveness
and
economic
viability
of
alternatives
to
Methyl
Bromide
soil
fumigation
for
nematode
disease
and
weed
control
in
plastic
mulch
vegetable
production
systems
in
Florida.
Establish
alternative
treatments
on
grower
fields
at
a
scale
sufficient
to
allow
their
evaluation
as
components
of
production
systems;
Establish
paired
subplots
in
alternative
treatments
and
adjacent
grower
standard
treatments;
Diagnose
and
monitor
nematodes,
soil­
borne
diseases,
and
practice
including
grading
fruit
and
recording
weights
conduct
a
comparative
cost/
benefit
analysis
of
the
alternative
treatments
using
the
whole
enterprise
budget
analysis
method.

10.
Evaluation
of
Fumigant
Efficacy
with
Virtually
Impermeable
Film
(
VIF)
Plastic
(
Sep
2002
­
Mar
2005)
Evaluate
the
effect
of
methyl
bromide
replacement
soil
fumigants
applied
under
standard
polyethylene
plastic
or
virtually
impermeable
film
on
pathogen
control
and
plant
health
in
production
fields.

11.
Alternatives
to
Pesticides
for
Controlling
Pathogens
in
Strawberry
&
Vegetable
Production
Systems
(
Aug
1999
­
Jun
2003)
Develop
integrated
management
approaches
to
control
diseases.
Investigate
the
basic
ecology
&
biology
of
pathogens
as
well
as
the
etiology
of
plant
infection
in
order
to
target
integrated
control
approaches.
Investigate
the
rhizosphere
ecology
of
crop
plants
grown
under
various
cultural
conditions
to
elucidate
the
influence
of
specific
microorganisms
on
plant
health
and
their
ability
to
influence
disease
expression
and
use
these
organisms
to
augment
nonfumigated
soil.

12.
Cultural
Management
of
Strawberries
and
Grapes
(
NC
State
University/
CSREES­
Oct
1998
­
Sep
2003)
Develop
alternatives
to
methyl
bromide
for
soil
fumigation
of
strawberry.
Develop
practices
fir
propagating
strawberry
runner
tips
in
greenhouses.
Develop
fertilization
practices
via
drip
irrigation,
to
improve
fresh
fruit
quality,
size
and
shelf­
life
of
`
Camarosa'
strawberry,
grown
in
plasticulture.
Page
23
Develop
practices
for
forcing
daynuetral
and
short
day
cultivars
for
early
winter
greenhouse
production.
13.
Evaluation
of
Fumigant
Efficacy
with
Virtually
Impermeable
Film
(
VIF)
Plastic
(
UC
Davis/
CSREES­
Sep
2002
­
Sep
2004)
To
identify
methods
to
maximize
the
effects
of
alternative
fumigants
on
soil
borne
pests,
while
minimizing
environmental
risk.
To
determine
the
minimum
effective
doses
of
chloropicrin
and
1,
3­
D
plus
chloropicrin
on
soil
borne
pathogens,
weeds
and
calla
lily
bulbs
under
virtually
impermeable
film
(
VIF).

14.
Alternative
Fumigants
for
the
Control
of
Soil
Pests:
Strawberry
as
a
model
system
(
UC
Davis/
CSREES­
Sep
2002
­
Aug
2004)
To
evaluate
the
efficacy
of
the
alternative
fumigants
for
the
control
of
soil
borne
pests
and
weeds
in
the
field.
The
crop
production
system
that
will
be
used
as
a
model
is
strawberry,
with
trails
addressing
fumigant
efficacy
in
both
runner
plant
nurseries
and
commercial
berry
production
fields,
different
soil
types
and
locations
in
the
state.
Since
this
plant
is
highly
susceptible
to
all
these
organisms
it
is
a
good
indicator
crop
to
use.

Based
on
preliminary
results
from
research
conducted
in
this
area
and
largely
in
the
area
of
tomatoes
and
strawberries,
researchers
believe
that
a
mix
of
fumigants
together
with
an
herbicide
treatment
is
the
best
possible
alternative
to
methyl
bromide.
Combinations
of
1,3
dichloropropene/
chloropicrin,
and
metam­
sodium/
chloropicrin
are
being
tested
for
disease
and
weed
control.
Future
research
plans
will
test
combinations
of
these
fumigants
with
chemicals,
such
as
halosulfuron,
metolachlor,
and
sulfentrazone.
A
program
to
evaluate
host
resistance
to
Phytophthora
root
and
crown
rot
has
been
implemented.
Growers
are
starting
to
deploy
lines
identified
as
having
both
genetic
resistance
and
acceptable
horticultural
qualities.

Research
in
application
technology
(
e.
g.,
injection
methods
and
application
rates)
may
improve
the
uniformity
of
soil
movement
of
chemicals,
such
as
metam­
sodium.
Non­
chemical
alternatives
have
been
incorporated
and
methods
such
as
IPM,
mulching,
solarization,
and
biofumigation
are
being
examined
as
part
of
an
overall
strategy
to
manage
production
in
strawberry
nurseries.
Trials
evaluating
compost­
based
systems
as
alternatives
for
chemical­
based
fumigations
are
already
being
conducted.
These
trials
will
continue
and
weed
ratings,
disease
incidence,
and
crop
yield
data
will
be
collected.

Research
by
Larson
and
Shaw
performed
under
nursery
production
conditions
indicate
rates
of
chloropicrin
that
are
effective
and
should
be
further
investigated
as
an
alternative
with
companion
compounds
for
nematode
control
including
1,3­
dichloropropene.
This
research
was
done
in
1993­
1996
and
does
not
appear
to
have
been
continued
or
follow­
up
studies
were
not
included
in
the
literature.

Work
by
Duniway
et
al.,
is
also
focused
on
developing
chemical
alternatives
for
nursery
production
and
was
funded
by
the
Strawberry
Commission.
This
research
was
performed
in
four
consecutive
years
on
the
same
soil
and
examined
the
use
of
VIF
films,
fumigant
application
through
drip
irrigation,
and
lower
rates
of
fumigants.
They
found
that
Verticillium
was
not
effectively
controlled
with
any
of
the
alternative
treatments,
while
some
improvement
in
weed
control
was
observed
with
alternative
fumigants
and
mulches.
These
researchers
are
also
involved
in
examination
of
Page
24
unregistered
alternative
fumigants
with
the
support
of
the
Strawberry
Commission
and
in
cooperation
with
the
University
of
California,
Davis
and
USDA,
ARS.
All
of
this
work
should
continue
to
be
supported.

Studies
by
Gordon
et
al.,
summarized
research
at
strawberry
nurseries
investigating
various
fumigants
and
rotation
crops
for
control
of
V.
dahliae
at
high
altitudes.
They
found
that
all
the
fumigants
tested
provided
similar
control
of
this
pathogen
while
none
of
the
nonchemical
treatments
provided
acceptable
control.
More
of
these
studies
evaluating
the
secondary
effects
of
alternatives
on
rotation
crops
such
as
contract
onion
are
needed.
Also,
studies
on
plant
back
intervals
required
for
alternative
fumigants
in
combination
with
VIF
films
should
be
performed.

Overall,
studies
on
alternatives
for
strawberry
nursery
production
are
limited.
A
majority
of
the
research
used
to
support
these
applications
is
for
strawberry
fruit
production
and
may
not
be
directly
relevant
to
strawberry
nurseries.
A
primary
weakness
in
the
overall
research
program
is
that
most
studies
with
alternatives
have
been
performed
on
ground
previously
fumigated
with
methyl
bromide.
While
it
is
stated
that
alternatives
do
not
deliver
the
deep
fumigation
control
obtained
with
methyl
bromide,
there
is
no
evidence
presented
that
alternative
application
techniques
have
been
evaluated
to
improve
fumigation
at
greater
depths
with
1,3­
Dichloropicrin,
chloropicrin
and
metam
sodium
products.

