U.
S.
A.
CUN2003/
059
­
STRAWBERRY
FRUIT
 
FIELD
STRAWBERRIES
GROWN
OUTDOORS
UNDER
PLASTIC
MULCH
FOR
FRUIT
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide...............................................................................................
3
Economic
Impacts.......................................................................................................................
3
Response
to
Questions
from
MBTOC/
TEAP
..............................................................................
5
Historical
Emission
Reductions
&
MB
Dosage
Rates................................................................
14
Virtually
Impermeable
Film
(
VIF)
Tarps
..................................................................................
14
Market
Window
Information.....................................................................................................
15
Definitions
................................................................................................................................
16
References
................................................................................................................................
18
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
............................................
3
Table
2.
Measures
of
Economic
Impact
of
1,3­
D
+
Chloropicrin
Use
in
Place
of
Methyl
Bromide
+
Chloropicrin
on
Strawberries
in
the
U.
S.
In
Areas
of
Moderate
To
Severe
Pest
Pressure................................................................................................................................
4
Table
3.
Effects
of
Soil
Fumigation
with
Methyl
Bromide/
Chloropicrin
(
MB/
CP)
vs.
Dichloropropene/
Chloropicrin
(
DP/
CP)
on
Yields
(
grams/
plant)
of
Strawberry
in
10
Studies
.............................................................................................................................................
8
Table
4.
Historical
Use
of
Methyl
Bromide
in
the
Strawberry
Sector*.....................................
12
Table
5.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Strawberry
Sector
..
12
Table
6.
Herbicides
Registered
in
the
United
States
to
Control
Nutsedge
in
Strawberries
.........
14
Appendix:
Table
3.
from
Nomination
Chapter:
Not­
in­
kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Strawberry
Field
Production.
.....................................................
19
Page
2
INTRODUCTION
The
United
States
(
U.
S.)
nomination
for
strawberry
fruit­
field
(
CUN2003/
059)
is
a
critical
need
for
an
amount
of
methyl
bromide
(
MB)
in
areas
with
moderate
to
severe
pest
pressure
(
see
Table
1),
because
currently
there
are
no
technically
feasible
alternatives
and
farmers
would
face
severe
economic
hardships
in
the
absence
of
MB.
Suggested
alternatives
for
strawberry
fruit
production
fail
to
provide
the
necessary
degree
of
pest
control
or
their
use
is
not
easily
adoptable
due
to
state­
imposed
restrictions
designed
to
safeguard
health
or
the
environment.
The
nomination
also
notes
that
applying
alternatives
is
further
complicated
when
plant­
back
restrictions
prevent
farmers
from
meeting
marketing
windows
(
e.
g.,
winter
or
early
spring)
when
strawberry
sale
prices
are
as
much
as
100%
higher
than
during
the
rest
of
the
year
(
see
Market
Window
Information).
The
nomination
notes
significant
progress
in
adopting
emission
reduction
technologies
and
changing
formulations
and
application
rates
to
reduce
MB
dosage
rates
to
some
of
the
lowest
in
the
world,
and
that
further
trials
are
being
conducted
to
evaluate
new
alternatives
and
to
test
ways
of
overcoming
constraints
in
further
lowering
MB
formulations
and
adopting
even
more
impermeable
barriers.
Page
3
CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
Region
Key
Pests
Critical
Need
for
Methyl
Bromide
California
Strawberry
Commission
(
CUE
02­
0024)
Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.),
fruit
and
crown
rot
(
Phytophthora
cactorum).

Nematodes:
Sting
(
Belonolaimus
spp.),
and
rootknot
(
Meloidogyne
spp.).

Weeds:
Common
purslane
(
Portulaca
oleracea),
chickweed
(
Stellaria
media),
mallow
(
Malva
spp.),
and
stinging
nettle
(
Urtica
dioica).
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
California.
Uses
of
alternatives
are
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
amount
of
1,3­
dichloropropene
that
can
be
used.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
57:
43
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

Florida
Fruit
and
Vegetable
Association
­
Strawberry
(
CUE
02­
0053)
Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.),
fruit
and
crown
rot
(
Phytophthora
cactorum).

Nematodes:
Sting
(
Belonolaimus
spp.),
and
rootknot
(
Meloidogyne
spp.).

Weeds:
Purple
and
yellow
nutsedge
(
Cyperus
esculentus
and
C.
rotundus)
and
ryegrass
(
Lolium
spp.).
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
Florida.
In
addition,
the
use
of
alternatives
are
limited
in
some
areas
because
the
soil
overlays
a
vulnerable
water
table
(
karst
topography).
Finally,
there
are
other
areas
where
regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures
make
alternatives
infeasible.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

Southeastern
Strawberry
Consortium
(
CUE
02­
0037)
Alabama,
Arkansas,
Georgia,
North
Carolina,
South
Carolina,
Tennessee,
Virginia,
Ohio,
and
New
Jersey.
Diseases:
Black
root
rot
(
Rhizoctonia
and
Pythium
spp.).

Nematodes:
Rootknot
(
Meloidogyne
spp.).

