METHYL
BROMIDE
CRITICAL
USE
NOMINATION
FOR
PREPLANT
SOIL
USE
FOR
STRAWBERRIES
GROWN
FOR
FRUIT
IN
OPEN
FIELDS
ON
PLASTIC
TARPS
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
STRAWBERRIES
GROWN
FOR
FRUIT
IN
OPEN
FIELDS
ON
PLASTIC
TARPS
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
ii
U.
S.
Environmental
Protection
Agency
Mail
Code
7503C
Washington,
DC
20460
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
____________________________________________________________
7
1.
Nominating
Party
_________________________________________________________
7
2.
Descriptive
Title
of
Nomination______________________________________________
7
3.
Crop
and
Summary
of
Crop
System___________________________________________
7
4.
Methyl
Bromide
Nominated
_________________________________________________
8
5.
Brief
Summary
of
the
Need
for
Methyl
Bromide
as
a
Critical
Use
___________________
8
6.
Summarize
Why
Key
Alternatives
Are
Not
Feasible______________________________
9
7.
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_____________________________
10
8.
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
__________________________
11
9.
Summarize
Assumptions
Used
to
Calculate
Methyl
Bromide
Quantity
Nominated
for
Each
Region___________________________________________________________________
12
California
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
______________
13
California
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
13
California
­
11.
Characteristics
of
Cropping
System
and
Climate
_____________________
14
California
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
15
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
____________________________________
16
California
­
13.
Reason
for
Alternatives
Not
Being
Feasible
_________________________
16
California
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide
____________
18
California
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
19
California
­
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
___
20
California
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
21
California
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
22
California
­
Summary
of
Technical
Feasibility
___________________________________
22
Eastern
US
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
_____________
22
Eastern
US
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request______________________________________________
22
Eastern
US
­
11.
Characteristics
of
Cropping
System
and
Climate
____________________
23
Eastern
US
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
____________________________
24
EASTERN
US
­
PART
C:
TECHNICAL
VALIDATION____________________________________
25
Eastern
US
­
13.
Reason
for
Alternatives
Not
Being
Feasible
________________________
25
Eastern
US
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
___________
27
Eastern
US
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
28
iv
Eastern
US
­
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
___
28
Eastern
US
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
29
Eastern
US
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?___________________________________________________
29
Eastern
US
­
Summary
of
Technical
Feasibility
__________________________________
29
Florida
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_________________
30
Florida
­
10.
Key
Diseases
and
Weeds
for
which
Methyl
Bromide
Is
Requested
and
Specific
Reasons
for
this
Request_____________________________________________________
30
Florida
­
11.
Characteristics
of
Cropping
System
and
Climate
_______________________
30
Florida
­
12.
Historic
Pattern
of
Use
of
Methyl
Bromide,
and/
or
Mixtures
Containing
Methyl
Bromide,
for
which
an
Exemption
Is
Requested
__________________________________
32
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION_______________________________________
33
Florida
­
13.
Reason
for
Alternatives
Not
Being
Feasible
___________________________
33
Florida
­
14.
List
and
Discuss
Why
Registered
(
and
Potential)
Pesticides
and
Herbicides
Are
Considered
Not
Effective
as
Technical
Alternatives
to
Methyl
Bromide:
_______________
35
Florida
­
15.
List
Present
(
and
Possible
Future)
Registration
Status
of
Any
Current
and
Potential
Alternatives
_______________________________________________________
36
Florida
­
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
___
36
Florida
­
17.
Are
There
Any
Other
Potential
Alternatives
Under
Development
which
Are
Being
Considered
to
Replace
Methyl
Bromide?
__________________________________
37
Florida
­
18.
Are
There
Technologies
Being
Used
to
Produce
the
Crop
which
Avoid
the
Need
for
Methyl
Bromide?
_______________________________________________________
37
Florida
­
Summary
of
Technical
Feasibility______________________________________
37
PART
D:
EMISSION
CONTROL
___________________________________________________
38
19.
Techniques
That
Have
and
Will
Be
Used
to
Minimize
Methyl
Bromide
Use
and
Emissions
in
the
Particular
Use
________________________________________________________
38
20.
If
Methyl
Bromide
Emission
Reduction
Techniques
Are
Not
Being
Used,
or
Are
Not
Planned
for
the
Circumstances
of
the
Nomination,
State
Reasons_____________________
39
PART
E:
ECONOMIC
ASSESSMENT________________________________________________
40
21.
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period____________
40
22.
Gross
and
Net
Revenue___________________________________________________
41
Measures
of
Economic
Impacts
of
Methyl
Bromide
Alternatives
_____________________
42
Summary
of
Economic
Feasibility
_____________________________________________
43
PART
F.
FUTURE
PLANS
_______________________________________________________
47
23.
What
Actions
Will
Be
Taken
to
Rapidly
Develop
and
Deploy
Alternatives
for
This
Crop?
________________________________________________________________________
47
24.
How
Do
You
Plan
to
Minimize
the
Use
of
Methyl
Bromide
for
the
Critical
Use
in
the
Future?
__________________________________________________________________
51
25.
Additional
Comments
on
the
Nomination
____________________________________
54
26.
Citations
______________________________________________________________
56
Citations
Reviewed
but
Not
Applicable
_________________________________________
58
v
APPENDIX
B.
SUMMARY
OF
NEW
APPLICANTS
___________
Error!
Bookmark
not
defined.

LIST
OF
TABLES
PART
A:
SUMMARY
_____________________________________________________________
7
Table
4.1:
Methyl
Bromide
Nominated
____________________________________________
8
Table
A.
1:
Executive
Summary
__________________________________________________
9
Table
7.1:
Proportion
of
Crops
Grown
Using
Methyl
Bromide
_________________________
10
California
­
Table
8.1:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
____________
11
Eastern
US
­
Table
8.2:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
___________
11
Florida
­
Table
8.3:
Amount
of
Methyl
Bromide
Requested
for
Critical
Use
______________
12
Table
A.
2:
2006
Sector
Nomination
 
Strawberries__________________________________
13
CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE_________________
13
California
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request__
13
California
­
Table
11.1:
Characteristics
of
Cropping
System___________________________
14
California
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
___________________
14
California
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
_____________________
15
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
16
California
 
Table
13.1:
Reason
for
Alternatives
Not
Being
Feasible
____________________
16
California
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
_________________
18
California
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_____________________
19
California
 
Table
16.1:
Effectiveness
of
Alternatives
 
Key
Pest
1
_____________________
20
Table
16.2.
Effects
of
Soil
Fumigation
with
Methyl
Bromide/
Chloropicrin
(
MB/
CP)
vs.
Dichloropropene/
Chloropicrin
(
DP/
CP)
on
Yields
(
grams/
plant)
of
Strawberry
in
10
Studies
_______________________________________________________________________
21
California
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
________________________
21
EASTERN
US
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
________________
22
Eastern
US
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request_
22
Eastern
US
­
Table
11.1:
Characteristics
of
Cropping
System__________________________
23
Eastern
US
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
__________________
23
Eastern
US
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide
____________________
24
EASTERN
US
­
PART
C:
TECHNICAL
VALIDATION
______________________________________
25
Eastern
US
 
Table
14.1:
Technically
Infeasible
Alternatives
Discussion
________________
27
Eastern
US
 
Table
15.1:
Present
Registration
Status
of
Alternatives
____________________
28
Eastern
US
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
_______________________
28
FLORIDA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
___________________
30
Florida
­
Table
10.1:
Key
Diseases
and
Weeds
and
Reason
for
Methyl
Bromide
Request
____
30
Florida
­
Table
11.1:
Characteristics
of
Cropping
System
_____________________________
30
Florida
­
Table
11.2
Characteristics
of
Climate
and
Crop
Schedule
_____________________
31
Florida
­
Table
12.1
Historic
Pattern
of
Use
of
Methyl
Bromide________________________
32
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION
_________________________________________
33
Florida
 
Table
15.1:
Present
Registration
Status
of
Alternatives
_______________________
36
Florida
 
Table
C.
1:
Alternatives
Yield
Loss
Data
Summary
__________________________
36
PART
D:
EMISSION
CONTROL
____________________________________________________
38
Table
19.1:
Techniques
to
Minimize
Methyl
Bromide
Use
and
Emissions
________________
38
PART
E:
ECONOMIC
ASSESSMENT
_________________________________________________
40
vi
Table
21.1:
Costs
of
Alternatives
Compared
to
Methyl
Bromide
Over
3­
Year
Period
_______
40
Table
22.1:
Year
1
Gross
and
Net
Revenue
________________________________________
41
Table
22.2:
Year
2
Gross
and
Net
Revenue
________________________________________
41
Table
22.3:
Year
3
Gross
and
Net
Revenue
________________________________________
41
California
­
Table
E.
1:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_______________
42
Eastern
US
­
Table
E.
2:
Economic
Impacts
of
Methyl
Bromide
Alternatives
______________
42
Florida
­
Table
E.
3:
Economic
Impacts
of
Methyl
Bromide
Alternatives
_________________
42
PART
F.
FUTURE
PLANS
________________________________________________________
47
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)._________________
60
Page
7
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
Strawberries
Grown
for
Fruit
in
Open
Fields
On
Plastic
Tarps
3.
CROP
AND
SUMMARY
OF
CROP
SYSTEM
This
nomination
covers
methyl
bromide
use
in
three
major
strawberry
production
areas
 
California,
Florida,
and
states
in
the
Eastern
US
(
Alabama,
Arkansas,
Georgia,
Illinois,
Kentucky,
Louisiana,
Maryland,
New
Jersey,
North
Carolina,
Ohio,
South
Carolina,
Tennessee,
West
Virginia
and
Virginia).

California.
California
produces
more
than
80
percent
of
the
fresh
market
and
processed
strawberries
grown
in
the
U.
S.
California
produces
about
20
percent
of
the
world's
strawberries.
Most
strawberries
exported
from
California
go
to
Canada,
Japan,
and
Mexico.

California
has
two
distinct
strawberry
production
areas.
The
southern
region
produces
both
fresh
(
63
percent)
and
processed
(
37
percent)
strawberries.
The
northern
region
includes
both
rotated
and
non­
rotated
strawberry
production
regimes,
with
each
producing
fresh
(
84
percent)
and
processed
(
16
percent)
strawberries.
The
majority
of
growers
are
farming
between
4
and
20
hectares
of
land
with
strawberry
fields
in
rotation.
Because
strawberry
production
in
California
is
concentrated
in
a
small
geographic
location
due
to
optimal
growing
conditions,
factors
that
affect
this
small
area
can
be
significant.
An
example
of
this,
which
is
discussed
later
in
this
chapter,
is
the
regulatory
limit
on
the
amount
of
1,3­
dichloropropene
(
Telone)
that
can
be
used
in
each
township
(
i.
e.,
36
square
mile
area,
approximately
95
square
km)
in
California.

Depending
on
the
region,
California
strawberries
are
planted
in
the
Summer
or
Fall.
Prior
to
planting,
fumigation
is
typically
performed
on
flat
ground
over
the
entire
surface
of
the
field.
Immediately
after
fumigation
the
field
is
covered
with
plastic.
At
the
end
of
the
fumigation
period,
the
plastic
is
removed
and
planting
beds
are
formed
and
covered
with
fresh
plastic.
Strawberry
plants
are
transplanted
about
two
weeks
after
fumigation
to
ensure
that
no
phytotoxic
levels
of
methyl
bromide
remain.
Harvest
begins
about
2
to
3
months
later.
At
the
end
of
the
first
harvest,
the
strawberry
plants
are
removed
and
the
field
is
readied
for
the
next
crop.
Rotational
crops
that
are
planted
after
strawberries,
and
that
benefit
from
the
previous
use
of
methyl
bromide
include
broccoli,
celery,
lettuce,
radish,
leeks,
and
artichokes.

Florida.
Florida
is
the
second
largest
strawberry
producing
state
with
12
percent
of
the
total
U.
S.
production.
Nearly
all
of
the
domestically
produced
strawberries
harvested
in
the
winter
are
grown
in
Florida.
Page
8
Strawberries
are
grown
as
an
annual
crop
in
Florida
using
a
raised­
bed
system.
Methyl
bromide
in
combination
with
chloropicrin
is
applied
to
the
soil
during
construction
of
the
raised­
beds
approximately
two
weeks
prior
to
planting
transplants.
Immediately
after
application,
the
bed
is
covered
with
plastic
mulch.
Drip
or
overhead
irrigation
is
used
to
help
establish
plants,
irrigate
plants,
and
to
protect
the
plants
from
frost.
Many
strawberry
growers
utilize
the
beds
and
drip
tubes
to
grow
a
second
crop,
such
as
cucurbits
or
solanaceous
crops.

Eastern
U.
S.
The
Eastern
U.
S.
strawberry
industry
is
highly
de­
centralized
and
primarily
consists
of
small
family
farms
with
several
hectares
of
strawberries
that
are
directly
marketed
through
U­
pick,
ready­
pick,
roadside
stands,
and
farmers
markets
Strawberry
production
in
the
eastern
states
differs
from
that
in
Florida
because
of
soils
type
(
Florida
typically
has
sandy
soils;
eastern
soils
are
heavier);
topography
(
Florida
has
much
karst
topography;
much
less
common
in
other
states),
climate
(
very
mild
winters
in
Florida),
farm
size
(
farms
are
larger
in
Florida),
and
marketing
practices
(
Florida
is
typically
commercial
compared
to
small
U­
pick
operations)
In
the
Eastern
U.
S.,
the
vast
majority
of
the
strawberry
farms
use
an
annual
cropping
plasti­
culture
production
system
where
the
berries
are
grown
on
raised
beds
similar
to
Florida
strawberry
production.
Planting
time
is
similar
to
Florida,
but
the
production
peak
occurs
later
in
the
season,
between
April
and
May.
About
50
percent
of
the
soils
have
textures
finer
than
sandy
loam.
Nutsedge
is
a
primary
pest
on
about
40
percent
of
the
land
that
typically
has
coarse­
textured
soils.
Some
double
cropping
of
beds
occurs.

4.
METHYL
BROMIDE
NOMINATED
TABLE
4.1:
METHYL
BROMIDE
NOMINATED
YEAR
NOMINATION
AMOUNT
(
KG)
NOMINATION
AREA
(
HA)
2006
1,615,339
8,680
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
US
strawberry
fruit
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
strawberry
fruit
production.
­
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
for
strawberry
fruit
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
townships
caps
and
in
Florida
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
Page
9
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

The
United
States
(
U.
S.)
nomination
for
strawberry
fruit­
field
is
a
critical
need
for
an
amount
of
methyl
bromide
(
MB)
in
areas
with
moderate
to
severe
pest
pressure,
because
currently
there
are
no
feasible
alternatives
and
farmers
would
face
severe
economic
hardships
in
the
absence
of
MB.
Where
there
is
moderate
to
severe
pest
pressure,
the
suggested
alternatives
for
strawberry
fruit
production
fail
to
provide
the
necessary
degree
of
pest
control
or
their
use
is
not
easily
adoptable
due
to
state­
imposed
restrictions.
The
nomination
also
notes
that
applying
alternatives
is
further
complicated
when
plant­
back
restrictions
prevent
farmers
from
meeting
marketing
windows
(
e.
g.,
winter
or
early
spring)
when
strawberry
sale
prices
are
as
much
as
100%
higher
than
during
the
rest
of
the
year
(
see
Market
Window
Information).
The
nomination
notes
significant
progress
in
adopting
emission
reduction
technologies
and
changing
formulations
and
application
rates
to
reduce
MB
dosage
rates
to
some
of
the
lowest
in
the
world,
and
that
further
trials
are
being
conducted
to
evaluate
new
alternatives,
and
to
test
ways
of
overcoming
constraints
in
further
lowering
MB
formulations
and
adopting
even
more
impermeable
barriers.

