1
2003
NOMINATION
FOR
A
CRITICAL
USE
EXEMPTION
FOR
STRAWBERRIES
FROM
THE
UNITED
STATES
OF
AMERICA
1.
Introduction
In
consultation
with
the
co­
chair
of
the
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
strawberries,
like
the
nomination
for
all
other
crops
included
in
the
U.
S.
request,
includes
general
background
information
that
the
U.
S.
believes
is
critical
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
strawberries
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,
but
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.

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.
2
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
strawberries,
following
detailed
technical
and
economic
review,
the
U.
S.
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
growing
strawberries
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
toxic,
and
some
may
pose
risks
to
human
health
or
the
environment
that
are
even
greater
than
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
toxicity
and
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
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
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
3
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
U.
S.
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
growers
across
the
U.
S.
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.

5.
Overview
of
Agricultural
Production
5a.
U.
S.
Agriculture
The
U.
S.
is
fortunate
to
have
a
large
land
expanse,
productive
soils
and
a
variety
of
favorable
agricultural
climates.
These
factors
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.
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
have
had
an
important
impact
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.
4
Other
factors
also
affected
the
general
development
of
agriculture
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.
developed
a
unique
brand
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
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
area
planted
in
fruits
and
vegetables
has
remained
stable
and
individual
farm
size
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
pesticides,
and
drip
irrigation,
as
well
as
improved
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.
U.
S.
Strawberry
Production
Strawberries
are
an
extremely
important
crop
in
the
U.
S.
In
terms
of
the
value
of
production,
strawberries
are
the
fourth
highest
fruit
crop.
Although
strawberries
are
one
of
the
most
expensive
crops
for
growers
to
produce,
with
total
costs
per
hectare
exceeding
US$
37,000,
the
high
value
per
hectare
for
harvested
strawberries
typically
makes
the
investment
worthwhile
to
the
grower.
In
the
eastern
U.
S.
and
Florida
the
primary
pest
problems
are
nematodes
and
perennial
and
annual
weeds.
In
the
western
U.
S.
the
primary
pest
problems
are
disease
and
nematodes.

U.
S.
strawberry
production
exemplifies
many
of
the
characteristics
of
U.
S.
agriculture
noted
above.
First,
the
strawberry
industry
is
large
in
the
United
States
­
in
dollar
terms,
it
is
about
a
billion
dollar
a
year
industry.
Second,
like
many
other
U.
S.
crops,
it
has
a
significant
export
component.
Third,
it
relies
on
mechanized
production
practices.
Strawberries
are
widely
grown
in
the
U.
S.
with
several
major
production
centers
that
differ
significantly
in
soil
and
climatic
conditions.
This
nomination
covers
methyl
bromide
use
in
three
major
strawberry
production
areas
 
California,
Florida,
and
states
in
the
southeastern
U.
S.

California.
California
produces
more
than
80
percent
of
the
fresh
market
and
processed
strawberries
grown
in
the
U.
S.
Productivity
is
very
high
(
only
50
percent
of
the
total
U.
S.
strawberry
area
is
in
California).
Bearing
strawberries
are
grown
on
approximately
8,900
to
10,100
hectares
per
year
in
California
with
an
average
production
of
680,400,000
kilograms
and
an
estimated
annual
value
of
US$
5
750
million.
California
produces
about
20
percent
of
the
world's
strawberries.
Most
strawberries
exported
from
California
go
to
Canada,
Japan,
and
Mexico.

California
has
two
distinct
strawberry
production
areas.
The
southern
region
produces
both
fresh
(
63
percent)
and
processed
(
37
percent)
strawberries.
The
northern
region
includes
both
rotated
and
non­
rotated
strawberry
production
regimes,
with
each
producing
fresh
(
84
percent)
and
processed
(
16
percent)
strawberries.
The
majority
of
growers
are
farming
between
4
and
20
hectares
of
land
with
strawberry
fields
in
rotation.
Because
strawberry
production
in
California
is
concentrated
in
a
small
geographic
location
due
to
optimal
growing
conditions,
factors
that
affect
this
small
area
can
be
significant.
An
example
of
this,
which
is
discussed
later
in
this
chapter,
is
the
regulatory
limit
on
the
amount
of
1,3­
dichloropropene
(
Telone)
that
can
be
used
in
each
township
(
i.
e.,
36
square
mile
area,
approximately
95
square
km)
in
California.

California
strawberry
producing
operations
are
mostly
in
either
the
largest
or
the
smallest
sales
category.
The
largest
farms
(
more
than
US$
500,000
in
sales)
averaged
98
hectares
of
cropland
and
the
smallest
(
less
than
US$
10,000
in
sales)
averaged
only
1.6
hectares
of
cropland.
There
is
a
wide
range
in
size
of
strawberry
production
areas
on
U.
S.
farms,
varying
from
and
average
of
32
hectares
for
the
large
farms
to
0.8
hectares
for
the
smallest
farms.

Depending
on
the
region,
California
strawberries
are
planted
in
the
Summer
or
Fall.
Prior
to
planting,
fumigation
is
typically
performed
on
flat
ground
over
the
entire
surface
of
the
field.
Immediately
after
fumigation
the
field
is
covered
with
plastic.
At
the
end
of
the
fumigation
period,
the
plastic
is
removed
and
planting
beds
are
formed
and
covered
with
fresh
plastic.
Strawberry
plants
are
transplanted
about
two
weeks
after
fumigation
to
ensure
that
no
phytotoxic
levels
of
methyl
bromide
remain.
Harvest
begins
about
2
to
3
months
later.
At
the
end
of
the
first
harvest,
the
strawberry
plants
are
removed
and
the
field
is
readied
for
the
next
crop.
Rotational
crops
that
are
planted
after
strawberries,
and
that
benefit
from
the
previous
use
of
methyl
bromide
include
broccoli,
celery,
lettuce,
radish,
leeks,
and
artichokes.

Florida.
Florida
is
the
second
largest
strawberry
producing
state
with
12
percent
of
the
total
U.
S.
production.
Nearly
all
of
the
domestically
produced
strawberries
harvested
in
the
winter
are
grown
in
Florida.
Approximately
2,428
hectares
are
in
production
each
year
in
Florida
resulting
in
76,204,800
kilograms
of
fresh
berries
valued
in
excess
of
US$
118.6
million.

Approximately
90
percent
of
Florida's
commercial
strawberry
production
area
is
located
in
Hillsborough
County
with
the
remainder
in
several
other
counties.
Like
those
in
California,
the
Florida
strawberry
producing
operations
are
mostly
in
either
the
largest
or
the
smallest
sales
category.
The
largest
farms
(
more
than
US$
500,000
in
sales)
averaged
160
hectares
of
total
cropland
and
the
smallest
(
less
than
US$
10,000
in
sales)
averaged
only
1.2
hectares
of
total
cropland.
The
area
in
strawberries
averaged
20
hectares
for
the
large
farms
and
0.8
hectares
for
the
smallest
farms.

Strawberries
are
grown
as
an
annual
crop
in
Florida
using
a
raised­
bed
system.
Methyl
bromide
in
combination
with
chloropicrin
is
applied
to
the
soil
during
construction
of
the
raised­
beds
approximately
two
weeks
prior
to
planting
transplants.
Immediately
after
application,
the
bed
is
covered
with
plastic
mulch.
Drip
or
overhead
irrigation
is
used
to
help
establish
plants,
irrigate
plants,
and
to
protect
the
plants
from
frost.
Many
strawberry
growers
utilize
the
beds
and
drip
tubes
to
grow
a
second
crop,
such
as
cucurbits
or
solanaceous
crops.
6
Eastern
U.
S.
The
Eastern
U.
S.
strawberry
industry
is
highly
de­
centralized
and
primarily
consists
of
small
family
farms
with
several
hectares
of
strawberries
that
are
directly
marketed
through
U­
pick,
ready­
pick,
roadside
stands,
and
farmers
markets.
Approximately
90
percent
of
the
farms
are
less
than
4
hectares.
The
farmgate
value
of
the
36,665,088
kilograms
of
strawberries
sold
by
farmers
in
the
nine
eastern
states
represented
is
approximately
US$
83
million.

Strawberry
production
in
the
eastern
states
differs
from
that
in
Florida
because
of
soils
type
(
Florida
typically
has
sandy
soils;
eastern
soils
are
heavier);
topography
(
Florida
has
much
karst
topography;
much
less
common
in
other
states),
climate
(
very
mild
winters
in
Florida),
farm
size
(
farms
are
larger
in
Florida),
and
marketing
practices
(
Florida
is
typically
commercial
compared
to
small
U­
pick
operations).
In
the
Eastern
U.
S.,
the
vast
majority
of
the
strawberry
farms
use
an
annual
cropping
plasticulture
production
system
where
the
berries
are
grown
on
raised
beds,
similar
to
Florida
strawberry
production.
Planting
time
is
similar
to
Florida,
but
the
production
peak
occurs
later
in
the
season,
between
April
and
May.
The
texture
of
about
50
percent
of
the
soils
is
finer
than
sandy
loam.
Nutsedge
is
a
primary
pest
on
about
40
percent
of
the
land
which
typically
has
coarse­
textured
soils.
Some
double
cropping
of
beds
occurs.

Given
the
value
of
strawberries,
the
U.
S.
put
a
great
deal
of
effort
into
researching
this
sector
and
into
preparing
this
nomination
for
a
critical
use
exemption
for
those
areas
for
which
alternatives
to
methyl
bromide
are
not
currently
available.

6.
Results
of
Review
­
Determined
Need
for
Methyl
Bromide
in
the
Production
of
Strawberry
6a.
Target
Pests
Controlled
with
Methyl
Bromide
U.
S.
strawberry
production
is
affected
by
a
large
number
of
pests.
Pests
of
particular
concern
include
black
root
rot
(
Rhizoctonia
and
Pythium
spp.),
crown
rot
(
Phytophthora
cactorum),
root
knot
nematode
(
Meloidogyne
spp.),
sting
nematode
(
Belonolaimus
spp.),
yellow
nutsedge
(
Cyperus
esculentus),
purple
nutsedge
(
Cyperus
rotundus),
ryegrass,
and
winter
annual
weeds.