Quality
programs
and
collaborative
relationships
are
in
place
to
facilitate
research
efforts
for
this
industry
and
approximately
US$
800,00000
to
US$
1,200,000.00
has
been
spent
in
support
of
these
programs.
However,
the
industry
is
encouraged
to
be
more
proactive
in
cooperating
with
researchers
to
develop
new
alternatives
since
the
availability
of
all
chemical
alternatives
currently
being
researched
is
questionable.
Additional
research
to
fine­
tune
use
of
alternative
fumigants
to
maximize
efficacy
and
yield
is
needed.
Where
nutsedge
is
a
problem,
research
is
needed
to
find
a
suitable
pre­
emergent
herbicide,
or
to
find
ways
to
get
better
herbicidal
efficacy
from
available
fumigants.
New
chemical
registrations,
such
as
Iodomethane,
could
hold
promise
as
possible
methyl
bromide
replacements.
Development
of
more
sustainable
production
systems
should
be
considered
an
extremely
high
priority.
Support
for
research
on
innovative
methods
and
long­
term
solutions
for
producing
strawberry
nursery
stock,
including
production
of
transplants
in
soilless
growing
media,
is
crucial.
Many
Southeast
strawberry
nursery
growers
are
converting
to
the
use
of
plug
transplants
and
it
is
recommended
that
the
California
nursery
growers
give
this
serious
consideration.

In
addition,
research
plans
submitted
by
applicants
for
the
strawberry
nursery
sector
include
ongoing
research
in
California
evaluating
various
studies
for
the
alternatives
Vapam
and
1,3
dichloropropene.
Further
research
evaluating
chemical
and
non­
chemical
alternative
is
planned
for
the
future.
So
far,
about
US$
100,000
has
been
spent
on
research.

As
demonstrated
by
the
table
6,
U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
substantial,
and
they
have
been
growing
in
size
as
the
phaseout
has
approached.
The
United
States
is
committed
to
sustaining
these
research
efforts
in
the
future
to
continue
to
aggressively
search
for
technically
and
economically
feasible
alternatives
to
methyl
bromide.
We
are
also
committed
to
continuing
to
share
our
research,
and
enable
a
global
sharing
of
experience.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Page
25
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

Registration
Program
The
United
States
has
one
of
the
most
rigorous
programs
in
the
world
for
safeguarding
human
health
and
the
environment
from
the
risks
posed
by
pesticides.
While
we
are
proud
of
our
efforts
in
this
regard,
related
safeguards
do
not
come
without
a
cost
in
terms
of
both
money
and
time.
Because
the
registration
process
is
so
rigorous,
it
can
take
a
new
pesticide
several
years
(
3­
5)
to
get
registered
by
EPA.
It
also
takes
a
large
number
of
years
to
perform,
draft
results
and
deliver
the
large
number
of
health
and
safety
studies
that
are
required
for
registration.

The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
U.
S.
EPA
registers
pesticides
provided
its
use
does
not
pose
unreasonable
adverse
effects
to
humans
or
the
environment.
Under
FFDCA,
the
U.
S.
EPA
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

The
process
by
which
U.
S.
EPA
examines
the
ingredients
of
a
pesticide
to
determine
if
they
are
safe
is
called
the
registration
process.
The
U.
S.
EPA
evaluates
the
pesticide
to
ensure
that
it
will
not
have
any
unreasonable
adverse
effects
on
humans,
the
environment,
and
non­
target
species.
Applicants
seeking
pesticide
registration
are
required
to
submit
a
wide
range
of
health
and
ecological
effects
toxicity
data,
environmental
fate,
residue
chemistry
and
worker/
bystander
exposure
data
and
product
chemistry
data.
A
pesticide
cannot
be
legally
used
in
the
United
States
if
it
has
not
been
registered
by
U.
S.
EPA,
unless
it
has
an
exemption
from
regulation
under
FIFRA.

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
process
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
The
average
processing
time
for
a
new
active
ingredient,
from
date
of
submission
to
issuance
of
a
registration
decision,
is
approximately
38
months.
In
most
cases,
the
registrant
(
the
pesticide
applicant)
has
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
Page
26
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized
The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps
and
groundwater
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
$
13.5
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
EPA's
participation
in
the
evaluation
of
research
grant
proposals
submitted
to
the
USDA's
Cooperative
State
Research,
Education,
and
Extension
Service
methyl
bromide
alternatives
research
program
of
US$
2.5
million
per
year
has
further
ensured
that
critical
registration
issues
are
being
addressed
by
the
research
community.

Since
1997,
EPA
has
registered
the
following
chemical/
use
combinations
as
part
of
its
commitment
to
expedite
the
review
of
methyl
bromide
alternatives:

1999:
Pebulate
to
control
weeds
in
tomatoes
2000:
Phosphine
to
control
insects
in
stored
commodities
2001:
Indian
Meal
Moth
Granulosis
Virus
to
control
Indian
meal
moth
in
stored
grains
2001:
Terrazole
to
control
pathogens
in
tobacco
float
beds
2001:
Telone
applied
through
drip
irrigation
­
all
crops
2002:
Halosulfuron­
methyl
to
control
weeds
in
melons
and
tomatoes
EPA
is
currently
reviewing
several
additional
applications
for
registration
as
methyl
bromide
alternatives,
with
several
registration
eligibility
decisions
expected
within
the
next
year,
including:

 
Iodomethane
as
a
pre­
plant
soil
fumigant
for
various
crops
 
Fosthiazate
as
a
pre­
plant
nematocide
for
tomatoes
 
Sulfuryl
fluoride
as
a
post­
harvest
fumigant
for
stored
commodities
 
Trifloxysulfuron
sodium
as
a
pre­
plant
herbicide
for
tomatoes
 
Dazomet
as
a
pre­
plant
soil
fumigant
for
strawberries
and
tomatoes
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
issues
related
to
toxicity,
ground
water
contamination,
and
the
release
of
air
pollutants
may
pose
significant
problems
with
respect
to
some
alternatives
that
may
lead
to
use
restrictions
since
many
of
the
growing
regions
are
in
sensitive
areas
such
as
those
in
close
proximity
to
schools
and
homes.
Ongoing
research
on
alternate
fumigants
is
evaluating
ways
to
reduce
emission
under
various
application
regimes
and
examining
whether
commonly
used
agrochemicals,
such
as
fertilizers
and
nitrification
inhibitors,
could
be
used
to
rapidly
degrade
soil
fumigants.
For
example,
if
registration
of
iodomethane
or
another
alternative
occurs
in
the
near
future,
commercial
availability
and
costs
will
be
factors
that
must
be
taken
into
consideration.
Page
27
It
must
be
emphasized,
however,
that
finding
potential
alternatives,
and
even
registering
those
alternatives
is
not
the
end
of
the
story.
Alternatives
must
be
tested
by
users
and
found
technically
and
economically
feasible
before
widespread
adoption
will
occur.
As
noted
by
TEAP,
a
specific
alternative,
once
available
may
take
two
or
three
cropping
seasons
of
use
before
efficacy
can
be
determined
in
the
specific
circumstance
of
the
user.
In
an
effort
to
speed
adoption
the
United
States
government
has
also
been
involved
in
these
steps
by
promoting
technology
transfer,
experience
transfer,
and
private
sector
training.

10.
Conclusion
and
Policy
Issues
Associated
with
the
Nomination
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
TEAP
listed
potential
alternatives
for
the
specific
crops
and
areas
covered
in
this
nomination
are
not
currently
technically
or
economically
viable
from
the
standpoint
of
United
States
growers
covered
by
this
exemption
request.
We
have
also
determined
that
the
absence
of
methyl
bromide
for
the
nominated
uses
will
result
in
a
significant
market
disruption
to
the
effected
sectors.
We
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
for
many
important
uses
are
under
investigation
and
may
be
on
the
horizon.
Based
on
this
analysis,
we
believe
those
requests
included
in
this
nomination
meet
the
criteria
set
out
by
the
Parties
in
Decision
IX/
6.

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
strawberry
nurseries
are
not
currently
technically
or
economically
feasible
in
the
management
of
the
major
pests
of
strawberry
nursery
plants,
specifically
on
insects,
weeds,
nematodes,
and
pathogens
from
the
standpoint
of
United
States
strawberry
nursery
growers
covered
by
this
exemption
nomination.

Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematode
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640).
Additionally,
there
are
specific
soil
treatment
and
handling
procedures
to
facilitate
compliance
with
the
regulations
for
the
Nursery
Stock
Nematode
Control
Program.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
and
"
commercially
clean
with
respect
to
established
pests
of
general
distribution"
in
order
to
qualify
for
a
nursery
stock
certificate
for
interstate
and
intrastate
shipments.