Weeds:
Purple
and
yellow
nutsedge
(
Cyperus
esculentus
and
C.
rotundus).
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
nutsedge
found
in
the
southeast
U.
S.
Regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures
make
the
use
of
alternatives
infeasible
for
many
Southeast
locations.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
150
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

ECONOMIC
IMPACTS
To
determine
whether
a
proposed
MeBr
alternative
was
economically
feasible
in
those
situations
Page
4
where
technically
feasible
alternatives
exist,
the
U.
S.
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
information
to
support
their
use
was
fairly
readily
available,
because
they
describe
different
aspects
of
potential
loss
and
finally,
because
they
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
economic
assessment
was
made.

The
original
U.
S.
nomination
presented
data
showing
that
the
next
best
alternative
to
MB,
1,3­
D
plus
chloropicrin
plus
metam­
sodium,
is
economically
feasible
in
California
under
conditions
of
light
to
moderate
pest
pressure
and
where
regulatory
constraints
do
not
limit
the
use
of
1,3­
dichloropropene.
In
Florida
and
other
southeastern
states,
1,3­
dichloropropene
plus
chloropicrin
might
be
effective
against
low
nutsedge
infestations,
but
the
pest
pressures
in
the
specific
areas
covered
in
this
CUN,
particularly
nutsedge,
are
more
severe
and
this
alternative
is
not
viable.
Given
this
caveat,
an
economic
analysis
of
1,3­
dichloropropene
plus
chloropicrin
plus
metamsodium
as
an
alternative
for
key
pests
in
California
and
an
economic
analysis
of
1,3­
dichloropropene
plus
chloropicrin
as
an
alternative
for
nutsedge
in
Florida
and
the
other
southeastern
states
were
conducted.
Based
on
the
results
of
this
analysis
shown
in
Table
2,
the
U.
S.
concluded
that
the
use
of
the
"
next
best"
alternatives
to
MeBr
was
not
economically
feasible
in
areas
of
moderate
to
severe
pest
pressure.

TABLE
2.
MEASURES
OF
ECONOMIC
IMPACT
OF
1,3­
D
+
CHLOROPICRIN
USE
IN
PLACE
OF
METHYL
BROMIDE
+
CHLOROPICRIN
ON
STRAWBERRIES
IN
THE
U.
S.
IN
AREAS
OF
MODERATE
TO
SEVERE
PEST
PRESSURE
Loss
Measure
California
(
CUE
02­
0024)
+
Metam­
Sodium
Florida
(
CUE
02­
0053)
Southeastern
US
(
CUE
02­
0037)

%
Yield
Losses
likely*
14%
Up
to
25%
Likely*
5%
Up
to
60%
likely*
5%
Loss*
Per
Hectare
US$
4,901­
5,952
US$
6,900­
10,600
US$
3,500­
7,200
Loss*
Per
Kg
MB
US$
33­
74
US$
37­
57
US$
24­
48
Loss*
as
a
%
of
Gross
Revenue
16­
20%
7­
10%
7­
14%

Loss*
as
a
%
of
Net
Cash
Returns
Not
Available
Not
Available
17­
34%
*
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
Southeastern
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.
The
California
yield
loss
number
is
different
from
the
nomination
package
and
is
based
on
the
work
of
Shaw
and
Larson
(
1999)
presented
in
Table
3.
Page
5
RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
detail
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount.

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
5.

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
U.
S.
adjusted
the
requests
from
the
user
community,
when
they
had
not
already
done
so,
to
change
the
amount
of
MB
nominated
to
account
for
only
(
1)
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
MB
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.

2.
Also
to
list
the
registration
status
of
herbicides
for
this
crop
and
provide
data
on
why
these
are
not
suitable
for
nutgrass
control
(
the
main
reason
why
MB
is
used
in
southeastern
USA).

A
list
of
herbicides,
with
activity
against
nutsedge
species,
which
are
currently
registered
for
some
or
all
U.
S.
strawberry
crops,
is
provided
in
Table
6.
There
are
currently
no
herbicides
registered
in
the
U.
S.
that
can
selectively
and
effectively
control
nutsedge
under
conditions
of
moderate
to
severe
weed
pest
pressures
in
strawberries.
Furthermore,
as
strawberries
in
the
U.
S.
are
grown
over
plastic
mulch
to
keep
the
fruit
from
being
in
direct
contact
with
the
soil
and
thus
being
exposed
to
pathogens,
the
use
of
conventional
herbicides
is
not
practical
after
planting.

3.
As
the
CUN
specifically
requests
MB
for
areas
where
nutgrass
exists
in
heavy
infestations,
the
Party
is
requested
to
clarify
the
exact
amount
of
MB
required
for
this
use
and
to
validate
the
amount
of
MB
required
for
those
areas
where
1,3­
D
is
not
available
through
local
restrictions
(
e.
g.
township
caps).