The
prevalence
and
the
severity
of
these
pests
differ
significantly
between
growing
regions
and
depend
on
local
environmental
conditions.
For
example,
nematode
pressure
may
be
more
severe
in
sandy
soils
and
plant
diseases
are
likely
to
occur
more
frequently
in
humid
environments.
In
California,
diseases
such
as
phytophthora,
rhizoctonia,
and
pythium;
nematodes
such
as
sting
and
rootknot;
and
weeds
such
as
common
purslane,
chickweed,
mallow,
and
stinging
nettle
are
the
most
severe
pests.
In
Florida,
the
key
diseases
are
black
root
rot,
fruit
and
crown
rot;
the
key
nematodes
are
sting
and
rootknot,
and
key
weeds
are
purple
and
yellow
nutsedge,
ryegrass,
anthracnose,
and
phytophthora.
In
the
eastern
U.
S.
states,
the
key
diseases
are
black
root
rot;
root
knot
is
the
key
nematode
pest;
and
purple
and
yellow
nutsedge
are
the
key
weed
pests.

Nutsedge.
Yellow
and
purple
nutsedge
(
Cyperus
spp.)
pressure
is
much
greater
in
Florida
and
the
eastern
states
than
in
California.
Yellow
nutsedge
(
Cyperus
esculentus
L.)
and
purple
nutsedge
Cyperus
rotundus
L.)
are
perennial
species
of
the
Cyperacea
family
that
are
widely
recognized
for
their
economic
impact
in
agriculture.
Purple
nutsedge
is
considered
the
worst
weed
in
the
world
due
to
its
widespread
distribution
and
difficult
control
(
Holm
et
al.
1977).
Nutsedge
is
considered
a
weed
in
at
least
92
countries
and
is
reported
to
be
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
the
coastal
southern
U.
S.
and
along
the
Pacific
coast
in
California
and
Oregon.
A
7
survey
conducted
in
Georgia
ranked
the
nutsedge
as
the
most
troublesome
weeds
in
vegetable
crops
(
there
are
more
30
vegetable
crops
grown
in
Georgia)
(
Webster
et
al.
2001).

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
reduce
crop
yields
at
low
plant
densities.

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

6b.
Overview
of
Technical
and
Economic
Assessment
of
Alternatives
Strawberry
growers
rely
on
fumigation
with
methyl
bromide/
chloropicrin
within
the
full­
bed,
plastic
mulch
production
system
to
control
soil
borne
diseases
and
pests.
There
has
been
extensive
research
on
alternatives
for
the
sector,
and
where
possible,
many
alternatives
and/
or
useful
cultural
practices
have
been
incorporated
into
the
standard
practices
used
in
the
sector.
However,
the
effectiveness
of
chemical
and
non­
chemical
alternatives
designed
to
fully
replace
methyl
bromide
must
still
be
characterized
as
uncertain.
These
alternatives
have
not
been
shown
to
be
stand­
alone
replacements
for
methyl
bromide.
Methyl
bromide
is
believed
to
be
the
only
treatment
currently
available
that
consistently
provides
reliable
control
of
nutsedge
species
and
the
disease
complex
affecting
strawberry
production.

Hand
Weeding.
This
practice
is
not
technically
feasible
in
strawberries
because
of
the
reproductive
strategy
of
some
difficult
to
control
perennial
weeds
such
as
nutsedge.
Sedges
reproduce
through
below
ground
tubers
or
nutlets.
When
a
sedge
plant
is
removed
by
hand
the
10
to
30
tubers,
which
grow
2
to
30
cm
(
1
to
12
inches)
below
ground,
will
rapidly
produce
new
plants.
Therefore,
hand
weeding
can
lead
to
a
rapid
10­
to
30­
fold
increase
in
weeds.
In
addition,
those
sedges
that
germinate
under
the
plastic
mulch
cannot
be
removed
by
hand
without
damaging
the
plastic
and
reducing
its
effectiveness
in
excluding
weeds,
insects,
and
pathogens.

Hand
weeding
strawberries
is
not
a
desirable
practice
for
controlling
nutsedge.
First,
it
is
feasible
only
in
the
bare
ground
between
rows
of
plants
which
are
in
plastic
mulch.
But
more
importantly,
hand
weeding
may
actually
exacerbate
the
weed
problem.
The
practice
may
seem
effective
in
the
short
term,
but
is
extremely
risky
and
can
significantly
compromise
the
viability
of
a
strawberry
field.
Hand
weeding
nutsedge
is
likely
to
produce
a
large
number
of
small
pieces
of
underground
reproductive
structures.
These
structures
are
capable
of
emerging
later
as
individual
plants
resulting
in
a
nutsedge
infestation
greater
in
magnitude
than
the
original
problem.
Ironically,
then,
hand
weeding
strawberry
fields
can
produce
a
cascading
effect
which
results
in
progressively
worse
nutsedge
infestations
over
time
8
6c.
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
Table
1
presents
a
list
of
the
"
in­
kind"
methyl
bromide
alternatives
identified
by
the
MBTOC
for
strawberry
fruit
production.

Table
1.
In­
kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Strawberry
Fruit
Production.
Methyl
Bromide
Alternatives
Technically
Feasible
Economically
Feasible
1,3­
Dichloropropene
(
1,3­
D,
Telone
)
No
No
1,3­
Dichloropropene/
Chloropicrin
Yes*
Yes**
1,3­
Dichloropropene/
Chloropicrin/
Metam­
sodium
Yes*
Yes**

Basamid
Not
registered
for
use
in
U.
S.
Basamid/
Chloropicrin
Not
registered
for
use
in
U.
S.
Chloropicrin
No
No
Metam­
sodium
No
No
Metam­
sodium/
Chloropicrin
No
No
Methyl
Iodide
Not
registered
for
use
in
U.
S.

*
These
alternatives
are
technically
feasible
only
in
areas
of
light
nutsedge
infestation.
**
These
alternatives
are
economically
feasible
only
in
areas
of
light
nutsedge
infestation.

1,3­
Dichloropropene
(
1,3­
D,
Telone).
1,3­
Dichloropropene,
by
itself,
is
not
a
technically
feasible
alternative
because
it
does
not
control
nutsedge
and
other
weeds.
It
does
however,
provide
good
nematode
control
and
moderate
control
of
some
diseases.
The
use
of
this
chemical
would
require
application
of
a
fungicide
and
a
herbicide
that
is
effective
for
nutsedge
to
reach
the
same
level
of
control
that
is
provided
by
methyl
bromide.
Failure
to
control
the
primary
fungal
pathogens
and
weed
seeds
in
the
soil
would
most
likely
lead
to
increased
disease
and
weed
pressure
over
time.

Requirements
for
buffers
and
Personal
Protective
Equipment
(
PPE)
may
make
it
impractical
to
adopt
1,3­
dichloropropene.
The
91
meter
(
300
feet)
buffer
requirement
would
be
particularly
constraining
on
smaller
fields
in
predominantly
urban
fringe
areas.
For
small
strawberry
farms
in
the
Eastern
U.
S.,
the
1,3­
dichloropropene
buffer
requirements
eliminate
a
great
amount
of
the
area
around
the
field
perimeter
which
impacts
the
total
area
available
for
strawberry
production.
Additionally,
the
1,3­
dichloropropene
PPE
requirements
(
which
include
protective
suits)
limit
the
operations
that
require
workers
to
be
in
the
field.
The
hot
and
humid
weather
in
Florida
and
other
southern
states
presents
a
health
risk,
from
possible
heat
exhaustion
and
heat
stroke,
to
field
workers
when
they
are
wearing
all
of
the
required
PPE.

Other
constraints
on
the
use
of
1,3­
dichloropropene
include
increased
pre­
planting
intervals.
The
reason
for
increased
pre­
planting
intervals
is
that
1,3­
dichloropropene
persists
longer
in
the
soil
than
methyl
bromide
and
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
transplants
in
the
ground.
This
forces
growers
to
delay
planting
and
to
modify
and/
or
extend
their
production
schedule
which
ultimately
has
a
cascading
effect
on
other
things
such
as
cultivar
options,
Integrated
Pest
Management
(
IPM)
practices,
timing
of
fruit
harvest,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
Growers
that
lease
land
for
rotation
into
vegetable
production
could
experience
extra
expenditures
for
land
rent,
shorter
intervals
between
9
crops
that
may
make
it
impossible
to
practice
crop
rotation,
and
a
yield
and/
or
quality
reduction
in
the
vegetable
crops
that
are
produced.

In
California,
1,3­
dichloropropene
is
not
being
used
alone
and
is
not
considered
technically
feasible
because
it
does
not
adequately
control
diseases
and
weeds.
Research
with
1,3­
dichloropropene
in
California
has
primarily
been
performed
in
combination
with
other
fumigant
chemicals.
Hence,
there
is
limited
strawberry
yield
data
available
for
use
of
1,3­
dichloropropene
alone.
Research
results
indicate
that
the
use
of
registered
rates
of
1,3­
dichloropropene
result
in
yield
losses
that
can
be
as
high
as
35
percent
of
those
resulting
when
a
combination
of
methyl
bromide
and
chloropicrin
is
used.
When
higher,
unregistered
rates
of
1,3­
dichloropropene
were
used
in
research
trials,
the
yield
loses
decreased
to
11
percent.
Shank
applied
1,3­
dichloropropene
requires
a
30
meter
(
100
feet)
buffer
zone
the
first
year
it
is
applied,
and
a
91
meter
(
300
foot)
buffer
zone
for
the
next
two
years.
Also,
in
California,
the
use
of
this
product
in
strawberry
production
areas
is
limited
because
of
the
state
regulations
regarding
township
caps,
as
previously
described
above.
Regulatory
constraints
on
1,3­
dichloropropene
products
impact
approximately
two­
thirds
of
California's
strawberry
production
area
when
this
product
is
not
available
as
an
alternative
fumigant.

In
Florida
and
in
other
eastern
states,
1,3­
dichloropropene
alone
is
not
technically
feasible
because
it
does
not
provide
effective
control
of
disease
and
nutsedge.
In
Florida
use
of
1,3­
dichloropropene
is
prohibited
in
areas
characterized
by
karst
topography
because
of
potential
drinking
water
contamination.
In
other
eastern
states
that
have
a
preponderance
of
small
strawberry
fields,
the
regulatory
requirements
for
buffers
for
1,3­
dichloropropene
means
that
only
a
small
portion
of
a
farm's
central
area
can
be
used,
since
buffer
requirements
establish
such
a
large
perimeter
(
90
percent
of
the
farms
are
smaller
than
4
hectares).

