METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
ORCHARD
REPLANT
FOR
ADMINISTRATIVE
PURPOSES
ONLY:
DATE
RECEIVED
BY
OZONE
SECRETARIAT:

YEAR:
CUN:

NOMINATING
PARTY:
The
United
States
of
America
BRIEF
DESCRIPTIVE
TITLE
OF
NOMINATION:
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Orchard
Replant
NOMINATING
PARTY
CONTACT
DETAILS
Contact
Person:
John
E.
Thompson,
Ph.
D.
Title:
International
Affairs
Officer
Address:
Office
of
Environmental
Policy
U.
S.
Department
of
State
2201
C
Street
N.
W.
Room
4325
Washington,
DC
20520
U.
S.
A.
Telephone:
(
202)
647­
9799
Fax:
(
202)
647­
5947
E­
mail:
ThompsonJE2@
state.
gov
Following
the
requirements
of
Decision
IX/
6
paragraph
(
a)(
1),
the
United
States
of
America
has
determined
that
the
specific
use
detailed
in
this
Critical
Use
Nomination
is
critical
because
the
lack
of
availability
of
methyl
bromide
for
this
use
would
result
in
a
significant
market
disruption.

X
Yes

No
CONTACT
OR
EXPERT(
S)
FOR
FURTHER
TECHNICAL
DETAILS
Contact/
Expert
Person:
Tina
E.
Levine,
Ph.
D.
Title:
Division
Director
Address:
Biological
and
Economic
Analysis
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
ii
U.
S.
A.
Telephone:
(
703)
308­
3099
Fax:
(
703)
308­
8090
E­
mail:
levine.
tina@
epa.
gov
LIST
OF
DOCUMENTS
SENT
TO
THE
OZONE
SECRETARIAT
IN
OFFICIAL
NOMINATION
PACKAGE
List
all
paper
and
electronic
documents
submitted
by
the
Nominating
Party
to
the
Ozone
Secretariat
1.
PAPER
DOCUMENTS:
Title
of
Paper
Documents
and
Appendices
Number
of
Pages
Date
Sent
to
Ozone
Secretariat
2.
ELECTRONIC
COPIES
OF
ALL
PAPER
DOCUMENTS:
Title
of
Electronic
Files
Size
of
File
(
kb)
Date
Sent
to
Ozone
Secretariat
iii
TABLE
OF
CONTENTS
PART
A:
SUMMARY
.....................................................................................................................
8
1.
Nominating
Party
_________________________________________________________
8
2.
Descriptive
Title
of
Nomination______________________________________________
8
3.
Crop
and
Summary
of
Crop
System___________________________________________
8
4.
Methyl
Bromide
Nominated
_________________________________________________
9
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
9
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible_____________________________
11
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
11
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
13
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
14
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE......................................................................................................
16
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request__________________
16
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
11.
Characteristics
of
Cropping
System
and
Climate_______________________________________________________________
16
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________________
18
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
C:
TECHNICAL
VALIDATION
.................................................................................................................................................
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
13.
Reason
for
Alternatives
Not
Being
Feasible
__________________________________________________________________
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
______________________________________________
21
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________
22
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
_________________________________________
22
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
________________________________________________________________________
23
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
________________
24
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Summary
of
Technical
Feasibility
_
24
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE.........................................................................
24
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request____
24
iv
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
11.
Characteristics
of
Cropping
System
and
Climate
________________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
________________________________________________________________
27
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
C:
TECHNICAL
VALIDATION..............................................................................................................................
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________________________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
______________________________________
30
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________
30
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________
31
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?_________________________________________________________________
33
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Summary
of
Technical
Feasibility
________________________________________________________________
34
CALIFORNIA
WALNUT
COMMISSION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE...........................................................................................................................................
34
California
Walnut
Commission
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
_________________________________
34
California
Walnut
Commission
­
11.
Characteristics
of
Cropping
System
and
Climate
____
35
California
Walnut
Commission
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
___________
36
CALIFORNIA
WALNUT
COMMISSION
­
PART
C:
TECHNICAL
VALIDATION.....................................
37
California
Walnut
Commission
­
13.
Reason
for
Alternatives
Not
Being
Feasible
________
37
California
Walnut
Commission
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_________________________________________________________________
39
California
Walnut
Commission
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_________________________________________
40
California
Walnut
Commission
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
___________________________________________________________
40
California
Walnut
Commission
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
______________
41
California
Walnut
Commission
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_____________________________________
42
California
Walnut
Commission
­
Summary
of
Technical
Feasibility
__________________
43
v
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
.............................................................................................................
43
Almond
Hullers
&
Processors
Association
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request
________________________
43
Almond
Hullers
&
Processors
Association
­
11.
Characteristics
of
Cropping
System
and
Climate
__________________________________________________________________
44
Almond
Hullers
&
Processors
Association
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
_____
46
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
C:
TECHNICAL
VALIDATION
................
47
Almond
Hullers
&
Processors
Association
­
13.
Reason
for
Alternatives
Not
Being
Feasible
47
Almond
Hullers
&
Processors
Association
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:_________________________________________________________
49
Almond
Hullers
&
Processors
Association
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________
49
Almond
Hullers
&
Processors
Association
­
16.
State
Relative
Effectiveness
of
Relevant
Alternatives
Compared
to
Methyl
Bromide
for
the
Specific
Key
Target
Pests
and
Weeds
for
which
It
Is
Being
Requested
__________________________________________________
50
Almond
Hullers
&
Processors
Association
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
_________
51
Almond
Hullers
&
Processors
Association
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
______________________
52
Almond
Hullers
&
Processors
Association
­
Summary
of
Technical
Feasibility__________
53
PART
D:
EMISSION
CONTROL
..................................................................................................
54
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
54
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
55
PART
E:
ECONOMIC
ASSESSMENT...............................................................................................
55
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
55
22.
Gross
and
Net
Revenue___________________________________________________
55
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
56
Summary
of
Economic
Feasibility
_____________________________________________
57
PART
F.
FUTURE
PLANS
.............................................................................................................
58
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
58
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
59
25.
Additional
Comments
on
the
Nomination
____________________________________
59
26.
Citations
______________________________________________________________
59
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.
vi
LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
8
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
9
Table
A.
1:
Executive
Summary
_________________________________________________
11
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
11
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use______________________
13
Table
A.
2:
2006
Sector
Nomination
______________________________________________
15
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________________________________________________
16
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_________________________________________
16
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________________
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule___________________________________________________________
17
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_________________________________________________________
18
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
C:
TECHNICAL
VALIDATION_
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible___________________________________________________________
19
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
___________________________________________________
21
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
15.1:
Present
Registration
Status
of
Alternatives___________________________________________________________
22
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder
_______________________________________________________
22
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary_______________________________________________________________
23
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________________________
24
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
________________________________
24
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
11.1:
Characteristics
of
Cropping
System_________________________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
________________________________________________
26
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
___________________________________________________
27
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
­
PART
C:
TECHNICAL
VALIDATION
_____________________________________________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
_____________________________________________
28
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
15.1:
Present
Registration
Status
of
Alternatives
___________________________________________
30
vii
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder
(
Nematodes)
__________________________________
31
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
______________________________________________________
32
CALIFORNIA
WALNUT
COMMISSION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
34
California
Walnut
Commission
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_________________________________________________________
34
California
Walnut
Commission
­
Table
11.1:
Characteristics
of
Cropping
System__________
35
California
Walnut
Commission
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
__
35
California
Walnut
Commission
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
____
36
CALIFORNIA
WALNUT
COMMISSION
­
PART
C:
TECHNICAL
VALIDATION_____________________
37
California
Walnut
Commission
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
___
37
California
Walnut
Commission
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
39
California
Walnut
Commission
 
Table
15.1:
Present
Registration
Status
of
Alternatives
____
40
California
Walnut
Commission
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
____
40
California
Walnut
Commission
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_______
41
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE____________________________________________________________
43
Almond
Hullers
&
Processors
Association
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
_______________________________________________
43
Almond
Hullers
&
Processors
Association
­
Table
11.1:
Characteristics
of
Cropping
System_
44
Almond
Hullers
&
Processors
Association
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_______________________________________________________________
44
Almond
Hullers
&
Processors
Association
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________________________________________________
46
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
PART
C:
TECHNICAL
VALIDATION
___________
47
Almond
Hullers
&
Processors
Association
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
________________________________________________________________
47
Almond
Hullers
&
Processors
Association
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion______________________________________________________________
49
Almond
Hullers
&
Processors
Association
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________________________________________________
49
Almond
Hullers
&
Processors
Association
 
Table
16.1:
Effectiveness
of
Alternatives
 
Replant
Disorder________________________________________________________________
50
Almond
Hullers
&
Processors
Association
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_______________________________________________________________________
51
PART
D:
EMISSION
CONTROL
___________________________________________________
54
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
54
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
55
PART
F.
FUTURE
PLANS
________________________________________________________
58
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
61
Page
8
PART
A:
SUMMARY
1.
NOMINATING
PARTY
The
United
States
of
America
(
U.
S.)

2.
DESCRIPTIVE
TITLE
OF
NOMINATION
Methyl
Bromide
Critical
Use
Nomination
for
Preplant
Soil
Use
for
Orchard
Replant
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
The
Orchard
Replant
sector
represents
stone
fruit,
almond,
and
walnut
orchards,
and
table
grape
and
raisin
vineyards,
in
California.
Growers
of
all
of
these
commodities
face
a
common
threat
 
a
poorly
understood
disease
complex
called
"
orchard
replant
problem"
or
"
disorder".
The
disorder
can
be
of
varying
severity
depending
on
orchard
location,
crop,
soil
texture,
soil
moisture,
or
other
factors.
Orchards
with
replant
problem
have
several
visible
effects,
the
first
and
most
apparent
is
poor
tree
growth
during
the
early
years
of
establishment
(
rejection
component)
and
in
some
cases
a
slow
and
detrimental
decline
in
root
health
and
plant
growth
caused
primarily
by
pathogenic
nematodes
and
fungi.
Environmental
interactions
and
damage
by
other
pests
(
e.
g.,
insects,
nutrient
deficiency
or
wind
blow­
down)
are
less
well
documented,
but
anything
that
limits
early
development
of
root
growth
can
predispose
the
trees
to
greater
damage
from
subsequent
agents.
The
long
life
of
a
productive
orchard
(
20
to
40
years)
necessitates
a
long­
term
approach
to
orchard
management.
Typically,
the
first
step
in
the
establishment
of
an
orchard
on
land
previously
planted
to
orchard
crops,
is
ripping
the
soil
and
then
fumigating.
These
eliminate
(
or
reduce)
both
pests
and
remnant
roots
of
previous
plantings
that
harbor
the
pests.
This
pre­
plant
fumigation
occurs
only
once
in
the
life
of
the
orchard,
and
therefore,
the
most
cost
effective
but
deep
penetrating
treatment
is
sought
by
growers.
In
the
past
both
methyl
bromide
(
MB)
and
1,3­
dichloropropene
(
1,3­
D)
have
been
the
standards
for
orchard
replant,
however
the
use
label
for
1,3­
D
was
revised
in
the
mid­
1990s
with
rate
and
use
restriction.
Consequently,
1,3­
D
is
not
effective
in
many
orchard
replant
situations,
which
makes
MB
a
critical
tool
to
an
orchard's
long­
term
productivity.

The
typical
practice
of
replanting
orchards
or
vineyards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest.
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
late
winter.
With
MB
growers
have
usually
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.
In
a
minority
of
orchard
replant
sites,
1,3­
D,
sometimes
in
combination
with
chloropicrin,
can
be
an
alternative
to
MB.
However,
it
is
only
effective
in
orchards
with
sandy
soils
where
moisture
levels
at
over
1
meter
depth
are
reduced
(
and
where
township
restrictions
do
not
apply).
When
it
is
used,
1,3­
D
is
applied
after
removal
of
old
trees,
followed
by
soil
ripping
and
deep
soil
drying
and
then
land
leveling
where
needed.
Depending
on
soil
texture,
availability
of
preferred
new
cultivars,
and
finances
of
the
enterprise,
the
land
is
left
fallow
for
one
year
to
accomplish
all
these
activities.
Page
9
4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
859,758
2,698
5.
BRIEF
SUMMARY
OF
THE
NEED
FOR
METHYL
BROMIDE
AS
A
CRITICAL
USE
The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
U.
S.
orchard
replant
production
there
are
several
factors
that
make
the
potential
alternatives
to
methyl
bromide
unsuitable.
These
include:
­
pest
control
efficacy
of
alternatives:
the
efficacy
of
alternatives
may
not
be
comparable
to
methyl
bromide
in
some
areas,
making
these
alternatives
technically
and/
or
economically
infeasible
for
use
in
orchard
replant.
­
geographic
distribution
of
key
target
pests:
i.
e.,
some
alternatives
may
be
comparable
to
methyl
bromide
as
long
as
key
pests
occur
at
low
pressure,
and
in
such
cases
the
US
is
only
nominating
a
CUE
where
the
key
pest
pressure
is
moderate
to
high.
­
regulatory
constraints:
e.
g.,
1,3­
D
use
is
limited
in
California
due
to
the
township
caps.
­
soil
conditions
may
not
be
suitable
for
use
of
the
alternative.
For
example
heavy
soils
retain
water
longer
may
not
be
suitable
for
the
use
of
1,3­
D.

The
U.
S.
Nomination
is
for
areas
within
this
sector
where
alternatives
are
not
suitable,
either
because
of
legal
restrictions
or
physical
features
such
as
unacceptable
soil
moisture.
For
most
sites
of
orchard
replant
with
stone
fruit,
grapes,
walnuts,
and
almonds
in
California,
MB
is
a
critical
tool
for
establishing
healthy,
long
lived
orchards.
Only
some
of
the
orchard
sites
in
California
are
currently
able
to
effectively
use
alternative
measures
to
manage
orchard
replant
disorder,
the
disease
complex
that
is
associated
with
various
pathogens
(
primarily
nematodes,
some
fungi,
and
possibly
at
least
one
insect
species)
and
environmental
forces
such
as
soils,
moisture,
climate,
and
nutrition
(
Browne
et
al.,
2002b;
McKenry,
1999).