The
CUN
requests
MBR
only
for
areas
where
nutsedge
exists
in
moderate
to
severe
infestations.
The
steps
to
calculate
the
nominated
amount
are
shown
in
Table
5,
and
the
details
of
the
reasoning
and
assumptions
and
the
citations
for
these
conclusions
are
explained
in
the
text
following
the
table,
as
well
as
in
the
responses
the
two
MBTOC/
TEAP
comments
immediately
following.
The
extent
of
the
nutsedge
infestation
of
concern
is
noted
in
the
line
on
Table
5
labeled
"
key
pest
impacts".

We
have
reviewed
related
documentation
and
confirmed
the
validity
of
levels
of
MB
required
for
those
areas
where
1,3­
D
is
not
available
because
of
local
restrictions.
Page
6
4.
MBTOC
found
it
difficult
to
provide
a
recommendation
on
this
CUN
as
the
table
on
alternatives
(
Table
3)
related
to
runner,
not
fruit
production,
so
the
performance
of
some
alternatives
could
not
be
correctly
evaluated.
Whilst
this
nomination
considered
a
number
of
alternatives
the
lack
of
references
and
comparative
data
made
it
difficult
for
MBTOC
to
determine
the
performance
of
many
of
these
alternatives.
The
Party
is
requested
to
supply
a
revised
Table
3
and
to
provide
comparative
performance
data
(
technical
and
economic)
to
allow
evaluation
of
alternatives.

Table
3
in
the
nomination
was
mislabeled.
It
should
have
read:
"
Table
3.
Not­
in­
kind
Methyl
Bromide
Alternatives
Identified
by
MBTOC
for
Strawberry
Field
Production."
However,
it
is
correct
and
has
been
attached
to
the
end
of
this
document.
For
a
discussion
of
comparative
data
see
Question
5
below.

5.
As
confirmed
by
the
CUN,
MBTOC
suggests
that
1,3­
D
combined
with
either
chloropicrin
or
metham
sodium
are
feasible
alternatives
to
MB
in
the
circumstances
of
the
nomination.
To
date
over
10%
of
the
industry
has
already
converted
to
the
use
of
formulations
of
1,3­
D/
Pic
in
some
regions.
MBTOC
recognizes
that
application
issues,
plant
back
times
and
reliability
restrict
adoption
of
other
fumigant
alternatives
by
the
industry.

While
it
is
true
that
1,3­
D
mixtures
have
been
used
by
over
10%
of
the
industry,
those
using
these
combinations
are
generally
not
faced
with
moderate
to
severe
nutsedge
infestations,
or
are
constrained
by
such
things
as
township
caps,
buffer
zones
or
karst
topography.
In
areas
where
such
pest
pressures
or
constraints
are
present,
these
1,3­
D
mixtures
are
not
feasible
alternatives.
The
U.
S.
CUE
request
includes
only
those
areas
where
the
use
of
these
alternatives
is
not
feasible.

General
comments
regarding
1,3­
D
+
chloropicrin
1,
3­
D
is
used
primarily
as
a
nematicide,
and
by
itself,
chloropicrin
supplies
good
disease
control,
but
poor
nematode
and
weed
control.
The
1,3­
D
+
chloropicrin
combination
offers
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
herbicide
applications
to
control
weeds
such
as
nutsedge.
However,
in
the
U.
S.
there
are
no
registered
herbicides
that
selectively
and
effectively
will
control
weeds
such
as
nutsedge
under
moderate
to
severe
weed
pressure,
and
the
use
of
herbicides
to
control
nutsedge
actually
stimulates
further
nutsedge
growth
(
see
response
to
Question
2).
Sequential
application
of
each
one
of
these
chemicals
requires
significantly
more
time
than
using
MB
alone,
and
growers
must
wait
longer
after
fumigation
to
put
the
strawberry
transplants
in
the
ground.

In
addition,
current
buffer
requirements,
longer
pre­
plant
intervals,
and
personal
protective
equipment
(
PPE)
requirements
for
1,3­
D
make
using
1,3­
D
infeasible
for
growers
in
some
circumstances
(
U.
S.
EPA,
1998).
Shank
applied
1,3­
D
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.
Page
7
There
are
also
PPE
requirements
for
1,3­
D
application,
which
limit
the
ability
of
farmers
to
use
the
chemical
in
tropical
and
subtropical
climates.
The
hot
weather
in
California,
and
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
if
they
wear
the
required
PPE.
For
example,
these
PPE
restrictions
require
applicators
to
wear
fully
sealed
suits,
with
respirators.
Such
suits
usually
do
not
have
refrigeration
components,
and
under
conditions
of
high
heat
and
humidity
rapidly
become
unbearable
for
a
typical
applicator.
Although
these
requirements
have
recently
been
eased
somewhat
so
that
fewer
people
are
subject
to
use
the
full
complement
of
PPE
(
U.
S.
EPA,
1998),
workers
who
come
in
close
contact
with
the
liquid
formulation
must
still
wear
heavy
layers
of
protective
equipment,
as
described
above.

1,3­
dichloropropene
is
restricted
from
use
in
soils
underlain
by
karst
topography
and
sandy
(
porous)
sub­
soils,
because
these
geological
features
­
common
in
the
southeastern
U.
S.
­
could
lead
to
ground­
water
contamination.
See
the
Reregistration
Eligibility
Decision
(
RED)
for
1,3­
D
(
U.
S.
EPA,
1998).