1,3­
Dichloropropene/
Chloropicrin.
The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances.
1,3­
dichloropropene
is
used
primarily
as
a
nematicide,
and
chloropicrin
supplies
good
disease
control,
but
poor
nematode
and
weed
control.
Together,
the
combination
of
1,3­
dichloropropene
and
chloropicrin
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds
such
as
nutsedge.

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
transplants
in
the
ground.
The
PPE
and
buffer
concerns
mentioned
above
for
the
use
of
1,3­
dichloropropene
alone
are
magnified
when
chloropicrin
is
added
to
the
fumigation
process.
The
same
buffer
and
PPE
issues
exist,
but
growers
have
an
even
longer
planting
delay
of
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
IPM
practices,
timing
of
fruit
harvest,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
As
previously
mentioned,
growers
that
lease
land
for
rotation
into
vegetable
production
could
experience
extra
expenditures
for
land
rent,
shorter
intervals
between
crops
that
may
make
it
impossible
to
practice
crop
rotation,
and
yield
and/
or
quality
reduction
in
the
vegetable
crops
that
are
produced.

California
This
alternative
is
being
used
in
California
on
a
limited
basis
and
is
technically
feasible
provided
that
an
adequate
means
of
weed
control
is
used
in
addition
to
this
chemical
combination.
Weed
control
with
combinations
of
1,3­
dichloropropene
and
chloropicrin
was
improved
with
use
of
VIF
(
virtually
impermeable
film)
in
combination
with
InLine,
an
emulsified
formulation
of
1,3­
10
dichloropropene
plus
chloropicrin.
However,
this
combination
does
not
control
weeds
in
the
row
centers
and
failure
to
control
weed
seeds
in
soil
is
likely
to
increase
weed
pressure
over
time.
There
have
also
been
reports
of
phytotoxicity
on
strawberry
observed
with
use
of
the
InLine
formulation.
Yield
estimates
based
on
research
results
from
IR­
4
trials
on
strawberries
in
California
with
InLine
did
not
differ
from
yields
obtained
with
a
combination
of
methyl
bromide
and
chloropicrin.
Based
on
these
results,
a
yield
loss
is
not
anticipated
with
use
of
this
chemical
combination
under
similar
pest
conditions.

Buffer
requirements,
longer
pre­
plant
intervals,
and
PPE
requirements
for
1,3­
D
make
using
1,3­
D
infeasible
for
growers
in
some
circumstances.
Shank
applied
1,3­
dichloropropene
requires
a
30
meter
(
100
feet)
buffer
zone
the
first
year
it
is
applied,
and
a
91
meter
(
300
feet)
buffer
zone
for
the
next
two
years.
Also,
in
California,
the
use
of
this
product
in
strawberry
production
areas
is
limited
because
of
the
state
regulations
regarding
township
caps,
as
previously
described
above.
Regulatory
constraints
on
1,3­
dichloropropene
products
impact
approximately
two­
thirds
of
California's
strawberry
production
areas
when
this
product
is
not
available
as
an
alternative
fumigant.

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
228
kilograms
per
hectare
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
reported
concerns
about
eye
and
lung
irritation
when
applying
chloropicrin.

Florida
The
combination
of
1,3­
dichloropropene
and
chloropicrin
is
already
being
used
in
Florida
on
a
limited
basis
and
is
technically
feasible
in
areas
of
light
nutsedge
pressure.
However,
it
is
probable
that
extensive
hand
weeding
would
be
necessary
in
areas
with
high
nutsedge
pressure,
and,
as
discussed
above,
although
hand­
weeding
can
suppress
nutsedge
in
the
short­
term,
over
the
longer
term
it
is
likely
to
severely
increase
the
nutsedge
pressure
as
the
plant
proliferate
from
the
reproductive
material
left
behind.
Data
associated
with
1,3­
dichloropropene
and
chloropicrin
combinations
show
a
range
of
yield
loses
from
0
percent
to
25
percent
compared
to
strawberry
fruit
production
using
methyl
bromide.

Additionally,
this
alternative
is
not
being
extensively
used
in
Florida
because
of
the
concerns
with
buffers,
PPE
requirements,
and
pre­
planting
intervals.
Also,
use
of
1,3­
dichloropropene
in
Florida
is
prohibited
in
areas
characterized
by
karst
topography
because
of
groundwater
contamination.
Research
suggests
that
when
chloropicrin
is
mixed
with
other
chemicals
at
a
level
higher
than
35
percent
and
applied
at
typical
rates,
it
can
increase
vegetative
growth
at
the
expense
of
strawberry
fruit
production.
When
1,3­
dichloropropene
is
used
in
combination
with
chloropicrin,
growers
experience
limited
flexibility
in
scheduling
fumigation
operations.
This
is
very
important
in
Florida
where
rain
storms
can
deposit
too
much
water
on
the
strawberry
beds
or
completely
wash
out
the
beds.
This
causes
delays
in
fumigation
and
planting.
Growers
may
be
forced
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.
11
Eastern
U.
S.
1,3­
Dichloropropene
and
chloropicrin
combinations
are
already
being
used
in
the
Eastern
U.
S.
on
a
limited
basis.
This
combination,
however,
is
technically
feasible
only
where
nutsedge
is
not
prevalent,
which
is
approximately
60
percent
of
the
area.
Therefore,
an
effective
companion
herbicide
is
needed
for
the
remaining
40
percent
where
nutsedge
is
a
problem.
The
yield
loss
estimate
associated
with
1,3­
dichloropropene/
chloropicrin
combinations
is
typically
5
percent,
with
a
range
from
0
percent
to
60
percent
compared
to
strawberry
fruit
production
with
methyl
bromide.
The
eastern
U.
S.
growers
can
also
experience
the
same
weather
related
delays
and
concerns
as
the
growers
in
Florida.

1,3­
Dichloropropene/
Chloropicrin/
Metam­
sodium.
The
combination
of
1,3­
dichloropropene,
chloropicrin
and
metam­
sodium
is
deemed
to
be
a
technically
feasible
alternative
to
methyl
bromide,
requiring
a
companion
herbicide
(
or
hand
weeding).
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.
The
combination
of
the
three
chemicals
would
still
require
a
companion
herbicide
(
or
hand
weeding).

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
transplants
in
the
ground.
The
concerns
mentioned
above
for
the
combined
use
of
1,3­
dichloropropene
and
chloropicrin
are
magnified
when
metam­
sodium
is
added
to
the
fumigation
process.
The
same
buffer
and
PPE
issues
exist,
but
growers
have
a
greater
planting
delay
for
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
IPM
practices,
timing
of
fruit
harvest,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
As
previously
mentioned,
growers
that
lease
land
for
rotation
into
vegetable
production
could
experience
extra
expenditures
for
land
rent,
shorter
intervals
between
crops
that
may
make
it
impossible
to
practice
crop
rotation,
and
yield
and/
or
quality
reduction
in
the
vegetable
crops
that
are
produced.
Also,
this
combination
would
be
subject
to
all
of
the
regulatory
issues
previously
mentioned
for
1,3­
dichloropropene
and
chloropicrin,
such
as
township
caps
in
California
and
buffers
and
PPE
restrictions.

California.
The
combination
of
1,3­
dichloropropene,
chloropicrin
and
metam­
sodium
is
not
being
used,
but
is
technically
feasible.
Yield
loss
estimates
based
on
research
results
from
IR­
4
trials
performed
on
strawberries
in
California
with
InLine
(
1,3­
dichloropropene
+
chloropicrin),
and
an
additional
application
of
metam
sodium,
did
not
differ
from
yields
obtained
with
a
combination
of
methyl
bromide
and
chloropicrin.
Based
on
these
results,
a
yield
loss
is
not
anticipated
with
use
of
this
chemical
combination
under
similar
pest
conditions.

Buffer
requirements,
longer
pre­
plant
intervals,
and
PPE
requirements
for
1,3­
dichloropropene
make
using
this
alternative
infeasible
for
growers
in
some
circumstances.
Shank
applied
1,3­
dichloropropene
requires
a
30
meter
(
100
feet)
buffer
zone
the
first
year
it
is
applied,
and
a
91
meter
(
300
feet)
buffer
zone
for
the
next
two
years.
Also,
in
California,
the
use
of
this
product
in
strawberry
production
areas
is
limited
because
of
the
state
regulations
regarding
township
caps,
as
previously
described
above.
Regulatory
constraints
on
1,3­
dichloropropene
products
impact
approximately
two­
thirds
of
California's
strawberry
production
areas
when
this
product
is
not
available
as
an
alternative
fumigant.
12
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
228
kilograms
per
hectare
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.

Florida.
The
combination
of
1,3­
dichloropropene,
chloropicrin,
and
metam
sodium
is
not
currently
being
used,
but
is
technically
feasible
in
the
short
term
when
combined
with
hand
weeding.
However,
it
is
probable
that
extensive
hand
weeding
would
be
necessary
in
areas
with
high
nutsedge
pressure,
which
would
then
exacerbate
the
nutsedge
problem.
We
are
unaware
of
any
research
for
this
combination
of
chemicals
in
these
regions,
but
data
associated
with
1,3­
dichloropropene
and
chloropicrin
combinations
show
a
range
of
yield
loses
from
0
to
25
percent
compared
to
strawberry
fruit
production
using
methyl
bromide.

Additionally,
this
alternative
is
not
being
used
in
Florida
because
of
the
concerns
with
buffers,
PPE
requirements,
and
pre­
planting
intervals.
Also,
use
of
1,3­
dichloropropene
in
Florida
is
prohibited
in
areas
characterized
by
karst
topography
because
of
groundwater
contamination.
Research
suggests
that
when
chloropicrin
is
mixed
with
other
chemicals
at
a
level
higher
than
35
percent,
and
applied
at
typical
rates,
it
can
increase
vegetative
growth
at
the
expense
of
strawberry
fruit
production.
When
1,3­
dichloropropene
is
used
in
combination
with
chloropicrin,
growers
experience
limited
flexibility
in
scheduling
fumigation
operations.
This
is
very
important
in
Florida
since
growers
often
experience
bad
weather
where
rain
storms
can
deposit
too
much
water
on
the
strawberry
beds
or
completely
wash
out
the
beds.
This
causes
delays
in
fumigation
and
planting.
Growers
may
be
forced
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.