Many
aspects
of
the
etiology
of
this
disease
complex
are
currently
not
known.
"
Orchard
replant
problem"
or
"
disorder"
presents
a
difficult
challenge
to
growers
when
replanting
orchards
and
vineyards,
considering
the
long­
term
investment
(
typically
fruit
orchards
and
vineyards
can
produce
for
20­
25
years,
walnut
orchards
can
produce
for
40
years,
and
almond
orchards
produce
on
average
25­
30
years)
that
is
necessary
for
fruit
and
nut
orchard
production.
Because
of
the
perennial
nature
of
orchards,
fumigation
of
orchards
occurs
only
once
during
the
bearing
life
of
the
trees,
and
so
the
most
efficient
system
to
produce
the
healthiest
trees
is
necessary
to
avoid
early
tree
removal,
added
costs,
and
lost
revenue
due
to
necessity
of
planting
and
then
replanting
orchards
if
replant
disorder
is
not
initially
addressed.

According
to
an
in­
depth
report
on
orchard
replant
(
McKenry,
1999),
in
1999
at
least
85%
of
the
California
walnut
acreage
is
infested
with
one
or
more
problem
nematodes
(
Pratylenchus
vulnus,
Criconemella
xenoplax,
or
Meloidogyne
spp.).
No
rootstocks
are
currently
available
that
have
sufficient
resistance
to
control
these
pests.
About
60%
of
vineyards
are
infested
with
problem
nematodes,
although
tolerant
rootstocks
can
help
ameliorate
the
replant
problem
for
some
nematodes.
However,
vineyards
are
also
susceptible
to
Phylloxera
and
Armillaria
root
Page
10
rots.
At
least
60%
of
cling
peach
areas
are
infested
with
Criconemella
xenoplax
and
another
35%
of
stone
fruit
plantings
are
infested
with
P.
vulnus
or
C.
xenoplax.
Around
35%
of
almond
plantings
are
infested
with
C.
xenoplax
and/
or
P.
vulnus;
15%
of
almond
orchards
are
infected
with
bacterial
canker,
and
5%
are
infected
with
oak
root
fungus.

Replant
disorder
is
mediated
by
environmental
conditions
or
stress,
such
that
management
can
be
effective
in
some
areas
but
not
in
others.
Effective
fumigation
prior
to
replanting
orchards
can
reduce
pest
populations
to
99.9%
in
the
top
1.5
meters
while
killing
remnant
roots
from
previous
orchard
trees.
Even
if
pests
can
be
sufficiently
controlled,
old
plant
roots
must
be
removed
or
made
unavailable
as
nutrients
over
a
period
of
time
to
allow
the
establishment
of
healthy,
actively
growing
trees.
For
the
fruit
and
nut
industries,
MB
is
critical,
especially
considering
the
once
in
an
orchard­
life
(
20­
40
years)
fumigation
requirement.

It
has
long
been
observed
that
fumigation
improves
the
growth
of
trees
in
the
beginning
stages
of
orchard
establishment
 
"
 
even
`
resistant'
rootstocks
grow
poorly
their
first
year
or
two
without
such
soil
treatments"
(
McKenry,
1999).
An
effective
pre­
plant
fumigation
should
kill
99.9%
of
nematode
pests
in
the
top
1.5
meters
of
orchard
soils,
and
should
kill
the
roots
remaining
from
the
previous
orchard
planting
(
McKenry,
1999).
If
growers
relied
on
postplanting
drip
treatments
it
would
be
difficult
to
achieve
greater
than
50­
75%
nematode
control
for
longer
than
6­
9
months
 
especially
since
no
remnant
roots
are
killed,
allowing
a
refuge
for
nematode
pests.
Pre­
plant
fumigation
also
provides
a
means
for
avoiding
repeated
post­
plant
nematicide
applications
during
the
years
following
planting;
thus
reducing
costs
and
further
pesticide
applications.
Thus,
the
importance
of
an
effective
pre­
plant
fumigation
treatment
is
critical
to
an
orchard's
survival
as
an
ongoing
commercial
operation.

Prior
to
1990,
1,3­
D
was
considered
at
least
as
good
as
MB
for
treatment
of
replant
problem
(
McKenry,
1999).
However,
due
to
environmental
and
health
concerns
(
it
is
a
B2
carcinogen
and
was
found
off
of
treatment
sites)
1,3­
D
was
banned
and
MB
became
the
predominant
treatment
for
orchard
replant.
With
the
re­
labeling
of
1,3­
D
in
the
mid­
1990s
there
were
new
restrictions
on
its
use
and
application
rate,
including
township
caps
in
California,
and
reduced
rates
that
were
considered
ineffective
for
some
severe
replant
situations
(
reduced
to
325
kg/
ha
from
427
kg/
ha).
MB,
therefore,
remains
the
standard
for
the
industry
when
establishing
nearly
all
of
California's
orchards,
except
in
the
few
with
light
soils,
with
appropriate
moisture
conditions,
where
lower
rates
of
1,3­
D
can
be
effective
(
McKenry,
1999).
[
Each
township
is
allowed
a
maximum
of
approximately
41,000
kg
per
year,
in
a
township
of
approximately
9300
ha;
at
225
kg/
ha,
180
ha
can
be
treated
with
1,3­
D
per
township.]
Page
11
TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
California
Walnut
Commission
Almond
Hullers
&
Processors
Association
AMOUNT
OF
NOMINATION
2006
Kilograms
553,098
78,944
95,525
129,491
Application
Rate
(
kg/
ha)
336
357
200
364
Area
(
ha)
1,645
221
477
355
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
716,449
165,561
226,796
176,901
Application
Rate­(
kg/
ha)
336
382
280
364
Area
(
ha)
2,131
433
809
486
ECONOMICS
Marginal
Strategy
Best
Alternative
Best
Alternative
Best
Alternative
Best
Alternative
Yield
Loss
(%)

Loss
per
hectare
(
US$/
ha)
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
Loss
as
%
of
Gross
Revenue
(%)
Loss
as
%
of
Net
Revenue
(%)
Not
included
as
there
is
no
technically
feasible
alternative.
Not
included
as
there
is
no
technically
feasible
alternative.
Not
included
as
there
is
no
technically
feasible
alternative.
Not
included
as
there
is
no
technically
feasible
alternative.

6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

The
best
alternative
for
the
orchard
replant
sector
is
1,3­
D
or
1,3­
D
with
chloropicrin,
and/
or
metam­
sodium,
especially
in
light
soils.
Under
some
soil
and
moisture
conditions
(
high
moisture
at
surface
and
less
than
12%
at
1­
1.5
meters)
1,3­
D
can
act
as
an
effective
management
tool
for
replant
problems.
However,
there
is
a
critical
need
for
MB
in
many
orchards
in
California
either
because
of
legally
mandated
township
caps
for
1,3­
D,
or
because
surface
moisture
requirements
can
not
be
met
(
e.
g.,
soils
can
not
be
adequately
dried
prior
to
use
of
1,3­
D).

7.
(
i)
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
TABLE
7.1:
PROPORTION
OF
CROPS
GROWN
USING
METHYL
BROMIDE
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
AVERAGE
TOTAL
CROP
AREA
IN
2001
AND
2002
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
not
available
(
2002)
[
requested,
2005:
3278
ha]
90%

California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
not
available
(
2002)
[
requested,
2005:
433
ha]
90%

California
Walnut
Commission
not
available
(
2002)
85%
Page
12
[
requested,
2005:
809
ha]

Almond
Hullers
&
Processors
Association
3,944
ha
planted
2002
(
of
217,570
ha
total
almonds)
Not
available
NATIONAL
TOTAL:
Not
available
Not
available
7.
(
ii)
IF
ONLY
PART
OF
THE
CROP
AREA
IS
TREATED
WITH
METHYL
BROMIDE,
INDICATE
THE
REASON
WHY
METHYL
BROMIDE
IS
NOT
USED
IN
THE
OTHER
AREA,
AND
IDENTIFY
WHAT
ALTERNATIVE
STRATEGIES
ARE
USED
TO
CONTROL
THE
TARGET
PATHOGENS
AND
WEEDS
WITHOUT
METHYL
BROMIDE
THERE.

Many
areas
of
California
that
are
amenable
to
these
crops
have
soil
types
and
moisture
characteristics
that
prevent
alternatives
from
acting
effectively
to
successfully
manage
replant
disorder;
some
areas
are
also
subject
to
township
caps
for
1,3­
D,
the
best
alternative.
In
addition,
nearly
all
orchards,
due
to
location,
soil
type,
or
other
environmental
conditions,
are
susceptible
to
the
replant
problem,
and
therefore,
require
MB
fumigation
prior
to
orchard
replant.
Areas
with
soils
that
contain
less
than
12%
moisture
at
approximately
1.5
meters
and
can
be
sufficiently
moistened
in
the
top
30
cm,
and
are
not
restricted
in
their
use
of
1,3­
D,
may
find
1,3­
D
an
effective
alternative
to
MB.
In
other
situations,
MB
is
the
only
effective
treatment.
Page
13
7.
(
iii)
WOULD
IT
BE
FEASIBLE
TO
EXPAND
THE
USE
OF
THESE
METHODS
TO
COVER
AT
LEAST
PART
OF
THE
CROP
THAT
HAS
REQUESTED
USE
OF
METHYL
BROMIDE?
WHAT
CHANGES
WOULD
BE
NECESSARY
TO
ENABLE
THIS?

Generally,
it
will
not
be
possible
to
expand
the
use
of
the
best
alternative,
1,3­
D
to
a
greater
percent
of
orchard
replant
situations
because
of
physical
and
legal
restrictions.
First,
at
current
label
rates,
1,3­
D
can
be
effective
in
light
soils,
but
not
medium
to
heavy
soils
where
moisture
content
below
1­
1.5
meters
and
on
the
surface
reduces
the
number
of
effective
sites.
Secondly,
only
if
township
cap
limitations
were
reduced
would
there
be
a
likelihood
that
1,3­
D
could
supplant
the
critical
need
for
MB
in
many
orchards.
This
is
not
a
realistic
scenario
given
environmental
and
health
concerns
for
1,3­
D
(
as
well
as
metam­
sodium)
in
California.
Furthermore,
prior
to
label
cancellation
in
1990,
1,3­
D
was
used
at
a
higher
rate
(
427
kg/
ha)
than
the
current
maximum
label
rate
(
375
kg/
ha),
established
after
its
reintroduction
for
perennials
in
1996
(
McKenry,
1999).
The
higher
rate
was
considered
significantly
more
effective
than
the
current
rate
(
where
1,3­
D
is
allowed
under
township
cap
restrictions).
Rates
are
unlikely
to
be
increased
due
to
the
probable
carcinogenic
nature
of
1,3­
D
(
B2
carcinogen).
Aside
from
township
caps,
efficacy
of
1,3­
D
is
highly
dependent
on
soil
type,
requiring
light
soils
to
be
most
effective
at
the
current
label
rates.

8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
TABLE
8.1.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
California
Walnut
Commission
Almond
Hullers
&
Processors
Association
YEAR
OF
EXEMPTION
REQUEST
2006
2006
2006
2006
KILOGRAMS
OF
METHYL
BROMIDE
716,449
165,561
226,796
176,901
USE:
FLAT
FUMIGATION
a
OR
STRIP/
BED
TREATMENT
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
Flat
Fumigation
Flat
Fumigation
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
98:
2
98:
2
98:
2
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
ha)
2,131
433
809
486
APPLICATION
RATE*
b,
c
(
kg/
ha)
[
ACTIVE
INGREDIENT]
335
(
bed
=
65%
of
ha)
382
280
364
DOSAGE
RATE*
(
g/
m2)
OF
ACTIVE
INGREDIENT
34
38.2
28
36.4
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
14
a
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
Various
methods
are
used
depending
on
the
particular
nursery,
fumigation
can
be
flat
fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application
 
approximately
0.5
kg/
tree).
b
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
Requested
rate
of
219
kg/
ha
is
dose
rate
(
21.9
g/
m2)
rather
than
rate
applied
as
if
entire
hectare
were
treated
(
335
kg/
ha).
c
Almond
Hullers
&
Processors
Association
Various
methods
are
used
depending
on
the
particular
nursery,
fumigation
can
be
Flat
Fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application
 
approximately
0.5
kg/
tree).

9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION:

The
amount
of
methyl
bromide
nominated
by
the
U.
S.
was
calculated
as
follows:
 
The
percent
of
regional
hectares
in
the
applicant's
request
was
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request.
 
Hectares
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
methyl
bromide
were
subtracted.
There
was
no
double
counting
in
this
sector.
 
Growth
or
increasing
production
(
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated)
was
subtracted.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
QPS
did
not
apply
to
this
sector.
 