Another
constraint
for
using
1,3­
D
is
long
pre­
planting
intervals
because
of
its
persistence
in
the
soil,
forcing
growers
to
delay
planting
and/
or
modify
their
production
schedules.
See
"
Market
Window
Information"
on
page
15
for
more
information.

The
combination
of
1,3­
D
and
metam
sodium
is
not
widely
used
in
the
U.
S.
because:
(
a)
mixing
1,3­
D
with
metam
sodium
does
not
control
any
of
the
key
pest
species
that
1,3­
D
alone
will
not
control,
(
b)
heavy
soil
in
any
growing
area,
township
caps
in
California
and
karst
topography
in
Florida
limit
the
use
of
1,3­
D,
whether
this
chemical
is
used
alone
or
in
combination
with
metam
sodium
(
c)
adding
metam
sodium
to
1,3­
D
will
not
provide
affective
disease
control,
in
areas
where
there
is
only
a
single
drip
irrigation
tape
used
in
those
cases
1,3­
D
needs
to
be
shank
injected
with
metam
sodium
sprayed
on
the
surface
of
the
bed
and
then
mechanically
incorporated
(
a
multi
step
process),
and
(
d)
there
are
different
moisture
requirements
for
1,3­
D
and
metam
sodium.

The
U.
S.
is
aware
that
approximately
10
percent
of
strawberry
growers
in
many
regions
have
adopted
the
1,3­
D
+
chloropicrin
combination
as
a
MB
alternative
and
this
information
was
taken
into
consideration
when
this
sector's
CUE
request
was
calculated.

California
A
major
impediment
to
the
broader
adoption
of
1,3­
D
fumigation
in
California
strawberry
production
areas
is
the
state
regulations
regarding
township
caps.
Regulatory
constraints
on
1,3­
D
products
impact
approximately
two­
thirds
of
California
strawberry
production
areas
when
this
product
is
not
available
as
an
alternative
fumigant.
Current
restrictions
in
the
State
of
California
limit
total
1,3­
D
use
within
36­
square­
mile­
areas,
known
as
townships.
This
(
maximum)
amount
depends
on
the
depth
and
timing
of
the
applications,
with
a
total
of
90,250
pounds
per
township
allowed
if
applications
are
made
to
a
depth
greater
than
18
inches
between
February
and
November.
The
limit
is
reduced
if
applications
are
made
at
shallow
depths
or
during
December
or
January.
Applied
at
140
lbs/
A
(
160kg/
ha)
a
maximum
of
645
acres
per
township,
just
under
3%
of
a
Page
8
township's
acreage,
may
be
legally
fumigated
with
1,3­
D
in
a
year.

The
combination
of
1,3­
D
and
chloropicrin
is
being
used
in
California
on
a
limited
basis
and
may
be
technically
feasible,
provided
that
an
adequate
means
of
weed
control
is
used
in
addition
to
this
chemical
combination.
However,
yields
for
1,3­
D
+
chloropicrin
treated
strawberry
fields
in
California
are
consistently
lower
than
fields
treated
with
MB
+
chloropicrin,
as
demonstrated
by
Shaw
and
Larson
(
1999)
through
a
meta­
analysis
of
strawberry
yield
responses
involving
9
of
10
individual
California
studies
examined
(
see
Table
3
below).
They
report
an
average
percent
yield
loss
of
over
14%
from
using
1,3­
D
+
chloropicrin,
and
Table
2
displays
the
significant
economic
impacts
on
California
farmers
when
using
alternatives.

TABLE
3.
EFFECTS
OF
SOIL
FUMIGATION
WITH
METHYL
BROMIDE/
CHLOROPICRIN
(
MB/
CP)
VS.
DICHLOROPROPENE/
CHLOROPICRIN
(
DP/
CP)
ON
YIELDS
(
GRAMS/
PLANT)
OF
STRAWBERRY
IN
10
STUDIES
(
FROM
SHAW
AND
LARSON
1999).
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%.

Currently,
85­
90
percent
of
strawberry
ground
is
broadcast
fumigated
with
MB/
chloropicrin.
Broadcast
fumigation
with1,3­
D/
chloropicrin
is
not
a
feasible
alternative
for
a
majority
of
the
hectares
due
to
regulatory
and
economic
constraints.
Most
of
the
strawberries
in
California
are
grown
in
coastal
urban/
agricultural
areas
where
buffer
zones
are
a
major
consideration
during
the
fumigation
permitting
process.
Buffer
zones
on
the
California
1,3­
D/
chloropicrin
labels
are
300
feet
(
91
meters)
for
broadcast
applications
when
used
on
annual
crops
such
as
strawberries.
A
new
federal
label
reducing
the
buffer
zones
to
100
feet
(
30
meters)
is
expected
to
be
submitted
soon
for
consideration
by
the
California
Department
of
Pesticide
Regulation.
(
Original
estimates
in
the
U.
S.
nomination
were
also
based
on
the
100­
foot
buffer
zone.)
Additionally,
the
significantly
higher
cost
of
broadcast
fumigation
with
1,3­
D/
chloropicrin
($
1400/
acre
broadcast
vs.
$
900/
acre
drip)
has
severely
limited
its
use
as
an
alternative
to
MB.