Eastern
U.
S.
The
combination
of
1,3­
dichloropropene,
chloropicrin,
and
metam
sodium
is
not
currently
being
used
in
the
Eastern
U.
S.,
but
it
is
technically
feasible
when
combined
with
hand
weeding.
Since
nutsedge
is
present
at
moderately
high
to
high
levels
on
approximately
40
to
60
percent
of
the
area,
an
effective
companion
herbicide
is
needed
for
the
area
where
nutsedge
is
a
problem.
We
are
unaware
of
any
research
for
this
combination
of
chemicals
in
these
regions,
but
the
yield
loss
estimate
associated
with
1,3­
dichloropropene
and
chloropicrin
combinations
is
typically
5
percent,
with
a
range
from
0
percent
to
60
percent,
compared
to
strawberry
fruit
production
with
methyl
bromide.
The
eastern
U.
S.
growers
can
also
experience
the
same
weather
related
delays
and
concerns
as
the
growers
in
Florida.
Basamid.
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.

Basamid
and
Chloropicrin.
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.

Chloropicrin.
Chloropicrin,
alone,
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control.
The
failure
to
control
nematodes
and
weeds
in
soil
could
lead
to
increased
pest
pressure
over
time
(
See
1,3
Dichloropropene/
chloropicrin
and
1,3­
Dichloropropene/
chloropicrin/
metam
sodium
for
additional
information).
13
California.
Chloropicrin
is
not
technically
feasible
in
California
because
it
does
not
show
significant
activity
against
nematodes
or
weeds.
Although
research
of
chloropicrin
alone
produced
some
of
the
best
yields
compared
to
a
methyl
bromide/
chloropicrin
combination,
large
yield
losses
were
shown
to
occur
after
several
years.
Multi­
year
studies
using
chloropicrin
alone
have
been
conducted
on
fields
previously
fumigated
with
methyl
bromide
and
demonstrated
increasing
yield
losses
as
the
pest
pressures
rebound
from
the
methyl
bromide
suppressed
level.
The
data
show
yield
loss
estimates
for
chloropicrin
alone
compared
to
methyl
bromide
as
being
2.2
percent
the
first
year,
10.6
percent
for
the
second
year,
and
13.7
percent
in
the
third
year.
Other
trials
indicate
that
use
of
chloropicrin
alone
can
provide
adequate
control
of
soilborne
pathogens
in
locations
without
significant
nematode
or
weed
pressure.
However,
this
control
of
pathogens
has
often
been
accomplished
using
rates
of
chloropicrin
that
are
strongly
discouraged,
if
not
illegal,
in
the
state
of
California.

Florida.
Chloropicrin
alone
is
not
technically
feasible
in
Florida
because
it
does
not
control
nematodes
and
weeds.
The
pre­
plant
intervals
with
chloropicrin
cause
growers
to
experience
limited
flexibility
in
scheduling
fumigation
operations.
This
is
very
important
in
Florida
since
growers
often
experience
rain
storms
which
deposit
too
much
water
on
the
strawberry
beds
or
completely
wash
out
the
beds.
This
causes
delays
in
fumigation
and
planting.
Growers
may
be
forced
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.

Eastern
U.
S.
Chloropicrin
alone
is
not
technically
feasible
in
the
Eastern
U.
S.
because
it
does
not
control
nematodes
and
weeds.
Since
nutsedge
is
present
at
moderately
heavy
to
heavy
levels
on
approximately
40
to
60
percent
of
the
area,
an
effective
companion
herbicide
is
needed
for
the
areas
where
nutsedge
is
a
significant
problem.
The
eastern
U.
S.
growers
can
also
experience
the
same
weather
related
delays
and
concerns
as
the
growers
in
Florida.
However,
in
finer
textured
soils
where
nutsedge
and
nematodes
are
not
typically
as
problematic,
chloropicrin
has
shown
promising
yields.
Two
years
of
trials
at
one
site,
and
one
year
at
a
second
site,
resulted
in
yields
with
a
10
percent
loss.
Workers
did
report
eye
and
lung
irritation
and
there
were
concerns
about
drift
to
adjacent
neighborhoods.

Metam­
sodium.
Metam
sodium
alone
is
not
technically
feasible
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
Metam
sodium
suffers
from
erratic
efficacy
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
(
See
1,3­
dichloropropene/
chloropicrin/
metam
sodium
for
additional
information.)

California.
Metam
sodium
alone
is
not
technically
feasible
in
California
because
it
has
limited
activity
against
soilborne
pathogens
in
strawberry
fields.
Failure
to
adequately
control
the
primary
fungal
pathogens
in
soil
could
lead
to
increased
disease
pressure
over
time.
However,
metam
sodium
has
some
activity
against
important
weeds,
and
is
effective
against
damaging
forms
of
nematodes
in
soil.
Application
of
fumigants
by
drip
fumigation
will
result
in
subsequent
increased
disease
pressure
in
the
rotated
vegetable
crops
or
inability
to
rotate
land
into
vegetables
which
could
result
in
increased
pathogen
pressure
in
subsequent
strawberry
crops.
14
An
average
yield
loss
of
21
percent
was
reported
from
26
research
trials
where
strawberry
transplants
were
fumigated
with
metam
sodium
alone
in
nursery
beds.
This
point
estimate
from
research
studies
removed
tests
where
the
untreated
control
did
not
differ
in
yield
from
the
methyl
bromide
plus
chloropicrin
treatment,
which
indicates
a
lack
of
disease
pressure
in
the
test
field.
The
actual
range
of
yield
change
in
the
extensive
studies
on
metam
sodium
on
strawberries
in
California
was
a
reduction
of
52
percent
to
a
gain
of
10
percent.
Growers
will
experience
the
same
application,
crop
rotation,
and
plant
back
interval
issues
as
discussed
above
in
the
discussion
about
1,3­
dichloropropene
/
chloropicrin
/
metam
sodium.

Florida.
Metam
sodium
is
not
technically
feasible
in
Florida
because
it
does
not
consistently
control
weeds
and
soilborne
pathogens.
In
Florida,
nutsedge
control
is
vital
for
strawberry
fruit
production.
Several
studies
by
various
researchers
have
failed
to
produce
consistent
and/
or
adequate
efficacy
results.
Yield
losses
have
ranged
from
10
percent
to
50
percent.

Eastern
U.
S.
Metam
sodium
is
not
technically
feasible
in
the
Eastern
U.
S.
because
it
does
not
consistently
control
weeds
and
soilborne
pathogens.
Studies
by
various
researchers
have
failed
to
produce
consistent
and/
or
adequate
efficacy.
However,
in
trials
in
the
eastern
U.
S.
with
relatively
low
disease
or
nutsedge
pressure,
metam
has
provided
results
comparable
to
methyl
bromide
in
multi­
year
trials.
Yield
losses
can
range
between
0
percent
to
20
percent.

Metam­
sodium
and
Chloropicrin.
The
combination
of
metam­
sodium
and
chloropicrin
is
not
a
technically
feasible
alternative
because
together
they
do
not
consistently
control
diseases,
nematodes,
and
weeds.
Metam
sodium
provides
only
moderate,
unpredictable
disease,
nematode,
and
weed
control.
Metam
sodium's
erratic
efficacy
is
most
likely
due
to
irregular
distribution
of
the
product
through
the
soil.
Chloropicrin
supplies
good
disease
control,
but
poor
nematode
and
weed
control.
Failure
to
adequately
control
the
nematode
and
weeds
in
soil
could
lead
to
increased
pressure
over
time
(
See
discussion
above
for
additional
information
on
constraints
for
these
two
chemicals).

California.
The
combination
of
metam
sodium
and
chloropicrin
is
not
being
used
and
is
not
technically
feasible.
Research
has
shown
that
there
is
as
little
as
2
percent
yield
loss
in
trials
performed
on
land
previously
fumigated
with
methyl
bromide.
However,
because
fumigation
with
methyl
bromide
reduces
pests
pressure
to
extremely
low
levels
which
then
recover
over
successive
years
in
which
methyl
bromide
is
not
used,
it
is
likely
that
yield
losses
would
increase
in
successive
years
to
mirror
those
found
in
studies
with
chloropicrin
alone.
These
could
be
as
high
as
13.7
percent
by
the
third
year.
These
compounds
cannot
be
applied
at
the
same
time,
requiring
at
least
a
5­
day
interval
between
applications,
further
extending
field
preparation
time
and
an
already
excessive
plant
back
interval
of
28
days
compared
to
a
much
shorter
interval
for
methyl
bromide.
See
1,3­
dichloropropene/
chloropicrin
and
1,3­
dichloropropene/
chloropicrin/
metam
sodium
for
additional
information.

Florida
and
the
Southeast
U.
S.
As
in
California,
this
alternative
combination
is
not
being
used
and
is
not
technically
feasible.

Methyl
Iodide.
Methyl
iodide
(
iodomethane)
is
not
currently
registered
in
the
U.
S.
for
strawberry
fruit
production.
Several
researchers
continue
to
get
exemptions
to
test
this
promising
alternative.
Like
methyl
bromide,
this
chemical
can
be
drip
applied.
Preliminary
research
has
shown
occasional
phytotoxicity
symptoms.
15
6d.
Economic
Feasibility
of
In­
Kind
(
Chemical)
Alternatives
The
most
economically
feasible
alternative
to
methyl
bromide
is
the
combination
of
1,3­
dichloropropene
and
chloropicrin,
but
this
combination
is
only
technically
feasible
in
areas
of
light
to
moderate
nutsedge
pressure
where
regulatory
constraints
do
not
limit
the
use
of
1,3­
dichloropropene.
In
these
circumstances
this
alternative
regime
is
economically
feasible,
because
the
additional
cost
of
this
alternative
is
minor.
In
the
eastern
U.
S.
and
Florida,
the
pest
pressures,
particularly
nutsedge,
are
more
severe
and
this
alternative
is
not
viable.