Only
the
acreage
experiencing
one
or
more
of
the
following
impacts
were
included
in
the
nominated
amount:
moderate
to
heavy
key
pest
pressure,
regulatory
impacts,
and
unsuitable
terrain.
Page
15
TABLE
A.
2:
2006
SECTOR
NOMINATION
FOR
ORCHARD
REPLANT*

2006
(
Sector)
Nomination
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
California
Walnut
Commission
Almond
Hullers
&
Processors
Association
Requested
Hectares
(
ha)
2,131
433
809
486
Requested
Application
Rate
[
Active
Ingredient]
(
kg/
ha)
336
(
bed
=
65%
of
ha)
382
280
364
(
bed
=
65%
of
ha)
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
716,449
165,561
226,796
176,901
Nominated
Hectares
(
ha)
1,645
221
477
355
Nominated
Application
Rate
(
kg/
ha)
336
357
200
364
CUE
Nominated
for
2006
Nominated
Kilograms
(
kg)
553,098
78,944
95,525
129,491
Overall
Reduction
(%)
33%

2006
U.
S.
CUE
Nomination
859,758
Research
Amount
(
kg)
1658
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
859,923
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
was
calculated.
Page
16
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
Replant
problem
is
a
disease
complex
comprised
of
interactions
between
various
pathogens
and
environmental
factors.
Nematodes
(
Primary
pests):
Meloidogyne
(
root
knot);
Criconemella
(
ring);
Xiphinema
(
dagger);
Pratylenchus
(
root
lesion);
and
Tylenchulus
(
citrus)
Pathogens:
Armellaria,
Phytophthora,
and
various
fungi,
depending
on
orchard
location
and
conditions
that
are
thought
to
contribute
to
orchard
replant
disorder.
Insect:
Pollyphylla
decemlineata
(
tenlined
June
beetle)
Some
alternatives,
such
as
1,3­
D,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
are
no
legal
restriction
and
in
light,
sandy
loam
soils,
and
where
there
is
acceptable
soil
moisture.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
the
only
compound
that
can
effectively
target
root
remnants
from
previous
orchard
trees.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
orchards
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
trees
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.
Due
to
the
late
harvest
of
the
stone
fruit
crops
there
is
not
generally
a
fallow
period
between
the
removal
of
the
old
trees
and
replanting
with
new
trees.
Page
17
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
California
Grape
and
Tree
Fruit
League
 
Stone
Fruit
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
stone
fruit
trees
for
production
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
(
20­
25
years)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
varied
(
light,
medium,
heavy)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
life
of
orchard
(
20­
25
years),
until
replant
with
new
orchard
OTHER
RELEVANT
FACTORS:
None
identified
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm)
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
20
years)
PLANTING
SCHEDULE
occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Orchard
replant
into
previously
planted
orchard
land
(
the
typical
situation
in
California)
requires
reducing
pathogen
populations
(
mostly
nematodes
and
fungi)
and
nutrient
sources
of
previous
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
In
other
situations,
this
compound
and
other
alternatives
are
not
able
to
move
sufficiently
through
the
soil
to
remove
the
problem
pests.
Thus,
there
is
a
critical
need
for
MB
not
only
for
the
stone
fruit
consortium,
but
for
other
consortia
of
this
sector.
The
infrequent
use
of
MB
(
once
in
25­
40
years)
and
the
positive
benefits
of
vigorous
early
tree
growth
make
MB
a
key
component
of
orchard
fruit
and
nut
production.
Page
18
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
3,435
2,815
3,522
1,723
1,063
not
available
RATIO
OF
FLAT
FUMIGATION
a
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
1,115,189
946,612
1,184,391
579,254
357,558
not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
not
available
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
shank
injected
shank
injected
shank
injected
shank
injected
not
available
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
336
336
336
336
336
not
available
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
343
343
343
343
343
not
available
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
34.3
34.3
34.3
34.3
34.3
not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
a
Various
methods
are
used
depending
on
the
particular
nursery,
fumigation
can
be
Flat
Fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application
 
approximately
0.5
kg/
tree).
Page
19
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
chloropicrin
has
some
activity
as
fungicide
and
may
be
useful
if
fungi
are
significant
causal
agents
of
replant
disorder
(
Trout
et
al.,
2002);
will
not
reduce
nematodes
significantly
and
they
are
major
cause
of
replant
disorder;
may
have
phytotoxicity
problems
at
rates
that
are
effective
against
pests
(
Browne
et
al.,
2002a)
no
1,3­
dichloropropene
(
1,3­
D)
Most
orchards
fall
in
areas
with
township
cap
restrictions
on
use
of
1,3­
D.
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
orchard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
is
not
effective
to
control
nematodes
associated
with
replant
disorder.
only
with
light
soils,
if
no
legal
restrictions
apply
metam­
sodium
May
be
effective
in
killing
root
tissue
near
soil
surface,
but
will
not
kill
roots
below
75
mm
when
metam­
sodium
is
applied
at
label
rates;
not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
However,
in
the
future,
new
delivery
systems
could
increase
effectiveness
of
this
compound
to
make
it
a
more
acceptable
alternative
to
MB
(
where
soil
conditions
are
amenable
to
its
use).
Reducing
time
in
which
material
can
diffuse
throughout
target
area
will
improve
efficacy
(
McKenry,
1999)
;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
no
dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
This
product
" 
will
not
be
successful
until
more
is
known
about
the
dissolution
rate
of
the
granules"
(
McKenry,
1999).
no
nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
no
Page
20
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
fallow
not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999)
and
may
not
be
sufficient
even
then;
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002)
no
rootstock
Genetic
factors
are
known
that
confer
some
tolerance
for
orchard
replant
problems
 
for
example,
in
one
study
an
orchard
with
Marianna
2624
Plum
rootstock
was
not
as
sensitive
as
an
orchard
with
Nemaguard
peach
rootstock
(
McKenry,
1999).
This
is
in
spite
of
the
resistance
of
Nemaguard
to
reproduction
of
root
knot
nematodes
 
however,
feeding
on
Nemaguard
roots
were
aided
by
reproduction
on
remnant
roots
causing
significant
replant
problem.
Rootstock
for
all
of
the
commodities
in
this
sector
are
subject
to
differential
effects
from
soil
and
other
environmental
factors,
as
well
as
the
array
of
pests
that
comprise
individual
orchards.
Consequently,
rootstock
can
only
be
considered
a
component
of
an
overall
orchard
management
plan,
and
not
a
solution
to
the
replant
problem.
no
biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
Crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry.
no
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
orchard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
is
not
effective
to
control
nematodes
associated
with
replant
disorder.
only
with
light
soils,
if
no
legal
restrictions
apply
Page
21
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

1,3­
D
+
metamsodium
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
orchard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
is
not
effective
to
control
nematodes
associated
with
replant
disorder.
If
soils
are
amenable,
1,3­
D
may
be
applied
followed
by
a
sprinkler
application
of
metamsodium
This
may
be
effective
if
the
irrigation
system
is
economically
feasible
and
if
land
preparation
is
of
sufficient
quality
to
expose
targeted
old
tree
roots
to
the
chemicals.
only
with
light
soils,
if
no
legal
restrictions
apply
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
acceptable
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting,
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.
Page
22
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
package
has
been
submitted
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
package
has
been
submitted
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER
KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
[
1]
MB
(
400
kg/
ha)
[
2]
1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
[
3]
1
year
fallow
(
non­
fumigated)
[
4]
non­
fumigated
Peach,
fumigation
Fall,
1997;
Replant,
Spring,
1998;
4
reps,
research
plots
Trunk
diameter
(
mm
for
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
114a
[
2]
92%
ab
[
3]
86%
bc
[
4]
81%
c
same
Market
Yield
(
kg/
tree
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
38a
[
2]
100%
a
[
3]
93%
a
[
4]
86%
a
Trout
et
al.,
2002
[
1]
MB
(
400
kg/
ha)
[
2]
1,3­
D
(
260
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
63
kg/
ha)
[
3]
1
year
fallow
(
non­
fumigated)
[
4]
non­
fumigated
Peach,
fumigation
Fall,
1998;
Replant,
Spring,
1999;
4
reps,
research
plots
Trunk
diameter
(
mm
for
MB
trt;
and
%
of
MB
value);
Aug.
2002:
[
1]
94.1a
[
2]
102%
a
[
3]
89%
b
[
4]
82%
b
same
Market
Yield
(
kg/
tree
MB
trt;
and
%
of
MB
value);
July,
2002:
[
1]
30ab
[
2]
109%
a
[
3]
87%
bc
[
4]
75%
c
Trout
et
al.,
2002
Page
23
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
No
alternatives
are
feasible
in
the
majority
of
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
below
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
385
kg/
ha)
nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
350
kg/
ha)
+
metam­
sodium
(
125
kg/
ha)
nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
above
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

In
situations
with
light
soil,
and
water
available
to
moisten
the
top
30
cm
of
soil,
1,3­
D
with
chloropicrin
or
metam­
sodium
can
be
effective
treatments
for
orchard
replant
problems.
However,
in
medium
or
heavy
soils,
high
moisture
content
below
1
to
1.5
meters
usually
reduces
the
efficacy
of
1,3­
D
and
precludes
its
use.
MB
is
therefore
critical
since
no
other
treatment
has
been
proven
to
exhibit
such
a
positive
effect
on
achieving
a
healthy
orchard
for
20­
25
years
of
production.
Alternatives
that
are
being
investigated
include
fallowing
studies
(
frequently
with
prior
treatment
with
an
herbicide
to
kill
remnant
roots
from
previous
plantings).
Thus
far,
nematode
control
is
short­
lived
(
only
up
to
6
to
9
months)
(
6).
Rootstock
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).
Page
24
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

Tests
are
being
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
efficiently
kill
roots
and
nematodes
that
feed
on
roots.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
stone
fruit,
as
well
as
walnuts,
grapes,
and
almonds.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT.
SUMMARY
OF
TECHNICAL
FEASIBILITY
No
alternatives
are
feasible
in
the
majority
of
stone
fruit
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Orchard
replant
problems
for
all
orchard
replant
sites
are
a
result
of
biological
and
environmental
causes,
and
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
Nevertheless,
Criconemella
xenoplax
infests
at
least
60%
of
hectares
planted
in
cling
peaches
(
McKenry,
1999).
An
additional
35%
of
fresh
peach,
plum,
and
nectarine
plantings
are
infested
with
P.
vulnus
and
a
somewhat
smaller
area
is
infested
with
C.
xenoplax.
As
such,
it
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available
 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchard
and
vineyard
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduce
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
the
near
future,
for
the
orchard
and
vineyard
sector
in
California,
MB
is
critical
to
the
efficient
management
of
many
of
these
commercial
orchards.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
Page
25
METHYL
BROMIDE
USE
IS
REQUESTED
NEEDED
(
e.
g.
Effective
herbicide
available,
but
not
registered
for
this
crop;
mandatory
requirement
to
meet
certification
for
disease
tolerance)

California
Grape
and
Tree
Fruit
League
 
Raisin
&
Table
Grapes
Replant
problem
is
a
disease
complex
comprised
of
interactions
between
various
pathogens
and
environmental
factors.
Nematodes
(
Primary
pests):
Meloidogyne
(
root
knot);
Criconemella
(
ring);
Xiphinema
(
dagger);
Pratylenchus
(
root
lesion);
and
Tylenchulus
(
citrus)
Pathogens:
Armellaria,
Phytophthora,
and
various
fungi,
depending
on
orchard
location
and
conditions,
that
are
thought
to
contribute
to
orchard
replant
disorder.
Insect:
At
some
sites
Pollyphylla
decemlineata
(
tenlined
June
beetle)
Some
alternatives,
such
as
1,3­
D,
may
be
effective
in
reducing
the
effects
of
orchard
replant
disorder
where
there
are
no
legal
restriction
and
in
light,
sandy
loam
soils,.
In
other
situations,
where
soils
are
medium
to
heavy,
or
where
township
caps
are
applicable,
MB
is
the
only
compound
that
can
reach
targeted
root
remnants
from
previous
orchard
trees.
Page
26
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
As
in
stone
fruit
orchards,
the
typical
practice
of
replanting
vineyards
with
MB
is
to
remove
the
old
plantings
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
plants
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
plants
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
raisins
and
table
grapes
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
(
average
of
22
year
vineyard
life)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
22
years
OTHER
RELEVANT
FACTORS:
The
applicant
did
not
identify
any
other
relevant
factors.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
22
years)
PLANTING
SCHEDULE
occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
Page
27
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Replanting
vineyards
into
non­
virgin
areas
(
the
typical
situation
in
California)
requires
removing
pathogens
(
nematodes
and
fungi)
and
nutrient
sources
of
previous
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
However,
in
vineyard
regions
of
California,
township
caps
may
reduce
use
of
1,3­
D
to
a
fraction
of
planted
vineyard
replant
situations.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
729
316
251
273
67
not
available
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
not
available
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
262,684
124,210
108,035
70,732
18,248
not
available
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
not
available
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
shank
injected
shank
injected
shank
injected
shank
injected
not
available
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
361
393
430
259
271
not
available
Page
28
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
368
401
439
264
277
not
available
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
36,8
40.1
43.9
26.4
27.7
Not
available
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
(
Give
list
of
all
relevant
chemical
and
non
chemical
alternatives,
and
their
combinations)

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
D
Where
soil
moisture
is
acceptable
and
township
caps
are
not
instituted,
1,3­
D
may
provide
sufficient
management
of
replant
disorder
in
vineyards
with
light
soils.
only
with
light
soils,
if
no
legal
restrictions
apply
metam­
sodium
not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils);
nematodes
are
the
primary
pest
in
the
replant
disorder
complex;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
no
chloropicrin
where
fungi
are
primary
pest
(
requires
addition
of
1,3­
D
is
nematodes
are
present)
no
dazomet
This
alternative
has
not
been
examined
by
researchers
for
vineyards,
however,
it
is
likely
that
problems
with
this
chemical
are
similar
to
the
stone
fruit
industry
 
i.
e.,
it
is
likely
similar
to
metam­
sodium
in
that
it
would
not
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
likely
would
not
be
feasible
in
a
typical
vineyard
situation.
no
nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
no
Page
29
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?
sodium
tetrathiocarbonate
This
compound
does
not
penetrate
the
old
roots
of
the
previous
vineyard.
By
this
chemical
not
penetrating
the
old
roots
it
then
can
be
a
source
of
inoculum
for
various
fungal
and
nematodes
pests.
Therefore,
the
use
of
this
product
alone
will
not
provide
adequate
control
of
the
pest
complex
in
vineyards.
This
product
is
being
used
by
some
of
the
growers
but
not
as
a
replacement
of
MB
but
instead
as
a
means
to
maintain
population
levels.
Generally
this
product
is
used
in
combination
with
other
practices
that
will
allow
for
successful
replanting.
no
NON
CHEMICAL
ALTERNATIVES
fallow
not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
6)
and
may
not
be
sufficient
even
then,
especially
if
vineyard
viruses,
such
as
grape
fan
leaf
virus
(
GFLV)
have
occurred;
may
provide
partial
control
in
some
crops
(
2,11),
however,
economically
difficult
for
grower
to
sustain
(
2,11)
no
rootstock
available
with
resistance
to
some
problem
nematode
species,
but
no
multiple
resistance;
no
biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices
(
Schneider
et
al.,
2000).
IPM
approaches
are
being
extensively
investigated
(
Schneider
et
al.,
1999).
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Development
of
durable
resistance
to
nematodes
in
grape
rootstock
is
an
ongoing
and
challenging
area
of
research
(
Ferris
and
Walker,
2002).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry.
no
Page
30
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
vineyard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
is
not
effective
to
control
nematodes
associated
with
replant
disorder.
only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
metamsodium
May
be
effective
where
township
caps
do
not
apply
and
where
soil
moisture
and
texture
are
such
that
1,3­
D
can
penetrate
to
remnant
tree
roots
of
previous
orchard.
Where
legal
restrictions
are
in
place
and/
or
where
soils
are
medium
to
heavy,
1,3­
D
is
not
effective
to
control
nematodes
associated
with
replant
disorder.
If
soils
are
amenable,
1,3­
D
may
be
applied
followed
by
a
sprinkler
application
of
metam­
sodium.
This
may
be
effective
if
the
irrigation
system
is
economically
feasible
and
if
land
preparation
is
of
sufficient
quality
to
expose
targeted
old
tree
roots
to
the
chemicals.
only
with
light
soils,
if
no
legal
restrictions
apply
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

MBTOC­
listed
alternatives
were
addressed
in
Section
13.
No
other
alternatives
were
considered
feasible.