In
California,
drip
applications
of
1,3­
D/
chloropicrin
are
less
expensive
and
require
smaller
buffer
zones
than
broadcast
applications,
making
drip
the
main
method
used
to
Page
9
apply
this
alternative.
Currently,
90
percent
of
the
1,3­
D/
chloropicrin
treated
strawberry
hectares
is
through
drip
application,
while
10
percent
is
through
broadcast
application.
However,
in
both
cases,
production
costs
are
significantly
higher
due
to
the
need
for
increased
herbicide
applications
and
hand
weeding
operations.
Recent
studies
in
California
found
that
the
cost
of
drip
or
shank
applications
of
1,3­
D/
chloropicrin
were
25­
36%
higher
than
MB/
chloropicrin
(
Goodhue
et
al.,
2001).
Costs
of
chloropicrin
alone
were
comparable
to
MB
but
chloropicrin
fails
to
control
nematodes.

There
are
also
significant
technical
barriers
to
drip
applied
1,3­
D/
chloropicrin
for
California
strawberry
growers.
For
many
farms
their
irrigation
systems
are
not
efficient
enough
to
be
used
for
drip
fumigation.
There
are
also
serious
technical
challenges
to
using
drip
irrigation
systems
to
uniformly
and
effectively
fumigate
slopes
and
hillsides,
where
significant
portions
of
California's
strawberries
are
grown.
It
will
require
a
significant
investment
of
capital
and
time
to
find
solutions
to
the
technical
limitations
inherent
in
the
adoption
of
drip
applied
1,3­
D/
chloropicrin.

In
California,
the
use
of
1,3­
D
has
resulted
in
longer
delays
between
fumigation
and
planting.
In
many
cases
this
forces
growers
to
abbreviate
their
growing
season
in
order
to
prepare
the
ground
for
the
following
season
in
areas
where
strawberries
are
not
rotated
with
other
crops.
The
timing
of
rotation
with
lettuce/
vegetable
crops
is
also
affected
due
to
the
need
to
fumigate
up
to
three
weeks
earlier
than
with
MB/
chloropicrin.
There
have
also
been
reports
of
phytotoxicity
on
strawberry
from
1,3­
D.

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
in
most
strawberry
producing
counties.
Because
of
the
range
of
economic,
environmental,
and
regulatory
difficulties
described
here,
the
United
States
deemed
1,3­
D
+
chloropicrin
was
not
a
feasible
alternative
in
areas
of
moderate
to
severe
pest
pressure.

The
combination
of
1,3­
D
and
metam
sodium
is
not
being
used
in
California,
because:
(
a)
mixing
1,3­
D
with
metam
sodium
does
not
control
any
of
the
key
pest
species
from
California
that
1,3­
D
alone
will
not
control,
(
b)
township
caps
limit
the
use
of
1,3­
D,
whether
this
chemical
is
used
alone
or
in
combination
with
metam
sodium
(
c)
adding
metam
sodium
to
1,3­
D
will
not
provide
affective
disease
control,
in
areas
where
there
is
only
a
single
drip
irrigation
tape
used
1,3­
D
needs
to
be
shank
injected
with
metam
sodium
sprayed
on
the
surface
of
the
bed
and
then
mechanically
incorporated
(
a
multi
step
process),
(
d)
there
are
different
moisture
requirements
for
1,3­
D
and
metam
sodium,
and
(
e)
California
is
reviewing
metam
sodium
as
a
potential
air
pollutant
and
because
future
use
may
be
constrained,
many
researchers
and
growers
are
not
actively
evaluating
this
product.

Florida
The
1,3­
D
+
chloropicrin
alternative
is
also
being
used
in
Florida
on
a
limited
basis
and
is
technically
feasible
only
in
areas
of
light
to
moderate
nutsedge
pressure.
Data
associated
Page
10
with
1,3­
D
+
chloropicrin
show
a
range
of
yield
loses
from
0­
25
percent
compared
to
strawberry
fruit
production
using
MB.

Additionally,
1,3­
D
+
chloropicrin
is
not
being
extensively
used
in
Florida
because
of
the
concerns
with
buffers,
PPE
requirements,
and
pre­
planting
intervals.
Also,
use
of
1,3­
D
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.
This
characteristic
is
desirable
for
orchard
replant
but
highly
undesirable
for
annual
crops
(
personal
communication
with
Sally
Schneider,
Agricultural
Research
Service,
US
Department
of
Agriculture;
and
Michael
V.
McKenry,
University
of
California.
Riverside,
Parlier,
California).
When
1,3­
D
is
used
in
combination
with
chloropicrin,
growers
experience
limited
flexibility
in
scheduling
fumigation
operations.
This
is
important
in
Florida
where
rainstorms
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
to
avoid
having
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.