The
economic
assessment
of
feasibility
for
pre­
plant
uses
of
methyl
bromide,
such
as
for
strawberries,
included
an
evaluation
of
economic
losses
from
three
basic
sources:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
quality
losses,
which
generally
affect
the
price
received
for
the
goods,
and
(
3)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices.

The
economic
reviewers
then
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
Losses
as
a
percent
of
gross
revenues.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
2)
Absolute
losses
per
hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
3)
Losses
per
kilogram
of
methyl
bromide
requested.
This
measure
indicates
the
value
of
methyl
bromide
to
crop
production
but
is
also
useful
for
structural
and
post­
harvest
uses.

(
4)
Losses
as
a
percent
of
net
cash
revenues.
We
define
net
cash
revenues
as
gross
revenues
minus
operating
costs.
This
is
a
very
good
indicator
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
owners
or
operators
of
an
enterprise.
However,
operating
costs
can
often
be
difficult
to
measure
and
verify.

(
5)
Changes
in
profit
margins.
We
define
profit
margin
to
be
profits
as
a
percentage
of
gross
revenues,
where
profits
are
gross
revenues
minus
all
fixed
and
operating
costs.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
strawberry
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.
16
Yield
loss
estimates
based
on
research
results
from
IR­
4
trials
performed
on
strawberries
in
California
with
both
Telone
InLine
(
a
formulation
of
1,3­
dichloropropene
and
chloropicrin)
and
also
with
Telone
InLine
with
an
additional
application
of
metam
sodium
did
not
differ
from
yields
obtained
with
a
combination
of
methyl
bromide
and
chloropicrin.
The
additional
application
of
metam
sodium
increases
the
cost
and
delays
planting
without
significantly
improved
yields,
therefore
this
alternative
regime
is
disadvantaged
economically
(
i.
e.
costs
are
higher
and
yields
are
not
improved)
relative
to
1,3­
dichloropropene
and
chloropicrin
without
metam
sodium.

Loss
Estimates.
The
losses
to
strawberry
producers
as
a
consequence
of
using
alternatives
to
methyl
bromide
are
summarized
in
Table
2.
These
losses
assume
the
use
of
1,3­
dichloropropene
in
combination
with
chloropicrin
for
Florida
and
the
eastern
U.
S.,
and
these
chemicals
plus
metam
sodium
for
California.
These
losses
are
based
on
the
likely
yield
loss,
which
is
the
estimated
yield
loss
assuming
light
pest
pressure,
the
situation
for
which
this
combination
is
considered
technically
feasible.

In
California,
1,3
D
with
chloropicrin
would
be
economically
feasible
under
conditions
of
light
to
moderate
pest
pressure.
However,
where
the
regulatory
constraints
of
township
caps
limit
the
amount
of
1,3­
D
that
can
be
used
in
a
year,
growers
may
still
have
a
critical
need
to
obtain
methyl
bromide.
In
this
case
the
yield
is
comparable
to
the
yield
obtained
with
methyl
bromide
are
assumed.
The
combination
of
1,3
D
with
chloropicrin
and
metam
sodium
costs
more,
which
is
indicated
in
Table
2.

In
Florida
and
Eastern
U.
S.,
the
estimated
losses
are
based
on
the
alternative
1,3­
dichloropropene
with
chloropicrin,
a
5
percent
yield
loss,
and
hand
weeding
costs
of
about
US$
1250
 
US$
5000
per
hectare.
As
previously
indicated,
hand
weeding,
if
effective,
is
only
effective
in
the
short
term,
until
the
reproductive
material
left
behind
becomes
active,
and
the
nutsedge
multiplies.
The
range
of
weeding
costs
drives
the
ranges
of
losses
and
profit
margins
in
Table
2.
The
upper
end
of
the
loss
ranges
assumes
higher
weeding
costs,
but
no
further
loss
of
yield.
Even
under
these
favorable
assumptions,
the
loss
per
kilogram
of
methyl
bromide
is
sufficiently
high
for
1,3­
dichloropropene
/
chloropicrin
to
be
economically
infeasible.

As
a
percent
of
gross
revenue,
1,3­
dichloropropene
with
chloropicrin
ranges
from
marginally
feasible
to
economically
infeasible,
depending
on
the
indicator
chosen.
In
summary,
under
ideal
pest
and
soil
conditions
with
very
low
or
no
yield
losses
and
low
hand
weeding
costs,
and
in
the
absence
of
regulatory
constraints,
such
as
township
caps,
buffer
zones
or
karst
topography,
1,3­
dichloropropene
with
chloropicrin
is
barely
be
economically
feasible.
If,
however,
the
actual
yield
losses
are
not
at
the
lowest
range
of
the
estimated
losses
this
alternative
becomes
economically
infeasible.
The
combination
of
1,3­
dichloropropene,
chloropicrin
and
metam
sodium
demonstrates
no
improvement
in
yield
relative
to
the
same
combination
without
metam
sodium,
but
it
does
cost
more,
so
the
cost
of
this
combination
was
not
estimated
and
it
is
not
included
in
Table
2.
If
anything,
the
cost
of
this
alternative
combination
would
be
higher
and
the
revenues
likely
lower
due
to
delayed
planting
required
when
metam
is
used
to
avoid
destruction
of
the
crops.
17
Table
2.
Measures
of
Economic
Impact
for
1,3­
Dichloropropene/
Chloropicrin
for
All
Regions,
and
Also
for
1,3­
Dichloropropene/
Chloropicrin/
Metam
Sodium
(
For
California
Only).
Loss
Measure
California
Florida
Eastern
US
%
Yield
Loss
with
best
alternative
likely*
0%
0­
25%
likely*
5%
0­
60%
likely*
5%
Increased
Costs
(
%
of
Gross
Revenue)
2­
5%
2­
5%
2­
9%

Loss*
as
a
%
of
Gross
Revenue
2­
5%
7­
10%
7­
14%

Loss*
Per
Acre
Loss*
Per
Hectare
US$
600­
1,600
US$
1,600­
4,000
US$
2,800­
4,300
US$
6,900­
10,600
US$
1,400­
2,900
US$
3,500­
7,200
Loss*
Per
Lb
MeBr
Loss*
Per
Kg
MeBr
US$
4­
9
US$
8­
20
US$
17­
26
US$
37­
57
US$
11­
22
US$
24­
48
Loss*
as
a
%
of
Net
Cash
Returns
9­
24%
NA
17­
34%

Profit
Margins*
with
MeBr
without
MeBr
6%
2­
5%
NA
30%
17­
25%
*
Loss
estimates
are
based
on
likely
yield
loss.
In
the
ranges
above,
the
higher
losses
and
lower
profits
margins
are
for:
California
 
as
a
result
of
using
metam
sodium
after
1,3­
dichloropropene/
chloropicrin;
Florida
and
Eastern
U.
S.
 
higher
costs
for
extra
weed
control,
which
is
assumed
to
be
sufficient
to
control
the
weed
pressure
while
maintaining
yield
loss
of
5
percent.

Other
Economic
Impacts.
The
following
economic
impacts
of
alternatives
to
methyl
bromide
were
not
addressed
because
of
a
lack
of
relevant
production
and
economic
data.

1.)
Increases
in
nematode
damage
may
become
increasingly
significant
in
the
future
should
methyl
bromide
no
longer
be
available.
Failure
to
adequately
control
the
primary
pests
in
soil
could
lead
to
increased
pressure
and
yield
losses
over
time.
Increased
disease
pressure
in
the
rotated
vegetable
crops
or
inability
to
rotate
land
into
vegetables
could
result
in
further
increased
pathogen
pressure
in
subsequent
strawberry
crops.
Yield
results
in
California
are
from
experiments
performed
on
land
previously
fumigated
with
methyl
bromide.
As
discussed
earlier,
this
is
likely
to
result
in
an
underestimate
of
yield
losses
due
to
the
nearly
complete
suppression
of
pathogens
and
the
subsequent
long
time
required
for
the
pest
population
to
recover
in
fields
where
methyl
bromide
has
been
used.
As
more
planting
seasons
pass
without
methyl
bromide
use,
pest
pressures
have
been
shown
to
increase.

2.)
Phytotoxicity
to
alternatives
may
result
in
economic
losses
but
these
potential
losses
are
not
included
in
this
assessment.

3.)
Variability
of
yields
are
a
risk
of
economic
loss
not
included
in
this
assessment
but
significantly
influencing
farmer
adoption
of
alternatives.
All
yield
loss
estimates
reflect
averages.
High
variability
in
losses
causes
farmers
at
the
high
end
of
the
loss
range
to
cease
production.

4.)
Time
loss
due
to
different
production
practices
and
the
often
longer
time
required
for
alternatives
to
be
efficacious
against
target
pests
can
result
in
economic
losses
and
may
affect
a
farmers
ability
18
meet
a
prime
marketing
window.
Some
growers
grow
a
second
crop,
and
a
significant
delay
could
preclude
this
practice.

5.)
Regulatory
constraints
such
as
township
caps,
buffer
zones,
karst
topography
make
currently
available
alternatives
technically
infeasible
in
areas
where
they
apply.
If
buffer
zones
were
to
remain
in
strawberry
production,
producers
would
need
to
rely
on
metam
sodium
in
those
zones,
resulting
in
significant
yield
impacts.

6.)
Time
of
Harvest
can
significantly
affect
the
strawberry
prices
and
alternatives
to
methyl
bromide
are
expected
to
affect
output
to
seasonal
markets.

Economic
Conclusion.
The
best
alternative,
a
combination
of
1,3­
dichloropropene
and
chloropicrin,
is
economically
feasible
where
pest
pressure,
such
as
that
produced
by
nutsedge
infestation,
is
light
to
moderate.
Because
nutsedge
is
ubiquitous
in
areas
of
the
eastern
U.
S.
and
the
coastal
west
where
fruit
and
vegetable
crops
are
grown,
but
in
some
areas
such
pressure
is
light
to
moderate,
the
total
nomination
for
methyl
bromide
for
this
sector
has
been
adjusted
to
only
reflect
the
proportion
of
the
area
where
the
alternatives
are
technically
and
economically
feasible.

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
production,
primarily
non­
chemical
alternatives.
Table
3
contains
a
summary
of
the
technical
assessment,
which
is
that
none
of
these
alternatives
were
found
to
be
technically
feasible.
Because
no
not­
in­
kind
alternative
was
found
to
be
technically
feasible,
no
economic
assessment
was
conducted.
A
description
of
each
alternative
follows.

