Page
1
U.
S.
A.
CUN2003/
056
­
ORCHARD
REPLANT
FIELD
GROWN
BEARING
TREES
WITH
DEEP
INJECTION
OF
METHYL
BROMIDE
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide...............................................................................................
2
Economic
Impacts.......................................................................................................................
3
Response
to
Questions
from
MBTOC/
TEAP
..............................................................................
5
References
................................................................................................................................
10
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
............................................
3
Table
2.
Measures
of
Economic
Impact
of
1,3­
Dichloropropene
Use
in
Place
of
Methyl
Bromide
on
Orchard
Replants
in
the
U.
S.
......................................................................................
4
Table
3.
Measures
of
Economic
Impact
of
1,3­
Dichloropropene
with
Metam­
Sodium
Use
in
Place
of
Methyl
Bromide
on
Orchard
Replants
in
the
U.
S.
..............................................
4
Table
4.
Measures
of
Economic
Impact
of
1,3­
Dichloropropene
with
Chloropicrin
Use
in
Place
of
Methyl
Bromide
on
Orchard
Replants
in
the
U.
S.........................................................
5
Table
5.
Historical
Use
of
Methyl
Bromide
in
the
Orchard
Replant
Sector
..................................
7
Table
6.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Orchard
Replant
Sector..............................................................................................................................
7
Page
2
INTRODUCTION
The
United
States
(
U.
S.)
is
providing
the
following
additional
information
to
clarify
several
issues
for
the
orchard
replant
CUE
nomination.
As
TEAP
has
noted,
treatments
with
methyl
bromide
(
MB)
alternatives
may
be
feasible
in
certain
areas
with
light
soils
and
reduced
pest
pressure
(
particularly
from
nematodes),
and
where
regulatory
restrictions
do
not
apply.
The
U.
S.
CUE
nomination
has
already
accounted
for
this
and
did
not
include
a
request
for
MB
in
areas
where
alternatives
can
be
used.

CRITICAL
NEED
FOR
METHYL
BROMIDE
Given
the
one­
time
use
of
fumigants
for
the
establishment
of
orchards
on
land
previously
maintained
as
orchards
and
where
soil
structure
includes
a
significant
clay
component,
MB,
due
to
its
high
vapor
pressure,
is
currently
the
only
product
that
can
ensure
orchard
and
vineyard
managers
that
their
long­
term
investment
is
worthwhile.
MB
is
considered
critical
to
replant
in
areas
with
medium
to
heavy
soils,
which
the
U.
S.
has
calculated
as
occupying
approximately
50
to
65%
of
orchards
or
vineyards
in
this
sector.
As
described
in
the
U.
S.
nomination
for
this
sector,
"
replant
problem"
is
a
well­
known,
little
understood
complex
that
involves
pathogens,
nematodes,
insects,
and
other,
unknown
factors
leading
to
loss
of
vigor
of
plants.
The
U.
S.
nomination
includes
a
request
for
those
areas
that
face
moderate
to
severe
pest
pressure,
principally
from
nematodes
and
disease
that
can
severely
hinder
replant
growth
and
establishment.

Because
of
the
perennial
nature
of
tree
orchards
and
vineyards,
slow
initial
plant
growth
and
early
replacement
of
damaged
plants
can
significantly
reduce
crop
production.
The
ability
to
replant
an
orchard
or
vineyard
on
land
that
has
been
prepared
optimally
is
the
best
means
of
obtaining
maximum
effectiveness
of
pest
control
and
initiating
strong
initial
plant
vigor.
Economic
analyses
(
as
detailed
in
the
U.
S.
nomination
for
this
sector)
showed
that
even
minimal
biological
impacts,
in
terms
of
planting
delays,
plant
survival
rates,
and
yield
losses
could
significantly
reduce
the
value
of
an
orchard
or
vineyard.
In
areas
where
alternatives
are
not
currently
feasible,
these
negative
economic
impacts
will
be
significant.
The
U.
S.
review
of
critical
needs
determined
that
there
were
no
technically
feasible
alternatives
to
MB
on
medium
to
heavy
vineyard
soils
(
calculated
as
50%
of
vineyard
soils).
There
were
three
presumptively
technically
feasible
alternatives
to
MB
for
the
stone
fruit,
walnut,
and
almond
orchards
planted
on
medium
to
heavy
soils.
However,
the
economic
impacts
of
these
alternatives
[
1,3­
dichloropropene
(
1,3­
D),
1,3­
D
+
metam­
sodium,
and
1,3­
D
+
chloropicrin]
are
described
in
Tables
2,
3,
and
4
and
detail
the
significant
losses
that
likely
would
be
incurred
without
MB,
thereby
making
them
economically
infeasible.
Page
3
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
U.
S.
Region
/
States
Key
Pests
Critical
Need
for
Methyl
Bromide
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
(
CUE02­
0013)