Use
of
methyl
bromide
to
control
pests
entitles
growers
to
the
presumption
that
they
have
met
the
applicable
standards,
while
use
of
alternative
methods
to
control
pests
requires
the
nursery
to
sample
the
nursery
stock,
with
all
samples
required
to
meet
the
standards
of
zero
(
only
non­
detectable
levels
of
)
pests.
Failure
to
meet
the
standard
requires
destruction
of
the
nursery's
entire
stock.
Use
of
an
alternative,
therefore,
subjects
the
growers
to
the
certain
costs
of
a
sampling
and
analysis
program
and
the
risk
of
the
complete
loss
of
stock
relative
to
the
situation
with
methyl
bromide
use.
Strawberry
nurserymen
must
document
compliance
on
a
monthly
basis.
These
plants
represent
a
5
year
investment
by
the
nursery
grower
and
are
shipped
worldwide
as
both
nursery
and
production
plants.
Page
28
Primary
countries
which
import
strawberry
nursery
stock
plants
from
California
nurseries
include
Canada,
Mexico,
Spain,
and
several
South
American
countries.
There
are
wide
and
specific
destination
quarantine
restrictions
and
international
quarantine
control
issues
involved
with
shipment
of
these
plants.
The
need
for
nursery
stock
to
be
clean
is
absolute
since
there
is
a
potential
for
nematodes
to
spread
on
national
and
international
levels.
For
the
California
Strawberry
Nursery
Association
growers,
the
MBTOC
alternatives
will
not
meet
requirements
of
CDFA
for
nursery
stock
certification,
either
individually
or
in
combinations.
Complete
crop
loss
can
occur
if
the
nursery
stock
cannot
be
certified
as
nematode
free.

While
the
Southeast
Strawberry
Consortium
growers
do
not
have
the
strict
state
requirements
that
California
does,
they
also
must
certify
that
their
nursery
stock
is
essentially
free
of
pests.
As
a
matter
of
social
policy,
society
has
an
interest
in
facilitating
the
spread
of
pests,
and
control
of
pests
in
nursery
stock
is
an
important
first
step.
Finally,
strawberry
nursery
stock
from
California
is
a
substitute
for
strawberry
stock
raised
elsewhere.
If
strawberry
growers
can
not
be
assured
that
the
stock
they
purchase
meets
the
same
standards
as
nursery
stock
from
California,
they
will
switch
producers,
eliminating
the
strawberry
nursery
stock
production
in
the
southeastern
U.
S.

There
is
large
potential
for
lost
time
due
to
alterations
in
production
practices
and
increased
time
required
for
nonchemical
alternatives
to
be
effective
in
reducing
pathogen
populations
which
would
increase
production
time
and
impact
economic
production
windows.
These
plants
represent
a
significant
investment
by
the
grower
and
are
shipped
worldwide
as
both
nursery
and
production
plants.
There
are
wide
and
specific
destination
quarantine
restrictions
and
international
control
quarantine
issues
involved
with
shipment
of
these
plants.

As
a
consequence,
both
applicants
have
made
a
strong
case
that
methyl
bromide
is
necessary
for
successful
and
profitable
strawberry
nursery
production
in
the
United
States.
None
of
the
MBTOC
alternatives
are
technically
feasible.
In
order
for
the
U.
S.
strawberry
nursery
industry
to
supply
the
world
wide
demand,
it
is
imperative
that
they
continue
to
have
access
to
the
use
of
methyl
bromide
to
manage
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.),
Crown
rot
(
Phytophthora
cactorum),
Root
Knot
nematode
(
Meloidogyne
spp.),
Yellow
nutsedge
(
Cyperus
esculentus)
and
Purple
nutsedge
(
Cyperus
rotundus).

In
addition
to
demonstrating
the
economic
and
technical
issues
associated
with
the
presently
available
alternatives,
we
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
in
the
strawberry
nursery
sector
may
be
on
the
horizon.
That
said,
it
must
be
stressed
that
the
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unacceptable
risk,
is
a
long
and
rigorous
process,
and
the
U.
S.
need
for
methyl
bromide
for
strawberry
nurseries
will
be
maintained
for
the
period
being
requested
for
an
exemption
in
this
nomination.

In
reviewing
this
nomination,
we
believe
that
it
is
important
for
the
MBTOC,
the
TEAP
and
the
Parties
to
understand
some
of
the
policy
issues
associated
with
our
request.
A
discussion
of
those
follows:
Page
29
a.
Request
for
Aggregate
Exemption
for
All
Covered
Methyl
Bromide
Uses:
As
mandated
by
Decision
XIII/
11,
the
nomination
information
that
is
being
submitted
with
this
package
includes
information
requested
on
historic
use
and
estimated
need
in
individual
sectors.
That
said,
we
note
our
agreement
with
past
MBTOC
and
TEAP
statements
which
stress
the
dynamic
nature
of
agricultural
markets,
uncertainty
of
specific
production
of
any
one
crop
in
any
specific
year,
the
difficulty
of
projecting
several
years
in
advance
what
pest
pressures
might
prevail
on
a
certain
crop,
and,
the
difficulty
of
estimating
what
a
particular
market
for
a
specific
crop
might
look
like
in
a
future
year.
We
also
concur
with
the
MBTOC's
fear
that
countries
that
have
taken
significant
efforts
to
reduce
methyl
bromide
use
and
emissions
through
dilution
with
chloropicrin
may
be
experiencing
only
short
term
efficacy
in
addressing
pest
problems.
On
the
basis
of
those
factors,
we
urge
the
MBTOC
and
the
TEAP
to
follow
the
precedent
established
under
the
essential
use
exemption
process
for
Metered
Dose
Inhalers
(
MDIs)
in
two
key
areas.

First,
because
of
uncertainties
in
both
markets
and
the
future
need
for
individual
active
moieties
of
drugs,
the
TEAP
has
never
provided
a
tonnage
limit
for
each
of
the
large
number
of
active
moieties
found
in
national
requests
for
a
CFC
essential
use
exemption
for
MDIs,
but
has
instead
recommended
an
aggregate
tonnage
exemption
for
national
use.
This
has
been
done
with
an
understanding
that
the
related
country
will
ensure
that
the
tonnage
approved
for
an
exemption
will
be
used
solely
for
the
group
of
active
moieties/
MDIs
that
have
been
granted
the
exemption.
We
believe
that
the
factors
of
agricultural
uncertainty
surrounding
both
pest
pressures
in
future
year
crops,
and
efficacy
of
reduced
methyl
bromide
application
provide
an
even
stronger
impetus
for
using
a
similar
approach
here.
The
level
of
unpredictability
in
need
leads
to
a
second
area
of
similarity
with
MDIs,
the
essential
need
for
a
review
of
the
level
of
the
request
which
takes
into
account
the
need
for
a
margin
of
safety.

b.
Recognition
of
Uncertainty
in
Allowing
Margin
for
Safety:
With
MDIs,
it
was
essential
to
address
the
possible
change
in
patient
needs
over
time,
and
in
agriculture,
this
is
essential
to
address
the
potential
that
the
year
being
requested
for
could
be
a
particularly
bad
year
in
terms
of
weather
and
pest
pressure.
In
that
regard,
the
TEAP's
Chart
2
in
Appendix
D
demonstrates
the
manner
in
which
this
need
for
a
margin
of
safety
was
addressed
in
the
MDI
area.
Specifically,
Chart
2
in
Appendix
D
tracks
national
CFC
requests
for
MDIs
compared
with
actual
use
of
CFC
for
MDIs
over
a
number
of
years.

Chart
2
in
Appendix
D
demonstrates
several
things.
First,
despite
the
best
efforts
of
many
countries
to
predict
future
conditions,
it
shows
that
due
to
the
acknowledged
uncertainty
of
out­
year
need
for
MDIs,
Parties
had
the
tendency
to
request,
the
TEAP
recommended,
and
the
Parties
approved
national
requests
that
turned
out
to
include
an
appreciable
margin
of
safety.
In
fact,
this
margin
of
safety
was
higher
at
the
beginning
 
about
40%
above
usage
 
and
then
went
down
to
30%
range
after
4
years.
Only
after
5
years
of
experience
did
the
request
come
down
to
about
10%
above
usage.
While
our
experience
with
the
Essential
Use
process
has
aided
the
U.
S.
in
developing
its
Critical
Use
nomination,
we
ask
the
MBTOC,
the
TEAP
and
the
Parties
to
recognize
that
the
complexities
of
agriculture
make
it
difficult
to
match
our
request
exactly
with
expected
usage
when
the
nomination
is
made
two
to
three
years
in
advance
of
the
time
of
actual
use.