TABLE
A.
1:
EXECUTIVE
SUMMARY
Region
California
Eastern
US
Florida
AMOUNT
OF
NOMINATION
2006
Kilograms
1,086,777
230,332
295,853
Application
Rate
(
kg/
ha)
196
151
185
Area
(
ha)
5,552
1,528
1,600
AMOUNT
OF
APPLICANT
REQUEST
2006
Kilograms
1,632,931
350,534
579,691
Application
Rate
(
kg/
ha)
202
151
202
Area
(
ha)
8,094
2,317
2,873
ECONOMICS
FOR
NEXT
BEST
ALTERNATIVE
Marginal
Strategy
1,3­
D+
PIC
1,3­
D+
PIC
1,3­
D+
PIC
Yield
Loss
(%)
14
14
25
Loss
per
hectare
(
US$/
ha)
11,817
9,319
14,447
Loss
per
kg
Methyl
Bromide
(
US$/
kg)
58.57
62.05
77.72
Loss
as
%
of
Gross
Revenue
(%)
16
18
20
Loss
as
%
of
Net
Revenue
(%)
87
42
52
6.
SUMMARIZE
WHY
KEY
ALTERNATIVES
ARE
NOT
FEASIBLE:

Despite
use
of
many
alternatives,
many
of
which
have
already
been
incorporated
into
standard
strawberry
production
systems,
methyl
bromide
is
believed
to
be
the
only
currently
available
treatment
that
consistently
provides
reliable
control
of
nutsedge
species,
nematodes
and
the
disease
complex
affecting
strawberry
production.
Only
acreage
with
moderate
to
high
pest
pressure
is
included
in
this
nomination.
Page
10
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
TOTAL
CROP
AREA
2001
&
2002
AVERAGE
(
HA)
PROPORTION
OF
TOTAL
CROP
AREA
TREATED
WITH
METHYL
BROMIDE
(%)
California
11,109
74
Eastern
US
Not
available
Not
available
Florida
2,873
94
NATIONAL
TOTAL*:
19,486
65
*
National
total
includes
other
regions
not
requesting
methyl
bromide.

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.

 
California
has
requested
enough
methyl
bromide
to
treat
about
75­
85%
of
the
state's
strawberry
crop
with
methyl
bromide.

 
Southeastern
states
consortium
claims
that
90%
of
the
total
acreage
grown
in
this
area
is
treated
with
methyl
bromide.

 
Total
acreage
grown
is
6900
acres
and
Florida
has
requested
7100
acres
to
be
treated
with
methyl
bromide.

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?

California
has
proposed
to
rigorously
test
alternatives
and
is
committed
to
finding
alternatives
to
methyl
bromide.
The
other
regions
have
not
proposed
reduction
in
use,
however,
these
regions
use
significantly
less
methyl
bromide
than
does
California.
Page
11
8.
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
CALIFORNIA
­
TABLE
8.1:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
CALIFORNIA
California
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
1,632,931
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Flat
Fumigation
FORMULATION
(
ratio
of
methyl
bromide/
chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
8,094
APPLICATION
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
202
DOSAGE
RATE*
(
G/
M
2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.

EASTERN
US
­
TABLE
8.2:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
EASTERN
UNITED
STATES
Eastern
U.
S.
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
350,534
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE
67:
33
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
2,317
APPLICATION
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
151
DOSAGE
RATE*
(
G/
M
2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
30.2
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
151
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
15
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
12
FLORIDA
­
TABLE
8.3:
AMOUNT
OF
METHYL
BROMIDE
REQUESTED
FOR
CRITICAL
USE
REGION:
FLORIDA
Florida
YEAR
OF
EXEMPTION
REQUEST
2006
KILOGRAMS
OF
METHYL
BROMIDE
579,691
USE:
FLAT
FUMIGATION
OR
STRIP/
BED
TREATMENT*
Bed
FORMULATION
(
ratio
of
methyl
bromide/
Chloropicrin
mixture)
TO
BE
USED
FOR
THE
CUE**
98:
2
TOTAL
AREA
TO
BE
TREATED
WITH
THE
METHYL
BROMIDE
OR
METHYL
BROMIDE/
CHLOROPICRIN
FORMULATION
(
m2
or
ha)
2,873
APPLICATION
RATE*
(
KG/
HA)
FOR
THE
ACTIVE
INGREDIENT
202
DOSAGE
RATE*
(
G/
M
2)
OF
ACTIVE
INGREDIENT
USED
TO
CALCULATE
REQUESTED
KILOGRAMS
OF
METHYL
BROMIDE
14
APPLICATION
RATE*
(
kg/
ha)
FOR
THE
FORMULATION
206
DOSAGE
RATE*
(
g/
m2)
OF
FORMULATION
USED
TO
CALCULATE
REQUESTED
KG
OF
METHYL
BROMIDE
142
*
Florida
states
maximum
bed
width
is
3
feet
with
10,100
linear
bed
feet/
acre,
which
totals
69%
of
acre
treated.
**
Florida
states
that
growers
use
98:
2
formulation
for
sting
nematode
control.

9.
SUMMARIZE
ASSUMPTIONS
USED
TO
CALCULATE
METHYL
BROMIDE
QUANTITY
NOMINATED
FOR
EACH
REGION
The
amount
of
methyl
bromide
nominated
by
the
US
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.
Values
greater
than
100
percent
are
due
to
the
inclusion
of
additional
varieties
in
the
applicant's
request
that
were
not
included
in
the
USDA
National
Agricultural
Statistics
Service
surveys
of
the
crop.
 
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.
The
three
applicants
that
included
growth
in
their
request
had
the
growth
amount
removed.
 
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Not
applicable
in
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,
karst
topography,
buffer
zones,
and
unsuitable
terrain.
Page
13
TABLE
A.
2:
2006
SECTOR
NOMINATION
 
STRAWBERRIES*

2006
Strawberries
Sector
Nomination
California
Eastern
US
Florida
Requested
Hectares
(
ha)
8,094
2,317
2,873
Requested
Application
Rate
(
kg/
ha)
202
151
202
Applicant
Request
for
2006
Requested
Kilograms
(
kg)
1,632,931
350,534
579,691
Nominated
Hectares
(
ha)
5,552
1,528
1,600
Nominated
Application
Rate
(
kg/
ha)
196
151
185
CUE
Nominated
for
2006*
Nominated
Kilograms
(
kg)
1,086,777
230,332
295,853
Overall
Reduction
(%)
37
2006
U.
S.
CUE
Nomination
(
kg)
1,612,962
Research
Amount
(
kg)
2,377
2006
Sector
Nomination
Totals
Total
2006
U.
S.
Sector
Nominated
Kilograms
(
kg)
1,615,339
*
See
Appendix
A
for
complete
description
of
how
the
nominated
amount
use
calculated.

CALIFORNIA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
CALIFORNIA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
CALIFORNIA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
IS
NEEDED
California
Diseases:
Black
root
rot
(
Rhizoctinia
and
Pythium
spp.),
crown
rot
(
Phytophthora
cactorum),

California
Nematodes:
root
knot
nematode
(
Meloidogyne
spp.)
Sting
nematode
(
Belonolaimus
spp.)

California
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus),
purple
nutsedge
(
Cyperus
rotundus),
ryegrass,
and
winter
annual
weeds.
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
California.
Uses
of
alternatives
are
limited
by
regulatory
restrictions
such
as
the
township
caps
on
the
amount
of
1,3­
dichloropropene
that
can
be
used.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
57:
43
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.
Page
14
CALIFORNIA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
CALIFORNIA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
CALIFORNIA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Fruiting
plants
grown
from
transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Cultured
as
annual
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Vegetables
(
e.
g.
broccoli,
celery,
lettuce,
radish,
leeks,
cauliflower,
artichokes)
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Light
and
medium
soils
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Yearly
OTHER
RELEVANT
FACTORS:
None
Identified
CALIFORNIA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
MAR
APR
MAY
JUN
CLIMATIC
ZONE
9
B
RAINFALL
(
mm)
trace
1.0
trace
0
44.7
56.9
9.9
30.5
16
72.1
17.3
0
OUTSIDE
TEMP.
(
°
C)*
30.3
27.4
25.1
18.4
13.4
9.6
10.3
10.6
14.4
14.8
20.8
25.7
FUMIGATION
SCHEDULE
X
PLANTING
IN
NORTH**
X
X
PLANTING
IN
SOUTH**
X
*
For
Fresno,
California.
**
In
Northern
California
the
crop
is
planted
in
September/
October
and
harvested
from
December
through
June/
July.
In
Southern
California
the
crop
is
planted
in
the
summer,
generally
in
July,
and
harvested
from
September
thru
December.
The
rotational
crop,
often
celery,
is
grown
from
March
thru
May.
Average
farm
size
in
this
area
is
about
30
acres,
100%
of
which
is
treated.
Rotational
crops
include
lettuce,
celery,
and
broccoli.
In
Northern
California
planting
occurs
in
October/
November
and
harvesting
occurs
from
April
thru
October;
average
farm
size
is
60
acres;
rotational
crops
include
lettuce,
strawberries,
broccoli
and
cauliflower.

CALIFORNIA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

To
the
best
of
our
knowledge
none
of
the
following
characteristics
of
the
cropping
system
would
affect
adoption
of
a
relevant
alternative.
The
US
believes
that
the
Telone
township
caps
prevent
the
further
adoption
of
Telone
as
an
alternative.
Page
15
CALIFORNIA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
CALIFORNIA
­
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)
6,808
7,401
8,600
8,248
8,456
7,912
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
Flat
Fumigation
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kilograms)
1,833,235
1,928,597
2,264,789
1.919,240
1,611,775
1,592,156
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
Typically
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Shank
injected
25
to
30
cm
deep
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
269
260
275
244
191
201
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
26.9
26
27.5
24.4
19.1
20.1
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
16
CALIFORNIA
­
PART
C:
TECHNICAL
VALIDATION
CALIFORNIA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
CALIFORNIA,
CALIFORNIA
 
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
Dichloropropene
(
1,3­
D,
Telone)
Used
alone,
1,3­
Dichloropropene
does
not
adequately
control
diseases
and
weeds.
Buffer
zones
of
100
feet
are
too
constraining
for
small
fields.
Required
Protective
equipment
(
protective
suits)
pose
a
health
risk
to
workers
in
hot
and
humid
weather.
Long
pre­
planting
intervals
affect
cultivar
selection,
Integrated
Pest
Management
practices,
timing
of
harvest,
marketing
window
options,
land
leasing
decisions
and
crop
rotation
schedules.
In
CA,
states
regulations
require
township
caps,
which
limits
use
of
1,3­
Dichloropropene.
No
Basamid
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Chloropicrin
Chloropicrin
alone
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control
No
Metam
sodium
Metam­
sodium
alone
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
Metam
sodium
suffers
from
erratic
efficacy
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
Metam
sodium
if
not
technically
feasible
in
California
because
it
has
limited
activity
against
soilborne
pathogens
in
strawberry
fields.
No
Metam
sodium,
chloropicrin
Metam­
sodium
with
chloropicrin
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
No
Methyl
iodide
Promising,
but
it
is
not
currently
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Nematicides
Addressed
individually
(
e.
g.,
1,3­
D).
No
Ozone
Ozone
is
not
technically
feasible
alone
because
it
doesn't
control
diseases
and
weeds.
No
NON
CHEMICAL
ALTERNATIVES
Page
17
Biofumigation
Biofumigation
is
not
technically
feasible
because
of
the
quantity
of
Brassica
crop
that
would
be
needed
to
control
target
pests
in
strawberries
(
approximately
three
hectares
would
be
required
for
every
hectare
of
strawberry
production).
Incorporation
of
Brassica
at
these
levels
is
likely
to
have
allelopathic
effects
on
the
target
crop.
In
addition,
field
trials
growing
tomatoes
in
cabbage
residue
produced
inconsistent
and
inadequate
efficacy,
and
poor
yield
in
two
years
out
of
three.
No
Solarization
Solarization,
when
used
alone
for
pre­
plant
fumigation,
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
a
wide
range
of
soil­
borne
diseases
and
pests.
This
process
is
highly
weather
dependent
and
works
best
in
combination
with
IPM
for
control
of
pests
and
diseases.
No
Steam
Although
practiced
successfully
in
greenhouse
situations,
fumigation
with
steam,
when
used
alone
in
the
field
for
preplant
fumigation,
is
not
operationally
practical
due
to
low
application
speeds
and
high
energy
requirements
(
1­
3
weeks
to
treat
one
hectare).
In
addition
results
from
field
experiments
steam
treatment
have
been
erratic.
No
Biological
Control
Biological
control
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide
because
it
does
not
provide
adequate
control
of
target
pests.
No
Cover
Crops
and
Mulching
Although
already
in
use
as
part
of
an
Integrated
Pest
Management
Program,
cover
crops
and
mulching
alone
do
not
provide
adequate
control
of
the
target
pests.
No
Crop
rotation/
fallow
Crop
rotation
is
already
being
used
in
many
strawberry
production
areas,
but
does
not
adequately
control
the
target
pests.
No
Flooding
and
water
management
Flooding
and
water
management
are
not
feasible
due
to
limited
water
resources,
uneven
topography
in
California,
and
in
the
eastern
states
by
sandy
soil
types
that
would
not
retain
the
flood
for
an
adequate
time
to
control
the
pests.
No
General
IPM
General
IPM
is
already
practiced
in
strawberry
production,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide
since
a
combination
of
IPM
methods
do
not
offer
adequate
pest
control
by
itself.
No
Grafting/
Resistant
rootstock/
plant
breeding
Grafting/
resistant
rootstock/
plant
breeding
is
not
being
used
and
it
is
not
technically
feasible
because
grafting
is
not
possible
given
the
physical
characteristics
of
strawberry
plants.
Breeding
for
resistance
to
pathogens
is
valuable
as
a
long­
term
endeavor
and
the
U.
S.
continues
work
in
this
area.
At
this
point
in
time,
plant
breeding
has
not
resulted
in
a
cultivar
that
is
sufficiently
resistant
to
the
major
target
pests.
No
Organic
Amendments/
Compost
Organic
Amendments/
Compost
is
already
being
used
in
certain
regions
of
the
U.
S.,
but
is
not
technically
feasible
as
a
standalone
replacement
for
methyl
bromide.
No
Organic
production
In
certain
regions
of
the
U.
S.
some
organic
production
of
strawberries
occurs.
However,
as
a
stand
alone
replacement
for
methyl
bromide
it
is
not
technically
feasible
because
of
reduced
yields.
No
Resistant
cultivars
Resistant
cultivars
are
already
being
used
in
certain
regions
of
the
U.
S.,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
No
Page
18
Soil­
less
culture
Soil­
less
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
No
Substrates/
Plug
plants
Substrates/
plant
plugs
are
currently
being
used
but
are
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
Although
plug
plants
have
actually
proven
to
be
more
vigorous
than
bare
root
transplants
in
research
trials,
it
is
not
known
to
what
extent
pathogens
are
controlled
by
this
method.
Weed
control
would
still
be
an
issue.
And
adopting
this
use
would
also
require
major
retooling
of
the
industry.
No
Hand­
weeding
Hand­
weeding
not
listed
as
a
standard
option.
Hand­
weeding
strawberries
is
not
a
desirable
practice
for
controlling
weeds
because
they
cannot
be
removed
without
damaging
the
plastic
and
thereby
reducing
its
effectiveness
in
excluding
weeds,
insects,
and
pathogens.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
Dichloropropene/
Chloropicrin
This
combination
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances.
Together
they
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds.
Regulatory
restrictions
for
each
of
the
chemicals
may
further
limit
their
use.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.