California
Grape
and
Tree
Fruit
League
 
Table
and
Raisin
Grapes
(
CUE
02­
0014)

California
Walnut
Commission
(
CUE
02­
0029)

Almond
Hullers
and
Processors
Association
(
CUE
02­
0043)
Diseases:
Armillaria
spp.;
Phytophthora
spp.

Nematodes:
ring
(
Mesocriconema
xenoplax);
root
knot
(
Meloidogyne
spp);
root
lesion
(
Pratylenchus
vulnus);
dagger
(
Xiphinema
americanum)

Insects:
tenlined
June
beetle
(
Polyphylla
decemlineata)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
California.
Alternatives
are
not
effective
in
medium
and
heavy
soils
and
may
be
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
use
of
1,3­
dichloropropene.
Methyl
bromide
applications
in
orchard
replant
situations
are
typically
made
using
67:
33
or
50:
50
mixtures
with
chloropicrin
without
plastic
tarps.

ECONOMIC
IMPACTS
In
order
to
determine
whether
a
proposed
alternative
to
MB
is
considered
to
be
`
economically
feasible'
for
those
situations
where
technically
feasible
alternatives
exist,
the
United
States
took
a
`
weight
of
the
evidence'
or
`
portfolio'
approach.
Rather
than
rely
on
a
single
indicator
or
even
a
series
of
indicators,
each
with
a
`
bright
line',
the
situation
of
the
applicant
with
respect
to
five
measures
was
assessed.
The
five
measures
selected
for
consideration
were:
loss
per
hectare;
loss
per
kilogram
of
MB;
loss
as
a
percent
of
gross
revenue;
loss
as
a
percent
of
net
cash
returns;
and
change
in
profit
margins.
These
measures
were
selected
because
the
information
was
fairly
readily
available,
they
describe
different
aspects
of
potential
loss
and
are
independent
of
each
other.
In
cases
where
information
was
not
available
for
one
or
more
of
the
measures,
the
remaining
measures
were
used.
In
cases
where
a
stream
of
benefits
was
derived
from
a
MB
application,
net
present
value
was
used
in
the
calculations.

When
evaluating
the
case
made
by
each
application,
expert
economic
judgement
was
used
to
determine
whether
each
loss
(
or
change
in
profit
margin)
was
significant,
not
significant,
or
borderline
within
the
context
of
the
applicant's
market.
Once
decisions
on
individual
measures
were
reached,
an
overall
assessment
was
made
which
included
the
individual
measures
and
any
additional
considerations
such
as
social
benefit.
Page
4
TABLE
2.
MEASURES
OF
ECONOMIC
IMPACT
OF
1,3­
DICHLOROPROPENE
USE
IN
PLACE
OF
METHYL
BROMIDE
ON
ORCHARD
REPLANTS
IN
THE
U.
S.

Loss
Measure
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
(
CUE02­
0013)
California
Walnut
Commission
(
CUE
02­
0029)
Almond
Hullers
and
Processors
Association
(
CUE
02­
0043)

Yield
loss
5
to
8%
6
to
8%
5
to
8%

Loss
per
Hectare
US$
2350
to
6,960
US$
1,610
to
2,870
US$
1,810
to
3,370
Loss
per
Kilogram
MB
US$
12
to
35
US$
4
to
7
US$
6
to
10
Loss
as
a
%
of
Gross
Revenue
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Loss
as
a
%
of
Net
Cash
Returns1
31
to
93%
15
to
27%
17
to
32%

Change
in
Profit
Margins
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
MB.
At
a
lower
discount
rate,
NPV
was
positive
for
prunes
and
almonds
with
MB,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.

