U.
S.
A.
CUN2003/
055
­
Fruit
Tree
(
Orchard)
Nurseries
ORCHARD
NURSERIES
GROWN
OUTDOORS
AFTER
BROADCAST
FUMIGATION
UNDER
PLASTIC
TARPS.
INCLUDING
AVOCADO,
CITRUS,
DECIDUOUS
TREES
AND
RASPBERRIES
TABLE
OF
CONTENTS
Introduction
........................................................................................................................................
2
Critical
Need
for
Methyl
Bromide........................................................................................................
2
Economic
Impacts...............................................................................................................................
2
Response
to
Questions
from
MBTOC/
TEAP.......................................................................................
2
Definitions...........................................................................................................................................
7
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide..............................................
2
Table
2.
Historical
use
of
methyl
bromide
in
the
orchard
replant
sector*.
....................................
4
Table
3.
Calculation
of
the
nominated
amount
of
methyl
bromide
in
the
orchard
replant
sector.
..
5
Page
2
INTRODUCTION
Methyl
bromide
is
needed
for
orchard
nursery
production
(
CUN
2003/
055)
to
produce
disease
and
pest
free
plants
to
meet
certification
standards.
The
diseases
and
pests
found
in
these
areas
are
listed
in
Table
1.
The
registered
alternatives
do
not
provide
acceptable
control
to
meet
the
certification
standards
and
require
additional
pest
sampling
for
verification
against
those
standards.
In
addition,
there
are
no
markets
for
plants
that
do
not
meet
the
certification
standards,
which
can
lead
to
extreme
economic
loss.
Further,
incomplete
disinfestations
can
lead
to
severe
loss
caused
by
uncontrolled
pests
in
orchard
production
fields.

CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
U.
S.
Region
/
States
Key
Pests
Critical
Need
for
Methyl
Bromide
Western
Raspberry
Nursery
Consortium
(
CUE02­
0010)

Washington
California
Nematodes:
Meloidogyne
spp.,
Pratylenchus
spp.,
Trichodorus
spp.,
Xiphinema
spp.,
and
Criconemella
spp.,
Tylenchulus
semipenetrans,
and
Radopholus
similes
Only
methyl
bromide
can
effectively
control
the
nematodes
found
in
Washington
and
California
to
meet
the
state
certification
requirements.

California
Assoc.
of
Nurseryment
 
Deciduous
Furit
and
Nut
Tree
Growers
(
CUE
02­
0035)

California
Association
of
Nurseryment
 
Citrus
and
Avocado
Growers
(
CUE02­
0036)
Nematodes:
Meloidogyne
spp.,
Pratylenchus
spp.,
Trichodorus
spp.,
Xiphinema
spp.,
and
Criconemella
spp.,
Tylenchulus
semipenetrans,
and
Radopholus
similes
Diseases:
(
Phytophthora
citrophthora,
P.
parasitica,
P.
cinnamomi,
Verticillium
spp.,
and
Armillaria
mellea)

Weeds:
Yellow
and
purple
nutsedge,
common
purslane,
lambsquarter,
little
mallow,
watergrass,
field
bindweed,
and
ragweed.
Only
methyl
bromide
can
effectively
control
the
target
pests
found
in
California
to
meet
the
state
certification
requirements.

ECONOMIC
IMPACTS
None
of
the
alternatives
were
considered
technically
feasible;
therefore
no
economic
analysis
was
conducted.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
Page
3
1.
Provide
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
of
methyl
bromide
required
for
those
areas
where
1,3­
D
is
not
available
through
local
restrictions
(
e.
g.
township
caps).

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
3.

The
methodology
used
by
the
U.
S.
carefully
scrutinized
applications
from
the
user
community
and
took
out
(
1)
double
counting;
(
2)
any
requested
growth
beyond
historical
acreage
planted,
and
(
3)
requested
amounts
that
fall
under
QPS.
Furthermore,
the
USA
adjusted
the
requests
from
the
user
community,
when
they
had
not
already
done
so,
to
change
the
amount
of
methyl
bromide
nominated
to
account
for
(
1)
only
the
area
where
pest
pressure
cannot
be
controlled
by
alternatives,
(
2)
the
area
where
regulatory
constraints
limit
adoption
of
alternatives,
such
as
buffers
near
inhabited
areas,
and
(
3)
the
area
where
soil/
geological
features
limit
use
of
alternatives,
such
as
groundwater
contamination
in
areas
with
karst
topography.
The
nominated
amount
incorporates
minimum
efficacious
use
rates,
mixtures
of
methyl
bromide
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.