1,3­
Dichloropropene/
Chloropicrin
and
Metam
sodium
These
combinations
also
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.

Basamid
+
Chloropicrin
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

CALIFORNIA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
CALIFORNIA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
1,3­
Dichloropropene
Drip
application
of
1,3­
D
in
California,
are
less
expensive
and
require
smaller
buffer
zones
than
broadcast
applications,
making
it
the
preferred
application
method
for
this
alternative
(
drip,
90%;
broadcast,
10%).
However,
when
1,3­
D
fumigations
by
drip
are
used
other
production
costs
are
significantly
higher
due
to
the
need
for
herbicide
applications
(
i.
e.
metam
sodium)
and
hand
weeding
operations.
Recent
studies
in
California
found
that
fruit
production
costs
were
20­
212%
higher
than
with
methyl
bromide/
chloropicrin
(
Goldhue),
with
the
smaller
cost
estimates
coming
from
VIF
mulch
treatments
that
are
not
currently
usable
due
to
regulatory
and
technical
issues.
Page
19
Chloropicrin
Chloropicrin
alone
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control
Metam
sodium
Metam­
sodium
alone
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
Metam
sodium
suffers
from
erratic
efficacy
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
Metam
sodium
if
not
technically
feasible
in
California
because
it
has
limited
activity
against
soilborne
pathogens
in
strawberry
fields.

Sodium
azide
Does
not
sterilize
ground.
Yields
equal
to
untreated.

1,3D/
chloropicrin
This
combination
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances.
Together
they
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds.
Regulatory
restrictions
for
each
of
the
chemicals
may
further
limit
their
use.

CALIFORNIA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

CALIFORNIA
 
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:

Basamid
Not
registered
for
use
in
U.
S.
Y
Unknown
Methyl
Iodide
Not
registered
for
use
in
U.
S.
Y
Unknown
Propargyl
bromide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
Sodium
azide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
Page
20
CALIFORNIA
 
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
 
TABLE
16.1:
EFFECTIVENESS
OF
ALTERNATIVES
 
KEY
PEST
1
YELLOW
NUTSEDGE
KEY
PEST:
KEY
PEST
1
AVERAGE
DISEASE
%
OR
RATING
AND
YIELDS
IN
PAST
3~
5
YEARS
METHYL
BROMIDE
FORMULATIONS
AND
ALTERNATIVES
#
OF
TRIALS
ACTUAL
YIELDS
(
T/
HA)
CITATION
MBR:
Chloropicrin
(
67:
33)
200
lb
Telone:
chloropicrin
17.5
gal.
drip
Chloropicrin
EC
100
lb
drip
Metam
sodium
35
gal
drip
1
lb/
A
14109
15551
14613
15117
(
N.
S.)
Ferguson,
2001
MBR:
Chloropicrin
390kg/
ha
Telone
+
35%
chloropicrin
(
327
L)
Telone
+
17%
chloropicrin
(
327
L)
Metam
sodium
(
300L)
Metam
NA
+
chloropicrin
(
300L
+
170
kg)
Solarization
(
painted
black)
1
of
2
flats/
ha
4131
(
a)
3541
(
ab)
3620
(
ab)
2552
(
bcd)
2199
(
cd)
2710
(
bcd)
Locascio,
1999
MBR:
Chloropicrin
390kg/
ha
Telone
+
35%
chloropicrin
(
327
L)
Telone
+
17%
chloropicrin
(
327
L)
Metam
NA
+
chloropicrin
(
300L
+
170
kg)
Metam
sodium
(
300L)
Solarization
(
painted
black)
2
of
2
flats/
ha
3511
(
ab)
3553
(
ab)
3333
(
ab)
3279
(
ab)
2933
(
bc)
3210
(
b)
Locascio,
1999
CALIFORNIA
 
TABLE
16.2:
EFFECTIVENESS
OF
ALTERNATIVES
 
MULTIPLE
PESTS
Page
21
EFFECTS
OF
SOIL
FUMIGATION
WITH
METHYL
BROMIDE/
CHLOROPICRIN
(
MB/
CP)
VS.
DICHLOROPROPENE/
CHLOROPICRIN
(
DP/
CP)
ON
YIELDS
(
GRAMS/
PLANT)
OF
STRAWBERRY
IN
10
STUDIES
(
FROM
SHAW
AND
LARSON
1999).
MB:
CP
treated
DP:
CP
treated
Study
No
Reps.
Mean
Yield
SD
Mean
Yield
SD
Percent
Increasez
ty
py
dy
2
6
992
177
856
109
15.9
1.60
0.070
0.93
5
6
1331
40
1046
55
27.2
10.27
<
0.001
5.93
7
5
1096
110
687
62
59.5
6.76
<
0.001
4.28
21
6
886
71
914
48
­
2.9
­
0.78
0.727
­
0.45
31
4
655
65
647
54
1.0
0.15
0.443
0.11
58
6
871
56
836
11
4.3
1.52
0.077
0.88
64
36
1381
146
1180
185
17.0
5.12
<
0.001
1.21
65
10
1742
131
1489
141
17.0
4.16
<
0.001
1.86
66
6
994
88
981
97
1.3
0.37
0.355
0.15
67
4
610
46
591
46
3.2
0.58
0.291
0.41
z
Unweighted
percent
increase
in
yield
for
the
MB:
CP
treatment
over
the
DP:
CP
treatment
group.
y
t
is
Student's
t
test
value,
p
is
a
one­
tailed
probability
(
requires
P<
0.025
for
conventional
significance),
and
d
is
the
standardized
effect
size.
Average
Percent
Increase
across
all
studies
is
14.35%.

CALIFORNIA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
Dichloropropene/
Chloropicrin
Weeds,
nematodes
and
diseases
1%
gain
to
14%
loss
14.4%
(
Shaw
and
Larson,
1999)
Chloropicrin/
Metam
sodium
Multiple
pests
6.6­
47%
27%
Locascio,
1999
Metam
sodium
Weeds,
nematodes
and
diseases
16%­
29.8%
29.8%
(
Shaw
and
Larson,
1999)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
14%

CALIFORNIA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Previous
research
evaluating
various
chemical
alternatives
to
methyl
bromide
suggests
that
the
mixture
of
1,3­
dichloropropene
(
Telone)
with
chloropicrin,
coupled
with
separate,
but
complementary
chloropicrin
and
herbicide
treatments
for
weed
control,
has
a
potential
an
IPM
alternative
to
methyl
bromide
to
manage
soil­
borne
pests
and
sustain
crop
yields,
but
this
is
only
feasible
in
areas
where
groundwater
concerns
could
allow
the
use
of
Telone.
There
are
no
selective
herbicides
for
the
control
of
the
wide
range
of
weeds
found
in
strawberries.

Iodomethane
plus
chloropicrin
is
a
promising
alternative.
It
is
actively
being
researched
with
promising
results
and,
if
registered,
would
be
a
viable
alternative
to
methyl
bromide,
depending
on
what
regulatory
restrictions
may
arise.
Page
22
CALIFORNIA
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?:

For
chemical
alternatives,
see
above
in
section
17.
Otherwise
no,
when
strawberries
are
grown
in
the
field
for
fruit,
the
growth
habit
of
strawberries
(
producing
runners
which
take
root
in
the
soil)
does
not
lend
itself
to
technologies
such
as
soil­
less
systems,
plug
plants,
or
containerized
plants.

CALIFORNIA
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
Regulatory
constraints
such
as
township
caps,
as
well
as
biological
considerations
such
as
heavy
pressure
from
pathogens,
nematodes
and
weeds,
increasing
nematode
damage
over
time
from
not
using
methyl
bromide,
phytotoxicity,
variation
in
yields,
time
lost
due
to
delays
in
planting,
and
missing
early
harvest
with
high
strawberry
prices
contribute
to
the
technical
infeasibility
of
replacing
methyl
bromide.

The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
strawberry
fruit
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
strawberry
fruit
production.
­
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
for
strawberry
fruit
where
the
key
pest
pressure
is
moderate
to
high..
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
in
California
due
to
township
caps.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

EASTERN
US
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
EASTERN
US
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
EASTERN
US
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Page
23
Diseases:
Black
Root
Rot
(
Pythium,
Rhizoctonia),
Crown
rot
(
Phytopthora
cactorum),

Nematodes:
Root
knot
nematode
(
Meloidogyne
spp.)
Eastern
US
Weeds:
Yellow
nutsedge
(
Cyperus
escultentus)
Purple
nutsedge
(
Cyperus
rotundus)
Ryegrass
(
Lolium
spp.)
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Eastern
United
States.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

EASTERN
US
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
EASTERN
US
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
EASTERN
US
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Fruiting
plants
grown
from
transplants.
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Cultured
as
annual.
TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Varies
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
50%
light,
45%
medium,
5%
heavy
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Yearly
OTHER
RELEVANT
FACTORS:
None
Identified
EASTERN
US
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
MAR
APR
MAY
CLIMATIC
ZONE
5b
 
8b
RAINFALL
(
mm)*
248.2
trace
158
84.3
121.9
108.7
136.9
36.6
131.3
206
107.7
147.8
OUTSIDE
TEMP.
(
°
C)*
25.6
27.2
27.5
25.1
20.0
11.4
7.5
6.2
9.7
15.1
17.7
22.9
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
X
*
Macon,
GA
EASTERN
US
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

To
our
knowledge
the
above
characteristics
would
not
prevent
adoption
of
any
relevant
alternative.
Page
24
EASTERN
US
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
EASTERN
US,
SOUTHEASTERN
UNITED
STATES
­
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)
1421
1446
1593
1694
1823
1879
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
strip/
bed
All
strip/
bed
All
strip/
bed
All
strip/
bed
All
strip/
bed
All
strip/
bed
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
312,231
317,918
239,851
254,689
274,405
283,530
FORMULATIONS
OF
METHYL
BROMIDE
(
methyl
bromide
/
chloropicrin)
67:
33
67:
33
67:
33
67:
33
67:
33
67:
33
METHOD
BY
WHICH
METHYL
BROMIDE
APPLIED
(
e.
g.
injected
at
25cm
depth,
hot
gas)
Pressurized
injection
at
20
cm
depth
 
two
shanks/
bed
(
approximately
76
cm
wide
bed;
25
cm
height
at
crown
of
bed)

APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
220
220
151
150
151
151
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
45
45
45
45
45
45
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
25
EASTERN
US
­
PART
C:
TECHNICAL
VALIDATION
EASTERN
US
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
EASTERN
US
 
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
Dichloropropene
(
1,3­
D,
Telone)
Used
alone,
1,3­
Dichloropropene
does
not
adequately
control
diseases
and
weeds.
Buffer
zones
of
100
feet
are
too
constraining
for
small
fields.
Required
Protective
equipment
(
protective
suits)
pose
a
health
risk
to
workers
in
hot
and
humid
weather.
Long
pre­
planting
intervals
affect
cultivar
selection,
Integrated
Pest
Management
practices,
timing
of
harvest,
marketing
window
options,
land
leasing
decisions
and
crop
rotation
schedules
No
Basamid
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Basamid,
Chloropicrin
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Chloropicrin
Chloropicrin
alone
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control
No
Metam
sodium
Metam­
sodium
alone
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
No
Metam
sodium,
chloropicrin
Metam­
sodium
with
chloropicrin
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
No
Methyl
iodide
Promising,
but
it
is
not
currently
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Nematicides
Addressed
individually.
No
Ozone
Ozone
is
not
technically
feasible
alone
because
it
doesn't
control
diseases
and
weeds.
No
NON
CHEMICAL
ALTERNATIVES
Page
26
Biofumigation
Biofumigation
is
not
technically
feasible
because
of
the
quantity
of
Brassica
crop
that
would
be
needed
to
control
target
pests
in
strawberries
(
approximately
three
hectares
would
be
required
for
every
hectare
of
strawberry
production).
Incorporation
of
Brassica
at
these
levels
is
likely
to
have
allelopathic
effects
on
the
target
crop.
In
addition,
field
trials
of
growing
tomatoes
in
cabbage
residue
produced
inconsistent
and
inadequate
efficacy,
and
poor
yield
in
two
years
out
of
three.
No
Solarization
Solarization,
when
used
alone
for
pre­
plant
fumigation,
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
a
wide
range
of
soil­
borne
diseases
and
pests.
This
process
is
highly
weather
dependent
and
works
best
in
combination
with
IPM
for
control
of
pests
and
diseases.
However,
solarization
only
suppresses
nutsedge
at
best.
(
Chase
et.
al.
1998.
Egley,
1983)
No
Steam
Steam,
although
successfully
used
in
greenhouse
situations,
when
used
alone
in
the
field
for
pre­
plant
fumigation,
is
not
operationally
practical
due
to
low
application
speeds
and
high
energy
requirements
(
1­
3
weeks
to
treat
one
hectare).
In
addition
results
from
field
experiments
steam
treatment
have
been
erratic.
No
Biological
Control
Biological
control
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide
because
it
does
not
provide
adequate
control
of
target
pests.
No
Cover
Crops
and
Mulching
Although
already
in
use
as
part
of
an
Integrated
Pest
Management
Program,
cover
crops
and
mulching
alone
do
not
provide
adequate
control
of
the
target
pests.
No
Crop
rotation/
fallow
Crop
rotation
is
already
being
used
in
many
strawberry
production
areas,
but
does
not
adequately
control
the
target
pests.
No
Flooding
and
water
management
Flooding
and
water
management
are
not
feasible
due
to
limited
water
resources,
uneven
topography
in
California,
and
in
the
eastern
states
by
sandy
soil
types
that
would
not
retain
the
flood
for
an
adequate
time
to
control
the
pests.
No
General
IPM
General
IPM
is
already
practiced
in
strawberry
production,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide
since
a
combination
of
IPM
methods
do
not
offer
adequate
pest
control
by
itself.
No
Grafting/
Resistant
rootstock/
plant
breeding
Grafting/
resistant
rootstock/
plant
breeding
is
not
being
used
and
it
is
not
technically
feasible
because
grafting
is
not
possible
given
the
physical
characteristics
of
strawberry
plants.
Breeding
for
resistance
to
pathogens
is
valuable
as
a
long­
term
endeavor
and
the
U.
S.
continues
work
in
this
area.
At
this
point
in
time,
plant
breeding
has
not
resulted
in
a
cultivar
that
is
sufficiently
resistant
to
the
major
target
pests.
No
Organic
Amendments/
Compost
Organic
Amendments/
Compost
is
already
being
used
in
certain
regions
of
the
U.
S.,
but
is
not
technically
feasible
as
a
standalone
replacement
for
methyl
bromide.
No
Organic
production
In
certain
regions
of
the
U.
S.
some
organic
production
of
strawberries
occurs.
However,
as
a
stand
alone
replacement
for
methyl
bromide
it
is
not
technically
feasible
because
of
reduced
yields.
No
Resistant
cultivars
Resistant
cultivars
are
already
being
used
in
certain
regions
of
the
U.
S.,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
No
Page
27
Soil­
less
culture
Soil­
less
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
No
Substrates/
Plug
plants
Substrates/
plant
plugs
are
currently
being
used
but
are
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
Although
plug
plants
have
actually
proven
to
be
more
vigorous
than
bare
root
transplants
in
research
trials,
it
is
not
known
to
what
extent
pathogens
are
controlled
by
this
method.
Weed
control
would
still
be
an
issue.
And
adopting
this
use
would
also
require
major
retooling
of
the
industry.
No
Hand­
weeding
Hand
weeding
strawberries
is
not
a
desirable
practice
for
controlling
nutsedge.
Sedges
reproduce
through
below­
ground
tubers
or
nutlets.
When
a
sedge
plant
is
removed
by
hand
the
10
to
30
tubers,
which
grow
2
to
30
cm
(
1
to
12
inches)
below
ground,
will
rapidly
produce
new
plants.
Therefore,
had
weeding
can
lead
to
a
rapid
10­
to
30­
fold
increase
in
weeds.
In
addition,
those
sedges
that
germinate
under
the
plastic
mulch
cannot
be
removed
by
hand
without
damaging
the
plastic
and
reducing
its
effectiveness
in
excluding
weeds,
insects,
and
pathogens.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
Dichloropropene/
Chloropicrin
This
combination
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances
where
weed
pressures
are
low.
Together
they
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
an
herbicide
partner
to
control
weeds
such
as
nutsedge.
Regulatory
restrictions
for
each
of
the
chemicals
may
further
limit
their
use.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.

