U.
S.
A.
CUN2003/
060
­
STRAWBERRY
NURSERIES
STRAWBERRY
TRANSPLANTS
GROWN
OUTDOORS
WITH
BROADCAST
FUMIGATION
WITH
POLYETHYLENE
TARPS
TABLE
OF
CONTENTS
Introduction
........................................................................................................................................
2
Critical
Need
for
Methyl
Bromide.......................................................................................................
2
Economic
Impacts...............................................................................................................................
2
Response
to
Questions
from
MBTOC/
TEAP
......................................................................................
3
Historical
Emission
Reductions
&
Methyl
Bromide
Dosage
Rates
......................................................
7
Virtually
Impermeable
Film
(
VIF)
Tarps
............................................................................................
7
Definitions
..........................................................................................................................................
8
References
..........................................................................................................................................
9
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
...................................................
2
Table
2.
Effects
of
Soil
Fumigation
with
Methyl
Bromide:
Chloropicrin
(
MB:
CP)
vs.
Dichloropropene:
Chloropicrin
(
DP:
CP)
on
Yields
(
grams/
plant)
of
Strawberry
in
10
Studies
................................................................................................................................
3
Table
3.
Historical
Use
of
Methyl
Bromide
in
the
Strawberry
Nursery
Sector
....................................
5
Table
4.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Strawberry
Nursery
Sector..................................................................................................................................
5
Page
2
INTRODUCTION
Methyl
bromide
is
needed
for
strawberry
nursery
production
(
CUN
2003/
060)
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
in
strawberry
fruit
production
fields
due
to
uncontrolled
pests.

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
California
Strawberry
Nursery
Association
(
CUE02­
0034)
Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.);
Crown
rot
(
Phytophthora
cactorum)

Nematodes:
Root
Knot
(
Meloidogyne
spp.)
Only
methyl
bromide
can
effectively
control
the
target
pests
found
in
California
to
meet
the
state
certification
requirements
Southeastern
Strawberry
Consortium
(
CUE
02­
0038)

North
Carolina
and
Tennessee
Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.);
Crown
rot
(
Phytophthora
cactorum)

Nematodes:
Root
Knot
(
Meloidogyne
spp.)

Weeds:
Yellow
nutsedge
(
Cyperus
esculentus);
Purple
nutsedge
(
Cyperus
rotundus)
Only
methyl
bromide
can
effectively
control
the
target
pests
found
in
the
southeast
U.
S
to
meet
the
North
Carolina
and
Tennessee
certification
requirements
ECONOMIC
IMPACTS
None
of
the
alternatives
were
considered
technically
feasible;
therefore
no
economic
analysis
was
conducted.
Page
3
RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
MBTOC
notes
that
the
applicant
has
not
technically
verified
that
any
alternatives
are
feasible.
The
CUN
states
that
MB
is
required
to
meet
certification
standards,
but
does
not
provide
data
that
other
alternatives
do
not
provide
the
same
disease
tolerance
threshold
to
satisfy
these
standards.

Nursery
stock
regulations
of
the
California
Department
of
Food
and
Agriculture
(
CDFA)
require
that
nursery
stock
for
commercial
farm
planting
be
nematicide
free
(
CDFA
Code
of
Regulations
Sections
3055
to
3055.6
and
3640)
and
in
Tennessee
(
Chapter
0080­
6­
2
Regulations
Governing
Strawberry
Plant
Growers
and
Dealers).
Additionally,
there
are
specific
soil
treatment
and
handling
procedures
to
facilitate
compliance
with
the
regulations
for
the
Nursery
Stock
Nematode
Control
Program.
Under
California
regulatory
laws,
nursery
crops
must
be
"
free
of
especially
injurious
pests
and
disease
symptoms"
and
"
commercially
clean
with
respect
to
established
pests
of
general
distribution"
in
order
to
qualify
for
a
nursery
stock
certificate
for
interstate
and
intrastate
shipments.
Strawberry
nurserymen
must
document
compliance
on
a
monthly
basis
and
if
they
are
found
to
have
nursery
stock
with
nematodes,
100%
of
their
strawberry
rootstock
is
at
risk
for
a
loss.
If
an
alternative
to
methyl
bromide
is
used,
sampling
may
be
required
with
the
potential
for
destruction
of
100
percent
of
the
strawberry
stock
if
detectable
levels
of
pests
are
found.
In
addition
work
by
Shaw
et
al.,
1999
evaluating
10
different
studies,
demonstrated
a
14.35%
fruit
yield
difference
between
methyl
bromide
with
chloropicrin
versus
1,3­
D
with
chloropicrin.
This
fruit
yield
loss
difference
demonstrates
a
severe
impact
on
plant
growth
and
hardiness
due
to
pest
infestation
and
the
failure
to
control
those
pests
for
certification.