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
Page
31
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED:
(
Use
same
groups
as
in
Question
10
and
provide
a
separate
table
for
each
target
group
for
which
methyl
bromide
is
considered
essential.
Omit
pathogen
and/
or
weed
tables
if
these
are
not
the
reason
why
critical
use
is
requested.)

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER
(
NEMATODES).
KEY
PEST:
REPLANT
DISORDER
(
NEMATODES)

METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
CITATION
[
1]
not
fumigated
[
2]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
3]
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
4]
InLine
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
5]
chloropicrin
(
455
kg/
ha)
[
drip]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
5
reps;
grapes
Meloidogyne
spp.
(#/
100
cc
soil)
(
trial
planted
and
sampled
2001)

[
1]
324a
[
2]
0c
[
3]
290a
[
4]
0c
[
5]
8b
Tylenchulus
semipenetrans
(#/
100
cc
soil)
(
trial
planted
and
sampled
2001)
[
1]
121a
[
2]
0c
[
3]
157a
[
4]
0c
[
5]
2bc
Schneider
et
al.,
2002
Meloidogyne
spp.
per
100
cc
soil
(
trial
planted
1998,
sampled
2001)

Thompson
seedless
rootstock
Teleki
5C
rootstock
Harmony
rootstock
[
1]
not
fumigated
[
2]
1­
year
fallow
[
3]
1­
year
fallow
+
cover
crop
[
4]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
5]
1,3­
D
(
352
kg/
ha)
[
in
60
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
6]
1,3­
D
(
352
kg/
ha)
[
in
100
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
5
reps;
grapes
[
1]
144ab
[
2]
215a
[
3]
145ab
[
4]
1def
[
5]
0.2ef
[
6]
6cde
[
1]
261a
[
2]
49b
[
3]
190a
[
4]
0.3c
[
5]
0.6c
[
6]
0.2c
[
1]
0.8a
[
2]
0.0a
[
3]
0.1a
[
4]
0.0a
[
5]
0.0a
[
6]
0.0a
Schneider
et
al.,
2002
Tylenchulus
semipenetrans
per
100
cc
soil
(
trial
planted
1998,
sampled
2001)
[
1]
not
fumigated
[
2]
1­
year
fallow
[
3]
1­
year
fallow
+
cover
crop
[
4]
MB
(
455
kg/
ha)
[
shanked,
tarp]
[
5]
1,3­
D
(
352
kg/
ha)
[
in
60
mm
water]
+
metam­
sodium
(
125
kg/
ha)
5
reps;
grapes
Thompson
seedless
rootstock
Teleki
5C
rootstock
Harmony
rootstock
Schneider
et
al.,
2002
Page
32
KEY
PEST:
REPLANT
DISORDER
(
NEMATODES)

METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
CITATION
[
microspray]
[
6]
1,3­
D
(
352
kg/
ha)
[
in
100
mm
water]
+
metam­
sodium
(
125
kg/
ha)
[
microspray]
[
1]
638a
[
2]
352a
[
3]
463a
[
4]
0.4c
[
5]
3c
[
6]
6b
[
1]
301a
[
2]
434a
[
3]
342a
[
4]
4b
[
5]
1b
[
6]
3b
[
1]
913a
[
2]
1123a
[
3]
723a
[
4]
2b
[
5]
6b
[
6]
7b
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
No
alternatives
are
feasible
in
the
majority
of
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
below
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
385
kg/
ha)
nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
above
Page
33
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

In
situations
with
light
soil,
and
water
available
to
moisten
the
top
30
cm
of
soil,
1,3­
D
with
chloropicrin
or
metam­
sodium
can
be
effective
treatments
for
replant
problems.
However,
in
medium
or
heavy
soils,
high
moisture
content
below
1
to
1.5
meters
usually
reduces
the
efficacy
of
1,3­
D
and
precludes
its
use.
MB
is
therefore
critical
since
no
other
treatment
has
been
proven
to
exhibit
such
a
positive
effect
on
achieving
a
healthy
vineyard
for
20­
25
years
of
production.
Alternatives
that
are
being
investigated
include
fallowing
studies
(
frequently
with
prior
treatment
with
an
herbicide
to
kill
remnant
roots
from
previous
plantings).
Thus
far,
nematode
control
is
short­
lived
(
only
up
to
6
to
9
months)
(
6).
Rootstock
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).

CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

Tests
are
being
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
efficiently
kill
remnant
roots
and
nematodes
that
feed
on
roots
(
e.
g.,
Martin,
2003;
McKenry,
2001).
McKenry
(
1999)
outlines
several
approaches
through
field
studies
that
can
address
MB
alternatives
for
walnuts,
grapes,
stone
fruit,
and
almonds.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.
Page
34
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
&
TABLE
GRAPES.
SUMMARY
OF
TECHNICAL
FEASIBILITY
No
alternatives
are
feasible
in
the
majority
of
vineyard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
vines
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
As
with
all
orchard
replant
sites,
orchard
replant
problems
for
vineyards
are
a
result
of
biological
and
environmental
causes,
and
probably
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
It
is
clear
that
the
long
life
of
vineyards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available
 
at
time
of
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchard
and
vineyard
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduce
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
the
near
future,
for
the
orchard
and
vineyard
sector
in
California,
MB
is
critical
to
the
efficient
management
of
many
of
these
commercial
operations.

CALIFORNIA
WALNUT
COMMISSION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
WALNUT
COMMISSION.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
WALNUT
COMMISSION.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Walnut
Commission
(
Central
Valley
and
coastal
valleys)
Replant
problem
caused
by
interactions
of
pests
and
environment
primarily
Nematodes:
(
in
~
85%
of
orchards)
Pratylenchus
vulnus,
Mesocriconema
xenoplax,
Meloidogyne
spp.
Township
caps
and
unacceptable
soil
moisture
(>
12%
at
over
1
meter
depths
in
medium
and
heavy
soils)
limit
1,3­
D
use
(
the
best
alternative)
to
approximately
only
30%
of
orchard
land.
Page
35
CALIFORNIA
WALNUT
COMMISSION.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
30­
40
years
 
and
sometimes
longer
 
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
orchards
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
trees
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.

CALIFORNIA
WALNUT
COMMISSION.
TABLE.
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
REGION
B
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
English
walnuts
on
black/
Paradox
rootstocks
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light
(
30%),
medium
(
40%),
heavy
(
30%)

FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
orchard
life
(
up
to
40
years)

OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified
by
the
applicant.

CALIFORNIA
WALNUT
COMMISSION.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
40
years)
PLANTING
SCHEDULE
occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
Page
36
CALIFORNIA
WALNUT
COMMISSION.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

In
approximately
70%
of
walnut
orchard
situations
(
Central
Valley
and
coastal
valleys
in
California)
surface
soil
moisture
and
restrictions
due
to
township
caps,
make
the
best
alternative,
1,3­
D,
unlikely
to
be
able
to
replace
MB
in
the
short
term.

CALIFORNIA
WALNUT
COMMISSION.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
WALNUT
COMMISSION.
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
344
249
348
89
1,393
No
data
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
Fumigation
Flat
fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
153,721
111,518
156,162
39,687
24,308
No
data
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
98/
2
98/
2
98/
2
98/
2
98/
2
98/
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
shank
injected
shank
injected
shank
injected
shank
injected
shank
injected
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
447
448
448
448
220
No
data
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
456
456
456
456
225
230
Page
37
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
45.6
45.6
45.6
45.6
22.5
23
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

CALIFORNIA
WALNUT
COMMISSION.
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
WALNUT
COMMISSION.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA
WALNUT
COMMISSION.
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
D
With
appropriate
soil
type
and
moisture
conditions,
an
effective
nematicide,
usually
more
effective
for
orchard
replant
problems
with
chloropicrin
for
added
fungicidal
activity;
also
is
relatively
effective
in
killing
remnant
roots
from
previous
orchard
planting;
however,
subject
to
strict
township
caps
and
specific
moisture
requirements.
only
with
light
soils,
if
no
legal
restrictions
apply
chloropicrin
May
perform
acceptably
alone
when
fungi
are
primary
cause
of
orchard
replant
problem;
for
nematode
causation,
presence
of
1,3­
D
is
necessary.
no
metam­
sodium
not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils);
however,
can
sometimes
kill
remnant
tree
roots
that
harbor
nematodes,
but
legal
label
rates
(
363
kg/
ha)
generally
can
only
kill
roots
above
the
surface
75
cm
(
McKenry,
1999);
below
this
level,
nematodes
populations
survived.
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
no
dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
no
nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
no
Page
38
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

NON
CHEMICAL
ALTERNATIVES
fallow
not
sufficient
alone;
frequently
done
for
1
year
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999);
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002);
might
be
used
following
herbicide
treatment
but
is
additional
expense
for
reduced
efficacy
compared
to
more
effective
fumigants.
no
resistant
rootstock
no
commercially
acceptable
rootstocks
that
have
resistance
(
McKenry,
1999)
no
biofumigation,
solarization,
steam,
biological
control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry
no
Page
39
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
metamsodium
only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
chloropicrin
+
metam­
sodium
1,3­
D
mixtures
can
be
effective
in
light
soils
in
areas
with
no
legal
restrictions
[
in
walnuts,
probably
only
30%
of
orchard
replant
situations
(
McKenry,
1999)];
or
situations
where
moisture
levels
are
acceptable
(
requires
less
that
12%
at
depths
of
up
to
1.5
meters,
and
sufficient
moisture
at
surface
to
disperse
compounds,
while
reducing
emissions);
restrictions
reduce
orchard
sites
where
1,3­
D
is
feasible
option;
in
heavy
soils
1,3­
D
is
not
a
feasible
alternative
only
with
light
soils,
if
no
legal
restrictions
apply
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

CALIFORNIA
WALNUT
COMMISSION.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

CALIFORNIA
WALNUT
COMMISSION
REGION
C.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
acceptable
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting,
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.
Page
40
CALIFORNIA
WALNUT
COMMISSION.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
WALNUT
COMMISSION.
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
CALIFORNIA
WALNUT
COMMISSION.
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
CALIFORNIA
WALNUT
COMMISSION.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1:
NEMATODES.

KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
see
Table
16.1
for
Regions
A
(
Stone
Fruit),
B
(
Grapes),
&
D
(
Almonds)
Page
41
CALIFORNIA
WALNUT
COMMISSION.
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
No
alternatives
are
feasible
in
the
majority
of
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
below
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
385
kg/
ha)
nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metamsodium
(
125
kg/
ha)
nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
above
CALIFORNIA
WALNUT
COMMISSION.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?:
(
If
so,
please
specify.)

According
to
the
consortium,
in
2001
MB
was
used
on
21,316
hectares
(
only
about
1/
3
of
the
area
is
actually
treated
in
strip
applications).
In
the
same
year,
1,3­
D
was
applied
to
113
hectares
and
metam­
sodium
was
applied
to
28
hectares.
The
limited
(
although
increasing)
use
of
the
best
alternative1,3­
D,
is
primarily
due
to
township
caps
in
the
concentrated
areas
of
walnut
production
in
California,
and
1,3­
D
use
may
be
limited
by
moisture
factors
when
1,3­
D
is
not
an
effective
nematicide
in
heavy
soils
of
an
orchard
and
soils
with
greater
than
12%
moisture.
In
this
situation
MB
is
critical
and
its
use
is
of
considerable
effectiveness
in
light
of
the
longevity
of
walnut
orchards
and
importance
of
early
tree
health
to
long
producing
orchards.
It
requires
8­
10
years
for
trees
to
produce
a
saleable
crop
and
the
failure
to
start
the
orchard
with
healthy
trees
or
in
a
pathogen
infested
site
will
reduce
production
over
its
40
year
life.
Improper
orchard
replant
can
lead
to
additional
replant
within
10
years
with
no
production
in
the
interim.
Page
42
CALIFORNIA
WALNUT
COMMISSION.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

MB
is
the
most
biologically
active
and
cost
effective
treatment
for
the
one
time
replant
application.
Starting
an
orchard
with
"
clean"
plantings,
which
will
accelerate
tree
growth
and
improve
production,
is
a
requirement
that
alternatives
can
not
achieve
under
many
orchard
replant
situations.
Consequently
the
risk
of
using
alternatives
without
the
success
rate
of
MB
presents
a
difficult
situation
for
growers.
1,3­
D
has
been
very
effective
in
locations
where
soil,
moisture,
and
legal
restrictions
are
not
problematic.
Where
1,3­
D
is
not
an
acceptable
treatment,
MB
is
critical
to
the
establishment
of
the
walnut
orchard.
This
includes
a
significant
number
of
walnut
orchards.