Table
3.
Not­
in­
kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Strawberry
Nursery
Production.
Methyl
Bromide
Alternative
Technically
Feasible
Economically
Feasible
Nematicides
No
No
Ozone
No
No
Biofumigation
No
No
Solarization
No
No
Steam
No
No
Biological
control
No
No
Cover
crops/
Mulching
No
No
Crop
rotation/
Fallow
No
No
Flooding/
Water
management
No
No
General
IPM
(
Integrated
Pest
Management)
No
No
Grafting/
Resistant
rootstock/
Plant
breeding
No
No
Organic
amendments/
Compost
No
No
Organic
production
No
No
Resistant
cultivars
No
No
Soilless
culture
No
No
Substrates/
Plug
plants
No
No
19
Nematicides.
Nematicides
are
not
technically
feasible
alone
because
they
do
not
control
diseases
and
weeds.
Additionally,
there
are
no
nematicides
registered
for
use
on
fruit
bearing
strawberries
in
California.

Ozone.
Ozone
is
not
being
used
and
it
is
not
technically
feasible.
Early
research
showed
promise
(
SoilZone,
1999.
Ozone
Gas
as
a
Soil
Fumigant.
1998
Research
Program.
Electric
Power
Research
Institute)
but
researchers
have
abandoned
this
line
of
investigation.
Ozone
is
a
very
unstable
and
short­
lived
molecule
and
the
inconsistent
results
obtained
by
researchers
are
assumed
to
be
a
consequence
of
the
difficulty
of
keeping
an
ozone
molecule
in
contact
with
the
soil
long
enough
to
be
effective.

Biofumigation.
Biofumigation
is
not
technically
feasible
because
of
the
quantity
of
Brassica
crop
that
would
be
needed
to
control
target
pests
in
strawberries.
Approximately
three
hectares
of
Brassica
would
be
required
for
every
hectare
of
strawberry
production.
Further,
incorporation
of
Brassica
at
these
levels
are
likely
to
have
allelopathic
effects
on
the
target
crop.
In
the
eastern
U.
S.,
production
field
trials
with
cabbage
residue
and
tomato
produced
inconsistent
and
inadequate
efficacy,
and
poor
yields
in
two
years
out
of
three.
Additionally,
summer
Brassica
are
not
available
in
Florida.

Solarization.
Solarization,
as
a
stand­
alone
pre­
plant
fumigation
alternative,
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
a
wide
range
of
soil­
borne
diseases
and
pests.
Solarization
is
a
weather
sensitive
process
that
requires
ideal
soil
moisture
and
sunlight
conditions.
Solarization
treatment
is
most
successful
in
regions
with
continuous
high
temperature
periods
during
summer.
As
part
of
an
IPM
program,
soil
solarization
is
compatible
with
raised­
bed,
plastic
mulch
production
systems,
and
can
be
an
effective
tool
for
the
management
of
many
economically
important
pests
and
diseases,
with
the
exception
of
nutsedge.
The
response
of
nutsedge
to
solarization
is
sporadic
and
not
well
understood.
Data
show
solarization
to
provide,
at
best,
some
suppression
of
nutsedge
populations
(
Chase
et
al.,
1998;
Egley,
1983).
Field
studies
indicate
that
raising
and
maintaining
soil
temperatures
throughout
the
soil
profile
to
levels
shown
to
control
nutsedge
is
extremely
difficult.
Nutsedge
has
shown
the
ability
to
emerge
from
deep
in
the
soil
profile
and
to
re­
infest
from
areas
outside
the
solarization
zone,
so
solarization
alone
will
not
be
an
effective
and
dependable
control
method
for
nutsedge.

In
California,
use
of
solarization
is
not
practical
due
to
the
depth
of
heating
required
to
eliminate
viable
weed
seed.
It
is
only
performed
in
areas
where
clear
plastic
is
used
over
beds.
In
Florida
,
this
alternative
is
not
being
used
and
it
is
not
technically
feasible.
The
yield
loss
range
could
be
as
much
as
10
percent
to
50
percent.
Several
solarization
studies
by
various
researchers
have
failed
to
produce
consistent
and/
or
adequate
efficacy
results.
Although
temperatures
and
solar
radiation
in
the
Southeast
are
adequate
for
solarization,
deep
heating
for
nematode
control
is
not
achieved.
Unpredictable,
stormy
summer
weather
still
creates
risks
and
may
damage
mulch.
This
alternative
could
be
valuable
when
used
in
combination
with
other
treatments
to
enhance
disease
control.
The
Southeast
is
similar
to
Florida
except
that
in
one
Southeast
field
trial,
solarization
gave
yields
in
two
years
out
of
three
with
a
loss
ranging
from
0
percent
to
40
percent
compared
to
methyl
bromide.

Steam.
Steam,
as
a
stand­
alone
pre­
plant
fumigation
alternative
for
strawberry
fruit
production,
is
not
technically
feasible
because
it
is
not
operationally
practicable
due
to
slow
application
speed
and
high
energy
requirements.
For
example,
when
treating
with
steam,
it
could
take
from
1
to
3
weeks
20
to
treat
one
hectare
to
a
depth
of
about
20
cm
in
sandy
soil.
To
treat
more
hectares,
it
would
require
more
time
and/
or
more
equipment.
Results
with
steam
often
vary
because
of
differences
in
terrain
and
soil
density.
Since
the
use
of
steam
requires
significantly
more
time
than
using
methyl
bromide
alone,
growers
actually
delay
planting
for
several
weeks,
which
will
extend
their
production
schedule.
This
directly
impacts
cultivar
options,
IPM
practices,
timing
of
fruit
harvest,
marketing
window
options,
land
leasing
decisions,
and
subsequent
crop
rotation
schedules.
As
previously
mentioned,
growers
that
lease
land
for
rotation
into
vegetable
production
could
experience
extra
expenditures
for
land
rent,
shorter
intervals
between
crops
that
may
make
it
impossible
to
practice
crop
rotation,
and
yield
and/
or
quality
reduction
in
the
vegetable
crops
that
are
produced.

Biological
Control.
Some
strawberry
producers
are
already
using
biological
control
of
some
target
pests
as
part
of
an
IPM
program.
However,
it
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide
because
it
does
not
provide
adequate
control
of
the
target
pests.
There
are
a
very
limited
number
of
biological
organisms
that
can
be
used
to
effectively
manage
soil
borne
diseases
and
pests.
Biological
control
agents
are
usually
very
specific
in
regards
to
the
organisms
they
control
and
their
successful
establishment
is
highly
dependent
on
environmental
conditions.
California
growers
use
biological
control
organisms
primarily
for
insects
that
this
industry
routinely
employs.
Any
choice
of
alternative
fumigants
must
be
evaluated
for
compatibility
with
this
important
component
of
their
existing
IPM
system.

Cover
crops/
mulching.
Cover
crops/
mulching
is
already
being
used
by
strawberry
producers
as
a
part
of
an
integrated
pest
management.
By
itself,
the
use
of
cover
crops/
mulching
does
not
provide
adequate
control
of
the
target
pests.

Crop
rotation/
fallow.
Crop
rotation/
fallow
is
already
being
used
in
many
strawberry
production
areas,
but
does
not
adequate
control
the
target
pests.
In
California,
crop
rotation
is
used
as
an
effective
pest
management
technique
that
helps
keep
strawberry
productivity
50
percent
higher
per
hectare
than
the
national
average.
In
Florida,
current
strawberry
production
is
concentrated
in
areas
where
there
is
inadequate
land
available
for
multi­
year
crop
rotation.
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.

Flooding
and
water
management.
Flooding
and
water
management
are
not
currently
being
used
and
are
not
technically
feasible.
The
limited
water
resources
and
the
uneven
topographic
features
of
many
production
areas
prevents
the
use
of
these
alternatives
in
California.
In
Florida,
and
many
eastern
states,
sandy
soils
in
the
strawberry
production
areas
would
not
retain
the
flood
for
an
adequate
time
period
to
control
the
target
pests.

General
IPM.
General
IPM
is
being
already
being
used
in
strawberry
production,
but
it
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide.
IPM
practices
that
are
commonly
practiced
in
strawberries
include
monitoring
for
pests,
field
sanitation,
crop
rotation
to
provide
non
host
periods,
and
developing
disease
resistant
varieties.
IPM
practices
do
not
offer
adequate
pest
control
by
itself.

Grafting/
resistant
rootstock/
plant
breeding.
Grafting/
resistant
rootstock/
plant
breeding
is
not
being
used
and
it
is
not
technically
feasible
because
grafting
is
not
possible
given
the
physical
characteristics
of
strawberry
plants.
Breeding
for
resistance
to
pathogens
is
valuable
as
a
long­
term
21
endeavor
and
the
U.
S.
continues
work
in
this
area.
At
this
point
in
time,
plant
breeding
has
not
resulted
in
a
cultivar
that
is
sufficiently
resistant
to
the
major
target
pests.

Organic
amendments/
compost.
Organic
amendments/
compost
is
already
being
used
in
certain
regions
of
the
U.
S.,
but
it
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide.
Composting
is
management
intensive
and
it
does
not
offer
adequate
pest
control
by
itself.
Yield
loss
are
estimated
to
ranged
from
0
percent
to
50
percent.
In
the
eastern
U.
S.,
current
trials
are
testing
managed
composts
and
composts
inoculated
with
biological
control
agents
in
production
fields.
Where
nutsedge
is
not
prevalent
and
disease
pressures
are
moderate,
composts
have
resulted
in
good
yields
despite
the
weak
disease
suppression.

Organic
production.
In
certain
regions
of
the
U.
S.
some
organic
production
of
strawberries
occurs.
However,
as
a
stand
alone
replacement
for
methyl
bromide
it
is
not
a
technically
feasible
alternative
because
of
reduced
yields.
Production
systems
completely
reliant
on
non­
chemical
methods
for
pest
control
comprise
less
than
1
percent
of
the
commercial
strawberry
production
in
the
U.
S.
Growers
that
choose
to
convert
to
certified
organic
production
realize
significantly
lower
yields
from
their
crop
but
command
a
higher
price.
It
is
not
feasible
for
all
strawberry
production
in
the
U.
S.
to
convert
to
organic
production
because
as
more
growers
convert,
the
price
of
organic
strawberries
will
decline
with
increased
availability
(
they
will
loose
their
scarcity
rent).
To
receive
the
monetary
benefits,
the
farm
must
receive
an
organic
certification.
The
conversion
to
certified
organic
production
requires
a
considerable
investment
of
time,
many
changes
in
production
practices,
new
record
keeping,
and
different
pest
control
strategies.