TABLE
2.
EFFECTS
OF
SOIL
FUMIGATION
WITH
METHYL
BROMIDE:
CHLOROPICRIN
(
MB:
CP)
VS.
DICHLOROPROPENE:
CHLOROPICRIN
(
DP:
CP)
ON
YIELDS
(
GRAMS/
PLANT)
OF
STRAWBERRY
IN
10
STUDIES
MB:
CP
treated
DP:
CP
treated
Study
No
Reps.
Mean
Yield
SD
Mean
Yield
SD
Percent
Increasez
ty
py
dy
2
6
992
177
856
109
15.9
1.60
0.070
0.93
5
6
1331
40
1046
55
27.2
10.27
<
0.001
5.93
7
5
1096
110
687
62
59.5
6.76
<
0.001
4.28
21
6
886
71
914
48
­
2.9
­
0.78
0.727
­
0.45
31
4
655
65
647
54
1.0
0.15
0.443
0.11
58
6
871
56
836
11
4.3
1.52
0.077
0.88
64
36
1381
146
1180
185
17.0
5.12
<
0.001
1.21
65
10
1742
131
1489
141
17.0
4.16
<
0.001
1.86
66
6
994
88
981
97
1.3
0.37
0.355
0.15
67
4
610
46
591
46
3.2
0.58
0.291
0.41
z
Unweighted
percent
increase
in
yield
for
the
MB:
CP
treatment
over
the
DP:
CP
treatment
group.
y
t
is
Student's
t
test
value,
p
is
a
one­
tailed
probability
(
requires
P<
0.025
for
conventional
significance),
and
d
is
the
standardized
effect
size.
Average
Percent
Increase
across
all
studies
is
14.35%.
Page
4
2.
The
CUN
also
does
not
consider
plug
plants
grown
in
hydroponics
as
a
possible
alternative,
but
MBTOC
considers
this
technology
a
technically
feasible
alternative,
but
understands
that
further
development
is
required
before
complete
adoption
is
possible.
The
Party
may
wish
to
reduce
the
CUN
to
account
for
plug
plant
development
as
an
alternative.

Substrates/
plug
plants
are
currently
being
produced
and
sold
in
the
southeast
and
to
a
very
limited
extent
in
California
but
this
method
alone
does
not
provide
pest
control
and
would
fail
to
produce
a
pest
free
product.
Furthermore,
this
method
would
require
extensive
retooling
by
the
nursery
industry.
The
use
of
plug
plants
is
expanding
in
the
Southeast
and
in
contrast
to
runner
plants,
plug
plants
are
produced
from
plantlets
(
tips)
propagated
on
raised,
mulched
beds
that
require
fumigation.
Roughly
the
same
land
area
is
required
to
produce
these
tips
(
about
620,000
plants
per
hectare)
as
is
required
to
produce
the
bare­
root
plants.
The
cost
of
plug
plants
is
about
16
cents
per
plant
compared
to
8
cents
per
plant
for
the
traditional
bare
root
plants.
Additionally,
strawberry
plants
are
moved
by
lowland
farms
to
highland
farms
and
back
again.
The
additional
plant
movement
and
the
infrastructure
required
would
make
large­
scale
adoption
of
a
plug
plant
system
more
difficult.

3.
The
industry
already
uses
low
dosage
rates
of
MB
and
is
encouraged
to
try
to
further
reduce
amounts
by
adopting
further
emission
control
technology
and
MB
formulations
with
lower
rates
of
MB
(
e.
g.,
MB/
Pic
50:
50)

The
U.
S.
nomination
considered
the
historical
efforts
by
strawberry
runner
growers
to
reduce
emissions
and
to
reduce
MB
dosages
described
in
the
section
below
titled,
"
Historical
Emission
Reductions
and
Methyl
Bromide
Dosage
Rates."
The
section
below
notes
success
in
the
United
States
at
efficiently
using
MB
at
low
dosages
with
emission
control
technologies
to
control
key
pests.
As
the
2002
MBTOC
report
states,
"
in
some
countries
(
e.
g.,
the
USA)
the
potential
for
reducing
MB
dosages
for
soil
fumigation
compared
to
many
other
countries
will
be
less
because
dosages
are
already
low."