Chart
2
in
Appendix
D
also
demonstrates
that,
even
though
MDI
requests
included
a
significant
margin
of
safety,
the
nominations
were
approved
and
the
countries
receiving
the
exemption
for
Page
30
MDIs
did
not
produce
the
full
amount
authorized
when
there
was
not
a
patient
need.
As
a
result,
there
was
little
or
no
environmental
consequence
of
approving
requests
that
included
a
margin
of
safety,
and
the
practice
can
be
seen
as
being
normalized
over
time.
In
light
of
the
similar
significant
uncertainty
surrounding
agriculture
and
the
out
year
production
of
crops
which
use
methyl
bromide,
we
wish
to
urge
the
MBTOC
and
TEAP
to
take
a
similar,
understanding
approach
for
methyl
bromide
and
uses
found
to
otherwise
meet
the
critical
use
criteria.
We
believe
that
this
too
would
have
no
environmental
consequence,
and
would
be
consistent
with
the
Parties
aim
to
phaseout
methyl
bromide
while
ensuring
that
agriculture
itself
is
not
phased
out.

c.
Duration
of
Nomination:
It
is
important
to
note
that
while
the
request
included
for
the
use
above
appears
to
be
for
a
single
year,
the
entire
U.
S.
request
is
actually
for
two
years
 
2005
and
2006.
This
multi­
year
request
is
consistent
with
the
TEAP
recognition
that
the
calendar
year
does
not,
in
most
cases,
correspond
with
the
cropping
year.
This
request
takes
into
account
the
facts
that
registration
and
acceptance
of
new,
efficacious
alternatives
can
take
a
long
time,
and
that
alternatives
must
be
tested
in
multiple
cropping
cycles
in
different
geographic
locations
to
determine
efficacy
and
consistency
before
they
can
be
considered
to
be
widely
available
for
use.
Finally,
the
request
for
multiple
years
is
consistent
with
the
expectation
of
the
Parties
and
the
TEAP
as
evidenced
in
the
Parties
and
MBTOC
request
for
information
on
the
duration
of
the
requested
exemption.
As
noted
in
the
Executive
Summary
of
the
overall
U.
S.
request,
we
are
requesting
that
the
exemption
be
granted
in
a
lump
sum
of
9,920,965
kilograms
for
2005
and
9,445,360
kilograms
for
2006.
While
it
is
our
hope
that
the
registration
and
demonstration
of
new,
cost
effective
alternatives
will
result
in
even
speedier
reductions
on
later
years,
the
decrease
in
our
request
for
2006
is
a
demonstration
of
our
commitment
to
work
toward
further
reductions
in
our
consumption
of
methyl
bromide
for
critical
uses.
At
this
time,
however,
we
have
not
believed
it
possible
to
provide
a
realistic
assessment
of
exactly
which
uses
would
be
reduced
to
account
for
the
overall
decrease.

11.
Contact
Information
For
further
general
information
or
clarifications
on
material
contained
in
the
U.
S.
nomination
for
critical
uses,
please
contact:

John
E.
Thompson,
Ph.
D.
Office
of
Environmental
Policy
US
Department
of
State
2201
C
Street
NW
Rm
4325
Washington,
DC
20520
tel:
202­
647­
9799
fax:
202­
647­
5947
e­
mail:
ThompsonJE2@
state.
gov
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
Page
31
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
12.
References
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L.
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W.
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Burgos,
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DC
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California
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Carpenter,
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D
Restrictions
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Chase,
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Sinclair,
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Profile
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California.
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United
States
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NSF
Center
for
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Crop
Profile
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Strawberries
in
Florida.
2002.
United
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of
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NSF
Center
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Integrated
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Crop
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Strawberries
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United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Egley,
G.
H.
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seed
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seedling
reductions
by
soil
solarization
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transparent
polyethylene
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Weed
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of
Plant
Protection
Regulations.
Oct.
2002.
Florida
Department
of
Agriculture
and
Consumer
Services.

Galloway,
B.
A.
and
L.
A.
Weston.
1996.
Influence
of
cover
crop
and
herbicide
treatment
on
weed
control
and
yield
in
no­
till
sweet
corn
(
Zea
mays
L.)
and
pumpkin
(
Cucurbita
maxima
Duch).
Weed
Technol.
10:
341­
346.
Page
32
Gamini,
S.
and
R.
K.
Nishimoto.
1987.
Propagules
of
purple
nutsedge
(
Cyperus
rotundus)
in
soil.
Weed
Technol.
1:
217­
220.

Georgia
Summary
of
Plant
Protection
Regulations.
Jan.
2000.
Georgia
Department
of
Agriculture.

Gilreath,
J.
P.,
J.
W.
Noling,
and
P.
R.
Gilreath.
1999.
Nutsedge
management
with
cover
crop
for
tomato
in
the
absence
of
methyl
bromide.
Research
summary.,
A
Specific
Cooperative
Agreement
58­
6617­
6­
013
Holm,
L.
G.,
D.
L.
Plucknett,
J.
V.
Pancho,
and
J.
P.
Herberger.
1977.
The
world's
worst
weeds:
distribution
and
biology.
Honolulu,
HI:
University
of
Hawaii
Press,
pp.
8­
24
Horowitz,
M.
1972.
Effects
of
desiccation
and
submergence
on
the
viability
of
rhizome
fragments
of
bermudagrass,
johnsongrass,
and
tubers
of
nutsedge.
Israel
J.
Agric.
Res.
22(
4):
215­
220.

Johnson,
G.
A.,
M.
S.
Defelice,
and
A.
R.
Helsel.
1993.
Cover
crop
management
and
weed
control
in
corn
(
Zea
mays).
Weed
Technol.
7425­
430.

Norsworthy,
J.
2000.
Allelopathic
effects
of
wild
radish
on
cotton.
Clemson
University.
Unpublished.

North
Carolina
Department
of
Agriculture
and
Consumer
Services.
North
Carolina
Agricultural
Statistics
Service.

North
Carolina
Summary
of
Plant
Protection
Regulations.
Jan.
2003.
North
Carolina
Department
of
Agriculture
and
Consumer
Services.

Patterson,
D.
T.
1998.
Suppression
of
purple
nutsedge
(
Cyperus
rotundus)
with
polyethylene
film
mulch.
Weed
Technol.
12:
275­
280.

SoilZone,
1999.
Ozone
Gas
as
a
Soil
Fumigant.
1998
Research
Program.
Electric
Power
Research
Institute.

Sorenson,
Kenneth
A.,
W.
Douglas
Gubler,
Norman
C.
Welch,
and
Craig
Osteen.
The
Importance
of
Pesticides
and
Other
Pest
Management
Practices
in
U.
S.
Strawberry
Production.
1997.
Special
Funded
Project
of
the
United
States
Department
of
Agriculture,
National
Agricultural
Pesticide
Impact
Assessment
program.
Document
Number
1­
CA­
97.

Tennessee
State
Department
of
Agriculture.
Tennessee
Agricultural
Statistics
Service.

Tennessee
Summary
of
Plant
Protection
Regulations.
Apr.
2000.
Tennessee
Department
of
Agriculture.

Thullen,
R.
J.
and
P.
E.
Keeley.
1975.
Yellow
nutsedge
sprouting
and
resprouting
potential.
Weed
Sci.
23:
333­
337.
Page
33
United
Nations
Environment
Programme
(
UNEP),
1998
.
Methyl
Bromide
Technical
Options
Committee
(
MBTOC).
1998
Assessment
of
alternatives
to
methyl
bromide.
p.
49.

Webster,
T.
M.
and
G.
E.
Macdonald.
2001.
A
survey
of
weeds
in
various
crops
in
Georgia.
Weed
Technol.
15:
771­
790.

13.
Appendices
Appendix
A.
List
of
critical
use
exemption
(
CUE)
requests
for
the
strawberry
nursery
sector
in
the
U.
S.

Southeast:

CUE­
02­
0038,
Southeast
Strawberry
Consortium
California:
California
CUE­
02­
0034,
California
Strawberry
Nursery
Association
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
None
of
the
alternatives
listed
by
MBTOC
and
reviewed
were
found
to
be
technically
feasible
for
the
strawberry
nursery
sector
therefore
no
economic
analysis
was
conducted.