2.
It
is
also
requested
that
the
Party
consider
recalculating
the
quantity
nominated,
consistent
with
the
use
of
emission
control
technologies
coupled
with
minimising
MB
dosages,
such
as
when
applied
in
conjunction
with
chloropicrin
where
feasible,
for
those
applications
where
alternatives
are
not
feasible
in
2005.

The
U.
S.
CUN
for
fruit
tree
nurseries,
assessed
and
described
the
use
of
three
chemical
alternatives
to
MB
 
1,3­
dichloropropene
(
1,3­
D)
+
chloropicrin,
1,3­
D
+
metam­
sodium,
and
1,3­
D
+
metam­
sodium
+
chloropicrin
(
see
Section
6c,
p.
8
of
the
Nomination).
In
addition,
the
CUN
addressed
numerous
non­
chemical
alternatives
(
see
Table
1,
p.
8
of
the
nomination).
All
applications
of
MB
for
this
industry
include
the
use
of
emission­
reducing
tarps
and
the
addition
of
some
amount
of
chloropicrin;
the
specific
amount
is
determined
by
efficacy
against
target
pests.
The
calculation
of
MB
needs
took
into
consideration
these
practices,
as
well
as
township
restrictions
on
the
use
of
1,3­
D.
The
request
for
MB
considered
that
further
reduction
of
MB
rates,
through
dilution
with
chemicals,
such
as
chloropicrin,
could
also
reduce
efficacy
to
the
level
that
certification
of
nursery
stock
would
be
impossible.
Furthermore,
calculation
for
MB
needs
took
into
account
differences
in
soil
types
and
the
amount
requested
reflected
the
efficacy
of
some
alternatives
in
sandy
soils,
but
not
in
heavy,
clay
soils
(
e.
g.,
see
Section
7
"
Critical
Use
Exemption
Nomination
for
Orchard
Nurseries"
of
the
Nomination,
p.
14).
In
addition,
Sections
6c
["
Technical
Feasibility
of
In­
Kind
(
Chemical)
Alternatives",
p.
8]
and
6e
("
Technical
Feasibility
of
Not
In­
Kind
MBTOC
Alternatives",
p.
12)
discuss
the
various
chemical
and
non­
chemical
alternatives
and
the
practice
of
concurrent
use
of
these
alternatives,
as
well
as
MB,
that
serves
to
reduce
overall
MB
use
in
the
production
of
fruit
tree
stock.
Page
4
TABLE
2.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
ORCHARD
REPLANT
SECTOR*.

Historical
Use
Average
Use
Rates
(
kg/
ha)
Total
Amount
(
kg)
Area
Treated
(
ha)

1997
303
1,549,418
7,136
1998
296
895,007
5,033
1999
301
1,219,716
6,888
2000
247
653,874
4,032
2001
359
1,218,144
3,944
*
Acres
planted
in
U.
S.
and
percent
of
U.
S.
acres
requested
is
not
available.
Page
5
TABLE
3.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
ORCHARD
REPLANT
SECTOR.

Calculation
of
Nominated
Amount
0010
 
Western
Raspberry
Nursery
Consortium
0035
 
CA
Assoc.
of
Nurserymen
 
Deciduous
Fruit
and
Nut
Tree
Growers
0036
 
CA
Assoc.
of
Nurserymen
 
Citrus
and
Avocado
Growers
Hectares
(
ha)
185
668
42
%
of
Regional
hectares
(
ha)(
A)
N/
A
N/
A
N/
A
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
46,510
224,528
19,051
Double
Counted
hectares
(
ha)(
B)
 
 
 
Growth
/
Increasing
Production
(
ha)(
C)
85
35
2
Quarantine
and
Pre­
Shipment
hectares
(
ha
)(
D)
60
538
35
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
40
95
5
Key
Pest
Impacts
(%)(
F)
100
100
100
Regulatory
Impacts
(%)(
G)
0
0
0
Soil
Impacts
(%)(
H)
0
0
0
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
100
Qualifying
Area
(
ha)(
J)
40
95
5
Use
Rate
(
kg/
ha)(
K)
252
336
448
CUE
Amount
Nominated
(
kg)(
L)
10,047
31,903
2,749
%
Reduction
from
Initial
Request
(
M)
78
86
88
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
44,699
Multiplier
for
Margin
of
Error(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
45,789
Page
6
Footnotes
for
Table
3:

Values
may
not
sum
exactly
due
to
rounding.