It
is
known
(
McKenry,
1999)
that
some
cultural
practices
can
be
instituted
to
reduce
the
effects
of
replant
problems.
It
is
generally
true
that
replant
problems
are
worse
in
sandy
or
alkaline
soils.
It
is
also
known
that
walnuts
grow
better
replanting
after
almond
orchards
(
or
grapes)
rather
than
after
walnuts.
Unfortunately,
many
growers
do
not
have
choices
of
replant
since
land
is
limited
and
choices
must
be
made
for
future
returns
of
a
long
term
crop.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
to
address
MB
alternatives
for
walnuts,
as
well
as
grapes,
stone
fruit,
and
almonds.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.
Page
43
CALIFORNIA
WALNUT
COMMISSION.
SUMMARY
OF
TECHNICAL
FEASIBILITY
No
alternatives
are
feasible
in
the
majority
of
walnut
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
In
1999,
it
was
estimated
(
McKenry,
1999)
that
85%
of
land
used
for
California
walnuts
was
infested
with
one
or
more
of
three
important
nematode
pests
(
Pratylenchus
vulnus,
Criconemella
xenoplax,
or
Meloidogyne
spp.).
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
As
with
the
stone
fruit
orchards,
orchard
replant
problems
for
walnut
orchards
are
a
result
of
biological
and
environmental
causes,
and
probably
interactions
of
these
forces.
Unfortunately,
there
are
no
commercially
available
resistant
rootstocks
that
can
provide
consistent
relief
from
orchard
replant
problem
in
walnuts.
It
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available
 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchard
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduces
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
the
near
future,
for
the
orchard
and
vineyard
sector
in
California,
MB
is
critical
to
the
efficient
management
of
many
of
these
commercial
operations.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
PESTS
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
Almond
Hullers
and
Processors
Association
(
California)
Replant
problem
is
a
disease
complex
comprising
an
interaction
of
pests
(
primarily
nematodes)
and
environmental
factors.
Nematodes:
Meloidogyne
incognita
(
root
knot),
Pratylenchus
vulnus
(
root
lesion),
Mesocriconema
xenoplax
(
ring),
Xiphinema
americanum
(
dagger)
Many
new
almond
orchards
were
planted
between
1979
and
1982.
These
orchards
will
soon
need
to
be
replanted
as
the
life
of
the
orchard
is
reaching
its
maximum
(
25­
30
years).
Because
no
virgin
land
is
available,
replant
problems
will
occur
in
these
locations.
Because
of
township
caps
and
water
moisture
issues,
the
best
alternative,
1,3­
D
is
not
available
or
effective
as
a
replacement.
Therefore,
MB
is
considered
critical
for
this
industry.
Page
44
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
(
Place
major
attention
on
the
key
characteristics
that
affect
the
uptake
of
alternatives):

The
demand
for
almonds
in
the
future
is
increasing,
thus
from
2005,
it
is
estimated
that
there
will
be
numerous
orchards
replanted
to
almonds
that
were
originally
planted
from
1979­
1982,
in
addition
to
other
orchards
that
will
be
replanted
to
almonds.
This
crop,
like
others
in
this
sector
are
infrequent
users
of
MB,
since
fumigation
occurs
only
once
in
the
long
life
of
the
orchard.

The
typical
practice
of
replanting
orchards
with
MB
is
to
remove
the
old
trees
after
the
final
harvest
(
typically
20­
25
years
after
planting).
The
soil
is
harrowed
and
the
remaining
roots
are
removed.
The
soil
is
fumigated
in
the
late
fall
and
the
trees
are
replanted
in
the
early
winter.
When
using
MB
growers
have
traditionally
not
needed
to
leave
a
fallow
period
between
tree
removal
and
the
replanting
of
the
new
trees.

The
typical
practice
of
replanting
orchards
with
1,3­
D
+
chloropicrin
(
the
best
alternative
where
conditions
permit),
is
to
remove
the
old
trees
after
harvest
and
as
many
of
the
roots
as
time
and
resources
permit.
After
the
removal
of
the
old
trees
the
soil
is
ripped
and
then
irrigated
to
allow
the
soil
to
settle.
Any
roots
that
are
pulled
to
the
surface
are
removed,
and
the
soil
is
graded.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
REGION
D
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
almond
trees
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
perennial
(
25­
30
years)

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
none
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
light,
medium,
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
once
in
25
to
30
years
OTHER
RELEVANT
FACTORS:
No
other
relevant
factors
were
identified
by
the
applicant.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
USDA
plant
hardiness
zones
9a,
9b
RAINFALL
(
mm):
30­
60
CM/
YR
16
72.1
17.3
0
trace
1.0
trace
0
44.7
56.9
9.9
30.5
OUTSIDE
TEMP.
(
°
C)
14.4
14.8
20.8
25.7
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
FUMIGATION
SCHEDULE
1st
year,
land
preparation
and
fumigation;
no
additional
fumigation
for
life
of
orchard
(~
25
to
30
years)
PLANTING
SCHEDULE
occurs
2nd
year,
after
fumigation
KEY
MARKET
WINDOW:
Not
applicable
*
For
Fresno,
California
Page
45
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

Orchard
replant
into
previously
planted
orchard
land
(
the
typical
situation
in
California)
requires
reducing
pathogen
populations
(
mostly
nematodes
and
fungi)
and
nutrient
sources
of
previous
orchard
tree
roots
and
root
remnants.
This
requires
an
effective
material
that
is
volatile
and
can
penetrate
into
the
soil
to
reach
these
plant
materials.
In
sandy,
loam
soils,
where
restrictions
do
not
apply,
1,3­
D
may
be
an
acceptable
alternative
that
can
penetrate
to
the
target
areas.
In
other
situations,
this
compound
and
other
alternatives
are
not
able
to
move
sufficiently
through
the
soil
to
remove
the
problem
pests.
Thus,
there
is
a
critical
need
for
MB
for
the
almond
consortium,
as
well
as
for
other
consortia
of
this
sector.
The
infrequent
use
of
MB
(
once
in
25­
40
years,
or
longer)
and
the
positive
benefits
of
vigorous
early
tree
growth
make
MB
a
key
component
of
orchard
fruit
and
nut
production.
Page
46
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
12.1
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE
FOR
AS
MANY
YEARS
AS
POSSIBLE
AS
SHOWN
SPECIFY:
1997
1998
1999
2000
2001
2002
AREA
TREATED
(
hectares)
3,102
1,613
2,046
1,430
496
139
(+
need
for
individual
tree
replacement
 
i.
e.,
"
hole"
amt.

RATIO
OF
FLAT
FUMIGATION
a
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]
usually
Flat
Fumigation
[
if
strip
 
65%
of
area
is
treated]

AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
1,314,601
547,622
703,401
497,810
174,502
41,774
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide/
chloropicrin)
98:
2
98:
2
98:
2
98:
2
98:
2
98:
2
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
shank
injected
shank
injected
shank
injected
shank
injected
shank
injected
Shank
injected
APPLICATION
RATE
[
ACTIVE
INGREDIENT]
(
kg/
ha*)
424
340
344
348
352
300
APPLICATION
RATE
[
FORMULATION]
(
kg/
ha*)
433
347
351
355
359
306
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
28
22
22
23
23
20
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
a
Various
methods
are
used
depending
on
the
particular
nursery,
fumigation
can
be
Flat
Fumigation,
strip,
or
even
"
by
the
hole"
(
for
individual
tree
replacement;
MB
is
the
only
product
that
has
acceptable
technology
for
hole
application
 
approximately
0.5
kg/
tree).
Page
47
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
PART
C:
TECHNICAL
VALIDATION
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
(
Give
list
of
all
relevant
chemical
and
non
chemical
alternatives,
and
their
combinations)

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
13.1:
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
NAME
OF
ALTERNATIVE
TECHNICAL
AND
REGULATORY*
REASONS
FOR
THE
ALTERNATIVE
NOT
BEING
FEASIBLE
OR
AVAILABLE
IS
THE
ALTERNATIVE
CONSIDERED
COST
EFFECTIVE?

CHEMICAL
ALTERNATIVES
1,3­
D
can
be
effective
in
orchards
with
light
soils;
not
feasible
in
medium
or
heavy
soils;
usually
more
effective
for
orchard
replant
problems
with
chloropicrin
for
added
fungicidal
activity;
subject
to
township
caps
and
specific
moisture
requirements.
only
with
light
soils,
if
no
legal
restrictions
apply
chloropicrin
may
perform
acceptably
alone
when
fungi
are
primary
cause
of
orchard
replant
problem;
for
nematode
causation,
MB
or
1,3­
D
is
necessary
no
metam­
sodium
not
an
effective
nematicide
since
it
can
not
reach
deep
areas
of
soil,
which
is
the
primary
cause
of
orchard
replant
problems;
generally
not
effective
in
areas
where
water
percolation
is
a
problem
(
e.
g.,
clay
soils).
no
dazomet
This
alternative
has
been
examined
by
researchers
and
is
inconsistent
in
field
trials.
This
has
been
deemed
not
feasible
due
to
lack
of
performance
in
field
trials
and
inability
to
penetrate
and
kill
nematodes
at
depths
required
for
orchard
replant
acceptability.
This
product
requires
that
there
be
uniform
saturation
of
the
granules
to
ensure
that
the
product
will
perform
consistently.
This
is
not
feasible
in
a
typical
orchard
situation.
no
nematicides
Other
nematicides
(
besides
1,3­
D)
have
limited
use
due
to
their
lack
of
performance
or
due
to
regulatory
issues.
Therefore,
this
product
was
deemed
not
feasible
no
Page
48
NON
CHEMICAL
ALTERNATIVES
fallow
not
sufficient
alone;
sometimes
done
regardless
of
fumigant
that
follows;
may
require
4­
10
year
fallow
for
some
crops
(
McKenry,
1999)
and
may
not
be
sufficient
even
then;
may
provide
partial
control
in
some
crops,
however,
economically
difficult
for
grower
to
sustain
(
Browne
et
al.,
2002b;
Trout
et
al.,
2002)
no
rootstock
similar
situation
to
stone
fruit,
rootstocks
can
help
reduce
some
problem
nematodes
but
are
not
tolerant
to
an
array
of
pests,
and
do
not
address
overall
replant
"
complex"
no
biofumigation,
solarization,
steam,
Biological
Control,
cover
crops
and
mulching,
crop
rotation
/
fallow,
crop
residue
and
compost,
substrate/
plug
plants,
plowing/
tillage,
resistant
cultivars,
grafting/
resistant
rootstock,
physical
removal,
organic
amendments/
compost,
general
IPM
Each
of
the
not
in
kind
alternatives
were
listed
as
options
for
replacement
of
MB.
Many
of
these
alternatives
are
currently
being
employed
with
current
replant
practices.
Alternatives
such
as
biofumigation,
solarization,
and
steam
are
not
feasible
due
to
planting
times,
one
time
fumigation
requirement
per
orchard
(
steam
treatment),
or
inability
to
attain
sufficient
biomass
of
plant
material
(
biofumigation).
Biological
control
may
have
promise
but
research
has
not
identified
agents
that
can
be
used
on
a
commercial
scale
or
that
work
consistently
well.
The
University
of
California
is
investigating
biological
control
of
major
fungal
pathogens,
but
this
work
is
still
in
the
early
stages
of
research.
As
such,
MB
is
currently
considered
critical
to
the
industry
no
Page
49
COMBINATIONS
OF
ALTERNATIVES
1,3­
D
+
chloropicrin
only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
chloropicrin
+
metam­
sodium
only
with
light
soils,
if
no
legal
restrictions
apply
1,3­
D
+
metamsodium
effective
against
nematodes,
fungi,
and
to
kill
remnant
roots
when
1,3­
D
is
used
in
orchards
with
light
soils;
not
feasible
in
medium
or
heavy
soils;
subject
to
township
caps
and
specific
moisture
requirements.
only
with
light
soils,
if
no
legal
restrictions
apply
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
herbicides
(
e.
g.,
triclopyr,
glyphosate)
Not
acceptable
treatment
alone.
Herbicides
are
used
for
killing
remnant
roots
of
previous
orchard
plants;
research
with
walnuts
(
McKenry,
1999)
suggested
that
herbicide
treatment
followed
by
18
months
fallow
can
result
in
root
knot
nematode
control
of
97%
compared
to
untreated
plots.
However,
this
effect
only
lasted
6
months,
not
long
enough
to
achieve
acceptable
establishment
of
new
orchard;
no
herbicides
were
found
that
kill
grape
roots
(
McKenry,
1999).
In
stone
fruit,
while
remnant
roots
were
killed
after
18
months,
endoparasitic
nematodes
were
not
significantly
reduced
(
McKenry
et
al.,
1995).
The
combination
of
herbicide
costs
plus
additional
18
months
waiting
period
prior
to
planting,
becomes
an
economic
burden,
especially
with
the
limited
effectiveness
of
treatment.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
15.1:
PRESENT
REGISTRATION
STATUS
OF
ALTERNATIVES
NAME
OF
ALTERNATIVE
PRESENT
REGISTRATION
STATUS
State
if
registered
for
this
crop,
registered
for
crop
but
use
restricted,
registered
for
other
crops
but
not
target
crop,
or
not
registered
REGISTRATION
BEING
CONSIDERED
BY
NATIONAL
AUTHORITIES?
(
Y/
N)
DATE
OF
POSSIBLE
FUTURE
REGISTRATION:

sodium
azide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
propargyl
bromide
not
registered
in
U.
S.,
no
registration
package
has
been
received
No
unknown
iodomethane
not
registered
in
U.
S.
Yes
unknown
Page
50
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
16.
STATE
RELATIVE
EFFECTIVENESS
OF
RELEVANT
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
FOR
THE
SPECIFIC
KEY
TARGET
PESTS
AND
WEEDS
FOR
WHICH
IT
IS
BEING
REQUESTED
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
REPLANT
DISORDER.
KEY
PEST:
REPLANT
DISORDER
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
(
include
dosage
rates
and
application
method)
#
OF
TRIALS
DISEASE
(%
OR
RATING)
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
fungal
pathogens
[
1]
MB
(
409
kg/
ha)
[
2]
chloropicrin
(
425
kg/
ha)
[
3]
1,3­
D
(
409
kg/
ha)
[
4]
non­
fumigated
Almond
(
Marianna
2624
rootstock),
2001;
4
reps,
research
plots
(
19
m
x
22
m),
no
tarp;
Trunk
diameter
(
mm)
(
increase
after
8
months
postfumigation
[
1]
4b
[
2]
10c
[
3]
2a
[
4]
1a
same
Trees
(%)
w/
growth
>
1.5
m
height
(
in
8
months):
[
1]
21%
a
[
2]
96%
b
[
3]
1%
a
[
4]
2%
a
Browne
et
al.,
2002b
fungal
pathogens
[
1]
MB
(
0.34
kg/
tree)
+
chloropicrin
(
0.11
kg/
tree)
[
2]
chloropicrin
(
0.45
kg/
tree)
[
3]
non­
fumigated
Almond
(
Marianna
2624
rootstock),
2002;
4
reps,
research
plots
(
19
m
x
22
m),
no
tarp;
Trunk
diameter
(
mm)
(
increase
after
8
months
postfumigation
[
1]
15b
[
2]
14b
[
3]
4a
same
Trees
(%)
w/
growth
>
1.5
m
height
(
in
8
months):
[
1]
94%
[
2]
83%
[
3]
6%
Browne
et
al.,
2002b
Page
51
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
No
alternatives
are
feasible
in
the
majority
of
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
Listed
below
are
alternatives
for
sites
where
soils
are
amenable
to
1,3­
D
and
where
township
caps
are
not
applicable.