1,3­
Dichloropropene/
Chloropicrin
and
Metam
sodium
These
combinations
also
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
(
or
hand
weeding)
to
control.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

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

EASTERN
US
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
Metam
sodium
This
potential
alternative
has
an
extended
time
between
application
and
crop
planting
(
compared
to
methyl
bromide)
and
is
not
very
effective
on
nutsedge.
It
also
can
be
inconsistent
for
disease
control.
chloropicrin
The
alternative
does
not
give
effective
control
of
nutsedge.
It
also
produces
objectionable
odors
(
a
serious
issue
in
urban
fringe
areas
where
strawberries
are
grown.)
Insufficient
root
knot
nematode
control.
1,3­
D
The
alternative
does
not
give
effective
control
of
nutsedge.
Excessive
PPE
requirements,
and
set
or
buffer
space
requirements.
Page
28
1,3­
D,
chloropicrin
The
alternative
does
not
give
effective
control
of
nutsedge.
Excessive
PPE
requirements,
and
set
or
buffer
space
requirements.
There
are
occasional
phytotoxicity
problems
associated
with
this
alternative.
1,3­
D,
chloropicrin,
metam
sodium
The
alternative
does
not
give
effective
control
of
nutsedge.
Excessive
PPE
requirements,
and
set
or
buffer
space
requirements.

Metam
sodium,
chloropicrin
The
alternative
does
not
give
effective
control
of
nutsedge.

Nematicides
None
registered
except
1,3­
D.

EASTERN
US
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES
EASTERN
US
 
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:

Basamid
Not
registered
for
use
in
U.
S.
Y
Unknown
Methyl
Iodide
Not
registered
for
use
in
U.
S.
Y
Unknown
Propargyl
bromide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
Sodium
azide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
EASTERN
US
­
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
See
California
region,
Section
16,
for
discussion
of
studies
of
relevant
alternatives.
EASTERN
US
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
Dichloropropene/
Chloropicrin
Weeds,
nematodes
and
diseases
1%
gain
to
14%
loss
14.4%
(
Shaw
and
Larson,
1999)
Chloropicrin/
Metam
sodium
Multiple
pests
6.6­
47%
27%
Locascio,
1999
Metam
sodium
Weeds,
nematodes
and
diseases
16%­
29.8%
29.8%
(
Shaw
and
Larson,
1999)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
14%
Page
29
EASTERN
US
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?

Iodomethane
plus
chloropicrin
is
the
clear
alternative.
It
is
actively
being
researched
with
promising
results
and,
if
registered,
would
be
a
viable
alternative
to
methyl
bromide.

EASTERN
US
­
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

For
chemical
alternatives,
see
above
in
section
17.
Otherwise,
no,
the
growth
habit
of
strawberries
(
producing
runners
which
take
root
in
the
soil)
does
not
lend
itself
to
technologies
such
as
soil­
less
systems,
plug
plants,
or
containerized
plants.

EASTERN
US
­
SUMMARY
OF
TECHNICAL
FEASIBILITY
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
found
in
the
Eastern
US.
MB
applications
in
strawberries
are
typically
made
using
67:
33
or,
where
feasible,
50:
50
mixtures
with
chloropicrin
under
plastic
mulch.
Related
dosage
rates
of
202
kg/
ha
are
below
the
threshold
in
the
MBTOC
2002
Report,
making
further
reduction
difficult
to
achieve
without
compromising
pest
management.

The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
strawberry
fruit
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
strawberry
fruit
production.
­
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
for
strawberry
fruit
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.
Page
30
FLORIDA
­
PART
B:
CROP
CHARACTERISTICS
AND
METHYL
BROMIDE
USE
FLORIDA
­
10.
KEY
DISEASES
AND
WEEDS
FOR
WHICH
METHYL
BROMIDE
IS
REQUESTED
AND
SPECIFIC
REASONS
FOR
THIS
REQUEST
FLORIDA,
FLORIDA
­
TABLE
10.1:
KEY
DISEASES
AND
WEEDS
AND
REASON
FOR
METHYL
BROMIDE
REQUEST
REGION
WHERE
METHYL
BROMIDE
USE
IS
REQUESTED
KEY
DISEASE(
S)
AND
WEED(
S)
TO
GENUS
AND,
IF
KNOWN,
TO
SPECIES
LEVEL
SPECIFIC
REASONS
WHY
METHYL
BROMIDE
NEEDED
Florida
Diseases:
Phytophthora,
Crown
Rot
(
P.
citricola,
P.
cactorum)

Florida
Nematodes:
Sting
(
Belonolaimus
longicaudatus)

Root­
knot
(
Meloidogyne
spp.)

Florida
Weeds:
Yellow
nutsedge
(
Cyperus
esculentus)

Purple
nutsedge
(
Cyperus
rotundus)

Carolina
Geranium
(
G.
carolinianum)

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

FLORIDA
­
11.
(
i)
CHARACTERISTICS
OF
CROPPING
SYSTEM
AND
CLIMATE
FLORIDA
­
TABLE
11.1:
CHARACTERISTICS
OF
CROPPING
SYSTEM
CHARACTERISTICS
FLORIDA
CROP
TYPE:
(
e.
g.
transplants,
bulbs,
trees
or
cuttings)
Transplants
ANNUAL
OR
PERENNIAL
CROP:
(#
of
years
between
replanting)
Cultured
as
annual.

TYPICAL
CROP
ROTATION
(
if
any)
AND
USE
OF
METHYL
BROMIDE
FOR
OTHER
CROPS
IN
THE
ROTATION:
(
if
any)
Cucurbits
and
peppers
SOIL
TYPES:
(
Sand,
loam,
clay,
etc.)
Sandy
to
loam
soil
FREQUENCY
OF
METHYL
BROMIDE
FUMIGATION:
(
e.
g.
every
two
years)
Annually
OTHER
RELEVANT
FACTORS:
None
Identified
Page
31
FLORIDA
­
TABLE
11.2
CHARACTERISTICS
OF
CLIMATE
AND
CROP
SCHEDULE
MAR
APR
MAY
JUN
JUL
AUG
SEPT
OCT
NOV
DEC
JAN
FEB
CLIMATIC
ZONE
(
e.
g.
temperate,
tropical)
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
9a­
10b
RAINFALL
(
mm)
65.5
50
72.6
134.1
175.8
193.3
152.7
65
42.7
158.8
62
66.8
OUTSIDE
TEMP.
(
°
C)
19.4
22.1
25.3
27.6
28.2
28.2
27.3
24.1
19.2
17.3
16
16.9
FUMIGATION
SCHEDULE
X
X
PLANTING
SCHEDULE
X
X
FLORIDA
 
11.
(
ii)
INDICATE
IF
ANY
OF
THE
ABOVE
CHARACTERISTICS
IN
11.
(
i)
PREVENT
THE
UPTAKE
OF
ANY
RELEVANT
ALTERNATIVES?

To
our
knowledge
none
of
these
characteristics
would
prevent
the
adoption
of
relevant
alternatives.
Page
32
FLORIDA
­
12.
HISTORIC
PATTERN
OF
USE
OF
METHYL
BROMIDE,
AND/
OR
MIXTURES
CONTAINING
METHYL
BROMIDE,
FOR
WHICH
AN
EXEMPTION
IS
REQUESTED
FLORIDA
­
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)
2469
2509
2509
2509
2630
2792
RATIO
OF
FLAT
FUMIGATION
METHYL
BROMIDE
USE
TO
STRIP/
BED
USE
IF
STRIP
TREATMENT
IS
USED
All
strip
AMOUNT
OF
METHYL
BROMIDE
ACTIVE
INGREDIENT
USED
(
total
kg)
542,315
551,205
464,025
471,282
486,477
516,414
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)
Chiseled
into
soil
30­
45
cm
below
surface
of
bed
APPLICATION
RATE
OF
FORMULATIONS
IN
kg/
ha*
220
220
185
188
185
185
ACTUAL
DOSAGE
RATE
OF
FORMULATIONS
(
g/
m2)*
15
15
13
13
13
13
*
For
Flat
Fumigation
treatment
application
rate
and
dosage
rate
may
be
the
same.
Page
33
FLORIDA
­
PART
C:
TECHNICAL
VALIDATION
FLORIDA
­
13.
REASON
FOR
ALTERNATIVES
NOT
BEING
FEASIBLE
FLORIDA
 
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
Dichloropropene
(
1,3­
D,
Telone)
Used
alone,
1,3­
Dichloropropene
does
not
adequately
control
diseases
and
weeds.
Buffer
zones
of
100
feet
are
too
constraining
for
small
fields.
Required
Protective
equipment
(
protective
suits)
pose
a
health
risk
to
workers
in
hot
and
humid
weather.
Long
pre­
planting
intervals
affect
cultivar
selection,
Integrated
Pest
Management
practices,
timing
of
harvest,
marketing
window
options,
land
leasing
decisions
and
crop
rotation
schedules
No
Basamid
Basamid
is
not
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Chloropicrin
Chloropicrin
alone
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control
No
Metam
sodium
Metam­
sodium
alone
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
No
Metam
sodium,
chloropicrin
Metam­
sodium
with
chloropicrin
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
No
Methyl
iodide
Promising,
but
it
is
not
currently
registered
in
the
U.
S.
for
strawberry
fruit
production.
No
Nematicides
Addressed
individually
(
e.
g.,
1,3­
D).
No
Ozone
Ozone
is
not
technically
feasible
alone
because
it
doesn't
control
diseases
and
weeds.
No
NON
CHEMICAL
ALTERNATIVES
Biofumigation
Biofumigation
is
not
technically
feasible
because
of
the
quantity
of
Brassica
crop
that
would
be
needed
to
control
target
pests
in
strawberries
(
approximately
three
hectares
would
be
required
for
every
hectare
of
strawberry
production).
Incorporation
of
Brassica
at
these
levels
is
likely
to
have
allelopathic
effects
on
the
target
crop.
In
addition,
filed
trials
on
tomatoes
grown
in
cabbage
residue
produced
inconsistent
and
inadequate
efficacy,
and
poor
yield
in
two
years
out
of
three.
No
Page
34
Solarization
Solarization,
when
used
alone
for
pre­
plant
fumigation,
is
not
technically
feasible
because
it
does
not
provide
adequate
control
of
a
wide
range
of
soil­
borne
diseases
and
pests.
This
process
is
highly
weather
dependent
and
works
best
in
combination
with
IPM
for
control
of
pests
and
diseases.
However,
solarization
only
suppresses
nutsedge
at
best.
(
Chase
et.
al.
1998.
Egley,
1983)
No
Steam
Steam,
when
used
alone
for
pre­
plant
fumigation,
is
not
operationally
practical
due
to
low
application
speeds
and
high
energy
requirements
(
1­
3
weeks
to
treat
one
hectare).
In
addition
results
from
field
experiments
steam
treatment
have
been
erratic.
No
Biological
Control
Biological
control
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide
because
it
does
not
provide
adequate
control
of
target
pests.
No
Cover
Crops
and
Mulching
Although
already
in
use
as
part
of
an
Integrated
Pest
Management
Program,
cover
crops
and
mulching
alone
do
not
provide
adequate
control
of
the
target
pests.
No
Crop
rotation/
fallow
Crop
rotation
is
already
being
used
in
many
strawberry
production
areas,
but
does
not
adequately
control
the
target
pests.
No
Flooding
and
water
management
Flooding
and
water
management
are
not
feasible
due
to
limited
water
resources,
uneven
topography
in
Florida,
and
in
the
eastern
states
by
sandy
soil
types
that
would
not
retain
the
flood
for
an
adequate
time
to
control
the
pests.
No
General
IPM
General
IPM
is
already
practiced
in
strawberry
production,
but
it
is
not
technically
feasible
as
a
stand
alone
replacement
for
methyl
bromide
since
even
a
combination
of
IPM
methods
do
not
offer
adequate
pest
control
by
itself.
No
Grafting/
Resistant
rootstock/
plant
breeding
Grafting/
resistant
rootstock/
plant
breeding
is
not
being
used
and
it
is
not
technically
feasible
because
grafting
is
not
possible
given
the
physical
characteristics
of
strawberry
plants.
Breeding
for
resistance
to
pathogens
is
valuable
as
a
long­
term
endeavor
and
the
U.
S.
continues
work
in
this
area.
At
this
point
in
time,
plant
breeding
has
not
resulted
in
a
cultivar
that
is
sufficiently
resistant
to
the
major
target
pests.
No
Organic
Amendments/
Compost
Organic
Amendments/
Compost
is
already
being
used
in
certain
regions
of
the
U.
S.,
but
is
not
technically
feasible
as
a
standalone
replacement
for
methyl
bromide.
No
Organic
production
In
certain
regions
of
the
U.
S.
some
organic
production
of
strawberries
occurs.
However,
as
a
stand
alone
replacement
for
methyl
bromide
it
is
not
technically
feasible
because
of
reduced
yields.
No
Resistant
cultivars
Resistant
cultivars
are
already
being
used
in
certain
regions
of
the
U.
S.,
but
it
is
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
No
Soil­
less
culture
Soil­
less
culture
is
not
being
used
and
it
is
not
technically
feasible
because
it
requires
a
complete
transformation
of
the
U.
S.
production
system.
There
are
high
costs
associated
with
this
as
compared
to
current
production
practices.
No
Page
35
Substrates/
Plug
plants
Substrates/
plant
plugs
are
currently
being
used
but
are
not
technically
feasible
as
a
stand­
alone
replacement
for
methyl
bromide.
Although
plug
plants
have
actually
proven
to
be
more
vigorous
than
bare
root
transplants
in
research
trials,
it
is
not
known
to
what
extent
pathogens
are
controlled
by
this
method.
Weed
control
would
still
be
an
issue.
Adopting
this
use
would
also
require
major
retooling
of
the
industry.
No
Hand­
weeding
Hand
weeding
strawberries
is
not
a
desirable
practice
for
controlling
nutsedge.
Sedges
reproduce
through
below­
ground
tubers
or
nutlets.
When
a
sedge
plant
is
removed
by
hand
the
10
to
30
tubers,
which
grow
2
to
30
cm
(
1
to
12
inches)
below
ground,
will
rapidly
produce
new
plants.
Therefore,
had
weeding
can
lead
to
a
rapid
10­
to
30­
fold
increase
in
weeds.
In
addition,
those
sedges
that
germinate
under
the
plastic
mulch
cannot
be
removed
by
hand
without
damaging
the
plastic
and
reducing
its
effectiveness
in
excluding
weeds,
insects,
and
pathogens.
No
COMBINATIONS
OF
ALTERNATIVES
1,3­
Dichloropropene/
Chloropicrin
This
combination
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances
where
weed
pressure
is
low.
Together
they
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds
such
as
nutsedge.
Regulatory
restrictions
for
each
of
the
chemicals
may
further
limit
their
use.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.