Appendix
C:
U.
S.
Technical
and
Economic
Review
Team
Members
Christine
M.
Augustyniak
(
Technical
Team
Leader).
Christine
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1985.
She
has
held
several
senior
positions,
both
technical
and
managerial,
including
Special
Assistant
to
the
Assistant
Administrator
for
Prevention,
Pesticides,
and
Toxic
Substances,
Chief
of
the
Analytical
Support
Branch
in
EPA's
office
of
Environmental
Information
and
Deputy
Director
for
the
Environmental
Assistance
Division
in
the
Office
of
Pollution
Prevention
and
Toxics.
She
earned
her
Ph.
D.
(
Economics)
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Augustyniak
is
a
1975
graduate
of
Harvard
University
(
Cambridge)
cum
laude
(
Economics).
Prior
to
joining
EPA,
Dr.
Augustyniak
was
a
member
of
the
economics
faculty
at
the
College
of
the
Holy
Cross
(
Worcester).

William
John
Chism
(
Lead
Biologist).
Bill
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
He
evaluates
the
efficacy
of
pesticides
for
weed
and
insect
control.
He
earned
his
Ph.
D.
(
Weed
Science)
from
Virginia
Polytechnic
Institute
and
State
University
(
Blacksburg),
a
Master
of
Science
(
Plant
Physiology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Agriculture)
from
California
Polytechnic
State
University
(
San
Luis
Obispo).
Dr.
Chism
is
a
1978
graduate
of
The
University
of
California
(
Davis).
For
ten
years
prior
to
joining
the
EPA
Dr.
Page
34
Chism
held
research
scientist
positions
at
several
speciality
chemical
companies,
conducting
and
evaluating
research
on
pesticides.

Technical
Team
Jonathan
J.
Becker
(
Biologist)
Jonathan
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Scientific
Advisor
within
the
Office
of
Pesticides
Programs.
In
this
position
he
leads
the
advancement
of
scientific
methods
and
approaches
related
to
the
development
of
pesticides
use
information,
the
assessment
of
impacts
of
pesticides
regulations,
and
the
evaluation
of
the
benefits
from
the
use
of
pesticides.
He
earned
his
Ph.
D.
(
Zoology)
from
The
University
of
Florida
(
Gainesville)
and
a
Masters
of
Science
(
Biology/
Zoology)
from
Idaho
State
University
(
Pocatello).
Dr.
Becker
is
a
graduate
of
Idaho
State
University.
Prior
to
joining
EPA,
Dr.
Becker
worked
as
a
senior
environmental
scientist
with
an
environmental
consulting
firm
located
in
Virginia.

Diane
Brown­
Rytlewski
(
Biologist)
Diane
is
the
Nursery
and
Landscape
IPM
Integrator
at
Michigan
State
University,
a
position
she
has
held
since
2000.
She
acts
as
liaison
between
industry
and
the
university,
facilitating
research
partnerships
and
cooperative
relationships,
developing
outreach
programs
and
resource
materials
to
further
the
adoption
of
IPM.
Ms.
Rytlewski
holds
a
Master
of
Science
(
Plant
Pathology)
and
a
Bachelor
of
Science
(
Entomology),
both
from
the
University
of
Wisconsin
(
Madison).
She
has
over
twenty
year
experience
working
in
the
horticulture
field,
including
eight
years
as
supervisor
of
the
IPM
program
at
the
Chicago
Botanic
Garden.

Greg
Browne
(
Biologist).
Greg
has
been
with
the
Agricultural
Research
Service
of
the
U.
S.
Department
of
Agriculture
since
1995.
Located
in
the
Department
of
Plant
Pathology
of
the
University
of
California
(
Davis),
Greg
does
research
on
soilborne
diseases
of
crop
systems
that
currently
use
methyl
bromide
for
disease
control,
with
particular
emphasis
on
diseases
caused
by
Phytophthora
species.
He
is
the
author
of
numerous
articles
on
the
use
of
alternatives
to
methyl
bromide
for
the
control
of
diseases
in
fruit
and
nut
crops
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
the
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
the
same
institution.
Dr.
Browne
is
a
graduate
of
The
University
of
California
(
Davis).
Prior
to
joining
USDA
was
a
farm
advisor
in
Kern
County.

Nancy
Burrelle
(
Biologist).
Nancy
Burelle
is
a
Research
Ecologist
with
USDA's
Agricultural
Research
Service,
currently
working
on
preplant
alternatives
to
methyl
bromide.
She
earned
both
her
Ph.
D.
and
Master
of
Science
degrees
(
both
in
Plant
Pathology)
from
Auburn
University
(
Auburn).

Linda
Calvin
(
Economist).
Linda
Calvin
is
an
agricultural
economist
with
USDA's
Economic
Research
Service,
specializing
in
research
on
topics
affecting
fruit
and
vegetable
markets.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Berkeley).

Kitty
F.
Cardwell
(
Biologist).
Kitty
has
been
the
National
Program
Leader
in
Plant
Pathology
for
the
U.
S.
Department
of
Agriculture
Cooperative
State
Research,
Extension
and
Education
Service
since
2001.
In
this
role
she
administrates
all
federally
funded
research
and
extension
related
to
plant
pathology,
of
the
Land
Grant
Universities
throughout
the
U.
S.
She
earned
her
Ph.
D.
Page
35
(
Phytopathology)
from
Texas
A&
M
University
(
College
Station).
Dr.
Cardwell
is
a
1976
graduate
of
The
University
of
Texas
(
Austin)
cum
laude
(
Botany).
For
twelve
years
prior
to
joining
USDA
Dr.
Cardwell
managed
multinational
projects
on
crop
disease
mitigation
and
food
safety
with
the
International
Institute
of
Tropical
Agriculture
in
Cotonou,
Bénin
and
Ibadan,
Nigeria.

William
Allen
Carey
(
Biologist).
Bill
is
a
Research
Fellow
in
pest
management
for
southern
forest
nurseries
,
supporting
the
Auburn
University
Southern
Forest
Nursery
Management
Cooperative.
He
is
the
author
of
numerous
articles
on
the
use
of
alternative
fumigants
to
methyl
bromide
in
tree
nursery
applications.
He
earned
his
Ph.
D.
(
Forest
Pathology)
from
Duke
University
(
Durham)
and
a
Master
of
Science
(
Plant
Pathology
)
from
The
University
of
Florida
(
Gainesville).
Dr.
Carey
is
a
nationally
recognized
expert
in
the
field
of
nursery
pathology.

Margriet
F.
Caswell
(
Economist).
Margriet
has
been
with
the
USDA
Economic
Research
Service
since
1991.
She
has
held
both
technical
and
managerial
positions,
and
is
now
a
Senior
Research
Economist
in
the
Resource,
Technology
&
Productivity
Branch,
Resource
Economics
Division.
She
earned
her
Ph.
D.
(
Agricultural
Economics)
from
the
University
of
California
(
Berkeley).
Dr.
Caswell
also
received
a
Master
of
Science
(
Resource
Economics)
and
Bachelor
of
Science
(
Natural
Resource
Management)
from
the
University
of
Rhode
Island
(
Kingston).
Prior
to
joining
USDA,
Dr.
Caswell
was
a
member
of
both
the
Environmental
Studies
and
Economics
faculties
at
the
University
of
California
at
Santa
Barbara.

Tara
Chand­
Goyal
(
Biology).
Tara
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
a
plant
pathologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
risk
reduction.
He
earned
his
Ph.
D.
(
Mycology
and
Plant
Pathology)
from
The
Queen's
University
(
Belfast)
and
a
Master
of
Science
(
Plant
Pathology
and
Mycology)
from
Punjab
University
(
Ludhiana).
Dr.
Chand­
Goyal
is
a
graduate
of
Punjab
University.
Prior
to
joining
EPA
Dr.
Chand­
Goyal
was
a
member
of
the
faculty
of
The
Oregon
State
University
(
Corvallis)
and
of
The
University
of
California
(
Riverside).
His
areas
of
research
and
publication
include:
the
biology
of
viral,
bacterial
and
fungal
diseases
of
plants;
biological
control
of
plant
diseases;
and,
genetic
manipulation
of
microorganisms.