ALTERNATIVE*
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
D
(
385
kg/
ha)
nematodes,
roots
0­
20%
(
based
on
research
plots)
10%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)
1,3­
D
(
265
kg/
ha)
+
chloropicrin
(
150
kg/
ha)
+
metam­
sodium
(
65
kg/
ha)
nematodes,
fungi,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

1,3­
D
(
350
kg/
ha)
+
metam­
sodium
(
125
kg/
ha)
nematodes,
roots
0­
10%
(
based
on
research
plots)
5%
(
based
on
research
plots)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
See
discussion
above
*
1,3­
D
is
not
a
feasible
alternative
where
soil
moisture
is
not
optimal
or
where
township
caps
restrict
its
use.

ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

1,3­
D
is
the
primary
alternative
to
MB
in
areas
where
it
is
effective
(
light
soils,
moisture
<
12%
at
1.5
meters,
high
moisture
above
30
cm)
and
allowed.
Previously
discussed
alternatives
are
the
primary
ones
continuing
to
be
examined.
Alternatives
that
are
being
investigated
include
fallowing
studies
(
frequently
with
prior
treatment
with
an
herbicide
to
kill
remnant
roots
from
previous
plantings).
Thus
far,
nematode
control
is
short­
lived
(
only
up
to
6
to
9
months)
(
6).
Rootstock
with
resistance
to
the
primary
nematode
pests
are
being
developed,
but
orchard
replant
disorder
is
caused
by
varying
factors
that
are
different
in
different
orchard
locations
and
according
to
the
crop
grown
(
and
crop
grown
prior
to
the
orchard
replant).
Page
52
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

Use
of
herbicides
can
reduce
remnant
roots
of
previous
plantings
and
reduce
the
nutrients
used
by
problem
nematodes,
but
fumigants
are
still
a
necessary
component.
In
addition,
in
orchards
not
subject
to
restrictions,
1,3­
D
can
be
in
some
situations
an
acceptable
alternative.
However,
as
with
the
other
commodities
of
this
sector,
there
are
numerous
uncertainties
in
effects
of
orchard
replant
problems
that
a
sound
practice
is
to
provide
the
initial
trees
the
optimal
environment
to
allow
a
highly
productive
and
long­
lived
orchard
 
this
translates
to
MB
once
in
the
life
of
the
orchard.
Tests
are
being
conducted
to
develop
new
delivery
systems
to
target
pests
with
alternatives
such
as
metam­
sodium
and
1,3­
D
to
depths
where
these
compounds
can
more
efficiently
kill
roots
and
nematodes
that
feed
on
roots.
McKenry
(
1999)
outlines
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
almonds,
as
well
as
walnuts,
grapes,
and
stone
fruit.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.
Page
53
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION.
SUMMARY
OF
TECHNICAL
FEASIBILITY
No
alternatives
are
feasible
in
the
majority
of
almond
orchard
replant
sites
(
i.
e.,
those
with
medium
to
heavy
soils)
and/
or
where
township
cap
restrictions
apply.
In
these
cases
losses
of
trees
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
As
with
the
other
commodities
of
the
orchard
replant
sector,
replant
problems
for
almonds
are
a
result
of
biological
and
environmental
causes,
and
interactions
of
these
forces.
Studies
of
individual
pest
populations
tell
only
a
small
portion
of
the
story
of
replant
complex,
since
individual
pests
cause
only
a
portion
of
the
adverse
growth
effects.
Nevertheless,
approximately
35%
of
hectares
planted
in
almonds
have
infestations
of
Criconemella
xenoplax
and/
or
Pratylenchus
vulnus
(
McKenry,
1999).
Nemaguard,
the
most
commonly
used
almond
rootstock,
has
resistance
only
to
Meloidogyne
spp.
As
such,
it
is
clear
that
the
long
life
of
orchards
requires
that
optimal
pest
management
strategies
be
employed
to
overcome
replant
disorder
during
the
one
opportunity
available
 
at
orchard
establishment.
The
long
history
of
1,3­
D
use
in
California
suggests
that
at
optimal
conditions
it
(
or
in
combination
with
another
chemical)
is
the
best
alternative
to
MB.
However,
the
reality
of
California
orchards
and
vineyards
locations
precludes
the
majority
of
growers
taking
advantage
of
the
material
since
either
township
caps
or
soil
texture/
moisture
issues
reduces
efficacy
or
legal
availability
to
1,3­
D.
Therefore,
for
the
near
future,
for
the
orchard
and
vineyard
sector
in
California,
MB
is
critical
to
the
efficient
management
of
many
of
these
commercial
operations.
Page
54
PART
D:
EMISSION
CONTROL
Research
is
being
conducted
among
all
the
orchard
replant
commodities
to
address
the
orchard
replant
disorder
complex.
Fumigation
is
only
one
means
of
achieving
optimal
orchard
establishment.
Other
practices
can
reduce
long­
term
effects
of
pathogens
and
biotic
and
abiotic
causes
of
this
disorder.
Such
practices
as
fallowing
land,
strategic
fertilization,
water
management,
development
of
genetically
robust
rootstocks,
deep
injection
of
chemicals
 
all
will
reduce
the
emissions
of
MB
(
or
other
of
the
toxic
chemicals
that
might
be
alternatives).
Current
research
also
includes
studies
with
soil
amendments,
such
as
thiosulfate
fertilizers
that
may
act
as
barriers
or
absorbents
of
MB
and
reduce
emissions.

19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE:
(
State
%
adoption
or
describe
change)

TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
TECHNIQUE
OR
STEP
TAKEN
VIF
OR
HIGH
BARRIER
FILMS
METHYL
BROMIDE
DOSAGE
REDUCTION
INCREASED
%
CHLOROPICRIN
IN
METHYL
BROMIDE
FORMULATION
LESS
FREQUENT
APPLICATION
WHAT
USE/
EMISSION
REDUCTION
METHODS
ARE
PRESENTLY
ADOPTED?
VIF
and
high
density
tarps
being
tested
(
almond)
testing
reduction
from
98:
2
to
75:
25
(
almond)
when
fungal
pathogens
are
main
concern
chloropicrin
percent
is
increased
fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
testing
deep
injection;
use
of
additional
herbicides
to
kill
remnant
roots
to
increase
efficacy
of
MB
and
other
fumigants;
reduction
of
MB
in
formulation
deep
injection,
increased
chloropicrin
in
formulation
to
50:
50
being
examined
fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
OTHER
MEASURES
(
please
describe)
unidentified
combination
of
chemicals
and
cultural
practices
such
as
fallow
+
alternatives
or
reduced
MB
combination
of
chemicals
and
cultural
practices
such
as
fallow
+
alternatives
or
reduced
MB
fumigation
is
applied
only
once
in
20­
40
years
for
this
sector
Page
55
Various
techniques
are
being
studied
to
improve
the
efficacy
of
alternatives.
Primary
is
the
development
of
application
techniques
to
improve
delivery
of
the
best
alternatives
such
as
1,3­
D
and
metam­
sodium
(
e.
g.,
McKenry,
2001).
In
situations
with
no
township
caps,
and
where
soil
moisture
is
less
than
12%
at
1.5
meters,
1,3­
D
may
be
effective
 
this
would
occur
generally
in
orchards
with
light,
sandy
soils.
There
is
interest
in
the
industry
to
increase
1,3­
D
application
rates
to
improve
efficacy
in
soils
with
up
to
20%
moisture,
but
label
restrictions
are
based
on
health
and
environmental
concerns
and
increased
label
rates
are
unlikely.
Because
township
caps
may
apply
to
replant
sites,
and
soil
moisture
reduces
efficacy
of
alternatives
in
numerous
orchard
locations,
MB
use
is
unlikely
to
become
less
critical
in
the
near
future.
However,
because
of
the
unique
cropping
system
of
these
orchards
(
i.
e.,
orchard
replants,
and
therefore
fumigation,
is
necessary
only
once
in
the
life
of
the
orchard
 
20­
40
years,
or
even
longer)
the
use
of
MB
by
this
sector
is
cost
effective
and
of
high
value,
while
of
relatively
low
impact.

20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED,
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS:

Research
is
currently
being
conducted
by
all
commodities
of
this
sector
to
find
increasingly
more
effective
ways
of
managing
orchard
replant
disorder
(
e.
g.,
Browne
et
al.,
2002b;
Ferris
and
Walker,
2002;
Martin,
2003;
McKenry,
1999,
2001;
Schneider
et
al.,
1999,
2000;
Trout
et
al.,
2001).
From
1992
to
2002,
the
expenditures
on
research
have
included
$
430,000
(
California
Walnut
Commission),
$
250,000
(
California
Grape
and
Tree
Fruit
League),
and
$
86,000
(
Almond
Hullers
and
Processors
Association).
Research
by
all
of
these
crop
associations
is
continuing.
This
industry
is
committed
to
reduction
in
MB
use.
Currently
there
is
use
of
MB
only
once
in
20
to
40
years,
but
ongoing
tests
to
determine
the
best
approach
to
producing
high
quality
fruit
and
nuts
as
well
as
reducing
MB
emissions
can
help
integrate
new
techniques.
These
include
herbicide
strategies
to
kill
remnant
roots
more
efficiently,
fallowing
regimes
that
will
not
result
in
a
significant
delay
in
replant,
and
deep
injection
to
improve
efficacy.

PART
E:
ECONOMIC
ASSESSMENT
21.
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD:

TABLE
21.1:
COSTS
OF
ALTERNATIVES
COMPARED
TO
METHYL
BROMIDE
OVER
3­
YEAR
PERIOD
This
table
is
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

22.
GROSS
AND
NET
REVENUE:

TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
Page
56
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.

MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
STONE
FRUIT
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
GRAPE
AND
TREE
FRUIT
LEAGUE
 
RAISIN
AND
TABLE
GRAPES
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
WALNUT
COMMISSION
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
ALMOND
HULLERS
&
PROCESSORS
ASSOCIATION
­
TABLE
E.
4:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
These
tables
are
not
included
since
none
of
the
alternatives
are
technically
feasible.
See
Summary
of
Economic
Feasibility
below.
Page
57
SUMMARY
OF
ECONOMIC
FEASIBILITY
An
economic
analysis
was
not
done
for
this
sector
because
most
of
the
losses
cannot
be
quantified.
The
critical
use
nomination
(
CUN)
for
this
sector
does
not
include
areas
where
soil
conditions
are
ideal
and
township
caps
do
not
restrict
the
use
of
1,3
dichloropropene
(
1,3
D).
This
CUN
only
applies
to
areas
where
township
caps
or
certain
soil
types
do
not
permit
the
use
or
effective
use
of
1,3
D.
In
such
areas
there
are
no
technically
or
economically
feasible
alternatives
and
tree
losses
are
likely
to
be
greater
than
20%
(
McKenry,
1999).
1,3
D
in
combinations
with
chloropicrin
or
metam
sodium
is
economically
feasible
in
ideal
soil
conditions
when
not
restricted
California
township
caps
on
1,3
D.
Where
soil
conditions
permit
the
effective
use
of
1,3
D
an
estimated
5%
tree
loss
is
expected
from
the
use
of
1,3
D
in
various
combinations
with
chloropicrin
and
metam
sodium.
A
5%
tree
loss
results
in
a
moderate
loss,
which
is
economically
feasible
providing
there
are
no
other
losses.

Where
1,3
D
is
not
permitted
there
are
no
effective
nematicides.
Trees
that
survive
are
likely
not
to
be
as
healthy
and
are
likely
to
suffer
yield
losses.
Many
trees
are
not
likely
to
survive.
Also,
it
is
unlikely
that
replacement
trees
would
be
able
to
survive.
If
a
nematode
infestation
causes
the
death
of
trees,
then
replacement
trees
would
also
suffer
the
same
infestation
without
an
effective
nematicide
or
possibly
many
years
of
fallow.