1,3­
Dichloropropene/
Chloropicrin
and
Metam
sodium
This
combination
also
provides
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
(
or
hand
weeding)
to
control.
No,
in
areas
with
moderate
to
severe
pest
infestation
and
if
not
allowed
by
local
regulations.
*
Regulatory
reasons
include
local
restrictions
(
e.
g.
occupational
health
and
safety,
local
environmental
regulations)
and
lack
of
registration.

FLORIDA
­
14.
LIST
AND
DISCUSS
WHY
REGISTERED
(
and
Potential)
PESTICIDES
AND
HERBICIDES
ARE
CONSIDERED
NOT
EFFECTIVE
AS
TECHNICAL
ALTERNATIVES
TO
METHYL
BROMIDE
FLORIDA
 
TABLE
14.1:
TECHNICALLY
INFEASIBLE
ALTERNATIVES
DISCUSSION
NAME
OF
ALTERNATIVE
DISCUSSION
1,3­
Dichloropropene
Drip
application
of
1,3­
D
in
Florida
are
less
expensive
and
require
smaller
buffer
zones
than
broadcast
applications,
making
it
the
preferred
application
method
for
this
alternative
(
drip,
90%;
broadcast,
10%).
However,
when
1,3­
D
fumigations
by
drip
are
used
other
production
cots
are
significantly
higher
due
to
the
need
for
herbicide
applications
(
i.
e.
metam
sodium)
and
hand
weeding
operations.
Recent
studies
in
California
found
that
fruit
production
costs
were
20­
212%
higher
than
with
methyl
bromide/
chloropicrin
(
Goldhue),
with
the
smaller
cost
estimates
coming
from
VIF
mulch
treatments
that
are
not
currently
usable
due
to
technical
issues.

Chloropicrin
Chloropicrin
alone
is
not
a
technically
feasible
alternative
because
it
provides
poor
nematode
and
weed
control,
although
it
provides
good
disease
control
Page
36
Metam
sodium
Metam­
sodium
alone
is
not
a
technically
feasible
alternative
because
it
provides
unpredictable
disease,
nematode,
and
weed
control.
Metam
sodium
suffers
from
erratic
efficacy
most
likely
due
to
irregular
distribution
of
the
product
through
soil.
Metam
sodium
if
not
technically
feasible
in
California
because
it
has
limited
activity
against
soilborne
pathogens
in
strawberry
fields.

Sodium
azide
Does
not
sterilize
ground.
Yields
equal
to
untreated.

1,3D/
chloropicrin
This
combination
is
considered
technically
feasible
as
an
alternative
in
certain
circumstances
where
weed
pressure
is
low.
Together
they
provide
good
nematicidal
and
fungicidal
capabilities,
but
would
still
require
a
herbicide
partner
to
control
weeds
such
as
nutsedge.
Regulatory
restrictions
for
each
of
the
chemicals
may
further
limit
their
use.
Not
economically
feasible.

FLORIDA
­
15.
LIST
PRESENT
(
and
Possible
Future)
REGISTRATION
STATUS
OF
ANY
CURRENT
AND
POTENTIAL
ALTERNATIVES:

FLORIDA
 
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:

Basamid
Not
registered
for
use
in
U.
S.
Y
Unknown
Methyl
Iodide
Not
registered
for
use
in
U.
S.
Y
Unknown
Propargyl
bromide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
Sodium
azide
Registration
in
US
has
not
yet
been
requested.
N
Unknown
FLORIDA
­
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
See
California
Region,
Section
16,
for
discussion
of
studies
of
relevant
alternatives.
FLORIDA
 
TABLE
C.
1:
ALTERNATIVES
YIELD
LOSS
DATA
SUMMARY
ALTERNATIVE
LIST
TYPE
OF
PEST
RANGE
OF
YIELD
LOSS
BEST
ESTIMATE
OF
YIELD
LOSS
1,3­
Dichloropropene/
Chloropicrin
Weeds,
nematodes
and
diseases
1%
gain
to
14%
loss
14.4%
(
Shaw
and
Larson,
1999)
Chloropicrin/
Metam
sodium
Multiple
pests
6.6­
47%
27%
Locascio,
1999
Metam
sodium
Weeds,
nematodes
and
diseases
16%­
29.8%
29.8%
(
Shaw
and
Larson,
1999)

OVERALL
LOSS
ESTIMATE
FOR
ALL
ALTERNATIVES
TO
PESTS
25%
Page
37
FLORIDA
­
17.
ARE
THERE
ANY
OTHER
POTENTIAL
ALTERNATIVES
UNDER
DEVELOPMENT
WHICH
ARE
BEING
CONSIDERED
TO
REPLACE
METHYL
BROMIDE?
Previous
research
evaluating
various
chemical
alternatives
to
methyl
bromide
suggests
that
the
mixture
of
1,3­
dichloropropene
(
Telone)
with
chloropicrin,
coupled
with
separate
,
but
complementary
chloropicrin
and
herbicide
treatments
for
weed
control,
has
a
potential
an
IPM
alternative
to
methyl
bromide
to
manage
soil­
borne
pests
and
sustain
crop
yields.
There
are
no
currently
registered
herbicides
for
the
control
of
sedges
in
strawberries.

Current
research
priorities
include
the
following:
­
Continue
to
identify
and
further
define
optimum
conditions
and
procedures
required
to
maximize
performance
of
Telone,
chloropicrin,
and
other
fumigant
and
herbicide
products.
­
Develop
a
more
comprehensive
understanding
of
the
possible
biologic
and
economic
impacts
of
implementing
the
proposed
alternatives
to
methyl
bromide
in
commercial
Florida
agriculture.
­
Continue
to
identify
and
resolve
implementation
constraints
to
methyl
bromide
alternatives
(
i.
e.,
high
costs,
lower
efficacy,
increased
production
or
environmental
risks,
regulatory
constraints,
and/
or
reduced
farm
profitability)
that
negatively
impact
future
widespread
adoption
of
such
alternatives.
­
Continue
to
develop
effective
multi­
crop,
IPM
based
systems,
including
characterization
of
impacts
and
residual
effects
within
current
double
cropping
systems.
­
Maintain
technology
transfer
projects
to
educate
growers
to
learn
how
to
effectively
choose,
apply,
and
incorporate
alternative
chemical
so
as
to
maximize
pest
control,
crop
response
and
to
avoid
problems
of
plant
phytotoxicity
and
crop
loss.
­
Continue
to
evaluate
mulch
technologies
and
procedures
to
minimize
emissions
of
methyl
bromide
and
other
soil
fumigant
compounds
from
soil.
­
Continue
to
identify
and
evaluate
emerging
nonchemical
alternatives.

FLORIDA
 
18.
ARE
THERE
TECHNOLOGIES
BEING
USED
TO
PRODUCE
THE
CROP
WHICH
AVOID
THE
NEED
FOR
METHYL
BROMIDE?

For
chemical
alternatives,
see
above
in
section
17.
Otherwise,
no,
the
growth
habit
of
strawberries
(
producing
runners
which
take
root
in
the
soil)
does
not
lend
itself
to
technologies
such
as
soil­
less
systems,
plug
plants,
or
containerized
plants.

FLORIDA
SUMMARY
OF
TECHNICAL
FEASIBILITY
Karst
topography,
as
well
as
biological
considerations
such
as
heavy
pest
pressure
(
especially
with
nutsedge),
increasing
nematode
damage
over
time
from
not
using
methyl
bromide,
phytotoxicity,
variation
in
yields,
time
lost
due
to
delays
in
planting,
and
missing
early
harvest
with
high
strawberry
prices
contribute
to
the
technical
infeasibility
of
replacing
methyl
bromide.
Page
38
The
US
nomination
is
only
for
those
areas
where
the
alternatives
are
not
suitable.
In
US
strawberry
fruit
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
strawberry
fruit
production.
­
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
for
strawberry
fruit
where
the
key
pest
pressure
is
moderate
to
high
such
as
nutsedge
in
the
Southeastern
US.
­
regulatory
constraints:
e.
g.,
telone
use
is
limited
due
to
the
presence
of
karst
geology.
­
delay
in
planting
and
harvesting:
e.
g.,
the
plant­
back
interval
for
telone+
chloropicrin
is
two
weeks
longer
than
methyl
bromide+
chloropicrin.
Delays
in
planting
and
harvesting
result
in
users
missing
key
market
windows,
and
adversely
affect
revenues
through
lower
prices.
­
unsuitable
topography:
e.
g.,
alternatives
that
must
be
applied
with
drip
irrigation
may
not
be
suitable
in
areas
with
rolling
or
sloped
topography
due
to
uneven
distribution
of
the
fumigant.

PART
D:
EMISSION
CONTROL
19.
TECHNIQUES
THAT
HAVE
AND
WILL
BE
USED
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
IN
THE
PARTICULAR
USE
TABLE
19.1:
TECHNIQUES
TO
MINIMIZE
METHYL
BROMIDE
USE
AND
EMISSIONS
Page
39
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?
Although
research
appears
to
be
promising,
early
adoption
has
come
upon
serious
logistical
and
practical
limitations
such
as:
1.
Unreliable
supplies
of
the
VIF
film
since
no
US
source
of
VIF
film
exists
(
only
European
sources);
2.
US
requires
season
long
UV
protection
in
film
vs.
Europe's
2
weeks;
and
3.
Difficulty
applying
VIF
under
US
production
systems
without
damaging
film.
Between
1997
and
2000
the
US
has
reduced
the
use
of
methyl
bromide
in
strawberries
grown
for
fruit
production
by
24%.
Reduction
of
MB/
Pic
in
mixtures,
i.
e.
changes
from
67:
33
to
57:
43
 
this
may
have
some
promise,
but
nutsedge
is
a
primary
pest
on
40%
of
the
land
in
Eastern
region
(
890
ha),
and
below
30.2
g/
m2
a.
i.
dosage,
nutsedge
cannot
be
controlled
successfully.
The
US
anticipates
that
the
decreasing
supply
of
methyl
bromide
will
motivate
growers
to
try
less
frequent
applications.

WHAT
FURTHER
USE/
EMISSION
REDUCTION
STEPS
WILL
BE
TAKEN
FOR
THE
METHYL
BROMIDE
USED
FOR
CRITICAL
USES?
Investigations
are
going
to
be
initiated
in
2004­
2005
with
VIF
in
Eastern
region
(
North
Carolina)
None
identified
None
identified
None
identified
OTHER
MEASURES
None
identified
None
identified
None
identified
None
identified
20.
IF
METHYL
BROMIDE
EMISSION
REDUCTION
TECHNIQUES
ARE
NOT
BEING
USED
OR
ARE
NOT
PLANNED
FOR
THE
CIRCUMSTANCES
OF
THE
NOMINATION,
STATE
REASONS
1.
Chloropicrin
(
drip
AND
shank)
shows
great
promise
in
Eastern
Region,
but
economic
feasibility
is
a
concern
with
Pic.
Multiple
Field
studies
and
economic
evaluation
have
been
conducted
by
Dr.
Frank
Louws
(
frank_
louws@
ncsu.
edu)
and
Lisa
Ferguson
(
lisa_
ferguson@
ncsu.
edu)
Also,
the
USDA­
Methyl
Bromide
Alternatives
Research/
Extension
interdisciplinary
working
group
at
NCSU
(
contact
Lisa
Ferguson)
is
preparing
an
important
summary
of
multiple
years
of
alternatives
research
for
several
Eastern
Region
States
and
a
manuscript
is
now
being
written
by
Page
40
Dr.
Charles
Safley,
NCSU,
Economist,
"
O.
Sydorovych,
C.
D.
Safley,
L.
M.
Ferguson,
F.
J.
Louws,
G.
E.
Fernandez,
and
E.
B.
Poling,
Economic
Evaluation
of
the
Methyl
Bromide
Alternatives
for
the
Production
of
Strawberries
in
the
Southeastern
United
States
2.
VIF
OR
HIGH
BARRIER
FILMS
 
E.
B.
POLING
is
initiating
work
in
late
summer
2004
with
harvest
in
Spring
2005
 
reports
available
in
summer
2005.
3.
Telone­
C35/
InLine
 
extensive
work
has
been
conducted
with
InLine
by
our
interdisciplinary
group
(
see
Word
Document
attachment),
and
yields
are
comparable
to
MB,
but
important
limitations
with
use
of
1,3­
D
+
Pic
in
the
Eastern
Region
have
already
been
presented
in
the
Narratives
for
2002
and
2003.
4.
Iodomethane
is
an
excellent
replacement
for
MB
(
it
has
been
tested
extensively
by
NCSU
researchers),
and
if
there
is
EPA
registration
in
late
2004,
there
could
be
widespread
industry
adoption
by
the
2005­
2006
season.
Two
years
of
unpublished
studies
at
NCSU
(
2002­
2003,
2003­
2004)
are
indicating
potential
of
using
relatively
low
application
rates
with
Iodomethane
­­
the
cost
savings
associated
with
these
lower
rates
will
potentially
speed
the
adoption
of
Iodomethane
in
the
Eastern
Region.
Studies
in
2004­
2005
will
be
initiated
with
tank
mixes
of
Methyl
Bromide
+
Iodomethane,
to
further
reduce
MB
needs
in
2005­
2006.

PART
E:
ECONOMIC
ASSESSMENT
Reader
please
note
that
in
this
study
net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
for
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
is
smaller
than
the
net
revenue
measured
in
this
study,
often
substantially
so.
We
did
not
include
fixed
costs
because
they
are
difficult
to
measure
and
verify.