A.
Percent
of
Regional
Hectares
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
B.
Double
counted
hectares
is
the
area
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide.
C.
Growth
/
increasing
production
hectares
is
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated
or
treated
at
a
higher
use
rate.
Values
in
parentheses
indicate
negative
values
and
are
shown
to
demonstrate
a
trend,
but
are
not
used
in
further
calculations.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
E.
Adjusted
hectares
requested
is
the
hectares
in
the
applicant's
request
minus
the
acreage
affected
by
double
counting,
growth
/
increasing
production,
and
quarantine
and
pre­
shipment.
F.
Key
pest
impacts
is
the
percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
methyl
bromide
alternatives.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
H.
Soil
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance).
I.
Total
combined
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
or
soil
impacts.
In
each
case
the
total
area
impacted
is
the
area
which
is
impacted
by
one
or
more
of
the
individual
impacts.
For
each
application
the
assessment
was
made
by
biologists
familiar
with
the
specific
situation
and
able
to
make
judgements
about
the
extent
of
overlap
of
the
impacts.
For
example,
in
some
situations
the
impacts
are
mutually
exclusive
 
in
heavy
clay
soils
1,3D
will
not
be
effective
because
it
does
not
penetrate
these
soils
evenly,
but
none
of
the
heavy
soil
areas
will
be
impacted
by
township
(
regulatory)
caps
because
no
one
will
use
1,3D
in
this
situation,
so
this
soils
impact
must
be
added
to
the
township
cap
regulatory
impact
in
a
California
application.
In
other
words
there
is
no
overlap.
In
other
situations
one
area
of
impact
might
be
a
subset
of
another
impact.
In
these
cases,
the
combined
impact
is
equal
to
the
largest
individual
impact.
J.
Qualifying
area
is
calculated
by
multiplying
the
adjusted
hectares
requested
by
the
total
combined
impacts.
K.
Use
rate
is
the
requested
use
rate
for
2005.
This
rate
is
typically
based
on
historical
averages.
In
some
cases,
the
use
rate
has
been
adjusted
downward
to
reflect
current
conditions.
L.
CUE
amount
nominated
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
M.
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
N.
Sum
of
all
CUE
nominations
in
sector.
Self­
explanatory.
O.
Multiplier
for
margin
of
error.
This
amount
is
one
percentage
point
of
the
original
(
1991)
baseline
amount.
This
factor
is
intended
to
compensate
for
the
compounding
influence
of
using
the
low
end
of
the
range
for
all
input
parameters
in
the
calculation
of
the
US
nomination
(
i.
e.,
using
the
lowest
percent
impact
on
the
lowest
number
of
acres
at
the
lowest
dosage
is
likely
to
result
in
values
that
are
unrealistically
too
small).
The
U.
S.
nominated
included
some
sectors
for
100%
of
the
amount
requested,
therefore
the
portion
of
the
multiplier
from
these
sectors
were
added
equally
across
all
other
sectors
resulting
in
a
final
multiplier
of
1.0244,
or
a
2.44%
increase
from
the
calculated
amount,
to
these
remaining
sectors.
P.
Total
U.
S.
sector
nomination
is
calculated
by
multiplying
the
summed
sector
nominations
by
the
margin
of
error
multiplier.
Page
7
DEFINITIONS
THAT
MAY
BE
RELEVANT
TO
THIS
CUN
Source
of
yield
loss
estimates
Where
published
studies
of
yield
losses
under
conditions
of
moderate
to
severe
key
pest
pressure
were
not
available
(
the
situation
for
which
the
U.
S.
is
requesting
continued
use
of
methyl
bromide),
the
U.
S.
developed
such
estimates
by
contacting
university
professors
conducting
experiments
using
methyl
bromide
alternatives
in
the
appropriate
land
grant
institutions.
The
experts
were
asked
to
develop
such
an
estimate
based
on
their
experience
with
methyl
bromide
and
with
alternatives.
The
results
of
this
process
were
used
when
better
data
were
not
available.