Resistant
Cultivars.
Resistant
cultivars
are
already
being
used
in
certain
regions
of
the
U.
S.,
but
it
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide.

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.
Limited
information
was
provided
by
the
applicants
on
soilless
culture.

Substrates/
plug
plants.
Substrates/
plug
plants
is
currently
being
used,
but
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide.
Plug
plants,
as
compared
to
bare
root
transplants,
have
actually
proven
to
be
more
vigorous
and
provide
increased
yields
over
bare
root
transplants
in
several
research
trials.
However,
it
is
unknown
what
pathogens
will
be
controlled
and
to
what
degree
in
nurseries
producing
plug
transplants.
This
method
of
production
would
require
extensive
retooling
by
the
industry
and
considerably
more
research
in
order
to
determine
the
feasibility
of
nurseries
converting
to
the
system.
A
change
to
this
system
would
not
be
possible
for
all
growers.
A
complete
change
to
plug
plant
production
would
require
many
changes
in
production
schedules.
Amplification
of
pest
problems
that
occur
in
the
nursery
is
highly
likely.
In
California,
only
1
percent
of
transplants
are
produced
as
plugs
plants
in
soilless
media.
The
use
of
plug
plants
is
more
extensive
in
the
southeast
U.
S.

7.
Critical
Use
Exemption
Nomination
for
Strawberry
The
critical
use
exemption
nomination
for
the
strawberry
sector
is
for
production
in
three
distinct
geographic
U.
S.
regions
 
California,
Florida,
and
Eastern
U.
S.
states.
The
California
strawberry
growers
critical
use
actual
amount
requested
is
for
a
total
of
10,100
hectares
for
each
year.
Rates
as
22
requested
conform
to
standard
practices
in
this
region.
Refer
to
Table
4
for
additional
usage
information.

Table
4.
Methyl
Bromide
Usage
and
Requests
for
California
Strawberry
Production.
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
1,830,000
1,930,000
2,360,000
1,920,000
1,920,000
2,040,000
2,040,000
2,040,000
hectares
6,810
7,420
8,600
8,250
10,200
10,100
10,100
10,100
rate
(
kg/
ha)
269
260
275
233
189
202
202
202
The
Florida
strawberry
growers
critical
use
actual
amount
requested
is
for
a
total
of
2,870
hectares
for
each
year.
Rates
as
requested
conform
to
standard
practices
in
this
region.
Refer
to
Table
5
for
additional
usage
information.

Table
5.
Methyl
Bromide
Usage
and
Requests
for
the
Florida
Strawberry
Production.
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
542,000
551,000
464,000
471,000
531,000
580,000
580,000
580,000
hectares
2,470
2,510
2,510
2,550
2,870
2,870
2,870
2,870
rate
(
kg/
ha)
220
220
185
185
185
202
202
202
The
Eastern
U.
S.
strawberry
critical
use
actual
amount
requested
is
for
approximately
2,041
hectares
of
strawberry
plasticulture
production
in
the
states
of
Alabama,
Arkansas,
Georgia,
New
Jersey,
North
Carolina,
Ohio,
South
Carolina,
Tennessee,
and
Virginia.
Rates
as
requested
conform
to
standard
practices
in
this
region.
Refer
to
Table
6
for
additional
usage
information.

Table
6.
Methyl
Bromide
Usage
and
Requests
for
the
Southeastern
Strawberry
Consortium
1997
1998
1999
2000
2001
2005
2006
2007
kilograms
262,000
276,000
210,000
227,000
239,000
273,000
246,000
246,000
hectares
1,190
1,260
1,400
1,510
1,590
1,820
1,640
1,540
rate
(
kg/
ha)
220
220
150
150
150
150
150
150
The
U.
S.
nomination
(
Table
7)
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
including
the
area
afflicted
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
groundwater
contamination,
and
historic
use
rates,
among
other
factors.

Table
7.
Methyl
Bromide
Critical
Use
Exemption
Nomination
for
Strawberries
Year
Total
Request
by
Applicants
(
kilograms)
U.
S.
Sector
Nomination
(
kilograms)
2005
2,893,763
2,468,873
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
23
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.

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
24
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.

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.
25
Table
8.
Methyl
Bromide
Alternatives
Research
Funding
History
Year
Amount
(
Million)
1993
US$
7.255
M
1994
US$
8.453
M
1995
US$
13.139
M
1996
US$
13.702
M
1997
US$
14.580
M
1998
US$
14.571
M
1999
US$
14.380
M
2000
US$
14.855
M
2001
US$
16.681
M
2002
US$
17.880
M
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.

As
demonstrated
by
the
table
above,
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
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

The
numerous
methyl
bromide
alternative
research
trials
that
have
been
produced
quantitative
yield
data
are
summarized
in
Table
9.
This
table
shows
that,
even
among
studies
that
demonstrate
significant
yields
using
the
alternatives,
there
is
significant
variation
in
the
performance
of
the
alternative.
Thus,
while
a
given
alternative
may
perform
well
in
one
study,
it
may
also
perform
below
acceptable
standards
in
another
study.
The
standard
used
to
characterize
success
in
the
analysis
presented
here
is
if
the
alternative
produced
crops
with
at
least
95
percent
of
the
yield
of
the
crop
with
a
methyl
bromide
control.
However,
in
some
instances,
even
a
95
percent
yield
may
involve
some
profit
losses.
26
Table
9:
Summary
of
Research
Results
for
Methyl
Bromide
Alternatives
on
U.
S.
Strawberry.
Alternatives
Total
Number
of
Studies
Number
of
Studies
with
Yield
at
Least
95%
of
Methyl
Bromide
Basamid
(
Dazomet)
and
combinations
27
12
Chloropicrin
and
combinations
58
36
Compost
systems
11
6
Enzone
3
0
Metam
sodium
(
Vapam)
and
combinations
73
24
Organic
production
5
1
Ozone
1
1
Solarization
and
Combinations
22
6
Tarps
3
1
Telone
(
1,3­
dichloropropene)
and
combinations
93
41
The
California
Strawberry
Commission
has
invested
approximately
US$
8
million
in
research
to
develop
alternatives.
Current
research
programs
supported
in
whole
or
in
part
by
the
California
Strawberry
Commission
include
long­
term
research
on
sustainable
production
practices,
short­
term
investigation
of
available
alternatives,
nursery
production
alternatives,
breeding
for
resistance,
and
research
on
soil
microbiology.
This
research
has
produced
a
great
deal
of
data
indicating
which
alternatives
may
be
the
most
promising
for
strawberry
production
in
California
and
where
more
information
is
needed.
The
research
results
generated
under
this
program
have
been
useful
for
many
commodities
seeking
information
on
alternatives.

Nematodes
are
not
extremely
damaging
pests
in
berry
production
in
California
at
this
time.
However,
they
may
become
increasingly
important
in
the
future
as
methyl
bromide
is
no
longer
used,
especially
if
strawberry
nursery
producers
do
not
retain
the
ability
to
continue
using
it.
There
is
a
clear
need
for
research
performed
in
successive
years
on
the
same
land
to
evaluate
the
durability
of
control
achieved
with
alternative
fumigants
in
strawberries.
More
studies
are
needed
where
VIF
films
are
utilized
with
alternatives
to
clearly
define
the
conditions
which
will
result
in
the
phytotoxicity
observed
in
some
research
trials
where
VIF
films
were
used.
Also,
use
of
alternative
application
technology
including
drip
fumigation
alone
and
combined
with
VIF
films
require
more
experience
to
develop
workable
systems
due
to
difficulties
in
laying
this
type
of
plastic
and
longer
plant
back
intervals
required
when
alternatives
are
combined
with
this
plastic.
Availability
of
VIF
films
is
also
uncertain.
Deep
fumigation
techniques
using
newly
developed
equipment
for
application
of
1,3­
dichloropropene
also
require
more
research.

Because
the
vast
majority
of
research
data
on
strawberry
production
was
performed
using
nursery
plants
produced
on
methyl
bromide
fumigated
soil,
there
will
likely
be
many
unanticipated
future
scenarios
in
production
fields
should
the
nursery
industry
not
retain
use
of
methyl
bromide
and
growers
begin
using
planting
stock
that
is
less
clean
than
is
currently
available.
Studies
have
shown
that
transplants
produced
using
alternative
fumigants
are
less
vigorous
and
have
reduced
yields
compared
to
transplants
produced
on
methyl
bromide
fumigated
soil.
There
is
a
clear
need
for
studies
to
be
implemented
using
plants
produced
on
ground
fumigated
with
alternatives.
Also,
long
term
studies
to
develop
more
sustainable
production
systems
for
strawberry
should
remain
of
highest
priority
due
to
the
uncertain
future
availability
and
environmental
and
human
health
issues
concerning
alternative
chemical
fumigants.

Florida
and
Eastern
U.
S.
Methyl
bromide
alternatives
for
strawberry
production
in
these
areas
continue
to
a
very
active
area
of
research.
Research
is
currently
being
conducted
by
USDA,
27
University
of
Florida
Institute
of
Food
and
Agricultural
Sciences,
and
the
Florida
Fruit
and
Vegetable
Association.
Over
100
peer
reviewed
articles
have
been
published
to
date
based
on
trials
conducted
by
the
above
groups.
Control
of
nutsedge
and
winter
annual
weeds
is
crucial
to
successful
berry
production
in
Florida.
Control
of
nutsedge
is
also
extremely
important
to
40
percent
of
the
Eastern
strawberry
production
land
where
nutsedge
is
a
problem.
In
the
near
term,
research
is
needed
to
find
a
suitable
pre­
emergent
herbicide,
or
to
find
ways
to
get
better
herbicidal
efficacy
from
currently
available
fumigants.
In
the
long
term,
efforts
should
be
continued
to
find
non­
chemical
means
to
suppress
nutsedge
damage.
Some
additional
research
to
fine­
tune
use
of
alternative
fumigants
to
maximize
efficacy
and
yield
is
also
needed.