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
ALTERNATIVE
YIELD*
COST
IN
YEAR
1
(
US$/
ha)
COST
IN
YEAR
2
(
US$/
ha)
COST
IN
YEAR
3
(
US$/
ha)
Methyl
Bromide
100
1,248
1,248
1,248
Chloropicrin+
metam
sodium
73
964
964
964
1,3­
d
chloropicrin
86
1,416
1,416
1,416
Metam
Sodium
70
849
849
849
*
As
percentage
of
typical
or
3­
year
average
yield,
compared
to
methyl
bromide.
Page
41
22.
GROSS
AND
NET
REVENUE
TABLE
22.1:
YEAR
1
GROSS
AND
NET
REVENUE
YEAR
1
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
TABLE
22.2:
YEAR
2
GROSS
AND
NET
REVENUE
YEAR
2
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
TABLE
22.3:
YEAR
3
GROSS
AND
NET
REVENUE
YEAR
3
ALTERNATIVES
(
as
shown
in
question
21)
GROSS
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
NET
REVENUE
FOR
LAST
REPORTED
YEAR
(
US$/
ha)
Methyl
Bromide
$
29,818
$
5484
Chloropicrin+
metam
sodium
$
20,679
$­
1,716
1,3­
d
chloropicrin
$
24,362
$
702
Metam
Sodium
$
19,829
$­
2,396
Page
42
MEASURES
OF
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
­
TABLE
E.
1:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
CALIFORNIA
METHYL
BROMIDE
ALTERNATIVE
PIC+
MS
ALTERNATIVE
1,3­
D+
PIC
ALTERNATIVE
MS
YIELD
LOSS
(%)
0
27%
14%
30%

YIELD
PER
HECTARE
(
FRESH)
48,438
35,359
41,639
33,906
*
PRICE
PER
UNIT
(
US$)
$
1.71
$
1.62
$
1.62
$
1.62
=
GROSS
REVENUE
PER
HECTARE
(
US$)
$
73,683
51,099
60,173
48,999
­
OPERATING
COSTS
PER
HECTARE
(
US$)
$
60,131
55,339
58,438
54,921
=
NET
REVENUE
PER
HECTARE
(
US$)
$
13,552
(
4,240)
(
1,735)
(
5,922)

LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
17,792
11,817
19,474
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
88.19
58.57
96.52
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
24%
16%
26%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
131%
87%
144%

FLORIDA
­
TABLE
E.
2:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
FLORIDA
METHYL
BROMIDE
ALTERNATIVE
1,3­
D+
PIC
YIELD
LOSS
(%)
0
25
YIELD
PER
HECTARE
3,138
2,353
*
PRICE
PER
UNIT
(
US$)
23.10
23.10
=
GROSS
REVENUE
PER
HECTARE
(
US$)
72,511
54,360
­
OPERATING
COSTS
PER
HECTARE
(
US$)
44,459
40,795
=
NET
REVENUE
PER
HECTARE
(
US$)
28,012
13,565
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
14,447
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
77.72
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
20%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
52%

EASTERN
UNITED
STATES
­
TABLE
E.
3:
ECONOMIC
IMPACTS
OF
METHYL
BROMIDE
ALTERNATIVES
EASTERN
UNITED
STATES
METHYL
BROMIDE
ALTERNATIVE
PIC+
MS
ALTERNATIVE
1,3­
D+
PIC
ALTERNATIVE
MS
YIELD
LOSS
(%)
0%
27%
14%
30%
Page
43
YIELD
PER
HECTARE
22,417
16,364
19,270
15,692
*
PRICE
PER
UNIT
(
US$)
2.59
2.59
2.59
2.59
=
GROSS
REVENUE
PER
HECTARE
(
US$)
51,892
37,881
44,608
36,324
­
OPERATING
COSTS
PER
HECTARE
(
US$)
29,623
30,555
31,658
30,270
=
NET
REVENUE
PER
HECTARE
(
US$)
22,269
7,327
12,950
6,054
LOSS
MEASURES
1.
LOSS
PER
HECTARE
(
US$)
$
0
14,942
9,319
16,215
2.
LOSS
PER
KILOGRAM
OF
METHYL
BROMIDE
(
US$)
$
0
99.49
62.05
107.96
3.
LOSS
AS
A
PERCENTAGE
OF
GROSS
REVENUE
(%)
0%
29%
18%
31%

4.
LOSS
AS
A
PERCENTAGE
OF
NET
REVENUE
(%)
0%
67%
42%
73%

SUMMARY
OF
ECONOMIC
FEASIBILITY
The
economic
analysis
evaluated
methyl
bromide
alternative
control
scenarios
for
strawberry
production
of
fruit
in
Southeastern
states,
Florida,
and
California
by
comparing
the
economic
outcomes
of
methyl
bromide
oriented
production
systems
to
those
using
alternatives.

The
economic
factors
that
most
influence
the
feasibility
of
methyl
bromide
alternatives
for
fresh
market
strawberry
production
are:
(
1)
yield
losses,
referring
to
reductions
in
the
quantity
produced,
(
2)
increased
production
costs,
which
may
be
due
to
the
higher­
cost
of
using
an
alternative,
additional
pest
control
requirements,
and/
or
resulting
shifts
in
other
production
or
harvesting
practices,
and
(
3)
missed
market
windows
due
to
plant
back
time
restrictions,
which
also
affect
the
quantity
and
price
received
for
the
goods.

The
economic
reviewers
analyzed
crop
budgets
for
pre­
plant
sectors
to
determine
the
likely
economic
impact
if
methyl
bromide
were
unavailable.
Various
measures
were
used
to
quantify
the
impacts,
including
the
following:

(
1)
Loss
per
Hectare.
For
crops,
this
measure
is
closely
tied
to
income.
It
is
relatively
easy
to
measure,
but
may
be
difficult
to
interpret
in
isolation.

(
2)
Loss
per
Kilogram
of
Methyl
Bromide.
This
measure
indicates
the
nominal
marginal
value
of
methyl
bromide
to
crop
production.

(
3)
Loss
as
a
Percentage
of
Gross
Revenue.
This
measure
has
the
advantage
that
gross
revenues
are
usually
easy
to
measure,
at
least
over
some
unit,
e.
g.,
a
hectare
of
land
or
a
storage
operation.
However,
high
value
commodities
or
crops
may
provide
high
revenues
but
may
also
entail
high
costs.
Losses
of
even
a
small
percentage
of
gross
revenues
could
have
important
impacts
on
the
profitability
of
the
activity.

(
4)
Loss
as
a
Percentage
of
Net
Operating
Revenue.
We
define
net
cash
revenues
as
gross
Page
44
revenues
minus
operating
costs.
This
is
a
very
good
indicator
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
owners
or
operators
of
an
enterprise.
However,
operating
costs
can
often
be
difficult
to
measure
and
verify.

(
5)
Operating
Profit
Margin.
We
define
operating
profit
margin
to
be
net
operating
revenue
divided
by
gross
revenue
per
hectare.
This
measure
would
provide
the
best
indication
of
the
total
impact
of
the
loss
of
methyl
bromide
to
an
enterprise.
Again,
operating
costs
may
be
difficult
to
measure
and
fixed
costs
even
more
difficult,
therefore
fixed
costs
were
not
included
in
the
analysis.

These
measures
represent
different
ways
to
assess
the
economic
feasibility
of
methyl
bromide
alternatives
for
methyl
bromide
users,
who
are
tomato
producers
in
this
case.
Because
producers
(
suppliers)
represent
an
integral
part
of
any
definition
of
a
market,
we
interpret
the
threshold
of
significant
market
disruption
to
be
met
if
there
is
a
significant
impact
on
commodity
suppliers
using
methyl
bromide.
The
economic
measures
provide
the
basis
for
making
that
determination.

Several
methodological
approaches
will
help
interpret
the
findings.
Economic
estimates
were
first
calculated
in
pounds
and
acres
and
then
converted
to
kilograms
and
hectares.
Costs
for
alternatives
are
based
on
market
prices
for
the
control
products
multiplied
by
the
number
of
pounds
of
active
ingredient
that
would
be
applied.
Baseline
costs
were
based
on
the
average
number
of
annual
applications
necessary
to
treat
strawberries
with
methyl
bromide.

Net
revenue
is
calculated
as
gross
revenue
minus
operating
costs.
This
is
a
good
measure
as
to
the
direct
losses
of
income
that
may
be
suffered
by
the
users.
It
should
be
noted
that
net
revenue
does
not
represent
net
income
to
the
users.
Net
income,
which
indicates
profitability
of
an
operation
of
an
enterprise,
is
gross
revenue
minus
the
sum
of
operating
and
fixed
costs.
Net
income
should
be
smaller
than
the
net
revenue
measured
in
this
study.
Fixed
costs
were
not
included
because
they
are
difficult
to
measure
and
verify.

Loss
per
hectare
measures
the
value
of
methyl
bromide
based
on
changes
in
operating
costs
and/
or
changes
in
yield.
Loss
expressed
as
a
percentage
of
the
gross
revenue
is
based
on
the
ratio
of
the
revenue
loss
to
the
gross
revenue.
Likewise
for
the
loss
as
a
percentage
of
net
revenue.
The
profit
margin
percentage
is
the
ratio
of
net
revenue
to
gross
revenue
per
hectare.
The
values
to
estimate
gross
revenue
and
the
operating
costs
for
each
alternative
were
derived
for
three
alternative
fumigation
scenarios
for
the
Eastern
States
and
California,
relative
to
methyl
bromide:
1)
metam
sodium
+
chloropicrin;
2)
1,3­
d
+
chloropicrin;
and
3)
metam
sodium.
Yield
loss
estimates
were
based
on
data
from
the
CUE's
and
EPA
data,
as
well
as
expert
opinion.

For
Florida,
three
scenarios
were
compared
to
the
methyl
bromide
baseline:
1)
1,3­
d
plus
chloropicrin;
2)
Iodomethane;
and
3)
Iodomethane
+
chloropicrin.
Because
Iodomethane
is
not
registered,
it
is
not
considered
a
feasible
alternative
but
the
analysis
is
provided
for
comparative
purposes.
Page
45
Florida
In
2002,
Florida
had
2,792
hectares
(
6,900
acres)
or
100%
of
harvested
area
treated
with
an
average
of
75
kilograms
(
166
pounds)
of
methyl
bromide
per
hectare
(
acre).
The
closest
chemical
alternative
to
methyl
bromide
is
1,3­
d
plus
chloropricrin
(
as
Telone
C­
35).
However,
US­
EPA
estimates
that
approximately
40%
of
Florida's
strawberry
growing
areas
overlay
Karst
geology,
which
prohibits
the
use
of
1,3­
d
because
of
the
potential
for
groundwater
contamination.
The
use
of
1,3­
d
also
requires
a
100­
foot
buffer
around
inhabited
structures.
This
would
reduce
the
strawberry
producing
acreage
by
about
10%.
Nematodes
and
nutsedge
are
key
pests
in
Florida
strawberry
controlled
with
methyl
bromide.
Chloropicrin
is
not
as
effective
in
controlling
weeds
as
methyl
bromide.
Using
chloropicrin
adds
to
production
costs
through
increased
weeding
and
labor
costs
(
to
search
for
and
pick
the
fruit).

The
least­
loss
scenario
for
Florida
in
the
absence
of
methyl
bromide
is
for
growers
to
use
1,3­
d
plus
chloropicrin.
Under
that
scenario,
yield
loss
would
be
approximately
27%,
not
including
increases
in
labor
costs
for
hand
weeding,
drip
irrigation
costs,
or
changes
in
market
prices
due
to
later
harvests
missing
early
market
price­
premiums.
A
delay
in
planting
occurs
due
to
the
longer
plant­
back
interval
for
1,3­
d,
which
means
delayed
harvesting.
According
to
U.
S.
Department
of
Agriculture
data,
market
prices
for
Florida
strawberries
decline
approximately
18%
between
December
and
January.
Yield
and
price
impacts
together
make
up
impacts
on
gross
revenues.

Under
Alternative
1
(
1,3­
d
plus
chloropicrin),
the
yield
loss
was
estimated
to
be
25%
with
operating
costs
in
US
dollars
per
hectare
of
$
40,795.
The
estimated
net
revenue
was
$
13,565
per
hectare.
The
estimated
loss
per
hectare
is
estimated
to
be
$
14.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
77.72
per
kilogram.
If
growers
miss
the
December
market
window,
a
loss
of
approximately
one
month's
revenue
would
reduce
grower
gross
revenues
by
about
22%
in
addition
to
the
yield
loss
of
25%.

The
following
alternatives
are
presented
for
comparative
purposes
only
as
the
products
are
not
registered.
Under
alternative
2
(
Iodomethane),
the
yield
loss
was
estimated
to
be
14%.
Operating
costs
in
US
dollars
per
hectare
are
$
40,795.
The
estimated
net
revenue
was
$
21,538
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
6,474.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
34.83
per
kilogram.

Under
alternative
3
(
Iodomethane
+
chloropicrin),
the
yield
loss
was
estimated
to
be
30%.
Operating
costs
in
US
dollars
per
hectare
are
$
40,795.
The
estimated
net
revenue
was
$
9,963
per
hectare.
The
loss
per
hectare
is
estimated
to
be
$
18,049.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
97.11
per
kilogram.

California
In
California,
1,3­
d
plus
chloropicrin
would
also
be
the
primary
replacement
for
methyl
bromide.
California
restricts
total
use
of
1,3­
d,
at
the
local
level
(
township
cap).
Approximately
63
percent
of
California's
strawberry
acreage
is
fumigated
with
methyl
bromide,
and
31
percent
is
Page
46
fumigated
with
alternatives.
Approximately
15
percent
of
the
strawberry
acreage
is
on
hillsides
with
slopes
severe
enough
to
make
drip
irrigation
impractical.

Increased
production
preparation
time
would
delay
planting
in
the
Southern
Region
and
reduce
the
harvest
period
in
the
Northern
Region,
leading
to
decreases
in
the
prices
farmers
receive.
Ground
preparation
between
crops
takes
30
days
longer
using
1,3­
d
and
chloropicrin
because
of
the
time
required
to
prepare
drip
irrigation.
According
to
U.
S.
Department
of
Agriculture
data,
market
prices
for
strawberries
California
decline
5%
between
January
and
February.
If
using
the
alternatives
delays
the
harvest
period,
US­
EPA
estimates
there
will
be
a
market
price
decline
in
addition
to
a
yield
loss.
The
following
paragraphs
illustrate
the
estimated
losses
with
three
alternatives
for
California.

Alternative
1
(
chloropicrin+
metam
sodium),
yield
loss
was
estimated
to
be
27%,
and
gross
revenues
are
expected
to
decline
24%.
The
estimated
net
revenue
is
estimated
to
decline
more
than
131%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
88.19
per
kilogram.

Under
alternative
2
(
1,3­
d
plus
chloropicrin),
the
yield
loss
was
estimated
to
be
14%
and
prices
by
05%,
if
growers
miss
key
market
windows.
Gross
revenue
is
expected
to
decline
16%.
The
net
revenue
is
expected
to
decline
by
more
than
87%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
58.57
per
kilogram.

Under
alternative
3
(
metam
sodium),
the
yield
loss
was
estimated
to
be
30%,
and
the
gross
revenue
loss
was
estimated
to
by
26%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
96.52
per
kilogram.

Eastern
United
States:
Under
Alternative
1
(
chloropicrin+
metam
sodium),
yield
loss
was
estimated
to
be
27%,
with
gross
revenues
decline
29%,
and
a
loss
in
estimated
net
revenue
of
67%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
99.49
per
kilogram.

Under
alternative
2
(
1,3­
d
+
chloropicrin),
the
yield
loss
was
estimated
to
be
14%,
with
gross
revenues
declining
18%,
and
net
revenues
expected
to
decline
by
42%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
62.05
per
kilogram.

Under
alternative
3
(
Metam
Sodium),
the
yield
loss
was
estimated
to
be
30%,
with
gross
revenues
declining
31%,
and
net
revenues
expected
to
decline
by
73%.
The
loss
per
kilogram
of
methyl
bromide
in
US
dollars
is
estimated
to
be
$
107.96
per
kilogram.

Note:
Market
price
data
was
not
available
for
the
Eastern
United
States
but
it
is
assumed
that
the
net
effect
of
shifting
from
methyl
bromide
to
any
of
the
alternatives
would
result
in
additional
revenue
reductions
due
fluctuations
in
market
price
due
to
changes
in
production
and
harvesting
times.

It
should
be
noted
that
the
applicants
do
not
consider
any
alternative
to
be
feasible
and
that
these
Page
47
estimates
are
an
attempt
to
measure
potential
impacts.

PART
F.
FUTURE
PLANS
23.
WHAT
ACTIONS
WILL
BE
TAKEN
TO
RAPIDLY
DEVELOP
AND
DEPLOY
ALTERNATIVES
FOR
THIS
CROP?

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
strawberry
fruit
research
will
require
2377
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.
One
example
of
the
research
is
a
field
study
testing
the
comparative
performance
of
methyl
bromide,
host
resistance,
cultural
practices,
pest
management
approaches
for
control
of
rootknot
nematodes.
Another
example
is
a
five
year
field
study
comparing
methyl
bromide
to
1,3­
D
combined
with
biologically
based
materials
including
transplant
treatments
for
control
of
weeds,
root­
knot
nematodes
and
soil
borne
fungal
pathogens.