Growers
requesting
this
exemption
have
routinely
used
plastic
tarpaulins
since
the
1980s
to
reduce
methyl
bromide
emissions
and
maximize
MB
effectiveness.
Recent
efforts
have
continued
to
try
to
maximize
each
quantity
of
methyl
bromide,
using
formulations
of
methyl
bromide
+
chloropicrin
with
lower
methyl
proportions
and
continued
testing
of
virtually
impermeable
film
(
VIF)
tarps.
The
difficulties
and
impediments
in
adopting
VIF
tarps
are
being
investigated
in
the
U.
S.
and
are
described
in
the
section
below
titled,
"
Virtually
Impermeable
Film
Tarps."
The
U.
S.
nomination
is
calculated
based
on
most
growers
continuing
to
use
a
67:
33
mixture
of
MB
with
chloropicrin.
Page
5
TABLE
3.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
STRAWBERRY
NURSERY
SECTOR
Historical
Use
Average
Use
Rates
(
kg/
ha)
Total
Amount
(
kg)
Area
Treated
(
ha)

1997
357
326,996
1,170
1998
356
331,336
1,194
1999
285
353,630
1,308
2000
282
353,042
1,334
2001
282
359,986
1,358
*
Strawberry
nurseries
acres
planted
in
U.
S.
and
percent
of
U.
S.
acres
requested
are
not
available.\

TABLE
4.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
STRAWBERRY
NURSERY
SECTOR
Calculation
of
Nominated
Amount
0034
 
California
Strawberry
Nursery
Association
0038
 
Southeastern
Strawberry
Consortium
Hectares
(
ha)
1,360
83
%
of
Regional
hectares
(
ha)(
A)
Not
Available
Not
Available
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
358,338
22,611
Double
Counted
hectares
(
ha)(
B)
 
 
Growth
/
Increasing
Production
(
ha)(
C)
65
 
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)
1101
74
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
194
9
Key
Pest
Impacts
(%)(
F)
100
100
Regulatory
Impacts
(%)(
G)
100
0
Soil
Impacts
(%)(
H)
0
0
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
100
Qualifying
Area
(
ha)(
J)
194
9
Use
Rate
(
kg/
ha)(
K)
264
271
CUE
Amount
Nominated
(
kg)(
L)
51,191
2487
%
Reduction
from
Initial
Request
(
M)
86
89
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
53,678
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
54,988
Page
6
Footnotes
for
Table
4:

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
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
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
soil
impact
must
be
added
to
the
township
cap
regulatory
impact
in
a
California
application.
In
other
words
there
is
no
overlap
in
this
particular
situation.
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
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.
Nomination
included
two
sectors
(
sweet
potatoes
and
cucurbits)
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
sectors.
P.
Total
U.
S.
sector
nomination
is
calculated
by
multiplying
the
summed
sector
nominations
by
the
margin
of
error
multiplier.
Page
7
HISTORICAL
EMISSION
REDUCTIONS
&
METHYL
BROMIDE
DOSAGE
RATES
The
U.
S.
strawberry
nursery
has
reduced
emissions
by
reducing
use
rates
by
21%
between
1997
and
2001
and
introducing
the
use
of
tarping
(
see
Table
3).
Information
from
California
(
on
all
crops)
indicates
that
use
of
tarps
with
methyl
bromide
has
gone
from
68%
in
1997
to
95%
in
2001
with
the
remaining
5%
attributable
to
deep
shank
injection
for
orchard
replant.
The
U.
S.
is
working
to
obtain
additional
historical
information
from
growers
of
strawberry
runners
in
California
and
in
the
Southeast
regarding
efforts
to
reduce
MB
emissions
through
tarping,
deep
soil
injection,
reductions
in
application
rates
and
switches
in
MB/
Pic
formulations.
As
soon
as
we
receive
information
about
these
types
of
historical
changes
to
reduce
emission
and
dosage
rates
for
strawberry
runners,
we
will
forward
it
to
the
MBTOC.