Research
studies
submitted
with
the
critical
use
exemption
request
packages
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.
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.

While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

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
28
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
U.
S.
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
high
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
for
all
types
of
pesticides
pending
in
its
review
process
than
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.
This
review
process
takes
an
average
of
38
months
to
complete.
Additionally,
the
registrant
(
the
pesticide
applicant)
has,
in
most
cases,
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
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
29
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
nematicide
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.
Several
additional,
promising
alternatives
are
under
review
at
EPA
that
may
be
able
to
be
used
on
strawberries
in
the
future.
These
include:
iodomethane
(
methyl
iodide)
and
propargyl
bromide,
which
currently
look
very
promising
in
field
studies.
Although
iodomethane
is
chemically
similar
to
methyl
bromide,
it
photodegrades
before
it
reaches
the
stratosphere,
and
therefore
is
not
a
significant
ozone
depleter.
While
iodomethane
and
propargyl
bromide
are
not
currently
registered
for
use
as
pesticides
in
the
U.
S.,
research
on
combinations
of
pesticides
with
chemicals
like
methyl
iodide
are
also
planned.
Some
of
these
trials
will
incorporate
screening
of
strawberry
varieties
for
tolerance/
resistance
to
Phytophthora
capsici.
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
concerns
about
toxicity,
drinking
water
contamination,
and
the
release
of
air
pollutants
regarding
some
alternatives
presents
another
difficulty
that
may
restrict
use
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.
If
registration
of
iodomethane
or
propargyl
bromide
occurs
in
the
near
future,
commercial
availability
and
costs
will
be
factors
that
must
be
taken
into
consideration.

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
to
be
technically
and
economically
feasible
before
they
are
widely
adopted.
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
U.
S.
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
30
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
the
strawberry
sector
are
not
currently
technically
or
economically
feasible
in
certain
circumstances
from
the
standpoint
of
U.
S.
strawberry
growers
covered
by
this
critical
use
exemption
nomination.
Under
certain
circumstances
in
the
absence
of
heavy
pest
pressure
and
regulatory
constraints,
1,3­
dichloropropene
with
chloropicrin,
and
possibly
also
with
metam
sodium,
may
be
economically
feasible,
and
indeed,
the
U.
S.
nomination
has
been
reduced
to
take
into
account
possible
use
in
areas
that
may
meet
such
circumstances.
However,
any
of
the
following
factors
would
or
could
make
the
alternatives
economically
infeasible:

 
Regulatory
constraints
such
as
township
caps,
buffer
zones,
and
karst
topology,
 
Heavy
pest
pressure
such
as
nutsedge,
 
Increasing
nematode
damage
over
time
from
not
using
methyl
bromide,
 
Phytotoxicity,
 
Variation
in
yields,
 
Time
lost
due
to
delays
in
planting,
 
Missing
early
harvests
with
high
strawberry
prices,
and
 
Less
vigorous
starter
plants
if
strawberry
nurseries
cannot
use
methyl
bromide.

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
strawberries
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unacceptable
risk,
is
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
strawberries
will
be
maintained
for
the
period
being
requested.

In
addition,
significant
efforts
have
been
made
to
reduce
the
use
and
emissions
of
methyl
bromide
associated
with
strawberries.
It
is
particularly
valuable
to
note
that
the
strawberry
production
industry
in
California
has
done
a
good
job
of
integrating
more
sustainable
and
environmentally
compatible
techniques
into
their
current
production
system.
These
currently
employed
strategies
include
the
use
of
insects
for
biological
control,
and
many
techniques
that
limit
losses
to
disease
including
use
of
crop
rotation,
alternation
of
chemicals
fungicides
to
limit
resistance
buildup,
clean
tillage,
water
management
and
field
sanitation.
Unfortunately
the
continued
success
of
their
well
constructed
IPM
system
is
dependent
on
the
use
of
methyl
bromide
as
a
pre­
plant
soil
fumigant.
Initial
reductions
in
populations
of
the
entire
pest
complex
achieved
with
methyl
bromide
make
it
feasible
to
use
more
environmentally
sound
control
measures
throughout
the
season
to
keep
reduced
pest
populations
in
check.
Without
a
replacement
capable
of
controlling
all
of
the
pests
that
methyl
bromide
controls,
the
entire
IPM
strategy
must
be
reconstructed.
Research
on
alternatives
for
this
commodity
has
been
progressive
and
productive.
There
have
been
promising
advances
towards
the
31
development
of
alternative
fumigants
and
application
methodologies.
The
regulatory
constraints
for
employment
of
the
currently
available
alternatives
remain
as
the
largest
obstacle
to
their
adoption
for
strawberry
production.

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:

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
32
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
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
33
Alternate
Contact:
Denise
Keehner,
Director
Biological
and
Economic
Analysis
Division
Office
of
Pesticides
Programs
US
Environmental
Protection
Agency,
7503C
Washington,
DC
20460
tel:
703­
308­
8200
fax:
703­
308­
8090
e­
mail:
methyl.
bromide@
epa.
gov
12.
References
California
Department
of
Food
and
Agriculture.
California
Agricultural
Statistics
Service.

Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3­
DC
will
Impact
Adjustment
to
Methyl
bromide
Phase­
out.
California
Agriculture,
Volume
55,
Number
3.

Carpenter,
Janet
and
Lori
Lynch.
1999.
Impact
of
1,3­
D
Restrictions
in
California
after
a
Ban
on
Methyl
Bromide.
Presentation
at
the
1999
Annual
International
Conference
of
Methyl
Bromide
Alternatives
and
Emissions
Reductions.

Crop
Profile
for
Strawberries
in
California.
1999.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Crop
Profile
for
Strawberries
in
Florida.
2002.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Crop
Profile
for
Strawberries
in
Virginia.
2000.
United
States
Department
of
Agriculture,
NSF
Center
for
Integrated
Pest
Management.

Florida
Department
of
Agriculture
and
Consumer
Services.
Florida
Agricultural
Statistics
Service.

Florida
Summary
of
Plant
Protection
Regulations.
Oct.
2002.
Florida
Department
of
Agriculture
and
Consumer
Services.

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.,
USDA
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.
34
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.

Virginia
Department
of
Agriculture
and
Consumer
Services.
Virginia
Agricultural
Statistics
Service.

Webster,
T.
M.,
A.
S.
Csinos,
A.
W.
Johnson,
C.
C.
Dowler,
D.
R.
Sumner,
and
R.
L.
Fery.
2001(
a).
Methyl
bromide
alternatives
in
a
bell
pepper­
squash
rotation.
Crop
Rotation
20:
605­
614
Webster,
T.
M.
and
G.
E.
Macdonald.
2001(
b).
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
Strawberry
CUE­
02­
0024:
California
Strawberry
Commission
CUE­
02­
0037:
Southeast
Strawberry
Consortium
CUE­
02­
0053:
Florida
Fruit
and
Vegetable
Association
 
Strawberry
35
Appendix
B.
Spreadsheets
Supporting
Economic
Analysis
This
appendix
presents
the
calculations,
for
each
sector,
that
underlie
the
economic
analysis
presented
in
the
main
body
of
the
nomination
chapter.
As
noted
in
the
nomination
chapter,
each
sector
is
comprised
of
a
number
of
applications
from
users
of
methyl
bromide
in
the
United
States,
primarily
groups
(
or
consortia)
of
users.
The
tables
below
contain
the
analysis
that
was
done
for
each
individual
application,
prior
to
combining
them
into
a
sector
analysis.
Each
application
was
assigned
a
unique
number
(
denoted
as
CUE
#),
and
an
analysis
was
done
for
each
application
for
technically
feasible
alternatives.
Some
applications
were
further
sub­
divided
into
analyses
for
specific
sub­
regions
or
production
systems.
A
baseline
analysis
was
done
to
establish
the
outcome
of
treating
with
methyl
bromide
for
each
of
these
scenarios.
Therefore,
the
rows
of
the
tables
correspond
to
the
production
scenarios,
with
each
production
scenario
accounting
for
row
and
the
alternative(
s)
accounting
for
additional
rows.

The
columns
of
the
table
correspond
to
the
estimated
impacts
for
each
scenario.
(
The
columns
of
the
table
are
spread
over
several
pages
because
they
do
not
fit
onto
one
page.)
The
impacts
for
the
methyl
bromide
baseline
are
given
as
zero
percent,
and
the
impacts
for
the
alternatives
are
given
relative
to
this
baseline.
Loss
estimates
include
analyses
of
yield
and
revenue
losses,
along
with
estimates
of
increased
production
costs.
Losses
are
expressed
as
total
losses,
as
well
as
per
unit
treated
and
per
kilogram
of
methyl
bromide.
Impacts
on
profits
are
also
provided.

After
the
estimates
of
economic
impacts,
the
tables
contain
basic
information
about
the
production
systems
using
methyl
bromide.
These
columns
include
data
on
output
price,
output
volume,
and
total
revenue.
There
are
also
columns
that
include
data
on
methyl
bromide
prices
and
amount
used,
along
with
data
on
the
cost
of
alternatives,
and
amounts
used.
Additional
columns
describe
estimates
of
other
production
(
operating)
costs,
and
fixed/
overhead
costs.

The
columns
near
the
end
of
the
tables
combine
individual
costs
into
an
estimate
of
total
production
costs,
and
compare
total
costs
to
revenue
in
order
to
estimate
profits.
Finally,
the
last
several
columns
contain
the
components
of
the
loss
estimates.
36
#
Notes
1
Provides
no
weed
control.
5%
yield
loss
based
on
biologist.

2
Based
on
IR­
4
trials
that
showed
no
significant
difference
with
MeBr.

3
Assumes
that
the
high
cost
for
weed
control
will
control
the
nutsedge
or
other
weed
pressure.

*
kg
ai
that
would
be
applied/
hectare
=
application
rate
for
the
alternatives
or
requested
application
rate
for
methyl
bromide.

*
Other
pest
control
costs
are
those
other
than
methyl
bromide
or
its
alternatives.
37
38
39
40
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.
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.
41
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.
(
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
42
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
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.
43
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
management
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.

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
44
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.

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
45
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,
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
(
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).
46
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
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
47
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