Daniel
Chellemi
(
Biologist).
Dan
has
been
a
research
plant
pathologist
with
the
U.
S.
Department
of
Agriculture
since
1997.
His
research
speciality
is
the
ecology,
epidemiology,
and
management
of
soilborne
plant
pathogens.
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
California
(
Davis)
and
a
Master
of
Science
(
Plant
Pathology)
from
The
University
of
Hawaii
(
Manoa).
Dr.
Chellemi
is
a
1982
graduate
of
the
University
of
Florida
(
Gainesville)
with
a
degree
in
Plant
Science.
He
is
the
author
of
numerous
articles
in
the
field
of
plant
pathology.
In
2000
Dr.
Chellemi
was
awarded
the
ARS
"
Early
Career
Research
Scientist
if
the
Year".
Prior
to
joining
USDA,
Dr.
Chellemi
was
a
member
of
the
plant
pathology
department
of
The
University
of
Florida
(
Gainesville).

Angel
Chiri
(
Biologist).
Angel
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997.
He
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
He
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
California
(
Riverside)
and
a
Master
of
Science
(
Biology/
Entomology)
from
California
State
University
(
Long
Beach).
Dr.
Chiri
is
a
graduate
of
Page
36
California
State
University
(
Los
Angeles).
Prior
to
joining
EPA
Dr.
Chiri
was
a
pest
and
pesticide
management
advisor
for
the
U.
S.
Agency
for
International
Development
working
mostly
in
Latin
America
on
IPM
issues.

Colwell
Cook
(
Biologist).
Colwell
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2000.
She
serves
in
the
Office
of
Pesticide
Programs
as
an
entomologist
and
specializes
in
analyzing
the
efficacy
of
pesticides
with
emphasis
on
benefits
of
pesticide
use.
She
earned
her
Ph.
D.
(
Entomology)
from
Purdue
University
(
West
Lafayette)
and
has
a
Master
of
Science
(
Entomology)
from
Louisiana
State
University
(
Baton
Rouge).
Dr.
Cook
is
a
1979
graduate
of
Clemson
University.
Prior
to
joining
EPA
Dr.
Cook
held
several
faculty
positions
at
Wabash
College
(
Crawfordsville)
and
University
of
Evansville
(
Evansville).

Julie
B.
Fairfax
(
Biologist)
Julie
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
currently
serves
as
a
senior
biologist
in
the
Biological
and
Economics
Analysis
Division,
and
has
previously
served
as
a
Team
Leader
in
other
divisions
within
the
Office
of
Pesticides
Programs.
She
has
held
several
technical
positions
specializing
in
the
registration,
re­
registration,
special
review
and
regulation
of
fungicidal,
antimicrobial,
and
wood
preservative
pesticides.
Ms.
Fairfax
is
a
1989
graduate
of
James
Madison
University
(
Harrisonburg,
VA)
where
she
earned
her
degree
in
Biology.
Prior
to
joining
EPA,
Julie
worked
as
a
laboratory
technician
for
the
Virginia
Poultry
Industry.

John
Faulkner
(
Economist)
John
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1989.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
He
earned
his
Ph.
D.
(
Economics)
from
the
University
of
Colorado
(
Boulder)
and
holds
a
Master's
of
Business
Administration
from
The
University
of
Michigan
(
Ann
Arbor).
Dr.
Faulkner
is
a
1965
graduate
of
the
University
of
Colorado
(
Boulder).
Prior
to
joining
EPA
was
a
member
of
the
economics
faculty
of
the
Rochester
Institute
of
Technology
(
Rochester),
The
University
of
Colorado
(
Boulder)
and
of
the
Colorado
Mountain
College
(
Aspen).

Clara
Fuentes
(
Biologist).
Clara
has
been
with
the
U.
S.
Environmental
Protection
agency
since
1999,
working
in
the
Philadelphia,
Pennsylvania
(
Region
III)
office.
She
specializes
in
reviewing
human
health
risk
evaluations
to
pesticides
exposures
and
supporting
the
state
pesticide
programs
in
Region
III.
She
earned
her
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
a
Master
of
Science
(
Zoology)
from
Iowa
State
University
(
Ames).
Prior
to
joining
EPA,
Dr.
Fuentes
worked
as
a
research
assistant
at
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
(
ARS)
(
Beltsville),
Maryland,
and
as
a
faculty
member
of
the
Natural
Sciences
Department
at
InterAmerican
University
of
Puerto
Rico.
Her
research
interest
is
in
the
area
of
Integrated
Pest
Management
in
agriculture.

James
Gilreath
(
Biologist).
Jim
has
been
with
the
University
of
Florida
Gulf
Coast
Research
and
Education
Center
since
1981.
In
this
position
his
primary
responsibilities
are
to
plan,
implement
and
publish
the
results
of
investigations
in
weed
science
in
vegetable
and
ornamental
crops.
One
main
focus
of
the
research
is
the
evaluation
and
development
of
weed
amangement
programs
for
specific
weed
pests.
He
earned
his
Ph.
D.
(
Horticulture)
from
The
University
of
Florida
(
Gainesville)
and
a
Master
of
Science,
also
in
Horticulture,
from
Clemson
University
(
Clemson).
Dr.
Gilreath
is
a
1974
graduate
of
Clemson
University
(
Clemson)
with
a
degree
in
Agronomy
and
Soils.
Page
37
Arthur
Grube
(
Economist).
Arthur
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1987.
He
is
now
a
Senior
Economist
in
the
Biological
and
Economics
Analysis
Division,
Office
of
Pesticide
Programs.
He
earned
his
Ph.
D.
(
Economics)
from
North
Carolina
State
University
(
Raleigh)
and
a
Masters
of
Arts
(
Economics)
also
from
North
Carolina
State
University.
Dr.
Grube
is
a
1970
graduate
of
Simon
Fraser
University
(
Vancouver)
where
his
Bachelor
of
Arts
degree
(
Economics)
was
earned
with
honors.
Prior
to
joining
EPA
Dr.
Grube
conducted
work
on
the
costs
and
benefits
of
pesticide
use
at
the
University
of
Illinois
(
Urbana).
Dr.
Grube
has
been
a
co­
author
of
a
number
of
journal
articles
in
various
areas
of
pesticide
economics
LeRoy
Hansen
(
Economist).
LeRoy
Hansen
is
currently
employed
as
an
Agricultural
Economist
for
the
USDA
Economic
Research
Service,
Resource
Economics
Division
in
the
Resources
and
Environmental
Policy
Branch.
He
received
his
Ph.
D.
in
resource
economics
from
Iowa
State
University
(
Ames)
in
1986.
During
his
16
years
at
USDA,
Dr.
Hansen
has
published
USDA
reports,
spoken
at
profession
meetings,
and
appeared
in
television
and
radio
interviews.

Frank
Hernandez
(
Economist).
Frank
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1991.
He
is
a
staff
economist
at
the
Biological
and
Economic
Analysis
Division
of
the
Office
of
Pesticide
Programs.
He
holds
degrees
in
Economics
and
Political
Science
from
the
City
University
of
New
York.

Arnet
W.
Jones
(
Biologist).
Arnet
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1990.
He
has
had
several
senior
technical
and
management
positions
and
currently
serves
as
Chief
of
the
Herbicide
and
Insecticide
Branch,
Biological
and
Economic
Analysis
Division,
Office
of
Pesticide
Programs.
Prior
to
joining
EPA
he
was
Senior
Agronomist
at
Development
Assistance
Corporation,
a
Washington,
D.
C.
firm
that
specialized
in
international
agricultural
development.
He
holds
a
Master
of
Science
(
Agronomy)
from
the
University
of
Maryland
(
College
Park).

Hong­
Jin
Kim
(
Economist).
Jin
has
been
an
economist
at
the
National
Center
for
Environmental
Economics
at
the
U.
S.
Environmental
Protection
Agency
(
EPA)
since
1998.
His
primary
areas
of
research
interest
include
environmental
cost
accounting
for
private
industries
He
earned
his
Ph.
D.
(
Environmental
and
Resource
Economics)
from
The
University
of
California
(
Davis)
and
holds
a
Master
of
Science
from
the
same
institution.
Dr.
Kim
is
a
1987
graduate
of
Korea
University
(
Seoul)
with
a
Bachelor
of
Arts
(
Economics).
Prior
to
joining
the
U.
S.
EPA,
Dr.
Kim
was
an
assistant
professor
at
the
University
of
Alaska
(
Anchorage)
and
an
economist
at
the
California
Energy
Commissions.
Dr.
Kim
is
the
author
of
numerous
articles
in
the
fields
of
resource
and
environmental
economics.