An
economic
analysis
was
not
done
because
most
of
the
losses
cannot
be
quantified
because
there
are
no
data
to
substantiate
the
magnitude
of
these
losses.
These
losses
include:
 
Delayed
planting
 
Fallow
 
Additional
use
of
herbicides
 
Tree
loss
 
Replant
costs
to
replace
tree
losses
 
Loss
of
trees
replanted
 
Yield
loss
of
fruit
or
nuts
A
number
of
soil
pathogens
and
nematodes,
many
still
poorly
understood,
amass
over
the
lifespan
of
an
orchard.
It
is
important
that
the
grower
be
able
to
reduce
the
amount
of
inoculum
in
the
soil
to
ensure
that
the
young
trees
have
the
opportunity
to
get
off
to
a
vigorous
start
to
ensure
survival.
1,3
D
alone
or
in
conjunction
with
chloropicrin
or
metam­
sodium
have
shown
promise
on
some
soil
types,
but
long­
term
research
on
tree
survival
and
on
yield
impacts
is
incomplete.
If
the
alternatives
do
not
work
as
effectively
as
methyl
bromide,
then
it
is
possible
that
other
losses
could
occur,
such
as
additional
replanting,
higher
yield
losses,
and
shorter
lifespan
of
the
whole
orchard
reducing
the
ability
to
amortize
the
initial
investment
costs.
Page
58
PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

Primarily,
development
of
technologies
to
improve
efficacy
of
alternatives
such
as
deep
injection
methods,
soil
moisture
management
by
improving
drip
technologies,
use
of
fallow,
experience
with
chemical/
non­
chemical
combinations.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements.
Considering
that
this
sector
uses
MB
(
or
other
fumigants)
only
once
in
the
life
of
the
orchard,
deployment
of
alternatives
to
replace
MB
will
have
to
be
well
considered
in
light
of
the
long­
term
impact
on
fruit
and
nut
production.
As
previously
described,
McKenry
(
1999)
has
outlined
several
approaches
through
field
research
studies
that
can
help
address
MB
alternatives
for
almonds,
as
well
as
walnuts,
grapes,
and
stone
fruit.
These
include
use
(
combinations)
of
herbicides
to
kill
remnant
roots,
use
of
fallow,
use
of
"
virgin"
soil
as
an
amendment
to
possibly
reduce
replant
problem,
resistant
rootstocks
when
available,
irrigation
regimes
to
improve
consistency
of
metam­
sodium,
etc.
Field
studies
on
these
perennial
crops
require
considerable
time
to
conduct
and
until
replicated
trials
can
be
analyzed
MB
is
required.

The
amount
of
methyl
bromide
requested
for
research
purposes
is
considered
critical
for
the
development
of
effective
alternatives.
Without
methyl
bromide
for
use
as
a
standard
treatment,
the
research
studies
can
never
address
the
comparative
performance
of
alternatives.
This
would
be
a
serious
impediment
to
the
development
of
alternative
strategies.
The
U.
S.
government
estimates
that
orchard
replant
research
will
require
1658
kg
per
year
of
methyl
bromide
for
2005
and
2006.
This
amount
of
methyl
bromide
is
necessary
to
conduct
research
on
alternatives
and
is
in
addition
to
the
amounts
requested
in
the
submitted
CUE
applications.
Two
examples
are
five
year
field
studies
on
orchard
and
vineyard
comparing
methyl
bromide
to
1,3­
D,
chloropicrin,
iodomethane,
fallow,
cover
crops,
solarization,
and
other
treatments
for
control
of
nematodes
and
unknown
soilborne
pests.
Page
59
24.
ARE
THERE
PLANS
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

As
stated
in
Section
23,
minimizing
use
of
MB
can
be
achieved
through
the
development
of
technologies
to
improve
efficacy
of
alternatives,
such
as
deep
injection
methods
or
soil
moisture
management,
and
still
have
reasonable
cost
effectiveness.
Even
where
MB
is
considered
critical,
an
improvement
in
efficient
delivery
techniques
will
result
in
reduction
of
MB
use
requirements,
even
though
use
of
MB
is
only
once
in
the
long
life
of
these
orchards.
Research
that
is
currently
being
conducted
by
all
of
the
crop
groups
of
this
sector
should
help
identify
strategies
to
most
effectively
manage
replant
disorder.
The
U.
S.
wants
to
note
that
our
usage
rate
is
among
the
lowest
in
the
world
in
requested
sectors
and
represents
efforts
of
both
the
government
and
the
user
community
over
many
years
to
reduce
use
rates
and
emissions.
We
will
continue
to
work
with
the
user
community
in
each
sector
to
identify
further
opportunities
to
reduce
methyl
bromide
use
and
emissions.

25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

This
methyl
bromide
critical
use
exemption
nomination
for
orchard
replant
has
been
reviewed
by
the
United
States
government
and
meets
the
guidelines
of
The
Montreal
Protocol
on
Substances
That
Deplete
the
Ozone
Layer.
This
use
is
considered
critical
because
there
are
no
feasible
alternatives
or
substitutes
available
for
nurseries.
MB
is
critical
in
the
numerous
orchards
where
1,3­
D
will
not
be
an
effective
treatment
to
orchard
replant
disorder,
especially
where
orchards
have
medium
to
heavy
soils,
and/
or
township
cap
restrictions
for
1,3­
D.
Under
these
circumstances
MB
is
critical
for
orchards
where
1,3­
D
is
not
effective
or
legal,
and
the
absence
of
MB
will
result
in
a
significant
burden
for
the
important
fruit
and
nut
industries
of
California.

26.
CITATIONS
Browne,
G.
T.,
Connell,
J.
H.,
Bulluck,
L.
R.,
Trout,
T.
J.,
and
Schneider,
S.
M.
2002a.
Management
and
etiology
of
replant
disorder
on
almond
and
peach.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

Browne,
G.,
Trout,
T.
and
Bulluck,
R.
2002b.
Cultural
control
and
etiology
of
replant
disease
of
Prunus
spp.
University
of
California,
Sustainable
Agriculture
Research
and
Education
Program.
http://
www.
sarep.
ucdavis.
edu/
grants/
reports/
mebr/
browne/
browne.
html
Ferris,
H.
and
Walker,
M.
A.
2002.
Development
of
grape
rootstocks
with
broad
and
durable
nematode
resistance.
University
of
California
Sustainable
Agriculture
Research
and
Education
Program.
Final
Report
(
updated
May,
2003).
http://
www.
sarep.
ucdavis.
edu/
Grants/
Reports/
MeBr/
Ferris/
ferris.
html
Page
60
Gan,
J.,
Becker,
J.
O.,
Ernst,
F.
F.,
Hutchinson,
C.,
Knuteson,
J.
A.,
and
Yates,
S.
R.
2000.
Surface
application
of
ammonium
thiosulfate
to
reduce
1,3­
dichloropropene
volatilization
from
soil.
Pest
Management
Science
56:
264­
270.

Martin,
F.
N.
2003.
Development
of
alternative
strategies
for
management
of
soilborne
pathogens
currently
controlled
with
methyl
bromide.
Annual
Review
of
Phytopathology
41:
325­
350.

McKenry,
M.
2001.
Performance
of
metam
sodium
drenched
to
six
different
replant
sites.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2001).
http://
mbao.
org/

McKenry,
M.
V.
1999.
The
replant
problem
and
its
management.
Contractor
for
California
Association
of
Nurseryman.
Prepared
for
California
Department
of
Pesticide
Regulation.
Catalina
Publishing,
Fresno,
California,
USA.
(
See
CUE
03­
0013,
CUE
03­
0014
request
packages
of
California
Grape
and
Tree
Fruit
League,
and
CUE
03­
0029
request
of
California
Walnut
Commission.)

McKenry,
M.,
Buzo,
T.,
Kaku,
and
S.
1995.
First­
year
evaluation
of
tree
and
vine
growth
and
nematode
development
following
17
pre­
plant
treatments.
In:
University
of
California
Plant
Protection
Quarterly.
Vol.
5,
No.
4.
http://
www.
uckac.
edu/
ppq/
PDF/
95oct.
pdf
Schneider,
S.,
Trout.
T.,
Browne,
G.,
Ajwa,
H.,
and
Sims,
J.
2002.
Vineyard
replant
disorder
 
results
after
1,2,
and
4
growing
seasons.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/

Schneider,
S.,
Ajwa,
H.,
Trout.
T.,
and
Sims,
J.
2000.
Alternatives
for
vineyard
replant
and
grapevine
nurseries.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2000).
http://
mbao.
org/

Schneider,
Ajwa,
H.
Trout,
T.
and
Sims,
J.
1999.
Grape
replant
disorder
 
an
integrated
management
approach.
USDA,
Agricultural
Research
Service,
Methyl
Bromide
Alternatives.
http://
www.
ars.
usda.
gov/
is/
np/
mba/
oct99/
grape.
htm
Trout.
T.,
Ajwa,
H.,
Schneider,
S.,
Gartung,
J.
2002.
Fumigation
and
fallowing
effects
on
replant
problems
in
California
peach.
Annual
International
Research
Conference
on
Methyl
Bromide
Alternatives
(
2002).
http://
mbao.
org/
Page
61
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
2001
&
2002
Average
%
of
2001
&

2002
Average
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
not
available
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
553,098
1,645
336
23%

78,944
221
357
52%

95,525
477
200
58%

129,491
355
364
27%

859,758
2,698
319
33%

33%
30%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
336
336
0
0
0
0
60
35
8
2
0
0
50
35
382
357
0
0
0
0
35
35
8
2
0
0
50
35
280
200
0
0
0
0
85
85
8
2
0
0
50
35
364
364
0
0
0
0
50
35
8
2
0
0
50
35
Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

Requirement
Change
from
Prior
CUE
Request
(+/­)
Verified
Historic
MB
Use
/

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MB
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
Y+
N
Yes
Yes
Deep
No
0
Yes
1
/
20
No
Yes
Yes
Deep
No
0
Yes
1
/
20
No
Yes
Yes
Deep
No
0
Yes
1
/
40
Y+
N
Yes
Yes
Deep
No
+
3
Yes
1
/
20
Alternatives
1,3­
D
may
not
be
suitable
due
to
soil
type,
pests
or
township
caps
Notes
1
2
3
Conversion
Units:
1
Pound
=
Kilograms
Hectare
58%

Average
Hectares
in
the
US:

%
of
Average
Hectares
Requested:
not
available
not
available
92%
58%

Combined
Impacts
(%)

HIGH
82%
70%
100%

77%
LOW
58%

not
available
not
available
not
available
not
available
%
of
Requested
Hectares
Regional
Hectares**
not
available
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
REGION
CA
Grape
&
Tree
Fruit
League
­
Grapes
CA
Walnut
Commission
Almond
Hullers
&
Processors
Association
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
CA
Grape
&
Tree
Fruit
League
­
Grapes
CA
Walnut
Commission
CA
Walnut
Commission
Almond
Hullers
&
Processors
Association
REGION
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
%
Reduction
from
Initial
Request
Adjustments
to
Requested
Amounts
Nomination
Amount
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruits
CA
Grape
&
Tree
Fruit
League
­
Grapes
0.453592
1
Acre
=

Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
(%)
Key
Pest
Distribution
Use
Rate
(
kg/
ha)
(%)
Karst
Topography
0.404686
CA
Grape
&
Tree
Fruit
League
­
Stone
Fruit
reported
historical
use
rates
that
were
grossly
underestimated
for
normal
fumigation
use.
A
use
rate
of
300
pounds
ai/
acre
was
multiplied
by
the
reported
acreage
to
reflect
a
more
accurate
estimate
of
methyl
bro
This
applicant
only
replanted
every
20
years,
so
change
from
2002
is
not
necessarily
relevant
since
replant
in
2002
reflects
status
of
market
in
~
1982,
which
was
less
than
planting
in
1970s
that
are
now
being
replanted.

Almond
Hullers
&
Processors
Association
*
Due
to
the
nature
of
these
applications,
the
historical
reported
data
varies
greatly
from
year
to
year.
Therefore
an
average
of
the
usage
from
1997
through
2001
were
used.

CA
Grape
&
Tree
Fruit
League
­
Stone
Fruit
requested
8100
acres
but
only
65%
of
those
acres
are
fumigated
due
to
strip
bed
treatment,
therefore
the
acreage
was
adjusted
downward.
1,3­
D+
MS/
1,3­
D+
MS+
Pic/
1,3­
D+
Pic
5%
Yield
Loss
5%
Yield
Loss
1,3­
D+
MS/
1,3­
D+
MS+
Pic/
1,3­
D+
Pic
Quality/
Time/
Market
Window/

Yield
Loss
(%)

5%
Yield
Loss
5%
Yield
Loss
Marginal
Strategy
1,3­
D+
MS/
1,3­
D+
MS+
Pic/
1,3­
D+
Pic
1,3­
D+
MS/
1,3­
D+
MS+
Pic/
1,3­
D+
Pic
Unsuitable
Terrain
(%)
Unsuitable
Soil
(%)

Economic
Analysis
CA
Grape
&
Tree
Fruit
League
­
Grapes
CA
Walnut
Commission
Almond
Hullers
&
Processors
Association
(%)
100
ft
Buffer
Zones
14%

0%
0%
10%
14%
Regulatory
Issues
(%)
1,107,210
902,527
30%
675,188
47%

1,285,707
1,285,707
1,154,214
1,107,210
­
97,078
89,312
176,901
­
­
­
­
136,214
102,603
226,796
­
90,991
38,727
­
587,488
415,540
165,561
­
40,502
8,277
­
81,747
67,733
716,449
­
­
­

2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
HIGH
LOW
MOST
LIKELY
IMPACT
VALUE
2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

1,706,048
5,061
317
0%

TOTAL
OR
AVERAGE
1,285,707
3,859
341
485
200
0%

176,901
486
364
647,587
1,737
373
0%

226,796
809
280
97,078
2,512
336
0%

165,561
433
382
116,782
327
357
0%

716,449
2,131
336
844,600
2006
Amount
of
Request
1997~
2001
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

Sector:
ORCHARD
REPLANT
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
Date:
2/
26/
2004
Methyl
Bromide
Critical
Use
Exemption
Process
Page
62
Footnotes
for
Appendix
A:
Values
may
not
sum
exactly
due
to
rounding.
1.
Average
Hectares
in
the
US
 
Average
Hectares
in
the
US
is
the
average
of
2001
and
2002
total
hectares
in
the
US
in
this
crop
when
available.
These
figures
were
obtained
from
the
USDA
National
Agricultural
Statistics
Service.
2.
%
of
Average
Hectares
Requested
­
Percent
(%)
of
Average
Hectares
Requested
is
the
total
area
in
the
sector's
request
divided
by
the
Average
Hectares
in
the
US.
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.
3.
2006
Amount
of
Request
 
The
2006
amount
of
request
is
the
actual
amount
requested
by
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
U.
S.
units
of
measure
were
used
to
describe
the
initial
request
and
then
were
converted
to
metric
units
to
calculate
the
amount
of
the
US
nomination.
4.
2001
&
2002
Average
Use
 