TABLE
3.
MEASURES
OF
ECONOMIC
IMPACT
OF
1,3­
DICHLOROPROPENE
WITH
METAM­
SODIUM
USE
IN
PLACE
OF
METHYL
BROMIDE
ON
ORCHARD
REPLANTS
IN
THE
U.
S.

Loss
Measure
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
(
CUE02­
0013)
California
Walnut
Commission
(
CUE
02­
0029)
Almond
Hullers
and
Processors
Association
(
CUE
02­
0043)

Yield
loss
1
to
2%
2
to
3%
1
to
2%

Loss
per
Hectare
US$
2,070
to
4,500
US$
4,290
to
4,830
US$
4,820
to
5,600
Loss
per
Kilogram
MB
US$
9
to
20
US$
10
to
11
US$
13
to
15
Loss
as
a
%
of
Gross
Revenue
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Loss
as
a
%
of
Net
Cash
Returns1
28
to
60%
41
to
46%
46
to
53%

Change
in
Profit
Margins
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
MB.
At
a
lower
discount
rate,
NPV
was
positive
for
prunes
and
almonds
with
MB,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.
Page
5
TABLE
4.
MEASURES
OF
ECONOMIC
IMPACT
OF
1,3­
DICHLOROPROPENE
WITH
CHLOROPICRIN
USE
IN
PLACE
OF
METHYL
BROMIDE
ON
ORCHARD
REPLANTS
IN
THE
U.
S.

Loss
Measure
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
(
CUE02­
0013)
California
Walnut
Commission
(
CUE
02­
0029)
Almond
Hullers
and
Processors
Association
(
CUE
02­
0043)

Yield
loss
2
to
5%
3
to
5%
2
to
5%

Loss
per
Hectare
US$
1,830
to
5,470
US$
800
to
2,020
US$
1,060
to
2,360
Loss
per
Kilogram
MB
US$
8
to
24
US$
2
to
5
US$
3
to
6
Loss
as
a
%
of
Gross
Revenue
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Loss
as
a
%
of
Net
Cash
Returns1
24
to
73%
8
to
19%
10
to
22%

Change
in
Profit
Margins
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
Not
Applicable
due
to
the
nature
of
this
type
of
investment
1Stone
fruit
impact
based
on
NPV
of
cherries.
Available
crop
budget
data
for
peaches/
nectarines,
plums,
prunes
and
almonds
indicate
negative
NPV
at
5
percent
discount
rate,
even
with
MB.
At
a
lower
discount
rate,
NPV
was
positive
for
prunes
and
almonds
with
MB,
but
not
with
alternatives.
Available
data
indicate
that
annual
returns
at
full
production
are
negative
for
peaches/
nectarines
and
plums.

RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
detail
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
and
to
identify
whether
the
suitability
of
alternatives
for
light,
sandy
soils
has
been
taken
into
account.
The
Party
may
wish
to
revise
the
nominated
quantity
of
MB
if
this
has
not
been
taken
into
account.

The
nomination
for
orchard
replant
submitted
by
the
United
States
considered
soil
type
and
reduced
the
amount
of
MB
nominated
in
cases
where
alternatives
were
identified
as
technically
feasible
for
light
sandy
soils
or
where
pest
pressure
is
generally
low
(
see
"
Impacts
to
Adjusted
Hectares"
in
Table
6).
Specifically,
reviewers
determined
that
1,3­
D,
or
1,3­
D
in
combination
with
chloropicrin
or
metam­
sodium
is
technically
feasible
on
light
soils,
which
represent
approximately
one­
third
to
one­
half
of
the
area
on
which
orchards
are
maintained.
Note
that
the
U.
S.
nomination
assumes
the
high
end
of
this
range
for
light
soils
(
50%)
in
estimating
the
area
where
alternatives
may
be
feasible
(
see
"
Soil
Impacts"
in
Table
6),
thereby
reducing
the
amount
of
MB
included
in
the
U.
S.
CUE
nomination.
No
alternatives
identified
by
MBTOC
were
found
to
be
feasible
for
use
on
medium
to
heavy
soils,
or
for
vineyard
replant.