James
Leesch
(
Biologist).
Jim
has
been
a
research
entomologist
with
the
Agricultural
Resarch
Service
of
the
U.
S.
Department
of
Agriculture
since
1971.
His
main
area
of
interest
is
post­
harvest
commodity
protection
at
the
San
Joaquin
Valle.
He
earned
his
Ph.
D.
(
Entomology/
Insect
Toxicology)
from
The
University
of
California
(
Riverside)
Dr.
Leesch
received
a
B.
A.
degree
in
Chemistry
from
Occidental
College
in
Los
Angeles,
CA
in
1965.
He
is
currently
a
Research
entomologist
for
the
Agricultural
Research
Service
(
USDA)
researching
Agricultural
Sciences
Center
in
Parlier,
CA.
He
joined
ARS
in
June
of
1971.
Page
38
Sean
Lennon
(
Biologist).
Sean
is
a
Biologist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
He
will
receive
his
M.
S.
in
Plant
and
Environmental
Science
in
December
2003
from
Clemson
University
(
Clemson).
Mr.
Lennon
is
a
graduate
of
Georgia
College
&
State
University
(
Milledgeville)
where
he
earned
a
Bachelor
of
Science
(
Biology).
Sean
is
conducting
research
in
Integrated
Pest
Management
of
Southeastern
Peaches.
He
has
eight
years
of
experience
in
the
commercial
peach
industry.

Nikhil
Mallampalli
(
Biologist).
Nikhil
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
2001.
He
is
an
entomologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
and
analysis
of
the
impacts
of
risk
mitigation
on
pest
management.
Dr.
Mallampalli
earned
his
Ph.
D.
(
Entomology)
from
The
University
of
Maryland
(
College
Park)
and
holds
a
Master
of
Science
(
Entomology)
from
the
samr
institution.
Prior
to
joining
the
EPA,
he
worked
as
a
postdoctoral
research
fellow
at
Michigan
State
University
(
East
Lansing)
on
IPM
projects
designed
to
reduce
reliance
on
pesticides
in
small
fruit
production.

Tom
Melton
(
Biologist).
Tom
has
been
a
member
of
the
Plant
Pathology
faculty
at
North
Carolina
State
University
since
1987.
Starting
as
an
assistant
professor
and
extension
specialist,
Tom
has
become
the
Philip
Morris
Professor
at
North
Carolina
State
University.
His
primary
responsibilities
are
to
develop
and
disseminate
disease
management
strategies
for
tobacco.
Dr.
Melton
earned
his
Ph.
D.
(
Plant
Pathology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
(
Pest
Management)
degree
from
North
Carolina
State
University
(
Raleigh).
He
is
a
1978
graduate
of
Norht
Carolina
State
University
(
Raleigh)
Prior
to
joining
the
North
Carolina
State
faculty,
Dr.
Melton
was
a
member
of
the
faculty
at
The
University
of
Illinois
(
Urbana­
Champaign).

Richard
Michell
(
Biologist).
Rich
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1972.
He
is
a
nematologist/
plant
pathologist
in
the
Herbicide
and
Insecticide
Branch
of
the
Biological
and
Economic
Analysis
Division.
His
primary
duties
include
the
assessment
of
pesticide
efficacy
in
a
variety
of
crops,
with
special
emphasis
on
fungicide
and
nematicide
use
and
the
development
of
risk
reduction
options
for
fungicides
and
nematicides.
Dr.
Michell
earned
his
Ph.
D.
(
Plant
Pathology/
Nematology)
from
The
University
of
Illinois
(
Urbana­
Champaign)
and
holds
a
Master
of
Science
degree
(
Plant
Pathology/
Nematology)
from
The
University
of
Georgia
(
Athens).

Lorraine
Mitchell
(
Economist).
Lorraine
has
been
an
agricultural
economist
with
the
U.
S.
Department
of
Agriculture,
Economic
Research
Service
since
1998.
She
works
on
agricultural
trade
issues,
particularly
pertaining
to
consumer
demand
in
the
EU
and
emerging
markets.
Dr.
Mitchell
earned
her
Ph.
D.
(
Economics)
from
The
University
of
California
(
Berkeley).
Prior
to
joining
ERS,
Dr.
Mitchell
was
a
member
of
the
faculty
of
the
School
of
International
Service
of
The
American
University
(
Washington)
and
a
research
assistant
at
the
World
Bank.

Thuy
Nguyen
(
Chemist).
Thuy
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1997,
as
a
chemist
in
the
Office
of
Pesticides
Program.
She
assesses
and
characterizes
ecological
risk
of
pesticides
in
the
environment
as
a
result
of
agricultural
uses.
She
earned
her
degrees
of
Master
of
Science
(
Chemistry)
from
the
University
of
Delaware
and
Bachelor
of
Science
(
Chemistry
and
Mathematics)
from
Mary
Washington
College
(
Fredericksburg,
VA).
Prior
to
joining
the
EPA,
Ms
Nguyen
held
a
research
and
development
scientist
position
at
Sun
Oil
company
in
Marcus
Hook,
Page
39
PA,
then
managed
the
daily
operation
of
several
EPA
certified
laboratories
for
the
analyses
of
pesticides
and
other
organic
compounds
in
air,
water,
and
sediments.

Jack
Norton(
Biologist).
Jack
has
worked
for
the
U.
S.
Department
of
Agriculture
Interregional
research
Project
#
4
(
IR­
4)
as
a
consultant
since
1998.
The
primary
focus
of
his
research
is
the
investigation
of
potential
methyl
bromide
replacement
for
registration
on
minor
crops.
He
is
an
active
member
of
the
USDA/
EPA
Methyl
Bromide
Alternatives
Working
Group.
Dr,
Norton
earned
his
Ph.
D.
(
Horticulture)
from
Texas
A&
M
University
(
College
Station)
and
holds
a
Master
of
Science
(
Horticultural
Science)
from
Oklahoma
State
University(
Stillwater).
He
is
a
graduate
of
Oklahoma
State
University
(
Stillwater).
Prior
to
joining
the
IR­
4
program,
Dr.
Norton
worked
in
the
crop
protection
industry
for
27
years
where
he
was
responsible
for
the
development
and
registration
of
a
number
of
important
products.

Olga
Odiott
(
Biologist)
Olga
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1989.
She
has
held
several
technical
positions
and
currently
serves
as
a
Senior
Biologist
within
the
Office
of
Science
Coordination
and
Policy.
In
this
position
she
serves
as
Designated
Federal
Official
and
liaison
on
behalf
of
the
Office
of
Pesticide
Programs
and
the
FIFRA
Scientific
Advisory
Panel,
an
independent
peer
review
body
that
provides
advice
to
the
Agency
on
issues
concerning
the
impact
of
pesticides
on
health
and
the
environment.
She
holds
a
Masters
of
Science
(
Plant
Pathology)
from
the
University
of
Puerto
Rico
(
San
Juan).
Prior
to
joining
EPA,
Ms.
Odiott
worked
for
the
U.
S.
Department
of
Agriculture.

Craig
Osteen(
Economist).
Craig
has
been
with
the
U.
S.
Department
of
Agriculture
for
over
20
years.
He
currently
is
with
the
Economic
Research
Service
in
the
Production
Management
and
Technology
Branch,
Resource
Economics
Division.
He
primary
areas
of
interest
relate
to
issues
of
pest
control,
including
pesticide
regulation,
integrated
pest
management,
and
the
methyl
bromide
phase
out.
Dr.
Osteen
earned
his
Ph.
D.
(
Natural
Resource
Economics)
from
Michigan
State
University
(
East
Lansing).

Elisa
Rim
(
Economist).
Elisa
is
an
Agricultural
Economist
interning
with
the
Office
of
Pesticide
Programs
of
the
U.
S.
Environmental
Protection
Agency.
She
earned
her
Master
of
Science
(
Agricultural
Economics)
from
The
Ohio
State
University
(
Columbus)
and
holds
a
Bachelor
of
Arts
(
Political
Science)
from
the
same
institution.
She
has
conducted
research
in
environmental
economics
and
developed
a
cost
analysis
optimization
model
for
stream
naturalization
projects
in
northwest
Ohio.

Erin
Rosskopf
(
Biologist).
Erin
received
her
PhD
from
the
Plant
Pathology
Department,
University
of
Florida,
Gainesville
in
1997.
She
is
currently
a
Research
Microbiologist
with
the
USDA,
ARS
and
has
served
in
this
position
for
5
years.