The
2001
&
2002
Average
Use
is
the
average
of
the
2001
and
2002
historical
usage
figures
provided
by
the
applicants
given
in
total
pounds
active
ingredient
of
methyl
bromide,
total
acres
of
methyl
bromide
use,
and
application
rate
in
pounds
active
ingredient
of
methyl
bromide
per
acre.
Adjustments
are
made
when
necessary
due
in
part
to
unavailable
2002
estimates
in
which
case
only
the
2001
average
use
figure
is
used.
5.
Quarantine
and
Pre­
Shipment
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
percentage
(%)
of
the
applicant's
request
subject
to
QPS
treatments.
6.
Regional
Hectares,
2001
&
2002
Average
Hectares
 
Regional
Hectares,
2001
&
2002
Average
Hectares
is
the
2001
and
2002
average
estimate
of
hectares
within
the
defined
region.
These
figures
are
taken
from
various
sources
to
ensure
an
accurate
estimate.
The
sources
are
from
the
USDA
National
Agricultural
Statistics
Service
and
from
other
governmental
sources
such
as
the
Georgia
Acreage
estimates.
7.
Regional
Hectares,
Requested
Acreage
%
­
Regional
Hectares,
Requested
Acreage
%
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.
8.
2006
Nomination
Options
 
2006
Nomination
Options
are
the
options
of
the
inclusion
of
various
factors
used
to
adjust
the
initial
applicant
request
into
the
nomination
figure.
9.
Subtractions
from
Requested
Amounts
 
Subtractions
from
Requested
Amounts
are
the
elements
that
were
subtracted
from
the
initial
request
amount.
10.
Subtractions
from
Requested
Amounts,
2006
Request
 
Subtractions
from
Requested
Amounts,
2006
Request
is
the
starting
point
for
all
calculations.
This
is
the
amount
of
the
applicant
request
in
kilograms.
11.
Subtractions
from
Requested
Amounts,
Double
Counting
­
Subtractions
from
Requested
Amounts,
Double
Counting
is
the
estimate
measured
in
kilograms
in
situations
where
an
applicant
has
made
a
request
for
a
CUE
with
an
individual
application
while
their
consortium
has
also
made
a
request
for
a
CUE
on
their
behalf
in
the
consortium
application.
In
these
cases
the
double
counting
is
removed
from
the
consortium
application
and
the
individual
application
takes
precedence.
12.
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
­
Subtractions
from
Requested
Amounts,
Growth
or
2002
CUE
Comparison
is
the
greatest
reduction
of
the
estimate
measured
in
kilograms
of
either
the
difference
in
the
amount
of
methyl
bromide
requested
by
the
applicant
that
is
greater
than
that
historically
used
or
treated
at
a
higher
use
rate
or
the
difference
in
the
2006
request
from
an
applicant's
2002
CUE
application
compared
with
the
2006
request
from
the
applicant's
2003
CUE
application.
13.
Subtractions
from
Requested
Amounts,
QPS
­
Subtractions
from
Requested
Amounts,
QPS
is
the
estimate
measured
in
kilograms
of
the
request
subject
to
QPS
treatments.
This
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison
then
Page
63
multiplied
by
the
percentage
subject
to
QPS
treatments.
Subtraction
from
Requested
Amounts,
QPS
=
(
2006
Request
 
Double
Counting
 
Growth)*(
QPS
%)
14.
Subtraction
from
Requested
Amounts,
Use
Rate
Difference
 
Subtractions
from
requested
amounts,
use
rate
difference
is
the
estimate
measured
in
kilograms
of
the
lower
of
the
historic
use
rate
or
the
requested
use
rate.
The
subtraction
estimate
is
calculated
as
the
2006
Request
minus
Double
Counting,
minus
Growth
or
2002
CUE
Comparison,
minus
the
QPS
amount,
if
applicable,
minus
the
difference
between
the
requested
use
rate
and
the
lowest
use
rate
applied
to
the
remaining
hectares.
15.
Adjustments
to
Requested
Amounts
 
Adjustments
to
requested
amounts
were
factors
that
reduced
to
total
amount
of
methyl
bromide
requested
by
factoring
in
the
specific
situations
were
the
applicant
could
use
alternatives
to
methyl
bromide.
These
are
calculated
as
proportions
of
the
total
request.
We
have
tried
to
make
the
adjustment
to
the
requested
amounts
in
the
most
appropriate
category
when
the
adjustment
could
fall
into
more
than
one
category.
16.
(%)
Karst
topography
 
Percent
karst
topography
is
the
proportion
of
the
land
area
in
a
nomination
that
is
characterized
by
karst
formations.
In
these
areas,
the
groundwater
can
easily
become
contaminated
by
pesticides
or
their
residues.
Regulations
are
often
in
place
to
control
the
use
of
pesticide
of
concern.
Dade
County,
Florida,
has
a
ban
on
the
use
of
1,3D
due
to
its
karst
topography.
17.
(%)
100
ft
Buffer
Zones
 
Percentage
of
the
acreage
of
a
field
where
certain
alternatives
to
methyl
bromide
cannot
be
used
due
the
requirement
that
a
100
foot
buffer
be
maintained
between
the
application
site
and
any
inhabited
structure.
18.
(%)
Key
Pest
Impacts
­
Percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
For
example,
the
key
pest
in
Michigan
peppers,
Phytophthora
spp.
infests
approximately
30%
of
the
vegetable
growing
area.
In
southern
states
the
key
pest
in
peppers
is
nutsedge.
19.
Regulatory
Issues
(%)
­
Regulatory
issues
(%)
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
their
use.
20.
Unsuitable
Terrain
(%)
 
Unsuitable
terrain
(%)
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)
or
terrain
configuration,
such
as
hilly
terrain.
Where
the
use
of
alternatives
poses
application
and
coverage
problems.
21.
Cold
Soil
Temperatures
 
Cold
soil
temperatures
is
the
proportion
of
the
requested
acreage
where
soil
temperatures
remain
too
low
to
enable
the
use
of
methyl
bromide
alternatives
and
still
have
sufficient
time
to
produce
the
normal
(
one
or
two)
number
of
crops
per
season
or
to
allow
harvest
sufficiently
early
to
obtain
the
high
prices
prevailing
in
the
local
market
at
the
beginning
of
the
season.
22.
Combined
Impacts
(%)
­
Total
combined
impacts
are
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
soil
impacts,
temperature,
etc.
In
each
case
the
total
area
impacted
is
the
conjoined
area
that
is
impacted
by
any
individual
impact.
The
effects
were
assumed
to
be
independently
distributed
unless
contrary
evidence
was
available
(
e.
g.,
affects
are
known
to
be
mutually
exclusive).
For
example,
if
50%
of
the
requested
area
had
moderate
to
severe
key
pest
pressure
and
50%
of
the
requested
area
had
karst
topography,
then
75%
of
the
area
was
assumed
to
require
methyl
bromide
rather
than
the
alternative.
This
was
calculated
as
follows:
50%
affected
by
key
pests
and
an
additional
25%
(
50%
of
50%)
affected
by
karst
topography.
23.
Qualifying
Area
­
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
by
the
combined
impacts.
24.
Use
Rate
­
Use
rate
is
the
lower
of
requested
use
rate
for
2006
or
the
historic
average
use
rate.
25.
CUE
Nominated
amount
­
CUE
nominated
amount
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
26.
Percent
Reduction
­
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
27.
Sum
of
CUE
Nominations
in
Sector
­
Self­
explanatory.
28.
Total
US
Sector
Nomination
­
Total
U.
S.
sector
nomination
is
the
most
likely
estimate
of
the
amount
needed
in
that
sector.
29.
Dichotomous
Variables
 
dichotomous
variables
are
those
which
take
one
of
two
values,
for
example,
0
or
1,
yes
or
no.
These
variables
were
used
to
categorize
the
uses
during
the
preparation
of
the
nomination.
30.
Strip
Bed
Treatment
 
Strip
bed
treatment
is
`
yes'
if
the
applicant
uses
such
treatment,
no
otherwise.
31.
Currently
Use
Alternatives
 
Currently
use
alternatives
is
`
yes'
if
the
applicant
uses
alternatives
for
some
portion
of
pesticide
use
on
the
crop
for
which
an
application
to
use
methyl
bromide
is
made.
Page
64
32.
Research/
Transition
Plans
 
Research/
Transition
Plans
is
`
yes'
when
the
applicant
has
indicated
that
there
is
research
underway
to
test
alternatives
or
if
applicant
has
a
plan
to
transition
to
alternatives.
33.
Tarps/
Deep
Injection
Used
 
Because
all
pre­
plant
methyl
bromide
use
in
the
US
is
either
with
tarps
or
by
deep
injection,
this
variable
takes
on
the
value
`
tarp'
when
tarps
are
used
and
`
deep'
when
deep
injection
is
used.
34.
Pest­
free
cert.
Required
­
This
variable
is
a
`
yes'
when
the
product
must
be
certified
as
`
pest­
free'
in
order
to
be
sold
35.
Other
Issues.­
Other
issues
is
a
short
reminder
of
other
elements
of
an
application
that
were
checked
36.
Change
from
Prior
CUE
Request­
This
variable
takes
a
`+'
if
the
current
request
is
larger
than
the
previous
request,
a
`
0'
if
the
current
request
is
equal
to
the
previous
request,
and
a
`­`
if
the
current
request
is
smaller
that
the
previous
request.
37.
Verified
Historic
Use/
State­
This
item
indicates
whether
the
amounts
requested
by
administrative
area
have
been
compared
to
records
of
historic
use
in
that
area.
38.
Frequency
of
Treatment
 
This
indicates
how
often
methyl
bromide
is
applied
in
the
sector.
Frequency
varies
from
multiple
times
per
year
to
once
in
several
decades.
39.
Economic
Analysis
 
provides
summary
economic
information
for
the
applications.
40.
Loss
per
Hectare
 
This
measures
the
total
loss
per
hectare
when
a
specific
alternative
is
used
in
place
of
methyl
bromide.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
41.
Loss
per
Kilogram
of
Methyl
Bromide
 
This
measures
the
total
loss
per
kilogram
of
methyl
bromide
when
it
is
replaced
with
an
alternative.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
42.
Loss
as
a
%
of
Gross
revenue
 
This
measures
the
loss
as
a
proportion
of
gross
(
total)
revenue.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
43.
Loss
as
a
%
of
Net
Operating
Revenue
­
This
measures
loss
as
a
proportion
of
total
revenue
minus
operating
costs.
Loss
comprises
both
the
monetized
value
of
yield
loss
(
relative
to
yields
obtained
with
methyl
bromide)
and
any
additional
costs
incurred
through
use
of
the
alternative.
It
is
measured
in
current
US
dollars.
This
item
is
also
called
net
cash
returns.
44.
Quality/
Time/
Market
Window/
Yield
Loss
(%)
 
When
this
measure
is
available
it
measures
the
sum
of
losses
including
quality
losses,
non­
productive
time,
missed
market
windows
and
other
yield
losses
when
using
the
marginal
strategy.
45.
Marginal
Strategy
­
This
is
the
strategy
that
a
particular
methyl
bromide
user
would
use
if
not
permitted
to
use
methyl
bromide.
Page
65
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
A
number
of
new
groups
applied
for
methyl
bromide
for
2005
during
this
application
cycle,
as
shown
in
the
table
below.
Although
in
most
cases
they
represent
additional
amounts
for
sectors
that
were
already
well­
characterized
sectors,
in
a
few
cases
they
comprised
new
sectors.
Examples
of
the
former
include
significant
additional
country
(
cured,
uncooked)
ham
production;
some
additional
request
for
tobacco
transplant
trays,
and
very
minor
amounts
for
pepper
and
eggplant
production
in
lieu
of
tomato
production
in
Michigan.

For
the
latter,
there
are
two
large
requests:
cut
flower
and
foliage
production
in
Florida
and
California
(`
Ornamentals')
and
a
group
of
structures
and
process
foods
that
we
have
termed
`
Post­
Harvest
NPMA'
which
includes
processed
(
generally
wheat­
based
foods),
spices
and
herbs,
cocoa,
dried
milk,
cheeses
and
small
amounts
of
other
commodities.
There
was
also
a
small
amount
requested
for
field­
grown
tobacco.

The
details
of
the
case
that
there
are
no
alternatives
which
are
both
technically
and
economically
feasible
are
presented
in
the
appropriate
sector
chapters,
as
are
the
requested
amounts,
suitably
adjusted
to
ensure
that
no
double­
counting,
growth,
etc.
were
included
and
that
the
amount
was
only
sufficient
to
cover
situations
(
key
pests,
regulatory
requirements,
etc.)
where
alternatives
could
not
be
used.

The
amount
requested
by
new
applicants
is
approximately
2.5%
of
the
1991
U.
S.
baseline,
or
about
1,400,000
pounds
of
methyl
bromide,
divided
40%
for
pre­
plant
uses
and
60%
for
postharvest
needs.

The
methodology
for
deriving
the
nominated
amount
used
estimates
that
would
result
in
the
lowest
amount
of
methyl
bromide
requested
from
the
range
produced
by
the
analysis
to
ensure
that
adequate
amounts
of
methyl
bromide
were
available
for
critical
needs.
We
are
requesting
additional
methyl
bromide
in
the
amount
of
about
500,000
Kg,
or
2%
or
the
1991
U.
S.
baseline,
to
provide
for
the
additional
critical
needs
in
the
pre­
plant
and
post­
harvest
sector.

Applicant
Name
2005
U.
S.
CUE
Nomination
(
lbs)

California
Cut
Flower
Commission
400,000
National
Country
Ham
Association
1,172
Wayco
Ham
Company
39
California
Date
Commission
5,319
National
Pest
Management
Association
319,369
Michigan
Pepper
Growers
20,904
Michigan
Eggplant
Growers
6,968
Burley
&
Dark
Tobacco
Growers
USA
­
Transplant
Trays
2,254
Burley
&
Dark
Tobacco
Growers
USA
­
Field
Grown
28,980
Virginia
Tobacco
Growers
­
Transplant
Trays
941
Michigan
Herbaceous
Perennials
4,200
Page
66
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