2.
Whilst
it
was
difficult
to
make
a
recommendation
based
on
the
lack
of
technical
data
provided
or
references
for
the
specific
crops
in
the
nomination,
MBTOC
noted
that
the
industry
is
aware
of
the
technically
available
alternatives
and
appears
to
be
making
an
effort
to
adopt
these
alternatives.
Three
alternatives,
1,3­
D
alone
or
1,3­
D
combined
with
chloropicrin
or
metam
Page
6
sodium
were
considered
to
be
technical
alternatives
in
the
CUN
for
treatment
in
light
soils.
The
nomination
appears
to
take
this
into
account
when
calculating
the
nominated
quantity
of
MB.

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
6
and
did
take
into
account
the
availability
of
alternatives
for
use
in
light
soils.
As
previously
mentioned,
the
U.
S.
nomination
only
considered
50%
of
the
area
in
this
sector
as
having
a
critical
need
for
MB
due
to
lack
of
feasible
alternatives;
the
other
half
of
orchard
lands
were
considered
to
have
feasible
alternatives
due
to
their
more
amenable
soil
types.
(
For
descriptions
of
the
limitations
to
1,3­
D
use
in
the
U.
S.
see
"
Reregistration
Eligibility
Decision"
document
(
EPA,
1998).)
Page
7
TABLE
5.
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
259
1,218,144
3,944
*
Acres
planted
in
U.
S.
and
percent
of
U.
S.
acres
requested
is
not
available.
Source:
Rates,
amounts,
and
area
treated
are
from
applicants'
information.

TABLE
6.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
ORCHARD
REPLANT
SECTOR
Calculation
of
Nominated
Amount
0013
 
California
 
Stone
Fruit
0014
 
California
 
Dried
Prunes
0029
 
California
Walnut
0043
 
California
Almond
Hectares
(
ha)
2,131
433
809
405
%
of
Regional
hectares
(
ha)(
A)
N/
A
0.4
1
0.2
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
716,449
165,561
226,796
147,417
Double
Counted
hectares
(
ha)(
B)
 
 
 
 
Growth
/
Increasing
Production
(
ha)(
C)
408
160
485
(
1,543)

Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
 
 
 
 
Adjustment
s
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
1,723
273
324
405
Key
Pest
Impacts
(%)(
F)
35
35
85
100
Regulatory
Impacts
(%)(
G)
1
1
2
2
Soil
Impacts
(%)(
H)
50
50
50
50
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
68
68
85
100
Qualifying
Area
(
ha)(
J)
1,172
185
275
405
Use
Rate
(
kg/
ha)(
K)
336
382
280
364
CUE
Amount
Nominated
(
kg)(
L)
393,912
70,916
77,111
147,418
%
Reduction
from
Initial
Request
(
M)
45
57
66
0
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
689,356
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
706,176
Page
8
Footnotes
for
Table
6:

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
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
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
MB.
There
was
no
double
counting
in
this
sector.
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.
Three
of
four
applicants
requested
growth.
This
amount
was
subtracted
from
the
request.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Quarantine
or
pre­
shipment
are
not
applicable
to
this
sector.
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
MB
alternatives.
For
this
sector
key
pests
are
nematodes,
disease
and
insects.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
This
impact
is
expected
to
be
low
 
one
to
two
percent
of
the
acreage.
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).
Approximately
50%
of
the
acreage
comprises
heavy,
clay
soils.
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
judgments
about
the
extent
of
overlap
of
the
impacts.
For
example,
in
some
situations
the
impacts
are
mutually
exclusive
 
in
heavy
clay
soils
1,3­
D
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
1,3­
D
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.
In
this
sector
three
of
four
applicants
have
had
use
rates
adjusted
down.
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
small).
The
U.
S.
nomination
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
sum
of
all
nominations
in
this
sector
by
the
margin
of
error
multiplier.
Page
9
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,
cited
below,
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
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.
Page
10
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.

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

Environmental
Protection
Agency,
1998.
Reregistration
Eligibility
Decision
(
RED)
1,3
Dichloropropene.
http://
www.
epa.
gov/
REDs/
0328red.
pdf
MBTOC.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.
Pg
52.