Carmen
L.
Sandretto
(
Agricultural
Economist).
Carmen
has
been
with
the
Economic
Research
Service
of
the
U.
S.
Department
of
Agriculture
for
over
30
years
in
a
variety
of
assignments
at
several
field
locations,
and
since
1985
in
Washington,
DC.
He
has
worked
on
a
range
of
natural
resource
economics
issues
and
in
recent
years
on
soil
conservation
and
management,
pesticide
use
and
water
quality,
and
small
farm
research
studies.
Mr.
Sandretto
holds
a
Master
of
Arts
degree
Page
40
(
Economics)
from
Harvard
University
(
Cambridge)
and
a
Master
of
Science
(
Agricultural
Economics)
from
The
University
of
Wisconsin
(
Madison).
Mr
Sandretto
is
a
graduate
of
Michigan
State
University
(
East
Lansing).
Prior
to
serving
in
Washington,
D.
C.
he
was
a
member
of
the
economics
faculty
at
Michigan
State
University
and
at
the
University
of
New
Hampshire
(
Durham).

Judith
St.
John
(
Biologist).
Judy
has
been
with
the
USDA's
Agricultural
Research
Service
since
1967.
She
currently
serves
as
Associate
Deputy
Administrator
and
as
such
she
is
responsible
for
the
Department's
intramural
research
programs
in
the
plant
sciences,
including
those
dealing
with
pre­
and
post­
harvest
alternatives
to
methyl
bromide.
Dr.
St.
John
earned
her
Ph.
D.
(
Plant
Physiology)
from
The
University
of
Florida
(
Gainesville).

James
Throne
(
Biologist).
Jim
is
a
Research
Entomologist
with
the
U.
S.
Department
of
Agriculture's
Agricultural
Research
Service
and
Research
Leader
of
the
Biological
Research
Unit
at
the
Grain
Marketing
and
Production
Research
Center
in
Manhattan,
Kansas.
He
conducts
research
in
insect
ecology
and
development
of
simulation
models
for
improving
integrated
pest
management
systems
for
stored
grain
and
processed
cereal
products.
Other
current
areas
of
research
include
investigating
seed
resistance
to
stored­
grain
insect
pests
and
use
of
near­
infrared
spectroscopy
for
detection
of
insect­
infested
grain.
Jim
has
been
with
ARS
since
1985.
Dr.
Throne
earned
his
Ph.
D.
(
Entomology)
in
1983
from
Cornell
University
(
Ithaca)
and
earned
a
Master
of
Science
Degree
(
Entomology)
in
1978
from
Washington
State
University
(
Pullman).
Dr.
throne
is
a
1976
graduate
(
Biology)
of
Southeastern
Massachusetts
University
(
N.
Dartmouth).

Thomas
J.
Trout
(
Agricultural
Engineer).
Tom
has
been
with
the
U.
S.
Department
of
Agriculture,
Agricultural
Research
Service
since
1982.
He
currently
serves
ar
research
leader
in
the
Water
Management
Research
Laboratory
in
Fresno,
CA.
His
present
work
includes
studying
factors
that
affect
infiltration
rates
and
water
distribution
uniformity
under
irrigation,
determining
crop
water
requirements,
and
developing
alternatives
to
methyl
bromide
fumigation.
Dr.
Trout
earned
his
Ph.
D.
(
Agricultural
Engineering)
from
Colorado
State
University
(
Fort
Collins)
and
holds
a
Master
of
Science
degree
from
the
same
institution,
also
in
agricultural
engineering.
Dr.
Trout
is
a
1972
graduate
of
Case
Western
Reserve
University
(
Cleveland)
with
a
degree
in
mechanical
engineering.
Prior
to
joining
the
ARS,
Dr.
trout
was
a
member
of
the
engineering
faculty
of
Colorado
State
University
(
Fort
Collins).
He
is
the
author
of
numerous
publications
on
the
subject
of
methyl
bromide
alternatives.

J.
Bryan
Unruh
(
Biologist).
Bryan
is
Associate
Professor
of
Environmental
Horticulture
at
The
University
of
Florida
(
Milton)
and
an
extension
specialist
in
turfgrass.
He
leads
the
statewide
turfgrass
extension
design
team.
Dr.
Unruh
earned
his
Ph.
D.
(
Horticulture)
from
Iowa
State
University
(
Ames)
and
holds
a
Master
of
Science
degree
(
Horticulture)
from
Kansas
State
University
(
Manhattan).
He
is
a
1989
graduate
of
Kansas
State
University.

David
Widawsky
(
Chief,
Economic
Analysis
Branch).
David
has
been
with
the
U.
S.
Environmental
Protection
Agency
since
1998.
He
has
also
served
as
an
economist
and
a
team
leader.
As
branch
chief,
David
is
responsible
for
directing
a
staff
of
economists
to
conduct
economic
analyses
in
support
of
pesticide
regulatory
decisions.
He
earned
his
Ph.
D.
(
Development
and
Applied
Economics)
from
Stanford
University
(
Palo
Alto),
and
a
Master
of
Science
(
Agricultural
Economics)
from
Colorado
State
University
(
Fort
Collins).
Dr.
Widawsky
is
a
1987
Page
41
graduate
(
Plant
and
Soil
Biology,
Agricultural
Economics)
of
the
University
of
California
(
Berkeley).
Prior
to
joining
EPA,
Dr.
Widawsky
conducted
research
on
the
economics
of
integrated
pest
management
in
Asian
rice
production,
while
serving
as
an
agricultural
economist
at
the
International
Rice
Research
Institute
(
IRRI)
in
the
Philippines.

TJ
Wyatt
(
Economist).
TJ
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
2001.
He
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
and
benefits
of
pesticide
regulation.
His
other
main
area
of
research
is
farmer
decision­
making,
especially
pertaining
to
issues
of
soil
fertility
and
soil
conservation
and
of
pesticide
choice.
Dr.
Wyatt
earned
his
Ph.
D.
(
Agricultural
Economics)
from
The
University
of
California
(
Davis).
Dr.
Wyatt
holds
a
Master
of
Science
(
International
Agricultural
Development)
from
the
same
institution.
He
is
a
1985
graduate
of
The
University
of
Wyoming
(
Laramie).
Prior
to
joining
the
EPA,
he
worked
at
the
International
Crops
Research
Institute
for
the
Semi­
Arid
Tropics
(
ICRISAT)
and
was
based
at
the
Sahelian
Center
in
Niamey,
Niger.

Leonard
Yourman
(
Biologist).
Leonard
is
a
plant
pathologist
with
the
Biological
and
Economic
Analysis
Division
of
the
U.
S.
Environmental
Protection
Agency.
He
currently
conducts
assessments
of
pesticide
use
as
they
relate
to
crop
diseases
He
earned
his
Ph.
D.
(
Plant
Pathology)
from
Clemson
University
(
Clemson)
and
holds
a
Master
of
Science
(
Horticulture/
Plant
Breeding)
from
Texas
A&
M
University
(
College
Station).
Dr.
Yourman
is
a
graduate
(
English
Literature)
of
The
George
Washington
University
(
Washington,
DC).
.
Prior
to
joining
EPA,
he
conducted
research
on
biological
control
of
invasive
plants
with
USDA
at
the
Foreign
Disease
Weed
Science
Research
Unit
(
Ft.
Detrick,
MD).
He
has
also
conducted
research
on
biological
control
of
post
harvest
diseases
of
apples
and
pears
at
the
USDA
Appalachian
Fruit
Research
Station
(
Kearneysville,
WV).
Research
at
Clemson
University
concerned
the
molecular
characterization
of
fungicide
resistance
in
populations
of
the
fungal
plant
pathogen
Botrytis
cinerea.

Istanbul
Yusuf
(
Economist).
Istanbul
has
been
with
the
U.
S
.
Environmental
Protection
Agency
since
1998.
She
serves
in
the
Office
of
Pesticide
Programs
analyzing
the
costs
imposed
by
the
regulation
of
pesticides.
She
earned
her
Master=
s
degree
in
Economics
from
American
University
(
Washington).
Ms
Yusuf
is
a
1987
graduate
of
Westfield
State
College
(
Westfield)
with
a
Bachelor
of
Arts
in
Business
Administration.
Prior
to
joining
EPA
Istanbul
worked
for
an
International
Trading
Company
in
McLean,
Virginia.

Appendix
D:
CHARTS
Charts
1
and
2
attached
as
separate
electronic
file