VIRTUALLY
IMPERMEABLE
FILM
(
VIF)
TARPS
Although
many
sectors
are
continuing
to
test
VIF
tarps
in
trials
throughout
the
country,
at
this
time
VIF
tarps
are
generally
not
technically
and
economically
feasible
for
the
following
reasons
(
U.
S.
EPA,
January
26,
1998):

Disposal
Issues

Landfill
disposal
of
VIF
and
VIF
burning
have
come
under
increasing
restrictions
in
some
jurisdictions
(
e.
g.,
California,
Department
of
Pesticide
Regulation,
00­
001;
Florida
 
62­
256.300
F.
A.
C.).


Both
landfilling
and
disposal
are
labor­
intensive
and
costly.


Ingredients
in
VIF
limit
recycling
into
end­
use
products.

Cost

Average
cost
of
VIF
tarps
is
$
580/
acre,
whereas
average
cost
of
low­
density
polyethylene
(
LDPE)
tarps
is
$
275/
acre,
and
high­
density
polyethylene
(
HDPE)
tarps
is
$
393/
acre.


Farmers
in
some
regions
report
VIF
tarp
removal
and
disposal
costs
of
more
than
$
240
per
acre
compared
to
removal
and
disposal
costs
of
approximately
$
60
per
acre
for
tarps
used
in
flat
fumigation.

Environmental
Consequences

Inorganic
bromide
residues
in
soil
are
higher
when
VIF
tarps
are
used;
further,
the
hydrolysis
of
methyl
bromide
in
water
may
result
in
the
accumulation
of
bromide
ions,
thus
increasing
the
chances
for
groundwater
contamination.


Evidence
suggests
that
VIF
tarping
could
actually
lead
to
increased
levels
of
emissions
when
the
tarps
are
removed,
thus
increasing
exposure
to
workers
and
nearby
structures.

VIF
Supply
&
Demand
Logistics

VIF
tarps
are
currently
manufactured
only
in
Europe,
and
current
VIF
tarp
production
capacity
in
Europe
is
not
high
enough
to
meet
U.
S.
demands.


VIF
tarps
manufactured
in
Europe
do
not
meet
U.
S.
application
size
and
criteria.


European
firms
are
unlikely
to
make
the
investment
necessary
to
ensure
a
viable
supply
Page
8
of
adequate
VIF
tarps
to
U.
S.
farmers
before
the
2005
phaseout
date.

VIF
Challenges
to
Agricultural
Practices

An
effective
glue
to
join
sheets
of
VIF
is
still
not
available.


Increasing
cover
times
with
VIF
to
between
10­
20
days
can
disrupt
double­
cropping
schedules
and
cause
growers
to
miss
optimum
marketing
windows.


Photo­
degradation
of
VIF
makes
it
brittle
and
ineffective
at
controlling
weeds
over
months
of
double
cropping
systems
(
current
non­
VIF
tarps
remain
on
beds
for
12­
15
months
after
one
MB
fumigation).

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
pest
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.

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
Page
9
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.

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
California.
2003.
Nursery
Inspection
Procedures
Manual.
Available
at:
http://
www.
cdfa.
ca.
gov/
phpps/
pe/
nipm.
htm
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.

Shaw,
D.
V.,
and
K.
D.
Larson.
1999.
A
Meta­
analysis
of
Strawberry
Yield
Response
to
Preplant
Soil
Fumigation
with
Combinations
of
Methyl
Bromide­
chloropicrin
and
Four
Alternative
Systems.
HortScience
34(
5):
839­
845.

Tennessee.
March
1999.
CHAPTER
0080­
6­
2
Regulations
Governing
Strawberry
Plant
Growers
and
Dealers.
Available
at:
http://
www.
tennessee.
gov/
sos/
rules/
0080/
0080­
06/
0080­
06­
02.
pdf
U.
S.
Environmental
Protection
Agency,
January
26,
1998,
Feasibility
of
Using
Gas
permeable
Tarps
to
Reduce
Methyl
Bromide
Emissions
Associated
with
Soil
Fumigation
in
the
United
States.