Research
for
a
methyl
bromide
alternative
for
strawberry
production
continues
to
be
a
very
active
area
of
research.
USDA,
University
of
Florida
Institute
of
Food
and
Agricultural
Sciences,
and
the
Florida
Fruit
and
Vegetable
Association
are
currently
conducting
research
in
this
area.
Over
100
peer­
reviewed
articles
have
been
published
to
date
based
on
trials
conducted
by
the
above
groups.
Control
of
nutsedge
and
winter
annual
weeds
is
crucial
to
successful
berry
production
in
Florida.
Control
of
nutsedge
is
also
extremely
important
to
40
percent
of
the
Eastern
strawberry
production
land
where
nutsedge
is
a
problem.
In
the
near
term,
research
is
needed
to
find
a
suitable
pre­
emergent
herbicide,
or
to
find
ways
to
get
better
herbicidal
efficacy
from
currently
available
fumigants.
In
the
long
term,
efforts
should
be
continued
to
find
non­
chemical
means
to
suppress
nutsedge
damage.
Some
additional
research
to
fine­
tune
use
of
alternative
fumigants
to
maximize
efficacy
and
yield
is
also
needed.

Research
studies
submitted
with
the
critical
use
exemption
request
packages
include
trials
conducted
to
assess
the
effectiveness
of
the
most
likely
chemical
and
non­
chemical
alternatives
to
methyl
bromide,
including
some
potential
alternatives
that
are
not
currently
included
in
the
MBTOC
list.
Based
on
preliminary
results
from
research
conducted
in
this
area
and
largely
in
the
area
of
tomatoes
and
strawberries,
researchers
believe
that
a
mix
of
fumigants
together
with
an
herbicide
treatment
is
the
best
possible
alternative
to
methyl
bromide.
Combinations
of
1,3­
dichloropropene/
chloropicrin,
and
metam­
sodium/
chloropicrin
are
being
tested
for
disease
and
weed
control.
Future
research
plans
will
test
combinations
of
these
fumigants
with
chemicals
such
as
halosulfuron,
metolachlor,
and
sulfentrazone.
A
program
to
evaluate
host
resistance
to
Phytophthora
root
and
crown
rot
has
been
implemented.
Growers
are
starting
to
deploy
lines
identified
as
having
both
genetic
resistance
and
acceptable
horticultural
qualities.
Page
48
As
demonstrated
by
the
chart
and
description
below,
U.
S.
efforts
to
research
alternatives
for
methyl
bromide
have
been
substantial,
and
they
have
been
growing
in
size
as
the
phase
out
has
approached.
The
U.
S.
is
committed
to
sustaining
its
research
efforts
out
into
the
future
until
technically
and
economically
viable
alternatives
are
found
for
each
and
every
controlled
use
of
methyl
bromide.
The
U.
S.
is
also
committed
to
continuing
to
share
our
research,
and
enable
a
global
sharing
of
experience.
Toward
that
end,
for
the
past
several
years,
key
U.
S.
government
agencies
have
collaborated
with
industry
to
host
an
annual
conference
on
alternatives
to
methyl
bromide.
This
conference,
the
Methyl
Bromide
Alternatives
Outreach
(
MBAO),
has
become
the
premier
forum
for
researchers
and
others
to
discuss
scientific
findings
and
progress
in
this
field.

Methyl
Bromide
Alternatives
Research
Funding
History
Year
Amount
(
Million)

1993
US$
7.255
M
1994
US$
8.453
M
1995
US$
13.139
M
1996
US$
13.702
M
1997
US$
14.580
M
1998
US$
14.571
M
1999
US$
14.380
M
2000
US$
14.855
M
2001
US$
16.681
M
2002
US$
17.880
M
The
numerous
methyl
bromide
alternative
research
trials
that
have
been
produced
quantitative
yield
data
are
summarized
in
the
table
below.
This
table
shows
that,
even
among
studies
that
demonstrate
significant
yields
using
the
alternatives,
there
is
significant
variation
in
the
performance
of
the
alternative.
Thus,
while
a
given
alternative
may
perform
well
in
one
study,
it
may
also
perform
below
acceptable
standards
in
another
study.
The
standard
used
to
characterize
success
in
the
analysis
presented
here
is
if
the
alternative
produced
crops
with
at
least
95
percent
of
the
yield
of
the
crop
with
a
methyl
bromide
control.
However,
in
some
instances,
even
a
95
percent
yield
may
involve
some
profit
losses.

Summary
of
Research
Results
for
Methyl
Bromide
Alternatives
on
U.
S.
Strawberry.

Alternatives
Total
Number
of
Studies
Number
of
Studies
with
Yield
at
Least
95%
of
Methyl
Bromide
Basamid
(
Dazomet)
and
combinations
27
12
Chloropicrin
and
combinations
58
36
Compost
systems
11
6
Enzone
3
0
Metam
sodium
(
Vapam)
and
combinations
73
24
Page
49
Organic
production
5
1
Ozone
1
1
Solarization
and
Combinations
22
6
Tarps
3
1
Telone
(
1,3­
dichloropropene)
and
combinations
93
41
Registration
While
the
U.
S.
government's
role
to
find
alternatives
is
primarily
in
the
research
arena,
we
know
that
research
is
only
one
step
in
the
process.
As
a
consequence,
we
have
also
invested
significantly
in
efforts
to
register
alternatives,
as
well
as
efforts
to
support
technology
transfer
and
education
activities
with
the
private
sector.

The
U.
S.
has
one
of
the
most
rigorous
programs
for
ensuring
that
new
pesticides
are
safe
for
both
health
and
the
environment.
These
safeguards,
however,
come
at
a
cost
of
both
money
and
time.
It
can
take
a
new
pesticide,
or
new
pesticide
use,
several
years
to
be
registered
by
the
U.
S.
EPA.
This
is
in
addition
to
the
time
it
takes
to
perform,
draft
results,
and
deliver
the
very
large
number
of
health
and
safety
studies
that
are
required
for
registration.
Few
countries,
particularly
in
the
developing
world,
have
the
resources
to
conduct
and
review
these
studies
or
the
market
power
to
leverage
chemical
companies
to
perform
and
submit
the
necessary
data.
Thus,
U.
S.
registration
decisions
are
often
the
basis
for
other
countries'
pesticide
regulations,
which
means
that
the
benefits
from
assuring
human
and
environmental
safety
accrue
globally.

The
U.
S.
EPA
regulates
the
use
of
pesticides
under
two
major
federal
statutes:
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
both
significantly
amended
by
the
Food
Quality
Protection
Act
of
1996
(
FQPA).
Under
FIFRA,
U.
S.
EPA
registers
pesticides
provided
its
use
does
not
pose
unreasonable
adverse
effects
to
humans
or
the
environment.
Under
FFDCA,
the
U.
S.
EPA
is
responsible
for
setting
tolerances
(
maximum
permissible
residue
levels)
for
any
pesticide
used
on
food
or
animal
feed.
With
the
passage
of
FQPA,
the
U.
S.
EPA
is
required
to
establish
a
single,
health­
based
standard
for
pesticides
used
on
food
crops
and
to
determine
that
establishment
of
a
tolerance
will
result
in
a
"
reasonable
certainty
of
no
harm"
from
aggregate
exposure
to
the
pesticide.

The
process
by
which
U.
S.
EPA
examines
the
ingredients
of
a
pesticide
to
determine
if
they
are
safe
is
called
the
registration
process.
The
U.
S.
EPA
evaluates
the
pesticide
to
ensure
that
it
will
not
have
any
unreasonable
adverse
effects
on
humans,
the
environment,
and
non­
target
species.
Applicants
seeking
pesticide
registration
are
required
to
submit
a
wide
range
of
health
and
ecological
effects
toxicity
data,
environmental
fate,
residue
chemistry
and
worker/
bystander
exposure
data
and
product
chemistry
data.
A
pesticide
cannot
be
legally
used
in
the
U.
S.
if
U.
S.
EPA
has
not
registered
it,
unless
it
has
an
exemption
from
regulation
under
FIFRA.

Since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
high
Page
50
registration
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
for
all
types
of
pesticides
pending
in
its
review
process
than
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
This
review
process
takes
an
average
of
38
months
to
complete.
Additionally,
the
registrant
(
the
pesticide
applicant)
has,
in
most
cases,
spent
approximately
7­
10
years
developing
the
data
necessary
to
support
registration.

As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized.

The
U.
S.
EPA
has
also
co­
chaired
the
USDA/
EPA
Methyl
Bromide
Alternatives
Work
Group
since
1993
to
help
coordinate
research,
development
and
the
registration
of
viable
alternatives.
The
work
group
conducted
six
workshops
in
Florida
and
California
(
states
with
the
highest
use
of
methyl
bromide)
with
growers
and
researchers
to
identify
potential
alternatives,
critical
issues,
and
grower
needs
covering
the
major
methyl
bromide
dependent
crops
and
post
harvest
uses.

This
coordination
has
resulted
in
key
registration
issues
(
such
as
worker
and
bystander
exposure
through
volatilization,
township
caps,
and
drinking
water
concerns)
being
directly
addressed
through
USDA's
Agricultural
Research
Service's
US$
15
million
per
year
research
program
conducted
at
more
than
20
field
evaluation
facilities
across
the
country.
Also
U.
S.
EPA's
participation
in
the
evaluation
of
research
grant
proposals
each
year
for
USDA's
US$
2.5
million
per
year
methyl
bromide
alternatives
research
has
further
ensured
close
coordination
between
the
U.
S.
government
and
the
research
community.

Several
additional,
promising
alternatives
are
under
review
at
EPA
that
may
be
able
to
be
used
on
strawberries
in
the
future.
These
include:
iodomethane
(
methyl
iodide)
and
propargyl
bromide,
which
currently
look
very
promising
in
field
studies.
Although
iodomethane
is
chemically
similar
to
methyl
bromide,
it
photodegrades
before
it
reaches
the
stratosphere,
and
therefore
is
not
a
significant
ozone
depleter.
While
iodomethane
and
propargyl
bromide
are
not
currently
registered
for
use
as
pesticides
in
the
U.
S.,
research
on
combinations
of
pesticides
with
chemicals
like
methyl
iodide
are
also
planned.
Some
of
these
trials
will
incorporate
screening
of
strawberry
varieties
for
tolerance/
resistance
to
Phytophthora
capsici.
Again,
while
these
activities
appear
promising,
it
must
be
noted
that
concerns
about
toxicity,
drinking
water
contamination,
and
the
release
of
air
pollutants
regarding
some
alternatives
presents
another
difficulty
that
may
restrict
use
since
many
of
the
growing
regions
are
in
sensitive
areas
such
as
those
in
close
proximity
to
schools
and
homes.
Ongoing
research
on
Page
51
alternate
fumigants
is
evaluating
ways
to
reduce
emission
under
various
application
regimes
and
examining
whether
commonly
used
agrochemicals,
such
as
fertilizers
and
nitrification
inhibitors,
could
be
used
to
rapidly
degrade
soil
fumigants.
If
registration
of
iodomethane
or
propargyl
bromide
occurs
in
the
near
future,
commercial
availability
and
costs
will
be
factors
that
must
be
taken
into
consideration.

24.
HOW
DO
YOU
PLAN
TO
MINIMIZE
THE
USE
OF
METHYL
BROMIDE
FOR
THE
CRITICAL
USE
IN
THE
FUTURE?

First,
the
Eastern
region
strawberry
growers
already
apply
fumigants
in
the
strip/
bed,
and
this
accounts
for
50%
lower
methyl
bromide
(
MB)
use
compared
to
strawberry
growing
regions
(
e.
g.
CA)
using
broadcast
applications.

Second,
in
1999
the
industry
switched
to
the
67:
33
formulation
from
98:
2,
and
this
is
the
main
factor
accounting
for
the
fact
that
while
total
plasticulture
acreage
in
our
consortium
has
increased
32
percent
since
1997,
total
methyl
bromide
usage
has
decreased
from
312,236
kg
(
a.
i.)
in
1997
to
283,535
kg
(
a.
i.)
in
2002.

Third,
an
extensive
number
of
research
and
grower
trials
in
the
Eastern
Region
would
suggest
that
further
alterations
in
the
MB:
pic
formulation
offers
our
best
near
term
strategy
to
achieve
significant
reductions
in
MB
dependency
without
creating
significant
market
disruption.
Chloropicrin
is
expected
to
be
a
very
important
part
of
pest
control
practices
in
the
Eastern
Region
when
methyl
bromide
is
no
longer
available.
Either
alone
or
in
combination
with
other
materials,
chloropicrin
has
performed
well
in
research
trials,
and
two
years
of
recent
research
has
demonstrated
very
high
strawberry
yields
in
plots
treated
with
a
stand
alone
rate
of
250
lb/
acre
of
96%
chloropicrin
(
Plymouth,
2000­
2001,
and
2001­
2002).
But,
this
formulation
of
chloropicrin
is
also
a
very
objectionable
chemical
to
work
with
 
causing
severe
eye
irritation
and
potential
acute
breathing
problems.
Worker
protection
standards
must
be
high.
Because
of
very
objectionable
odor,
it
may
be
impractical
to
use
by
farmers
in
this
consortium,
most
of
whom
have
their
strawberry
pick­
your­
owns
and
ready­
pick
operations
on
the
fringe
of
urban
and
suburban
populations.
Drift
could
also
be
a
serious
problem.

Nonetheless,
we
wish
to
achieve
further
reductions
in
MB
use
in
areas
of
the
Eastern
Region
where
nutsedge
is
not
a
primary
pest
(
representing
about
60%
of
the
industry,
or
1333
ha)
by
actively
pursuing
a
change
in
formulation
to
57:
43
for
the
non­
nutsedge
areas
­­
this
one
change
can
result
in
a
9%
reduction
methyl
bromide
use
in
2005
(
Table
2).
By
2006,
it
may
be
feasible
to
use
50:
50
mixtures
Page
52
with
chloropicrin
under
plastic
mulch
beds
to
achieve
further
reductions
 
shown
in
Table
3.

Stepwise
Reductions
Proposed
for
the
Eastern
Region
(
January
2004)

Table
1.
Base
information
before
implementation
of
stepwise
reductions
Eastern
Region
(
hectares)
Year
Nutsedge
areas
=
40%
Consortium
Non­
nutsedge
areas
=
60%
of
Consortium
Total
MB
a.
i.
Application
rate
for
the
a.
i.
(
kg/
ha)
2222
2005
134,278
201,418
335,696
151
2317
2006
140,216
210,324
350,841
151
2376
2007
143,936
215,905
359,841
151
Table
2.
Reductions
for
Step
1
 
With
adoption
of
57:
43
by
non­
nutsedge
group
Eastern
Region
(
hectares)
Year
Nutsedge
areas
=
40%
Consortium
Non­
nutsedge
areas
=
60%
of
Cons.
Table
1
MB
Kg
(
a.
i.)
Adjusted
MB
Kg
(
a.
i.)
Ave.
Appl.
Rate
(
kg/
h)
2222
2005
134,278
171,356
335,696
305,634
138
2317
2006
140,216
178,932
350,841
319,148
138
2376
2007
143,936
183,680
359,841
327,616
138
Table
3.
Reductions
for
Step
1
 
With
adoption
of
50:
50
by
non­
nutsedge
group
in
2006
Eastern
Region
(
hectares)
Year
Nutsedge
areas
=
40%
Consortium
Non­
nutsedge
areas
=
60%
of
Cons.
Table
1
MB
Kg
(
a.
i.)
Adjusted
MB
Kg
(
a.
i.)
Ave.
Appl.
Rate
(
kg/
h)
2222
2005
134,278
171,356
335,696
305,634
138
2317
2006
140,216
156,958
350,841
297,174
128
2376
2007
143,936
161,122
359,841
305,058
128
Step
1
(
increasing
the
percentage
of
Pic)
can
occur
with
the
fewest
obstacles
to
implementation,
and
can
potentially
reduce
MB
use
by
9%
in
2005,
15%
in
2006
and
15%
in
2007
(
Table
3).
It
is
more
difficult
to
accomplish
comparable
reductions
in
MB
use
for
growers
in
nutsedge
regions
by
formulation
changes,
as
our
experience
has
shown
that
MB
dosages
below
30.2
g/
m2
do
not
provide
satisfactory
nutsedge
control.
Therefore,
for
growers
in
nutsedge
areas,
we
wish
to
investigate,
in
cooperation
with
VIF
or
High
Barrier
film
manufacturers,
the
potential
of
growers
in
these
areas
to
cut
MB
usage
by
at
least
1/
3rd
with
these
films.