The
1,3­
D
and
metam
sodium
combination
is
not
considered
a
viable
alternative
in
Florida
because:
(
a)
mixing
1,3­
D
with
metam
sodium
does
not
control
any
of
the
key
pest
species
from
Florida
that
1,3­
D
alone
will
not
control,
(
b)
adding
metam
sodium
to
1,3­
D
will
not
provide
affective
disease
control,
in
areas
where
there
is
only
a
single
drip
irrigation
tape
used
1,3­
D
needs
to
be
shank
injected
with
metam
sodium
sprayed
on
the
surface
of
the
bed
and
then
mechanically
incorporated
(
a
multi
step
process),
(
c)
there
are
different
moisture
requirements
for
1,3­
D
and
metam
sodium,
and
(
d)
1,3­
D
is
restricted
to
areas
without
karst
topography
as
would
a
combination
of
1,3­
D
and
metam
sodium.

Southeastern
U.
S.
The
1,3­
D
and
chloropicrin
combination
is
being
used
in
the
Southeastern
U.
S.
on
a
limited
basis.
This
combination,
however,
is
technically
feasible
only
where
nutsedge
is
not
prevalent
under
moderate
to
severe
pressure
pest
situations,
which
is
approximately
30
percent
of
the
area.
An
effective
companion
herbicide
is
needed
for
the
remaining
70
percent
where
nutsedge
is
a
major
problem.
However,
as
discussed
above,
no
such
herbicide
is
currently
available
in
the
United
States
The
yield
loss
estimate
associated
with
1,3­
D/
chloropicrin
combination
ranges
up
to
60
percent
compared
to
strawberry
fruit
production
with
MB.
The
Southeastern
U.
S.
growers
can
also
experience
the
same
weather
related
delays
and
concerns
as
the
growers
in
Florida.

Requirements
for
a
91­
meter
buffer
zone
(
now
changing
to
a
30­
meter
buffer
zone
at
the
national
level,
although
the
revised
buffer
is
not
accepted
by
all
states)
and
PPE
that
must
still
be
used
by
those
coming
in
contact
with
the
substance
may
make
it
impractical
to
adopt
1,3­
D.
For
small
farms
in
the
Southeastern
U.
S.,
the
buffer
requirements
eliminate
Page
11
a
large
portion
of
the
area
around
the
field
perimeter,
reducing
the
total
area
available
for
strawberry
production.
The
typical
size
of
a
strawberry
field
in
the
southeastern
U.
S.
is
four
hectares
or
less,
or
is
a
"
you­
pick"
operation
located
close
to
inhabited
structures.
1,3­
D
cannot
be
used
on
up
to
90%
of
the
hectares
due
to
these
regulatory
buffer
zone
restrictions.

The
combination
of
1,3­
D
and
metam
sodium
is
not
widely
used
in
the
southeast
U.
S.
because:
(
a)
mixing
1,3­
D
with
metam
sodium
does
not
control
any
of
the
key
pest
species
that
1,3­
D
alone
will
not
control,
(
b)
heavy
soil
in
any
growing
area
limits
the
use
of
1,3­
D,
whether
this
chemical
is
used
alone
or
in
combination
with
metam
sodium
(
c)
adding
metam
sodium
to
1,3­
D
will
not
provide
affective
disease
control,
in
areas
where
there
is
only
a
single
drip
irrigation
tape
used,
in
those
cases
1,3­
D
needs
to
be
shank
injected
with
metam
sodium
sprayed
on
the
surface
of
the
bed
and
then
mechanically
incorporated
(
a
multi
step
process),
and
(
d)
there
are
different
moisture
requirements
for
1,3­
D
and
metam
sodium.
Page
12
TABLE
4.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
STRAWBERRY
SECTOR*

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

1997
236
2,637,817
10,470
1998
233
2,755,404
11,185
1999
203
3,039,117
12,510
2000
189
2,617,237
12,307
2001
175
2,690,102
14,643
*
Strawberry
acres
planted
in
U.
S.:
47,400
(
19,182
ha).
Percent
of
U.
S.
strawberry
acreage
requested:
77%
Source:
Rates,
amounts,
and
area
treated
are
from
applicants'
information.
Percent
of
U.
S.
acreage
is
from
USDA,
2001.
National
Agricultural
Statistics
Service,
Agricultural
Statistics
2001
TABLE
5.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
STRAWBERRY
SECTOR
Calculation
of
Nominated
Amount
0024
 