Source
of
buffer
restriction
implications
for
methyl
bromide
use
Estimates
of
the
impact
of
buffers
required
when
using
some
methyl
bromide
alternatives
on
the
proportion
of
acreage
where
such
alternatives
could
be
used
were
developed
from
confidential
information
submitted
to
EPA
in
support
of
a
registration
application
for
a
methyl
bromide
alternative.
Because
at
the
time
of
the
analysis,
a
request
to
reduce
the
size
of
the
required
buffer
for
some
alternatives
was
under
consideration,
a
smaller
buffer
was
selected
for
the
analysis.
Since
that
time
the
size
of
the
regulatory
buffer
has
been
reduced
so
that
it
now
conforms
to
the
buffer
selected
for
this
analysis.

Source
of
area
impacted
by
key
pests
estimates
One
of
the
important
determinants
of
the
amount
of
methyl
bromide
requested
has
been
the
extent
of
area
infested
with
`
key
pests',
that
is,
pests
that
cannot
be
controlled
by
alternatives
to
methyl
bromide
when
such
pests
are
present
at
moderate
to
severe
levels.
Because
there
are
few
surveys
that
cover
substantial
portions
of
the
areas
for
which
methyl
bromide
is
requested,
we
have
relied
on
a
variety
of
sources
in
addition
to
the
surveys.
These
sources
include
websites
of
land­
grant
universities;
discussions
with
researchers,
both
those
employed
by
USDA
in
the
Agricultural
Research
Service
(
ARS)
and
those
at
land
grant
universities;
discussions
with
growers
whose
operations
cover
widely
different
locations
encompassing
different
incidences
of
key
pests;
information
from
pesticide
applicators;
and,
information
taken
from
the
applications
themselves.

Source
of
area
impacted
by
regulations
estimates
There
are
two
main
sources
used
to
develop
the
estimate
of
area
impacted
by
regulations.
First,
for
the
impact
of
Township
caps
in
California
we
have
used
a
series
of
papers
by
Carpenter,
Lynch,
and
Trout,
supplemented
by
discussions
with
Dr.
Trout
to
ensure
that
any
recent
regulatory
changes
have
been
properly
accounted
for.
Second,
the
estimate
of
the
area
impacted
by
buffers,
is
described
above.

Source
of
area
impacted
by
soil
type
estimates
First,
for
the
area
impacted
by
karst
topography,
estimates
were
developed
and
mapped
by
he
Florida
Department
of
Environmental
Protection.
The
area
of
California
used
for
agriculture
and
which
is
made
of
clay
soils
unsuitable
for
pest
control
with
a
methyl
bromide
alternative
has
been
determined
by
discussions
with
agricultural
researchers
and
agricultural
extension
agents
in
California,
and
discussion
with
other
knowledgeable
individuals
such
as
pesticide
applicators.
The
Page
8
estimates
for
California
understate
the
areas
in
which
alternatives
to
methyl
bromide
are
not
suitable
because
no
effort
was
made
to
estimate
the
extent
of
hilly
terrain
where
currently
available
substitutes
cannot
be
applied
at
uniform
dosages.

Source
of
area
impacted
by
combined
impacts
estimate
Combined
impacts
were
determined
on
a
case­
by­
case
basis
for
each
specific
crop/
location
combination
after
consultation
with
individuals
knowledgeable
with
the
specific
circumstances.
The
nature
of
the
individual
impacts
is
such
that
in
some
situations
they
are
independent
of
each
other,
in
some
they
are
mutually
exclusive,
and
in
some
cover
identical
areas.
It
was
not,
therefore,
possible
to
have
a
formula
that
would
arrive
at
an
appropriate
estimate
of
combined
impacts.
A
more
complete
description
is
found
in
the
footnotes
to
the
`
calculation'
table.