If
VIF
or
High
Barrier
Research
and
Extension
Demonstrations
in
High
Pressure
Nutsedge
Areas
of
the
Eastern
Region
in
2004­
2005
and
2005­
2006
are
successful,
there
is
potential
in
2006
and
2007
to
significantly
reduce
methyl
bromide
use
further:
the
current
projected
amount
of
MB
a.
i.
needed
in
Eastern
Region
nutsedge
areas
for
2006
is
calculated
to
be
140,216
kg
(
350,540
x
.4),
and
this
research
has
the
potential
to
lower
this
region's
dependency
from
140,216
kg
to
93,947
kg
(
Table
4).
The
net
effect
of
implementing
steps
1
and
2
on
the
Eastern
Page
53
Region
would
be
a
28.4
%
reduction
in
2006,
and
28.4%
reduction
in
2007
(
relative
to
our
current
request),
and
a
lowering
of
the
average
application
rate
for
our
region
to
108
kg/
ha.

Table
4.
Reductions
for
Step
2
 
With
adoption
of
High
Barrier
Films
by
Nutsedge
Eastern
Region
(
hectares)
Year
Nutsedge
areas
=
40%
Consortium
Non­
nutsedge
areas
=
60%
of
Cons.
Table
1
MB
Kg
(
a.
i.)
Adjusted
MB
Kg
(
a.
i.)
Ave.
Appl.
Rate
(
kg/
h)
2222
2005
134,278
171,356
335,696
305,634
138
2317
2006
93,947
156,958
350,841
250,905
108
2376
2007
96,437
161,122
359,841
257,559
108
Page
54
25.
ADDITIONAL
COMMENTS
ON
THE
NOMINATION?

In
summary,
a
review
of
the
critical
use
exemption
criteria
in
Decision
IX/
6
demonstrates
that
the
Parties
clearly
understood
the
many
issues
that
make
methyl
bromide
distinctly
different
from
the
industrial
chemicals
previously
addressed
by
the
Parties
under
the
essential
use
process.
It
is
now
the
challenge
of
the
MBTOC,
TEAP
and
the
Parties
to
consider
the
national
submission
of
critical
use
nominations
in
the
context
of
that
criteria,
and
the
information
requirements
established
under
Decision
XIII/
11.

In
accordance
with
those
Decisions,
we
believe
that
the
U.
S.
nomination
contained
in
this
document
provides
all
of
the
information
that
has
been
requested
by
the
Parties.
On
the
basis
of
an
exhaustive
review
of
a
large,
multi­
disciplinary
team
of
sector
and
general
agricultural
experts,
we
have
determined
that
the
MBTOC
listed
potential
alternatives
for
the
strawberry
sector
are
not
currently
technically
or
economically
feasible
from
the
standpoint
of
U.
S.
strawberry
growers
covered
by
this
critical
use
exemption
nomination.
Under
certain
circumstances
in
the
absence
of
heavy
pest
pressure
and
regulatory
constraints,
1,3­
dichloropropene
with
chloropicrin,
and
possibly
also
with
metam
sodium,
may
be
economically
feasible,
and
indeed,
the
U.
S.
request
has
been
reduced
to
take
into
account
possible
use
in
areas
that
may
meet
such
ideal
circumstances.
However,
any
of
the
following
factors
would
or
could
make
the
alternatives
economically
infeasible:

 
Regulatory
constraints
such
as
township
caps,
buffer
zones,
and
karst
topology,
 
Heavy
pest
pressure
such
as
nutsedge,
 
Increasing
nematode
damage
over
time
from
not
using
methyl
bromide,
 
Phytotoxicity,
 
Variation
in
yields,
 
Time
lost
due
to
delays
in
planting,
 
Missing
early
harvests
with
high
strawberry
prices,
and
 
Less
vigorous
starter
plants
if
strawberry
nurseries
cannot
use
methyl
bromide.

We
have
demonstrated
that
we
have
and
continue
to
expend
significant
efforts
to
find
and
commercialize
alternatives,
and
that
potential
alternatives
to
the
use
of
methyl
bromide
in
strawberries
may
be
on
the
horizon.
The
registration
process,
which
is
designed
to
ensure
that
new
pesticides
do
not
pose
an
unacceptable
risk,
is
long
and
rigorous.
The
U.
S.
need
for
methyl
bromide
for
strawberries
will
be
maintained
for
the
period
being
requested.

In
addition,
significant
efforts
have
been
made
to
reduce
the
use
and
emissions
of
methyl
bromide
associated
with
strawberries.
It
is
particularly
valuable
to
note
that
the
strawberry
production
industry
in
California
has
done
a
good
job
of
integrating
more
sustainable
and
environmentally
compatible
techniques
into
their
current
production
system.
These
currently
employed
strategies
include
the
use
of
insects
for
biological
control,
and
many
techniques
that
limit
losses
to
disease
including
use
of
crop
rotation,
alternation
of
chemicals
fungicides
to
limit
resistance
buildup,
clean
tillage,
water
management
and
field
sanitation.
Unfortunately
the
continued
success
of
their
well
constructed
IPM
system
is
dependent
on
the
use
of
methyl
bromide
as
a
pre­
plant
soil
fumigant.
Initial
reductions
in
populations
of
the
entire
pest
complex
achieved
with
methyl
bromide
make
it
feasible
to
use
more
environmentally
sound
Page
55
control
measures
throughout
the
season
to
keep
reduced
pest
populations
in
check.
Without
a
replacement
capable
of
controlling
all
of
the
pests
that
methyl
bromide
controls,
the
entire
IPM
strategy
must
be
reconstructed.
Research
on
alternatives
for
this
commodity
has
been
progressive
and
productive.
There
have
been
promising
advances
towards
the
development
of
alternative
fumigants
and
application
methodologies.
The
regulatory
constraints
for
employment
of
the
currently
available
alternatives
remain
as
the
largest
obstacle
to
their
adoption
for
strawberry
production.
Page
56
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2001.
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1999.
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D.,
1999.
A
meta­
analysis
of
Strawberry
Yield
Response
to
Pre­
plant
Soil
Fumigation
with
Combinations
of
Methyl
Bromide­
chloropicrin
and
Four
Alternative
Systems.
HortScience
34:
839­
845.

California
Studies:

Ajwa,
H.
Study
conducted
from
2001
through
2003.
Iodomethane
and
Iodine
­
based
Materials
for
Strawberry
Production
in
California.
Publication
not
specified,
UC­
Davis.

Ajwa
H.,
Kabir
Z.
and
Fennimore
S.
Year
of
experiment
or
publication
not
specified.
Drip
Fumigation.
UC­
Davis.

Ajwa
H.,
Trout,
T.
Mueller
S.,
Wilhelm
S.,
Nelson
S.
D.,
Scoppe
R.
and
Shately
D.,
Application
of
Alternative
Fumigants
Through
Drip
Irrigation
Systems.
Phytopathology
92:
1349­
1355.

Browne
G.
T.,
Becherer
S.
T.,
Bhat
R.
G.
and
Lee
R.
C.
M..
2003.
Strategies
for
Management
of
Pytophthora
on
California
Strawberries.
USDA­
ARS,
Department
of
Plant
Pathology
UC
Davis,
Monterey
Bay
Academy
Field
Day.

Duniway
J.
M.,
Status
of
Chemical
Alternatives
to
Methyl
Bromide
for
Pre­
plant
Fumigation
of
Soil.
2002.
Phytopathology
92:
1337­
1343.

Duniway
J.,
Dopkins
D.
and
Hao
J.
2003.
Current
Experiments
on
Alternatives
to
Methyl
Bromide
for
Strawberry.
Published
for
the
Annual
Monterey
Bay
Academy
Field
Day.
Page
59
Fennimore
S.
A.,
and
Valdez
J.,
Study
conducted
in
2002
and
2003.
Strawberry
Herbicide
Evaluation,
Monterey
Bay
Academy.
UC­
Davis,
Publication
not
specified.

Kabir
Z.,
Fennimore
S.,
Ajwa
H.,
and
Roth
K.
Study
conducted
in
2001
and
2002.
Chloropicrin
and
InlineTM
Field
Dose­
Response
Study
Under
VIF
and
Standard
Tarp:
Weed
Biomass
and
Weeding
Time
at
Las
Cuevas,
CA.
Publication
not
stated.

Kabir
Z.,
Fennimore
S.,
Ajwa,
and
Roth
K.
Study
conducted
in
2002
and
2003.
The
Efficacy
of
Agrizide
and
Plant
Pro
Alone
or
in
Combination
with
Chloropicrin
on
Weeds
Seeds
and
Native
Weeds
at
La
Cuevas,
CA.
Publication
not
stated.

Kabir
Z.,
Fennimore
S.,
Ajwa,
and
Roth
K.
Weed
Control
Efficacy
of
Drip
and
Shank
Applied
Iodomethane:
Chloropicrin
at
MBA,
CA
2002­
3.
Publication
not
specified.

Martin
F.
N.,
Management
of
Root
Diseases
of
Strawberry.
USDA­
ARS
Publication
not
specified.

Martin
F.
N.,
Study
conducted
in
2002.
The
Use
of
Remote
Sensing
in
Strawberry
Production.
Publication
unspecified.

Martin
F.
N.,
and
Bull
D.
T.,
Biological
Approaches
for
Control
of
Root
Pathogens
of
Strawberry.
Phytopathology
92:
1356­
1362.

Noling
J.
W.
The
Practical
Realities
of
Alternatives
to
Methyl
Bromide:
Concluding
Remarks.
Presented
at
the
Methyl
Bromide
Alternatives
­
Meeting
the
Deadlines
Symposium.
2002.
Published
in
Phytopathology
92:
1373­
1375.

Subbarao
K.
V.
Methyl
Bromide
Alternatives
­
Meeting
the
Deadlines.
Presented
at
the
92nd
Annual
Meeting
of
the
American
Phytopathological
Society,
Augus
14,
2000.
Accepted
for
publication
by
the
American
Phytopathological
Society
on
23
July
2002.

Trout,
T.
and
Gartung
J.,
2003.
Irrigation
Water
Requirements
for
California
Strawberries.
Not
used,
neither
methyl
bromide
nor
alternatives
were
evaluated,
just
water
requirements.
Publication
unspecified.

Yates
S.
R.,
Gan
J.
Papiernik
S.
K.
Dungan
R.
and
Wang
D.
Reducing
Fumigant
Emissions
After
Soil
Application.
2002.
Phytopathology
92:
1344­
1348.
Page
60
APPENDIX
A.
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI).
19,486
68%

2001
&
2002
Average
%
of
2001
&
2002
Average
Requested
Hectares
%

11,109
74%
73%

not
available
not
available
not
available
2,873
94%
100%

13,982
91%
95%

Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
%
Reduction
1,086,777
5,552
196
33%

230,332
1,528
151
34%

295,853
1,600
185
49%

1,612,962
8,680
177
37%

37%
35%

2006
Low
High
Low
High
Low
High
Low
High
Low
High
Low
High
Low
HIGH
LOW
202
196
0
0
0
0
0
0
67
47
15
15
0
0
72%
55%

151
151
0
0
90
90
40
30
0
0
0
0
0
0
94%
93%

202
185
40
40
1
1
40
30
0
0
0
0
0
0
60%
55%

Strip
Bed
Treatment
Currently
Use
Alternatives?
Research
/

Transition
Plans
Tarps
/

Deep
Injection
Used
Pest­

free
Cert.

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

State
Frequency
of
Treatment
Loss
per
Hectare
(

US$/

ha)
Loss
per
Kilogram
of
MeBr
(

US$/

kg)
Loss
as
a
%

of
Gross
Revenue
Loss
as
a
%

of
Net
Revenue
No
Yes
Yes
Tarp
No
­
Yes
1/
year
10,732
$
53
$
15%
79%

Yes
Yes
Yes
Tarp
No
+
Yes
1/
year
8,661
$
47
$
14%
­
128%

Yes
Yes
Yes
Tarp
No
0
Yes
1/
year
9,319
$
62
$
18%
42%

Notes
Conversion
Units:
1
Pound
=
Kilograms
Hectare
Regional
Hectares**

Methyl
Bromide
Critical
Use
Exemption
Process
2006
Methyl
Bromide
Usage
Numerical
Index
(
BUNI)
MOST
LIKELY
IMPACT
VALUE
Date:
26­
Feb­
2004
Average
Hectares
in
the
US:

Sector:
STRAWBERRIES
%
of
Average
Hectares
Requested:

2006
Amount
of
Request
2001
&
2002
Average
Use*
Quarantine
and
Pre­
Shipment
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)
Kilograms
(
kgs)
Hectares
(
ha)
Use
Rate
(
kg/
ha)

REGION
1,632,931
8,094
202
1,601,966
8,184
196
0%

350,534
2,317
151
278,967
1,851
151
0%

2,382,379
12,747
177
579,691
2,873
202
501,446
TOTAL
OR
AVERAGE
2,563,155
13,284
185
2,711
185
0%

2006
Nomination
Options
Subtractions
from
Requested
Amounts
(
kgs)
Combined
Impacts
Adjustment
(
kgs)

0%

2006
Request
(­)
Double
Counting
(­)
Growth
or
2002
CUE
Comparison
(­)
Use
Rate
Difference
(­)
QPS
HIGH
LOW
1,632,931
­
­
48,709
­
1,140,640
871,322
350,534
­
104,977
­
­
230,823
228,368
579,691
­
32,659
45,586
­
300,868
275,795
Nomination
Amount
2,563,155
2,563,155
2,425,520
2,331,225
2,331,225
1,672,331
1,375,485
9%
35%
46%

%
Reduction
from
Initial
Request
0%
0%
5%

Use
Rate
(
kg/
ha)
(%)
Karst
Topography
(%)
100
ft
Buffer
Zones
9%

(%)
Key
Pest
Distribution
Regulatory
Issues
(%)
Unsuitable
Terrain
(%)
Cold
Soil
Temp
(%)
Combined
Impacts
(%)

Other
Considerations
Dichotomous
Variables
(
Y/
N)
Other
Issues
Economic
Analysis
CALIFORNIA
EASTERN
US
FLORIDA
1,3­
d+
pic/
Metam+
Pic
14%
Yield
Loss
1,3­
d+
pic
Quality/
Time/

Market
Window/

Yield
Loss
(%)
Marginal
Strategy
14%
Yield
Loss
Metam­
Sodium
+
Pic
*
SE
Strawberry
Consortium
(
AL,
AR,
GA,
NC,
SC,
TN,
OH,
NJ,
VA)
requested
a
greater
quantity
of
Methyl
Bromide
from
their
2002
CUE
application,
due
to
the
inclusion
of
4
new
states
(
Illinois,
Kentucky,
Louisiana,
and
Maryland)
in
the
2003
CUE
Application,

0.453592
1
Acre
=
0.404686
REGION
REGION
REGION
CALIFORNIA
EASTERN
US
FLORIDA
CALIFORNIA
EASTERN
US
FLORIDA
Adjustments
to
Requested
Amounts
CALIFORNIA
EASTERN
US
FLORIDA
14%
Yield
Loss
Page
61
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
62
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
63
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
64
APPENDIX
C.
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
65
Ozark
Country
Hams
240
Nahunta
Pork
Center
248
American
Association
of
Meat
Processors
296,800
Total
lbs
1,087,434
Total
kgs
493,252