California
Strawberry
Commission
0037
 
Southeastern
Strawberry
Consortium
0053
 
Florida
Fruit
and
Vegetable
Association
 
Strawberry
Hectares
(
ha)
10,117
1,817
2,873
%
of
Regional
hectares
(
ha)(
A)
95
112
109
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
2,041,164
272,908
579,691
Double
Counted
hectares
(
ha)(
B)
0
0
0
Growth
/
Increasing
Production
(
ha)(
C)
(
58)
0
0
Quarantine
and
Pre­
Shipment
hectares
(
D)
0
0
0
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)
10,117
1,817
2,873
Key
Pest
Impacts
(%)(
F)
89
30
40
Regulatory
Impacts
(%)(
G)
64
90
1
Soil
Impacts
(%)(
H)
0
0
40
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
89
90
60
Qualifying
Area
(
ha)(
J)
9,004
1,635
1,724
Use
Rate
(
kg/
ha)(
K)
202
150
202
CUE
Amount
Nominated
(
kg)(
L)
1,816,637
245,617
347,814
%
Reduction
from
Initial
Request
(
M)
11
10
40
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
2,410,068
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
2,468,873
Page
13
Footnotes
for
Table
5:
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
al2ways
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nominations
(
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.
No
growth
was
requested
in
this
sector.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Quarantine
and
pre­
shipment
is
not
applicable
to
this
sector.
E.
Adjusted
hectares
requested
is
the
hectares
in
the
applicant's
request
minus
the
hectares
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
Florida
and
the
Southeastern
U.
S.
the
key
pest
is
nutsedge,
for
California
the
key
pest
is
Phytophthora.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps).
For
California,
the
regulatory
constraint
is
the
township
cap.
In
the
southeast
and
Florida
the
required
buffer
to
inhabited
structures
is
the
regulatory
constraint.
The
buffer
constraint
has
a
much
bigger
impact
in
the
southeast
than
in
Florida
due
to
the
very
small
average
size
of
operations
in
the
southeast.
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
40%
of
the
strawberry
growing
areas
in
Florida
have
karst
topography
and
the
1,3­
D
cannot
be
used
due
to
the
potential
for
groundwater
contamination.
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.
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
Page
14
error
multiplier.
TABLE
6.
HERBICIDES
REGISTERED
IN
THE
UNITED
STATES
TO
CONTROL
NUTSEDGE
IN
STRAWBERRIES
Herbicide
U.
S.
Registration
Status*
Major
Comments
Glyphosate
Yes
Non­
selective;
only
temporarily
suppresses
nutsedge
and
may
promote
further
nutsedge
growth
by
releasing
tubers
from
dormancy;
rotation
restrictions
Paraquat
Yes
Non­
selective;
suppresses
nutsedge
only
temporarily
and
may
promote
further
nutsedge
growth
by
releasing
tubers
from
dormancy;
rotation
restrictions
Terbacil
Yes
Suppresses
nutsedge
temporarily
and
may
promote
additional
nutsedge
growth
by
releasing
tubers
from
dormancy;
rotation
restrictions
*
Y
=
Registered
for
use;
N
=
Not
registered
for
use
Additional
notes
on
specific
herbicides
listed:
Glyphosate
Glyphosate
is
a
non­
selective
herbicide
that
usually
only
suppresses
but
does
not
control
nutsedge
development.
Additionally,
glyphosate
provides
no
residual
weed
control.
Glyphosate
may
be
applied
prior
to
planting
or
ONLY
between
vegetable
rows.
Contact
of
glyphosate
with
the
crop
will
likely
cause
severe
injury.
Row
middle
application
use
is
limited
because
of
the
potential
of
glyphosate
drift
to
the
crop
causing
severe
injury.
Paraquat
Paraquat
is
a
non­
selective
herbicide
that
provides
poor
control
of
nutsedge.
Additionally,
paraquat
does
not
provide
residual
weed
control.
Paraquat
may
be
applied
prior
to
planting
or
ONLY
between
vegetable
rows.
Contact
of
paraquat
with
the
crop
can
cause
severe
injury.
Terbacil
Terbacil
is
registered
for
use
in
strawberries
in
Florida
and
the
Southeast,
but
is
not
registered
in
California.
According
to
the
label,
this
herbicide
provides
partial
control
of
yellow
nutsedge.
By
only
suppressing
yellow
nutsedge,
terbacil
does
not
provide
adequate
control
of
nutsedge
under
moderate
to
high­
pressure
conditions.
Other
limitations
to
this
herbicide
include
rotational
restrictions
of
one
to
two
years,
depending
on
the
crop,
and
it
may
not
be
applied
to
soils
with
less
that
0.5
percent
organic
matter.

HISTORICAL
EMISSION
REDUCTIONS
&
METHYL
BROMIDE
DOSAGE
RATES
The
U.
S.
strawberry
fruit
production
sector
has
been
a
leader
in
testing
and
adopting
emission
reduction
technologies,
such
as
tarps
and
soil
injection,
to
reduce
emissions
and
increase
the
effectiveness
of
each
unit
of
MB
used.
In
addition,
this
sector
has
shifted
to
formulations
with
lower
MB
concentrations
and
continues
to
test
other
formulations
with
even
lower
proportions
of
MB.
In
California,
the
MB
dosage
rate
in
1997
was
270
kg/
ha
and
declined
to
240
kg/
ha
in
2002
 
with
the
reduction
being
due
to
lowered
overall
application
rates
during
this
period,
as
well
as
a
significant
shift
to
a
57:
43
formulation
(
by
up
to
50%
of
California
strawberry
growers).

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:

Disposal
Issues

Landfill
disposal
of
VIF
and
VIF
burning
have
come
under
increasing
restrictions
in
some
jurisdictions;
both
are
labor­
intensive
and
costly.
Page
15

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
MB
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
of
adequate
VIF
tarps
to
U.
S.
farmers
before
the
2005
phase­
out
date.

VIF
Challenges
to
Agricultural
Practices

A
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).

MARKET
WINDOW
INFORMATION
The
series
below
indicate
the
importance
of
considering
market
windows,
and
the
concomitant
large
difference
in
prices
that
accompany
them,
when
deciding
if
alternatives
to
MB
are
economically
feasible.
Although
such
detailed
series
are
not
available
for
all
crops,
both
tomatoes
and
strawberries
demonstrate
large
fluctuations
in
prices
over
three
week
intervals
from
peak
price
to
the
mid­
season
price.
This
pattern
is
also
observable
for
other
fresh
fruit
and
vegetable
crops.
The
existence
of
these
sharp
declines
in
prices
which
occur
after
a
short
period
of
high
prices
(
a
period
know
as
`
the
market
window')
ensure
that
revenue
losses
caused
by
the
longer
plant­
back
periods
required
when
using
certain
alternatives
will
not
be
proportional
to
the
lost
production
time
but
will,
rather,
be
amplified
by
the
lower
commodity
price
of
the
post­
`
market
window'.
The
result
is
a
decline
in
crop
revenue,
which
in
the
case
of
Florida
strawberries
would
be
approximately
40%
of
gross
revenue
apart
from
any
losses
due
to
reduced
production.
Page
16
Prices
received
by
strawberry
growers
rapidly
decline
from
their
early
season
peak.
The
average
price
received
by
Florida
Strawberry
growers
dropped
30%
between
February
and
March
in
1999,
37%
in
2000,
and
40%
in
2001.
In
California
strawberry
prices
declined
in
this
time
period
19%
in
1999,
29%
in
2000,
and
23%
in
2001.

Plant
back
restrictions
could
cause
growers
to
completely
miss
critical,
short­
lived
market
windows
when
products
reach
their
peak
market
prices;
forcing
producers
to
sell
at
significantly
lower
prices.
Missing
a
market
window
could,
therefore,
turn
a
profitable
year
into
an
unprofitable
one
for
the
affected
growers.

Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
01
Feb­
01
Mar­
01
Apr­
01
May­
01
Jun­
01
Jul­
01
Aug­
01
Sep­
01
Oct­
01
Nov­
01
Dec­
01
FL
CA
Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
1999
­
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
99
Mar­
99
May­
99
Jul­
99
Sep­
99
Nov­
99
Jan­
00
Mar­
00
May­
00
Jul­
00
Sep­
00
Nov­
00
Jan­
01
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
DEFINITIONS
THAT
MAY
BE
RELEVANT
TO
THIS
CUE
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
United
States
is
requesting
continued
use
of
MB),
the
United
States
developed
such
estimates
by
contacting
university
professors
conducting
experiments
using
MB
alternatives
in
the
appropriate
land
grant
institutions.
The
experts
were
asked
to
develop
such
an
estimate
based
on
their
experience
with
MB
and
with
alternatives.
The
results
of
this
process
were
used
when
better
data
were
not
available.
Page
17
Source
of
buffer
restriction
implications
for
MB
use
Estimates
of
the
impact
of
buffers
required
when
using
some
MB
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
MB
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
the
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
which
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
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.
Page
18
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.

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.

Environmental
Protection
Agency,
1998.
Reregistration
Eligibility
Decision
(
RED)
1,3­
Dichloropropene.
Available
at
http://
www.
epa.
gov/
REDs/
0328red.
pdf
Goodhue,
Rachael
E.,
Steven
A.
Fennimore,
and
Husein
Ajwa.
2001.
Economic
Feasibility
of
Methyl
Bromide
Alternatives:
Field­
Level
Cost
Analysis.
University
of
California,
Davis.
Unpublished
report.

Shaw,
Douglas
V.
and
Kirk
.
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.

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

USDA.
1999.
Crop
Profile
for
Strawberries
in
California.
http://
pestdata.
ncsu.
edu/
cropprofiles/
docs/
castrawberries.
html
USDA.
2002.
Crop
Profile
for
Strawberry
in
Florida.
http://
pestdata.
ncsu.
edu/
cropprofiles/
docs/
FLstrawberries.
html
U.
S.
EPA.
1998.
Reregistration
Eligibility
Decision
(
RED),
1,3­
Dichlorpropene
http://
www.
epa.
gov/
REDs/
0328red.
pdf
Page
19
APPENDIX:
TABLE
3.
FROM
NOMINATION
CHAPTER:
NOT­
IN­
KIND
METHYL
BROMIDE
ALTERNATIVES
IDENTIFIED
BY
MBTOC
FOR
STRAWBERRY
FIELD
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
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.)
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
Page
20
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
MB.

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
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
MB
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
MB
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
prevent
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.
Page
21
General
IPM.
General
IPM
is
being
already
being
used
in
strawberry
production,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
MB.
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
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
MB.
Composting
is
management
intensive
and
it
does
not
offer
adequate
pest
control
by
itself.
Yield
loss
are
estimated
to
range
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
MB
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
MB.

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
are
currently
being
used,
but
are
not
technically
feasible
as
a
standalone
replacement
for
MB.
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.
